Dear Planning Officer
1. As you will be aware, applications for waste facilities must be evaluated against the requirements of all relevant national guidance, including PPS1 Supplement on Climate Change.
2. For disposal and recovery operations this consideration includes the documents which form part of the Article 7 plan, as per §§ 8.9 and 8.10 of the Companion Guide to PPS10, namely PPS10 and Waste Strategy for England 2007.
3. This submission calls attention to issues arising from this application in relation to climate change impacts and to the importance of abiding by the waste hierarchy, and ensuring that waste management takes place at the highest possible level of the hierarchy.
Planning Policy Statement 10: Planning for Sustainable Waste Management
4. PPS10 § 1 states that "moving the management of waste up the ‘waste hierarchy’" is part of the Government's overall policy objective.
5. PPS10 § 23 makes it clear that the Waste Planning Authority (WPA) should determine proposals in a way that is consistent with the policies of PPS10.
6. The principle that waste management should be driven up the waste hierarchy is acknowledged by the applicant at § xxxxx of their Environmental Statement.
7. The Waste Hierarchy is defined in Annex C of PPS10 as: Reduction, followed by Re-use, followed by Recycling & Composting, followed by Energy Recovery, followed by Disposal.
8. This application is for an Energy Recovery facility that would rely upon material that could viably be recycled, and thus goes against the waste hierarchy and therefore conflicts with one of PPS10’s core objectives.
9. By going against the waste hierarchy, a grant of permission for this application conflicts with the policy objective enshrined in PPS10, and therefore this application should be refused.
Waste Strategy for England (2007) and PPS1 Supplement on Climate Change
10. PPS10 § 3 also makes clear that WPAs should deliver strategies that “help deliver the national waste strategy and supporting targets”.
11. As with PPS10, the Waste Strategy for England 2007 (WS2007) promotes adherence to the waste hierarchy.
12. Page 9 of WS2007 includes a diagram of the waste hierarchy and goes on to note that:
“The dividends of applying the waste hierarchy will not just be environmental. We can save money by making products with fewer natural resources, and we can reduce the costs of waste treatment and disposal. Waste is a drag on the economy and business productivity. Improving the productivity with which we use natural resources can generate new opportunities and jobs.”
13. Chapter 1 of WS2007, §§ 20 and 21, make clear that adherence to the waste hierarchy encapsulates the Government’s overall objectives for waste policy. The waste hierarchy outlined in Figure 1.3 of WS2007 is consistent with the waste hierarchy in PPS10, and makes clear that recycling is to be preferred over energy recovery.
14. Chapter 5 of WS2007, § 1 states that:
“We need waste to be minimised to the greatest extent practicable, and such waste as does arise to be managed as far up the waste hierarchy as is reasonably achievable. Resources should be recovered in ways that maximise the cost-effective reduction in greenhouse gas emissions over the lifecycle.”
15. Chapter 1 of WS2007, § 22 states that:
“Recent studies have confirmed that the waste hierarchy remains a good general guide to the relative environmental benefits of different waste management options...”
16. As recycling is higher on the waste hierarchy than energy recovery then the applicant should be required to robustly demonstrate that either the timber would otherwise go to landfill or that, in this specific instance, the waste hierarchy is mistaken.
17. WS2007 Annex K states that:
“In particular, WS2007 makes clear that energy should be recovered only from residual waste that cannot viably be recycled, as well as certain biomass wastes such as wood and food waste (via anaerobic digestion) where there are clear carbon benefits of doing so.”
18. The application currently being considered fails to demonstrate that either:
a. Energy recovery would be only from residual waste that cannot viably be recycled; or that
b. There are clear carbon benefits in using the timber for biomass energy recovery, instead of as material available for wood panelling (see below).
19. PPS1 Supplement on Climate Change makes clear that “tackling climate change is a key Government priority for the planning system”.
20. Thus, the proposed facility conflicts with WS2007 and PPS1 Supplement on Climate Change, and therefore this application should be refused.
Wood Panelling
21. Wood panels are produced using a range of sources, including small roundwood, chips, sawdust and recycled wood. Each type of panel has various applications in the construction, furniture and do-it-yourself sectors, including cladding, packaging, kitchen worktops and laminate flooring. Panels are a vital component that can only be replaced by more expensive and less sustainable products[1].
22. Subsidies that incentivise the use of wood harvest in energy generation are causing tension between the processing industry and the energy sector. The direct use of biomass and wood for energy production is not only reducing the wood supply but also creating negative consequences for the environment[2].
23. Several studies indicate an important difference between the available amount of woody biomass in Europe, and the quantity that is needed to fulfil the targets concerning renewable energy. For the year 2020, a shortage of 230 million m³ wood (McKinsey, 2007) – 400 million m³ wood (FAO/UNECE/University of Hamburg) is estimated. This deficit accounts for 1/3 of the total demand of wood in 2020[3].
24. Wood products should be reused and recycled before being turned into fuel. Forest products have the ability to store carbon, because carbon remains bound for the entire service life. After wood-products have been used, they can often be re-used and recycled, then eventually burnt, when the stored CO2 returns to the atmosphere[4].
25. The hierarchy of use principle would help rationalise the use of wood and define preferred options, i.e. using and recycling wood and only burning in last resort. If more and more wood and forest residues go directly to energy plants we are wastefully minimising the carbon cycle of wood[5].
26. We also call your attention to the 12th May 2010 report by Europe Economics, entitled The Wood Panel Industry in the UK, a summary of which is available from http://www.makewoodwork.co.uk/GalleryEntries/Manifesto_and_Reports/Documents/Europe_Economics_final_report_May_12_2010.pdf
27. The report is concerned primarily with the economic impact of the presence of the wood panel manufacturing industry in the UK, and of the potential threats to it.
28. Although we appreciate the relatively small scale of the proposed operation, this report calls into question the social, economic and environmental claims made by the applicant, and in our view its findings are a material planning consideration.
29. Two further studies provide additional relevant information that we believe should be taken into account in any evaluation of this application.
30. Wood fibre availability and demand in Britain (4th May 2010), by John Clegg Consulting Ltd., provides a picture of wood fibre supply and demand in Britain for the next 15 years. The report was commissioned by the Confederation of Forest Industries (CONFOR), the United Kingdom Forest Products Association (UKFPA) and the Wood Panel Industries Federation (WPIF). A summary is available from:
http://www.makewoodwork.co.uk/GalleryEntries/Manifesto_and_Reports/Documents/Wood_Fibre_Availability_Demand_Report.pdf
31. Carbon emissions for end of life scenarios for wood fibres (4th May 2010), by Carbon River, was commissioned by the Wood Panel Industries Federation. This report, which is primarily concerned with net CO2 emissions arising from competing uses for the UK’s scarce and finite timber resources, maps and compares the emissions associated with the processing of one tonne of wood through the wood panel production process and the transport and eventual burning of one tonne of wood to generate electricity. A summary is available from:
http://www.makewoodwork.co.uk/GalleryEntries/Manifesto_and_Reports/Documents/WPIF_Project_Subsidy_Report.pdf
32. This report explains how, until recently, the wood panel industry has sourced its timber domestically in the UK on a competitive basis. The competitive market began to be undermined in 2002 by the Government’s introduction of a subsidy to compensate electricity generators for burning “renewable” fuel in the form of the Renewables Obligation Certificate (ROC).
33. At § 1.5 of Carbon emissions for end of life scenarios for wood fibres we read:
“As a result of the ROC subsidies, the projected demand for timber in the UK will outstrip supply by 2012: ‘The biological availability of British sourced wood fibre is forecast to increase up to about 2019 when it reaches just over 20 million tonnes per annum and then it is forecast to start decreasing’ [Clegg Report – Wood availability and demand in Britain 2007 - 2025]. Demand during the same period is set to increase to 50 million tonnes as a result of proposed increases in biomass electricity generation.”
34. According to the report, although the burning of timber is virtually carbon neutral over the lifecycle in comparison to fossil fuels, when compared to wood panel manufacture it is a significantly greater source of CO2 emissions.
35. The CO2 emissions from the wood panel industry equate to 378kg CO2 per tonne of timber processed. In comparison, the CO2 emissions from the biomass industry consuming domestically sourced timber equates to 1905kg CO2 per tonne of timber processed.
36. We note the difference between 378kg and 1905kg equates to 1527kg of CO2 per tonne of timber processed (or 1.527 tonnes of CO2 per tonne of timber processed).
37. If we use a figure of 20,000 tonnes of timber to be processed in the proposed facility, and if we assume that all of this material could otherwise have been used by the wood panel industry, then the additional emissions would amount to 30,540 tonnes of CO2 per annum (and the total CO2 emissions from the proposed facility would amount to more than 38,000 tonnes per annum).
38. If we use a figure of 22,000 tonnes to be processed in the proposed facility (as stated in the Non-Technical Summary, § xxxx and the Environmental Statement, Volume II, § xxxx), and if we assume that all of this material could otherwise have been used by the wood panel industry, then the additional emissions would amount to nearly 33,600 tonnes of CO2 per annum (and the total CO2 emissions from the proposed facility would amount to nearly 42,000 tonnes per annum).
39. These figures call into question those supplied by the applicant, and serve to undermine the applicant’s claims regarding the desirability of their facility in relation to climate change.
Conclusion
40. For the reasons outlined above, we respectfully ask that the application be refused planning permission on the basis that the application conflicts with relevant planning policy guidance, including PPS1 Supplement on Climate Change, PPS10: Planning for Sustainable Waste Management, and Waste Strategy for England 2007.
6
[1] European Panel Federation Fact Sheet (dated 28/10/2010) available from: http://www.makewoodwork.co.uk/GalleryEntries/Manifesto_and_Reports/Documents/EPF_Environment_Fact_Sheet.pdf
[2] Ibid.
[3] Ibid.
[4] Ibid.
[5] Ibid.