‘Many countries are applying an incineration tax to disincentivise destruction of waste over recovery. Denmark, once paladin of incineration, has now understood it has over-relied upon incineration to the detriment of material recovery and needs to import waste to keep its plants running. Britain risks making the same mistake’
— Prof. Stephen Jenkinson, waste management veteran and former chairman of the UK’s resource and waste management industry trade body, the Environmental Services Association (ESA)
Annex 1 How energy-from-waste incineration undermines circularity and the net-zero carbon target
The UK Government has the power to usher in a momentous transformation of the waste and resource sector to accelerate the transition towards a genuine, zero-waste circular economy. We argue that the continued reliance on energy-from-waste (EfW) incineration impedes this transformation, as EfW incineration is incompatible with the three principles on which the circular economy is founded: designing out waste and pollution, keeping products and materials in use, and regenerating natural systems.[1] The failure to uphold these principles is what makes burning materials a form of ‘leakage’ from the circular economy. We hold that the continued inclusion of EfW incineration as a core component of waste and resource management would not only slow our economic recovery following the Covid-19 pandemic, but also be disastrous for climate change mitigation, since ‘fossil emissions from energy from waste plants are growing rapidly’, as the Committee on Climate Change (CCC) notes in its 2020 Progress Report to Parliament.[2]
Moreover, we wish to underscore that a continued expansion of EfW incineration capacity in the UK heightens risks associated with overcapacity, including sunk costs and stranded assets. As Green Alliance cautions: ‘The history of waste treatment in Scandinavian countries clearly shows the unfortunate consequences, indeed the avoidable folly, of starting at the wrong end of the material cycle and over investing in EfW. It should be a warning to the UK not to make the same mistake’ (emphasis added).[3]
This point is echoed by Prof. Stephen Jenkinson, waste management veteran and former chairman of the UK’s resource and waste management industry trade body, the Environmental Services Association (ESA), who states: ‘Many countries are applying an incineration tax to disincentivise destruction of waste over recovery. Denmark, once paladin of incineration, has now understood it has over-relied upon incineration to the detriment of material recovery and needs to import waste to keep its plants running. Britain risks making the same mistake’ (emphasis added).[4]
This annex offers clarity on why exacerbating our dependency on EfW incineration cannot be part of the transition to a circular economy. As aptly stated by Dr Alan Whitehead MP, ‘We are at a turning point. The future is net zero; it cannot be incineration.’[5] This vision of the future outshines EfW expansion on several fronts: the shift towards circularity will reduce pollution and greenhouse gas emissions, create far more jobs, and prevent the UK from destroying resources and forgoing value-added activities, instead injecting billions of pounds into the UK economy—while public health and well-being improve.[6]
This section identifies six key reasons why EfW incineration is a poor choice for waste and resource management (see Figure A). Specifically, it explains that EfW incineration:
I. destroys resources instead of recovering them, costing the UK billions per year
II. impairs the transition to a circular economy by preventing material reuse and recycling
III. slows economic recovery and hinders job growth in the circular economy
IV. inhibits the full decarbonisation of the power sector
V. is a costly means of generating energy and managing waste
VI. presents serious financial risks as EfW facilities become stranded assets.
The following elaboration of these points underscores that we need to stop wasting resources, which means that we need to stop planning and constructing new incinerators. Building this understanding among policy-makers and industry professionals is critical if the UK is to meet its circular economy targets and achieve its ambitious carbon budgets. An expansion of EfW incineration capacity is inconsistent with the Paris Agreement and the UK’s legally binding net-zero commitments. If ministers fail to consider whether the planned construction of incinerators is compliant with climate obligations, the Government will effectively inhibit the decarbonisation of the UK economy.
![Figure A EfW incineration vs. a transition to the circular economy in the UK[i]](https://images.squarespace-cdn.com/content/v1/5f95667217eb67456f4ebd4e/1605454853567-5R8SPBBRXE44VEO65D19/CE_initiative_summary_3.PNG)
Figure A EfW incineration vs. a transition to the circular economy in the UK[7]
I. EfW incineration destroys resources instead of recovering them, costing the UK billions per year.
o Burning resources perpetuates avoidable dependency on imports. More than half of the ‘residual’ waste that is currently incinerated is actually recyclable or digestible, meaning that the scale of resource destruction through EfW incineration is massive—and that it is set to grow as the proportion of recyclable arisings increases. In England, for instance, an estimated 53% of the residual waste is readily recyclable, 27% is potentially recyclable, 12% is potentially substitutable for recyclable materials, and only 8% is difficult to recycle or substitute, based on estimates by WRAP.[8] In comparison to the amounts of material collected for recycling, at least three times as many textiles and plastic, and five times as much food waste is incinerated every year in the UK’s municipal waste streams.[9] This resource destruction is part of the reason that the UK is highly import-dependent: 79% of the materials used to produce goods and services in 2017 were imported.[10]
o Incineration means less bang for our buck. As shown in Figure B, the current gross value added (GVA) associated with pursuing circular economy strategies for local authority-collected waste streams is already five times larger than the GVA of landfill and EfW incineration (£7 billion vs. £1.4 billion), even though the recycling rate is lower than the rate of landfilling and incineration (45% vs. 55%). Indeed, recycling and composting alone contribute roughly 80% more to the economy than do landfilling and EfW incineration (£2.5 billion vs. £1.4 billion). At the same time, England’s local authorities spend three times more on landfilling and incineration per year than they do on dry and organic recycling services, including on gate fees (£2 billion vs. £0.6 billion).[11] These disparities indicate that the economic benefits of pursuing a circular economy—by utilising waste streams as resources—far outweigh those of disposal in landfill and through incineration. The following GVA breakdown illustrates this point:
the circular economy provides £7 billion in GVA per year:
£2 billion from dry material recovery, including sorting and recycling;
£0.5 billion from organics recycling through anaerobic digestion and composting;
£3.6 billion from repair services, including IT equipment, appliances, and other household goods; and
£0.9 billion from retail sales of second-hand goods;
the linear economy contributes about £1.4 billion in GVA per year through landfilling and EfW incineration.[12]
o A modest step up the waste hierarchy would add £35 billion to the wider UK economy. A detailed WRAP analysis shows that moderate improvements in recycling, repairing, renting out, and remanufacturing materials would generate far greater economic returns—direct benefits in the waste and resource sector, and indirect ones in other sectors—than the use of landfill and incineration to dispose of and destroy the same resources. An increase in recycling rates from 45% to 65% would add £5.3 billion in GVA; a 5% growth in repair activities would add £1.5 billion in GVA; 25% more renting and leasing would add £7.8 billion; and a 20% expansion in the remanufacturing sector would add £20.9 billion to the economy across all sectors.[13]
![Figure B. Gross value added (GVA) by the circular economy vs. the linear economy, 2018[i]](https://images.squarespace-cdn.com/content/v1/5f95667217eb67456f4ebd4e/1605127617926-HGLUG5U523MECEG2W6I5/Jobs_Circular_Linear_Economy.png)
Figure B. Gross value added (GVA) by the circular economy vs. the linear economy, 2018[14]
II. EfW incineration impairs the transition to a circular economy by preventing material reuse and recycling.
Policy Connect claims to have ‘found no evidence to support claims that EfW incineration inhibits recycling rates’,[15] yet ample data and documentation are in fact readily available.
o EfW incineration competes for recyclables. At the system level, waste incineration and recycling compete for the same materials,[16] as evidenced by the fact that more than half of the materials that are currently being incinerated in EfW facilities are readily recyclable.[17] Once EfW infrastructure is in place, a local authority is contractually obligated to allow the incinerator operator to process collected waste in the EfW facility, typically for 10 years or more.[18] Such contracts create negative trade-offs by maintaining a higher demand for virgin raw materials and imports than would be the case in a circular economy, in which recycling would meet demand.[19]
o High incineration rates keep recycling rates low. DEFRA data on waste collected by 123 local authorities show a clear relationship between above-average incineration rates and lower recycling rates when controlling for landfilled waste (see Figure C).[20] After a local authority has reduced its landfilling share of collected waste to below 15%, the share of incinerated waste becomes highly linearly correlated with the share of recycled and composted waste: each 1% increase in EfW incineration results in a 0.8% reduction in recycling and composting.[21] At a landfilling share of collected waste below 10%, each 1% increase in EfW incineration results in a 0.94% reduction in recycling and composting.[22] Of the local authorities with landfilling rates below 10%, 55 incinerate more than 50% of their waste, 26 incinerate more than 60%, and 7 incinerate more than 70%. Their poor recycling performance, combined with low landfilling, indicates that they are incinerating a significant amount of readily recyclable materials.
o The more we incinerate, the less we recycle, and vice versa. Areas with the lowest rates of incineration tend to have the highest rates of recycling and vice versa. In 2018/19, the UK’s South West had the lowest rate of incineration (28.4%) and the highest rate of recycling (49.8%), whereas London had the highest rate of incineration (59.3%) and the lowest rate of recycling (30.2%).[23]
o Sustained increases in recycling rates necessitate cuts in EfW incineration, says the CCC. In commenting on Policy Connect’s claim that EfW does not hinder recycling, the CCC notes: ‘The premise that EfW does not inhibit recycling rates is based on 2017 European data […] this same dataset shows that those countries with the highest recycling rates (e.g. Germany, Austria, Slovenia) also have significantly lower EfW rates than other countries with low landfill. And given this is a historical snapshot, it doesn’t consider the future – continued increases in recycling will eventually have to come at the expense of EfW, if landfill has already largely disappeared.’[24]
![Figure C The share of waste recycled and composted vs. the share of waste incinerated, with control for the share of waste landfilled per local authority, 2017/18 (N=123)[i]Note: For each of the 123 local authorities in this sample, the…](https://images.squarespace-cdn.com/content/v1/5f95667217eb67456f4ebd4e/1605259151333-BRD16RDG4DAOOYF2P659/Share_of_recycling_incineration_landfilling.PNG)
Figure C The share of waste recycled and composted vs. the share of waste incinerated, with control for the share of waste landfilled per local authority, 2017/18 (N=123)[25]
Note: For each of the 123 local authorities in this sample, the dot colour indicates the share of waste landfilled. These data show a clear relationship between above-average incineration rates and lower recycling rates when controlling for landfilled waste.
III. EfW incineration slows economic recovery and hinders job growth in the circular economy.
If encouraged to expand, as detailed in Section 2 of this annex, the circular economy will serve as a job engine: since reuse, repair, remanufacturing, and recycling are more labour-intensive processes than EfW incineration, they offer far greater job creation potential.
o Compared to the circular economy, EfW incineration is a low-employment sector:
Once operational, an incinerator whose construction may have required investment of £145–£200 million[26] typically employs only 30–40 people.[27]
For every 10,000 tonnes of waste processed, an estimated 1–2 permanent jobs are created through EfW incineration, compared to 6 jobs through landfilling, 36 jobs via recycling, and more than 200 jobs through the reuse of products such as textiles and appliances.[28]
o EfW incineration accounts for just 2% of jobs in the waste and resources sectors. Repair and reuse jobs alone outnumber landfill and EfW incineration jobs by a factor of 15. It is worth noting that repair and reuse activities are not currently reflected in official waste and resource data, but rather in other categories, in line with national and international reporting standards.[29] Since these activities are part of the circular economy, however, this annex includes repair and reuse jobs in the employment figures for the waste and resource sector. Overall, the sector employs a total of 223,900 people, only 2% (5,000) of whom work in EfW incineration. In the following breakdown, the jobs that are exclusively linked to the circular economy are italicised, while linear economy jobs are underlined:
72,000 in waste collection (for both the linear and circular economies);
23,000 in treatment and disposal of non-hazardous wastes, as follows: [30]
5,000 in EfW incineration, including in planning, operations, and construction;
8,500 in landfilling;
5,500 in organics recycling (anaerobic digestion and composting); and
4,000 in other waste treatment operations;
6,000 in the treatment of hazardous wastes;
22,000 in dry material recovery, including sorting and recycling;
191,400 in repair and reuse:
97,400 in industrial machinery and equipment repair;
49,500 in household product repair activities;
11,900 in the wholesale waste and scrap business; and
32,600 in retail sales of second-hand goods (see Figure D).[31]
o A significant shift from EfW incineration to a circular economy would cause a job boom. An increase to 70% recycling (the 2030 target recommended by the CCC) and to 20% remanufacturing would translate into more than 200,000 new jobs overall, or 54,000 net additional jobs, based on evaluations by WRAP and Green Alliance.[32]
![Figure D Jobs in the linear economy (including landfilling and EfW incineration), waste collection, and the circular economy, 2018[i]](https://images.squarespace-cdn.com/content/v1/5f95667217eb67456f4ebd4e/1605259537935-QRK2NWZWR7O7TKXA2AXK/Estimated_Jobs_economy.PNG)
Figure D Jobs in the linear economy (including landfilling and EfW incineration), waste collection, and the circular economy, 2018[33]
IV. EfW incineration inhibits the full decarbonisation of the power sector
It cannot help the UK deliver on its net-zero carbon ambitions. Incinerator emissions have a relatively high CO2 concentration—one ‘similar to coal’,[34] as roughly one tonne of carbon dioxide equivalent (CO2e) is released for every tonne of waste that is incinerated. About half of this CO2 derives from fossil sources such as plastic.[35] Since EfW incinerator emissions are included under the power sector, not the waste sector, government data show that they inhibit the decarbonisation of the energy supply rather than of waste management.
o Greenhouse gas emissions from EfW incineration have increased 12-fold since 2000. In 2019, the UK’s 54 EfW incinerators released more than 12 million tonnes of CO2e, including 7.4 million tonnes of fossil-based CO2e emissions—a 12-fold increase over the 0.6 million tonnes of fossil-based CO2e emitted in 2000, based on BEIS and CCC data (see Figure E).[36]
o Grid decarbonisation has undermined the justification for EfW incineration. Due to the progressive decarbonisation of electricity supplied via the National Grid, the relative climate change impact of incinerators in the power sector is growing rapidly.[37] The average carbon intensity of the grid in 2019 was 214 grams per kilowatt-hour (kWh), while the current average fossil carbon emission intensity of energy from EfW incineration is four times that: 860 grams per kWh.[38]
o EfW incineration accounts for an unduly large proportion of power sector emissions. EfW incineration accounted for 13% of the 57 million tonnes of power sector emissions from fossil-fuel sources in 2019 (see Figure F), while generating only 2.4% of the UK’s electricity and a mere 0.2% of the UK’s heat supply.[39]
o The coal phase-out exposes EfW incineration as incompatible with UK climate targets. It is no longer possible to obtain substitution benefits by replacing coal with EfW incineration since coal has been almost entirely phased out of the National Grid, accounting for just 2% of 2019 power generation.[40] Dominic Hogg of Eunomia concurs: ‘When coal is phased out for generating electricity, incineration of unrecycled waste will be the most CO2-intensive form of generation. This doesn't make sense if the government’s trying to reduce CO2 emissions.’[41]
o No measures are in place to slow or stop the expansion of EfW incineration capacity. Seventeen EfW facilities are currently in the late stages of commissioning or under construction; at full capacity, they will add an estimated 2 million tonnes of fossil-based CO2 emissions per year to UK totals.[42] Industry-driven efforts to build further capacity can be expected in the absence of a moratorium or other regulations (see Section 2 of this annex).[43]
o EfW incineration is not the only—nor the least carbon-intensive—alternative to landfill. Construction of new EfW facilities is partly justified based on the claim that a redirection of waste from landfill to EfW incineration ‘saves’ greenhouse gas emissions by preventing the biodegradable portion of that waste from releasing CO2e emissions through decomposition in landfill.[44] In terms of greenhouse gas emissions, this argument fails to acknowledge that incineration is a poor substitute for landfilling, especially in relation to the following alternatives (see Figure G):
organic waste prevention: For every tonne of food waste we avoid by not producing the food in the first place, we prevent an estimated 3.74 tonnes of CO2e.[45] Similarly, if we reduce paper and board usage by 1 tonne—such as by cutting back on packaging or using digital devices instead of printing—we avoid an estimated 1.7 tonnes in CO2e.[46]
non-organic waste prevention: Waste prevention through reuse, light-weighting, and the avoidance of packaging can bring about far greater reductions in greenhouse gas emissions than would be secured by shifting from landfilling to EfW incineration. Indeed, preventing the use of 1 tonne of glass saves an estimated 0.9 tonnes of CO2e; the same principle applies with respect to preventing the use of 1 tonne of plastic (1.9 tonnes of CO2e saved), steel (2.1 tonnes of CO2e saved), aluminium (12 tonnes of CO2e saved), and textiles (24.3 tonnes of CO2e saved).[47]
organic material recycling: Anaerobic digestion of organic waste is preferable to EfW incineration in that the process is nearly fossil CO2-neutral[48] and can generate high-standard natural fertiliser (digestate), which can replace artificial fertiliser,[49] as well as biogas, which can replace natural gas for heating. For every tonne of organic material digested, anaerobic digestion emits 0.14–0.34 fewer tonnes of CO2e than would be released if that tonne were sent to EfW incineration.[50]
non-organic material recycling: Recycling of all materials yields significant CO2 reductions by reining in the demand for energy-intensive processes across the supply chain, including mining, processing, and manufacturing. Every tonne of glass that is recycled saves an estimated 0.2–0.7 tonnes of CO2e, in part by obviating the need for virgin materials. The CO2e savings are somewhat higher for every tonne of recycled steel (0.5–1.8 tonnes CO2e), dense plastic (0.6–1.8 tonnes CO2e), waste electric and electronic equipment (WEEE) (1.3–1.5 tonnes CO2e), and textiles (1.8–8.0 tonnes CO2e), and significantly higher for every tonne of aluminium (9–12 tonnes CO2e).[51]
o Delivering on net zero requires transitioning to the circular economy for CO2 savings. The total impact of the transition to a high-value circular economy—with a focus on ratcheting up waste prevention, reuse, and recycling—is expected to save 68 million tonnes of CO2 per year by 2030,[52] or 15% of the UK’s total emissions, based on 2018 data.[53] Given that the CCC has warned that the UK is not on track to meet the fourth or fifth carbon budgets (2023–27 and 2028–32) and that ‘progress will need to accelerate’ if the UK is to meet the net-zero target by 2050,[54] the transition to a circular economy is an essential contributor to achieving the UK’s climate ambitions.[55]
o Technology that limits CO2 emissions will make the cost of EfW incineration rise steeply. The CCC indicates that to ensure power sector decarbonisation, EfW incineration facilities will necessarily have to integrate costly carbon capture and storage (CCS) technology.[56] The most recent CCS technology estimates show that, as a result, energy-generation costs will increase by £136 per megawatt-hour (MWh),[57] causing a marked increase in the cost of EfW incineration, as discussed in point V, below.
Figure E Fossil-based CO2 emissions from EfW incineration and biogenic methane emissions from landfill, 2000–19, with indicative paths to reach net-zero carbon for both disposal methods by 2030, 2040, and 2050, derived from Committee on Climate Change (CCC) values[58]
Note: This figure presents landfill emissions from biogenic sources, namely methane released from decomposing organic material, converted into CO2 equivalent values (CO2e). EfW incineration emissions in the figure are due to the burning of fossil-derived materials (excluding biogenic values), primarily plastics. This approach is based on the latest standardised greenhouse gas emissions accounting practices as set out by the Intergovernmental Panel on Climate Change.[59]
![Figure F CO2e emissions caused by coal, natural gas, oil, and EfW incineration in the generation of electricity, as a % of total power sector emissions, in millions of tonnes of CO2e (MtCO2e) for 2019, 2015, 2010, and 2000[61] Note: Due to rounding,…](https://images.squarespace-cdn.com/content/v1/5f95667217eb67456f4ebd4e/1605260381194-ZOP4ZXYQ7M97RBHJO6K4/power_sector_emissions_shares.PNG)
Figure F CO2e emissions caused by coal, natural gas, oil, and EfW incineration in the generation of electricity, as a % of total power sector emissions, in millions of tonnes of CO2e (MtCO2e) for 2019, 2015, 2010, and 2000[60]
Note: Due to rounding, not all percentages add up to precisely 100%.
![Figure G Tonnes of CO2e emissions generated or saved through EfW incineration, waste prevention, reuse, and recycling, per tonne of waste or material[61] Note: UK-wide fossil emissions from EfW incineration are estimated at 0.51 to…](https://images.squarespace-cdn.com/content/v1/5f95667217eb67456f4ebd4e/1605260568796-8RLA9BGAWUIU2MROWN04/Carbon_comparison_incineration_recycling_waste_prevention_reuse.PNG)
Figure G Tonnes of CO2e emissions generated or saved through EfW incineration, waste prevention, reuse, and recycling, per tonne of waste or material[61]
Note: UK-wide fossil emissions from EfW incineration are estimated at 0.51 tonnes per tonne of fossil CO2e emissions.[62] Carbon emissions accounting of EfW incineration typically present the replacement of electricity from the grid as a counterfactual. The idea is that when a new EfW incineration plant begins to produce electricity, it replaces other power sources.[63] If, for example, EfW incineration replaces electricity from the grid at the 2019 grid carbon intensity of 214 grams per kWh, then total emissions that have been accounted for drop to 0.39 tonnes per tonne of fossil CO2e emissions.[64] If compensation for heat generation is factored in, they go down to 0.29 tonnes per tonne of fossil CO2e emissions, based on the replacement of gas consumption in heating.[65]
V. EfW incineration is costly means of generating energy and managing waste,[66], as compared to alternative options that combine recycling and energy generation.
Initially, waste incineration was intended only as a waste disposal alternative to landfill, yet today it is funded and planned for as a combined solution for waste disposal and energy generation. As noted in point II, above, more than half of the ‘residual’ waste that is currently being sent to incineration in the UK could be recycled—if recycling programmes were to be upgraded. Therefore, a circular economy-based counterfactual for EfW incineration is recycling combined with renewable energy generation. In this comparison, the quality, uniformity, and degree of contamination of materials collected for recycling, also referred to as recyclate, need to be taken into account, as these factors can significantly alter the monetary value of recycling.[67] Accordingly, the following assessment presents comparative cost estimates based on the recycling of low- and high-quality recyclate:
o The combined cost of high-value recycling and renewable energy is 20%–25% lower than EfW incineration, if the costs of EfW carbon emissions are excluded. New EfW facilities commissioned by 2025 will provide electricity and heat at an estimated cost of £248 per MWh to cover capital and operational costs, and at £152 per MWh for facilities generating electricity only, based on 2020 BEIS calculations.[68] These costs are displayed in Figure H, which compares the combined costs of high-value recycling and renewable energy relative to EfW incineration, using a baseline EfW incineration value of 1.63 tonnes of waste for every MWh of energy generated.[69] The comparison reveals that the cost of recycling combined with solar photovoltaic (PV) or wind energy is 20% to 25% lower than the cost of EfW incineration, based on a like-for-like comparison of combined waste disposal with energy generation vs. recycling and energy generation, given the following rates:
high-value recycling plus solar PV electricity: £136/MWh (of which £44/MWh is for solar PV electricity);
high-value recycling plus offshore wind electricity: £149/MWh (of which £46/MWh is for offshore wind electricity);
EfW incineration electricity, excluding gate fee compensation: £152/MWh;
high-value recycling and geothermal combined heat and power (CHP): £225/MWh (of which £133/MWh is for geothermal CHP electricity and heat); and
EfW CHP incineration electricity and heat, excluding gate fee compensation: £248/MWh (see Figure H).[70]
o The combined cost of low-value recycling and renewable energy is 20%–50% higher than EfW incineration, if the costs of EfW carbon emissions are excluded. The savings demonstrate the importance of single-stream source separation, standardisation of packaging materials, and other recyclate collection quality improvements. The comparison is based on the following rates:
recycling of low-value recyclates plus solar PV electricity: £221/MWh (of which £44/MWh is for solar PV electricity);
recycling of low-value recyclates plus offshore wind electricity: £234/MWh (of which £46/MWh is for offshore wind electricity);
EfW incineration electricity, excluding gate fee compensation: £152/MWh;
recycling of low-value recyclates and geothermal electricity and heat: £310/MWh (of which £133/MWh is for geothermal electricity and heat); and
electricity and heat from EfW incineration, excluding gate fee compensation: £248/MWh (see Figure H).[71]
o Artificially high gate fees under long-term contracts spur investment in EfW incinerators.[72] The main reason why investments in new EfW incineration facilities are highly competitive—in contrast to recycling investments—is that plant operators can continue to charge local authorities artificially high gate fees that do not reflect the actual cost of producing energy while incinerating waste. At an average cost of £89 per tonne of waste, gate fees for EfW incineration in the UK are currently more than three times higher than the average gate fee paid for material recovery facilities (£25), which provide recovery operations before sales of materials to recycling plants or exporters.[73] These gate fees, which are paid by local authorities, account for a staggering 70% of the revenues of EfW incinerator operators.[74] A few factors have led to inflated gate fees: the high cost of landfilling (including the landfill tax),[75] limited competition,[76] and the tender-based waste contract market structure, which allows waste operators to lock excessive EfW incinerator gate fees into contracts for ten or more years, at levels just below the cost of landfilling. As a consequence, local authorities effectively subsidise EfW facilities or, to be more precise, they subsidise the price of electricity from EfW facilities. By paying gate fees, local authorities—in other words, the taxpayers—effectively pay about 60% of the actual cost of energy provided by EfW CHP incinerators, meaning that electricity consumers pay £103 per MWh generated instead of the £248 it actually costs to provide that MWh. For EfW incinerators that provide only electricity, the subsidy effect is even greater: local councils effectively pay 75% of the true cost of the electricity, allowing plant operators to charge consumers £39 per MWh generated rather than the £152 it actually costs to provide that MWh (see Figures H and I).[77] The fact that the subsidy effect is greater for electricity-only plants helps to explain why few EfW incinerators are built with heat energy delivery in the UK.[78] As long as waste operators can charge local authorities artificially high gate fees, electricity-only EfW incineration will remain financially far more attractive than recycling source-separated waste and using renewable energy.
o Skewed market conditions limit investments in recycling facilities. Gate fees for EfW incineration are currently 3.5 times higher than gate fees for recycling.[79] From a financial perspective, this gate fee discrepancy indicates that EfW incineration is a highly inefficient way to manage waste and produce electricity and heat. If the waste sector and its markets were regulated by a market regulator based on competitive dynamic pricing without artificial price setting due to the landfill tax, a shift from EfW technology to recycling would already be under way, given the relative costs of alternative technologies. As noted in Annex 2, regulation of the waste sector could usefully:
include an auction system—similar to those employed in the electricity sector—based on processing lots of residual waste and source-separated recycling in the wholesale market (between local authorities on the one hand and waste collectors and processors on the other) such that gate fees may be set on an annual basis in a transparent competitive manner; and
incorporate waste disposal fees in direct costs to households, such as via pay-as-you-throw systems and deposit return schemes, which add the fees to product prices in the business-to-consumer retail market. The evidence for pay-as-you-throw schemes demonstrates that cities and local authorities with such schemes achieve significant reductions in waste arisings, higher recycling rates, and lower overall waste management costs.[80]
o Commingled and low-value materials reduce the profitability of recycling. In addition to the skewed market conditions mentioned above, suboptimal material design and collection systems tip the scales in favour of investments in EfW incineration over recycling. As a consequence, significant amounts of low-quality materials with limited uniformity and elevated contamination levels make their way into the waste system, at a high cost to local authorities. As noted in point III of Section 2, below, these deficiencies could be addressed through efforts such as:
o single-stream collections or multi-stream collections with kerbside sorting, instead of commingled streams. In addition to reducing the need for material recovery facilities and thus minimising capital costs, this approach would ensure more uniform recyclate streams and reduce contamination levels.
o standardisation of high-quality recyclable materials, especially for packaging. This approach would improve the value of end-of-life materials by design and would introduce a level playing field for companies, in part by removing disincentives that keep businesses from investing in or purchasing packaging made of high-value recyclable materials. Such standardisation would encourage companies to replace multi-layer, multi-material packaging with readily recyclable alternatives that are already available.[81]
o EfW incinerators that go clean by installing CCS will no longer be financially viable, even with artificially high gate fees. Installing CCS technology will add an estimated £136 per MWh of generated energy, as noted above.[82] This added expense will push up the cost of EfW incineration with electricity and heat recovery to £384 per MWh, rendering the technology more costly than any other alternative, unless the costs of CCS can be reduced drastically in the medium term. By 2025, EfW incineration will be more than twice as expensive as natural gas-based electricity with CCS, which will cost an estimated £177 per MWh when combined with recycling (see Figure H).[83]
![Figure H Technology cost comparison: EfW incineration vs. recycling and renewable energy, excluding gate fees[i] Note: The energy technology costs are based on combined capital expenditure (CAPEX) and operational expenditure (OPEX) data…](https://images.squarespace-cdn.com/content/v1/5f95667217eb67456f4ebd4e/1605459202107-4X53TLM4CMHO158TQTRZ/Chart_technologies_cost_comparison_excl_gate_fees.PNG)
Figure H Technology cost comparison: EfW incineration vs. recycling and renewable energy, excluding gate fees[84]
Note: The energy technology costs are based on combined capital expenditure (CAPEX) and operational expenditure (OPEX) data from BEIS cost models. Costs of material recovery and recycling are net of recovered and recycled material sales, estimated based on local-authority recycling costs from MHCLG.
![Figure I Company cost comparison: EfW incineration vs. recycling and renewable energy, including gate fee compensation[i] Note: Gate fees, which are paid by local authorities, are income for waste operators (grey bar: negative cos…](https://images.squarespace-cdn.com/content/v1/5f95667217eb67456f4ebd4e/1605459228747-UPA2LKI0S3JALXYZDNDT/Chart_technologies_cost_comparison_incl_gate_fees.PNG)
Figure I Company cost comparison: EfW incineration vs. recycling and renewable energy, including gate fee compensation[85]
Note: Gate fees, which are paid by local authorities, are income for waste operators (grey bar: negative cost) and effectively reduce technology costs (white bar: cost reduction impact). The energy technology costs are based on combined capital expenditure (CAPEX) and operational expenditure (OPEX) data from BEIS cost models. The costs of material recovery and recycling are net of recovered and recycled material sales, estimated based on local-authority recycling costs from the Ministry of Housing, Communities and Local Government (MHCLG).
VI. EfW incineration presents a serious financial risk as EfW facilities become stranded assets in the medium term.
This risk applies particularly to EfW projects in the pipeline, due to the high likelihood that residual waste arisings will decline substantially by 2030, in response to increasing waste prevention, reuse, and recycling.
o Business as usual means that EfW incineration capacity will expand significantly, given the 20 million tonnes of additional capacity in the current planning pipeline. Unless the UK introduces measures to halt this expansion, the problem of overcapacity is unavoidable:
Current capacity: A total of 54 EfW incinerators treated 12.6 million tonnes of residual waste in 2019, or 45.5% of all residual waste generated, with a combined EfW plant operational capacity of 14.6 million tonnes.[86]
Capacity in 2024 and 2030: According to Tolvik’s figures, the UK’s EfW capacity will grow to at least 18.5 million tonnes per year by 2024, as five plants are in the late commissioning stages and another 11 plants are already under construction. This projection is likely to be an underestimate, however, as it anticipates a slowdown in the number of plants being realised—an improbable scenario given that, as noted above, a further 20 million tonnes of EfW incineration capacity are in the pipeline and half of these projects have already been granted planning consent.[87] If capacity expansion continues at pace, and just 50% of the projects that are planned, approved, or under construction are realised, total EfW operational capacity will rise to 21.8 million tonnes by 2024, and to 25 million tonnes by 2030.[88]
o Meeting UK recycling targets will lead to substantial EfW incineration overcapacity, in line with decreases in residual waste arisings.
If the UK reaches a 60% recycling rate by 2030, total residual waste arisings will drop down to between 17 and 23 million tonnes, according to simulations by leading waste and resource sector companies, including Biffa, Eunomia, FCC Environment, and SLR.[89]
DEFRA expects waste prevention, reuse, and recycling based on current policies to cut residual waste down to 22 million tonnes by 2030 and to 20 million tonnes by 2035.[90]
A comparison of DEFRA’s residual waste forecasts and EfW incineration expansion projections cited above points to a high risk that EfW incineration overcapacity will reach at least 5 million tonnes by 2035.[91] This assessment assumes that the UK Government is serious about achieving its 65% recycling target by 2035 and that it will succeed in nearly eliminating exports of refuse-derived fuel (RDF) by the same date (see the blue line in Figure J).[92]
o EfW incineration capacity is already larger than genuinely residual waste arising. None of the waste and resource sector evaluations referenced in the previous bullet point consider the impacts of a rapid, comprehensive shift towards a zero-residual-waste economy, which would be particularly disruptive for EfW incineration.[93] As noted above, 53% of the ‘residual’ waste that is being incinerated is in fact readily recyclable or digestible, according to studies by WRAP and DEFRA.[94] If that portion were to be recycled or digested instead of incinerated, and if overall waste arisings were to drop by just 10% through waste prevention programmes, residual waste arisings would decrease from 28.7 million tonnes in 2016 to 12 million tonnes by 2035.[95] As a result, the UK would potentially face 14 million tonnes of EfW incineration overcapacity by 2035, assuming RDF exports are nearly eliminated by then (see the red line in Figure J).[96]
o Overcapacity heightens the risk that incinerators will become stranded assets. Investors and public bodies face sunk costs as the UK moves up the waste hierarchy and residual waste streams dwindle, incineration needs plummet, and recycling rates increase. Local authorities that have taken on financial investment risks may be left to pay off debts for stranded plants.
o An overcapacity of 5 million tonnes in 2035 means £4.2 billion in stranded EfW assets. An EfW incinerator costs about £9 million per MW of energy-generation capacity,[97] which is equivalent to an investment of £165 million for a facility that can process 200,000 tonnes per year. As mentioned above, DEFRA’s waste arisings calculations indicate that the UK faces a high risk of 5 million tonnes of overcapacity by 2035, which would correspond to £4.2 billion in stranded EfW incineration assets.
o Overcapacity has already become a reality in other countries. Denmark, the Netherlands, and Sweden already have significant EfW incineration overcapacity. The UK can learn from these examples and reduce the risk of stranded EfW assets.
In Denmark, which currently registers a waste incineration overcapacity of 0.5 million tonnes,[98] the government is decommissioning EfW facilities with an eye to reducing capacity by 35% by 2030, in line with re6sidual waste reduction targets and in order to meet its new goal for a climate-neutral waste sector by 2030 (see Table A in Section 2). The Danish climate plan for a green waste sector and circular economy states: ‘Overcapacity in Danish incineration plants means that the plants—in order to fill up the furnaces—import large amounts of waste for incineration in Denmark. This waste contains significantly more plastic than Danish waste, and it therefore increases the Danish CO2 emissions.’[99] To facilitate this transition, the Danish government has instituted a stranded asset pool of DKK 200 million (£25 million) to compensate local authorities for stranded EfW decommissioning costs.[100]
The Netherlands has an overcapacity of 2 million tonnes, which is expected to grow to 5.4 million tonnes by 2022, relative to its domestic residual waste arisings. Dutch EfW incineration facilities remain in operation by importing residual waste from the UK.[101]
Sweden has an overcapacity of 2.3 million tonnes, which is fed through imports from Norway and the UK.[102]
In the medium term, as residual waste arisings dwindle and less feedstock is available for incineration, the Netherlands and Sweden will inevitably have to manage sunk costs to reach zero carbon targets.
![Figure J DEFRA and potential circular economy policy scenarios for residual waste arisings by 2035 vs. current and planned EfW incineration capacity[i]](https://images.squarespace-cdn.com/content/v1/5f95667217eb67456f4ebd4e/1605261261928-T3X3VRL9F66ODW38Y7B9/EfW_Capacity_Change_Scenarios.PNG)
Figure J DEFRA and potential circular economy policy scenarios for residual waste arisings by 2035 vs. current and planned EfW incineration capacity[103]
Notes
[1] Ellen MacArthur Foundation, The Circular Economy in Detail, n.d., https://www.ellenmacarthurfoundation.org/explore/the-circular-economy-in-detail.
[2] Committee on Climate Change, Reducing UK emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/.
[3] Libby Peake, Scandinavians call their waste incineration ‘crazy’, so why copy them?, Green Alliance, 20 July 2020, https://greenallianceblog.org.uk/2020/07/20/scandinavians-call-their-waste-incineration-crazy-so-why-copy-them/.
[4] Stephen Jenkinson, Reviewing biowaste treatment in the UK, Resource, 14 August 2020, https://resource.co/article/reviewing-biowaste-treatment-uk. See also EUWID, Danish ministers call for cuts to waste imports, 20 May 2020, https://www.euwid-recycling.com/news/business/single/Artikel/danish-ministers-call-for-cuts-to-waste-imports.html.
[5] Dr Alan Whitehead, speaking at a Westminster Hall debate on waste incineration facilities, 11 February 2020, https://hansard.parliament.uk/Commons/2020-02-11/debates/D1799344-3D26-4DF0-94C1-3AEB397AF375/WasteIncinerationFacilities.
[6] While it is beyond the scope of this annex to examine the health impacts of EfW incineration, a growing body of evidence links long-term exposure to pollution emitted by EfW facilities to various conditions and health risks, including with reference to ultra-fine particulate matter and metals. See, for example: James Langley, EfW plants ‘cause deaths’ of 15 Londoners per year, Letsrecycle.com, 21 October 2020, https://www.letsrecycle.com/news/latest-news/efw-plants-cause-deaths-of-15-londoners-per-year/; Agostino Di Ciaula et al., Biomonitoring of Metals in Children Living in an Urban Area and Close to Waste Incinerators, International Journal of Environmental Research and Public Health, 17(6), https://www.mdpi.com/1660-4601/17/6/1919; Peter W. Tait et al., The health impacts of waste incineration: a systematic review, Australian and New Zealand Journal of Public Health, 44(1), https://onlinelibrary.wiley.com/doi/full/10.1111/1753-6405.12939; UK Without Incineration Network, Waste Incineration and Particulate Pollution: A failure of governance, 2018, https://ukwin.org.uk/btb/Particulate_Pollution_July_2018.pdf.
[7] This figure summarises findings from Annex 1; for sources, see the references cited in throughout the annex. The £1 billion estimate for expenditure on incineration is based on an estimated EfW incineration share of the expenditures for waste disposal from the Ministry of Housing, Communities & Local Government, Local authority revenue expenditure and financing England: 2018 to 2019 budget, Items 582 (waste disposal) and 584 (recycling), 2019, https://www.gov.uk/government/statistics/local-authority-revenue-expenditure-and-financing-england-2018-to-2019-budget-individual-local-authority-data.
[8] DEFRA, Resources and Waste Strategy: Monitoring Progress, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/907029/resources-and-waste-strategy-monitoring-progress.pdf.
[9] Resource Recovery from Waste Programme, Energy from Waste and a Circular Economy: A Response from the Resource Recovery from Waste Programme to the Policy Connect Call for Evidence on Energy from Waste, July 2020, https://resourcerecoveryfromwaste.files.wordpress.com/2020/07/policy-connect-evidence-call-efw_response-rrfw_final.pdf.
[10] UK Office for National Statistics, Material footprint in the UK: 2017, 2020, https://www.ons.gov.uk/economy/environmentalaccounts/articles/materialfootprintintheuk/2017.
[11] Ministry of Housing, Communities & Local Government, Local authority revenue expenditure and financing England: 2018 to 2019 budget, Items 582 (waste disposal) and 584 (recycling), 2019, https://www.gov.uk/government/statistics/local-authority-revenue-expenditure-and-financing-england-2018-to-2019-budget-individual-local-authority-data.
[12] The ONS unhelpfully lumps together the treatment and disposal of non-hazardous waste through landfilling, EfW incineration, anaerobic digestion, and composting, arriving at a combined GVA of £1.86 billion. Waste flow quantities indicate that about 25% of this GVA is generated by anaerobic digestion and composting (£0.46 billion), while landfilling and EfW incineration account for nearly 75% (£1.40 billion). Office for National Statistics, Non-financial business economy, UK: Sections A to S, 2020, https://www.ons.gov.uk/businessindustryandtrade/business/businessservices/datasets/uknonfinancialbusinesseconomyannualbusinesssurveysectionsas. Note that the GVA is estimated at £3.61 billion for waste collection and £0.32 billion for hazardous waste treatment and disposal, including nuclear waste treatment, disposal, and storage.
[13] Keith James, Peter Mitchell and Dorothea Mueller, Extrapolating resource efficient business models across Europe, WRAP, 2016, http://www.rebus.eu.com/wp-content/uploads/2017/07/Extrapolating-resource-efficient-business-models-across-Europe.pdf.
[14] Figure B data source: Office for National Statistics, Non-financial business economy, UK: Sections A to S, 2020, https://www.ons.gov.uk/businessindustryandtrade/business/businessservices/datasets/uknonfinancialbusinesseconomyannualbusinesssurveysectionsas.
[15] Oliver Feaver, No Time to Waste: Resources, Recovery & the Road to Net-Zero, Policy Connect, July 2020, https://www.policyconnect.org.uk/sites/site_pc/files/report/1326/fieldreportdownload/policyconnect-notimetowaste-final.pdf.
[16] As Jeff Seadon of Auckland University of Technology points out: ‘The waste materials that are easiest to source and have buyers for recycling—like paper and plastic—also produce most energy when burned.’ Jeff Seadon, Climate explained: seven reasons to be wary of waste-to-energy proposals, The Conversation, 11 December 2019, https://theconversation.com/amp/climate-explained-seven-reasons-to-be-wary-of-waste-to-energy-proposals-128630.
[17] DEFRA, Resources and Waste Strategy: Monitoring Progress, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/907029/resources-and-waste-strategy-monitoring-progress.pdf; WRAP, Commercial and Industrial Waste in Wales, 2020, http://www.wrapcymru.org.uk/sites/files/wrap/Composition%20analysis%20of%20Commercial%20and%20Industrial%20waste%20in%20Wales_0.pdf.
[18] The duration of contracts between local authorities and waste operators varies substantially, covering anywhere from a minimum of 5 years to about 30 years. The typical length is more than 10 years, as noted by industry consultants Tolvik: ‘The “term” gate fee data is based on contracts of minimum 5 years (more typically 10 years+), with a credit worthy waste supplier and often has a deferred commencement date (i.e. the contract term only starts once a new EfW is operational).’ See Tolvik, UK Energy from Waste Statistics: 2017, June 2018, https://www.tolvik.com/wp-content/uploads/2018/06/Tolvik-UK-EfW-Statistics-2017.pdf. The London Assembly Environment Committee made a similar point in 2018: ‘Investing in more EfW can negatively affect long term recycling rates. This investment needs to be paid for by an assured income stream, usually through contracts with local authorities to pay the EfW operator to take waste. Contracts are often lengthy—the majority are over 20 years. The terms of contracts, such as minimum annual payments, or a low fee per tonne of waste, can undermine the financial viability for the local authority of reducing waste, or sending it to other destinations such as recycling.’ See London Assembly Environment Committee, Waste: Energy from Waste, 2018, https://www.london.gov.uk/sites/default/files/waste-energy_from_waste_feb15.pdf.
[19] Resource Recovery from Waste Programme, Energy from Waste and a Circular Economy: A Response from the Resource Recovery from Waste Programme to the Policy Connect Call for Evidence on Energy from Waste, July 2020, https://resourcerecoveryfromwaste.files.wordpress.com/2020/07/policy-connect-evidence-call-efw_response-rrfw_final.pdf.
[20] DEFRA, Local Authority Collected Waste Statistics: Local Authority Data, 11 December 2018, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/766014/LA_and_Regional_Spreadsheet_201718_rev2.xlsx.
[21] Significant at R2=0.86.
[22] Significant at R2=0.94.
[23] DEFRA, Statistics on waste managed by local authorities in England in 2018/19, 2019, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/918853/201819_Stats_Notice_FINAL_accessible.pdf.
[24] The quote is drawn from email correspondence of 13 August 2020, in which the CCC comments about Policy Connect’s No Time to Waste, stating: ‘The CCC has read the Policy Connect report, but we were not asked to make a contribution or to review it. Policy Connects assumption is that England will struggle to meet Defra’s 2035 municipal recycling targets (65%), and hence the amount of residual waste will be large, requiring EfW. They also position EfW as the necessary means to avoid landfill and exports. However, the CCC’s scenarios for Net Zero rely on 70% recycling across the UK at the latest by 2030 (and increases beyond this to 2050), large reductions in food waste over the next 10 years, and a large near-term update in recycling, AD [anaerobic digestion] and composting to be able to ban biodegradable wastes from landfill by 2025. The CCC’s scenarios as to what is required for Net Zero are therefore much more ambitious than current policy in England and NI (Scotland and Wales are closer to being on-track), and hence the assumptions underlying the Policy Connect report. The premise that EfW does not inhibit recycling rates is based on 2017 European data, showing that countries with higher recycling also have lots of EfW, in comparison to countries with low recycling rates and the rest landfilled. However, this same dataset shows that those countries with the highest recycling rates (e.g. Germany, Austria, Slovenia) also have significantly lower EfW rates than other countries with low landfill. And given this is a historical snapshot, it doesn’t consider the future – continued increases in recycling will eventually have to come at the expense of EfW, if landfill has already largely disappeared.’
[25] Figure C data source: DEFRA, Local Authority Collected Waste Statistics: Local Authority Data, 2018, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/766014/LA_and_Regional_Spreadsheet_201718_rev2.xlsx.
[26] DEFRA, Incineration of Municipal Solid Waste, 2013, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/221036/pb13889-incineration-municipal-waste.pdf.
[27] The estimate is based on employment figures at four UK EfW incinerators: Greatmoor (345,000 tonnes per year) ‘provides around 40 permanent jobs’ (Buckinghamshire Council, Energy from waste, n.d., https://www.buckscc.gov.uk/services/waste-and-recycling/energy-from-waste/); Irvine (180,000 tonnes per year) ‘estimate that between 25 and 30 permanent jobs would be created at the site’ (Andy Hamilton, Jobs created after Irvine waste recycling plant plans approved, Irvine Times, 23 January 2020, https://www.irvinetimes.com/news/18183257.jobs-created-irvine-waste-recycling-plant-plans-approved/); Drakelow (169,000 tonnes per year) ‘will generate over 30 long-term permanent jobs’ (Jenny Moody, Dozens of jobs coming to Burton and South Derbyshire at new power plant, DerbyshireLive, 14 May 2020, https://www.derbytelegraph.co.uk/burton/dozens-jobs-coming-burton-south-4126285); and Alton (330,000 tonnes per year), with ‘40 permanent jobs once operational’ (NS Energy, Veolia seeks planning approval for advanced energy recovery facility in UK, 2 July 2020, https://www.nsenergybusiness.com/news/veolia-advanced-energy-recovery-uk/).
[28] RREUSE Network, Briefing on job creation potential in the re-use sector, 2015, http://www.rreuse.org/wp-content/uploads/Final-briefing-on-reuse-jobs-website-2.pdf.
[29] On the whole, current DEFRA and ONS reporting distinguishes between activities related to materials and those associated with products, such as repair and reuse. More to the point, repair and reuse activities are not currently reflected in official waste and resource data; there is no reporting on products in circulation (in-use stock or disused stock); and the ONS reports on industry repair and reuse under ‘manufacturing’ and on household goods repair and reuse under ‘other service activities’, meaning that both the GVA (the impact on the economy) and the jobs generated by reuse and repair are attributed to ‘manufacturing’ and to ‘other service activities’ rather than to the waste and resource sector.
[30] The number of EfW incineration jobs is estimated based on 12.63 million tonnes of residual waste processed in 2019 and a total of 2 jobs created per 10,000 tonnes of waste processed, plus another 2,500 jobs estimated in the planning and construction of new EfW facilities. Note that the ONS figure of 23,000 involved in non-hazardous waste treatment includes anaerobic digestion and composting, landfilling, the disposal of fallen livestock, and solvent waste disposal. Disaggregated data for these statistics are not directly available. We estimate that out of the 23,000 involved in non-hazardous waste treatment, 5,000 are involved in EfW incineration; 8,500 in landfilling across close to 500 landfill sites; 5,500 in organics recycling across 579 anaerobic digestion sites and 323 composting sites; and 4,000 in various other waste treatment operations, including fallen livestock treatment (about 100 companies) and solvent waste treatment. See Office for National Statistics, Non-financial business economy, UK: Sections A to S, 2020, https://www.ons.gov.uk/businessindustryandtrade/business/businessservices/datasets/uknonfinancialbusinesseconomyannualbusinesssurveysectionsas.
[31] Peter Mitchell, Employment and the circular economy: Job creation through resource efficiency in London, WRAP, London Sustainable Development Commission, Mayor of London, London Waste and Recycling Board, 2015, https://www.london.gov.uk/sites/default/files/lsdc_et_al_-_circular_economy_jobs_report_2015.pdf; Office for National Statistics, Environmental Goods and Services Sector (EGSS) estimates, 2020, https://www.ons.gov.uk/economy/environmentalaccounts/datasets/ukenvironmentalgoodsandservicessectoregssestimates.
[32] Julian Morgan and Peter Mitchell, Opportunities to tackle Britain’s labour market challenges through growth in the circular economy, WRAP and Green Alliance, 2015, https://www.wrap.org.uk/sites/files/wrap/Opportunities%20to%20tackle%20Britain's%20Labour%20Market%20Challenges%20full%20report.pdf.
[33] Figure D data source: Office of National Statistics, Non-financial business economy, UK: Sections A to S, 2020, https://www.ons.gov.uk/businessindustryandtrade/business/businessservices/datasets/uknonfinancialbusinesseconomyannualbusinesssurveysectionsas.
[34] Dennis Gammer and Susie Elks, Energy from Waste Plants with Carbon Capture: A Preliminary Assessment of Their Potential Value to the Decarbonisation of the UK, Catapult Energy Systems, May 2020, https://es.catapult.org.uk/reports/energy-from-waste-plants-with-carbon-capture/?download=true.
[35] Committee on Climate Change, Reducing UK emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/.
[36] Total emissions from waste incineration reached 7.6 million tonnes of CO2e emissions (MtCO2e) in 2019: 7.4 MtCO2e from EfW incineration and 0.2 MtCO2e from waste incineration without energy recovery. The latter are counted as waste sector emissions in UK statistics. The value of 7.6 MtCO2e for 2019 is based on provisional BEIS greenhouse gas emissions statistics per fuel type, as listed under ‘other emissions’, a category that covers waste incineration with and without energy recovery. BEIS, Provisional UK greenhouse gas emissions national statistics, 2020, https://www.gov.uk/government/collections/provisional-uk-greenhouse-gas-emissions-national-statistics. For previous years, these values are aligned with Committee on Climate Change data on EfW incineration. Committee on Climate Change, Net Zero Technical Report: Net-Zero Exhibits—Power and Hydrogen, 2019, https://www.theccc.org.uk/wp-content/uploads/2019/05/Net-Zero-Technical-Report-Power-chapter-exhibits-Web.xlsx. See also Committee on Climate Change, Reducing UK Emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/; Tolvik Consulting, UK Energy from Waste Statistics: 2019, May 2020, https://www.tolvik.com/wp-content/uploads/2020/05/Tolvik-UK-EfW-Statistics-2019-Report-June-2020.pdf.
[37] UKWIN, Evaluation of the climate change impacts of waste incineration in the United Kingdom, October 2018, rev. edn. April 2019, https://ukwin.org.uk/files/pdf/UKWIN-2018-Incineration-Climate-Change-Report.pdf.
[38] Carbon intensity is calculated from data provided by the National Grid in partnership with the Environmental Defense Fund, the University of Oxford, and WWF (Carbon Intensity API, n.d., https://carbonintensity.org.uk/). Carbon intensity from EfW incineration is based on 455 kg of fossil CO2 per tonne of waste and 531 kWh of net energy generated per tonne of input. For parameter values, see Tolvik Consulting, UK Energy from Waste Statistics: 2019, May 2020, https://www.tolvik.com/wp-content/uploads/2020/05/Tolvik-UK-EfW-Statistics-2019-Report-June-2020.pdf; Dennis Gammer and Susie Elks, Energy from Waste Plants with Carbon Capture: A Preliminary Assessment of Their Potential Value to the Decarbonisation of the UK, Catapult Energy Systems, May 2020, https://es.catapult.org.uk/reports/energy-from-waste-plants-with-carbon-capture/?download=true; and Ramboll, North London Heat and Power Project: Carbon Impact Screening Edmonton ERF, 2019, http://northlondonheatandpower.london/media/udfapcyh/nlwa-carbon-impact-study-report-ver-2-f.pdf.
[39] The share of EfW carbon emissions in the power sector is 13%, or 7.4 millions of tonnes of carbon dioxide equivalent (MtCO2e) of a total of 57.3 MtCO2e, as shown in Table B, below. The other figures—2.4% of the power sector electricity supply and 0.2% of the heat supply—are based on the 7.7 TWh electricity and 1.4 TWh heat supply generation figures in Tolvik Consulting, UK Energy from Waste Statistics; 2019, May 2020, https://www.tolvik.com/wp-content/uploads/2020/05/Tolvik-UK-EfW-Statistics-2019-Report-June-2020.pdf. The heat supply value of 760 TWh is based on Ofgem, Decarbonisation of heat, 2016, https://www.ofgem.gov.uk/system/files/docs/2016/11/ofgem_future_insights_programme_-_the_decarbonisation_of_heat.pdf. The value of 324 TWh of electricity supplied in the UK is based on BEIS, Fuel used in electricity generation and electricity supplied, 2020, https://www.gov.uk/government/statistics/electricity-section-5-energy-trends.
Table B Fossil Emissions values (MtCO2e) used to estimate the percentage share of EfW incineration in power sector emissions.
*Excluding emissions from waste incineration without energy recovery, which is counted under the waste sector in the UK emissions statistics. In 2019 these emissions are estimated at 0.2 MtCO2e, resulting in a total emissions value of 7.6 MtCO2e from waste incineration including and excluding energy recovery.
Sources: Committee on Climate Change, Reducing UK Emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/; BEIS, Provisional UK greenhouse gas emissions national statistics, 2020, https://www.gov.uk/government/collections/provisional-uk-greenhouse-gas-emissions-national-statistics
[40] Simon Evans, UK low-carbon electricity generation stalls in 2019, 2010, https://www.carbonbrief.org/analysis-uk-low-carbon-electricity-generation-stalls-in-2019#:~:text=Coal%20accounted%20for%20just%202,gas%20and%20higher%20CO2%20prices.
[41] Roger Harrabin, Should we burn or bury waste plastic?, BBC News, 20 February 2018, https://www.bbc.co.uk/news/science-environment-43120041.
[42] Tolvik Consulting, UK Energy from Waste Statistics: 2019, May 2020, https://www.tolvik.com/wp-content/uploads/2020/05/Tolvik-UK-EfW-Statistics-2019-Report-June-2020.pdf.
[43] Construction News, How new energy-from-waste players avoid being burned, 21 November 2019, https://www.constructionnews.co.uk/agenda/contractors-guide-energy-waste-sector-21-11-2019/.
[44] Nowadays the majority of landfills are equipped with landfill gas capture, yet these systems only capture about 50% of the methane released from landfill and a significant portion is released as CO2 during decomposition. For an overview of the release pathways, see: Kimberley Pratt and Michael Lenaghan, The climate change impact of burning municipal waste in Scotland: Technical Report, 2020, https://www.zerowastescotland.org.uk/sites/default/files/ZWS%20%282020%29%20CC%20impacts%20of%20incineration%20TECHNICAL%20REPORT.pdf. Moreover, when the captured methane is used for heating or other purposes, it is converted into CO2 emissions when burnt. For more details, see DEFRA, Energy from waste: A guide to the debate, 2014, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/284612/pb14130-energy-waste-201402.pdf.
[45] The emissions saved include those that would have been generated through the production, processing, consumption, and disposal of food as waste. Martin Bowman and Krysia Woroniecka, Bad Energy: Defining the true role of biogas in a net zero future, Feedback, 2020, https://feedbackglobal.org/wp-content/uploads/2020/09/Feedback-2020-Bad-Energy-report.pdf; Peter C. Slorach, Harish K. Jeswani, Rosa Cuéllar-Franca, and Adisa Azapagic, Assessing the economic and environmental sustainability of household food waste management in the UK: Current situation and future scenarios, Science of the Total Environment, vol. 710, 25 March 2020, https://www.sciencedirect.com/science/article/pii/S0048969719355755.
[46] Eunomia, The Potential Contribution of Waste Management to a Low Carbon Economy, 2015, http://www.eunomia.co.uk/wp-content/uploads/2015/11/Technical-Appendices-EN-1.pdf.
[47] Emissions saved include those that would have been generated through mining, extracting, processing, manufacturing, and disposing of the materials. Eunomia, The Potential Contribution of Waste Management to a Low Carbon Economy, 2015, http://www.eunomia.co.uk/wp-content/uploads/2015/11/Technical-Appendices-EN-1.pdf.
[48] Note that this excludes the greenhouse gas emissions balance of growing the crops or producing the organic material in the first place, as this will be equal regardless of the processing route. More information about the total greenhouse gas balance can be found in Ofgem, Guidance for Anaerobic Digestion generators: SEG sustainability criteria and reporting requirements, 2019, https://www.ofgem.gov.uk/system/files/docs/2019/12/seg_sustainability_guidance_final_0.pdf.
[49] European Biogas Association, Digestate Factsheet: the value of organic fertilisers for Europe’s economy, society and environment, n.d., https://www.europeanbiogas.eu/wp-content/uploads/2019/07/Digestate-paper-final.pdf.
[50] Eunomia, The Potential Contribution of Waste Management to a Low Carbon Economy, 2015, http://www.eunomia.co.uk/wp-content/uploads/2015/11/Technical-Appendices-EN-1.pdf; Mark Walker et al., Assessment of micro-scale anaerobic digestion for management of urban organic waste: A case study in London, Waste Management, vol. 61, March 2017, 258–68, https://doi.org/10.1016/j.wasman.2017.01.036.
[51] Eunomia, The Potential Contribution of Waste Management to a Low Carbon Economy, 2015, http://www.eunomia.co.uk/wp-content/uploads/2015/11/Technical-Appendices-EN-1.pdf.
[52] CIE-MAP, Resource consumption, industrial strategy and UK carbon budgets, 2018, http://ciemap.leeds.ac.uk/wp-content/uploads/2018/05/Briefing-Note-4.pdf.
[53] In 2019 the UK’s total CO2 emissions were estimated at 451 million tonnes, based on which a savings of 68 million tonnes translates into a 15% reduction in economy-wide CO2 emissions. Data source: Committee on Climate Change, Reducing UK emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/.
[54] Committee on Climate Change, Reaching Net Zero in the UK, n.d., https://www.theccc.org.uk/uk-action-on-climate-change/reaching-net-zero-in-the-uk.
[55] CIE-MAP, Resource consumption, industrial strategy and UK carbon budgets, 2018, http://ciemap.leeds.ac.uk/wp-content/uploads/2018/05/Briefing-Note-4.pdf.
[56] Committee on Climate Change, Reducing UK emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/.
[57] Dennis Gammer and Susie Elks, Energy from Waste Plants with Carbon Capture: A Preliminary Assessment of Their Potential Value to the Decarbonisation of the UK, Catapult Energy Systems, May 2020, https://es.catapult.org.uk/reports/energy-from-waste-plants-with-carbon-capture/?download=true.
[58] Figure E data source sources: Committee on Climate Change, Net Zero Technical Report: Net-Zero Exhibits—Power and Hydrogen, 2019, https://www.theccc.org.uk/wp-content/uploads/2019/05/Net-Zero-Technical-Report-Power-chapter-exhibits-Web.xlsx; Committee on Climate Change, Reducing UK Emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/.
[59] Intergovernmental Panel on Climate Change, 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories, vol. 5, 2019, https://www.ipcc-nggip.iges.or.jp/public/2019rf/vol5.html.
[60] Figure F data sources: Committee on Climate Change, Net Zero Technical Report: Net-Zero Exhibits—Power and Hydrogen, 2019, https://www.theccc.org.uk/wp-content/uploads/2019/05/Net-Zero-Technical-Report-Power-chapter-exhibits-Web.xlsx; Committee on Climate Change, Reducing UK Emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/; BEIS, Digest of United Kingdom Energy Statistics 2020, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/924591/DUKES_2020_MASTER.pdf.
[61] Figure G data sources: Eunomia, The Potential Contribution of Waste Management to a Low Carbon Economy, 2015, http://www.eunomia.co.uk/wp-content/uploads/2015/11/Technical-Appendices-EN-1.pdf; Tolvik Consulting, UK Energy from Waste Statistics: 2019, May 2020, https://www.tolvik.com/wp-content/uploads/2020/05/Tolvik-UK-EfW-Statistics-2019-Report-June-2020.pdf.
[62] Tolvik Consulting, UK Energy from Waste Statistics: 2019, May 2020, https://www.tolvik.com/wp-content/uploads/2020/05/Tolvik-UK-EfW-Statistics-2019-Report-June-2020.pdf.
[63] Note that this assumption is only valid for newly built EfW incineration facilities, and not for ones that replace existing EfW plants that already produce electricity.
[64] Values are based on compensation of 0.61 MWh of grid mix replaced per tonne of waste incinerated, given a 22% incineration efficiency and a 10 GJ per tonne calorific value, which results in an efficiency of 1.64 tonnes of waste per MWh of electricity generated. The calculation is based on the average grid mix carbon intensity of 214 kilograms per MWh, or a total reduction of 130 kilograms per tonne of waste incinerated (0.61 MWh per tonne incinerated multiplied by 214 kilograms per MWh). Instead of using average grid carbon intensity values as counterfactuals, some studies use carbon intensity values associated with natural gas power plants. This approach is misleading because EfW incineration facilities do not provide a 1:1 replacement of natural gas power. Cited values are drawn from BEIS, Electricity Generation Costs 2020, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/911817/electricity-generation-cost-report-2020.pdf.
[65] The calculation is based on an estimated 0.4 MWh of heat produced per tonne of waste incinerated and a carbon intensity for gas boilers of 236 kg of CO2 equivalent per MWh, resulting in 94 kg of CO2e per tonne of waste. Values are drawn from Ramboll, North London Heat and Power Project: Carbon Impact Screening Edmonton ERF, 2019, http://northlondonheatandpower.london/media/udfapcyh/nlwa-carbon-impact-study-report-ver-2-f.pdf.
[66] Note that recovery operations differ from disposal operations, whereby EfW incineration serves to treat hazardous waste or non-hazardous waste that is currently difficult to recycle. See Chartered Institution of Wastes Management, The R1 Energy Efficiency Formula, 2020, https://www.ciwm.co.uk/ciwm/knowledge/the-r1-energy-efficiency-formula.aspx.
[67] The quality of collected materials for recycling also affects costs to local authorities, since lower-quality materials with higher contamination levels increases the cost of processing and recycling. The result is a rise in gate fees to waste operators or material recovery facilities for processing the source-separated recycling materials.
[68] BEIS, Electricity Generation Costs 2020, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/911817/electricity-generation-cost-report-2020.pdf.
[69] The baseline EfW incineration value of 1.63 tonnes of waste that provides for 1 MWh of energy by incineration is calculated based on two assumptions: 1) that 10 GJ of energy is contained in a tonne of waste (2.78 MWh/tonne), and 2) that EfW incineration efficiency is 22%, implying an energy loss of 78% in the conversion and from parasitic load. Both assumptions are from BEIS, Electricity Generation Costs 2020, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/911817/electricity-generation-cost-report-2020.pdf.
[70] The cost values for high-value recycling are based on the net cost of recycling after sales of recycled materials, excluding material recovery, estimated at £31 per tonne, based on the net revenue burden of recycling per household for England (see SUEZ, The Economics of Change in the Resources and Waste Sector, 2019, https://www.suez.co.uk/-/media/suez-uk/files/publication/suez-economicsofchange-2019941.pdf). The assumption here is that the low recycling rate in England (43% in 2018/19) means that primarily high-value materials are recycled, which results in a low marginal cost of recycling. For example, the material recovery facility cost of separating commingled waste is equivalent to the gate fee of £17 per tonne for England (see Hannah Dick and Peter Scholes, Comparing the costs of alternative waste treatment options: WRAP gate fees 2018/19 report, 2019, https://www.wrap.org.uk/sites/files/wrap/WRAP%20gate%20fees%20report%202019.pdf). That translates into a £28 cost for processing 1.63 tonnes. The renewable energy costs are drawn from BEIS, Electricity Generation Costs 2020, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/911817/electricity-generation-cost-report-2020.pdf.
[71] The cost values for high-value recycling are based on the net cost of recycling after sales of recycled materials, excluding material recovery, estimated at £31 per tonne, based on the net revenue burden of recycling per household for Wales (see SUEZ, The Economics of Change in the Resources and Waste Sector, 2019, https://www.suez.co.uk/-/media/suez-uk/files/publication/suez-economicsofchange-2019941.pdf). The assumption here is that the much higher recycling rates in Wales (above 65%, which is among the highest in the world) means that a significant stream of low-value materials is recycled, which results in a high marginal cost of recycling. For example, the material recovery facility cost of separating commingled waste is equivalent to the gate fee of £49 per tonne for Wales (see Hannah Dick and Peter Scholes, Comparing the costs of alternative waste treatment options: WRAP gate fees 2018/19 report, 2019, https://www.wrap.org.uk/sites/files/wrap/WRAP%20gate%20fees%20report%202019.pdf). That translates into a £80 cost for processing 1.63 tonnes. The renewable energy costs are drawn from BEIS, Electricity Generation Costs 2020, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/911817/electricity-generation-cost-report-2020.pdf
[72] Note that the evaluation here concerns investments in new EfW incineration capacity, in contrast to existing EfW incinerators, which have already amortized their capital investment costs. The evaluation also excludes the costs of polluting, such as carbon pricing costs, and other externalities, given that these are currently not priced in and thus do not have an impact on EfW incineration investment decisions.
[73] Hannah Dick and Peter Scholes, Comparing the costs of alternative waste treatment options: WRAP gate fees 2018/19 report, 2019, https://www.wrap.org.uk/sites/files/wrap/WRAP%20gate%20fees%20report%202019.pdf.
[74] Simon Rawlinson and Matthew Hicks, Cost Model Energy from Waste, Building Magazine, 22 April 2010, https://www.slideshare.net/matthewhicks/efw-cost-model-from-building-magazine.
[75] Key evidence that EfW incineration gate fees follow the price of landfill gate fees + the landfill tax over time is the parallel increase in both, as shown in Table C.
Table B Landfill tax and gate fees vs. EfW incineration gate fees, 1996–2020
Note: Values are in 2018 real prices.
Data sources: Credit Suisse, Energy from Waste: the next downside risk, 2013, https://research-doc.credit-suisse.com/docView?sourceid=em&document_id=x529593&serialid=9tJdZlDpO3IAxfhYGLt9Zn5SYWx9KMTsn%2FS70UOA4nc%3D; EU Commission, Waste management options and climate change, 2001, https://ec.europa.eu/environment/waste/studies/pdf/climate_change.pdf; Eunomia, ‘Biostabilisation’ of Wastes: Making the Case for a Differential Rate of Landfill Tax, 2008, http://www.organics-recycling.org.uk/dmdocuments/Eunomia_Jan_2008_report.pdf; Eunomia, Costs for Municipal Management in the EU, 2002, https://ec.europa.eu/environment/waste/studies/pdf/eucostwaste.pdf; Institute for Fiscal Studies, Rates of Landfill Tax 1996–2015, n.d., www.ifs.org.uk/uploads/publications/ff/landfill.xls; London Assembly, London Assembly Environment Committee’s Response to the Public Consultation Draft of the Municipal Waste Management Strategy, 2002, https://www.london.gov.uk/sites/default/files/gla_migrate_files_destination/archives/assembly-reports-environment-waste_dec02.pdf; WRAP, Gate Fees Report 2008: Comparing the cost of alternative waste treatment options, https://www.wrap.org.uk/sites/files/wrap/W504GateFeesReport%20FINAL.pdf; WRAP, Gate fees report 2015/2016: Comparing the costs of waste treatment options, 2016, https://www.wrap.org.uk/sites/files/wrap/Gate%20fees%20infographic%20020616.pdf; WRAP, Gate fees report 2018/2019: Comparing the costs of alternative waste treatment options, 2019, https://www.wrap.org.uk/gatefees2019
In a 2013 analysis of the UK EfW market, investment bank Credit Suisse describes price setting of EfW incineration gate fees relative to landfilling: ‘There is currently c6mt of EfW capacity in the UK, with c40mt of waste going to landfill p.a. This drives the perceived opportunity for investment in EfW, as operators can charge only a small discount to the all-in landfill cost (gate fee + tax) for waste intake, and earn additional revenue from power generation.’ Credit Suisse, Energy from Waste: the next downside risk, 2013, https://research-doc.credit-suisse.com/docView?sourceid=em&document_id=x529593&serialid=9tJdZlDpO3IAxfhYGLt9Zn5SYWx9KMTsn%2FS70UOA4nc%3D.
Waste and resource industry stakeholders have similarly noted: ‘The lack of alternatives to landfill within the UK was stated as a secondary consideration but all stakeholders said they would use local facilities if available and the costs were comparable. It was noted by several that gate fees at UK & Irish EfW facilities seem to track the increased cost of landfill rather than becoming a more competitive option as landfill tax rates increase.’ Chartered Institution of Wastes Management, Research into SRF and RDF Exports to other EU countries, 2013, https://www.ciwm.co.uk/Custom/BSIDocumentSelector/Pages/DocumentViewer.aspx?id=QoR7FzWBtisamYEcWSfL6SxAJRLAPT9vf9UOxY7TX%252bRTmuWeo5keV9skGlWyOY%252bUp7ncAXRDbF5GQWy%252bL3ZD1svIqkmjQD8b%252bRybjUOcZx%252bbtUeOK%252boD%252bWOteFwHaqlYgAzUrm8WMLMdw9l4vZRVeLc0jOqrhVN1UXyICTOMcvHDJhyoW%252b1C2Q%253d%253d.
For further evidence, see section 6.3 in Environment Agency, Evidence: reasons for trends in English refuse derived fuel exports since 2010, 2015, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/438906/Reasons_for_trends_in_English_refuse_derived_fuel_exports_since_2010_report.pdf.
[76] The UK Competition & Markets Authority concluded that local authorities are still entering into longer and broader domestic waste collection contracts, which can limit competition and are associated with authority spending that is statistically significantly higher. See UK Competition & Markets Authority, Local authority waste contracts: CMA analysis, 2017, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/657858/local-authority-waste-contracts-cma-analysis.pdf.
[77] BEIS, Electricity Generation Costs 2020, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/911817/electricity-generation-cost-report-2020.pdf.
[78] Tolvik Consulting, UK Energy from Waste Statistics: 2019, May 2020, https://www.tolvik.com/wp-content/uploads/2020/05/Tolvik-UK-EfW-Statistics-2019-Report-June-2020.pdf.
[79] Hannah Dick and Peter Scholes, Comparing the costs of alternative waste treatment options: WRAP gate fees 2018/19 report, 2019, https://www.wrap.org.uk/sites/files/wrap/WRAP%20gate%20fees%20report%202019.pdf.
[80] For examples, including evidence from European cities, Japan, and the United States, see the following studies: Juergen Morlok et al., The Impact of Pay-As-You Throw Schemes on Municipal Solid Waste Management: The Exemplar Case of the County of Aschaffenburg, Germany, Resources, 6(1), 2017, https://www.mdpi.com/2079-9276/6/1/8; Christopher Wright, John M. Halstead, and Ju-Chin Huang, Estimating Treatment Effects of Unit-Based Pricing of Household Solid Waste Disposal, Agriculture and Resource Economics Review, 2019, https://www.cambridge.org/core/services/aop-cambridge-core/content/view/BCB860759B12645C695E1C519B61AB9E/S1068280518000023a.pdf/div-class-title-estimating-treatment-effects-of-unit-based-pricing-of-household-solid-waste-disposal-div.pdf; Takehiro Usui and Kenji Takeuchi, Evaluating Unit-Based Pricing of Residential Solid Waste: A Panel Data Analysis, Environmental and Resource Economics, 58, 245–71, https://link.springer.com/article/10.1007/s10640-013-9702-7; Nicole Seyring et al., Assessment of separate collection schemes in the 28 capitals of the EU, European Commission Directorate-General Environment, 2015, https://ec.europa.eu/environment/waste/studies/pdf/Separate%20collection_Final%20Report.pdf.
[81] Multi-layer, multi-material packaging consists of two or more layers—each of a different material, such as card and aluminium—that are often glued together. The materials tend to be difficult to separate and thus are no longer recyclable. A popular example is crisps packaging, which typically consists of layers of different plastic types. Alternative solutions include easily separable packaging, multi-layer replacement with mono-material multi-layer packaging, or biodegradable multi-layer packaging.
[82] The calculation is based on £100 million per existing incinerator, plus £4 million per year of operation. Dennis Gammer and Susie Elks, Energy from Waste Plants with Carbon Capture: A Preliminary Assessment of Their Potential Value to the Decarbonisation of the UK, Catapult Energy Systems, May 2020, https://es.catapult.org.uk/reports/energy-from-waste-plants-with-carbon-capture/?download=true.
[83] Dennis Gammer and Susie Elks, Energy from Waste Plants with Carbon Capture: A Preliminary Assessment of Their Potential Value to the Decarbonisation of the UK, Catapult Energy Systems, May 2020, https://es.catapult.org.uk/reports/energy-from-waste-plants-with-carbon-capture/?download=true; BEIS, Electricity Generation Costs 2020, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/911817/electricity-generation-cost-report-2020.pdf.
[84] Figure H data sources: this study; BEIS, Electricity Generation Costs 2020, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/911817/electricity-generation-cost-report-2020.pdf; Hannah Dick and Peter Scholes, Comparing the costs of alternative waste treatment options: WRAP gate fees 2018/19 report, 2019, https://www.wrap.org.uk/sites/files/wrap/WRAP%20gate%20fees%20report%202019.pdf); MHCLG, Local authority revenue expenditure and financing England: 2018 to 2019 budget individual local authority data, 2018, https://www.gov.uk/government/statistics/local-authority-revenue-expenditure-and-financing-england-2018-to-2019-budget-individual-local-authority-data; SUEZ, The Economics of Change in the Resources and Waste Sector, 2019, https://www.suez.co.uk/-/media/suez-uk/files/publication/suez-economicsofchange-2019941.pdf.
[85] Figure I data sources: this study; BEIS, Electricity Generation Costs 2020, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/911817/electricity-generation-cost-report-2020.pdf; Hannah Dick and Peter Scholes, Comparing the costs of alternative waste treatment options: WRAP gate fees 2018/19 report, 2019, https://www.wrap.org.uk/sites/files/wrap/WRAP%20gate%20fees%20report%202019.pdf); MHCLG, Local authority revenue expenditure and financing England: 2018 to 2019 budget individual local authority data, 2018, https://www.gov.uk/government/statistics/local-authority-revenue-expenditure-and-financing-england-2018-to-2019-budget-individual-local-authority-data; SUEZ, The Economics of Change in the Resources and Waste Sector, 2019, https://www.suez.co.uk/-/media/suez-uk/files/publication/suez-economicsofchange-2019941.pdf.
[86] Tolvik Consulting, UK Energy from Waste Statistics: 2019, May 2020, https://www.tolvik.com/wp-content/uploads/2020/05/Tolvik-UK-EfW-Statistics-2019-Report-June-2020.pdf; DEFRA, Local authority collected waste: annual results tables, 2020, https://www.gov.uk/government/statistical-data-sets/env18-local-authority-collected-waste-annual-results-tables.
[87] Tolvik Consulting, UK Energy from Waste Statistics: 2019, May 2020, https://www.tolvik.com/wp-content/uploads/2020/05/Tolvik-UK-EfW-Statistics-2019-Report-June-2020.pdf; Augean, Investor Presentation: The UK’s leading provider of hazardous waste management solutions, November 2019, https://www.augeanplc.com/wp-content/uploads/Augean-Investor-Presentation-November-2019.pdf.
[88] Note that these calculations refer to operational capacity and not headline capacity. The scenario assumes a headline capacity of 26 million tonnes by 2035.
[89] Tolvik Consulting, UK Residual Waste: 2030 Market Review, 2017, https://www.tolvik.com/wp-content/uploads/2017/11/UK_Residual_Waste_Capacity_Gap_Analysis.pdf.
[90] DEFRA, Our Waste, Our Resources: A Strategy for England, 2018, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/765914/resources-waste-strategy-dec-2018.pdf.
[91] Resource Recovery from Waste Programme, Energy from Waste and a Circular Economy: A Response from the Resource Recovery from Waste Programme to the Policy Connect Call for Evidence on Energy from Waste, July 2020, https://resourcerecoveryfromwaste.files.wordpress.com/2020/07/policy-connect-evidence-call-efw_response-rrfw_final.pdf.
[92] DEFRA, Circular Economy Package Policy Statement, 30 July 2020, https://www.gov.uk/government/publications/circular-economy-package-policy-statement/circular-economy-package-policy-statement.
[93] Tolvik Consulting, UK Residual Waste: 2030 Market Review, 2017, https://www.tolvik.com/wp-content/uploads/2017/11/UK_Residual_Waste_Capacity_Gap_Analysis.pdf.
[94] DEFRA, Resources and Waste Strategy: Monitoring Progress, 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/907029/resources-and-waste-strategy-monitoring-progress.pdf;
[95] DEFRA, Our Waste, Our Resources: A Strategy for England—Evidence Annex, 2018, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/765915/rws-evidence-annex.pdf.
[96] The potential overcapacity of 14 million tonnes of EfW incineration overcapacity is based on an increase in EfW incineration headline capacity from 15.4 million to 21.8 million tonnes by 2024 and 26 million tonnes by 2030, after which it is expected to stabilise, and a reduction in residual waste arisings from 28.7 million tonnes in 2019 (of which 2.35 million tonnes was exported as RDF), to 22 million tonnes by 2024, 16.8 million tonnes by 2030, and 12.0 million tonnes by 2035. The scenario assumes that the EfW incineration facilities that are currently under construction will be completed, along with 50% of EfW incineration plants that have been commissioned or that are in the planning pipeline.
[97] Michael Ware, Is energy from waste the next big investment opportunity?, Green Giraffe, 18 April 2019, https://green-giraffe.eu/blog/energy-waste-next-big-investment-opportunity.
[98] Danish Environmental Protection Agency (Miljøstyrelse), Affaldsstatistik 2018, 2020, https://www2.mst.dk/Udgiv/publikationer/2020/05/978-87-7038-183-3.pdf.
[99] Government of Denmark, Aftale mellem regeringen (Socialdemokratiet) og Venstre, Radikale Venstre, Socialistisk Folkeparti, Enhedslisten Det Konservative Folkeparti, Liberal Alliance og Alternativet om Klimaplan for en grøn affaldssektor og cirkulær økonomi, 16 June 2020, https://www.regeringen.dk/media/9591/aftaletekst.pdf.
[100] Government of Denmark, Aftale mellem regeringen (Socialdemokratiet) og Venstre, Radikale Venstre, Socialistisk Folkeparti, Enhedslisten Det Konservative Folkeparti, Liberal Alliance og Alternativet om Klimaplan for en grøn affaldssektor og cirkulær økonomi, 16 June 2020, https://www.regeringen.dk/media/9591/aftaletekst.pdf.
[101] Dutch Waste Management Association (Vereniging Afvalbedrijven Nederland), Beleidskader Afvalverbranding in Nederland: Sluitstuk in de transitie naar een circulaire economie, 2018, https://www.verenigingafvalbedrijven.nl/userfiles/files/LAP3-Beleidskader%20Afvalverbranding%20in%20Nederland.pdf.
[102] Swedish Environmental Protection Agency (Natursvardsverket), Att gora mer med mindre: Nationell afvallsplan och afvallsforebyggande program 2018–2023, 2018, http://www.naturvardsverket.se/Documents/publikationer6400/978-91-620-6857-8.pdf?pid=23951.
[103] Figure J data sources: this study; DEFRA, Local authority collected waste: annual results tables, 2020, https://www.gov.uk/government/statistical-data-sets/env18-local-authority-collected-waste-annual-results-tables; Tolvik Consulting, UK Energy from Waste Statistics: 2019, May 2020, https://www.tolvik.com/wp-content/uploads/2020/05/Tolvik-UK-EfW-Statistics-2019-Report-June-2020.pdf.