In a campaign guide for environmental groups looking to influence policy makers as they work towards transposing the legislation nationally by December 12 2010, the body argues that this proves that the main aim of energy-from-waste facilities is not to produce energy.
If we want the incineration industry to be considered as energy production then it should be considered as stringently as other energy production
Stephane Arditi, waste policy officer, EEB
And, the EEB also attacked the fact that the formula used to calculate whether a facility can be classed as 'recovery' did not differentiate between whether it produced electricity or heat – despite heat being more efficient than electricity production – saying that more should be done to promote district heating as an option.
The 'Campaign Guide to the Waste Framework Directive transposition – opportunities and actions for NGOs', aims to outline the key aspects of the legislation and how its represent opportunities for groups in relation to areas such as incineration, reuse and waste prevention.
Hierarchy
Under the revised Waste Framework Directive, there are now five stages to the waste hierarchy: disposal; recovery – including 'efficient' energy recovery; recycling; reuse; and, prevention, with a new statutory requirement for countries to apply it to their waste policies.
However, the Directive also allows operation to be considered outside the hierarchy if the environmental benefits of a facility can be proved using a lifecycle assessment.
And, this was also highlighted as an issue by Stephane Arditi, policy officer for waste at the EEB, who claimed that it had “opened the door” for incinerators. “There are now a lot of lifecycle assessments pointing out that energy recovery is better for the environment than recycling activities,” he told letsrecycle.com.
In terms of the 'R1 formula' which will be used to calculate whether incinerators are 'efficient' and can therefore be classed as a recovery operation, the EEB claims that, by allowing incinerators to move up the hierarchy with only 65% of the efficiency of other energy sources, “it is remarkable that this calculation allows reclassifying some incinerators that only produce electricity with an energy efficiency” of “24.7%”.
It compares this to the average energy efficiency of power plants like coal, gas and hydroelectric which, it says, is 38%.
Mr Arditi explained that: ” If we want the incineration industry to be considered as energy production then it should be considered as stringently as other energy production.”
He also pointed towards ways in which facilities might try make it easier to meet the energy efficiency requirements, such as underestimating the energy content of the waste, which, he said “means they underestimate the energy content that will make it easier for them to meet the energy efficiency.”
And, he took issue with facilities considering all the energy they produce an output, rather than just the electricity and heat that could be sent to the network – i.e. the National Grid – as contributing towards any calculations.
“That which is used in the facility should not be considered as an outcome,” he said. “If there was no incinerator there would be no office to heat or no office to maintain. This should not be considered as an output.
Heat
The EEB has stressed that it does not support incineration, but Mr Arditi explained that, if the process was used, it was best to maximise the heat from it by connecting facilities to district heating.
“We do not promote incineration but if we have to deal with it we are realistic, we can't say 'close every energy generation facility today'. If we have to incinerate, try to couple it with district heating,” he said.
As well as the increased energy efficiency of generating heat, he added: “If we maximise heating recovery then that means you have integrated the facility in the urban landscape so have probably paid more attention to emissions.”
Valid
The EEB has said that, with the formula in place, it was not in a position to argue whether or not it is valid, but Mr Arditi explained that it wanted to make sure the formula was “properly implemented”.
In particular, he said: “We need to have a formula that is applied all over Europe to make sure we have a got a standard and because there is a risk of waste for internal shipment in the internal market.”
Targets
Elsewhere in the campaign guide, the EEB states that the final Directive is “extremely disappointing”.
However, it adds that: “Despite the limitations of the WFD, there is sufficient scope within the proposed provisions on waste prevention, re-use, recycling and end-of-waste criteria for strong advocacy by EEB member groups to maximise the potential of action further up the hierarchy.”
In particular, it highlights the fact that the recycling targets set in the Directive are minimum goals, explaining that groups should “maintain momentum with Member State Government to be more ambitious than the minimum targets set out in the WFD”.
And, it also calls for a push for specific targets for both waste prevention and reuse, as well as vigilance from groups to make sure that the requirements of the Directive are enforced.
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