Implementation of climate finance

Waste, Cement and Climate Change: the case of India

Sanghi Cement1

Cement industry is looking to waste to energy solutions as a cheap alternative to fossil fuels. Photo: GAIA

In an earlier article published in October 2016 we looked at the growing trend towards using waste as replacement of fossil fuels in cement production, a practice that has been supported and encouraged by the GIZ with dedicated climate finance in several countries of the Global South, despite the severe consequences for climate change, air pollution and resource efficiency. We now take the chance to look more closely at the case of India, where this practice continues to pose environmental and public health challenges among communities.

Albert Einstein once said, “If I had an hour to solve a problem I would spend 55 minutes thinking about the problem and 5 minutes thinking about the solution.”

We are in a hyper problem solving age where solution seeking and making has become an assembly line phenomenon. For every problem that emerges we have a surplus of scientists, experts and consultants on standby to “solve it”. Solutions thus evolved create more problems than they set out to solve.

Cement feeds on plastic at the global level – a sound climate strategy?

The interest of the cement industry for waste-based fuels started in the mid-1980s and since then it has increased exponentially at the global level. Initially, the primary goal in substituting traditional fossil fuels by waste was to reduce production costs, as fuel consumption accounts for almost one-third of the cost of producing cement. However, as pressure has mounted on the cement industry over the environmental impact of cement production worldwide, the industry has made an effort to claim the environmental advantages of burning waste instead of traditional fossil fuels.

Indeed, cement production is a major contributor to climate change and it has been listed as the only non-fossil fuel producer in the top 90 companies responsible for 63% of all GHG emissions. In particular, the cement industry is responsible on its own for 5% of CO2 global emissions, and consequently, it has devised burning household and industrial waste (so-called alternative fuels) as the key strategy to presumably reduce its GHG emissions and pretend it’s not using fossil fuels. Using waste-based fuels instead of fossils fuels is technically known as co-incineration.

Co-incineration is a process wherein industrial and municipal waste is converted into fuel through pre-procerefuse-derived-fuel-250x250ssing techniques and introduced into the kiln to be used as fuel. In this way, the co-incineration process replaces the traditional fuels used in cement production, mainly petcoke (by-product of the oil refining process), by waste-based fuels. Waste-based fuels are often used in the form of Refused-Derived Fuel, which are pellets produced by shredding and dehydrating municipal solid waste municipal solid waste so that it can be used as fuel in cement production. While the cement industry claims this is environmentally beneficial, evidence of co-incineration worldwide suggests the opposite.

However, waste-based fuels include an important proportion of fossil fuels in the form of plastic, including tyres, fossil-based waste, oil waste – so in fact the substitution of fossil fuels as the industry claims is not real and therefore cannot contribute supporting any country’s climate strategy towards compliance of the Paris Agreement’s commitments.

Specifically looking at the case in India, the average composition of Refuse-Derived Fuels (see figure 1), shows that an important portion of materials that could have been recycled, reused or redesigned, such as plastics, paper, textiles and wood.

In this sense, co-incineration creates a vacuum-cleaner effect – it absorbs an important portion of waste that otherwise could have been recycled, reused or redesigned out of the production and consumption system, following the guidance of the Waste Hierarchy. This further exacerbates the increase of GHG emissions, given that the recycling of these materials would have been equivalent to more significant GHG emissions savings.

Average composition of Refused-Derived Fuels in India

Source: Dharmendra C. Kothari, Prashant V. Thorat & Sanjay Avhad, “Integrated Solid Waste Processing Technology”, Proceeding of National Conference on Frontier Technologies in Waste Management, AISSMS College of Engineering, Pune, Maharashtra, Volume 1, pp 9 – 13, Conference Proceeding

Moreover, the economic and political support for co-incineration creates a lock-in effect, whereby the waste management system, along with energy and climate policies, are stuck in this strategy over more environmentally and resource-efficient policies that would prioritise waste reduction, reuse and recycling. In this way, local governments are prevented from reorganising the waste management system in the cities and co-incineration becomes a key obstacle for the implementation of most effective climate and waste management policies.

Ultimately, the use of certain hazardous types of industrial waste or certain types of plastics as fuel are a key driver for the increase of air pollution, which added to a usual lack of monitoring, proper enforcement of regulations and technical procedures, exacerbates the pollution potential of co-incineration and calls for maximum precaution before promoting this procedure as a climate change solution.

What’s happening with waste in India

It is no doubt that countries like India are reeling under a waste crisis that threatens its environment and public health. However, contrary to Einstein’s notions, solutions to the crisis are emerging from a poor understanding of the problem at hand.

Over the last decade, a combination of rapid urbanization and economic growth has significantly increased the rate of material and energy flows in the economy. While the absolute quantity of solid waste has increased with more recyclable materials such as plastics, paper and metals, over 50% of the waste is still organic in nature. Most cities in the Global South, including India, have unplanned waste management systems which has resulted in large unmanaged open waste dumps, increased conflicts over waste disposal and pollution among other impacts.

In order to address the growing menace of municipal and hazardous waste, India has embraced waste co-incineration technology. In 2010, the Central Pollution Control Board (CPCB) approved a set of guidelines (updated in 2016) that facilitated the implementation of this scheme.

Several cement manufacturing units were given approvals by the pollution control agencies based on “trial runs” that tested any changes in pollution load due to waste burning. Needless to say, all the trial runs were successful. In theory, the process of co-incineration seemed the ideal almost magical solution to sort out India’s waste conundrum. However, ground realities have told a different story.

To begin with, the trial runs are usually carried out in “optimum conditions”, which is when the kiln operates at its optimum temperature and samples are taken at the stack. This does not account for upset conditions (or upset events) which are an unpredictable failure of air pollution or process equipment that result in an increase of air pollution and violation of emission-control regulations.

The US Environmental Protection Agency (USEPA) is among a few regulatory agencies that mandates documentation and reporting of upset events. The data from one such study conducted between 1999 and 2005 reveals the shocking frequency at which such upsets take place. Cemex reported 99 upsets between January and October 1999 and Swiss-owned Holcim Inc. reported 375 upsets during the same period at their plants in Colorado/US. Furthermore, cement kilns lack the pollution capture devices present in modern incinerators which makes them far more dangerous. According to the USEPA, cement kilns that burn hazardous waste produce 80 times higher dioxin emissions in the stack gases than those which use only conventional fuels.

Antecedents of the cement industry in India

It is needless to mention the fact that the regulatory systems in India lag far behind international standards and basic pollution monitoring procedures are seldom implemented. Indian cement plants are known to be notorious for their negative ecological and social externalities. In May of 2012, the High Court of Himachal Pradesh slapped a fine of US$15 million on Jaypee Cements (subsidiary of Birla UltraTech Cements), one of India’s largest cement producers, for flouting of environmental laws. In October 2016, the Maharashtra Pollution Control Board shut down a cement plant in Mumbai due to excessive pollution. Similarly, the Central Pollution Control Board has issued closure notices to 3 cement factories in June 2017 for failing to comply with pollution control norms.

In order to control the menace of pollution from the sector, India updated the pollution limits for cement plants in May 2016. However, industry has failed to comply with them despite repeated notices by the CPCB and the environment ministry, citing unavailability of technological suppliers.

Environmental experts have termed the new emission control laws as lax compared to countries like Germany, Australia and South Africa. Nevertheless the Indian cement industry has been demanding further dilution in standards.

GIZ keeps promoting co-incineration as a climate strategy in India

The GIZ has played a key role in promoting co-incineration in the Global South, as highlighted in our last article. The position of GIZ as a reputable technical expert has pitched it at an advantage where its advice is key in pushing environmental policies in India. Unfortunately, despite bringing the negative implications of co-incineration to the notice of the GIZ, it continues to propagate it in India.

Most recently, at the International Conference on Alternate Fuels & Raw Materials in Cement Industry 2017 the agency presented cement co-incineration as a climate mitigation strategy under the Nationally Appropriate Mitigation Action (NAMA) for India. The proposal promoted the idea of producing Refused-Derived Fuel (fuel derived from municipal waste) as a climate mitigation strategy – again, a false solution to waste management and climate change.

Furthermore, Germany’s role in promoting unclean technologies like incineration and Refuse Derived Fuels (RDF) in India is not a recent trend. In 2012, India’s biggest RDF processing company, Hanjer BioTech Energies, raised $40 million from Deutsche Investitions- und Entwicklungsgesellschaft GmbH (DEG). Hanjer was investigated for fraud and money laundering in 2014 by the Enforcement Directorate of India.

The case at the National Green Tribunal

Taking note of the poor regulations governing co-incineration of waste in cement plants and the evidence gathered and published, a public interest petition was filed with the National Green Tribunal challenging the poor regulatory due diligence. As a result, the Central Pollution Control Board (CPCB) was forced to amend the Environment Protection Act (section concerning cement). Following this, stricter draft guidelines covering safety issues during storage, transportation and pre-processing of waste were also announced. However, the implementation of these legislations is yet to be seen.

Given these ground realities and the poor track record of the Indian cement industry, the promotion of a potentially dangerous process like co-incineration is imprudent and the GIZ should stop the promotion of this practice without delay.

Looking forward…

The case in India illustrates the need to look at climate solutions closely and beyond the theoretical modeling. Solutions for the waste sector should be driven by climate concerns and be based on the Waste Hierarchy, which encourages preventing waste and expanding reuse, recycling, and composting programs — that is, aiming for zero waste — as one of the fastest, cheapest, and most effective strategies available for combating climate change.

Co-incineration, as it happens with incineration or landfill of waste, remain a disposal option which perpetuates an over-consumption and throwaway society – far from the climate smart future we need to build to avoid catastrophic climate change and comply with the Paris Agreement.

Guest article by Dharmesh Shah/ GAIA and Mariel Vilella / Zero Waste Europe

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