Independent review of the role of incineration in the waste hierarchy: Scottish Government response

Our initial response to Stop, Sort, Burn, Bury? - the recommendations of the independent review of the role of incineration in the waste hierarchy in Scotland.

2. Summary of main findings and recommendations

12. Dr Church sets out 14 recommendations in his report. Two of these recommendations, on decarbonising incineration infrastructure, are provisional pending completion of the further work on options to decarbonise residual waste infrastructure.

13. The Review report based these 14 recommendations on key findings around capacity and strategic planning, local authority preparations for the forthcoming ban on landfilling biodegradable municipal waste, data, community engagement, and decarbonisation.

14. In terms of managing residual waste, the Review noted that the best form of residual waste treatment is to prevent it occurring in the first place, by reducing waste and recycling. Evidence submitted to the Review noted that up to 60% of residual waste is made up of recyclable materials. The Review, therefore, recommends that the Scottish Government rapidly seek further reductions in the proportion of recyclable materials in the residual waste stream (recommendation 1).

15. Where residual waste does occur, the Review assessed the feasibility of several options to deal with this waste. The Review considered feasibility along with an appraisal of social, health, and climate considerations relating to these options. The Review found that incineration's current place within the waste hierarchy is correct, meaning that overall it is preferable to other forms of residual waste treatment, such as landfill, but less preferable than reducing the quantity of residual waste either through recycling or not producing it (reflected in Recommendation 7).

16. On capacity, the Review found that there is likely to be a gap between the amount of residual waste produced and the treatment capacity available in Scotland in 2025 when the ban on landfilling biodegradable municipal waste comes into force. While this capacity gap could be closed by Scotland achieving its waste and recycling targets, stakeholders raised concerns to the Review about the likelihood of achieving these targets, drawing on experience and comparisons with other nations as evidence of what could be possible. The Review also found that only using infrastructure with long operational lifespans to manage this capacity gap presents a risk of overcapacity in the long-term. Moreover, the Review found that there is enough capacity across facilities that are operational and currently in development (i.e. being built or with planning permission) to manage Scotland's residual waste from 2027 onwards. In light of these findings, the Review recommends that Scotland should:

  • limit the granting of further planning permissions for incineration infrastructure (Recommendation 4); and
  • develop an indicative cap for the residual waste treatment needed as Scotland transitions towards a fully circular economy (Recommendation 5).

17. While the Review found that Scotland has enough capacity to manage its residual waste in the development pipeline, stakeholders raised concerns in the Call for Evidence that decisions regarding the location of facilities and future developments were not undertaken in a strategic way. The Review, therefore, notes that, despite the recommendation to limit planning permission to incineration facilities (Recommendation 4), it may be justifiable to allow the development of some capacity in remote and rural locations. This led the Review to recommend that the Scottish Government:

  • work with local authorities in remote and rural areas to explore options that might, if fully justified, lead to the creation of a small amount of additional capacity (Recommendation 10)
  • work with industry to develop a strategic approach to planning and deploying waste collection, reprocessing and management facilities (Recommendation 11)

18. Given the findings on the potential capacity gap in 2025, balanced against the long-term risk of overcapacity, the Review found that the risk of lock-in in waste management contracts is genuine. This is particularly important for local authorities who are looking to procure contracts for their residual waste ahead of the forthcoming ban on sending biodegradable waste to landfill in 2025. In light of this finding, the Review recommends that local authorities specifically address this within their contracts (Recommendations 6).

19. During its review of available evidence, it became apparent to the Review that there were deficiencies in both data and community engagement that require attention. The Review noted that the quality, quantity and accessibility of some data around waste management in Scotland is lacking. This includes the quality of commercial and industrial waste arisings and the accessibility and transparency of carbon emissions data. To address this, the Review sets out recommendations for:

  • The Scottish Government should develop better waste management data and improve its capacity to model future trends across the whole waste management system (Recommendation 2); and
  • Industry, local authorities and the Scottish Government should do more to improve the transparency and accessibility of waste data, particularly for incineration (Recommendation 3).

20. The Review also noted stakeholders' concerns around the difficulties they had experienced when attempting to engage with planning processes, as well as ongoing difficult relationships with local facilities more generally. The Review found that communities deserve more authentic and committed engagement from local authorities and industry than is sometimes the case (reflected in Recommendations 8 and 9).

21. On improving the carbon performance of residual waste treatment, the Review found that currently, incineration is less damaging to the environment than landfill. However, changes to waste composition and wider decarbonisation of the energy system could change this.

22. The Review has commissioned separate work to inform further consideration of opportunities to decarbonise the residual waste treatment infrastructure sector in Scotland. In the meantime, the Review notes four ways to redress the balance for incineration:

  • removal of plastics from the waste before burning;
  • greater use of by-products;
  • improved efficiency through the use of the waste heat; and
  • capturing carbon emissions.

Although, the Review notes that the first, stopping plastic from being incinerated, is the quickest and most reliable route to reduce the carbon impact of incineration. Pending conclusion of the further work, the Review has provisionally recommended improving pre-treatment processes before incineration, with a particular focus on plastics (Recommendation 13) and pursuing combined heat and power for as many incineration facilities as possible (Recommendation 14).

23. To help Scotland monitor the decarbonisation of the residual waste sector, as well as improve the accessibility of carbon emissions data (Recommendation 3), the Review has also recommended that greenhouse gas emissions from incineration are reported separately from other energy-related emissions (Recommendation 12).



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