Earlier this year, the government announced its commitment to include all waste incineration and energy-from-waste (EfW) facilities in the ETS by 2028.
In response to this news, and ahead of a consultation which is due to be published by the end of the year, the Environmental Services Association (ESA), the trade association representing the waste industry, has published a report outlining its key requirements.
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Its first requirement is that there must be a “deliverable timeline” that aligns with other waste-related policies. The government has received continued criticism for delaying the roll out of key waste reforms, with three of the key planks of the 2018 Resources and Waste Strategy - extended producer responsibility (EPR), the deposit return scheme (DRS) and consistent collections - all delayed.
The report states that by implementing these reforms it will ensure that there are “robust policies” in place to reduce the amount of non-recyclable plastic generated in the first place, which in turn will reduce the amount of CO2 generated by incineration, “thereby reducing the financial burden on waste producers”.
Specifically, the report also states that the government must implement policies to avoid “landfill leakage” - this is a situation where waste is sent to landfill rather than EfW or incineration facilities because this is the cheaper option.
“It is essential that any new policy intervention does not undermine the waste hierarchy and continues to support the sector’s transition away from landfill”, the report states.
To achieve this, the ESA has called for a “comprehensive municipal waste to landfill ban”.
Similarly, to avoid an increase in waste exports, the report also calls for a prevention in refuse derived fuel (RDF) export when sufficient UK capacity becomes operational. RDF is a term used to describe residual waste that has undergone some processing that allows it to be used as a fuel in an energy-from-waste facility.
“As the UK builds out the planned 4-6 Mt of EfW capacity in the next five years, there will be adequate capacity to manage the 1.6 Mt of RDF that is currently exported to the EU in our own borders. Suitable fiscal measures on RDF exports are required to ensure equivalent carbon costs are paid by exporters”, the report states.
Speaking at the Resource and Waste Management conference in Birmingham last week, Chris Jonas, director of Tolvik consultancy, warned that the worst outcome of including EfW in the ETS would be that the cost of EfW becomes so expensive that it leads to more waste going to landfill.
“It is essential that we avoid unintended consequences. It will be a poor show for the government if increased costs see waste drift away to worse environmental outcomes, like waste emitting methane in landfill or being exported and travelling further distances.
“If that happens we will have failed”, he said.
Commenting on the report, ESA energy and climate change policy advisor, Charlotte Rule, said: “Carbon pricing can provide a powerful incentive for net zero investment and support delivery against ambitious recycling targets but it is essential this intervention is applied with the utmost care to avoid any perverse outcomes - most importantly to prevent waste moving down the waste hierarchy to landfill. The reforms also need to complement the implementation of key packaging and recycling policies to drive up recycling rates”.
The full ESA report is available to view here.