8^th January 2025 – An Open Letter

Anna Turley MP
24 Palace Hub
28-19 The Esplanade
Redcar
TS10 3AE

Dear Anna,
I write in response to your open letter addressed to Redcar and Cleveland Borough Council (RCBC) published on 2^nd January 2025 noting your objection to the Tees Valley Energy Recovery Facility (TV ERF) project, of which RCBC is one of seven project partner authorities.

As you will be aware from the briefing provided to you by project officers in October 2024, the partner Councils have been working for several years now to find a sustainable long-term solution for treating our region’s residual waste – which is the waste left over after recycling. We are currently in the final stages of a lengthy competitive procurement process, and expect to conclude this in 2025 with the appointment of a Tenderer.

The partner authorities each have a statutory duty to safely manage thousands of tonnes of residual waste produced each day in our respective regions and this is one of the most essential day-to-day functions of any council. In this context, any solution for meeting this statutory obligation must, as priority considerations, be safe, reliable, sustainable and affordable. The TV ERF project is the only solution with the potential to meet all of these criteria, subject to the outcome of the procurement process.

With existing long-term residual waste treatment arrangements coming to an end from 2026, the process to find an appropriate long-term alternative began during your previous tenure as MP for Redcar and has included the following milestones:

• The development of the Strategic Outline Business Case in 2018
• The development of the Tees Valley Joint Waste Management Strategy, supported by a Strategic Environmental Assessment. These were subject to an initial Scoping exercise with Statutory Consultees, prior to undertaking a comprehensive 8-week public consultation process. The documents were finalised and agreed by the councils in early 2019.
• The Outline Business Case supporting the development of a new-build Energy Recovery Facility was agreed in 2019. This included a detailed and comprehensive Site Selection process which considered 176 different sites across the Tees Valley against specific criteria. This ultimately identified the former steelworks site on Teesworks as the preferred site for development.
• Outline Planning Permission for the TV ERF was granted in July 2020. The application, which was supported by a comprehensive Environmental Impact Assessment, was subject to full public consultation as required by the regulations and this included the display of site notices, an advertisement in the local press and neighbour-notification. In addition, consultation was carried out with internal Council service teams and a range of external statutory and non-statutory bodies. In arriving at the decision on the application the Council (RCBC) considered all of the comments it received in respect of the proposal.
• In July 2020, the OJEU Notice to commence the procurement was published.
• The site was granted full planning permission by RCBC in July 2023, following the submission of Reserved Matters applications earlier in 2023. Once again, the submission was the subject of a further round of public consultation as required by the regulations, including the display of site notices, an advertisement in the local press and neighbour-notification. Further consultation took place with a range of stakeholders and the public comments received in respect of the application were given full consideration in arriving at the final decision.
• An Environmental Permit for the TV ERF was granted by the Environment Agency in August 2024, following approximately 2.5 years of detailed consideration, including two rounds of public consultation.

Central to our long-term waste management strategy is to decrease overall waste volumes; increase recycling rates and send as little as possible to landfill. But even under the most ambitious future recycling and waste-reduction scenarios, there will still be a significant proportion of residual waste to manage over the lifetime of the TV ERF project and into the foreseeable future.

In your letter you refer to Defra’s Residual Waste Infrastructure Capacity Note and the accompanying announcement published on 30^th December 2024 expressing the Government’s intention to introduce additional requirements on new EfW development.

Far from preventing the development of the TV ERF, the Defra study and announcement reconfirms the importance of the project for the following reasons:

• The TV ERF secured full planning permission in 2023 and an Environmental Permit in 2024. As such, the TV ERF has been factored into Defra’s calculations as consented capacity (as of October 2024). Defra notes that the vast majority of “consented capacity” included in the study comprises “merchant” facilities with no underlying local authority contract, and that this capacity may or may not be delivered in practice because it remains subject to commercial conditions. The TV ERF does not fall into this category, since it will serve a known, demonstrable, local need for treating waste under the control of the partner authorities.
• To underscore the long-term local requirement for the TV ERF, the Defra capacity study also refers to Government’s target of achieving a national average residual waste volume of 287kg per person per annum by 2042 – which is approximately a 50% reduction on current levels. This means that, even with dramatically increased recycling rates locally by 2042, and without making an allowance for increased overall waste volumes associated with population growth, the partner authorities can still expect to have to treat more than 400,000 tonnnes of residual waste each year through energy recovery, or landfill in the absence of EfW. In practice, this figure is likely to be higher.
• The new TV ERF facility will be more efficient and will operate to significantly tighter emissions limits than existing older facilities – deploying the best available technologies and techniques. It will comply with, and likely exceed, all existing and future regulatory requirements regarding efficiency, emissions and other regulatory factors.
• The TV ERF will be Combined Heat and Power (CHP) enabled, thereby potentially allowing export of low-carbon heat from the facility to surrounding users in future. It has also been specifically designed to be Carbon Capture (CCS) ready, which will enable the deployment of carbon capture technology subject to a viable business case. The project partners applied to DESNZ for CCS funding in 2023 as part of the East Coast Cluster, which would have enabled the deployment of CCS from the outset. Unfortunately, no EfW projects from the East Coast Cluster were selected for funding support – but the partners remain committed to pursuing this outcome and await the publication of the Track-1 Expansion documents.

In your letter you refer to being “inundated with concerns” from members of the community. We understand that this followed a period of canvassing for views by yourself on social media.

Naturally, we take the concerns and views of the community we all serve very seriously, and every major step of the process for delivering the TV ERF, over the last seven years, has been subject to community consultation as set out earlier in this letter.

There are several EfW facilities operating on Teesside currently, including the Haverton Hill facility in Billingham (where RCBC’s waste has been processed for decades) and the Wilton 11 plant in Redcar. Since entering service, these facilities have operated safely and largely anonymously for many years now with no individual or cumulative negative impact on local air quality, health or amenity.

In recent months, EfW operations have come under an unprecedented degree of media scrutiny following coverage by the BBC in October 2024. These news articles were highly selective in the information they presented and, for those involved in the day-to-day planning and operation of waste services, do not reflect the operational realities of recovering energy from waste.

We have also seen a recent increase in local activism from anti-incineration campaigners, some of which participated in this media coverage.

Unfortunately, this can only be viewed by the partner authorities as scaremongering. It is designed to undermine confidence in a vital, mature, proven technology we all rely on, both now and in the future, and generates unnecessary concern within the community.

The goal of the well-established anti-incineration lobby (which operates both nationally and locally) is to completely abandon EfW in favour of increased recycling and other technologies. In practice, the partner authorities are all already actively working to increase recycling and, indeed, increased recycling rates are factored into the capacity considerations for the TV ERF.

Recycling and energy-recovery are both necessary and complementary components of a circular economy. Although some other emerging technologies exist to treat residual waste (all through various forms of thermal treatment), none meet all of the aforementioned criteria of being safe, reliable, sustainable and affordable. Unfortunately, there is a historic litany of “alternative” residual waste treatment projects that have become expensive failures for local authorities and we should not join these ranks.

In your letter, you raise concerns that communities near to the TV ERF will be disproportionately affected, but this is predicated on the notion that the facility will create disamenity, which we do not agree with.

The TV ERF site at Teesworks is not only ideally situated to ensure the TV ERF can make use of heat offtake and carbon capture in future, but the project also regenerates a disused industrial brownfield site which otherwise has good transport network links; good access to electricity grid infrastructure and which is ideally situated to develop carbon capture and storage infrastructure should the opportunity become available.

Furthermore, as part of the procurement process, significant weighting has been given to the creation of social value for the local community or, in other words, delivery of additional community investment and benefits beyond the core service and associated new employment/local supply chain opportunities (both during construction and long-term operation). We look forward to being able to share more details about this once the procurement process is concluded.

Regarding day-to-day operations, EfW facilities are among the most highly regulated industrial installations in Europe and must meet strict conditions regarding emissions, odours and a range of other factors. They are subject to constant monitoring and often operate at just a fraction of permitted emissions levels with no detrimental impact on air quality. The Environment Agency granted an Environmental Permit for the facility in 2024, confirming its satisfaction that the proposals will comply with all applicable regulatory requirements, and the UK Health Security Agency has no objection to the continued use of energy recovery – building on decades of scientific study looking into potential health effects of EfW operations.

In practice, unlike landfill, all of the waste management activity occurs within the envelope of the building, which prevents odours, and waste is processed quickly, often within hours, so does not linger long enough to attract pests.

Finally, but importantly, unlike an open-market short term solution, the TV ERF will remain under the control and governance of the project partner authorities throughout its lifetime. This will provide another layer of scrutiny and control to ensure all planning, permit and contractual conditions are adhered to and any community concerns, however unlikely, are acknowledged and dealt with quickly.

All of the partner authorities committed to the procurement of the TV ERF in 2019 and are represented on its governance board. To abandon the project at this very late stage would not only expose the councils to significant abortive costs in the short term, but will also leave the councils hostage to fortune with respect to service costs and meeting their statutory waste management obligations in future.

We understand your desire to represent the view of residents who have concerns about the project, and we acknowledge these concerns, but these have been addressed many times over during the course of the project to date and, as such, do not change our position with regard to pursuing the TV ERF. It is also unfortunate that you chose to publish your views in an open letter in the first instance, rather than engaging in qualitative discussion with me directly as Project Sponsor, or with the Leaders of the partner authorities.

More information about the project is publicly available at www.tverf.co.uk and we are currently producing additional communications materials to address some of the misinformation and concerns about the project raised in recent months.

Yours sincerely

Denise McGuckin
TV ERF Project Sponsor

Cc (by email):

• Matt Vickers MP
• Chris McDonald MP
• Luke Myer MP
• Andy McDonald MP
• Jonathan Brash MP
• Lola McEvoy MP
• Luke Akehurst MP
• Mary Kelly Foy MP
• Grahame Morris MP
• Sam Rushworth MP
• Alan Strickland MP
• Liz Twist MP
• Chi Onwurah MP
• Catherine McKinnell MP
• Mary Glindon MP
• The Council Leaders and Chief Executive Officers/Managing Directors of Darlington Borough Council, Durham County Council, Hartlepool Borough Council, Middlesbrough Council, Newcastle City Council, Redcar & Cleveland Borough Council, and Stockton-on-Tees Borough Council
• Members of the TV ERF Governance Board