Scotland’s residual waste may have to be sent to England due to a capacity gap following the implementation of the country’s biodegradable waste landfill ban, according to a new report commission by the Scottish Government.
From 1 January 2021, landfill operators in Scotland will be prohibited from accepting biodegradable municipal waste for disposal in landfill.
Despite industry investment in around 950,000 tonnes of additional treatment capacity to help meet the 2021 ban, the country’s residual waste policy framework, coupled with what the Scottish Environmental Services Association (SESA) calls an “uncoordinated approach to public procurement”, has made it difficult to secure the additional investment needed to close the capacity gap further.
The study, which was commission by the Scottish Government and produced by Eunomia Research & Consulting, concludes there is a significant capacity gap. It suggests the resulting scale and affordability of alternative solutions means these are unlikely to be available when the ban takes effect.
In terms of industry readiness, 14 local authorities will have solutions in place, with the remaining 18 in various stages of preparedness.
SESA’s policy advisor, Stephen Freeland – “To unlock investment in sufficient non-landfill capacity the industry needs more commitment from the Scottish Government than a fleeting reference to the landfill ban within regulation.”
Commercial waste operators do not appear yet to have made adequate preparations for the ban.The shortfall being predicted in Year 1 is of between 1.01 million tonnes to 1.28 million tonnes, as of the 1 of January 2021.
The Eunomia study examined two options for how the gap could be managed, both of which present real and immediate challenges to the industry with significant costs ranging from £414 million to £1.156 billion during the period 2021 – 2030.
The first of these is based on Scotland exporting residual waste to treatment facilities in England or continental Europe, or landfill sites in England – there are significant risks associated with this – political, increasing treatment costs, loss of revenue, and a diminishing and finite capacity south of the border.
The second focuses on Scotland constructing its own additional treatment facilities, which in later years would reduce the amount of waste (and therefore revenue) that is exported, and would help to limit haulage distances.
But these facilities will not be online before 2025, and the economic benefits that could be achieved are not sufficient to outweigh the costs incurred between 2021 and 2024 for the interim solutions that are still required to meet the requirements of the ban.
Bruce Reekie, Vice Chair of CIWM Scotland – “This study highlights the many challenges that the BMW ban poses for our sector and we at CIWM have established a Landfill Ban for Biodegradable Waste Working Group involving key industry partners, including the Scottish Government, SEPA, SESA, local authorities, the private waste sector and Zero Waste Scotland to discuss potential interim solutions”
SESA’s policy advisor, Stephen Freeland said: “To unlock investment in sufficient non-landfill capacity the industry needs more commitment from the Scottish Government than a fleeting reference to the landfill ban within regulation. This investment is reliant upon a strong and enabling waste policy framework for non-recyclable waste which has, up to now, been sadly lacking. We suggest that the Scottish Government provides details of a long term infrastructure and investment plan for Scotland to allow private and public-sector partners to adequately identify options for appropriate development.”
“SESA Members aim at all times to achieve cost effective regulatory compliance. Unfortunately, in this case, landfill in England is the only practical option available to the industry for dealing with the majority of the 1 million tonnes of waste that needs a new home in 2021. This will be a £100m Landfill Tax gift to the English revenue.”
Bruce Reekie, Vice Chair of CIWM Scotland, stated: “This study highlights the many challenges that the BMW ban poses for our sector and we at CIWM have established a Landfill Ban for Biodegradable Waste Working Group involving key industry partners, including the Scottish Government, SEPA, SESA, local authorities, the private waste sector and Zero Waste Scotland to discuss potential interim solutions.
“Ideas put forward include proposals for a system based around the principles of the Landfill Allowance Scheme (LAS) with the baseline set to 2021 and with the allowance provided directly to local authorities, or deferrals with increased landfill tax costs to drive progress. We look forward to working with the Scottish Government to help develop practical, affordable and acceptable interim solutions to support the implementation of the BMW ban.”