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Why Oppose Incineration

There are many reasons why people oppose incineration, including because:

Alternatives to incineration are less costly, more flexible, quicker to implement and better for the environment. Rather than incinerating waste, local authorities should focus on maximising re-use and recycling alongside providing a weekly separate food waste collection for treatment by composting or anaerobic digestion (AD). See UKWIN briefing on how local councils can improve their recycling rates.

Incineration harms recycling

For councils with above-average rates of incineration the is a clear correlation between higher rates of incineration and lower recycling rates. Data source: Defra.

Studies indicate that most of what is currently in the ‘residual’ waste stream is readily recyclable, meaning a significant proportion of what is currently incinerated could have been recycled or composted (Source). A Defra report published in August 2020 stated that: “Of total residual waste from household sources in England in 2017, an estimated 53% could be categorised as readily recyclable, 27% as potentially recyclable, 12% as potentially substitutable and 8% as difficult to either recycle or substitute” (Source).

If incinerators limited their feedstock to genuinely residual waste then it would free up more than half of their current capacity, undermining the rationale for building new incinerators in the UK.

Many councils are signed up to long-term waste contracts that involve incineration. These contracts usually ensure that the council takes on the primary risk of the incinerator not getting enough waste to burn, meaning councils are in effect penalised for not sending enough waste for incineration. Incinerators cost around £200m+ to build and that money cannot then be spent on recycling (Source, Source).

Contractual mechanisms such as ‘minimum tonnage guarantees’, ‘put-or-pay’ clauses and ‘banding mechanisms’ undermine the economic incentive to reduce, re-use and recycle even where funds are available (Source, Source, Source).

There is a correlation between high rates of incineration and low rates of recycling (Source, Source, Source, Source). Many councils have told the Government that their low recycling rates are due to their incineration-based waste contracts that undermine their incentive or ability to invest in improvements to their recycling service (Source, Source).

The Government has a target for England to achieve 65% recycling for municipal solid waste by 2035 and no more than 10% landfill (Source). As some residual waste is not combustible, the Government’s 65% recycling target implies that the rate of incineration should be no higher than a maximum of around 30%. However, in 2018/19, 43.8% of England’s local authority collected waste was incinerated (Source).

Investing in more EfW can negatively affect long term recycling rates. This investment needs to be paid for by an assured income stream, usually through contracts with local authorities to pay the EfW operator to take waste. Contracts are often lengthy – the majority are over 20 years. The terms of contracts, such as minimum annual payments, or a low fee per tonne of waste, can undermine the financial viability for the local authority of reducing waste, or sending it to other destinations such as recycling.

London Assembly Environment Committee Report: ‘Waste: Energy from Waste’ (February 2018)



Incineration exacerbates climate change

Incineration releases significantly more CO2 for every kWh exported to the electricity grid than the conventional use of fossil fuels, with the incineration of plastics being worse than coal (Source, Source)

According to the Committee on Climate Change: “Achieving significant emission reductions in the waste sector requires a step-change towards a circular economy, moving away from landfill and incineration (and the associated methane and fossil CO₂ emissions), and towards a reduction in waste arisings and collection of separated valuable resources for re-use and recycling” (Source)

Incineration results in high levels of greenhouse gas emissions. For every tonne of waste burned, typically around one tonne of CO is released into the atmosphere, and around half of this is fossil CO₂ (Source). 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’.

In 2019 the UK’s 53 incinerators released a combined total of around 13.3m tonnes of CO₂e, around 6.6 million tonnes of which were from fossil sources such as plastic (Source). The 6.6 million tonnes of fossil CO released by UK incinerators in 2019 resulted in an unpaid cost to society of more than £450 million (Source).

Even when methane generation from the landfill of biogenic material is taken into account, over its lifetime a typical waste incinerator built in 2020 is estimated to release the equivalent of around 1.6 million tonnes of CO₂ more than sending the same waste to landfill (Source). When electricity generation is taken into account, each tonne of plastic burned at that incinerator would result in the release of around 1.43 tonnes of fossil CO₂ (Source).

Around half of the biogenic material sent to landfill does not rot down and therefore does not exacerbate climate change, whereas were the same waste to otherwise be incinerated then all of the biogenic carbon in the waste would converted into CO₂ and released into the atmosphere (Source, Source, Source). Biostabilisation can be used to significantly increase the amount of biogenic carbon that is sequestered in landfill, meaning the landfill acts as a carbon sink for nearly all of the biogenic material which would otherwise be converted into CO₂ were the waste to be incinerated. Whilst incineration performs poorly against sending waste to landfill, it performs. even worse when compared with sending waste that has been biostabilised to landfill (Source, Source, Source).

Composition analysis indicates that much of what is currently used as incinerator feedstock could be recycled or composted (see recycling section above), and recycling what would otherwise be incinerated would result in significant carbon savings and other environmental benefits. Thus, incinerating waste comes with a significant ‘opportunity cost’ that has a significant adverse climate change impact (Source).

Decarbonisation of the grid has been so successful that EfW technologies can no longer be considered low carbon solutions. Decisions on future management must be based on the most current and accurate data possible to ensure climate change impacts are minimised.

The climate change impacts of burning municipal waste in Scotland (technical report) (Zero Waste Scotland, October 2020)



Incineration is a barrier to the Circular Economy

Moving away from incineration is a key element in moving towards a more circular economy because, instead of being destroyed, materials and nutrients can remain available thereby avoiding the additional extraction of finite resources

The ‘linear economy’ relies on extraction and processing, followed by consumption and disposal (via incineration or landfill). Extraction and disposal deplete finite resources and cause environmental and social harm. With a circular economy the value of resources is preserved, material and nutrients that are needed to create new products are maintained, and the most is made of existing resources. (Source)

Incineration has no place in the circular economy towards which we should be working. Incineration waste finite resource, squanders nutrients vital for the health of our soil, and is recognised as a ‘leakage’ to be minimised (Source, Source, Source). Products currently being incinerated should be treated at a higher tier of the Waste Hierarchy, and where that is not possible they need to be ‘designed out’.

“One of the central pillars of a circular economy is feeding materials back into the economy and avoiding waste being sent to landfill or incinerated, thereby capturing the value of the materials as far as possible and reducing losses”

Circular economy in Europe – Developing the knowledge base. European Environment Agency, January 2016.



The UK already faces incineration overcapacity

Calculation of residual treatment overcapacity based on UKWIN’s analysis of Eunomia’s Residual Waste Infrastructure Review, 12th Issue (Source)

The UK currently has more incineration capacity existing and under construction than genuinely residual waste to burn, and there are many more incinerator projects in the pipeline. 

Incineration overcapacity harms the markets for recycling and reduces the marginal benefits of waste minimisation and re-use schemes, causing significant environmental harm. Locking our valuable materials into incineration creates a serious long-term risk to UK resource security and is a huge waste of money.

Even those who believe that incineration is a good way to treat genuinely residual waste should oppose the construction of new incinerators because they exacerbate long-term overcapacity. This is also a reason why the prospect of ‘alternatives’ to conventional incineration such as gasification and pyrolysis are a distraction from the need to invest in the higher tiers of the waste hierarchy.

The majority of the material that is currently incinerated is readily recyclable, with a 2020 Defra report stating that: “Of approximately 13.1 million tonnes of residual waste generated by household sources in England in 2017, around 7 million tonnes could be categorised as readily recyclable, 3.5 million tonnes as potentially recyclable, 1.6 million tonnes as potentially substitutable, and 1.0 million tonnes as difficult to recycle or substitute” (Source, Source). As more of this material is recycled, and as non-recyclable products are increasingly phased out, more and more capacity at existing incinerators will become available.

Furthermore, the move away from single-use plastics is increasing the treatment capacity of existing incinerators, and many existing incinerator permits have been varied to increase the quantity of feedstock they are permitted to burn (Source).

There is widespread acknowledgement across Europe that those countries which pursued incineration with the most vigour, such as Germany, Denmark, and the Netherlands, are now facing incineration overcapacity which is harming recycling (Source, Source, Source, Source). It is vital that we learn from their mistakes, not repeat them.

It would be wise to limit development of new thermal treatment capacity to that required once any targets have been met to avoid creating overcapacity as recycling increases.

Waste markets study (Eunomia report for the Scottish Government, 23 April 2019)


Incinerators harm air quality

Artistic impression of incinerator emissions, many of which are invisible to the human eye (Credit: F. Howe 2016)

In addition to greenhouse gas emissions that exacerbate climate change, incinerators emit many toxins and pollutants that harm local air quality. Emissions include dioxins, NOx and ultrafine particulate matter that can be harmful to both human health and the natural environment. There is not enough monitoring, not enough enforcement, and not enough transparency.

“There is no safe level for particulate matter (PM10, PM2.5), while NO2 is associated with adverse health effects at concentrations at and below the legal limits.”

Air Quality: A Briefing for Directors of Public Health. Defra, Public Health England and the Local Government Association, March 2017.


Incinerators are bad neighbours

Communities living near incinerators have many complaints that arise during construction, pre-operational testing (commissioning) and full operation, including:

  • Noise, vibration, plume, flies and odours – These disamenities are often downplayed by operators during the planning and permitting application stages, however when problems do occur some of these same operators dismiss the problems as inevitable or unavoidable. Press coverage reflecting some of these problems with incinerators include:
    • In Runcorn, where waste is delivered by rail, it was reported that: “one resident said she faced daily noise from cargo trains en route to deliver the waste to be burned, well into the evening” and that: “It’s unbelievable – you can lie in bed at night and feel the vibration of the train as it goes past but it goes that slow it takes about two to three minutes to come past through the station.” (Source)
    • It was also reported in Runcorn that: “Around 100 people attended a meeting…to protest over the noise, smell, steam and pollution from the plant.” quoting one resident saying: “I’ve been awake most of the night and I’m losing the will to live. Then wagons beeping their horns this morning followed by banging of containers“. The organiser of the meeting is quoted as stating: “People feel trapped. It’s gone from a place where they could sit in their garden to closing doors and windows because it stinks”. This report also quoted the local MP as follows: “People have been complaining about a droning noise disturbing their sleep. These are genuine concerns about the vapour, noise and smells.” (Source)
    • In Derby, one resident stated: “Where we are, the stench is really strong and smells like rotting food. We have been getting loads of flies around here as well. The summer has been horrendous, we have had to keep our windows closed in the hot weather because when we open them it is just awful.” (Source). It was also reported that: “Bad smells from the controversial Sinfin waste treatment plant are still plaguing residents almost a year after the stink first started. Last August, residents and businesses near to the plant complained to the Environment Agency about a compost-like smell shortly after waste arrived for pre-opening commissioning. They were told the smell would disappear and was due to waste being stored on the site ahead of testing. But the smell has continued to plague residents – especially during the recent warmer weather – despite earlier promises from the operators that there would be no smell off-site from the facility” (Source).
    • In Derby, the operator stated: “we acknowledge…that some nuisance has been caused especially overnight when background noise levels are lower, and the warm weather leaves residents understandably wishing to have windows open” (Source).
    • In Gloucestershire, the operator stated in relation to hot commissioning that: “During this period, up until the facility is fully operational in summer 2019, there will be occasional loud noises, which sound similar to when you bleed a radiator, and plumes of steam as the first combustion gases are pushed through the ducting to test all systems” (Source).
    • An incinerator in Plymouth has also generated numerous complaints from local residents, with one commenting to the Plymouth Herald 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: “It smells, it makes me feel sick”. 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). It was also reported that: “A ‘rotten smell’ was frequently emitted when first constructed, and still occurs in the summer” (Source).
  • Light pollution – Bright lights are typically placed towards the top of the incinerator stack to reduce the risk of aircraft collision. This is a constant reminder of the incinerator and a source of distress to many residents. For example, it was reported in Runcorn that one resident: “said she now lives with her curtains drawn at night to block the lights from the site, which include a pair of red lights like eyes peering from the top of the main chimney stack, from shining into her home and bedroom, having previously enjoyed looking out at the trees behind her home and the site” (Source).
  • Visual impact of the chimney stack and building – Incinerators are often seen as a blot on the local landscape and a constant reminder of the pollution that they cause. For example, one local newspaper article about an incinerator in North Yorkshire described the Allerton plant as one which “dominates the skyline of the main road to the North” quoting a councillor as stating: “A lot of people do feel it is a blot on the landscape, I’m astonished that it can be seen from so many places” (Source).
  • Traffic – In addition to increases in the general volume of traffic and the pollution that this brings, some of those living near incinerators have observed HGVs ignoring planning conditions designed to control adverse impacts. For example, lorries delivering feedstock sometimes travel along routes that are disallowed by planning conditions, despite assurances made at the planning application stage that this would not happen. In other instances, after planning permission is granted on the basis of strict controls over when and where the HGVs can travel, it is not unusual for operators to seek to change the arrangement to enable increases in the number of vehicles, extensions of the time these vehicles are permitted, and expansion of the routes that they are allowed to take. Such changes are often allowed under delegated powers without any community consultation, even in circumstances where the changes directly break promises made to the community about how traffic impacts will be strictly controlled.
  • Broken promises, misinformation and lack of transparency – In addition to the broken promises referred to above in relation to disamenities, there are various other instances where operators behave differently to how they said they would during consultations or where operators have not acted with full candour. For example:
    • Operators routinely state that inverse pressure will be used in buildings to avoid noise and odour issues, with doors being mostly shut, but then too often the operators end up leaving doors open for operational reasons which results in disamenities to neighbours.
    • Areas have faced real-world reductions in recycling rates despite assurances that the incineration plant would only be used for “non-recyclable” waste. In some cases, this is a result reduced recycling services once the incinerator is in place.
    • Liaison groups set up with the stated purpose of engaging with the community are often not informed of forthcoming changes to planning permissions and environmental permits, e.g. proposals to increase capacity. Those who ask tough questions are often excluded from liaison groups, and applicants often use participation in the liaison group as evidence of ‘community support’ for the facility (even in circumstances where the operator promised that they would not do so). In many cases, liaison groups are given the promise of helping to design the proposal but end up having influence over the location, capacity and technology choices adopted by the operator.
    • Operators often try to give the impression that all emissions are continuously monitored when in most cases emissions of concern, such as dioxins, are only monitored a few times a year.
    • Even in cases where operators have carried out compositional analysis of what they are burning, they often do not publish this information and will not release it to the public when this information is requested.
  • Inadequate responses to complaints – When communities face serious nuisance from an incinerator, residents who reach out to the operator are too often greeted with denials that the problems are caused by the incinerator. Even when the operator is subsequently found to be at fault, these operators rarely apologise for having denied the issues were their responsibility. It is extremely rare for an operator to provide any compensation for the nuisances that they cause.
  • Property values – Whether or not the loss of property value is a material planning consideration, it is not unusual for houses prices to fall when there is a proposed or actual incinerator. There are numerous instances where residents have reported experiencing difficulty selling their property due to the threat of an incinerator. Operators do not tend to compensate residents who have suffered financially as a result of incinerators or incinerator proposals.
  • Problems with district heating schemes including:
    • Outages, where residents are left in the cold due with no heating or hot water, e.g. because of an unplanned incinerator shut-down.
    • Costs, where residents may be tied into paying above-market-rate prices for their heating. Residents often do not have alternative means of powering their heating system (e.g. they have no boiler), and they are contractually obliged to pay for the heating network.

Further reading