UKWIN has produced a substantial response to Defra’s call for evidence to inform the UK Government’s review of waste policies.

Our full 87-page submission is now available to download from:

The document was produced in consultation with all of our members. We would like to thank everyone who participated in the creation of UKWIN’s submission.

The whole process has involved many dedicated people devoting much time and careful consideration to a wide range of waste management issues.

UKWIN is grateful for the pioneering work of the zero waste movement, and the entire Zero Waste Declaration (A Bridge Half Built) has been appended to our consultation response, along with a critique of the WRATE waste modelling tool.

We are confident that UKWIN’s submission reflects the views of the anti-incineration community.

Several representative paragraphs are reproduced below:

  • UKWIN believes that the current “dump it or burn it” mindset undermines sustainability and is fundamentally hostile both to enhancing the environment and to the Government’s other objectives.
  • UKWIN sees zero waste contributing to reducing energy requirements, reducing CO2 emissions, reducing imports, and reducing damage to our environment. Incineration goes against all of these aims.
  • Current policies that profit the waste management industry at the expense of householders must be reversed. UKWIN calls for a hasty end to all subsidies for incineration thereby freeing up money to help reduce the fiscal deficit.
  • UKWIN calls for the introduction of an incineration tax (starting at a minimum of £40 per tonne) to ensure economic benefits reward resource efficiency, reduction, reuse, repair, recycling (precycling, freecycling, upcycling, etc.), composting and AD, and to add to the financial resources available to tackle the fiscal deficit.
  • Subject existing waste incinerators to greater scrutiny, including ending the self-regulation of incinerator bottom ash toxicity classification, increase the frequency of emissions monitoring and extend the number of emissions that are monitored – making greater use of continuous emissions monitoring systems, and impose tighter restrictions on emissions than is required by the Waste Incineration Directive (WID), and take more forceful action in response to exceedances.
  • UKWIN also calls for more stringent regulation of hazardous incinerator ash that is sent to landfill, to avoid further occurrences such as that at Bishop’s Cleeve.
  • Give communities the automatic right to appeal all incineration-related planning decisions, and make explicit that local opposition to waste incinerator proposals should be treated as a material planning consideration, alongside the public perception of health dangers associated with waste incineration.
  • Ensure that the financial rewards of segregating discarded materials are returned to those who segregate, allowing greater rewards for greater segregation.
  • Make the cost of waste services more transparent, e.g. by putting all public waste contracts and waste invoices on the Internet without redaction, so that householders can assess whether or not they are receiving value for money.
  • It should be noted that plastics do not release GHGs when landfilled, but they do when incinerated. In addition, when landfilled plastics can be mined at a future date, when economics allow, providing future generations with the benefit of those resources.
  • When comparing technologies in relation to climate change impacts, short-cycle (biogenic) carbon should be included in the assessment, and not discounted as if incineration of biogenic material is somehow carbon neutral.
  • Incineration diverts resources from recycling and diverts biogenic resources from composting and effective energy recovery via AD. The installation of incinerators, which are inherently energy inefficient, produce toxic emissions and massive quantities of CO2e and do not save on GHG emissions, should cease forthwith, and pending the achievement of zero waste, inert non-recyclables should be put to landfill.
  • UKWIN urges the Government to adopt the Zero Waste Alliance International (ZWAI) definition of zero waste (dated 29th November 2004).
  • UKWIN believes that building new waste incinerators is antithetical to working towards a zero waste economy, and should therefore cease.
  • Subsidies for incineration should be removed, e.g. incinerator bottom ash (IBA) should be subject to a higher rate of landfill tax. Additionally, a disposal tax that covers both landfill and incineration should be introduced (or at least a £40 per tonne incineration tax).
  • Working with local communities leads to both better decision making and a greater sense of ownership, helping to avoid lengthy and costly conflicts between communities, local authorities and waste companies regarding proposed waste facilities. Conversely, civil society in general and local communities in particular are alienated when incinerators are imposed against their will. Some have expressed experiencing their own local authorities acting as agents for the waste companies intent on forcing through decisions to build waste incinerators without due regard for the views of local residents in the vicinity of the proposed development.
  • In meetings held between waste industry representatives and UKWIN we have learned that incineration and the long-term “integrated waste management” contracts associated with incineration and with the provision of waste management services by a single company are major barriers to innovation and investment in advances in recycling and reuse.
  • A distinction needs to be made between facilities that are located higher in the waste hierarchy and facilities that follow the waste hierarchy. Burning material in an incinerator that could be recycled should not be justified by recourse to the notion that incineration is somehow better than landfill. Currently, such spurious arguments are advanced for each and every incinerator application, and this serves to further stifle innovation and to further alienate community stakeholders.
  • The Landfill Directive, the LATS system, the Landfill Tax and the fear of huge fines for exceeding biodegradable landfill allocations combine to greatly reduce the quantities of waste sent to landfill. Local authorities and waste contractors have, by and large, merely focussed on sending waste to the next rung of the hierarchy, turning to incineration as their response to landfill avoidance, rather than focussing on the higher rungs of the hierarchy to achieve zero waste.
  • Materials that cannot readily be reused, recycled or composted should be phased out of use.
  • Practices, such as incineration of valuable resources, act as barriers to recycling by diverting recyclables and by perpetuating the cynical concept of waste disposal, and therefore should cease.
  • There is a wealth of evidence that incineration is incompatible with, and works directly against, a high recycling strategy. UKWIN refutes the notion that high recycling and high incineration can be seen as compatible. Incineration is in fact a barrier to high recycling. The idea that one could have both high recycling and high incineration is a contradiction in terms.
  • Whilst 6.7% of the current waste stream may not be recyclable that does not mean that it is combustible and due to waste minimisation efforts the quantity of such waste should be expected to decrease in real terms. In fact, in a zero waste strategy this nonrecyclable waste should be a top priority for waste minimisation efforts and should not be used to justify waste incineration.
  • UKWIN notes that the WRATE (Waste and Resources Assessment Tool for the Environment) modelling software used to assist Life Cycle Analysis (LCA) ignores biogenic carbon and produces flawed results. See Appendix B for A Critique of WRATE.
  • Incinerators are associated with the unintended creation of persistent organic pollutants (POPs). In correspondence with the Environment Agency (EA) they have made it clear that planning authorities have a responsibility to honour the UK’s commitment to the Stockholm Convention and the obligations under the 2007 Persistent Organic Pollution Regulations to give priority consideration to alternatives to incineration that do not give rise to persistent organic pollutants (“Annex III substances”).
  • Despite the EA’s clearly-stated position, UKWIN has seen no evidence to demonstrate that local authorities are either qualified or willing to meet these responsibilities. Indeed, we have a wealth of evidence that shows that local authority planning officers routinely insist that the entire responsibility for POPs rests solely with the EA. In the event no authority takes proper responsibility for the UK’s compliance with the laws regarding the avoidance of unintended POPs.
  • UKWIN therefore calls upon the Government to issue clear guidelines to both planning authorities and the Environment Agency spelling out their respective roles and responsibilities in relation to implementing the UK’s POPs obligations.
  • Incinerators emit particles including nanoparticles. There is widespread concern amongst scientists over the medical risks that accompany the spread of these particles, both in general and, specifically arising from incineration processes.
  • There are sound economic arguments against waste incineration…UKWIN cites the following statement by the Policy Exchange to support our call for an incineration tax: “By introducing taxation on incineration a clear preference is signalled to reduce, reuse, recycle or compost where possible.”
  • Whilst UKWIN opposes the introduction of any new incinerators, we agree with and would like to reiterate the recommendation of the House of Commons Environment, Food and Rural Affairs Committee that: “Waste should only be used for energy recovery if it is not possible to re-use, recycle or compost it. To achieve maximum energy efficiency levels, planning consent for energy from waste plants must require heat to be captured and used”.
  • Landfilling is better than incineration for plastics, although the reduction, reuse and recycling of plastics are preferable. The Government acknowledges, for example in the 2007 Waste Strategy, that “burning plastics has a general net, adverse greenhouse gas impact due to the release of fossil carbon” and that this can “outweigh the returns of energy recovery”. Recycling, by contrast, shows “significant potential for carbon and energy savings through displacing virgin materials”. The academic literature strongly supports these conclusions. Landfill does not have the opportunity costs associated with incineration, because while incinerations require constant feedstock, landfills do not. Landfill sites also offer the potential of landfill mining in the future, so plastics that are not currently recycled can be stored in the ground and recycled at a later date when this becomes more technologically feasible and economically attractive.
  • …whilst some are content with a simplistic interpretation involving the slogan “zero waste to landfill”, UKWIN strongly believes that such one-dimensional interpretations fails to reflect the genius of zero waste, and that there is no place for incineration in a zero waste economy.
  • If residual waste is the excess that remains after all materials that can be reused are reused, and all materials that can be recycled are recycled, and all material that can be composted has been composted, then a zero waste economy should plan for a future with very little residual waste indeed. In such a zero waste future our members could expect to witness the fulfilment of our shared vision of a United Kingdom without incineration.

2 Responses to “UKWIN responds to Defra’s call for evidence”

  1. Seems reasonable to me. Need to remember that WRATE is for relative comparison not a predictor of accurate results and nothing else goes so far as WRATE in assessing waste supply chain performance. The EA should be congratulated and development of the software encouraged rather than just rubbishing its outputs.

    Secondly, DEFRA will no doubt print your doucment out and thanks to the huge margins that you have used, they will require 30% more paper than it should. This is an estimate but it might be worth thinking about if you want to be taken seriously.

  2. Yes, I’m not sure it would be an 87 page submission with a narrower margin!!!

    Still, some very good points and hard to ignore the call for an incineration tax given the current economic situation.

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