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

24.Combined Heat and Power (‘CHP’):

343. 
     WRATE Assessment for 2008XX.The proposed incinerator at Javelin Park would be capable of exporting heat produced through the waste combustion process and is described as 'CHP- ready'. The Environment Agency’s Decision Document¹⁰⁴ says the design “incorporates heat export capability of up to 10 MW as low pressure steam/ hot water” yet no heat user has been identified and the application does not include provision of necessary infrastructure apart from fitting the steam turbine with steam extraction points¹⁰⁵.
     
344. 
     The Appellant confirms the County Council made it clear to selected preferred bidders for the residual waste management contract that despite selecting EfW with CHP as the 'reference technology', none of the 5 shortlisted technologies (EfW with CHP; mechanical-biological treatment (MBT) producing a fuel to power dedicated CHP; MBT producing a biologically stabilised material that is sent to landfill; autoclave producing an active fibre fuel that is sent to power dedicated CHP; and advanced thermal treatment with syngas used for electricity production and recovery of heat) were deemed to be superior to any of the others.
     
345. 
     A 2008 report by Consultants Entec¹⁰⁶ for GCC reviewed these options using WRATE and this showed that the electricity only option performed badly against the alternatives – and much worse than those with CHP:
     

346. 
     This is presumably one reason GCC dropped EFW without CHP from their shortlist.
     
347. 
     The appeal proposal is, however, EfW without CHP. It is common ground that this is inferior to EfW with CHP - and hence to the other shortlisted technologies. The GlosVAIN evidence will show that these superior technologies, together with options even higher up the waste hierarchy would be more sustainable than EfW without CHP, more closely aligned with the Development Pan and would better discharge the obligations arising from the Waste Framework Directive, the National Waste Strategy and the Waste (England and Wales) Regulations.
     
348. 
     Incinerators are particularly inefficient generators of electricity. This can be improved by operation as combined heat and power (“CHP”) plants but, if this is to be meaningful and effective, this requires a large heat load. Only in those circumstances, as can be seen below, is incineration likely to be notably better than landfill.
     
349. 
     The Waste Incineration Directive¹⁰⁷ says:
     

Article 4 (2)(b):

(b) the heat generated during the incineration and co-incineration process is recovered as far as practicable e.g. through combined heat and power, the generating of process steam or district heating;

Article 6 (6):

6. Any heat generated by the incineration or the co-incineration process shall be recovered as far as practicable.

350. 
     Whilst the Environment Agency is the body normally responsible for implementing the “Waste Incineration (England and Wales) Regulations 2002” the locational requirements for CHP can only be secured at the planning stage and should be addressed as part of this application.
     
351. 
     UBB effectively claim that all that needs to be done is to consider the potential for CHP. This must be considered as an unsatisfactory response to the legal obligations arising from the WID – particularly with the huge challenges of climate change currently facing us.
     
352. 
     It is immediately obvious from the predominantly agricultural nature of the land surrounding the site that there is no suitable heat load for the proposed incinerator:
     

353. 
     I note also that DEFRA's Outline Business Case template for PFIs (Department for Environment Food and Rural Affairs (DEFRA) 2008) says:
     

Combined Heat and Power (CHP) solutions are typically the most efficient outcomes giving a significant climate change benefit.

354. 
     WS 2007 delivers a similar message¹⁰⁸: “The Government, while not generally expressing a preference for one type of technology over another for EfW, does believe that any given technology is (where applicable) more beneficial if both heat and electricity can be recovered. The strategy therefore states that particular attention should be given to the siting of plant to maximise opportunities for CHP. Greenhouse gas emissions should be an important criterion for stakeholders developing EfW plant. Some indications of typical emissions patterns are given in the summary guidance, but these will, of course, vary from location to location according to local transport links, etc”.
     
355. 
     In a 2005 report for DEFRA on extending the Renewable Obligation to include energy from waste with CHP ILEX consulting wrote:
     

We estimate that EfW with CHP will produce a net environmental gain, producing additional carbon savings beyond that from electricity-only EfW plant – of between 120 kgCO₂ and 380kgCO₂ for each MWhth of heat produced.

356. 
     They thus estimated that:
     

“ a 400kt/yr EfW with CHP facility would create additional carbon savings of between 0.7 and 1.0 million tonnes¹⁰⁹ of carbon dioxide (CO2) in total over a 20-year lifetime, over and above those achieved by a conventional EfW facility without CHP.”

357. 
     Combined heat and power is currently "vastly under-utilised" in the UK with only 3 out of the 25 plants currently exporting heat - even these plant are not maximising their heat export capacity [Nixon, 2013].
     
358. 
     The evidence demonstrates:
     

• the site selection procedure was flawed - and was restricted in scope and criteria - largely due to the Javelin Park site having been pre-determined by GCC.

• the proposed site is inappropriate for CHP no heat user has been identified and the application does not extend to provision of necessary infrastructure. It is unlikely that the proposed incinerator would ever run in CHP mode

• alternative sites, technologies and smaller incinerator capacity would provide more environmentally friendly solutions better suited to the changes in waste arisings and composition. Such sites would also facilitate the use of CHP and would therefore be much more closely aligned with the Development Plan, Government policy and environmental imperatives.

• there is a high 'opportunity cost' associated with the use of this scale of incineration on this site.

• the climate change benefits and the contribution to renewable energy are, in any case, overstated by the appellant.

• the excessively high carbon intensity of electricity generated by the proposed incinerator - particularly in the absence of CHP - compared to genuine low carbon generation

• the total climate change and energy benefits associated with recycling, digestion and alternative treatments are significantly higher than from incineration when robust comparisons are made.

359. 
     In conclusion I consider that CHP, with the associated reduction in climate change impacts, would be unlikely ever to be achieved at this entirely unsuitable and inappropriate site.