In line with WRAP’s research which warned against moving from landfill to incineration, the Chief Executive of WRAP Liz Goodwin has warned against incineration overcapacity.

According to the report WRAP calls for curb on EfW growth by Food Manufacture: “The current growth in energy-from-waste (EfW) incineration plants around the UK needs to be restrained by central government, the Waste & Resources Action Programme (WRAP) has said, to allow for a more resource-efficient ‘circular’ economy.”

At the same event, the Confederation of Paper Industries (CPI) David Workman asked: “Are we going to get to the stage of having huge overcapacity in EfW? …This seems to pose a potential threat to the idea of a circular economy” and Goodwin stated that: “We mustn’t let EfW capacity become so large that we can’t recycle as much as we want to.”

Back in September 2012 the CPI stated that: “Subsidies for Energy from Waste and large scale energy only biomass should be phased out as they put at risk supplies of the Paper Industry’s basic raw materials – recycled fibres and wood pulp”.

Dr Alan Seatter, deputy director general at the European Commission’s Environment DG, has also recently warned against incineration overcapacity. He is reported by letsrecycle as stating that: “There is an opportunity in the UK to go to a different stage and leapfrog the incineration stage” through measures such as increased waste segregation, and warning that “high waste incineration levels in Norway and Sweden should act as a warning to the UK”. MRW reported Seatter as stating that: “Britain has the opportunity avoid overcapacity and can leapfrog the incinerator stage to cut waste generated in the first instance…”

This is reminiscent of other recent comments from the European Commission, including the statement by European Commissioner for the Environment Janez Potočnik that in relation to plastics: “Today, even in countries with high recovery rates, there is simply not enough plastic available for recycling because most of it goes to energy recovery. A dominance of energy recovery over recycling is not acceptable in the medium-term…” and the comment by William Neale (member of cabinet for European Environment Commissioner with responsibility for waste) that: “We have to have a circular economy concept, so it’s highly important that we’re pumping back materials into the economy rather than burning or burying them.”

Furthermore, back in March 2012 a European Commission spokesman stated that: “The big challenge is to reduce the amount of waste that is sent for incineration which could be recycled instead. In the UK there is a decrease in the proportion of waste that is going to landfill, which is good, but this is still a high proportion of the total waste…To solve this, the UK should look to reuse and recycling and not to over capacity of incineration – Countries like Denmark and Switzerland are burning much more than they should and that’s not good. There is an opportunity for the UK to take positively; I hope they will move in the right direction.”

Of course, talking about ‘avoiding incineration overcapacity’ ignores the question of whether we already have overcapacity. As UKWIN reported in September 2012 the Government has not been monitoring overcapacity. Issue 3 of the Eunomia Residual Waste Infrastructure Review from November 2012 concluded that the UK could have more residual waste treatment capacity than residual waste by 2015, but as UKWIN pointed out at the time their definition of overcapacity was whether residual waste treatment was greater than current mixed waste arisings that could be treated at such a facility.

UKWIN’s view on overcapacity is that, as the amount of ‘residual’ waste is expected to reduce but residual waste treatment capacity is expected to increase, we should be looking at whether there is already more incineration capacity built or under construction than current and future available combustible genuinely residual waste (and that conclusion is reached even before one gets into the question of whether such material would be better treated through means other than incineration, even if that material were to exist).

UKWIN’s view is that incineration has no place in a circular zero waste economy, as any material that cannot be re-used, recycled or composted should be designed out. Working towards more efficient use of waste is also of great interest to the European Commission.

A recent European Commission proposal for a new general Union Environment Action Programme to 2020 (“Living well, within the limits of our planet”) carries forward the work of the Roadmap to a Resource Efficient Europe which the European Parliament endorsed in May 2012.

The November 2012 European Commission proposal states that:  “…market-based instruments that privilege prevention, recycling and re-use should be applied much more systematically across the EU. Barriers facing recycling activities in the EU internal market should be removed and existing prevention, reuse, recycling, recovery and landfill diversion targets reviewed so as to move towards a ‘circular’ economy, with a cascading use of resources and residual waste close to zero…In order to turn the EU into a resource-efficient, green and competitive low-carbon economy, the programme shall ensure that by 2020: …(d) Waste is safely managed as a resource, waste generated per capita is in absolute decline, energy recovery is limited to non-recyclable materials and landfilling of recyclable and compostable materials is effectively eradicated… This requires, in particular: …(e) Fully implementing EU waste legislation. This will include applying the waste hierarchy and the effective use of market-based instruments and measures to ensure that landfilling is effectively phased out, energy recovery is limited to non-recyclable materials, recycled waste is used as a major, reliable source of raw material for the EU, hazardous waste is safely managed and its generation is reduced, illegal waste shipments are eradicated and internal market barriers for environmentally-sound recycling activities in the EU are removed.”

Appendix 6 of the Impact Assessment identifies incineration subsidies as a barrier to the implementation of the waste hierarchy: “Concerning the application of market-based instruments aiming at creating the economic conditions to support the waste hierarchy, the main challenges are related to: …In some MS [member states], presence of harmful subsidies (e.g. to support incineration);…”

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