Warrington Clinical Waste Treatment Centre Appeal Proposed Outline Evidence of Alan Watson

6. Renewables; Carbon Emissions and CHP

1. 
   In this section of my evidence I consider firstly the contribution to renewable energy which would be made by the proposed incinerator and then the assessment of carbon emissions including consideration of combined heat and power (‘CHP’).
   
2. 
   It is common ground that some of the energy which would be generated would be classed as renewable. There is an on-going dispute as to the proportion this represents. Examination of the climate change impacts of the proposal show that even the fossil related emissions are similar to or greater than modern gas fired power stations. Over the next twenty years as electricity generation is increasingly decarbonised the emissions of the incinerator will be very much higher than the grid average. I argue that policy requires that the biogenic emissions should be quantified and included as well as the fossil based emissions – not least as the proportion of fossil emissions in residual wastes will increase substantially with higher recycling. The consequence of these changes are that the proposed incinerator would quickly become an anachronism and thus undermine efforts both to reduce the total carbon footprint of Gloucestershire and to reduce the carbon intensity of the grid. Any approval based on the proposals as currently framed would not give the long-term contribution to renewable energy supply that is claimed; it would not deliver the carbon savings claimed by the applicant and any electricity generated would certainly not be low-carbon.
   

21.Renewables:

264. 
     It is common ground with the Appellant that the energy derived from the biogenic portion of waste is classed as renewable energy in policy terms. This is because it is based on organic carbon with a relatively short cycle time between plants growing, being used as paper, cloth or food, and then becoming waste. The incinerator can therefore reasonably be described as a waste treatment facility generating electricity – some of which is renewable.
     
265. 
     The renewable portion of the electricity exported is a function of the biogenic waste which would be incinerated at the plant. The Review of Waste Policy in England 2011⁸⁴, for example, confirms that it is “the energy generated from the biodegradable fraction” of waste which contributes “towards our renewable energy targets”.
     

The review also emphasises⁸⁵: “Our aim is to get the most energy out of genuinely residual waste, not to get the most waste into energy recovery”.

266. 
     It is not appropriate to burn waste unless it is genuinely residual. Waste should not be targeted for renewable energy via mass burn incineration for planning purposes without first assessing whether the waste can be reduced, re-used, recycled (and in the case of food waste treated by the Government’s preferred method of anaerobic digestion) and secondly determining the residual unrecyclable biomass fraction of that waste.
     
267. 
     The SOC says⁸⁶ “Approximately 14.5MW of electricity would be exported to the local distribution network, a proportion of which would be classed as renewable, with the remainder being used in the operation of the plant”.
     
268. 
     The question which must be addressed is therefore what is the biogenic carbon content of the waste which would be incinerated?
     
269. 
     The assumptions made in the application are that 56% of the waste which would be incinerated would be biogenic and therefore only c.44% of the waste is fossil based. However no evidence is presented to support this assumption and as there is no waste composition data for the commercial and industrial waste it is unlikely to be a robust estimate.
     
270. 
     Furthermore I note that the appellants claim of 56% biogenic carbon is based on the proportion by mass of the biogenic element. This is incorrect – as shown in the example below from DECC where the biogenic proportion is calculated on the basis of the energy contribution rather than the mass. This is, of course, more logical in any case. The appellants approach would mean that waste collected in wetter weather and thus with a higher moisture content in the paper and food waste would generate a higher proportion of renewable electricity than waste collected dry. In fact the opposite would be true and the wet waste would simply use more energy in boiling off water.
     
271. 
     The biogenic contribution can be considered in the light of the 2007 consultation (Department of Trade and Industry 2007) on the review of the Renewables obligation. This confirms that at least 50%, rising to 65%, of the waste that would be burned should be classed fossil fuel.
     
272. 
     The Government’s response to the Statutory Consultation on the Renewables Obligation Order 2009 (Department of Energy and Climate Change 2008) stated: “Defra’s waste policy projections suggests that removing a large proportion of recyclable materials from the residual waste stream (including, for example, high levels of food and green waste in line with the Government's aspirations) would reduce its biomass energy content to around 35% by 2020. This is illustrated by the scenarios in Annex E, which suggest that high rates of recycling could result in residual biomass energy content in the range 30–38%”:
     

273. 
     I note that the consultations calculations calculates the energy contribution on the basis of the gross calorific value⁸⁷ – a more robust approach would be to use net calorific value to better reflect the quite large proportion of energy from biogenic waste which simply boils the water from the waste in any case. The consultation and response clearly shows, however, that the Government’s approach is based on the energy contribution rather than the mass and that biogenic carbon proportions in the waste are likely to fall with the removal of the recyclables that the Government envisaged being recycled.
     
274. 
     The waste composition used by the appellant for the calculation of the 55% biogenic level appears to be that included in the Ramboll WRATE assessment:
     

275. 
     When these compositions are substituted into the DECC calculation then (even using GCV) the contribution to the CV from the biogenic elements are:
     

WCA Waste	HRC Waste	3rd Party Waste
49.07%	34.78%	48.91%

1. 
   The weighted average for the waste claimed by the appellant would therefore be 47.8%. This would be likely to fall still further with increased recycling or with a higher proportion of HRC or 3rd Party wastes. It would also be lower if the calculation was based on NCV rather than GCV.
   
2. 
   In January 2008 the Government said⁸⁸ : “Deeming the biomass fraction of waste: we will proceed with the introduction of deeming, but will begin with a lower deemed level of 50% fossil fuel energy content that will increase over time to 65% following a trajectory in line with the Government’s waste policy”⁸⁹.
   
3. 
   But warned: “Ofgem will be given powers to withhold ROCs for mixed waste streams where there is reasonable doubt that the biomass energy content reaches the deemed level. This is consistent with the approach currently used under the scheme for issuing Climate Change Levy Exemption Certificates. It should be noted that lowering the deemed level of fossil-fuel energy from 65% to 50% is likely to increase the risk for some stations that a test of reasonable doubt will be met”.
   
4. 
   I conclude that whilst some renewable energy would be produced by the incinerator the proportion of renewable energy would be at least 15% lower than claimed by the appellant and that the proportion is likely to decrease further over the next decade or so even without the ban on biodegradable waste proposed by the European Parliament and discussed above.
   

22.Accounting for Biogenic Carbon:

280. 
     The general approach throughout the application has been to ignore the emissions arising from the biogenic carbon. The Appellants response⁹⁰ to a question from GlosVAIN about this was that: “In accordance with international guidance (e.g. IPCC), the WRATE model considers biogenic CO2 as climate neutral” and “Due to above mentioned guidelines it not appropriate to add biogenic CO2 releases to the non- biogenic CO2 releases”.
     
281. 
     No source or reference was given for this statement.
     
282. 
     In fact the Intergovernmental Panel on Climate Change says⁹¹: “if incineration of waste is used for energy purposes, both fossil and biogenic CO₂ emissions should be estimated. Only fossil CO₂ should be included in national emissions under Energy Sector while biogenic CO₂ should be reported as an information item also in the Energy Sector”.
     
283. 
     IPCC continues: “Moreover, if combustion, or any other factor, is causing long term decline in the total carbon embodied in living biomass (e.g., forests), this net release of carbon should be evident in the calculation of CO₂ emissions described in the Agriculture, Forestry and Other Land Use (AFOLU) Volume of the 2006 Guidelines”.
     
284. 
     Eunomia report⁹² “Brief discussions with IPCC suggest that they believe that the issue of biogenic carbon is effectively dealt with through the reporting under the Land Use, Land-Use Change and Forestry (LULUCF) sector”. He comments “The approach used here is to use stock changes to estimate emissions. In theory, IPCC has suggested (in a private communication) that this is meant to include not just uptake of CO₂ by crops and forests etc but also, the release of CO₂ after use as food, fuel or from waste disposal. Perhaps unsurprisingly – neither incinerators nor landfills obviously look like something which registers under ‘Land-use Change and Forestry’ – these do not seem to be reported. We believe this is a potentially significant omission”.
     
285. 
     It appears, therefore, that the claim made by the appellants in relation to the need to report is incorrect but because of the confusing approach adopted by IPCC under-reporting is widespread.
     
286. 
     Whether carbon neutral or not the biogenic carbon should be reported and not ignored as in this application. Whilst the cycle time is relatively short compared with that of carbon in fossil fuels biogenic carbon is still important for the management of climate change. How we treat these carbon emissions as a molecule of carbon dioxide has the same impact on the atmosphere whether derived from fossil or biogenic sources.
     
287. 
     In general the longer that carbon can be sequestered – held without releasing it to the atmosphere – the better. This is particularly true at present where we are struggling to control atmospheric carbon dioxide levels in an attempt to avert the possibility of runaway climate change. Sequestering carbon so that it is ultimately released only slowly and in the future makes sense if we anticipate that overall carbon releases are to be reduced or to fall. It is therefore important that we measure and, so far as possible, control biogenic carbon releases as well as those from fossil sources.
     
288. 
     That this is the appropriate approach has recently been confirmed in a strongly worded editorial by Ari Rabl in the International Journal of Life Cycle Assessment⁹³: “In a part of the LCA community, a special convention has been established according to which CO₂ emissions need not be counted if emitted by biomass. For example, many studies on waste incineration do not take into account CO₂ from biomass within the incinerated waste, arguing that the creation of biomass has removed as much CO₂ as is emitted during its combustion”.
     
289. 
     Rabl comments: “The logic of such a practice would imply absurd conclusions, e.g. that the CO2 emitted by burning a tropical forest, if not counted, would equalize the climate impact of burning a forest and preserving it, which is obviously wrong. Likewise, the benefit of adding carbon capture and sequestration (CCS) to a biomass fuelled power plant would not be evaluated because that CO₂ is totally omitted from the analysis.
     
290. 
     Rabl concludes: “By explicitly counting CO₂ at each stage, the analysis is consistent with the 'polluter pays' principle and the Kyoto rules which imply that each greenhouse gas contribution (positive or negative) should be allocated to the causing agent”.
     

Energy intensity of Electricity including biogenic carbon

291. 
     The only place in the documents in which the full carbon effects have been included appear to be in the emission factors calculated by the Environment Agency and included in the decision document⁹⁴.
     
292. 
     These calculations assume that the plant will burn 190,000 tpa of waste and produce 45,000 tpa of bottom ash. The Environment Agency say the Applicant has assumed that the carbon content of the waste is 26% and, conservatively in terms of emissions, that the residual carbon content of the bottom ash can be up to 3%. Thus the net carbon content consumed by combustion would be 48,050 tonnes resulting in a total CO₂ release of 176,183 tonnes per annum.
     
293. 
     Overall the emissions of CO₂ are estimated as follows:-
     

Burning of Waste	176,183
Burning of Auxiliary Fuel	1,600
Electricity Imported	250
Nitrous Oxide (CO2 equivalent)	900
Total	178,933 tonnes

294. 
     On the credit side is the CO₂ saved from the export of 116,000 MWh electricity to the public supply which displaces the burning of virgin fuels
     
295. 
     The Environment Agency assumes a generous 0.398 tonnes per MWh for this displaced electricity which gives a credit for the exported electricity of - 46,214 tonnes.
     
296. 
     The net emissions from the incinerator would therefore be at least the equivalent of 132,719 tonnes of CO₂.
     
297. 
     With exports of 116,000 MWh this is the equivalent of 1.14 kg CO₂/kWh.
     
298. 
     Taking the appellants claimed breakdown of the waste to include 56% biogenic carbon then the emissions associated with the fossil carbon would still be 503 g CO₂/kWh.
     
299. 
     The Environment Agency notes that this incinerator does well compared with the range of emissions in the guidance and says: “The Applicant’s assessment shows that the GWP of the plant is dominated by the emissions of carbon dioxide that result from the combustion of the waste input to the plant, and this will be the same for all thermal treatment technologies”. This is true but the difference is that incinerators are far less efficient than the other thermal electricity generators and so the displaced electricity benefits are very small.
     
300. 
     Some of the important assumptions made in this calculation are quite conservative in terms of emissions. Assuming 3% residual carbon in ash, for example, is very high level of residual carbon which would not normally be expected from a modern grate incinerator. Better burn-out of the ash would lead to even higher carbon emissions.
     
301. 
     Furthermore the displaced carbon emissions from the grid are reasonable for today but will reduce by about 50% by 2010 by about 75% by 2030. This will have the effect of making the incinerator far more carbon intensive than is currently the case.
     
302. 
     A carbon credit for displaced electricity of just 100 g CO₂/kWh by 2030, for example, would mean the offset would be reduced to only 11,600 tonnes. The net carbon emissions from the incinerator will be 167143 tonnes and the carbon intensity of generation would be 1.44 kg CO₂/kWh.
     
303. 
     The conclusion that can be drawn from this is that when properly assessed the Javelin Park incinerator would be a high carbon generator.
     

Contribution to Regional and National Renewable Electricity Supply

304. 
     It is suggested by the Appellant that the proposed incinerator would make a significant contribution to renewable electricity supply. It is not, however, sensible to consider the contribution based just on Gloucestershire. Regional provision is more relevant in order to allow for the distribution of facilities where natural resources like wind are more appropriate.
     
305. 
     The DECC planning database indicates that the current operational capacity of renewable energy in the south-west is approximately 538MW with a further 1,221 MW approved and currently awaiting construction giving a total approved capacity of 1,759MW. Applications for a further 614 MW of capacity have been submitted.
     
306. 
     The c. 8.1 MW of renewable energy claimed by the appellant therefore would add just 0.45% to the existing approved capacity of renewable energy in the South-West and 0.34% of the total renewable energy capacity when that currently being determined is included.
     
307. 
     Nationally RESTATS shows that there was 15,741 MW operational in 2012 with a further 3,106 MW which has become operational between January and August 2013 - a total of 18,847 MW. There is a total of 17,996 MW of capacity which has been consented and is either under construction or awaiting construction. The proposed Javelin Park incinerator would therefore represent an increase in the approved capacity of 8.1/36,843 = 0.022% of the operational or approved capacity. The additional capacity vanishes to practical insignificance when taken as a percentage of the nationally operating, approved and pre-consented applications.
     

23.Carbon Emissions

308. 
     Waste Strategy 2007⁹⁵ shows that whilst recycling makes a strong positive contribution to reducing climate change impacts, energy from waste is, at best, very slightly positive:
     

309. 
     It can be seen that recycling gives positive benefits in terms of greenhouse gases in every case whilst incineration is effectively considered carbon neutral. Clearly the ‘opportunity cost’ of incineration in circumstances where recyclable material is burned would include the lost benefits associated with recycling.
     
310. 
     Waste Strategy 2007 also includes a helpful comparison of the carbon benefits of diverting wastes from landfill. The assessments of the best treatment options made by DEFRA are that paper and card, textiles, plastics, metals and glass are recycled; food waste is anaerobically digested, and garden/plant waste is composted. Only wood is incinerated with energy recovery. The WRATE waste composition assessment indicates 0% for the proportion of wood in the waste stream and infers that no wood is to be burned in the Javelin Park plant. This may be because the waste composition has been aggregated to suit the constraints of WRATE but the demand for waste wood from reprocessors and for dedicated bioenergy has increased enormously over the past five years or so to the point where much of the wood supply now has a negative gate fee. It would therefore be unrealistic to assume that any wood waste would be available for this facility from either MSW or C&I waste streams.
     

Would the proposed incinerator be a ‘Low Carbon’ source of electricity?

311. 
     The non-technical publication by DEFRA “Energy from Waste - A Guide to the Debate”⁹⁶ says that EfW plants provide valuable low carbon energy. The purpose of that guide, however, is to: “provide a starting point for discussions about the role energy from waste might have in managing waste”. It cannot be relied upon for any definitive information on the question of low-carbon generation.
     
312. 
     Low carbon technologies are those that can help reduce emissions compared to conventional use of fossil fuels. It would be self-defeating and inconsistent with the Government’s approach to low carbon energy to include options which produce more carbon than conventional fossil fuel power stations.
     
313. 
     The most recent fuel mix disclosure tables includes the following emission factors:
     

Electricity Generator	DECC
Coal fired power stations	910
Combined Cycle Gas Turbines (CCGT)	390
Renewables	0
UK ‘Average Mix’ 2012/13	470

314. 
     By comparison I have shown that allowing for displaced electricity the Javelin Park incinerator has a total emission factor of 1,140 g CO₂/kWh of which at least 503 g CO₂/kWh is fossil derived. Without displacement, as is appropriate for the comparisons here, the Javelin Park proposal would have a total emission factor of 1,540 g CO₂/kWh of which at least 679 g CO₂/kWh is fossil derived.
     
315. 
     There is no sensible way in which a generator with this level of emissions can be described as producing low carbon electricity when compared with even the current fuel mix. The lacuna between the Javelin Park proposal and low carbon generation is even more clear when comparison is made with the summary of international carbon footprints for low-carbon electricity recently published by the Houses of Parliament’s Parliamentary Office of Science and Technology⁹⁷:
     

316. 
     It is notable that waste is excluded from the examples of low carbon generation and that the report comments that: “the significant diversity of bioenergy options and methods of production gives rise to wide variation in carbon footprints, and researchers emphasise the need for location-specific assessments”. Because of this and “the scarcity of UK-specific, peer-reviewed studies”, bioenergy is excluded from the figure giving examples of low carbon technologies.
     
317. 
     It can clearly be seen, however, that the median carbon intensity for these technologies is all well below 100 gCO₂ per kWh and even the extreme outliers are below 175 gCO₂ per kWh.
     
318. 
     The Climate Change Act 2008 incorporated the targets suggested by the Committee on Climate Change and requires that greenhouse gas emission reductions through action in the UK and abroad of at least 80% by 2050, with reductions in CO₂ emissions of at least 26% by 2020, against a 1990 baseline. Implementation of the Act will mean that energy and particularly electricity generation needs to be very significantly ‘decarbonised’ over the coming decades. As this happens the benefit from energy generation from waste, in climate change terms, even if biogenic carbon is ignored will rapidly turn negative. In the meantime, the marginal new sources will have to have a carbon intensity which, on average, declines rapidly over time. Therefore practically the worst thing that could be done with waste – looking to 2050 and the Government’s targets – is to burn waste containing plastics, or any other fossil carbon, at the low efficiencies of the proposed incinerator. Whilst the current climate performance of energy from waste is poor the technology will become an increasing liability over the coming years.
     
319. 
     DECC’s projections for overall emissions intensity of electricity generation through to 2030 are⁹⁸:
     

320. 
     This shows a fall to less than 200 gCO₂ per kWh by 2020 and a target of 100 gCO₂ per kWh by 2020. Any generation source with a higher energy intensity than these levels will make the targets harder to achieve.
     
321. 
     The most modern coal fired power stations are capable of generating at about 700-800 g CO₂/kWh when using integrated gasification combined cycle ‘IGCC ‘ and this can be reduced to below 100g CO₂/kWh with carbon capture. It can be seen from the figure that after about 2026 the only coal feeding the grid will be those carbon capture stations.
     
322. 
     The consequence is that the proposed incinerator produces more fossil based carbon dioxide (and far more total carbon dioxide) than the current average mix of electricity supply; much more fossil carbon dioxide than combined cycle gas turbine (CCGT) power stations and far more total carbon dioxide than even coal fired power stations. It is irrational to class such a high carbon emitters as a “low carbon” supply of electricity – particularly when considering future emission scenarios.
     

The Climate Change Assessment supporting the Application:

323. 
     The Appellants included an assessment of the Global Warming Potential of the proposed incinerator by consultants Ramboll as part of the Environmental Statement⁹⁹. This assessment used the Environment Agency's Waste and Resources Assessment Tool for the Environment (‘WRATE’) and claims that managing waste at the facility would result in a net annual reduction of 40,480 tonnes of CO₂ equivalent per annum:
     

324. 
     The WRATE assessment by Ramboll compared incineration only with landfill and did not include any comparators with alternative treatments. It can be seen from the output that the vast majority of these savings relate to the displacement of waste from landfill. This is not a helpful or realistic scenario as by 2020 it is certain that more waste will be diverted from landfill whether the incinerator goes ahead of not. Even with the very positive national position on progress towards the Landfill Directive targets Gloucestershire will still more towards or exceed the Directive’s targets locally via increased recycling, MBT or AD, not least because of the high cost of landfill due to the landfill tax, and so the positive credits for incineration by comparison with ‘business as usual landfill’ are purely fictitious and highly misleading.
     
325. 
     A more complete breakdown was given later in response to questions from GlosVAIN¹⁰⁰:
     

1. 
   This shows that the most significant aspect was the high credit given for recycling by the incinerator. This is certainly anomalous as whilst ferrous and some non-ferrous metals can be recovered post incineration they are low grade and heavily alloyed. My understanding is that WRATE treats all recovered material as being of the same standard, however, and does not take into account the additional energy inputs required to recover more heavily contaminated material.
   
2. 
   There are a number of concerns in relation to this assessment, however, and whilst GlosVAIN has repeatedly sought further information from the appellant in order to clarify the uncertainties associated with the modelling the responses have not been particularly helpful or illuminating. These are listed below.
   
3. 
   Firstly however it is interesting to compare the claimed emissions in this WRATE model with those calculated by the Environment Agency and included in the decision document outlined above¹⁰¹ which shows that the incinerator would emit the equivalent of 132,719 tonnes of CO₂/year even after allowing for displaced electricity.
   
4. 
   Key additional concerns include:
   

• 
  The WRATE modelling is based only against a baseline of continued reliance on landfill and not does not include comparisons with more sustainable options.
  
• 
  The savings predicted by WRATE are very sensitive to the assumptions fed into the model – particularly in the case of comparisons with landfill sites with the waste composition analysis and the assumed leakage rates for methane. Contrary to good practice the assumptions made are not declared by Ramboll.
  
• 
  No comparison is included for scenarios including CHP to help establish what additional benefits would be gained.
  
• 
  The high assumptions for the recycling of ferrous and non-ferrous materials.
  
• 
  The waste composition analysis upon which the model outputs depend are out of date and inaccurate for MSW and unsupported by any evidence base in the case of C&I waste.
  

330. 
     As the Ramboll analysis did not cover technical options other than that proposed and in the absence of evidence comparing the chosen option with the others that were evaluated as part of the Council’s Waste Strategy development, even without the other deficiencies in the modelling, the analysis is of limited value as a demonstration of the sustainability of the proposal.
     
331. 
     The savings predicted by WRATE are sensitive to the assumptions fed into the model – particularly in the case of comparisons with landfill sites with the assumed leakage rates for methane. The latest progress report from the Climate Change Commission to Parliament¹⁰² notes that biodegradable waste sent to landfill has decreased by over 60% since 1990 and that methane capture rates are assumed by the National Atmospheric Emissions Inventory are 75%. A further 10% methane oxidation is also expected in the landfill cap. It is clear from the trends with methane capture and the reduction in biodegradable waste being sent to landfill that these higher capture values should be used and that the situation will be very different by 2020 in case :
     

332. 
     The results of this WRATE assessment cannot be considered reliable or useful to inform the planning decision.
     

Displaced Electricity:

333. 
     It has been well documented in the scientific literature that the assumptions made about the electricity supply displaced by an incinerator are perhaps the most critical aspects of modelling the benefits – or dis-benefits – of electricity generation the more ‘dirty’ in climate change or emission terms the displaced electricity the better the incinerator looks in the comparison.
     
334. 
     The Government’s advice on the displaced electricity to use is that it is appropriate to use the displaced emissions from the long run marginal electricity projections. The DECC guidance¹⁰³ states: “ 3.15 For grid electricity there are different types of power plant generating electricity, each with different emissions factors. This mix varies over time, which means that emissions factors will also vary. Analysts should use the (long run) marginal grid electricity emissions factors in table 1 of the supporting tables when estimating the impacts on GHG emissions from changes in grid electricity consumption”. Whilst this guidance has been repeated in the recently published guidance it was Government guidance at the time Ramboll prepared the WRATE assessment (having replaced the previous guidance that the emissions associated with new CCGT capacity should be used. It is not clear why Ramboll did not follow the Government’s advice.
     
335. 
     Instead Ramboll used an electricity mix based on “the marginal fuel mix in UK 2020” and this was illustrated in their table 7:
     

336. 
     The fact that the UK2020 mix is “a standard value within WRATE” is irrelevant to the proper application of the model in the light of the DECC and Treasury guidelines. Although Ramboll do not say in their report supporting the planning application what the energy intensity of their fuel mix would be this is included in their otherwise similar report to the Environment Agency as part of the Environmental Permit Application as 0.677 t of carbon dioxide equivalent per MWh of power generated i.e. 0.67 kg CO₂/kWh.
     
337. 
     The long run marginal grid emission factors for 2020, the year modelled, is 0.26 kg CO₂/kWh – just 38% of the very high emission factor used by Ramboll and the differences in the outcome from using the appropriate factor, with an additional 0.41 kg CO₂/kWh emissions from the incinerator, are very large: Total power generation is claimed to be approximately:
     

17.4 x 8,000 = 139,200 MWh

338. 
     Therefore the additional carbon dioxide released each year equals:
     

0.41 x 139,000 = 57,072 tonnes

1. 
   As the savings claimed for the incinerator in the WRATE assessment are 40,480 tonnes CO₂ equivalent then this is clearly a very significant difference.
   
2. 
   Furthermore as time passes the long run marginal grid emission factor gets smaller reflecting the transition to genuinely low carbon electricity generation – and by 2030 falls to just 0.093 kg CO₂/kWh in line with the DECC trajectory for decarbonisation.
   
3. 
   It is therefore concluded that using the correct input data would make an enormous difference to the results of the WRATE assessment carried out by Ramboll and that this cannot be relied upon to demonstrate any saving in carbon dioxide emissions.
   
4. 
   The fall means that AD and even landfill gas, which are 100% biogenic and therefore renewable, electricity become more attractive than incineration which relies so heavily on the fossil element of the plastics with emissions exacerbated by the inherently low (<22.7%) efficiency of the boilers.