Role of incineration in the waste hierarchy - review: call for evidence

The call for evidence seeks your views and evidence relating to the review of the role of incineration in the waste hierarchy.

1. Introduction

1.1 Overview

The Scottish Government has committed to reviewing the role of incineration in the waste hierarchy in Scotland, to ensure that how residual waste is managed in Scotland aligns with Scotland's carbon reduction ambitions.

On 30 September, the Minister for Green Skills, Circular Economy and Biodiversity set out Scottish Government's intention to appoint an independent chair to undertake the work, and for it to prioritise consideration of national capacity requirements for incineration[1]. Dr Colin Church subsequently agreed to take on this task and the review team has started its work under his leadership.

The Review is in the context of Scotland's waste management ambitions and its progress towards meeting them. This Call is therefore seeking evidence on five broad topics:

  • 1. Given Scotland's 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 impact?

The Review will consider these topics in the context of the treatment of household (HH) and commercial and industrial (C&I) waste streams.

The Review will consider options for residual waste treatment beyond incineration, including, but not limited to, landfill, mechanical biological treatment (MBT), and biostabilisation. In this Call for Evidence, the following definitions apply:

  • Incineration – the thermal treatment of waste with or without the recovery of energy, including advanced thermal treatment processes such as pyrolysis, gasification or plasma methods.
  • Mechanical biological treatment (MBT) – a group of solid waste management systems, typically used for the pre-treatment of waste, that combines a sorting facility with a form of biological treatment such as composting or anaerobic digestion. Unless specified, MBT is used in this Call to specifically mean processes that produce a high calorific fuel called Refuse Derived Fuel (RDF), which can be used in cement kilns or power plants.
  • Biostabilisation – A specific form of MBT which seeks to reduce the biodegradability of mixed wastes for the purpose of landfilling the stabilised waste.
  • Landfilling - the deposition of the waste onto or into land.
  • Residual waste – the material left that cannot be reused or recycled and thus must be disposed of safely.
  • Household (HH) waste – waste generated by households. This includes waste collected through kerbside collections, household collections such as bulky waste collections, waste deposited by householders at household waste recycling centres and recycling points/ bring banks.
  • Municipal waste - waste from households as well as other waste which because of its nature or composition is similar to waste from households.
  • Biodegradable waste - any waste capable of undergoing anaerobic or aerobic decomposition such as food, garden waste, paper and cardboard
  • Biodegradable Municipal Waste - municipal waste that is also biodegradable.
  • Commercial & Industrial (C&I) waste – waste from commercial and industrial sources. Includes waste from business and industrial premises in Scotland, but excludes waste from the construction and demolition industry.
  • Construction & Demolition (C&D) waste - waste from the construction and demolition industry.

The Review will not include:

  • the incineration of biomass for energy.
  • consideration of high-temperature incineration for the treatment of some. healthcare and hazardous wastes.
  • construction and demolition (C&D) waste streams.
  • an in-depth review of health impacts of residual waste treatment.

The Review is seeking to give stakeholders the opportunity to contribute their evidence and views, both through this Call for Evidence and during stakeholder events taking place on 18, 26, and 27 January 2022. Please contact for more information on attending these events.

1.2 What does the Call for Evidence cover?

The priority for the Review is an assessment of national capacity requirements (Topic 1) as Scotland moves towards its waste reduction, recycling and circular economy ambitions.

This Call for Evidence seeks your views and evidence on Topics 1-5 and prioritises Topics 1-4 in line with the task we have been set. We intend to also commission separate work to review the options to improve the performance of the existing incineration infrastructure in Scotland (Topic 5). This may take longer than the current Review deadline, in which case we will be limited in what we can say on Topic 5 in our report. However, the Review team will consider all evidence received on this and ensure the evidence is shared with the Scottish Government to inform the separate piece of work.

1.3 How is the Call for Evidence structured?

Section 3 presents a series of questions about you, which will help to contextualise your response to the Call for Evidence.

Section 4 Sets out the policy landscape, including the Scottish Government's targets and ambitions, and provides an overview of waste management in Scotland.

Section 5 Considers the question of what capacity is required to manage residual waste in Scotland, given Scotland's ambitions and current progress towards these (Topic 1).

Section 6 Considers the possible options for managing residual waste in Scotland (Topic 2).

Section 7 Considers the potential economic, environmental and social tradeoffs of the potential residual waste management options in Scotland (Topic 3).

Section 8 Looks at what considerations should be examined in determining where residual waste management capacity should be located (Topic 4).

Section 9 invites any comments on what can be done to improve existing residual waste treatment facilities in terms of carbon performance and societal impact residual waste management in Scotland (Topic 5).

1.4 How to respond to the Call for Evidence

The deadline for responses to this Call for Evidence is 21 February 2022. If you would like to respond but will not be able to do so in the timeframe, please contact to discuss.

The best way to respond to this Call for Evidence is through CitizenSpace, which can be accessed at the following link from Monday 20 December:

Alternatively, you can also to send your response by email to:

Representation by mail and requests for free of charge paper copies and alternative formats of this document can be sent to:

Incineration Review

C/O Zero Waste Team,

Scottish Government,

3H South, Victoria Quay,

Edinburgh, EH6 6QQ

Any questions about the Call for Evidence can also be sent to

This document can also be accessed from the website.

All responses will be acknowledged, but it will not be possible to give substantive replies to individual representations. We intend to publish a summary of evidence alongside the final report. This may involve publishing your response in full, or as part of a summary of responses.

The most useful contributions to the Review will be evidence that addresses the questions posed, so please do try to focus your contributions on that. This Call for Evidence will inform the Review's report to Scottish Ministers in 2022.



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