Get ya ROCs off!

On April 30th 2018 Resource Recovery Solutions Derbyshire Ltd (RRS) announced that their controversial waste gasification incineration plant had been granted ROCs - Renewable Obligation Certificates for the electrical energy they will produce from the biodegradable aspect of household waste which the plant will take in for burning.

Renewi one of the parent companies of RRS released a press release relating to the granting of ROCs to the Sinfin Lane, Derby project which contain quite a degree of hot air.

They stated that "Up to 98% of the residual waste managed at the facility will be diverted from landfill, which will also generate enough green electricity to power approximately 14,000 homes."

While the plant may generate enough electricity for 14,000 homes - that is yet to be shown one thing is for sure - an unconfirmed percentage of the power generated will come not from so called green electricity - which is considered by the likes of OFGEM as biodegradable wastes being combusted but in fact non biodegradable waste such as plastics - ie fossil fuels.

It is fact (confirmed via FOI/EIR) that in the city of Derby 9,000 properties have no recycling scheme in place - after Derby City Council removed the service stating recycling bin contamination as an excuse.

What this means is that a percentage of waste entering the Sinfin facility will have had no prior recycling applied to it. Paper and card should have been recycled removing it from the residual waste stream entering the Sinfin site in Derby. Instead such material is condemned to be burnt to generate OFGEM funded electricity via ROC payments - ROCs being funded from green charges applied to our energy bills.

Has recycling been removed in the city to procure suitable waste to generate lucrative ROC payments?

Someone called James Priestley said the following-

James Priestley, Managing Director of Renewi’s Municipal Division, said:

 “We are delighted to have been awarded this important ROCs accreditation which is another significant milestone achieved in this project. Not only does this accreditation bring financial support to the project, it also shows how we are using innovative technologies to operate sustainably, divert waste from landfill and create valuable products from waste. We are looking forward to completing the final stages of commissioning and to providing first class, sustainable waste services for the people of Derby and Derbyshire.”

  Now when you use the terms innovative and first class you think ground breaking and efficient and you could be forgiven for thinking this applied in the Derby projects case but the reality is somewhat different.

At the second public inquiry into the project the planning inspector required RRS to provide evidence of their projects energy efficiency status - an important aspect of the project which was a useful insight into the project.

At the second public inquiry RRS were forced to admit that

 in the plants standard electricity only mode their plant was in fact nothing more than what is known as a D10 disposal plant because the energy efficiency status of the process falls below that which would class the plant as an efficient recovery process.

 

To see what the Waste Framework Directive says about a plant being recovery R1 or disposal D10 below is a series of quotes from the directive.

Recovery or disposal – the meaning of R1

47. The Waste Framework Directive (WFD) sets out the waste hierarchy and enshrines it in law. It requires that a waste management route defined as recovery should be used ahead of an alternative that is classified as disposal. Exceptions can be made (see below) but this general principle makes it important to know whether a process is considered recovery or disposal. 

48. Historically the Waste Framework Directives have included annexes which set out lists of what are considered to be recovery or disposal operations. Each is given a number and a letter: R for recovery, D for disposal. In the current directive the classifications of particular relevance to energy from waste are: • R1 – Use principally as a fuel or other means to generate energy • D10 – Incineration on land 

49. What this means is that where waste is burnt as a fuel to generate energy it can potentially be considered a recovery operation (R1) but where the purpose of incineration is to get rid of waste, it is considered D10 and hence disposal.  All municipal waste incinerators were and are deemed as disposal activities (D10) unless and until they are shown to meet the requirements of R1. This is why the term R1 often crops up in the debate about how good an energy from waste plant might be and how it compares to other options. 

50. For municipal solid waste, which includes all the waste collected from households, the EU has gone further by defining what it considers to be sufficient for recovery status under R1. The WFD includes a formula relating to the efficiency of the combustion plant. A municipal waste combustion plant can only be considered to be a recovery operation under R1 if it generates energy and the plant meets the efficiency thresholds calculated using the R1 formula

SO THAT IS THE OFFICIAL BLURB FROM DEFRA ON RECOVERY OR DISPOSAL PLANTS AS GOVERNED BY EU DIRECTIVES - WHICH STILL GOVERN THE UK SINCE BREXIT.

Why are OFGEM supporting inefficient waste gasification incineration plants? the lure of lucrative subsidies in this case in Sinfin Derby has in part led to the route this project has taken which is condemning resources to being burnt for a small amount of energy made financially viable by government subsidy.

OFGEM are rewarding failure.

©SIMON BACON 2018

Dont put it in the recovery position !

It was a simple innocent question that I put to Resource Recovery Solutions at a meeting of the Sinfin waste incineration plants Community Liaison Group (CLG) meeting back in early 2016.

 

We were part way though a presentation by a representative of RRS / SHANKS in relation to what they teach school children they visit at schools across Derby and Derbyshire or tours the construction site with and I was feeling somewhat uneasy that the councils were paying a company that was being employed to burn vast volumes of waste to then also educate school children what we should do with waste.

So at that point I thought hey ho lets just pop a question across to the the RRS / SHANKS  just to satisfy myself that they were in fact educating school children correctly and that I was being unfair to judge them. It was at this point that a representative of RRS / SHANKS (named in the meetings official minutes) told the meeting that they told children it was a recovery plant.

WOW THERE ! WOW THERE ! now hold on just a minute ! did they say it was a RECOVERY PLANT ? really ! a RECOVERY PLANT ?

 

Now burning waste is a funny old game because doing so can be considered to be one of two things when it comes to considering the process in the waste hierarchy it is considered a disposal process unless it can prove otherwise in which case it is a recovery process.

 The waste hierarchy just for clarity is a set of processes when dealing with the whole issue of waste that must be considered as it takes in best practices to deal with waste in the most sustainable way.

It starts with REDUCTION / PREVENTION where the aim is to reduce what waste we produce so managing materials in the best way - by not using them to start with ! Then we have RE-USE which is where whenever possible we take items that are now scrap and attempt to use them again in an innovative way to keep them out of landfill and incineration. Then comes RECYCLE which is when materials at the end of their life if not reused are reprocessed into new items by making use of the products raw material make up. As we head down the hierarchy we get closer to less sustainable methods of waste management such as incineration and landfill - neither of which are good methods of waste disposal. This brings us to RECOVERY which is when those handling waste start to use wastes for energy generation such as in incineration plants which meet an efficiency target called R1. These are plants which can show that their efficiency of energy generation meets a strict target and often requires such plants to export large volumes of heat or steam to customers to meet that efficiency rating. Finally we come to DISPOSAL which includes inefficient energy generation in incineration plants and also landfill.
In a twist to things a plant that meets R1 efficiency targets is STILL a disposal plant until it is granted recovery status.

Now rather conveniently for the UK government they use a waste hierarchy image as shown below which I consider to be incorrect as it blurs the lines between recovery and disposal in the waste hierarchy by using questionable wording.

The image shown below is the image in question and is used by DEFRA in their document

Energy from Waste a Guide to the Debate dated Feb 2014
 

 

Now reviewing the image it would be very easy to be misled into thinking that any incineration plant - including gasification is recovery in the waste hierarchy if it generates energy. The image appears to imply this is the case and as this image is commonly reproduced a gross misunderstanding takes place!

It is only when you take the chance to read other areas of the document that the issue of R1 and its application are considered and at that point you realise the difference between recovery and disposal. Obviously there are some who favour this blurring as it allows them to paint a picture of a project that makes it conveniently sound better than it is.

To aid you readers below is produced a series of statements from DEFRA from the document in relation to R1 and what is known as D10 disposal.

 

Recovery or disposal – the meaning of R1

47. As described above the Waste Framework Directive (WFD) sets out the waste hierarchy and enshrines it in law. It requires that a waste management route defined as recovery should be used ahead of an alternative that is classified as disposal. Exceptions can be made (see below) but this general principle makes it important to know whether a process is considered recovery or disposal. 

48. Historically the Waste Framework Directives have included annexes which set out lists of what are considered to be recovery or disposal operations. Each is given a number and a letter: R for recovery, D for disposal. In the current directive the classifications of particular relevance to energy from waste are: • R1 – Use principally as a fuel or other means to generate energy • D10 – Incineration on land 

49. What this means is that where waste is burnt as a fuel to generate energy it can potentially be considered a recovery operation (R1) but where the purpose of incineration is to get rid of waste, it is considered D10 and hence disposal.  All municipal waste incinerators were and are deemed as disposal activities (D10) unless and until they are shown to meet the requirements of R1. This is why the term R1 often crops up in the debate about how good an energy from waste plant might be and how it compares to other options. 

50. For municipal solid waste, which includes all the waste collected from households, the EU has gone further by defining what it considers to be sufficient for recovery status under R1. The WFD includes a formula relating to the efficiency of the combustion plant. A municipal waste combustion plant can only be considered to be a recovery operation under R1 if it generates energy and the plant meets the efficiency thresholds calculated using the R1 formula

SO THAT IS THE OFFICIAL BLURB FROM DEFRA ON RECOVERY OR DISPOSAL PLANTS AS GOVERNED BY EU DIRECTIVES - WHICH STILL GOVERN THE UK SINCE BREXIT.

So returning to what the RRS / SHANKS representative said they teach students the plant is. they stated they teach students that the plant is a RECOVERY plant - which raises the issue of R1 as noted above.
When we consider R1 and the claims of the RRS / SHANKS representative we know what they are teaching children is false because at the 2nd planning inquiry the developer had to admit that their plant fails the R1 test in its standard mode.
If you tell children something that is false then in general it is usually considered a lie.
It is a lie in this case because staff employed in waste disposal and waste management will know the requirements of the waste hierarchy

 IT IS THEIR JOB.


©SIMON BACON 2016

The S.S.A.I.N press release - 22nd Aug 2014

DERBY UK 22^ND AUG 2014 – RESPONSE TO DERBY CITY AND COUNTY COUNCIL PRESS RELEASE OF 21^ST AUG 2014

 

SINFIN INEFFICIENT WASTE INCINERATION PLANT BACKED BY SO CALLED GREEN INVESTMENT BANK GETS GO AHEAD

As the recycling rate of Derby City Council enters an ever steeper decline with the implementation of a £40 garden waste tax news broke on 21^st of August that the councils of Derby and Derbyshire have reached closure on a controversial waste incineration plant to be constructed in an area of poor health and deprivation in the heart of Sinfin in the city of Derby.

Sited on an ex tannery and landfill http://derby-waste-a-rubbish-blog.blogspot.co.uk/2014_05_01_archive.html currently subject to local concern regarding anthrax site contamination risking health both on and off site the controversial waste incineration plant has been successfully delayed by campaigners concerned about health impacts from the billion cubic metres of emissions per year from the plant along with the threat of wide spread combustion in the plant of materials which could and should be recycled. This was confirmed in the recent Derbyshire County Council waste draft strategy document on page 16 where it is noted 47% of residual waste in Derbyshire is recyclable waste. http://www.derbyshire.gov.uk/images/Dealing%20with%20Derbyshires%20Waste%20Draft%20Strategy_tcm44-234569.pdf

In a bizarre twist supported by Vince Cable the UK Green Investment Bank (GIB) has agreed to invest £64 million in the project even though the plant destroys potentially recyclable material and was show at the 2^nd Derby public inquiry to be in its standard electricity only mode an inefficient waste disposal incineration plant which fails to meet the requirements of the R1 formula test of plant efficiency. It is not clear why a green investment bank would invest in such an inefficient plant. The council’s developer – Resource Recovery Solutions has at no point shown any evidence of local customer demand for heat and steam from the plant which would allow the plant to become an R1 compliant recovery facility. It therefore languishes on the bottom tier of the waste hierarchy in disposal.

The council press release implied that any recyclable materials would be extracted at the plant however no documents were put forward at either planning or at either public inquiry showing this to be the case – only that which would not burn would be extracted.

The councils of Derby and Derbyshire are very enthusiastic for the Sinfin plant to go ahead. In the case of Derbyshire County Council this is because they get their rubbish burnt on someone else’s door step and in the case of both councils they will be rewarded for procuring the correct feedstock – as shown in the waste contract with highly lucrative Renewable Obligation Certificates known as ROC’s. It is not clear why such an inefficient plant that sits at the bottom of the waste hierarchy will be rewarded for its failure to be efficient at energy generation and this opens the door for similar inefficient plants to be constructed across the UK. A legacy of the Green Investment Bank will be waste forced down the waste hierarchy with the claims of green energy and sustainable waste management while the reality is large volumes of combustion emissions will be pumped into a poor city community, resources will be destroyed and lives ruined – all in the name of green energy.

SIMON BACON

CHAIRMAN

SINFIN, SPONDON AND ALL AGAINST INCINERATION (S.S.A.I.N)

EMAIL S.S.A.I.N via ssainderby@aol.com

Twitter @ssainderby

END

©SIMON BACON 2016