Silk purses, pigs’ ears….
A few things, but firstly: Someone had to ask. This month's shredding of the government's Waste Strategy 2000 at the hands of the Environment, Transport and Regional Affairs Committee, including a particularly inflamed tirade over the role of incineration within it, perhaps even set the scene a little. In the end it was down to Dominic Grieve, Conservative MP for Beaconsfield, in the House of Commons: "To ask the Secretary of State for the Environment, Transport and the Regions what assessment has been made of the quantity and effect of emissions into the air of dioxins resulting from the burning of coal slag, railway sleepers and the other materials being used for the incineration of animals culled for the purpose of eradicating foot and mouth disease..."
The National Environmental Technology Centre of AEA Technology has, in fact, calculated the amounts of air pollutants – including dioxins, particles and nitrogen oxides – released from the burning of carcasses and fuels on the pyres. At the time of writing, estimates of dioxin release levels are around the 10-20g mark – between three and six per cent of the total annual emissions of dioxins in the UK, or, as Environment Minister Michael Meacher put it in response, roughly equivalent to the amount released annually from domestic burning of coal and wood.
And, of course, they’re here.
The Climate Change Levy came into effect on the first of this month; targets have been agreed and it’s all to play for.
And the first IPPC permit in the UK has been issued, to Shotton Combined Heat and Power Ltd, covering a new Combined Heat and Power Plant operated by TXU, to supply energy (electrical power and steam) to the Shotton Paper Company plant on the Deeside Industrial Park in North Wales…
Draft guidance providing details of how the Environment Agency envisages inclusion of an IPPC Site Report with permit applications was issued earlier this year. Now, the primary function of a Site Report is to provide details of baseline conditions against which any subsequent impacts can be assessed. But the ramifications, it seems, go much further. According to Jonathan Steeds, director of the Environ-mental Remediation Division at WS Atkins, because many IPPC processes in the UK occupy sites with a relatively long industrial history, it is likely that the majority of IPPC Site Reports will identify contamination of some sort. In such circumstances, the guidance gives clear indication that Part IIA of the contaminated land regime should apply, providing that the site can be deemed to satisfy the legislative definition of contaminated land. On sites with a long history of industrial use, the current operator is likely to be held liable. “It is interesting,” as Steeds notes, “to speculate whether the result of such potentially adverse publicity could be industrial companies taking pre-emptive remedial action to achieve acceptable ‘base-line conditions’ prior to producing the Site Report.”