Environmental groups call for investigation into Scottish Government's incineration policy

Environmental groups in Scotland have today (19 June) formally requested the country's environmental watchdog, Environmental Standards Scotland, to investigate the grounds for why the Scottish Government has not used its powers to halt expansion of incineration capacity.

The Scottish Government introduced a moratorium on new waste incinerators in 2022 in response to the findings of an independent review, which warned of a risk of long-term overcapacity by 2026 or 2027 if all planned incineration capacity was built.

However, loopholes in the moratorium have allowed developers to continue pursuing plans for new incinerators, and Scotland's largest existing incinerator, operated by Viridor in Dunbar, was permitted by the Scottish Environment Protection Agency (SEPA) to increase its input capacity by 20 per cent in July 2023. As a result, Scotland's incineration capacity has increased by 215,000 tonnes, or 17 per cent, since the moratorium was introduced.

Environmental organisations argue that incineration is expensive, emits harmful pollution, contributes to climate change, and hinders effective reuse and recycling efforts.

Ministers have the power to direct SEPA to refuse incineration permits under Regulation 60 of the Pollution Prevention and Control (PPC) regulations 2012. However, they have not used these powers to pause the issuing of permits while measures to close loopholes in the moratorium are implemented.

Environmental groups have submitted a joint request for Environmental Standards Scotland to urgently investigate the Scottish Government's lack of action before it is too late.

Kim Pratt, Circular Economy Campaigner from Friends of the Earth Scotland, said: "The Scottish Government is turning a blind eye whilst Scotland's waste burns, causing harmful pollution and blocking effective management of our resources. It has the power to halt the increase in incineration today but it has repeatedly refused to act, despite the clear evidence of loopholes in its incinerator ban."

Ben Christman, In-house solicitor at the Environmental Rights Centre for Scotland, compared the Scottish Government's "incineration moratorium" to Swiss cheese, stating that despite telling the public they wanted to reduce Scotland's incineration capacity, ministers' refusal to use their powers over the past two years has led to an increase in capacity.

Shlomo Dowen, National Coordinator, the UK Without Incineration Network said: "Scotland is continuing to drift in the wrong direction. For the sake of the climate, air quality, and the circular economy, the Scottish Government should be publishing an incineration exit strategy, not allowing yet more damaging incineration capacity to go ahead."

Rebecca Glen from Irvine Without Incinerators said: "We know that if every incinerator that is currently in development goes ahead, Scotland will be overcapacity by 2027. We believe that Irvine is the wrong place for such a project, due to the excessively high rates of deaths and hospitalisations due to respiratory disease in North Ayrshire.

"It shouldn't be left to local activists to challenge the construction and operation of these incinerators without any support – the Scottish Government should respect not only the letter, but the spirit of their moratorium on incineration and intervene before they completely lose the trust of people who recognise the need to move away from incineration and towards a circular economy model. Studies show a direct correlation between rates of incineration rising and rates of recycling declining and this is the opposite direction of where we should be headed."

The environmental groups argue that urgent action must be taken to prevent the predictions of overcapacity outlined in the independent review from becoming a reality, and they consider the current situation to be exceptional, warranting the use of the Scottish Government's powers under the PPC regulations.