In view of the position of the environmental committees of Fanna and Maniago, which would like to qualify co-incineration as a harmful practice and contrary to the principles of circular economy, Buzzi Unicem wishes to provide the following explanations on an issue of fundamental importance for proper waste management, maximum utilization of recoverable fractions and savings of non-renewable fossil resources.
Solid Secondary Fuel (SSF) that can be used in the cement production cycle comes from the recovery of that fraction of waste which, at the end of separate collection, cannot be further reused or recycled. In particular, in order to be used as fuel these materials are carefully selected, processed and transformed into SSF.
This is a form of recycling of materials, however existing, whose alternative final destination would be disposal through incineration, landfill or export to other countries. They are not, therefore, materials taken from more valuable recycled material.
For these reasons, there is no doubt that the recycling of CSS in cement factories or other plants, such as thermoelectric power stations, fully complies with the principles of the circular economy and the European waste hierarchy. On this point, the Lazio Regional Administrative Court recently handed down sentence no. 219/2021, recognizing that "the phases of production and use of SSF-Fuel are carried out without danger to human health and environmental protection, thus placing this legislation within the more general framework of European policies for the creation and promotion of the so-called "circular economy”.
With reference to the considerations on the changed reference framework of the European directives on circular economy, the fact that waste to be used as fuel is not counted towards the recycling targets does not affect the qualification in terms of recovery, since recycling is one of the forms of recovery envisaged by the EU and - as recognized by the Lazio Regional Administrative Court - energy recovery is to be preferred to any other form of disposal that is hierarchically inferior. Material recycling and energy recovery are therefore two practices which are not contradictory but complementary instead.
It should also be noted that the production of SSF, in all its phases, allows a significant reduction in the amount actually intended for combustion: suffice it to consider that starting from 100 kg of undifferentiated waste, about 30-40 kg of SSF are obtained, following the additional selection and differentiation carried out in the production system of the SSF.
Subsequent to its production, the use of SSF in cement plants allows the useful exploitation of an existing production process, without significant changes in emissions, and actually contributes to reducing overall emissions, avoiding those due to landfill or incineration.
Finally, we reiterate that the many continuous studies on the environmental impact of the cement plant, both by the Company and - most importantly - by the relevant authorities, have never detected any anomalous or alarming data in the area concerned, especially as regards PCBs.
In this regard, in fact, we must bear in mind that there are many combustion processes, not only industrial but also civil and agricultural ones, that can generate dioxins, furans and PCBs. If we then add the fact that studies carried out by ARPA FVG have identified a situation of contamination by similar micropollutants in areas not subject to the fallout from the cement plant, we may deduce that our emissions are compatible with the context in which the cement plant is located and that, at the same time, emission checks should also be performed at other possible sources.
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