The ESA's report entitled A sustainable transition into the Emissions Trading Scheme outlines the ESA's proposed approach "for the application of the Emissions Trading Scheme (ETS) to EfW facilities that is pragmatic."

The document lays out five priority areas which are all required to facilitate a feasible transition. These are: 

1. Working to a deliverable timetable 
2. Avoiding unintended consequences such as more waste going to landfill 
3. Ensuring clear and practical implementation supported by clear regulation 
4. Maintaining sustainable economic impacts 
5. Incentivising investment 

The ESA also outlines some priority conditions which must be in place before full implementation of the ETS is applied to EfW facilities. These are to: 

• Deliver the key Resource & Waste Strategy policies to increase recycling 
• Implement policies to protect against landfill leakage 
• Ensure suitable fiscal and volume controls on RDF Exports 
• Effective regulation and enforcement of waste crime

Regarding RDF exports, the ESA report states: 

The introduction of carbon pricing to EfW should not encourage the export of residual waste outside the UK. The ESA believes the most appropriate mechanism for managing this leakage risk is a prevention of RDF export when sufficient UK capacity becomes operational. The existing transfrontier shipment of waste regulations provide a potential mechanism to address this."

You can view the full document here.