Use of solid recovered fuels for heat production - analysis of Czech legislation

Abstract

The article is about solid recovered fuel (SRF) and its legislation possibilities to use them as a fuel in heating plants. This solution is quite popular because it brings solution of two very problematic tasks – the decreasing of waste landfilling and the end of fossil fuel (especially coal) combustion. Due to these arguments are there many producers which offer SRF (often in the pellets form) to conventional heating plants. However heating plant have flue gas cleaning technologies, which are able to combustion SRF and keep current emissions limits, the usage of SRF is forbidden for them. The reason is in the classification of origin material as a waste and the permission and limits as a waste combustion is required. The criteria and limits for waste combustion are much stricter and for heating plants is very difficult to reach them if it is possible. The article is about view of Czech legislation, where some of law had different interpretation about waste material and SRF combustion. Article compare requirements and results for SRF from waste and SRF from waste biomass. The interpretation is described from a view of waste, air protection, IPPC, EU ETS and support of renewable energy sources law based on Czech a EU law documents. The most important is origin of SRF. When the SRF is made by waste (municipal or industrial) all laws must assess final combustion technology as waste combustion technology, the support for renewable energy sources is not allowed (except biodegradable municipal waste) and CO2 emission permit is not required. With new regulation No. 169/2023 Coll. is possible to combustion SRF, which is based on waste biomass from forestry and agriculture. The permits and limits for combustion plants are same as biomass combustion, support for renewably energy sources is possible and CO2 emission permits are not required. Investment to SRF combustion technology is not advantageous, because purchase prize of SRF will be higher than standard waste but requirements for technology will be same. Meaning of the newest legislation was not in possibilities to use of more SRF in heating plant, but bring waste and air protection law into accord, because some of waste biomass was possible to combust, however it was waste by waste law.