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Paul Levett shares his response to the recent RDF consultation

Date: 12/05/2014 | Author: Paul Levett

Image for Paul Levett shares his response to the recent RDF consultationPaul Levett is a non-executive board member for a number of companies in the recycling and waste sector. Here he shares his response to the recent consultation from Defra on Refuse Derived Fuel that closed last week.

The increase in landfill tax has made disposal to landfill progressively uneconomic. Recycling is a good alternative. However, to be economic the sale price of the materials plus the landfill tax saved must exceed the incremental cost of transporting and sorting the materials. Capturing potential recyclates from mixed residual waste can be expensive and the value of the material can be depressed if it is dirty or contaminated.

The production of Refuse Derived Fuel (RDF) allows that material which can be cost effectively separated and which is of saleable quality to be extracted prior to the remaining materials being shredded and processed to create a fuel which meets the specification required by the end user.

Energy from Waste (EfW) plants in UK have usually been built as part of PFI contracts for Municipal Solid Waste (MSW) and have limited spare capacity.

Many power plants cannot accept RDF because they are not Waste Incineration Directive compliant. It can be anticipated that new merchant plants will be developed to process some of the RDF being generated in UK. However, funding has not been available during the recession and there is a lead-time for design, planning, funding and construction - say 3-4 years.

While UK is waiting for the new plants to be built, RDF is being exported to continental Europe to EfW plants which have spare capacity and to cement kilns which can use Solid Recovered Fuel (SRF) as a substitute for fossil fuel. It is likely that some RDF will continue to be exported even after UK has opened plants for as long as there exists spare capacity in Europe.


Q1 – a) What evidence do you have on how fully the production and use of RDF respects the waste hierarchy? b) What evidence do you have that there are beneficial environmental outcomes relative to alternative waste management routes for RDF? c) What evidence do you have on the need for some form of Government intervention in the RDF market?


a&b) Providing that RDF is the result of a process to extract those recyclates which can be economically extracted, that the fuel is processed by shredding to an appropriate size and that the output is transported in an effective form (eg baled and wrapped for sea shipments) and the end user meets R1 recovery status, then this represents a superior outcome vs landfill and is consistent with the waste hierarchy.

c) Government should fund enforcement such that unprocessed residual waste cannot be misrepresented as RDF. The latter should be subject to at least shredding, and recyclates should be extracted where economically and practically viable.


Q2 – What evidence and assumptions should we use in considering any action?


The RDF should be subject to sorting and shredding as described in the overview above.

As RDF production is economically more attractive than landfill at an £80 per tonne tax rate, it's likely that more commercial and industrial waste collectors will move towards RDF production and that hence the number of such facilities will grow rapidly - often starting as transfer stations and evolving into RDF facilities as equipment is added.

Recyclates may be in the C&I waste stream because it is sometimes impractical or uneconomic to segregate at source. It would make sense, in a year or two, to review the experience in Scotland where regulations requiring segregation have recently been introduced. 

In the case of MSW, residual waste streams can sometimes contain recyclates because householders are confused or uninterested in full compliance with segregation requirements, or simply because the recycling bins are too small. The solutions could be more standardisation of collection systems and a requirement for separate food and glass collection.

Most current UK EfW plants are able to take unprocessed waste and hence it would not be cost effective to receive RDF as the pre-processing cost would yield little value. The exception would be fluidised bed incinerators which require pre-processed materials. Many of the future EfW plants in UK will be gasification - these will mostly require pre- processed input and hence RDF will be relevant. Where fuel is prepared to SRF standard, it can be processed in UK cement kilns.

The main reason for notifications exceeding actual shipped volumes is the lead time on getting approvals which leads applications to apply well in advance and to be conservative in terms of volumes for which approvals are sought. It is difficult to accurately quantify RDF yield as % of gross waste input - this will always lead to some estimation error. 

RDF does not improve with age and activities involving the storage of such material should be carefully scrutinised . Unless there is a delay due to TFS approval or shipping capacity it may be that the storer does not have adequate cash or credit capacity to pay for the shipping and gate fees for the material. There could be a risk of bankruptcy with stockpiled material being abandoned.


Q3 – What evidence do you have as to what are the key drivers defining the RDF market? a) What specifications are domestic and foreign buyers of RDF putting on its quality or composition? b) Do you have any experience of the export of RDF affecting availability of RDF on the domestic market?


a) Currently the specification of RDF and SRF is defined by the market ie it depends on end user technology type - specifications may include calorific value, moisture content, shred size, chlorine content, dust content, etc. No single specification is appropriate and testing regimes could be complex. As such, regulation specification is not recommended.

b) There is no shortage of RDF for the domestic market. On the contrary, there is a shortage of EfW capacity to process it.


Q4 a) Can you provide evidence on the reasons for the production of RDF with no end user? b) What evidence do you have on the amounts of RDF being stockpiled and the quality of this RDF?


a) RDF could be produced pending conclusion of commercial terms with an end user but production of RDF without access to outlets makes no sense (other than to avoid landfill tax).


b) This tends to be limited to illegal operators. Hopefully edoc plus greater enforcement activity will eliminate this.


Q5 – Can you provide evidence on possible options for intervention in the RDF market?


Government should fund greater resources for the Environment Agency to inspect and enforce regulation of RDF to ensure that unprocessed residual waste is not exported. A minimum processing requirement could be applied eg shredding and removal of metals.


Q6 – Do you have any evidence which would suggest potential intervention in the market could lead to perverse outcomes?


The sources and types of materials are diverse eg MSW, C&I, construction and demolition. This precludes a one size fits all output specification. Regulations requiring the extraction of dirty or contaminated materials with no resale value could be a perverse outcome.


Q7 – a) Can you provide evidence that shows that some form of standard would address the issues around RDF production and use? b) If so, can you provide evidence on how any standard might be applied and what should be included?


a&b) There is already a regulation requiring landfilled waste to have been pretreated. Perhaps a requirement for RDF to be shredded could apply.


Q8 – What evidence do you have on suitable intervention measures for addressing the issues regarding the stockpiling of RDF?


Environmental Permits could regulate the amount and age of stored RDF.


Q9 – What evidence do you have on different approaches to delivering an intervention e.g. legislation, enforcement guidance and the implications for delivery via that route e.g new burdens and costs?


Enforcement is essential and should be the priority. Those currently guilty of bad practice would simply ignore any new rules unless there is strong enforcement. This requires adequate funding for the Environment Agency.


Q10 – a) Do you have any evidence to suggest you might be subject to additional burdens or costs if a standard for RDF or other intervention was implemented? b) Do you have evidence of any specific burdens or costs that small and medium enterprises (SME) might face?


a) Good operators should not face additional costs from a requirement for shredding and from additional enforcement.

b) SME waste producers might face additional costs if new regulations required source separation or if they currently use illegal waste operators.


Additional Comments


While some RDF is currently being produced from MSW residual waste, this is mostly on a temporary basis while the councils concerned are waiting for PFI EfWs to be delivered. Long-term contracts for RDF export can be difficult to secure and are subject to exchange rate fluctuations on gate fees and shipping costs. MSW from councils which don't have separate food waste collection will include dirty recyclates which can have low, or even negative, value.


It is strongly advised that RDF is not considered for end of waste status as this would leave it unregulated.

Output standards for RDF would be difficult to develop because of the diverse inputs and the diverse requirements of end users. However, a requirement to shred would make sense.

When developing policy, consideration needs to be given to cross border flows of RDF between England/Scotland/Wales prior to export. 

Waste composition may change over time if requirements for source segregation are introduced in England.

Some MSW MRFs are sending their residue down the RDF route. The residue has increased due to the collection by some councils of pots, tubs and trays. The residue either gets blended with other recyclates eg paper or plastics for (illegal) export or is landfilled, incinerated or sent to RDF.

Page 20 of the consultation document refers to"fluffy" waste in RDF form. It should be noted that some cement kilns require the SRF to be finely shredded because it is "blown" into the kiln.


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