‘Incinerator rules alone will not increase recycling’: NAWDO’s important response to DEFRA’s latest proposals                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        

In recent months, the Energy from Waste sector has been largely demonised by the UK government and mainstream media; waste incinerators added to the Emissions Trading Scheme as of 2028, for example, alongside the Conservative promise to ban EfW plants as part of their July 2024 manifesto ahead of the most recent general election.

And, following a tough few months for EfWs, on 30th December DEFRA announced that waste incinerators will only receive planning approval if they ‘meet strict new local and environmental conditions’.

Admittedly, this sounds bleak for the sector and, in the New Year, the National Association of Waste Disposal Officers (NAWDO) responded by warning that restricting EfW capacity will not in itself drive reductions in material use, nor increases in reuse and recycling.

NAWDO stated that:

“Local authorities already have a statutory duty to dispose of municipally collected waste and bear the cost and delivery risk if there is not enough EfW capacity, and it’s therefore essential for government to have in place regulations that require producers and retailers to drive the delivery of low waste outcomes without leaving the problem to hard pressed councils alone.”

Sensible comments from NAWDO, they serve to highlight that EfW in isolation is not the issue.

But what exactly are the ‘strict new local and environmental conditions’?

• Projects to maximise efficiency and support the delivery of economic growth, Net Zero and the move to a circular economy

• Developers to demonstrate that their projects will help lower the amount of non-recyclable waste sent to landfill or enable the replacement of older, less efficient plants

• New projects to be built Carbon Capture ready and make use of the heat they produce. This will include plants that produce fuels that can be used to decarbonise other sectors, such as aviation

• New waste incinerators will need to meet existing high standards on air pollution and other environmental impacts to receive an environmental permit

And, whilst some of these conditions seem reasonable and encouraging, others certainly don’t.

Firstly, Carbon Capture, Usage and Storage (CCUS) is currently a complex undertaking without much of a market here in the UK. For CCUS to be both achievable and financially viable for the majority of EfW projects, there are policies, regulations and initiatives that need to change.

Secondly, and in conjunction, EfWs and air pollution is a controversial topic as the discourse surrounding waste incinerators focuses heavily on how polluting these facilities are.

Although this isn’t without some truth as incinerators especially release a number of pollutants into the air, including greenhouse gases and heavy metals which, depending on how strict the ‘high standards’ expected are, could actually rule out incineration entirely, without consideration of the fact that waste incinerators are valuable waste treatment facilities that play a vital role in waste recycling and the reduction of waste taken to landfill.  

Indeed, if we didn't have incinerators we would need to landfill that waste and this could have much more harmful impacts both on the climate and our health. Landfill direct emissions consist of methane (CH₄), carbon dioxide (CO₂), volatile organic compounds (VOCs), and hydrogen sulfide (H₂S), where methane is a potent greenhouse gas with a global warming potential significantly higher than CO₂.  

Alongside this, landfills continue to emit methane for decades even after closure and pose risks of leachate contamination, fugitive emissions, and structural issues requiring long-term monitoring, as well as being inherently more prone to odour problems due to the anaerobic decomposition of waste, and in particular sulphur bearing wastes which generate hydrogen sulphide (H2S). H2S is extremely odorous, very toxic and significantly more flammable than methane. Odour from landfills alone can blight communities for years.

EfW facilities are more controlled and emit fewer pollutants than landfills. EfW facilities release primarily CO₂ (mostly biogenic), small amounts of NOₓ, sulphur compounds, particulate matter, and minimal dioxins and furans.

What’s more, advanced emissions control technologies ensure compliance with stringent BAT standards, and EfWs avoid methane emissions entirely whilst producing significantly less odour.

In conclusion, whilst this is all part of the long and exciting journey to Net Zero and the inevitable increase in renewable energy generation & use, it does seemingly fail to appreciate the important role incinerators play in waste treatment and recycling, and taking waste away from harmful landfill sites, as part of the road to a cleaner, more sustainable future.