Independent Review of the Role of EfW in Scotland recommends cap on new EfW plants

The Scottish government's review into EfW led by Dr Colin Church which set out to examine the role of EfW in Scotland's waste hierarchy has been released.
Independent Review of the Role of EfW in Scotland recommends cap on new EfW plants

The Independent Review of the Role of Incineration in the Waste Hierarchy (‘the Review’) commenced in November 2021, with this report being delivered in April 2022.

Below you can read a summary of the report, as published by the Review body.

The Review, chaired by Dr Colin Church, set out to answer five key questions:

1. Given Scotland’s waste management ambitions and current progress towards these, what capacity is required to manage residual waste in Scotland?

2. What are the options for managing residual waste?

3. What are the economic, environmental and social trade-offs of those residual waste management options?

4. How do we decide where capacity should be located, and in what form?

5. What can be done to improve existing residual waste treatment facilities in terms of carbon performance and societal impacts?

The Review was asked by the Minister to prioritise the assessment of national capacity requirements (Topic 1). To respond to these topics, the review considered existing evidence and commissioned additional capacity modelling, an appraisal of waste treatment options and a rapid evidence review of the potential health impacts of incinerating waste. Additionally, the Review opened a Call for Evidence, allowing stakeholders to submit written and verbal evidence and considerations for the Review.

During its review of available evidence, it became apparent to the Review that the accessibility, quality and quantity of some data around waste management in Scotland is lacking in some key aspects. To address this, the Review recommends improvements to the Scottish Government’s waste management data and for the Scottish Government, industry and local authorities to improve the transparency of their data (see Recommendation 2 and Recommendation 3).

Capacity to manage residual waste in Scotland
Overall, the capacity analysis completed for the Review suggests that there is likely to be a capacity gap in 2025, when the biodegradable municipal waste (BMW) ban comes into force. This will clearly be exacerbated if the ban is extended to include all non-municipal biodegradable waste. While this capacity gap could be closed by Scotland achieving its waste and recycling targets, stakeholders raised concerns about the likelihood of achieving these targets, drawing on experience and comparisons with other nations as evidence of what could be possible. The Review recommends that Scotland should limit the granting of further planning permissions for incineration infrastructure (see Recommendation 4). Further to this, the Review recommends that an indicative cap for the residual waste treatment needed in Scotland should be developed, and that this should decline over time as Scotland transitions towards a fully circular economy (see Recommendation 5).

The short term nature of the capacity gap, balanced against the long term likelihood of overcapacity, highlighted the difficulty in using infrastructure with long operational lifespans alone to treat residual waste. The Review finds that the risk of lock-in in waste management contracts is genuine, and recommends that local authorities specifically address this within their contracts (see Recommendation 6).

Residual Waste Management Options
The best form of residual waste treatment is preventing it occurring in the first place,
through reducing waste and recycling. The Review recommends that the Scottish
Government does more to reduce the proportion of recyclable materials in the
residual waste stream (see Recommendation 1).

In terms of managing the remaining residual waste, the Review assessed the
feasibility of a number of residual waste treatment options. In consideration of this
assessment, along with a further appraisal of social, health and climate
considerations relating to waste treatment, the Review finds that incineration’s
current place within the waste hierarchy, where overall it is preferable to other forms
of residual waste treatment, but less desirable than reducing and recycling waste, is
correct. It recommends that the most feasible waste treatment options are
incineration, landfill and export of waste (see Recommendation 7).

Trade-Offs
The Review considered the health and social impacts of residual waste management
in Scotland. This included a Rapid Evidence Review on health impacts from Public
Health Scotland, which confirmed its previous view that such impacts were likely to
be small. The Review also considered the impacts: on local amenity; the link
between deprivation and location of facilities; perception and employment, as well as
the Scottish Landfill Communities Fund and heat and energy offtake. The Review
additionally heard from stakeholders regarding the difficulties they experienced
engaging with planning processes and difficult relationships with local facilities. The
Review finds that communities deserve more authentic and committed engagement
from local authorities and industry than is currently sometimes the case (see
Recommendation 8 and Recommendation 9).

Decarbonisation
The Review has found that currently, incineration is less damaging to the
environment than landfill. However, increased incineration, changes to waste
composition and wider decarbonisation will make this less favourable over time. To
assist in monitoring this, the Review has recommended that greenhouse gas (GHG)
emissions from incineration are reported separately from other energy-related
emissions. (see Recommendation 12)

Separate work has been commissioned to inform further consideration of opportunities to decarbonise the residual waste treatment infrastructure sector in Scotland, with the main focus on waste incineration (Topic 5). In the meantime, the Review has provisionally recommended improving pre-treatment processes before incineration, with a particular focus on plastics (see Recommendation 13). Additionally the Review has provisionally recommended that combined heat and power should be pursued for as many incineration facilities as possible (see Recommendation 14).

Recommendations
The Review’s Recommendations are summarised here for ease of reference, but should be considered in the context both of the discussion around them in the Report and of the Report as a whole.

  • Recommendation 1: Scottish Government should rapidly seek further reductions in the proportion of recyclable materials in the residual waste stream. It should do this in the forthcoming Route Map.
  • Recommendation 2: The Scottish Government should develop better waste management data, especially around the composition of all types of waste and the arisings and fate of commercial and industrial waste, and improve its capacity to model future trends across the whole resource and waste management system. The forthcoming Route Map should set out how the Scottish Government will do this.
  • Recommendation 3: Industry, local authorities and the Scottish Government should do more to make data around waste in general, and around incineration in particular, more transparent and accessible for all stakeholders. This should be done alongside development and implementation of the Route Map.
  • Recommendation 4: Effective immediately, the Scottish Government should ensure that no further planning permission (i.e. beyond that already in place) is granted to incineration infrastructure within the scope of this Review unless balanced by an equal or greater closure of capacity. The only exceptions to this should be those outlined in Recommendation 10.
  • Recommendation 5: As part of an overall strategic approach to planning and deploying waste management capacity (see Recommendation 11), the Scottish Government should develop an indicative cap that declines over time for the amount of residual waste treatment needed as Scotland transitions towards a fully circular economy.
  • Recommendation 6: When negotiating contracts for residual waste management treatment, local authorities should specifically address the risks of lock-in and ensure those contracts are aligned with meeting Scotland’s current and future targets on resource and waste management.
  • Recommendation 7: The most feasible treatment options to manage Scotland’s residual waste are incineration, landfill and export of waste. Scottish Government should work with local authorities to ensure they have a solution to manage their residual waste in 2025 based on this.
  • Recommendation 8: As part of the strategic approach referred to in Recommendation 11, Scottish Government and Local Authorities should ensure that adequate time and resource is dedicated to local and community engagement.
  • Recommendation 9: Operators of all residual waste treatment facilities should work to significantly strengthen community engagement and trust before, during and after development. Clear guidelines for authentic and effective community engagement should be co-produced by Scottish Government with community groups and local authorities by the end of 2023.
  • Recommendation 10: Scottish Government should urgently work with local authorities in remote and rural areas of Scotland without a settled residual waste management solution to meet the Ban to explore options that might, if fully justified, lead to the creation of a small amount of additional capacity.
  • Recommendation 11: Scottish Government and local authorities should work with industry to develop a strategic approach to planning and deploying waste collection, reprocessing and management facilities by the end of 2023, which takes account of the key issues. The Scottish Government should consider how best to incorporate this into the proposed fourth National Planning Framework.
  • Recommendation 12: The Scottish Government should report greenhouse gas emissions from incineration separately from other energy-related emissions as soon as possible, ideally from the 2021 data onwards.
  • Recommendation 13: (Provisional) The Scottish Government should immediately strengthen existing requirements for pre-treatment and work with local authorities and industry to apply them to all existing and future incineration facilities to remove as much recyclable material as feasible, with a particular focus on plastics.
  • Recommendation 14: (Provisional) The Scottish Government and local authorities should continue to work with industry to deploy combined heat and power for as many existing incineration facilities as possible.

To read the full report click here

Source: Scottish Government