Issue 5 of Eunomia’s Residual Waste Infrastructure Review was published on the 28th of November 2013. The Report reveals both residual waste treatment overcapacity and the constraining effect of long-term waste management contracts on recycling.

As Eunomia put it on their website: “residual waste treatment facilities already in the pipeline could limit the rate of recycling in 2020 for local authority collected (LAC) wastes in England to no more than 60%”.

This is a very conservative estimate, and UKWIN hopes that action is taken to combat the disincentive to recycling posed by incineration contracts that guarantee payment for incineration capacity irrespective of whether that capacity is actually used.

The Report’s lead author Adam Baddeley commented that: “It’s worrying that we are already in danger of limiting how far we can go with recycling in England. If we genuinely aspire to develop a circular economy, then we must shift the focus of investment away from residual waste towards options further up the hierarchy.”

The Government’s EfW Guide commented that: “At the more local level the risk that energy from waste can compete with, not complement, recycling does exist…Waste infrastructure has a long lifetime and care needs to be taken at the start to ensure systems can adapt to potential long term change and drive waste up the hierarchy, not constrain it”.

UKWIN’s experience with local authority procurement is that insufficient care has been taken to prevent constraints to future reduction, re-use, recycling and composting, especially in relation to the separate collection of food waste for Anaerobic Digestion and that recycling rates are already being constrained across the country. UKWIN recently made a submission regarding Defra’s oversight of the Waste PFI in Nottinghamshire.

The “Summary of Current Position for the UK” from the Eunomia Report states that:

  • “Based on our estimates of residual waste arisings in 2012/13 there is a ‘capacity gap’ of around 7.6 million tpa between the quantity of residual waste and the amount of treatment infrastructure capacity currently either ‘operating’ or ‘under construction’.
  • Without any change in residual waste quantities, however, there would be overcapacity of 13.8 million tpa if the 21.4 million tpa of waste treatment capacity that has planning consent reaches financial close and subsequent operation;
  • Planning consent is being sought for a further 2.8 million tpa of waste treatment capacity; and
  • A further 300,000 tpa of residual waste treatment capacity is currently in appeal following refusal of planning permission or is subject to judicial review.”

The Eunomia report also states that:

  • “Modelling of our central scenario suggests that the capacity gap between residual waste arisings and available treatment capacity will fall over time, decreasing from the current (based on 2012/13 arisings data) level of 12.9 million tonnes, and moving to a situation of potential overcapacity in the UK in 2017/18 of around 3.0 million tonnes, and rising to an overcapacity of 10.1 million tonnes in 2020/21…
  • As mentioned above, our model does not include potential future capacity, which has not yet entered the planning system, and which may result in earlier overcapacity. This is a situation broadly reflected in our ‘high’ infrastructure scenario in which the onset of overcapacity is in 2016/17, and potentially reaches around 20.3 million tonnes in 2020/21.” (High-level Analysis, Page 17)

The trend of waste arisings slightly falling in the future adopted by Eunomia are generally consistent with those set out in the Government’s Forecasting 2020 Waste Arisings and Treatment Capacity Report (Revised October 2013), but both assume a general fall in waste. Eunomia have also set out a Short Waste Prevention Wish-list which highlights the sort of thinking that can help bring us even lower waste arisings in the future.

The Eunomia report perhaps underestimates future levels of RDF export, which therefore overestimates any capacity gap. As UKWIN discussed in October 2012 it is not a good idea to create new RDF-burning incinerators in the UK.

UKWIN maintains the position that there is already more waste incineration capacity operational and under construction than genuinely residual combustible waste that would be available to burn, so even if incinerators were the best way to treat that waste (which they are not), this would not justify building new incineration capacity in the UK.

In related news, Ann Ballinger (a Senior Consultant at Eunomia, but who was not writing on behalf of Eunomia) posted a very insightful article on the Isonomia blog in November 2013 entitled ‘What’s wrong with WRATE‘. It sets out some of the problems with WRATE and its default assumptions that can unfairly flatter incinerators compared to other waste treatment options.

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