Future waste management methods - What you told us at the Issues and Options Stage

Comment

Representation ID: 861

Received: 12/04/2022

Respondent: Shlomo Dowen

Energy from incineration should not be described as ‘low carbon’
82. Only Solutions takes issue with the dWLP framing that, in relation to the views of
Issues and Options consultees, “The majority of respondents supported the use of
energy recovery where this would reduce the need for landfill and increase the
supply of low carbon energy”.
83. Numerous studies have found that is not correct to suggest that the energy
currently generated from waste incineration could reasonably be described as
‘low carbon energy’, including ‘Evaluation of the climate change impacts of waste
incineration in the United Kingdom’24,‘The climate change impacts of burning
municipal waste in Scotland - Technical Report’25, ‘Greenhouse Gas and Air
Quality Impacts of Incineration and Landfill’26, 'Dirty white elephants: Incinerators
were supposed to solve the UK’s waste crisis. Are they making it worse?'27 and
the Climate Change Committee’s (CCC’s) Sixth Carbon Budget (see below).
84. The incineration of a tonne of waste typically results in the direct release of
around 1 tonne of CO2. Around half of the CO2 in mixed waste is 'fossil CO2', and
this proportion can be significantly higher when food waste is separately
collected.
85. As set out in the table overleaf, the CCC noted that "In a Net Zero world EfW
facilities are likely to be significantly higher carbon than other forms of energy
production" and the CCC categorises unabated waste incineration as a 'highcarbon'
activity.
86. In May 2021 the UK Government stated: "Incineration of fossil derived waste is a
contributor to greenhouse gas emissions. Total greenhouse gas emissions from
waste incineration accounted for around 1.4% (6.47 million tonnes of carbon
dioxide equivalent) of the UK’s [non-biogenic] greenhouse gas emissions in 2019.
Of this, about 6.19 million tonnes of [fossil] carbon dioxide equivalent was
emitted from Energy from Waste plants. It is clear that we will need to reduce
that impact. That is why the Government continues to take action, including
through our Environment Bill measures, to reduce, re-use and recycle more of our
waste and to move to a circular economy".29
87. Focussing on the fossil CO2e released per net unit of energy exported to the grid,
the annual reported real world carbon intensity of the incinerators set out above
typically ranged from around 828 to 873 grams of fossil CO2e per kWh exported.
This is significantly higher than the carbon intensity of Combined Cycle Gas
Turbines (CCGT) and the BEIS estimates for long-run and grid average fossil
carbon intensity. The total CO2 emissions released by these incineration plants is
roughly double the fossil CO2 figure because of the release of biogenic CO2.
88. Even if one assumes the carbon intensity for incinerators is the same as that
claimed by Cory Energy for their Riverside incinerator of 617 gCO2/kWh30, modern
waste incinerators still have a significantly higher carbon intensity than the
conventional use of fossil fuels (and far higher emissions than technologies like
solar and wind).
89. Tables overleaf are reproduced from the July 2021 ‘Good Practice Guidance for
Assessing the GHG Impacts of Waste Incineration’.
(see attached document for tables)
90. Furthermore, as set out in the Glossary to the National Planning Policy
Framework (NPPF), energy generated by waste incinerators fails to meet the
NPPF definition of ‘low carbon’ which relates only to “technologies…that can help
reduce emissions (compared to conventional use of fossil fuels)”.