Why Oppose Incineration
Why UKWIN seeks a United Kingdom without incineration
The alternatives to incineration are cheaper, more flexible, quicker to implement and better for the environment. Rather than incinerating waste, local authorities should focus on maximising recycling and providing a weekly separate food waste collection for treatment by composting or anaerobic digestion (AD). Recyclables and biodegradables should be separated from the small amount of residue material. This residue should be stabilised by composting and then sent to landfill.
Incineration is a barrier to the Circular Economy
The traditional ‘linear economy’ is one based on extraction and processing, followed by consumption and disposal. In contrast to this, the circular economy is one where materials are neither burned nor buried, where products are designed to be re-used and recycled and repaired, and where nutrients are retained. One needs no ‘end of pipe’ technology such as incineration because the pipe never ends. The closed-loop circular ‘zero waste’ economy is better for the environment, the people and the economy. Incineration has no place in the circular economy towards which we should be working, as any material that cannot be re-used, recycled or composted should be designed out.
Incineration destroys valuable materials and nutrients, removing them from the circular economy. In addition to being a ‘leakage’ from this circular economy, incineration is also a serious barrier to achieving a more circular economy because incinerators are so expensive to build. Money invested in incineration cannot be invested in better collection, sorting and treatment infrastructure, and the presence of expensive infrastructure results in ‘lock-in’ into incineration that reduces the financial incentives to reduce, re-use and recycle.
Incineration depresses recycling
Recycling is harmed by incineration for various reasons, including the presence of incineration capacity and government subsidies for incineration discouraging investment in recycling, the long-term lock-in of money and feedstock to existing and proposed incineration capacity, and the fact that the true costs of incineration are not reflected in the price of treatment (Source).
Taken together, these factors serve to perversely disincentivise individual councils and businesses from maximising the high quality recycling of plastics, food and other waste, and in turn this reduces the market for such services hampering investment in research and development of technologies and construction of recycling facilities (Source).
An opportunity cost of investing in incineration capacity is that the financial benefits of reduction, reuse and recycling will be reduced for the host local authority, other local authorities and businesses. In May 2014 UKWIN provided the Environment, Food and Rural Affairs Committee with evidence that incineration harms recycling, including what the EFRACOM report describes as “data showing an apparent correlation between high rates of incineration and low rates of recycling” (Source).
Incineration wastes finite resources
Despite trying to brand incineration as ‘renewable energy’ projects, the feedstock does not in fact occur naturally and repeatedly in the environment and so is not ‘renewable’ in the common sense definition. Incineration relies upon fossil fuels such as plastic, and the remainder is processed material that should be recycled, composted or sent for anaerobic digestion to retain its nutrient value or to prevent virgin material from having to be used to replace what would be burned.
To quote the Environment, Transport and Regional Affairs Committee: “…We do not accept that energy from waste incineration is a renewable form of energy. Even if one considers that it meets the technical definition of renewable energy, it utterly fails to meet what might be called a ‘common-sense’ interpretation. A waste stream is only ‘sustainable’ in the most twisted definition of the word since sustainable waste management has as its cornerstone the minimisation of waste, and the explicit maintenance of waste streams for the purposes of incineration is in complete contradiction of this principle…” (Source)
Incineration exacerbates climate change
Incineration results in high levels of greenhouse gas emissions. For every tonne of waste burned, typically more than one tonne of CO2 is released into the atmosphere. This means that incineration has a higher carbon intensity than the conventional use of fossil fuels, and significantly higher than what most people would consider ‘low carbon’. By 2050 incinerators could be more than ten times the average carbon intensity of the electricity grid, making incineration a significant barrier to the long-term decarbonisation of the power supply and an obstacle to a low-carbon economy (Source).
Furthermore, by harming waste reduction, reuse and recycling incineration can result in significantly higher levels of greenhouse gas emissions than would have occurred had the waste been dealt with sustainably.
Incineration gives rise to legitimate air pollution concerns
In addition to greenhouse gas emissions that exacerbate climate change, incinerators (including gasification and pyrolysis plants) emit many toxins and pollutants, giving rise to public health concerns. Although incinerator fumes pass through expensive filter systems, modern incinerators still emit significant levels of dioxins, NOx and ultrafine particles that can be harmful to both human health and the natural environment.
Dioxins are a group of chemicals that are carcinogenic and act as endocrine disruptors. Dioxin emission levels from incinerators are typically measured twice a year by external assessors who have to give prior notice of their visits, so operators can ensure that a plant is running under optimal conditions for that visit. Even then, where problems are detected they are often blamed on unrepresentative samples or poorly calibrated equipment and are re-run. The assumption is not typically made that non-breech readings could be untrue and need to be re-run, so there is a bias towards under-reporting emissions breaches. Where more frequent or continuous measurements are made, total dioxin emissions have been found to be very much higher than those calculated from biannual measurements [De Fre and Wevers 1998 & Reinmann et al 2006].
In relation to incinerator emissions, there is not enough monitoring, not enough enforcement, and not enough transparency. Neither the Environment Agency nor the incinerator operators have adequately opened the monitoring and enforcement processes for public scrutiny.
Incineration overcapacity exists and is harmful
The UK has more incineration capacity existing and under construction than genuinely residual waste to burn, and there are many more incinerator projects in the pipeline. Locking our valuable materials into incineration is a serious long-term risk to UK resource security. Government-subsidised and Government-sanctioned incineration overcapacity harms the markets for recycling and reduces the marginal benefits of waste minimisation and re-use schemes, causing significant environmental harm. UKWIN has called on the Government to produce an incineration exit strategy that will allow for a move to a zero waste circular economy (Source).
According to guidance from the European Commission: “…over-capacity in incineration undermines waste prevention, re-use and recycling, drives waste imports to feed existing under-used facilities and can represent high-costs for the tax payers. Priority should be given to the development of the necessary infrastructures to ensure high re-use, recycling (including composting) rates including the development of the necessary separate collection systems…” (Source)
Many European countries have significant and widely acknowledged incineration overcapacity, e.g. the Netherlands, Germany and Sweden. Back in 2012 the UK was warned by the European Commission’s Dr Alan Seatter that “high waste incineration levels in Norway and Sweden should act as a warning to the UK” (Source) and by the European Commission itself that “…the UK should look to reuse and recycling and not to overcapacity of incineration – Countries like Denmark and Switzerland are burning much more than they should and that’s not good…” (Source). Unfortunately, these warnings from 2012 were not heeded, and the UK has substantially increased its incineration capacity whilst under-investing in re-use and recycling.
Incinerators cause a nuisance
Those living near incinerators report having had to deal with problems such as noise, odour, traffic, visual intrusion, worsened air quality and light pollution.
Despite assurances made at the planning and permitting stages that the facility would be safe and trouble-free, INEOS Chlor’s incinerator at Runcorn has been quite problematic. Within a six-month period there were two spillages of hydrated lime resulting in employees needing to go to hospital (Source). Additionally, the Environment Agency has received over a thousand complaints from residents, covering nuisances such as noise, odour, and dust (Source, Source).
MVV’s incinerator in Devonport, Plymouth has also generated many complaints from local residents, with one commenting that: “The summer was awful, all the flies, the rubbish, the smell. I am looking to move because we have had enough of it”, and another stating that: “It smells, it makes me feel sick” (Source). According to an ITV report: “Residents nearby have complained about the smell, the noise and flies in their homes. They say their worst fears have been realised” (Source).