Stop, Sort, Burn, Bury - incineration in the waste hierarchy: independent review

2 General Themes From The Review

The remainder of this document considers the different questions the Review considered in seeking to provide advice to the Scottish Government. However, during its work, several cross-cutting themes emerged which apply across the topic of the role of incineration in managing residual waste in Scotland. These are set out in this section.

2.1.1 Avoid residual waste

The best form of residual waste treatment is preventing it occurring in the first place. This can be through preventing waste at all or by recycling it when it arises. For Scotland to meet its resource and waste management and climate mitigation targets, more will need to be done in this area. The Review understands that the Scottish Government is working with stakeholders to develop a route map to deliver Scotland's resource and waste management targets ('the Route Map') and it is to be hoped that this will address making further progress on this.

Recommendation 1 ScottishGovernment should rapidly seek further reductions in the proportion of recyclable materials in the residual waste stream. It should do this in the forthcoming Route Map.

• The primary focus should be on upstream measures to reduce the amount of recyclable material entering residual waste by waste prevention and source separation.
• Given the high proportion of recyclable material in residual waste, the Scottish Government should work with local authorities and the waste industry to remove recyclable material from the residual waste stream.

2.1.2 Community engagement

As set out in the draft fourth National Planning Framework (NPF4)^[9], community engagement at all stages of a major project is essential to 'respect, protect and fulfil human rights'. Experience and anecdotal evidence suggest that meaningful and ongoing community engagement is also vital to help deliver a better, more successful project, especially for waste management. However, the Review received evidence that the standard of community engagement by both public and private entities varied greatly and it is clear that the general level should be improved. (See Section 5.4 and Section 5.5 for more details and specific recommendations.)

2.1.3 Data

The Review found the relatively poor quality and scope of some data that was available to it a limiting factor in its work, a concern shared by many stakeholders. Whilst data on household (HH) waste arisings and fate is generally good, data on its composition is not. For other types of waste, most aspects are much less well understood. There were also uncertainties about the real-life capacities of existing and planned incineration facilities. Beyond data quality and availability, the Review has relied on consultant support for detailed modelling. This will bring challenges for Scottish Government if it wishes to use the same model in the future rather than expanding its in-house resource. There needs to be significant investment in both data collection and in the capacity to analyse it and draw conclusions, ideally in a manner that enjoys broad stakeholder support. (See Recommendation 2.)

2.1.4 Systems thinking

No part of the resource and waste management system can be considered in isolation. Changes to one part of it have impacts on others, which can be hard to predict. In turn, improvements in one area are often dependent on changes happening in others. It is therefore essential for decision makers to consider the whole system wherever possible when making changes. For example, both stakeholders and the Review found it hard to assess the likely or expected impacts of upstream measures on future residual waste quantities and composition, which has hindered the ability to make firm predictions.

Recommendation 2 The Scottish Government should develop better waste management data, especially around the composition of all types of waste and the arisings and fate of commercial and industrial waste, and improve its capacity to model future trends across the whole resource and waste management system. The forthcoming Route Map should set out how the Scottish Government will do this.

2.1.5 Transition

Incineration should be thought of as a transitional technology that helps Scotland bridge the gap from mass landfill to a low waste, low carbon, more circular economy. We are currently in the growth phase, but as set out by several stakeholders, if Scotland is to meet its resource and waste management and climate change mitigation targets, there will be a corresponding future phase down. Planning by central and local government for how to manage this is essential to avoid unnecessary expense or environmental damage. (See also: Section 3.6, Recommendation 4 and Recommendation 5.)

2.1.6 Transparency

Greater transparency around the data that does exist would help build greater trust in the incineration industry and support more robust decision making. Some data may legitimately need to be kept confidential for commercial reasons but given the environmental and social considerations the test for this should be reasonably stringent. Transparency also means presenting the data in an accessible and coherent manner with appropriate explanations.

Recommendation 3 Industry,local authorities and the Scottish Government should do more to make data around waste in general, and around incineration in particular, more transparent and accessible for all stakeholders. This should be done alongside development and implementation of the Route Map.