WRA welcomes plans to withdraw RPS 250
Following five years of work to clarify which waste wood items are potentially hazardous, the Wood Recyclers’ Association (WRA) says it welcomes plans by the Environment Agency to withdraw RPS 250 on September 1st.
Introduced in July 2021, the WRA says the Regulatory Position Statement (RPS) 250 currently allows potentially hazardous “amber” waste wood items from the construction and demolition (C&D) waste stream to be moved and processed as non-hazardous.
However, from September 1st 2023, the Environment Agency has confirmed this will be withdrawn. The WRA says this means that a small number of items from pre-2007 buildings will automatically be classified as hazardous and will not be able to be sent to wood recyclers.
Instead, they will require specialist hazardous waste disposal, unless they are sent for a simple test to demonstrate that they are not.
The WRA says the move comes after they successfully worked in partnership with UK regulators over five years to gather evidence to “drastically” narrow down the list of potentially hazardous C&D amber items to just ten, as part of its Waste Wood Classification Project.
These ten items, all from pre-2007 buildings, are barge boards; external fascia; soffit boards; external joinery; external doors; roof timber; tiling cladding; tiling battens; timber frames and timber joists.
The WRA says its efforts in spearheading this work were applauded this month by the Environment Agency’s Howard Leberman at the WRA’s Spring meeting, where he also confirmed the withdrawal of the RPS.
Julia Turner, Executive Director of the WRA, commented: “We are delighted that the work we’ve carried out has provided clarity that the majority of waste wood is non-hazardous.
“While we still have several items to test, end-user testing of C&D material has indicated a hazardous content of less than 1% – representing a tiny proportion (0.08%) of UK total waste wood arisings, at around 4,000 tonnes.”
“We believe the potentially hazardous items can be reduced further with more testing and could be easily accommodated by existing hazardous outlets. Therefore this will not impact the industry’s role of providing recycling and recovery outlets and security for local authorities, waste management companies and biomass plants going forward.”
The withdrawal of the RPS from September will put the onus on the waste producer rather than wood reprocessors to identify, test and classify wood at source, in line with current legal requirements.
The WRA says it will continue to champion testing and has produced a Quick Guide to support this.
Meanwhile, wood recyclers will no longer be able to take this material and have been told they will need to amend their acceptance criteria to add these items to their unacceptable items list and communicate the change to their customers.
By doing so they will avoid the “substantial” costs and potential stigma of becoming hazardous waste sites for the sake of a very small amount of material. This was a huge fear for the market and could have resulted in several companies being unable to continue trading.
It will also ensure that potentially hazardous material is not sent to biomass and panelboard markets which have always said they don’t want any type of hazardous feedstock.
Turner goes on to say: “We welcome plans to withdraw RPS 250. Responsibility for finding and testing the small number of potentially hazardous items in the demolition waste stream will now lie with the waste producer.
“We hope this will incentivise more widescale testing to enable even more items to be deemed non-hazardous in future.
“End users of waste wood – including panelboard and biomass – do not want material that is still classified as potentially hazardous and this will give clarity to both the waste wood supply chain and UK regulators.
“The WRA will continue to encourage sampling and testing of amber items and offer support and training.”
The withdrawal of RPS 250 applies to construction and demolition waste only, the WRA says. The Association continues that testing is currently ongoing on potentially hazardous waste wood from households and is expected to confirm that its hazardous content is diminishing and soon likely to disappear altogether.
Opinion
EfW Carbon Tax – a welcome catalyst for positive change
Lee Knott, Chief Commercial Officer, Advetec, asks as the cost of incinerating waste increases, is now the time to explore greener waste treatment options?
As the climate crisis develops, the spotlight is firmly on the volume of waste sent to conventional mass burn Energy from Waste (EfW) plants – and we must ask ourselves why this continues to be the favoured route. The answer is almost certainly habit, and because there is still a lack of transparency, autonomy and information surrounding waste.
However, as the impetus for environmental change increases, the cost of incinerating waste is set to rise drastically – not only calling into question its economic viability but forcing much-needed conversation around alternative, greener and more future-focused waste treatment options.
Political impetus and changing goals
Both the EU and the UK are seeking to expand their emissions trading schemes to align reduction targets with the global climate change goals of the Paris Agreement. One shared proposal is to bring EfW facilities – which have previously been excluded – into scope by putting a price on CO2 emitted from these facilities.
The European Parliament and Council have already reached a provisional agreement to include EfW facilities in the EU Emissions Trading System (EU ETS) by 2030 at the latest, and EU countries will be required to measure, report and verify the emissions from EfW facilities from as soon as 2024.
Closer to home, the UK Climate Change Committee stressed last year that Government needs to “address with urgency the rising emissions from, and use of, Energy from Waste” and recommended a consultation on the introduction of a carbon tax (either as part of the UK ETS or a separate instrument) aimed at curbing rising emissions from EfW.
The UK will need to ensure that any changes to the ETS don’t impact the waste hierarchy, by increasing the volume of waste sent to landfill or exports of refuse-derived fuel (RDF) – which remains a popular choice to countries such as Turkey.
From March to June 2022 the UK Government ran the Developing the UK Emissions Trading Scheme (UK ETS) consultation and launched a call for evidence on expanding the UK ETS to include waste incineration (with no energy recovery) and EfW.
The consultation recognised that EfW facilities emitted 6.2 MtCO2e in 2019, representing c.1% of UK emissions and determined that the government could expand the UK ETS to waste incineration and EfW by the mid-late 2020s.
But what’s the likely cost?
The recent Tolvik Consulting report, titled “Response to Call for Evidence on Inclusion of EfW in the UK Emissions Trading”, estimates that with a fossil content of residual waste between 30% and 60%, and a range of carbon processes between £45 and £85 per tonne, the impact on EfW gate fees could increase between £13 and £51 per tonne.
The UK’s call for evidence requests feedback on several issues, in particular the approach to the monitoring, reporting and verification (MRV) of emissions. This is important as it may impact the extent and cost of an operator’s UK ETS compliance obligation – and the starting proposition in the consultation is for the UK ETS to cover the incineration of fossil material only, and that biogenic material would be excluded.
The consultation noted that the mixed black bag waste treated at EfW facilities is typically assumed to be 50% from biogenic material and 50% from fossil material.
After analysing waste from various handlers in the UK though, we collected data that suggests most residual waste contains around 60% carbon, which means the additional cost per tonne is likely to be at the upper end, between £40 and £45 per tonne.
The expansion of the ETS to include EfW facilities will, of course, have a significant impact on EfW operators’ obligations and liabilities and plants in Europe are already looking at alternative pre-treatment waste streams to minimise carbon emissions and tax. However, the implications will also be felt across the supply chain, including local authorities and municipal waste operators.
Should we welcome the price hikes?
In the current climate, waste operators’ response to any further financial pressure is naturally going to be negative. However, it could be argued that the impending tax is a welcome and arguably long overdue catalyst for positive change within the industry – particularly as technology is already available to divert mixed residual waste from EfW and landfill – as well as unlock the value of waste for the circular economy, reduce costs and lower CO2.
By removing the organic fraction of waste, Advetec’s biotechnology creates a high-quality coal replacement product – or as we call it floc – which can have tremendous value to the circular economy.
When mixed residual waste goes through our aerobic process the resulting floc is a consistent, homogenous and high-quality material. It’s such high quality that it can go on to be used as a Solid Recovered Fuel (SRF).
SRF produced from this unrecyclable waste stream has greater value than SRF produced from recyclate because the digestion process gives the waste a higher calorific value and a biogenic carbon fraction, so is optimally suited to replace carbon-emitting coal to power cement kilns for cement production.
As such, it means that conventional mass burn EfW is no longer the only disposal route for mixed residual waste, higher gate fees won’t present an issue and operators can futureproof operations by becoming early adopters of disruptive technology – all the while boosting the green credentials of themselves and their clients.
The inclusion of EfW facilities in the EU ETS comes at the perfect time and will no doubt force several typically more traditional businesses down a route of being more open-minded towards innovation. Deciding to embrace technology saves money and improves ESG goals – and with legislative changes on the horizon, seeking alternative routes to waste disposal has never been timelier.
To find out more about Advetec and how its biotechnology can make residual waste AT4 compliant and create SRF, visit www.advetec.com/uk/what-we-do.
The Contribution of Commingled Recycling to Northern Ireland’s Recycling Performance
Joseph Doherty, Managing Director of Re-Gen Waste in Newry, claims the contribution of commingled recycling collections made the greatest contribution to Northern Ireland’s recycling performance in 2021-2022.
Reviewing Northern Ireland’s recycling performance for April 2021 to March 2022, the normal reporting year, it is notable that six of the top seven councils were collecting their dry recycling mixed as commingled collections. These commingled collections accounted for 62% of the tonnage collected from Northern Ireland households. But only 57.4% of households are on commingled collections which proves it is a system that collects the highest tonnage and makes the greatest contribution to the region’s household recycling rate that year.
A single bin is the cheapest for collection as it involves one large container per household that can be serviced by standard refuse trucks as opposed to the more expensive and mechanically complicated multi-compartment vehicles used for box collections. This means that replacement vehicles can be quickly sourced from within a council’s refuse fleet during emergencies: obviously cleaned before use to avoid contamination.
Commingling is popular because it is efficient and effective. It is simple and convenient for householders because glass, plastic, aluminium and steel cans, paper and cardboard can be recycled together. There is no sorting for householders: but they are asked to rinse and dry materials.
Investments in MRF technology for artificial intelligence (AI), visual recognition (VR) and robotics are being made to further improve sorting accuracy and material quality. Re-Gen is already investigating how we can process film and flexible plastics in the future when extended producer responsibility (EPR) is expanded to include them in the material delivered to us.
We are in a time of recessionary balance sheets for councils and devolved administrations, and a cost-of-living crisis for households. It is only right that a system that is proven to deliver results – while costing the ratepayer less than the alternatives – should be given equal weight in the arguments about what the future recycling system for Northern Ireland needs to be.
We know that the past performance of some material recovery facilities (MRFs) has not delivered the quality expected by end markets and the aspirations of policymakers. Re-Gen is not one of those MRFs. We continue to make a significant investment in AI and VR so that the technology, rather than the householder, takes the strain on sorting out what can be recycled.
MRFs can achieve 90% back-to-bottle in glass recycling when working with other advanced technology, as referred to by Tim Gent, Director of glass re-processor Recresco UK. Re-Gen does with a European glass partner company, and we are light years beyond where we were a few years ago.
Technology advances and it would be remiss to ignore the benefits it can bring to household recycling collections, making things simpler for the resident and easier for them to participate.
At a recent collection planning workshop for the sector, DAERA stated that if the entirety of Northern Ireland households were changed over to a multi-container system using the more expensive vehicles, it would only raise the household recycling rate by 8%. However, ensuring every business recycled the same materials as households would double the volume of recycling collected from them.
They did not provide any comparative figures for a complete changeover to a single bin commingled system. That will be the challenge in terms of cost and changing householders’ hearts and minds. In Northern Ireland, we have a system that works and where all recyclates can be collected in one location.
They only provided one side of the argument. But if they made businesses recycle the same way as residents by separating recycling from their waste and having separate food waste collections, this would raise the business recycling rate from 40% to 80%.
This should easily achieve their 65% target by 2035 and would mean that residents could keep their single-commingled recycling bin and continue to contribute two-thirds of the recycling from households. And possibly more if other councils followed their lead and provided fully commingled collections. This would also be far less disruptive and costly for businesses than the multi-bin or box system that is being considered.
DAERA and their advisers continually push Wales as the best recycling system to replicate and that we should adopt it here. But in the same meeting, they admitted that Wales’ household recycling rate is only 54%, not the 65% that is widely published. That is only 4% above where Northern Ireland is now.
A lot of Wales’ success can be put down to its restriction of residual waste capacity, either by the size of the bin or the frequency of collections. And let us not forget they can fine residents £100 and are proposing to fine businesses £300 that do not follow their rules.
Is this really what we want for Northern Ireland? Councils may find themselves forced to buy overly complicated collection vehicles to service this myriad of containers to raise the recycling rate by just 4%.
Re-Gen does not think so. Advanced MRFs such as ours can help deliver a 65% recycling rate for Northern Ireland at a lower cost than what is being considered for changing residents’ kerbside collections and collections from businesses over to a multi-container system. The efficient and effective services enjoyed by residents in Re-Gen’s customer councils must be defended or they will find themselves burdened by more containers, be they bins or boxes.
We are also pleased to see that councils who use Re-Gen for treating their residual waste are the best performers about diverting this waste from landfill, with our four customer councils being in the top five for performance, as outlined in the table above. Does this support the claim that when you restrict residents’ ability and opportunity to recycle by using multiple small containers, they only have their residual bin to use for any excess, which increases the residual waste collected?
