An independent peer review of the recently published European Environmental Bureau report ‘Eco-dumping by energy recovery’
brings into serious question some of the key findings of the report and finds its key legislative recommendations unbalanced.
The peer review was carried out by CE Delft, of The Netherlands, on behalf of ASSURRE (Association for the Sustainable Use and Recovery of Resources in Europe). Although the review agrees that legislation should be adopted in some way for co-incineration with recovered fuel, they believe that:
- the report’s failure to compare the environmental impact of using fossil fuels – not just the recovered fuel that substitutes them - presents a misleading picture. The report failed to compare concentrations of pollutants in coal with those of recovered fuel and also ignored the positive effects of recovered fuel co-incineration (SO2 & CO2 emissions, quality of residues) versus coal
- the recommendation for harmonisation of emission limits for all processes at industrial furnaces (i.e. cement kilns, coal-fired power plants) using recovered fuel to substitute fossil fuels, is unbalanced and ignores the environmental impact normally caused by the fuel substituted – namely coal. A better route would be to employ these limits solely for the energy from waste process, leaving furnace owners to comply with those limits
- the recommendation that recovered fuel is co-incinerated only in modern and energy efficient industrial furnaces is not relevant, as a plant can be inefficient whatever the fuel used. More pertinent would be to require a minimum thermal efficiency for recovered fuel, comparable to fossil fuel.