1. What are the benefits of the proposals?

The Northacre facility will generate low carbon energy from residual waste that would otherwise either be sent to landfill or exported to Europe for energy recovery outside of the UK.

Government strategy recognises that energy from waste is preferable to landfill in the waste hierarchy and that the export of waste-derived fuel does not contribute to UK energy targets and is effectively a lost resource to the UK.

The Northacre facility would represent a £200 million capital investment in Wiltshire.

Once operational, the Northacre facility will support 40 permanent, skilled jobs. During the construction phase, at peak activity, there will circa 450 construction workers employed.

The capital and annual on-going annual investment will result in local economic benefits.

The Northacre facility will include electric vehicle charging stations to support the transition to electric vehicles in Westbury for staff, suppliers and visitors. This reflects our fundamental commitment as a business to mitigating climate change.

In addition, the electricity generated will boost the local electricity supply network, unlocking development on the surrounding employment zone on Northacre Industrial Estate and nearby Hawke Ridge Business Park.

2. Why are you not pursuing the existing consent for a gasification facility?

The decision has been made to move from a gasification technology, to a conventional grate technology.

This technology is widely established and proven. It is used in ~90% of the UK’s 48 fully operating energy from waste (“EFW”) facilities and in over 400 EFW facilities across Europe. This will necessitate a new planning application / permission.

There are three primary reasons why the technology for the project is being changed.

In the latter in part of 2019, new standards were introduced, driven by European legislation requiring reductions emissions limits from industrial facilities such as energy from waste. These standards are derived from the “Best Available Techniques Reference Document” or BREF and means that conventional moving grate combustion technology must now be built to achieve the predicted performance of gasification technologies. As a result, the more challenging to deliver gasification option offered no advantages on emissions under these new standards when compared to tried and tested combustion technologies.

The investment decision in September 2019, influenced largely by the uncertainties with BREXIT at the time, shifted away from gasification technologies with less stable supply chains which could no longer offer competitive solutions or guarantee build times required for this £200m investment. The supply chains for a tried and tested conventional moving grate combustion technology are more established, and better able to offer competitive solutions whilst guaranteeing build times in a post-BREXIT UK. Therefore, it was not just technology type, but the deliverability that influenced the investment decision.

During development of the project, there has been an increased focus and effort on removing certain materials from waste streams, which NREL supports, with plastics being a recent example. Conventional moving grate combustion technology offers more flexibility with predictable performance to adapt to these changes in residual waste whilst generating low carbon energy.

3. Where will the waste come from?

The sources of the residual waste will include industries, businesses and trade premises, such as shops and restaurants, collectively called commercial and industrial wastes.  It will also include residual household waste, including from the adjacent waste treatment facility.

The focal point for the source of the waste will be commerce, industry and households within Wiltshire. Waste will also be sourced from neighbouring authority areas and surrounding region.

This catchment is consistent with the application site’s strategic allocation in the Waste Plan, noting that the Plan expects that: strategic facilities will serve either large areas within, or the entire Plan area. Additionally, they may also serve areas of Wiltshire and Swindon and surrounding local authorities in a more sub-regional context.

 The strategic site concept is consistent with national Government strategy which specifically acknowledges that there is nothing in the legislation or the proximity principle that says accepting waste from another council, city, region or country is a bad thing and indeed in many cases it may be the best economic and environmental solution.

4. How much waste will be processed at the facility?

The capacity of the Northacre facility, or any EfW facility, is based upon a combination of the thermal capacity of the plant, the amount of energy in the waste that it treats, and the number of hours per year the plant operates. Based upon NREL analysis of the variables, it is predicted the maximum likely waste throughput will be 243,000 tonnes per year.

It is estimated a person in the UK produces 409kg of waste annually. Of that, the Government estimates that 45% is recycled and 24% is sent to landfill. To put that into context, nearly 100kg of waste a UK adult produces every year is sent to landfill. When you consider the UK’s population is roughly 68 million, it means every year we send an estimated 6.8 million tonnes of residual waste to landfill every year. For business waste, recycling rates are better with over 50% being recycled.

5. Why has the tonnage increased from the previous planning application?

The tonnage has increased from 160,000 tonnes per year to a maximum of 243,000 tonnes whilst maintaining the same footprint and building volume. The increase in throughput reflects a number of factors.

First, during the development of the project, there has been an increased focus and effort on removing certain materials from waste streams, which NREL supports, with plastics being a recent example. This reduces the energy content in the residual waste, as a result we forecast a different maximum volume.

Second, the more established combustion grate EFW technology offers an improved economy of scale compared to the original proposals for gasification solutions.

6. What are the outputs from the process?

The main output will be the generation of energy, typically in the form of electricity, although the Northacre facility would also be able to export heat, in the form of either steam or hot water.

When configured to only export electricity, the Northacre facility would have a generating capacity of 25.6MW which would produce 201,830MWh/year which is sufficient to meet the average annual domestic power requirements of just over 54,000 homes.[1]

NREL is working to identify customers for potential use of heat and government strategy recognises the difficulties in securing a heat off-take prior a facility is actually operational.

In terms of residues, the Northacre facility would produce about 52,000 tonnes per year of bottom ash, referred to as IBA. This is an inert material from which metals will be removed for recycling. Thereafter, the IBA can be recycled as an aggregate for use in the construction industry.

The other residue is air pollution control residues (APCR) from the flue gas cleaning plant of which there would be about 9,000 tonnes per year. This is a powdered material that can be used to produce other materials or disposed of to landfill.

At the outset, all power is most likely to be exported to the grid, through a connection point at Frome. However, in the longer term NREL hopes to supply power to local business directly with a private wire network which could link to Northacre Industrial Trading Estate and Hawke Ridge Business Park who are constrained by power from the local grid.

[1] Based on UK average domestic consumption of 3.7MWh per household per year. Source Ofgem

7. How do we know that it will be safe?

The proposed development is based on technology that has been successfully and safely deployed around Europe for many decades.

In terms of human health impacts, Public Health England has been undertaking an ongoing major Government funded study since 2012 into the potential health effects of emissions from waste combustion. PHE has repeatedly reported that it has not found a consistent or conclusive linkage between energy-from-waste plants and adverse human health. Accordingly, Government policy continues to support the development of energy-from-waste facilities.

Safety and environmental issues are regulated by the Environment Agency, which will determine whether to grant the facility an Environmental Permit. These regulations have significant teeth; non-compliance can lead to prosecutions as well as closures.

8. Are the emissions harmful?

Waste combustion involves very heavily regulated emissions control and the application of best available techniques to ensure that emissions remain within clearly stipulated legislative limits. These limits, which were already extremely stringent, have been recently tightened further.

The height of the stack has been specifically calculated to ensure that emissions are sufficiently dispersed such that their effects can be categorised as negligible for all pollutants, in all locations, over all time periods.

Emissions are monitored 24 days a day and the data is submitted to the Environment Agency and is publicly available.

9. Will the facility be noisy?

The majority of noise emitting operations will take place within a fully enclosed building which provides sufficient noise attenuation to ensure no unacceptable noise impacts would occur.

Noise assessments have been carried out to demonstrate that no unacceptable noise impacts occur and the results of those assessments will be in the Environmental Statement. The results of the assessment would be used establish planning conditions limiting noise levels. The Northacre facility would then have to operate within the set limits.

10. How much CO2 will be saved from the facility?

The Northacre facility would produce low carbon energy. The carbon assessment indicates that the Northacre facility would typically save approximately 58,000 tpa CO2 equivalent over a default position of the residual waste that would be treated at the facility being landfilled and the equivalent energy generation occurring via a gas fired power station.  This approach / method of calculating CO2 savings has been accepted by the authorities on numerous other EfW projects.

11. Would the facility be in conflict with the governments policy on climate and Net Zero commitments?

The Northacre facility would be aligned with the Government’s current approach in relation to climate change.

The Committee on Climate Change (“CCC”) Technical Report (May 2019) states: Additional private sector investment is required in alternative waste disposal facilities – AD [anaerobic digestion], MBT [mechanical biological treatment] and incineration to deal with waste diverted from landfill. There are risks of offshoring waste if this doesn’t happen.”

Offshoring in this context means waste exports.  In short, it is wrong and irresponsible for the UK to meet its zero carbon targets by burdening other countries with our waste carbon.

Within the CCC report’s section on Power and Hydrogen Production, the CCC emphasises the continued roll out of renewables and low carbon technologies. It says CO2 emissions from such technologies should reduce over time by a movement towards Carbon Capture & Storage (CCS).  “CCS could provide firm and mid-merit low-carbon power, with significant deployment potential. As well as in application to gas-fired power stations we consider potential use of CCS in combination with bioenergy.” [EfW is a partial bio-energy technology.]

A further reduction in carbon emissions from EfW is anticipated through the de-carbonisation of the residual waste itself as legislation and society move away from high (non-biogenic) carbon products such as plastic.

The CCC report recognises the ongoing need for baseload low carbon technologies because of the intermittency of renewables (i.e. they require the wind to blow or the sun to shine). Thus, the CCC offers support for: “non-intermittent low-carbon plant such as nuclear power or gas or bioenergy plant with CCS”.

12. Wiltshire Council acknowledged a Climate Emergency in February 2019. What does this mean for Northacre?

The Council statement, when taken alongside the endorsement by the Committee for Climate Change, represents a significant policy development which we at NREL wholeheartedly support. The Northacre facility and other energy from waste plants are part of the solution.

We all need to do more to reduce single-use plastics, re-use items and recycle as much as we can. After this, diverting this residual waste from landfill and reducing waste exports to Europe to capture the energy locally is an important step in the right direction.

13. How much additional traffic will the facility generate?

All of the residual waste that would be treated at the Northacre facility is already being transported by road within Wiltshire and the wider area. The development of the Northacre facility would affect the pattern of travel of that waste.

We estimate that the plant will generate a net contribution of around 53 HGV net movements (lorries entering and leaving the plant) per working day when both the deliveries to the Northacre facility and the savings on HGV traffic on the highway made when material outputs from adjacent waste treatment plant directed to the Northacre Facility are considered . This compares to a net contribution of circa 42 HGV net movements per working day under the previous proposal, approved in 2019. Whilst there is an increase in throughput tonnage and HGV numbers, the comparison of daily traffic flows shows no significant changes arising from the development, with the increases in general traffic on local roads all well below 1% and specifically less than 0.1% on the A350. Such changes in traffic levels are imperceptible.

14. What route will the lorries take and how can you be sure they won’t use The Ham or Station Road?

The Highway Authority has imposed weight restrictions on Station Road to limit its use by HGVs. Additionally, a traffic management plan is already in place for the neighbouring Hills waste management facility, which prevents HGVs using The Ham or Station Road, and it has previously been agreed with Wiltshire Council that the same can be adopted in respect of the development of the Northacre facility.

15. Will the air quality in Westbury be affected?

Operation of the Northacre facility will have a negligible impact on air quality on all locations, for the reasons previously described.

16. Why are you connecting the facility to the grid at Frome rather than locally in Westbury?

NREL applied to Scottish and Southern Energy (SSE), the local grid company, for a connection to the local grid. SSE determined the most suitable location for this connection was at Frome, which is a matter for them to determine as owners and operators of the local grid.

Grid connection is complex and can only take place where there is capacity available without needing to make unfeasible / unrealistic changes to the network. Thus, relatively distant grid connections are not an uncommon feature of many power generating facilities.

17. How long will it take to construct the facility?

The typical construction period for a Facility such as that proposed at Northacre is 36 months.

18. How has the visual impact of the updated proposals been addressed?

The landscape and visual impact assessment carried out by NREL follows best practice guidance set out in The Landscape Institute’s Guidelines for Landscape and Visual Impact Assessment (version 3). This concludes that the influence of industrial development upon the surrounding area is well established and acknowledges that the existing planning consent for a similar scale facility exists but has sought to include further mitigation in the design features.

19. Who is the technology provider?

There are multiple providers of this technology type and NREL has not yet procured a supplier or suppliers.

20. Why was Westbury chosen for the Northacre facility?

In 2013, Wiltshire Council allocated the whole of the Northacre Industrial Estate as suitable for strategic scale waste management facilities. Plans for this allocation were consulted upon at the time. The need for the Northacre facility and the suitability of the location have been established by previous planning permission granted in July 2019.

21. Why is the waste not being recycled & how will the facility impact recycling efforts in Wiltshire?

The Northacre Facility will turn thousands of tonnes of the region’s commercial and industrial residual waste into low carbon energy that would otherwise be buried in landfill sites or needlessly exported to Europe as fuel for similar EfW facilities.

Residual waste is waste material which is left over after economically recyclable material has been removed from the waste stream.

It is right that society aims to achieve very high levels of recycling. The Northacre facility does not hinder or compete with recycling efforts, but instead goes hand in hand by providing a solution to non-recyclable commercial and industrial  residual waste. However, even with policy intervention and increased recycling in Wiltshire and the surrounding regions, over 200,000 tonnes of commercial and industrial residual waste will still require a disposal solution by 2035, which should not include landfill.

22. Will the Northacre Facility be incinerating plastic or any other materials that could have been recycled?

The input waste for Northacre will be non-recyclable, residual waste from commercial and industrial outlets. This mix may include some plastics and that’s because not all plastic can be recycled and unfortunately, not everybody recycles responsibly. We wholeheartedly support the waste hierarchy and support a move for legislation which sees manufacturers move away from products such as plastic, instead using responsible products and packaging. We also support better recycling labelling to encourage both businesses and individuals, to refrain from putting recyclable material in their waste bins, which then becomes too contaminated to recycle. As a society we must all recognise the part we play in helping England reach the Government targets of 65% recycling, by 2035.

23. How can this be described as renewable energy when waste is being incinerated?

Energy from residual waste is a partially renewable energy source, sometimes referred to as a low carbon energy source. The energy it generates is significantly cleaner and less carbon producing than traditional sources and provides a responsible solution to the ever-growing problem of how UK business and wider society manages its waste. Landfill is the worst option for disposing of non-recyclable waste at scale. The energy produced by facilities such as Northacre is simply a useful by-product of this process.

24. Is it better for the environment to put the waste in to landfill rather than incinerating it?

The Committee on Climate Change (“CCC”) Technical Report (May 2019) states: “Additional private sector investment is required in alternative waste disposal facilities – AD [anaerobic digestion], MBT [mechanical biological treatment] and incineration to deal with waste diverted from landfill. There are risks of offshoring waste if this doesn’t happen.”

The Committee on Climate Change’s Sixth Carbon Budget Report published in December 2020 evidences the waste industry’s current contribution to overall greenhouse gas emissions is 6% – of which 60% of those emissions are from landfill.

Our mission is simple, we need to do more to prevent non-recyclable commercial and industrial  residual waste going to landfill and the Northacre facility is part of the solution available now which will help to achieve this, by reducing greenhouse gas emissions by approximately 58,000 tonnes per annum.

25. What is the expected impact on air quality and will any emissions be detrimental to our health?

The core technology has been successfully and safely deployed across Europe for many decades. Public Health England’s risk assessment remains that modern, well run and regulated municipal waste incinerators are not a significant risk to public health, which is supported by our detailed assessment on the impact on local air quality. Emissions from the facility would be tightly regulated by an Environmental Permit (EP) for the facility and will include limits on emissions These limits, which were already extremely stringent, have been recently tightened further. Emissions will be monitored 24 hours a day and the data will be submitted to the Environment Agency (EA) and made publicly available.

26. Is Northacre under a PFI contract and are we, the public, paying more for this incinerator?

The Northacre facility is backed by private investment and the input commercial and industrial residual waste for the facility will be secured through a series of contracts with a number of waste management companies to serve the wider market, and not through a direct public service waste contract. PFI was used to finance important infrastructure projects, which, in the past, has included some EfW facilities.

27. Why can this waste not be sent to other facilities?

The UK has a significant shortage of EfW facilities, such as Northacre, to dispose of all the non-recyclable rubbish we all produce. The operating facilities in neighbouring counties are already functioning at full capacity and even if we achieve the government’s ambitious target of 65% recycling by 2035, we will still need more facilities, like Northacre, to avoid sending material to landfill.

28. Westbury already has too many HGV’s on the road, why are you adding more?

All of the residual waste that would be treated at the Northacre facility is already being transported by road within Wiltshire and often, even further afield by being needlessly transported to other EfW facilities in Europe. The development of the Northacre facility would affect the pattern of travel of that waste but in turn, reduce HGV emissions by reducing the distance of travel required for the waste – which has a positive impact on the UK as a whole.

Our transport assessment shows that comparison of daily traffic flows shows no significant changes arising from the Northacre development, with the increase in traffic on local roads for this proposed development being well below 1% and specifically less than 0.1% on the A350.

29. What are the benefits of the facility to Westbury?

The project represents a £200 million investment in the local economy and a major new source of employment including many highly-skilled permanent roles. The project will turn 243,000 tonnes of the region’s commercial and industrial residual waste into low carbon energy; enough to power 48,000 homes. We believe this to be very much part of the Green Recovery, which will contribute to the UK achieving its ambitious net zero-carbon policy.

It is our responsibility to develop the best possible project and, if granted permission, we would have an opportunity to build a state-of-the-art facility which addresses the pressing need for a sustainable long-term solution, to non-recyclable waste in Wiltshire by reducing landfill’s contribution to climate change. Northacre Renewable Energy is ready and committed to play its part in the transition to a low carbon economy.