Residual Waste Team

DEFRA

Area 2B Nobel House

17 Smith Square

London

SW1P 3JR

CALL FOR EVIDENCE – REFUSE DERIVED FUEL MARKET IN ENGLAND

Dear Sir or Madam,

Thank you providing the North London Waste Authority with the opportunity to respond to the Call for Evidence relating to the Refuse Derived Fuel Market in England

The North London Waste Authority (NLWA) is one of the six statutory joint waste disposal authorities in England and one of the four in London. It is the second largest waste disposal authority in England, handling circa800ktpa tonnes per annum of municipal solid waste (MSW) from the following boroughs: Barnet, Camden, Enfield, Hackney, Haringey, Islington and Waltham Forest. The NLWA operates an energy-from-waste (EfW) facility at Edmonton where circa 530ktpa of waste of waste left over after recycling and compostingis burnt to produce electricity, thereby displacing fossil fuel extraction andconsumption.

Therefore, the Authorityregards the production of electricity from waste to be of greater benefit than consigning waste to landfill, making a real and positive contribution to the UK’s generating capacity, meeting renewable energy targets and assisting with energy security in Europe. As such, the NLWA is broadly supportive of refuse derived fuel (RDF)being sent to overseas facilities where it is economically advantageous, does not undermine local energy ambitions, and is environmentally safe/effective.

However, the NLWA only considers this to be a short to medium term opportunity and that greater encouragement should be given to increasing domestic energy-from-waste capacity for residual wastes, particularly commercial and industrial waste. The UK could benefit from the energy value in the waste rather than continental countries; even if it is possible to import back the electricity from UK RDF in the short term, it would seem illogical to do this in the long term. This follows on from the NLWA’s view that while producers of RDF are able to enjoy low gate fees at European facilities in the short term due to a combination of depreciation and spare capacity, as European facilities come off line or other waste producers compete with UK exports, replacement capacity will need to be provided here in the UK.

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One of the reasons the UK can currently benefit from nearby continental capacity is due to decisions made by municipalities to build significant capacity and to take a longer term perspective on investment/operation (longer depreciation periods or debt-free periods) than can usually be achieved through private sector schemes that are often predicated in the UK on a twenty-year repayment period for principal bank debt. An improved understanding of the rationales and commercial approaches taken elsewhere in Europe might help the UK identify and implement optimal long-term solutions here that contribute to waste service security and energy security objectives.

Consideration should also be given to how local authoritycontrolled wastes can help deliver capacity for commercial & industrial wastes. This could increase the chances of developing UK energy capacity and would be particularly beneficial where it can be done in conjunction with heat off-take. Here, if encouraged by government,local authorities could take a longer term strategic view of infrastructure needs beyond usual commercial timeframes considered under private finance schemes, and in the long term provide greater value to both the residents they serve and local businesses together with helping with UK energy security.

Notwithstanding this, in the short to medium term, the NLWA recognises the need for a common regulatory approach to the production, storage, and transportation of RDF to ensure that the risk of potential environmental harm is minimised, and to ensure consistency and appropriate quality across the marketplace.

If you require any further clarification of the points raised in our response or have additional queries please do not hesitate to contactthe Authority’s Technical Solutions Manager, Euston Ling ().

Yours sincerely,

Andrew Lappage

Head of Operations

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