Comment

Representation ID: 859

Received: 12/04/2022

Respondent: Shlomo Dowen

1. Paragraph 3.5 of the draft Waste Local Plan (dWLP) states that: “Although the UK
left the EU in January 2020, the Government has stated that there are unlikely to
be any immediate changes to UK waste policy and targets, however this will be
kept under review and this plan will be updated accordingly” citing a non-
Government website as the source.
2. In reality, Government has put forward a range of post-Brexit proposals to change
UK waste policy and targets, over and above the measure set out in the
Resources and Waste Strategy (e.g. consistency of collection requirements
including of food waste and dry recyclate, 65% recycling target, Extended
producer Responsibility (EPR) scheme, Deposit Return Scheme (DRS), etc.).
3. These additional post-Brexit proposals include:
• Changes to the National Policy Statement for renewable energy infrastructure
(EN-3) to strengthen protections against incineration overcapacity;
• New waste reduction targets which imply higher recycling ambitions; and
• Inclusion of incineration (EfW) in the Emissions Trading Scheme (ETS) which
could free up capacity at existing waste incinerators whilst making recycling
and waste minimisation more financially attractive.
Changes to EN-3 to strengthen protections against incineration overcapacity
4. Draft EN-3 (2021) are paragraphs 2.10.4 and 2.10.5 states that:
“2.10.4 As the primary function of EfW plants is to treat waste, applicants must
demonstrate that proposed EfW plants are in line with Defra’s policy position on
the role of energy from waste in treating municipal waste.
"2.10.5 The proposed plant must not result in over-capacity of EfW waste
treatment at a national or local level.”
5. One planning professional who is currently working for the incineration industry
commented on the significance of this national requirement, stating that "…this
wording would mean they [promoters of new EfW waste treatment schemes] will
need to be robust in making the case that there is demand for the project"
6. This indicates that the Government is acknowledging the need for the planning
system to ensure that controls are in place to prevent incineration overcapacity.
Such an interpretation is in line with other Government statements.
7. In the House of Commons John Grogan MP questioned the then Environment
Secretary Michael Gove, asking: "Most studies now indicate that we have an
excess of incineration capacity to deal with residual waste. Is there not a danger
that, if we build more incinerators, waste that would otherwise be recycled will
be diverted to those incinerators?" and the Environment Secretary acknowledged
this danger by responding: "That is a fair point".2
8. Rebecca Pow, speaking on behalf of the Government, told Parliament that: "...we
seek to minimise the amount of waste that goes to incineration or landfill…"3
9. The UK Government's then Resource Minister Thérèse Coffey gave oral evidence
to the Environmental Audit Committee that: "I think, actually, there is sufficient
capacity out there for incineration”.4
New waste reduction targets which imply higher recycling ambitions
10. The Government has announced proposals for an environmental target to halve
the waste that ends up at landfill or incineration by 2042.5
11. The Government explains that the target “would represent a municipal recycling
rate of around 70-75% by 2042”, and so this goes beyond the Resources and
Waste Strategy’s ambition to reach 65% recycling by 2035.
12. This indicates that we could have significant incineration overcapacity compared
future demand, highlighting the importance of ensuring that there are high
recycling and waste minimisation targets along with appropriate planning
controls to prevent incineration overcapacity.
Inclusion of incineration (EfW) in the Emissions Trading Scheme (ETS) which could
make recycling and waste minimisation more financially attractive.
13. The UK’s Emissions Trading Scheme (ETS) provides a mechanism to require those
who produce electricity to pay towards the carbon cost of their activity.
14. For years incinerator operators have been exempt from being part of this
scheme, but the Government is now proposing to close this loophole.
15. According to the consultation document: “Our starting proposition is that the UK
ETS should cover the incineration of fossil material by all waste incinerators. This
means the UK ETS obligation for robust monitoring, reporting and verification
(MRV) would be placed on all operators of waste incinerators. For EfW, this
would mean conventional incineration and ATT/ACT (pyrolysis/gasification) would
fall under the scope of the UK ETS and pay a carbon price according to their
greenhouse gas emissions”.6
16. Increasing the price of incineration could potentially push waste further up the
waste hierarchy, making higher recycling and waste minimisation objectives more
financially attractive.
17. Measures to reduce the quantity of plastic and other high-carbon materials going
to incineration, such as front-end sorting, would free up capacity at existing
incinerators. To the extent that removing plastic reduces the calorific value of the
feedstock, it can increase the total capacity of the incineration plants.
18. Incinerators that increased their permitted/consented capacity while maintaining
their thermal MW capacity to allow for greater operational hours and/or reduced
average CV include: Ardley7 (Oxfordshire), Avonmouth8 (Bristol), Beddington
Lane9 (South London), Cardiff10, Great Blakenham11 (Ipswich), K3 CHP12 in
Sittingbourne (Kent), Runcorn13 (Cheshire), Severnside Energy Recovery14 (South
Gloucestershire), and Slough Multifuel15 (Berkshire).
19. For example, the above sources show that in Cardiff it was reported that: “lower
average calorific value of waste is being generated – meaning more waste is
needed to maintain the energy output”, and in relation to Beddington Lane it was
stated that: “There is no change to the original design capacity of the incinerator
and this increase [in maximum authorized capacity] reflects the potential for the
burning of a higher tonnage of waste at a lower calorific value”.