The call for evidence on RDF – what’s next?
In late 2014, Defra announced the outcome of the Government’s call for evidence on RDF. Having had time to digest the resulting announcements, Waste to Energy specialist Gary Moore (sales manager at UNTHA UK), considers the likely implications for the industry as 2015 unfolds.
Defra’s call for evidence on RDF, which began back in March 2014, was a fairly significant milestone for the Waste to Energy industry. Of course we didn’t know what the findings would be, but it was, nevertheless, a sign that the Government was finally paying greater attention to the WtE landscape. It indicated politicians’ attempts to better understand what is not only a complex industry, but also a highly valuable one, steeped in potential.
The outcome didn’t necessarily need to be one rich in praise. We didn’t expect Refuse Derived Fuel to be hailed as a panacea, for instance. There is always room for improvement in any area of business, and nobody would have disputed the fact that RDF is far from perfect. But we all hoped for progress.
This is because, prior to the call for evidence, the Government appeared to like the idea of RDF, a little. However, opportunities were perhaps brushed under the carpet in favour of quick wins or vote stealers. There is more than enough non-recyclable waste in the commercial sector to feed WtE plants, for example, but revenue, planning and long-term vision has been lacking.
This limited commitment and investment in RDF has restricted the sector from reaching its full potential, which has perhaps led to the ever-increasing export figures that we read about within the press. Trade on the continent has proven attractive, whilst domestic strategy has lagged.
To a certain extent, because RDF hasn’t been a priority, this has also enabled less scrupulous producers to go about their business with little regard for standards or the sector’s wider reputation. Many operators who have put the effort in have essentially been penalised as a result – commercially they’ve struggled to compete with firms that cut corners, and their PR has been overshadowed by stories of ‘rotting RDF idling at the docks’.
It’s perhaps no surprise that in the face of such negative messages, and with little words of encouragement from the Government, the general public doesn’t particularly embrace WtE, like communities do in some neighbouring European nations.
So to what extent will the outcome of Defra’s call for evidence change all of this? What are the likely implications of their findings?
A quality standard is something we have spoken about for some time, with mixed feedback from the industry. Many agree that greater clarity and consistency is needed; others see it as an opportunity to ensure better recyclate recovery; and some fear it could create unnecessary industry barriers. I suppose it is a case of defining and introducing a standard for the right reason.
In the world of production, a system should be designed to support the satisfaction of a product specification; that specification ought to be dictated by the end user, not an industry body such as Defra or the Environment Agency. This is why SRF is manufactured to a defined brief, as stipulated by cement kilns and other customers of the fuel. In the case of RDF however, the end user isn’t particularly quality driven, which is where this argument falls down.
Perhaps the answer is a recovery standard, rather than a product standard. Parameter RDF grades could be defined, but the required robustness of the RDF production company could also be specified. Similar to an ISO accreditation, the standard would then only be granted if a number of quality benchmarks were achieved. These benchmarks could relate to the organisation’s approach to storage, the degree of recyclates that must be extracted to support utmost waste hierarchy compliance, and the health and safety standards upheld on site, for instance.
Of course there is the matter of policing such behaviour, which would be no mean feat. However, tighter enforcement to clamp down on waste crime has been promised by Defra – in conjunction with the Environment Agency – as a result of the call for evidence exercise. And this should be applauded. This isn’t a case of tying responsible companies up in red tape and making it harder for them to do business. It’s about heightening the ethicality and professionalism of the sector, so that we can move forward.
The apparent lack of manpower within the agency could, in truth, make such policing tough. I suspect investment in resources will be required, so that the job doesn’t become impossible to manage. Some thought should also be given to the penalty of quality breaches. Will a warning, or even a fine, automatically cleanse the WtE industry of less responsible operators, keen to make a quick buck? It’s doubtful. To truly deter non-compliant behaviour, perhaps regulation, with clear routes of personal prosecution, is required.
Many people feel it’s a shame that the Government won’t subsidise gate fees. The reasoning behind Defra’s decision is that they feel cost-effective and efficient domestic facilities should be able to attract feedstock without intervention, and that the presence of gate fees would restrict the long-term viability of such plants. This is probably true. However, some initial investment support, to help plants invest in the technology that will help them operate cost-effectively and efficiently, would have been nice.
Perhaps, truthfully, they feel that landfill targets are largely being met, and the export market is working to a certain degree, so why bother intervening? In theory continued export levels could compromise domestic RDF infrastructure, so a level of concern is understandable. But there is so much work to be done in the short-medium term, to improve our capability to better harness RDF domestically, that export does offer an interim solution.
This whole exercise is hopefully the first stage of a transformational process to loosen the ‘waste’ classification on alternative fuels. If RDF was brought in line with biomass, for instance, which has more recognition as a product, we’d perhaps overcome many of the problems we are currently experiencing. That’s not to say RDF is a true product, like SRF, but it is a fuel. There is therefore an argument that it should come under its own classification, not just a typical waste stream.
I hope that more focus will also be given to the activities and behaviours that occur before waste is even considered for RDF. I’ve said for some time that the Government needs to introduce policy, a sense of direction and education opportunities, for the entire population, to promote greater waste hierarchy compliance.
Hopefully, this resurgence of conversation surrounding alternative fuels, will kick-start action, not just chit chat, and we can all start to see the progress we wish for. The likelihood is that the market won’t change drastically for some time, as there is no quick fix. However, Defra has confirmed that there is an “environmental rationale for intervention in the RDF market in England”, and this should be seen as a good thing.