SITA incinerator plans Presentation to Cornwall County Council 17 th September 2008

Objections/issues/concerns 1. Non compliance with the waste hierarchy 2. Non-compliance with National Waste Strategy 3. Non compliance with PPS 1 Planning and Climate Change supplement 4. BPEO and Wastes Local Plan on which application is based is flawed 5. Lack of need for centralised incinerator

1. Waste Hierarchy Source: Defra, 2008

1 The proposed incinerator is below the cut-off point for classification as “recovery” Waste Incineration Directive formula for "efficiency“ energy produced - energy from fuels used - other energy imports X 0.97 (waste energy input + energy from fuels) X 2.6 for electricity produced X 1.1 for heat produced Total efficiency 57% Limit for consents % Therefore application is for Disposal not Recovery

2. National Waste Strategy 2007 National targets for local authorities  recycling and composting of household waste: 40% by 2010, 45% by % by 2020;  recovery of municipal waste: 53% by 2010, 67% by % by 2020.

Local targets with incinerator  recycling and composting of household waste :  recovery of municipal waste : yearNationalCornwall %31% %47% %47% yearNationalCornwall %31% %47% %47% o Non compliant with Waste Strategy 2007

3. PPS 1 : Planning and Climate Change Supplement  “planning authorities should have regard to this PPS as a material consideration which may supersede the policies in the development plan” To meet PPS1 requirements …. the proposal should at the very least provide a reduction in carbon emissions compared to the present situation”

Flawed calculation by Sita on CO 2  Incinerator vs. Landfill 1. Uses incorrect figure for carbon saved from electricity produced 2. Does not compare carbon on the same basis for the two options 3. Their transport calculation ignores lorry return journeys

GHG conversion figures The 524g CO2/kWh used is incorrect for replaced fossil electricity Defra clearly state that this figure should only be used for short term measures. eg low energy light bulbs The figure of 430 g/kWh for long term is a more representative figure ………. When calculating emissions reductions based on long term investment decisions …companies should use this factor. ie Sita overstate savings on this by 22% Source: Guidelines to Defra's GHG conversion factors for company reporting, 2007

Emission source tpa CO2eIncineratorLandfill Emissions190,47448,593 Avoided emissions Total avoided72,372120,544 Net emissions118,10213,768 Incinerator worse by104,334 However Sita say-36,61149,070 Sita say incin better by85,700 Comparison of GHG emissions for incinerator & landfill options, calculated on an equal treatment basis Incinerator worse by 4.75 million tonnes CO2e over 25 years

GHG emissions conclusion Incinerator worse by 4.75 million tonnes CO2e over 25 years ie 190,000 tpa CO2 or Four times CO2 emissions from all CCC activities or 14% of Cornwall’s travel CO2 Saying yes to the incinerator says no to all climate change policies

4. BPEO and Waste Local Plan WLP based on BPEO Inspector passed WLP in 2002 as the Waste Strategy promised. Not yet prepared: therefore no major push for recycling Example error in BPEO : Anaerobic Digester option:  Major flaw in the BPEO report reduces income from AD plant by three quarters  Assumptions invalidate the positive environmental credentials of AD for 10 factors by times  2 nd BPEO report in 2001 enabled CCC to ignore major potential for AD  errors in this BPEO so bad government changed the methodology to SA

5. The lack of need for a centralised incinerator  The case for the incinerator is based on the BPEO  flawed document  Transport analyses show little difference in the amount of travel required to feed 1, 2 and 5 incinerators  wrong 400,000 miles pa lower for 3 plant  The 5 sites option is based on all 5 being the same size requiring extra waste trucking  poor choice of option (deliberate?)  ERM 2008 facilities analysis is biased to the single incinerator and hence reaches invalid conclusions  based on inaccurate key assumptions

5. The lack of need for a centralised incinerator Sita are now progressing small plant e.g. planning application submitted for 60,000 tpa oscillating kiln w-t-e plant to Telford and Wrekin Council  cleaner technology (could be better)  smaller footprint  higher capital cost, but faster build, saves LATS

A more sustainable way forward Three local sustainable technology sites better :- Transport savings of £3.6m pa 400,000+ lorry miles pa saved Increased local heat sales so GHG savings > 20k+ tpa Reduced local objections by providing local benefits (employment and heat) reduces the health impacts at St Dennis, a material consideration for planning.  Total increased GHG savings of 22,000 t CO2 pa

A more sustainable way forward Local waste treatment using sustainable technologies ensures: local choices of suitable technology eg AD, MBT, etc local responsibility local respect local employment lower pollution lower transport impacts quicker build 1-3 years not 4-5 years more flexibility in changing times

A more sustainable way forward Example gasification plant for 275,000 people

Comparing options £m IncinDecentralised GasificationMBT + compost MBT + AD Capital costs Op costs pa Income pa Net income pa Tax/LATS Total net costs to Savings over incin to

Conclusions  five major policy reasons to refuse  saying yes to the incinerator says no to all climate change policies  the decentralised options are cheaper for the Council so cost concerns can be discounted  developing a decentralised Waste Strategy first will reap dividends in local acceptance