International Review of Waste Management Policy - Department of ...

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Ew means annual energy contained in the treated waste calculated using the
net calorific value of the waste (GJ/year)
Ei means annual energy imported excluding Ew and Ef (GJ/year)
0,97 is a factor accounting for energy losses due to bottom ash and radiation.
This formula shall be applied in accordance with the reference document on
Best Available Techniques for waste incineration.
In order to meet this criterion, a new facility generating only electricity has to exceed
24.25% gross efficiency even if no energy is used in the process itself (in other words,
even if Ei and Ef are set equal to zero in the above formula). Including the energy use,
a report by CEWEP suggests that at existing plants generating mainly electricity, 6 of
25 facilities reviewed would meet the threshold for new facilities. 1050
Although facilities which met this threshold efficiency level would be classified as
‘recovery’ under the revised Directive, this does not necessarily confer upon such
plants a preferred position in the hierarchy over all other residual waste treatments.
Article 4 of the Waste Framework Directive states:
When applying the waste hierarchy referred to in paragraph 1, Member States
shall take measures to encourage the options that deliver the best overall
environmental outcome. This may require specific waste streams departing from
the hierarchy where this is justified by life-cycle thinking on the overall impacts of
the generation and management of such waste.
Given this, it might have been expected that the Commission itself would have sought
to demonstrate a clear distinction between incinerator which would, and would not,
meet the recovery criteria. To the best of our knowledge, it did not. Given that a tradeoff
may exist, in some instances, between an incinerator’s energy use, and the quality
of flue gas cleaning, such an analysis would have been entirely appropriate.
The above externality assessment, as well as the analysis in Annexes 61.0 and 62.0,
suggests that for municipal waste, there is no obvious reason why incineration which
qualifies as recovery should be preferred to some other forms of residual waste
treatment. Even with respect to landfilling of untreated waste, surprisingly, the
evidence is equivocal, including some of the work carried out under auspices of the
European Commission itself. The Waste Framework Directive is also not well adapted
to answering questions as to whether, and if so, under what conditions, different
configurations of MBT should be regarded as recovery or disposal.
In the light of the above, Government may wish to consider issuing a statement to the
effect that as regards residual waste, the levy is intended to internalise environmental
costs. With these estimated externalities internalised through the levy, other factors
would be used to determine the pattern of residual waste treatment used, including
other policy instruments and their effects. Indeed, it is not clear what is to be gained
by Government stating a preference for one or other approach to dealing with residual
1050 D.O. Reimann (2006) CEWEP Energy Report, Report for CEWEP, Update July 2006.
International Review of Waste Policy: Annexes