Communication Barrier

The European Commission’s long-awaited Communication on Waste to Energy is “confused, complacent and counter-productive to sustainable waste management”, says the ESA’s policy & parliamentary affairs officer, Libby Forrest.

In January this year, the European Commission published its long-awaited Communication on Waste to Energy (WtE). The purpose of the Communication, as stated in the preliminary Roadmap published early 2016, is to “harness the potential in extracting resources, eg, energy and materials embedded in non-recyclable waste” by clarifying the role of WtE in the waste hierarchy, addressing unevenly spread capacities across member states and optimising the contribution of WtE to the EU’s climate and energy objectives.

Unlike the Circular Economy Package, it is not legally-binding, relieving us of an additional set of speculations about how EU legislation might apply to the UK after Brexit. Rather, it is meant to send a message to policy-makers and investors on how WtE should be deployed in a circular economy.

Disappointingly, the message the Commission has sent is confused, complacent and counter-productive to sustainable waste management. It significantly weakens the view put forward in the Roadmap that WtE for non-recyclable waste “not only makes sense under the resource circularity, but also … [has] a powerful climate change [mitigation] potential”.

Instead, its tone is half-hearted, failing to recognise the importance of WtE in a circular economy and the reality of residual waste management under-capacity across the EU as a whole.


The Commission appears to pit WtE, in particular incineration with energy recovery (energy from waste, EfW), against recycling. Having previously cited Germany and the Netherlands as having high incineration rates, it states that these rates are “inconsistent with more ambitious recycling targets”, omitting the fact that the aforementioned countries also have some of the highest levels of recycling in the EU. It is clearly untrue that EfW is incompatible with high recycling rates.

“Disappointingly, the message the Commission has sent is confused, complacent and counter-productive to sustainable waste management.”

This false dilemma between EfW and recycling is unhelpful; the focus should be on determining the appropriate waste treatment method from a technical, environmental and economic perspective for different waste streams. Even with 65% or 70% household recycling targets by 2030 in the forthcoming Circular Economy Package, there will still be 30-35% residual waste.

Moreover, there will always be some non-recyclable waste and residues from recycling for which EfW is the main alternative to landfill in treating it in the most environmentally-friendly and resource-efficient way.

The Commission is sending mixed messages by pursuing greater landfill diversion without fully appreciating the role EfW has to play in treating waste that cannot be recycled.

In suggesting that EfW is holding back recycling, the Commission misdiagnoses the problem; weak markets for recycled materials are the real threat. Measures to boost recycling should address this rather than seek to curb EfW, for example with the incineration taxes proposed in the Communication.


The waste hierarchy

On top of this, the Communication is overly cautious about excessive capacity of EfW. ESA agrees that it is important to avoid over-capacity, but this is an unlikely scenario in the UK, and as the Commission states, there is currently an under-capacity across Member States.

In the UK, that under-capacity is a serious threat to waste management. The rate of landfill closures in the UK is exceeding the rate at which new residual waste treatment capacity, mainly EfW, is being developed. Landfill capacity was estimated at 20 million tonnes in 2015. This is expected to almost halve by 2020 before dropping further to 6 million tonnes in 2025 and just 4 million tonnes in 2030. At the same time, it is uncertain how far we can continue to rely on exports of refuse-derived fuel post Brexit.

Given that new EfW plants have lead in times of four to six years, if we do not address the capacity gap now, we will sleepwalk into a situation in which the only viable option is to open new landfills, a backwards step in sustainable waste management. Calls for incinerations taxes are therefore highly premature and send the wrong signal to investors.


The Communication also fails to recognise the contribution of EfW in reducing emissions, generating low-carbon power and tackling climate change, which is disappointing given that it was announced under the Energy Union.

From an environmental point of view, EfW supports the waste hierarchy in diverting waste that cannot be recycled from landfill. This avoids emissions associated with landfill; the Government greenhouse gas conversation factor for municipal waste treated by EfW is 21kg CO₂ equivalent per tonne whereas landfill is 421kg CO₂e/t.

“For the UK, policy clarity is all the more important with the additional uncertainties over the terms of the UK’s eventual exit from the EU.”

Energy generation also offsets emissions resulting in further carbon savings. As a source of low-carbon power, EfW benefits security of supply as well as contributing to renewable energy targets. In 2015, it provided 1.6% of the UK’s total electricity and 3.3% of our renewable electricity.

It therefore plays a small but significant role in the UK’s energy mix. The Communication missed the opportunity to promote these benefits of EfW, and instead its unnecessarily cautious tone could be damaging to resource efficiency and progress in tackling climate change.

Looking ahead

As previously mentioned, it is vital that the UK builds more EfW capacity. This will require fresh private investment, which can only be delivered under clear policy direction. It is therefore disappointing that the Communication sends such a confused and tentative message. For the UK, policy clarity is all the more important with the additional uncertainties over the terms of the UK’s eventual exit from the EU.

The Industrial Strategy and 25 year plan for the environment provide opportunities for the UK to set its own strategy for dealing with residual waste. We hope they will both take seriously the urgency of the residual waste treatment situation in the UK and seek to capitalise the benefits EfW has to offer.

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