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The following are quotes which you may wish to use in consultation responses, planning objections, etc. Please feel free to suggest new content for this section.

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The following are quotes which you may wish to use in consultation responses, planning objections, etc. Please feel free to suggest new content for this section.


Government Review of Waste Policy in England 2011. Defra, June 2011. Available from:

“Our aim is to get the most energy out of genuinely residual waste, not to get the most waste into energy recovery.” (Paragraph 22)

“Our evidence base shows that of the main options for the treatment of food waste, anaerobic digestion offers the greatest environmental benefit…To be treated by anaerobic digestion, it is best if food waste is collected separately at source…” (Paragraph 196)

“It is important to treat food waste as high up the hierarchy as possible” (Paragraph 204)

“Waste infrastructure has a long lifetime and therefore changes in the composition and potential volumes of waste in the future cannot be ignored in the development and selection of technologies now.” (Paragraph 230)

DOWNLOAD UKWIN Briefing on DEFRA’S Waste Review (June 2011)

DOWNLOAD UKWIN 2-Page Initial Response to DEFRA’S Waste Review

The Economics of Waste and Waste Policy. Waste Economics Team Environment and Growth Economics, Defra (June 2011). Available from:

“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.” (page 14)

“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.” (page 25)

“…since 2003, waste arisings have fluctuated around a flat/downward overall trend, indicating some decoupling of waste arisings from economic growth” (page 27)

“…the trend in arisings since 2003 points to some potential decoupling of waste from economic growth, and calls into question the value of using expenditure as the driving factor in forecasting waste arisings.” (pages 28 and 29)

Statistical Release: Local Authority Collected Waste Management Statistics for England – Final Annual Results 2011/12. Defra, November 2012. Available from:

“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.” (Page 4)

Waste Infrastructure Delivery Programme Information Note on Combined Heat and Power. Defra, January 2009. Available from:

“Under the deeming provision, the level of the fossil fuel energy content of MSW is deemed to be 50% from 2009 to 2013, 60% from 2013 to 2018 and 65% from 2018. This trajectory is in line with waste policy, reflecting how the composition of residual municipal waste is expected to change over time with increased separate collection and treatment of food and other biodegradable waste streams.” (Page 7)

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UK Bioenergy Strategy

UK Bioenergy Strategy. Published April 2012. DECC, Defra, DfT. Available from:

“…Bioenergy is not automatically low carbon, renewable or sustainable…” (Paragraph 1.8)

“…it is essential that bioenergy which contributes to our short and medium term targets, such as the 2020 renewable energy targets, also puts the UK in a good place for longer term decarbonisation…” (Paragraph 1.9)

“The amount of residual waste from municipal and commercial sources is expected to decline gradually to 2030 as policies to encourage better environmental and energy outcomes succeed (i.e. waste prevention, reuse and recycle)…” (Paragraph 3.9)

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EFRACOM and Other Parliamentary Committees

House of Commons Environment, Food and Rural Affairs Committee (EFRACOM) Report on Waste Strategy 2007. Third Report of Session 2009-10, Volume I (published January 2010). Available from

“Waste should only be used for energy recovery if it is not possible to re-use, recycle or compost it. To achieve maximum energy efficiency levels, planning consent for energy from waste plants must require heat to be captured and used…” (Page 3)

Evidence given to the House of Commons Environment, Food and Rural Affairs Committee Committee. Third Report of Session 2009-10, Volume II (Published January 2010). Third Report of Session 2009–10. Available from

“The objective for me would be that you should not have an incinerator which then destroys waste minimisation programmes or interrupts re-use and recycling…” – Dr Paul Leinster, Chief Executive of the Environment Agency (Ev13, Q53)

In answer to the question: “…During the 25 years [of the Nottinghamshire Waste PFI contract] and in the next 25 years the way that we dispose of our waste will change radically. I do not think in 25 years’ time there will be enough waste to feed this [proposed] incinerator. Is that a concern of yours?”, Dr Paul Leinster, Chief Executive of the Environment Agency, stated that: “Absolutely. 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.” (Ev14, Q58)

“Defra’s advice on the Waste Strategy is very clear, that local authorities need to avoid being locked into long term contracts or plant that is too big. They need to be responsive to future, technological changes.” – Ms Liz Parkes, Head of Waste, Environment Agency (Ev 14, Q59)

House of Commons Communities and Local Government Committee Report on Refuse Collection. Fifth Report of Session 2006–07, Volume I (published July 2007). Available from

“Incinerators are both expensive for those who construct them and unpopular among those near whom they are built. Their presence may also have an impact on local authority strategies to reduce, reuse or recycle waste, particularly if they offer a cheap alternative or if an incineration contract requires the incinerator to be ‘fed’.” (Paragraph 101)

“…those authorities that decide to invest in producing more energy from waste will need to develop strategies to send only unrecyclable material for incineration…” (Paragraph 103)

Environment, Transport and Regional Affairs Committee Report on Delivering Sustainable Waste Management. Fifth Report of Session 2000-01, Volume I (published March 2001). Available from

“The nature of incineration is such that it can ‘crowd out’ recycling: if a significant number of large incinerators, operating on long contracts, are allowed to be built, the long-term prospects for recycling will be diminished…” (Paragraph 106 & Summary recommendation S1)

“We are concerned that incinerators may end up being built according to the ‘path of least resistance’ rule. If allowed to happen, this may mean that poorer areas of towns and cities are left effectively blighted by the presence of a large incinerator. This must not be allowed to happen.” (Paragraph 110 & Summary recommendation T1)

“…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…” (Paragraph 149 & Summary recommendation X1)

“…There must be no subsidy to the growth of incineration. If fiscal instruments favour the development of incineration, then the result in 20 years time could be a large and overbearing incineration industry which effectively crowds out the more attractive options of minimisation, re-use, recycling and composting” (Paragraph 122 & Summary recommendation A2)

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House of Commons Debates

“…No development can take place that is unsustainable. That is the commitment that we give on that point…” – Greg Clark, Minister of State, Communities and Local Government (HC Deb, 27 March 2012, c1344)

“…We want to make sure that all the latest technology for alternatives to incineration is considered, so that we can make sure that we are using the best ways to achieve a green approach” – David Cameron MP, Prime Minister (HC Deb, 30 June 2010, c853)

“Following the logic of the waste hierarchy, it is reasonable to ask whether, if we are burning waste, we need not recycle it. Worse, might we be providing incentives specifically not to reduce, reuse or recycle before recovering energy from waste?” Richard Benyon MP, Parliamentary Under-Secretary of State for Environment, Food and Rural Affairs (HC Deb, 16 February 2011, c1102)

“It is important that any plans for waste to energy facilities emerge out of local waste strategies, so that all options for reuse, recycling and composting can be explored first” – Richard Benyon MP, Parliamentary Under-Secretary of State for Environment, Food and Rural Affairs (HC Deb, 26 July 2010, c715W)

“Incineration should be considered for electricity generation only after all other options, such as recycling and reuse, have been looked at” – Charles Hendry MP, Minister of State (Renewable Energy), Energy and Climate Change (HC Deb, 18 July 2011, c684)

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Scottish Government / SEPA

Scotgen (Dumfries) LTD Dargavel Energy from Waste Facility, SEPA Site Status Report, V13. SEPA, August 2013. Available from:

“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'” – SEPA’s Jim McIntyre, Specialist I, Ops (SW) Technical Support Unit

Policy Statement – Zero Waste Regulations. The Scottish Government, October 2011. Available from:

“There will of course always be a requirement for some form of residual waste treatment, but the measures being taken forward through the Zero Waste Regulations will significantly reduce both the volume and type of materials that will require residual waste treatment, e.g. incineration – the feedstock simply won’t be available to feed large-scale plants or an extensive network of incinerators across Scotland.” (Section 6.1)

Partial Business and Regulatory Impact Assessment for the Landfill Tax Bill 2012. The Scottish Government, October 2012. Available from:

“…when plastics are switched from landfill to incineration, the net impact in terms of climate change is, under most reasonable assumptions, strongly negative.” (Section: ‘Recycling’)

“There is risk associated with the escalation in the standard rate of landfill tax and the potential for competing residual waste options to substitute for landfill…Importantly, the calorific value of fuel derived from waste is variable and as different types of wastes (e.g. plastics & paper) are removed from waste streams, energy inputs can fall and adversely affect plant efficiency…” (Section: ‘Competing Residual Waste Treatment Options (Energy from Waste and Recovery)’)

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Welsh politicians / parties

The Petitions Committee’s Report on the Incineration of Waste, 6 February 2013. Available from:
“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.” Russell George, Welsh Conservative spokesperson on the environment,

“We can see from recommendation 2 that it is crucial to ensure that local authorities are not tied into long-term incineration contracts and thus robbed of the flexibility that they need to react to new developments in waste management that may be more effective and cheaper in the long term. I think that is reflected in the Welsh Government response, which says that long-term contracts must be designed to flexible in respect of input tonnages.” – Bethan Jenkins, Petition Committee Member, Plaid Cymru

“…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….” – Llyr Huws Gruffydd, Plaid spokesperson on the environment

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European Commission and European Parliament

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

“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.”

Plastic should be recycled not sent to recovery says European Commission. MRW, April 2015. Available from:

“…Our way of counting recycling is flawed… We are lying to everyone. We do not recycle, we incinerate and incineration is not recycling…”- Helmut Maurer of the EC’s waste and recycling division

Higher recycling targets package ‘out in June’. Letsrecycle, 9 May 2015. Available from:

“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’” – Environment Commissioner Janez Potonik

Janez Potočnik European Commissioner for Environment: Achieving a sustainable economy, 9 October 2012, available from:

“…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.”


Resolution on a Resource-efficient Europe. European Parliament resolution of 24 May 2012 on a resource-efficient Europe (2011/2068(INI)). Available from:

“Calls on the Commission to streamline the waste acquis, taking into account the waste hierarchy and the need to bring residual waste close to zero; calls on the Commission, therefore, to make proposals by 2014 with a view to gradually introducing a general ban on waste landfill at European level and for the phasing-out, by the end of this decade, of incineration of recyclable and compostable waste; this should be accompanied by appropriate transition measures including the further development of common standards based on life-cycle thinking; calls on the Commission to revise the 2020 recycling targets of the Waste Framework Directive; is of the opinion that a landfill tax – as has already been introduced by some Member States – could also help achieve the above ends.” (Action 33)

Roadmap to a Resource Efficient Europe. European Commission, 20 September 2011. Available from:

“If waste is to become a resource to be fed back into the economy as a raw material, then much higher priority needs to be given to re-use and recycling… Milestone: By 2020, waste is managed as a resource. Waste generated per capita is in absolute decline. Recycling and re-use of waste are economically attractive options for public and private actors due to widespread separate collection and the development of functional markets for secondary raw materials. More materials, including materials having a significant impact on the environment and critical raw materials, are recycled. Waste legislation is fully implemented… Energy recovery is limited to non recyclable materials, landfilling is virtually eliminated and high quality recycling is ensured.” (Section 3.2 – Turning waste into a resource)

UK edges up European recycling league table. LetsRecycle, 1 March 2012. Available from:

“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.” – a European Commission spokesman

Any Future for the Plastic Industry in Europe? Janez Potocnik. European Commissioner for Environment. 21 September 2012. Available from:

“…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 Environment Commissioner Janez Potocnik

The Commission proposal for a new general Union Environment Action Programme to 2020: “Living well, within the limits of our planet”. European Commission, November 2012. Available from:

“Turning waste into a resource, as called for in the Resource Efficiency Roadmap, requires the full implementation of EU waste legislation across the EU, based on strict application of the waste hierarchy and covering different types of waste. Additional efforts are needed to: reduce per capita waste generation in absolute terms, limit energy recovery to non-recyclable materials, phase out landfilling, ensure high quality recycling, and develop markets for secondary raw materials. Hazardous waste will need to be managed so as to minimise significant adverse effects on human health and the environment, as agreed at the Rio+20 Summit. To achieve this, 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.” (Paragraph 38)

“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.” (Paragraph 41)

“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);…” (Impact Assessment, Annex 6: The Underlying Analysis of Priority Objectives, Page 67)

Resourcefully efficient. Charles Newman. Resource Magazine, November 2012. Available from:

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

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Audit Commission / Well Disposed

Well Disposed. Audit Commission, September 2008. Available from

“Authorities with waste disposal responsibilities should…ensure public consultation includes clear communication of the financial impact on council budgets and on taxpayers of different options of dealing with waste…” (page 10)

“WDAs 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.” (Paragraph 151)

“If WDAs overestimate the amount of waste they will need to process, both the overall cost and the cost per tonne of waste processed are likely to be higher than they would have been had estimates proved accurate…” (Paragraph 159)

“One of the common objections to Energy from Waste (EfW) facilities is that after they have been built they will discourage further improvements to recycling because the facility is designed to process a fixed amount of waste (between an upper and lower limit). WDAs therefore need to build ambitious forecasts for recycling and waste minimisation into business cases for disposal infrastructure if they are to avoid creating such a disincentive. Where possible they should design facilities and contractual terms to be flexible to changes that might occur in future…” (Paragraph 160)

“In procuring waste disposal infrastructure, WDAs should avoid creating disincentives to pursuing waste minimisation and recycling initiatives.” (Circa Paragraph 160)

“…where authorities have been shocked into taking action, there is a risk that they become desensitised to costs by the scale of the task and the huge sums of money involved…” (Paragraph 164)

“…the less capital intensive elements of the contract do not need to be financed by a 25 year PFI deal, and some elements of the contract such as collection would need to be soft market tested periodically in order to maintain competitiveness…” (Paragraph 176)

“…A large long-term waste management contract needs to have some flexibility designed into it in case forecasts turn out to be inaccurate…” (Paragraph 178)

“Some WDAs have found that they continued to bear risks they thought they had allocated to a contractor. Such risks include planning delays and technology failures – contractors were able to ensure the WDA bore the risk by threatening to walk away from the contract, leaving the WDA without waste disposal infrastructure.” (Paragraph 179)

“Around 70 per cent of household waste is readily recyclable…” (Paragraph 140)

Inspection Report for Nottingham City Council. Audit Commission, July 2002. Available from:

“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.” (Paragraph 115)

Waste Management Quick Guide (August 2007). Audit Commission. Available from:

“The importance is not to embark on [an] arrangement that will prevent another [treatment method] taking place. Incineration has typically been a culprit in this – the contractor requires, say, 100,000 tonnes of waste a year to operate the incinerator. This is the big difference between incinerators and other treatments.”

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Environment Agency

Scoping Response for the Proposed Development of an Energy Recovery Facility employing Gasification Technology at Bilsthorpe business Park, Earking Road, Bilsthorpe, 2nd April 2014. Available from: Bilsthorpe/Planning%20Application%20Nov%202013/ES/Volume%202/Appendix_2-2_EIA_Scoping_Opinion.pdf

“The long term nature of waste infrastructure means that care needs to be taken to ensure that proposals can adapt to potential long term change (i.e. in waste arisings and composition) and drive waste up the waste hierarchy, not constrain it. As such, the consequences of over-capacity, with respect to relying on waste to produce energy,should be considered now and in the future.” – Stuart Taylor, Planning Liaison Officer at the Environment Agency


Permitting Process Overview (Presentation on behalf of the Environment Agency). Alasdair McKellar (Environment Agency PPC Compliance Officer). Rookery South RRF Community Liaison Panel Meeting, 13th December 2010. Available from:

“Using the ‘I’ Word: Incinerators are often described as ‘Energy from Waste Plant’, ‘Energy Recovery Facility’ and ‘Resource Recovery Parks’, but this is less transparent and stigmatises Incineration.”

Decision Document for PPC Application BP3035MG. Environment Agency, June 2009. Available from:

“…It is possible that mixed municipal waste, which is the waste stream that the facility will be designed to burn, may contain some food waste that has not been segregated at source. It is for Nottinghamshire County Council, as the waste disposal authority, working with Veolia as its contractor, to provide facilities for the segregation and composting of food waste to enable as much of this waste as possible to be recycled in this way.” (Page 119)

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LG Improvement and Development

Is energy from waste a sustainable option?. Local Government Improvement and Development (formerly known as I&DeA), May 2010. Available from:
“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.”

“Planning for any EfW facility must only take place after proper engagement and consultation of local communities.”

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Organisation for Economic Co-operation and Development (OECD)

Instrument Mixes Addressing Household Waste. OECD Working Party on National Environmental Policy, February 2007. ENV/EPOC/WGWPR(2005)4/FINAL. Available from:

“…the environmental harm caused by a modern landfill and a modern incineration plant are of a similar magnitude, while the costs of building and operating an incinerator are much higher than the similar costs for a landfill. Hence, the total costs to society as a whole of a modern incinerator seem significantly higher than for landfilling – which indicates that some reconsideration of the current preference being given to incineration could be useful.” (Page 6)

OECD Environmental Performance Review of Germany – Revised Assessment and Recommendations. Environment Policy Committee / OECD Working Party on Environmental Performance, 19 January 2012. Available from:

“[Recommendations:] Consider creating an effective carbon tax in the sectors not covered by the EU ETS and ensure that other, non-carbon related, externalities are adequately priced… Strengthen waste prevention, for instance by: broadening and strengthening extended producer responsibility systems; expanding the use of economic instruments to promote primary resource substitution (e.g. incineration tax); and expanding knowledge networks and dissemination of best practices…” (Pages 5 and 6)

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Take cautious approach to large-scale energy from waste, urges academic. 6 September 2013, MRW. Available from:

“It’s obvious that in another decade we are not going to have the quantities of waste that we think we are going to have. We have to be conservative in our building of EfW plants…I think we are at 45% recycling – we can easily get to 65%. That would remove that feedstock and there’s a business trend to close the loop of resources – again reducing feedstock.” – Ian Williams, professor in engineering and environment at University of Southampton

What is the best disposal option for the “Leftovers” on the way to Zero Waste? Dr. Jeffrey Morris, Dr. Enzo Favoino, Eric Lombardi and Kate Bailey, May 2013. Available from:

“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.”

Environmental Consultancies and Think Tanks

Anaerobic Digestion Market Update: Addressing the Feedstock Famine. Eunomia, June 2014. Available from:

“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

“Whilst there has been a steady increase in the number of local authorities providing separate food waste collections to households, the 0.3 million tonnes per annum currently collected still represents a small proportion of total food waste arisings.” -Eunomia

“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” -Eunomia

“It should be noted that in England, in 2012, around 40% of all residual waste was sent for incineration and that this residual waste might comprise up to 40% food waste (where no separate collection system is in place). Unless local authorities renegotiate contracts with their treatment suppliers, or unless they are required to change their approach to waste management…, therefore, large amounts of food waste are likely to remain within the residual waste stream.” -Eunomia

Defra’s ex WRATE-ed guide. March 2014. Available from:

“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.” – Ann Ballinger, Senior Consultant at Eunomia

Green Alliance evidence to EFRACOM investigation into Waste Management in England, May 2014. Available from:

“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.”

Eunomia Research & Consulting Ltd’s evidence to EFRACOM investigation into Waste Management in England, May 2014. Available from:

“We believe that there is a danger that England invests too heavily in residual waste treatment. If higher recycling rates are delivered, then this may become problematic. There is already evidence locally of residual waste treatment contracts having the effect of constraining recycling increases.“The main causes of this are as follows: Authorities and their advisers have tended to overstate the rate at which waste would grow; Authorities and their advisers have underestimated the potential for recycling; and Incinerator contracts often include a guarantee from the waste disposal authority to supply a minimum tonnage of waste to the facility. Some contracts seek to ‘weaken’ the strength of this bind by placing a requirement on the contractor to make endeavours to cover any shortfall in the guaranteed minimum tonnage, but in practice, it might be expected that local authorities would still lose money under such arrangements as a result of the underpinning ‘put-or-pay’ nature of the contract.”

“We have clear evidence that, locally, this is already a problem for many local authorities….Authorities already incinerating more than 50% of their waste may, it seems reasonable to argue, have to consider scaling back quantities being incinerated in order to improve recycling. Some of these may be under no major contractual constraint, but equally, it seems reasonable to say…that few of these would feel compelled to seek to recycle more waste: affordability does not appear to be their problem.”

“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”

English councils limited to 60% recycling rate by residual pipeline. MRW, November 2013. Available from:

“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 residual waste treatment plants we have built, and are building, will be with us for many years to come. Rather than making production and consumption sustainable, we are putting in place infrastructure that needs existing consumption patterns to continue in order to sustain it.” – Adam Baddeley, Head of Energy at Eunomia

National Residual Waste Infrastructure Review – Issue 3. Eunomia, November 2012. Available from:

“In the UK, there were over 29.6 million tonnes of residual waste arising from local authority collected (MSW) and commercial and industrial (C&I) sources in 2011/12…Without any change in residual waste quantities…there would be overcapacity of 6.9 million tonnes (per annum) if the 19.6 million tonnes of waste treatment capacity that has planning consent reaches financial close and subsequent operation. Planning consent is being sought for a further 4.4 million tonnes of waste treatment capacity…the lead-times involved in the development process, and the level of inertia associated with this, imply that the speed with which the system responds to the emergence of over-capacity is unlikely to be rapid.” (Section 1.2, ‘Summary of Current Position for the UK’)

“Rubbish Economy” – A Review of Business Waste
production in England: Past, Present & Future
. Urban Mines, September 2011. Available from:

“…increasing recycling from residual waste is likely to remove high calorific value materials from that waste stream, such as paper, plastics, wood etc. This would reduce the calorific value of residual waste over time, potentially changing its suitability for energy recovery” (Page 23)

Residual waste arisings down by 20%. MRW, 22 July 2010. Available from:

“It is particularly surprising how effective the landfill tax has been on the residual waste arisings. There has been a recessionary effect too but I believe that it is the Landfill tax that is the greater driver.” – Tolvik director Adrian Judge

Designing for a changing feedstock supply (Chapter 7). Tolvik Consulting, July 2010. Available from:

“For local authorities, a guaranteed minimum tonnage, particularly if incorrectly set, has the potential to transfer significant risk to the public sector.” (Chapter 7, Page 64)

Climate Change Impacts of Residual Waste Treatment. Eunomia, July 2011. Available from:
“Our analysis indicates that where biogenic CO2 results are included, and the results for landfill are considered over a 150 year period, climate change impacts associated with landfilling Shropshire’s residual waste are lower than those associated with incineration.” (Page 16)

“The approach…taken by the majority of LCA [Life Cycle Analysis] practitioners is likely to underestimate the climate change impacts of incineration relative to landfill…[T]o be methodologically correct according to both LCA and GHG [Greenhouse Gas] accounting there should be a credit applied back to the system to account for the permanent store of carbon through waste management, but…there is no agreed methodology for doing this. As such this credit is typically not applied; the resulting analysis thus overestimates emissions from landfill, although it has no impact on the modelling of the performance of an incinerator.” (Annex)

North West of England C&I Waste Survey 2009 for the Environment Agency. Urban Mines, March 2010. Available from:

“…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.” (Page 43)

More Jobs, Less Waste. Anna MacGillivray of URSUS consulting (primary author), September 2010. Available from:

“For the United Kingdom, if an ambitious but achievable recycling target of 70% for municipal waste was set and achieved by 2025, then conservative estimates suggest that across the UK this could create 29,400 new direct jobs in recycling, 14,700 indirect jobs in supply chains and 7,300 induced jobs in the wider economy relative to 2006. Of these potential 51,400 total new jobs some 42,300 might be in England with an estimated 4,700 in Scotland, 2,600 in Wales and 1,800 in Northern Ireland.” (Page 2)

The tax that dare not speak its name. Mike Brown, September 2012. Available from:

“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.” – Eunomia Managing Director Mike Brown

Reshuffling the waste hierarchy. Phillip Ward, September 2012. Available from:

“…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.” – Resource Futures Non-executive Chair Phillip Ward

Science Advisory Council

Science Advisory Council Waste sub-group (SAC-Waste) Final Report. SAC-Waste/Defra, 14 June 2011. Available from:

“…Although landfilling tends to be regarded as inherently bad and to be avoided, there is evidence that in some instances…landfill may be the least environmentally, economically or technically unsuitable option. Landfill can also be a way of storing materials that have a potential future value, and other countries already recognise the value of landfill mining. Landfill mining is already being undertaken in Israel and Sweden, and investigated in the UK. Defra could consider landfilling waste segregated by type or composition or planning landfills to be excavatable in future.” (Paragraph 3.5.1)

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EfW Development Guidance. WRAP, September 2012. Available from:

“[Gasification is] not yet commercially proven in the UK using MSW” (3.3 Gasification, Page 14)

Environmental Benefits of Recycling – 2010 Update. WRAP, March 2010. Available from:

“…most studies [reviewed by WRAP] show that recycling offers more environmental benefits and lower environmental impacts than the other waste management options.” (Page 1)

“Looking to the future, as the UK moves to a lower-carbon energy mix, collection quality improves and recycling technology develops, then recycling will become increasingly favoured over energy recovery for all impact categories [for treating paper and card]” (Page 2)

“Incineration [of plastics] with energy recovery performs poorly with respect to climate change impact…As the UK moves to a lower-carbon energy mix, recycling will become increasingly favoured.” (Page 2)

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Industry Professionals / Trade Bodies

Don’t scrap food waste collections. Opinion piece, 10 March 2016. Available from:

“…unavoidable food waste should go to AD or compositing. It’s economically, environmentally and socially irresponsible to send it to landfill or incineration.” -Dean Hislop, chief executive of organic waste treatment firm Tamar Energy

DS Smith and BPF say Circular Economy package could be more ambitious. DS Smith, December 2015. Available from:

“In too many areas the programme does not go far enough to tackle what is required. The Commission accepts that incineration is better than landfill but could have done more to stop the huge volumes of recyclable materials that are needlessly incinerated through poor collection choices.”

Leading anaerobic digestion operator Tamar Energy is celebrating another successful year of growth but has cautioned that the government must ensure that there is a level playing field for the UK’s waste management solutions, as DECC reviews its tariff regime support for renewable technologies. Tamar Energy, September 2015. Available from:

“Of the 40% of residual household waste going to incineration, it is estimated 40% of this is food waste. This runs counter to the waste hierarchy. Tamar Energy is calling for measures to ensure this food waste is diverted to AD, where its full potential as a source of energy and environmentally-friendly biofertiliser can be realised.” – Peter Clayson, DS Smith business development and external affairs manager

Statement on European Policies for a Modern Circular Economy. bvse, 27th October 2014. Available from:

“…Only if waste is recycled as extensively as possible, primary resource will be preserved sustainably. In order to achieve cascade utilization of the valuable waste materials in an optimal way, to enable efficient resource preservation and maximize greenhouse gas savings, materials have to be kept in the cycle for as long and extensively as possible….the capacities available for incineration have to be reduced to a necessary minimum. With regards to the fact that existing incineration capacities are mostly sufficient, the bvse requires EU funding for incineration plants to be stopped.” –  bvse, the German Federal Association for Secondary Raw Materials and Waste Management

Written evidence submitted by BSW Timber to the Environmental Audit Committee, June 2013. Available from:

“Whilst sawlogs are the most expensive part of the tree, and energy generators currently say they do not intend to burn them, we believe that companies like ours are still at risk from biomass subsidy policies. The price premium of saw-logs will not dissuade energy generators from using them for biomass, as it will increasingly become easier and cheaper to purchase whole trees instead of splitting them into premium and ‘lower value’ parts. Generators will start to purchase saw-log timberWritten evidence submitted by BSW Timber to the Environmental Audit Committee, diverting this wood from the timber industry and undermining the Waste Hierarchy. Whole trees have already been used for pellets in North America.” – BSW Timber (‘the largest sawmilling business in Great Britain’)

DS Smith evidence to EFRACOM investigation into Waste Management in England, 8 May 2014. Available from:

“Processing materials through thermal treatment plants is not recycling and therefore should not count towards the country’s recycling rates. It has a negative impact on recycling and does not follow the principles of the waste hierarchy.” – DS Smith (‘the largest integrated paper and packaging company in the UK and the second largest packaging company in Europe’)

Confederation of Paper Industries evidence to EFRACOM investigation into Waste Management in England, May 2014. Available from:

“In the absence of strategic planning, new regional EfW facilities generate substantial risk [to England’s municipal recycling rates]…For those English Unitary and Waste Disposal Authorities entering into long-term residual treatment contracts, underpinned by guaranteed minimum tonnages (GMT), residual treatment overcapacity may well act as a disincentive to increasing recycling rates. Whilst investment in infrastructure to achieve landfill diversion and recycling improvements is an imperative, the business case for exceeding the recycling performance is questionable; not only does the cost of delivering additional recycling typically increase as the ‘higher hanging fruit’ is sought, but also an increase in recycling may also bring with it a greater risk that future residual feedstock falls below minimum contractual thresholds.”

Institution Of Civil Engineers evidence to EFRACOM investigation into Waste Management in England, May 2014. Available from:

“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) evidence to EFRACOM investigation into Waste Management in England, May 2014. Available from:

“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 evidence to EFRACOM investigation into Waste Management in England, May 2014. Available from:

“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.” – Novamont SpA , Bioplastic manufacturer

Wood Panel Industries Federation evidence to EFRACOM investigation into Waste Management in England, May 2014. Available from:

“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”

Sita’s evidence to EFRACOM investigation into Waste Management in England, May 2014. Available from:

“…high recycling targets automatically constrain the role of incineration…”

“The future is not for waste-to-energy – that is only a downstream technology to fill the gap. I understand that might [not?] be a very popular message but this is the truth!”

Identiplast: European plastics ‘set to change’. Recycling International, 5th December 2013. Available from:

“The future is not for waste-to-energy – that is only a downstream technology to fill the gap. I understand that might [not?] be a very popular message but this is the truth!” – Martin Engelman, Plastics Europe’s resource efficiency director of Plastics Europe (‘represents the interest of the plastics manufacturing industry in Western Europe at European level’)

Wealth from waste: The Local Government Association Local Waste Review, June 2013. Available from:

“We leave it to others, for now, to mount the environmental soap box and make the moral case for recycling, or the strategic case for materials security. The simple fact is that taxpayers will be better off, the economy will benefit, and more people will have jobs if we grow our domestic market for collecting, sorting and reprocessing recycling. Landfilling waste costs a lot of money; burning it is still expensive; recycling actually brings in cash for the taxpayer and we owe it to today’s hardpressed taxpayers to get as much of their money back as possible.” – Councillor Mike Jones, Chairman, LGA Environment and Housing Board

Incineration must be challenged to avoid ‘environmental vandalism’. DS Smith Recycling’s European Sales & Purchasing Director Jim Malone, 9 July 2013. Available from:–environmental-vandalism–/

“If we, as an industry and as a nation, walk blindly towards accepting incineration as a solution for the volumes of badly sorted recyclate rather than challenge our existing collection and sorting models then I consider this a form of environmental vandalism…I passionately believe this is the wrong path and we must not walk blindfold into a new resource wasting trap…The aim should always be to maximise waste minimisation opportunities while looking at the best ways of recovering a quality recycling product to deliver to reprocessors.”

UK Paper Industry Calls for U-turns in Manufacturing Policy. Confederation of Paper Industries, 18 September 2012. Available from:
“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”

Use our understanding of resource efficiency. MRW, 24 February 2012. Available from:

“Source-segregation and the treatment of organics through AD is the only way that we can recoup the value both of the energy and nutrients trapped in the food we throw away, as well as saving money. Incinerating valuable resources that can be recycled does not make environmental or economic sense in the long term. We are facing a period of economic difficulty that throws our short sighted attitudes to resource use into sharp relief. This is true of all our vital materials: paper, glass, metals, electrical components and food.” – Charlotte Morton, Anaerobic Digestion and Biogas Association (Chief Executive)

Note: Also see comments by Charlotte Morton that the spread of incinerators is a “really worrying” threat.

Getting EfW back on track in the UK. MRW, 13 August 2010. Available from:

“The country needs more facilities built on a normal basis without PFI, because we need to get more plants and the PFI process just slows things down. I don’t see how we can claim PFI is value for money because of the risks involved. It is very different to building a hospital or a school and people are having to pay for that risk premium.” – Nick Dawber, Energos (Managing Director)

“Although the technology may be bankable, PFI is very expensive for the client.” – Richard Turner, Viridor (Director of Energy from Waste)

“I don’t really see the big need for PFI in this sector because it tends to encourage people to go for more expensive solutions…PFI is going to be more difficult, so councils are going to have to focus on procuring value for money more than they have done in the past.” – Malcolm Chilton, Covanta Energy (Managing Director)

PFI distorts the market not social enterprise groups. MRW, 29 October 2010. Available from:

“The biggest market distortion in our industry falls within PFI, where lengthy contracts underpinned by unrealistic gate fees enable the construction of superfluous infrastructure that discourage service efficiencies.” – Matthew Thomson, Chief Executive of the London Community Recycling Network

Packaging boss: ‘Paper for recycling is short in Europe’. EurActiv, 23 May 2012. Available from:

“…what we strongly object is incineration of paper. Our raw material is far too valuable to be burned” – Roberto Villaquiran, FEFCO, an umbrella organisation representing European associations of corrugated board manufacturers.


Bristol to join North Somerset RDF deal with Boomeco. Letsrecycle, 5 June 2015. Available from:

“…I am aware of the danger that long term commitments to combined heat and power plants can lead to a reduction in the incentives to reduce and re-use waste.” – Daniella Radice, Bristol city council’s Assistant Mayor for neighbourhoods

Material Campaigns. Resource Magazine, 17 November 2014. Available from:

“…In the last 10, 20 years, Landfill Tax has really driven recycling…I think there’s a need to take that further now and start to introduce an incineration tax as well…” – Andrew Bird of LARAC, the Local Authority Recycling Advisory Committee

Keep Britain Tidy evidence to EFRACOM investigation into Waste Management in England, May 2014. Available from:

“…Defra needs to set a policy framework to get recycling moving again whilst ensuring that increasing capacity for residual waste treatment does not undermine this….Whilst energy is produced from thermal treatment and incineration of waste, these treatments are still an inefficient way of producing energy and are at best a stepping-stone to a sustainable economy…We would welcome an incineration tax that supports recycling alongside the existing landfill tax. Furthermore we need to review and implement fiscal measures that support the waste hierarchy and focus on prevention and reuse where possible.”

Leicestershire Waste Partnership evidence to EFRACOM investigation into Waste Management in England, May 2014. Available from:

“It is likely that the current regulatory framework and fiscal pressures will drive England towards greater use of large scale incineration…”
“…[incineration] undermines the concept of waste being a resource….”

“[Regarding the extent to which increasing the capacity of thermal treatment plants could impact England’s municipal waste recycling rates] Anecdotally we would expect to see an impact on a regional basis, where a high capacity of thermal treatment may undermine recycling efforts. There is already a perception that there are a number of regions with high thermal treatment capacity that have lower recycling levels than would otherwise be expected.”

London councils’ evidence to EFRACOM investigation into Waste Management in England, May 2014. Available from:

“In order to keep these costs down, councils need to reduce the amount of waste sent to landfill and incineration (the two most expensive options) and invest in waste prevention, re-use and recycling.”

Government sets out new strategy for ‘Denmark without waste’. International Law Office, February 2014. Available from:

“We incinerate an enormous amount of waste in Denmark; waste which the Government could get much more out of by more recycling and better recycling.”  – Ida Auken, Denmark’s Environment Minister (November 2013 announcement of the introduction of a new Danish strategy for waste for the next decade in their new strategy: ‘Denmark without waste – Recycle More, Incinerate less’)

Environment minister calls for increased recycling and waste sorting, Online Post, 26 August 2013. Available from:

“…The goal is definitely to recycle more and incinerate less. That is a paradigm shift for Denmark, because so far, we have been the world champions of waste incineration…” – Ida Auken, Denmark’s Environment Minister

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One thought on “Quote Bank

  1. Andrew Gillespie

    Over time, such wastes might cause issues such as liver failure, breathing problems or even cancer. Prolonged exposure may even harm off-spring, causing birth defects and reproductive disorders. At worst, failing to dispose of hazardous wastes correctly can even lead to death.

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