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Quotes

Governmental Sources

Rebecca Pow, The Parliamentary Under-Secretary of State for Environment, Food and Rural Affairs:
I wanted to be very clear, and I hope it has come out in what I have said, that the measures in the resources and waste strategy and the Environment Bill will enable a paradigm shift, in relation to reducing, reusing and recycling our waste, that should limit the amount that ever has to go to incineration and landfill. I hope that, from what I have said, hon. Members understand what is happening, the direction that the Government are absolutely committed to, and the move to a circular economy.

Rebecca Pow, The Parliamentary Under-Secretary of State for Environment, Food and Rural Affairs:
On taxing incinerators…if the wider policies set out in the resources and waste strategy do not deliver our waste ambitions, as laid out in the Environment Bill and the strategy, including higher recycling rates, the Government outlined in the 2018 Budget that we will consider introducing a tax on the incineration of waste, operating in conjunction with the landfill tax and taking account of the possible impact on local authorities.

Rebecca Pow, The Parliamentary Under-Secretary of State for Environment, Food and Rural Affairs:
I want to set the record straight: as my right hon. Friend the Member for Romsey and Southampton North (Caroline Nokes) highlighted, our focus as a Government ​is on “reduce, reuse, recycle”. We are sticking to that, as well as to the drive towards an ever more circular economy, which many Members touched on. That means extracting maximum value from our resources, then recovering and regenerating products and materials at the end of their lifespan. Through that, we seek to minimise the amount of waste that goes to incineration or landfill, which certainly are at the bottom of the waste chain...Policies aimed at diverting waste away from landfill mean that, in addition to recycling gains, the volume of waste being treated at energy-from-waste plants has increased. Of course, however, the aim with all the measures in the waste and recycling strategy is to bring that down.

Prime Minister Boris Johnson:
I see my right hon. Friend’s point [seeking reassurance that regulations on emissions from incineration will be further enhanced and greener alternatives encouraged] with great concern. As we move to a net zero [carbon] economy by 2050...it is vital that we tackle those kinds of [greenhouse gas] emissions. That is why we are establishing the Office for Environmental Protection, and I will chair a new Cabinet Committee to drive forward action on climate change across the whole of Government.

Stroud District Council leaders Doina Cornell (Labour), Martin Whiteside (Green) and Ken Tucker (Liberal Democrat):
The incinerator is a disaster. It is expensive to run, the contract undermines attempts to reduce the amount of waste we produce and recycle, and will undermine our commitment to become carbon neutral by 2030 and tackle climate change.

Report by Eunomia for the Scottish Government:
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.

Dawn Woodward, DEFRA's Deputy Head of Resources and Waste:
[EfW] is at the bottom of the waste hierarchy. There always be a place for it but we hope with the activities [set out in the Government's waste and resources strategy] that we will push up everything else and that EfW remains at the bottom. There should not be such a parity between recycling and EfW.

A spokesperson for the National Infrastructure Commission:
Far too much of our waste goes to landfill or incineration, releasing harmful carbon emissions and hampering efforts to tackle climate change. Our research shows the strong public support there is for action to ramp up recycling and to tackle plastics and food waste in particular.

HM Government:
Sending plastic waste to, for example, incineration, has an environmental cost in the form of additional CO2 emissions.

The Danish Government:
We incinerate an enormous amount of waste in Denmark; waste which we could get much more out of by more recycling and better recycling.

Michael Lenaghan, Environmental Policy Advisor at Zero Waste Scotland:
The grid is decarbonising…and burning waste is adding emissions and not helping to decarbonise. Energy from Waste is problematic from a climate change perspective…compared to other renewables.

National Infrastructure Commission:
Reducing the waste sent to energy from waste plants (incinerators) by recycling more plastic and converting more food waste into biogas can also help reduce overall emissions…The successful delivery of a low cost, low carbon energy and waste system requires…encouraging more recycling, and less waste incineration

Department for Environment, Food and Rural Affairs (Defra):
Increased recycling and use of recyclate will lead to less landfilled and incinerated packaging waste, less litter and decrease in the use of virgin raw materials. These outcomes will improve the environment for the public and for wildlife, as well as generating carbon savings...Increased recycling of packaging waste will also lead to less packaging waste being sent to energy-from-waste and landfill treatment. Packaging waste going to landfill or incineration loses its residual value for good and harms the environment at the same time.

Thérèse Coffey, Resource Minister:
My hon. Friend the Member for Rugby referred to energy from waste. I caution against some of what he said. In environmental terms, it is generally better to bury plastic than to burn it...We need to be careful about what incentives we push.

Professor Ian Boyd, Chief Scientific Adviser, Department for Environment, Food and Rural Affairs:
If there is one way of quickly extinguishing the value in a material, it is to stick it in an incinerator and burn it. It may give you energy out at the end of the day, but some of those materials, even if they are plastics, with a little ingenuity, can be given more positive value. One thing that worries me is that we are taking these materials, we are putting them in incinerators, we are losing them forever and we are creating carbon dioxide out of them, which is not a great thing...I think that incineration is not a good direction to go in.

Defra, Public Health England and Local Government Association:
...the latest epidemiology demonstrates that harm occurs at pollution levels below EU limit values, so if your area doesn’t have an AQMA it doesn’t mean there isn’t a public health issue to consider

Defra, Public Health England and Local Government Association:
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.

European Parliament (Directorate General for Internal Policies):
Although WHO AQGs [World Health Orgnisation Air Quality Guidelines] are based on health considerations, exposure even below the guideline values may constitute health risks that cannot be excluded. This is especially true for pollutants such as PM [Particulate Matter] for which it has been found that there is no threshold level below which adverse effects can be excluded. Also, mixtures of pollutants might have additive effects; highly sensitive groups might also be affected when exposed to levels at or below the WHO AQG.

SEPA’s Jim McIntyre, Specialist I, Ops (SW) Technical Support Unit:
The revocation notice [for the Dargavel gasification plant] was issued to the company for the following reasons…: persistent non-compliance with the requirements of the permit; failure to comply with an enforcement notice; failure to maintain financial provision and resources to comply with the requirements of failure to recover energy with a high level of efficiency… The Operator submitted a final commissioning report on 30 July 2013 which provided confirmation of the predicted efficiency of energy recovery at this site. The predicted figure of ~3% is significantly below what was expected. After >4 years of commissioning, SEPA have assessed that the level of the energy recovery likely to be achieved by the plant in its current configuration is considerably lower than the levels which could be considered a ‘high level of energy efficiency'

Defra:
At Local Authority level, individual recycling rates ranged from 14 per cent to 69 per cent…lower rates could result from an authority focusing on avoiding landfill by investing in incineration and targeting its waste management policies on that treatment solution, rather than poor recycling awareness or initiatives.

The Scottish Government:
...when plastics are switched from landfill to incineration, the net impact in terms of climate change is, under most reasonable assumptions, strongly negative.

DECC and Defra:
...Bioenergy is not automatically low carbon, renewable or sustainable...

DECC and Defra:
it is essential that bioenergy which contributes to our short and medium term targets...also puts the UK in a good place for longer term decarbonisation

Charles Hendry MP, Minister of State (Renewable Energy), Energy and Climate Change:
Incineration should be considered for electricity generation only after all other options, such as recycling and reuse, have been looked at

Defra (Waste Economics Team):
MBT (mechanical biological treatment)-landfill provides the best emissions performance in terms of the treatment/disposal of residual waste. It essentially involves landfilling somewhat stabilised wastes with some material recovery. The magnitude of the environmental impact depends on the extent to which the waste is stabilised.

Defra (Waste Economics Team):
The emissions from waste combustion of non-biogenic material (via any technology including mass-burn incineration) are also not comprehensively reflected in the price of disposal. Unless the installation in question is in the ETS (municipal solid waste incinerators are excluded) a negative externality persists – such installations are creating GHG emissions without paying the relevant price.

Natural Scotland & SEPA:
Incinerator Bottom Ash (IBA) resulting from the thermal treatment of combustible waste can be used in the manufacture of construction materials as a substitute for virgin aggregate. The use of incinerator bottom ash in construction projects is not the same as recycling the materials which were burnt to generate the ash - it is an example of downcycling. The aim of the Zero Waste Plan is that most waste is sorted into separate streams for closed loop recycling and minimise the quantities requiring tertiary treatment and, in the case of thermal treatment, minimise the amount of ash being produced which then requires further management and/or disposal. Therefore, the use of incinerator bottom ash (IBA) will not count towards the household waste recycling target...

Dr Paul Leinster, Chief Executive of the Environment Agency:
...What we should not be doing is having incinerators which then mean minimisation, re-use, recycling get impacted and that has to be over the 25 year period. I do have concerns over locking technologies in on a 25 year basis when technologies are moving as fast as they do....

Local Government Improvement and Development:
There is a danger that investing in large, inflexible EfW incineration facilities as a technical fix to divert waste from landfill can undermine efforts to prioritise minimisation and recycling.

Urban Mines:
...the recorded data suggests that up to 97.5% of the C&I waste landfilled in the [North West] region could be recycled if the correct facilities and services were available.

Audit Commission:
WDAs [Waste Disposal Authorities] might buy too much disposal infrastructure if they: overestimate future volumes of waste arising (including other authorities’ waste or trade waste). They may also achieve a worse environmental solution if, by building large disposal facilities, they reduce their own financial incentive to pursue waste reduction or recycling initiatives.

Audit Commission:
The challenge exercise for recycling and the Council’s ability to maximise recycling is limited by the emphasis that has been placed on incineration and the need to maintain guaranteed minimum tonnages of waste to support the operation of the incinerator.

Parliamentary Sources

Wera Hobhouse, Liberal Democrat Spokesperson for the Environment and Climate Change:
I believe that we should not send waste to incinerators...Recovering energy from waste produces more carbon emissions than burning gas...The more incineration plants are built in this country, the less likely we are to achieve our [recycling] target, because local authorities need to fill incinerators with waste for them to function...I believe that incentives and disincentives are the way forward. I also support the idea of an incineration tax. The landfill tax has made a massive difference in ​diverting waste from landfill; an incineration tax would ensure that we do not just divert all our waste to incinerators.

Dr Alan Whitehead, Shadow Minister - Department for Business, Energy and Industrial Strategy and Energy and Climate Change:
...We need to understand why, in an era of zero-carbon ambitions for our economy, the idea of granting permission for such enormous plants to deal with our waste is still being contemplated. In general policy, we must recognise that the age of incinerators is over. A decade or two ago, perhaps we could have said that incineration was an improvement on the previous practice of landfill...However, as we move towards net zero, we are in danger of freezing in time our waste strategies by granting permission for large incinerators that capture waste streams over time. That will prevent us from moving up the waste hierarchy in dealing with our waste generally, and in looking at it as a resource to be recycled, reused and put back into the circular economy—rather than put in landfill or burned, usually for minimal energy recovery...We are at a turning point. The future is net zero; it cannot be incineration. We have to move rapidly up the waste hierarchy, and there are challenges and obstacles to that ambition.

Dr Alan Whitehead, Shadow Minister - Department for Business, Energy and Industrial Strategy and Energy and Climate Change:
There is a temptation to try to resolve the problems in a local area by going into partnership with a waste company. That may produce a solution to the local waste disposal problems, but it will do so at the cost of a 20, 30 or even 40-year contract that will fix the future policy of that local authority or consortium of local authorities. It is imperative to recognise that to move up the waste hierarchy nationally, we need the resources to get away from incineration...we need to ensure that local authorities have the resources to enable them to move up the waste hierarchy without being subject to the temptation of using large incinerators to solve their problems.

Dr Alan Whitehead, Shadow Minister - Department for Business, Energy and Industrial Strategy and Energy and Climate Change:
Real residual waste is a fairly small proportion of the waste stream, which suggests that a policy of introducing very large incinerators to collect that waste would fix us in place on the waste hierarchy rather than move us up it.

Environmental Audit Committee:
While incineration of unsold stock ‘recovers’ some energy from the products, it multiplies the climate impact of the product by generating further emissions and air pollutants that can harm human health. Incineration of clothes made from synthetic fibres may release plastic microfibres into the atmosphere. Climate changing emissions will have been generated when the products were created and more CO2 will be produced when they are burnt. The waste hierarchy suggests that reuse and recycling comes first. This should be a priority means of dealing with unsold stock. Incineration should only be used as a last resort where there is a health and safety case for destroying the stock. The Government should ban incinerating or landfilling unsold stock that can be reused or recycled.

London Assembly Environment Committee:
Burning waste takes materials out of the circular economy...

London Assembly Environment Committee:
Investing in more EfW [incineration] can negatively affect long term recycling rates...

20 MPs:
That this House notes in the UK there is now more waste incineration capacity built and under construction than it is forecast there will be genuinely residual combustible waste to burn; further notes that incineration overcapacity can be a barrier to achieving the recycling society; believes that realising such a recycling society would result in significant economic, social and environmental benefits; acknowledges the need to send a clear message that the waste hierarchy should shift focus away from incineration and towards waste reduction, reuse, recycling and composting; and calls on the Government and the devolved governments to introduce a complete moratorium on new waste incineration capacity, covering both conventional waste incineration and other forms such as gasification and pyrolysis, as a matter of urgency.

Environment, Food and Rural Affairs Committee (EFRACOM):
When we [EFRACOM] asked the Minister how the Government ensures that only genuinely residual waste is sent to incinerators, he told us that the key pressure is gate fees—i.e. the charge that must be paid to dispose of waste in an incineration facility. However, we are concerned about the effectiveness of this singular mechanism following evidence we received about ‘put or pay contracts’ and negative impacts on recycling rates.

Russell George, Welsh Conservative spokesperson on the environment:
There has to be greater understanding and acceptance that the waste that we generate is a valuable resource that must be properly capitalised in the Welsh economy. We have a circular economy concept, and that is why I believe it is highly important that we are pumping back materials into the economy rather than burning or burying them. That is the only viable solution for the future.

Llyr Huws Gruffydd, Plaid spokesperson on the environment:
The current policy to fund waste incineration projects for 25 years is unsustainable for economic and environmental reasons...Waste incineration would mean that local authorities would have the perverse incentive not to increase recycling rates as they would otherwise struggle to supply waste incinerators with sufficient combustibles

European Union Sources

Oakdene Hollins (UK) at the request of the Scientific Foresight Unit (STOA) within the Directorate-General for Parliamentary Research Services (DG EPRS) of the European Parliament:
The UK currently exports approximately half of its domestic municipal waste but is planning to develop incinerator plants domestically. Due to the high capital costs associated with the construction of incinerators, once incineration is available, it can create a lock-in effect and divert investment away from higher value applications for recyclates, undermining waste prevention strategies (Wilts & von Gries, 2015). Additionally, overcapacity can lead to financial risks both for local governments and private businesses (GAIA, 2013).

Oakdene Hollins (UK) at the request of the Scientific Foresight Unit (STOA) within the Directorate-General for Parliamentary Research Services (DG EPRS) of the European Parliament:
FEAD (2016) states that the Commission should be cautious of calling gasification and pyrolysis 'mainstream technologies', especially for mixed municipal waste. The Coolsweep (2015) report states that pyrolysis, plasma gasification and gasification could all gain relative market share but there are still concerns about these technologies. For gasification, the need for a certain degree of pre-treatment makes it costly when compared with energy from waste (EfW) and the benefits have yet to be defined at a commercial scale.

Waste Framework Directive Experts' Group:
Too much reliance on "quick-fix" solutions to increase their capacity to pre-treat mixed waste, such as expanding MBT or mixed waste incineration capacity, would be at odds with and undermine more long-term solutions guided by circular economy thinking and the waste hierarchy. Thus, particular attention should be paid to rolling out separate collection and recycling (in particular for municipal of bio-waste) and waste prevention (including of food waste).

European Environment Agency:
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.

European Environment Agency:
While energy recovered through incineration can partly compensate for (fossil) fuel use, incineration is to be minimised, as the energy from incineration can be used only once and thus removes materials from the loop.

Helmut Maurer, European Commission’s waste and recycling division:
…Our way of counting recycling is flawed… We are lying to everyone. We do not recycle, we incinerate and incineration is not recycling…

Janez Potočnik European Commissioner for Environment:
We should avoid over investment in incineration to the extent that it inhibits progress to further recycling and waste reduction because once built, as you mentioned yourself, they need to be fed with waste for many decades and in a way we could be locked in

William Neale, member of cabinet for European Environment Commissioner Janez Potočnik with responsibility for waste.:
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.

Janez Potočnik European Commissioner for Environment:
...unlimited growth on a limited planet means that this linear approach will inevitably lead to scarcity, price-volatility, supply disruptions and pricing levels that are unaffordable for our economy’s industrial base. This is particularly problematic for Europe, where we are heavily import dependent for our materials. The answer is, instead of burying or burning those materials at the end of their life, to pump them back into the economy.

Janez Potočnik European Commissioner for Environment:
...There are two major objectives we need to pursue. Obviously, landfill rates must go down as quickly as possible, but it is also important to switch from energy recovery to increased recycling. Plastic recycling rates are far too low across Europe with an average of just 24 per cent. 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…...

European Commission:
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

Envionmental Consultancy Sources

Eunomia:
It will be appreciated that AD sits above incineration in the waste hierarchy, which presents a certain irony as many current local authority residual waste contracts disincentivise food waste collection and AD...Introducing food waste collection reduces the tonnage of waste which needs to be sent for residual treatment. Many waste collection authorities (WCAs) have no incentive to offer such collections due to the fact that waste disposal authorities have clauses within contracts for the management of their residual waste stream which state that if they supply less than a guaranteed minimum tonnage (GMT) to the contractor, they risk having to pay for the shortfall in waste delivered. This means that once residual waste falls below a certain level, the marginal benefit from avoiding disposal becomes, potentially, zero... It will be appreciated that AD sits above incineration in the waste hierarchy, which presents a certain irony as many current local authority residual waste contracts disincentivise food waste collection and AD...

Eunomia:
At the local level, there are a number of local authorities in England who are already in a situation where the options for additional recycling are constrained by contracts they have entered into with companies regarding incineration of residual waste.

Ann Balinger, Senior Consultant at Eunomia:
If biogenic carbon storage is accounted for, using the national waste composition based on 41% recycling, government guidance on assumptions for electricity generation and a GWP of 25 for methane, even if we assume Defra’s central landfill gas capture rate of 60%, there will be no net climate change benefit over the lifetime of the plant for an incineration facility commencing operation next year if that facility generates only electricity.

Mike Brown, Eunomia Managing Director:
Most local authorities that started incinerator projects, often with government PFI support, did so with a clear commitment to burn only what couldn’t be recycled, but then found themselves tempted by a business case that stacked up better for a big plant than for a small one. Once the incinerator is built, they have to keep it supplied and rapidly the economic logic of return on investment trumps concerns about recycling.

Phillip Ward, Resource Futures Non-executive Chair:
black bag waste is not a single material. Resource Futures are the holders of comprehensive information about its composition and their study – published by Defra – shows that it is largely made up of regular recyclable materials and much of it is non-combustible.

Academic Sources

Professor Nicky Gregson, Durham University:
...there is a distinct trade-off. The areas with higher levels of incineration have the lowest recycling rates.

Dr. Jeffrey Morris, Dr. Enzo Favoino, et. al.:
WTE facilities are not the best environmental option for managing leftover waste and they are not a bridge to a Zero Waste future, as claimed by the WTE industry.

Other Sources

Robert Clarke, Forbes Contributor:
The main reason for companies to opt for landfill or incineration is unfortunately down to both convenience and cost and, with carpets currently being difficult to recycle, manufacturing processes also have to change. Legislation is urgently required to increase the cost of both incineration and landfill which would then encourage recycling as the viable solution. Without the transparency needed to highlight these issues, improvements will take longer to implement.

Christian Schaible, Policy Manager for Industrial Production at the European Environmental Bureau (EEB):
...There is no place for waste incineration in a circular economy...Ultimately, Europe must prevent waste and stop burning precious resources. To embrace the zero pollution strategy, we need to replace waste incineration with clean heating alternatives. Yet as long as incineration plants are still operating, Europeans expect and deserve the very best protection

Nadeem Arshad, a partner at law firm Bevan Brittan:
There have been a number of notable failures in the UK EfW market, especially in the gasification sector – which is still unproven technology in the UK – particularly where the feedstock is municipal waste.

Changing Markets Foundation, Zero Waste Europe and UKWIN:
In a world increasingly aware of its planetary boundaries, limited resources and rising restrictions on carbon emissions, and with the UK Government committed to achieving net zero emissions by 2050, it’s imperative that every sector within the UK dramatically shifts to a circular economy model. It is essential that manufacturers – including those in the carpet industry – begin to take responsibility for the products they put on the market, including collection and recycling. Carpet must be designed with waste reduction, reuse and recycling in mind – and this recycling must be carpet-to-carpet in order to close the loop.

Changing Markets Foundation, Zero Waste Europe and UKWIN:
With regard to incineration alone, the cost to society of the adverse climate impact of the CO2 released from burning carpets is estimated to be £16.5 million in the UK in 2019...Burning old carpets comes with a significant adverse climate cost, both in terms of the greenhouses gases released through combustion and because of the environmental impact of extracting new resources to replace the carpet that was incinerated. Eunomia research found that burning waste carpet, which is predominantly plastic, is likely to be a higher carbon route than burning gas, and that the burning of waste is generally more carbon intensive than all but coal.

Changing Markets Foundation, Zero Waste Europe and UKWIN:
Instead of focusing on increasing carpet-to-carpet recycling, CRUK has relied heavily on incineration and downcycling...Given that so little progress has been made over the past decade, it is time for the UK Government to introduce mandatory legislation for Extended Producer Responsibility (EPR) in the carpet industry...Shifting the carpet industry to a circular economy model is crucial to tackling its substantial waste problem. The current system means society is throwing away billions of pounds of valuable products, while polluting the environment with negative impacts on human health. Carpet companies must redesign their products to reduce waste at source, and enable reuse and closed-loop recycling of their products at the end of life. The way in which carpet is currently designed (mixed fibres, latex secondary backing, glued, use of potentially hazardous chemicals) makes it difficult to recycle...

Libby Peake, senior policy adviser at resources think tank Green Alliance:
Years of neglecting the top options - recycling, reuse and, most importantly, reduction - are starting to take their toll. Most waste isn't an inevitability, but a failure of our current linear economy. Focusing exclusively on diverting material from landfill (in most instances into incineration) represents only a marginal improvement and risks detracting attention from the larger structural changes that will be required to make the economy more sustainable.

Zero Waste Europe:
Gasification presents more or less the same risks and challenges as pyrolysis. The technology is also energy-intensive and requires large volumes of stable waste in terms of composition and moisture. A pre-treatment is necessary to remove moisture and increase the calorific value of the input, resulting in higher costs. The output chemicals can produce fuels and fertiliser, but they will most likely be used as fuel, as it is the case today. As with pyrolysis, policy intervention is needed to ensure plastic gasification stays in the plastic-to-plastic loop instead of being diverted to fuel.

Ellen MacArthur Foundation:
Landfill, incineration, and waste-to-energy are not part of the circular economy target state

Jeffrey Morris, Ph.D. Economist, Sound Resource Management Group::
Because plastics are relatively inefficient as a fuel source and also contain many additives that release pollutants harmful to human and ecosystems health, the solution to plastics littering our waters and landscapes does not lie with using waste plastics as energy sources. That will increase the harm waste plastics are already doing to our climate and health. Rather, effective solutions to our plastics crisis need to come from reductions in the generation of plastics waste by such actions as eliminating single use plastic packaging of all kinds, promoting compostable as well as reusable food carry out containers, and requiring true biodegradability in all items that currently are found on roadsides, in waterways and our oceans.

Center for International Environmental Law (CIEL):
...incineration is the primary source of greenhouse gas emissions from the management of plastic waste. As reliance on incineration grows, so do emissions from plastic waste. Even when waste incinerators generate electricity that might otherwise have been generated by burning natural gas, incineration still consumes more energy, resulting in greater greenhouse gas emissions compared to other management options. Moreover, the offset greenhouse gas emissions will decrease over time as fossil fuels for electricity generation are phased out. As this energy mix shifts to incorporate more renewable sources, using plastic incineration for energy production will become a much greater percentage of net CO2 emissions from the energy sector. In Europe, the total greenhouse gas emissions from plastic—estimated at 132 Mt in 2017—and an additional 90 Mt of CO2 will be released each year based on the current trend of increased incineration in the region. This projection highlights the urgent need to end the use of incineration as a waste management strategy. This conclusion runs counter to the dangerous trend of new and expanded investments in incineration in Asia, Latin America, and Africa.

Center for International Environmental Law (CIEL):
Incineration leads to extremely high emissions and is the primary driver of emissions from plastic waste management...As the [low carbon] energy transition occurs, the incineration of plastic waste will become one of the largest sources of fossil fuel emissions in Europe’s energy sector... Even at present, carbon emissions per kilowatt generated from WTE incineration of plastic waste are not low enough to beat natural gas carbon emissions per kilowatt hour. That is, WTE incineration of plastic packaging waste is over 20 percent higher in carbon emissions per kilowatt hour than natural gas. Compared to renewables, the carbon emissions from WTE are greater by an order of magnitude.

Peter Høngaard Andersen, Director of Innovation Fund Denmark:
Denmark is very, very bad (regarding) reusable plastic, and that is because, for many years, we have burned our waste using incinerator plants...

Global Alliance for Incinerator Alternatives (GAIA):
Incineration converts waste into air pollutants, fly and bottom ash, boiler slag, and wastewater sludge through burning. This process harms human health and the planet by emitting nanoparticles and other respiratory irritants, cancer-causing dioxins and furans, heavy metals including mercury, cadmium and lead.

UKWIN:
The 5 million tonnes of fossil CO2 released by UK incinerators in 2017 resulted in an unpaid cost to society of around £325 million.

UKWIN:
...composition analysis indicates that a clear majority of 'residual waste' is readily recyclable...

ClientEarth:
...even when energy is recovered in the [incineration] process, the net effect of incineration of plastic waste is to contribute to [i.e. exacerbate] climate change...

Material Economics:
...plastic contains substantial embedded carbon in the material itself, which is released as CO2 when plastics are incinerated…a continuation of the current shift towards burning plastics would result in substantial additional emissions in 2050...Clearly, the incineration of fossil-based plastics cannot continue in a low-carbon economy

Keith Freegard, Axion Polymers Director and Vice-chair of the British Plastics Federation Recycling Group:
The carbon release from waste incineration needs to be considered and compared to the alternative methods of generating an equivalent amount of electrical power. Typical Energy from Waste plants have efficiencies of up to 30% for converting feed material into electricity; in contrast, a modern Combined Cycle Gas Turbine's efficiency is typically about 50%... this disparity in efficiencies means that producing 1 MWh of electricity from a CCGT produces just 40% of the CO2 emissions for the same amount of energy made from plastic incinerated at an EfW plant...Increasing incineration capacity also stifles innovation in alternative resource recovery technologies because investment is diverted away from developing new processes towards building huge plants for burning materials to inefficiently create power...Climate change concerns us all and efforts to control rising global temperatures have included a focus on the uncontrolled burning of fossil fuels in many parts of the world. The huge shift in corporate and national energy-habits required to leave fossil fuels in the ground will only happen with a Carbon Tax placed on the generation of electrical power that is directly linked to the tonnes of CO2 released into the atmosphere per unit of power created.

Keith Freegard, Axion Polymers Director and Vice-chair of the British Plastics Federation Recycling Group:
Even the most modern burner [waste incinerator] designs are relatively inefficient at energy recovery, generating lower amounts of electrical power per tonne of fuel burned when compared to high efficiency, combined cycle gas turbine systems (CCGT). Both power generating units are ultimately doing the same task: converting carbon-rich fuels into electricity…while sending atmospheric-polluting carbon emissions up the exhaust stack as a major environmental cost associated with the beneficial electrical power supplied into the local grid

Green Alliance:
Landfill bans are not a silver bullet however and to avoid landfill bans simply leading to an increase in incineration of residual waste, it is important to introduce them with supporting policies that develop collection and recycling systems. The Waste (Scotland) Regulations provide an instructive example of a well-targeted package of measures that includes landfill and incineration bans.

Institution of Civil Engineers:
In the waste hierarchy, recovery through thermal treatment is below recycling. This suggests waste should only be recovered where it is not possible to recycle. As such, efforts to decrease the amount of waste produced and to increase the amount of recycling could be affected by the drive to develop EfW

Chartered Institution of Water and Environmental Management (CIWEM) :
Energy incentives must not be allowed to distort re-use and recycling markets for waste. Too much thermal capacity is highly likely to have an adverse impact on recycling rates; this can be seen with the current competition for feedstock from underutilised European plant. An approach similar to that taken in Scotland may be appropriate, ensuing that recyclable materials are as far as possible recovered for recycling prior to waste being incinerated…there is a need to ensure that only truly residual waste is used [for incineration]...

Novamont SpA , Bioplastic manufacturer:
Experiences from Scandinavia, the Netherlands and Germany where today recycling has plateaued and excess incineration capacity exists leading to significant cross border transfer of residual waste at low costs show that high levels of incineration not only hinders recycling at a local level but in other countries as well.”

Wood Panel Industries Federation:
Current biomass energy generation policies are undermining this principle by subsidising energy generators to burn not only waste wood that could be reused by wood processors but also virgin timber that could been processed and recycled numerous times before being burned. Unfortunately the subsidies provided to biomass energy generators offer a very significant market advantage in purchasing this wood, damaging efforts to encourage wood recycling and reuse by acting as a disincentive for segregation and sorting….It is essential that only waste wood which could not have been reused or recycled should be incinerated. Energy plants will naturally gravitate towards the cheapest and easiest material to use – namely, uncontaminated wood – unless specific measures are put in place to focus incentives (and restrictions) around the use of contaminated wood…A ban on sending wood to landfill alongside a ban on burning uncontaminated waste wood would ensure that the best use is made of our valuable and finite timber resource

World Health Organisation (WHO):
PM [Particulate Matter] is a widespread air pollutant, present wherever people live. The health effects of PM10 and PM2.5 are well documented. There is no evidence of a safe level of exposure or a threshold below which no adverse health effects occur. Since even at relatively low concentrations the burden of air pollution on health is significant, effective management of air quality aiming to achieve WHO AQG [World Health Organisation Air Quality Guidelines] levels is necessary to reduce health risks to a minimum.

Ellen MacArthur Foundation:
Today’s recycling processes are typically ‘loose’ or long cycles that reduce material utility to its lowest 'nutrient' level. This is even more true for the incineration of waste. In a circular economy, by contrast, reverse activities in the circular economy will extend across an array of circles for repair and refurbishment of products, and remanufacturing of technical components. Likewise, the reverse chain for biological nutrients returns those back to the biosphere via composting and anaerobic digestion.

Ellen MacArthur Foundation:
Today, ‘reverse cycles’ are significantly impaired by...leakage from the system through subsidised incineration...

World Health Organization:
The current WHO Air quality guidelines (AQG) provide exposure-response relationships describing the relation between ambient PM and various health endpoints. No specific guideline value was proposed as it was felt that a threshold could not be identified below which no adverse effects on health occurred. In recent years, a large body of new scientific evidence has emerged that has strengthened the link between ambient PM exposure and health effects (especially cardiovascular effects), justifying reconsideration of the current WHO PM Air quality guidelines and the underlying exposure-response relationships...Epidemiological studies on large populations have been unable to identify a threshold concentration below which ambient PM has no effect on health. It is likely that within any large human population, there is such a wide range in susceptibility that some subjects are at risk even at the lowest end of the concentration range.