Incineration policy must reflect wider waste management issues

An independent review of the role of incineration in Scotland, authored by waste sector expert Dr Colin Church, was published last month. This looked at the role of incineration in the waste hierarchy and how national capacity could be aligned with Scotland’s waste reduction targets, with a number of core recommendations for the Scottish Government, local authorities and the wider waste industry.

John Ferguson, Head of Strategy at Binn Eco ParkThese included that no further planning permission should be granted to incineration infrastructure unless this was balanced by an equal or greater closure of capacity. Dr Church also called for a declining indicative cap on the amount of residual waste treatment needed as Scotland transitions towards a fully circular economy, stressing the need for greater community engagement during and after this process.

As operators that make up Scotland’s waste management sector, we welcome many of the recommendations put forward by Dr Church, a well-respected figure within our industry. I do however believe the proposal to significantly curtail new incineration will make it near impossible to manage the nation’s residual waste stream and could also result in missed opportunities to deliver better outcomes for local communities unless this ban is flexibly managed. This is particularly the case given the uncertainty in the delivery of some of the current facilities which do have planning permission but face other issues in terms of commercial development. Further discussion between Scottish Government and the sector to ensure we have correct capacity to meet the forthcoming landfill ban is absolutely crucial.

The Scottish resource management sector strongly supports the aim to reduce carbon emission from incineration facilities. We also welcome the recognition of the wider functions the sector provides in dealing with societies residual waste which is, sadly, a daily reality needing robust management systems.

However, we must not address incineration policy in isolation. We need to focus on consumer responsibility to reduce residual waste and also ensure we have an environmentally sound end-of-life solution for all items disposed of by households, which will ultimately reduce the required volumes of incineration. The sector is ready to support this work through a range of measures including increased consumer participation in recycling, better material choices in manufacturing, improved product design, and incentives for recycling problematic wastes.

Policy will also need to be adapted to develop improved public procurement purchasing policies to stimulate demand for recycled materials, including more extensive use of mandatory recycled content instruments.

With the responsibility for waste sitting with each and every individual, the Scottish Government must further invest to change behaviour to address the impact of consumer consumption. The Deposit Return Scheme for empty drink bottles and cans, which comes into effect in August 2023, is a great example of how public policy can incentivise positive consumer behaviour.

In terms of reducing the carbon impacts of incineration, we must firstly start to capture all plastic waste separately from residual waste and process this complex group of materials in facilities designed to maximise recovery value. This not only reduces the non-biogenic carbon impacts of incineration; it also supports the regionalisation of plastics management creating new circular economy opportunities for plastics. This whole system approach could operate at a global level significantly stemming the catastrophic leakage of plastic waste into the environment.

Project Beacon, the proposed advanced plastics sorting and upcycling demonstration facility included in the £300m Tay Cities Deal, is a great example of how the industry and government can work hand in hand to achieve a successful outcome.

We can also enhance carbon performance of incineration by using it more effectively for district heating and industrial processes, including food production. Improved self-sufficiency in food production, including reducing food miles, is of growing environmental importance, and it delivers wider benefits for society as we face mounting concerns about the cost of living and food security. This form of incineration-driven energy use does however require greater flexibility within our planning system so we are able to fill any capacity gaps to deliver maximum benefit to communities.

It's also important to recognise that while incineration is a stepping-stone technology that will likely be a prominent residual waste management solution for a number of years, there are new emerging technologies which can deliver better outcomes in the long term once proven at a commercial scale. The waste management industry needs support to develop these new forms of technology which will ultimately help deliver on government net-zero commitments.

We await the Scottish Government’s response to Dr Church’s review, expected later this month, and hope that it will recognise the on-going importance of incineration, not only in managing waste streams but also its potential role in creating new low carbon economic opportunities and providing community benefit. In the interim period, our industry will continue to manage waste in the least impactful manner, whilst protecting public health and the environment and preserving resources. That is why we are here.