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

Report and supporting documents relating to the Independent Review of the Role of Incineration in the Waste Hierarchy in Scotland.

5 Trade-Offs

What are the environmental and social trade-offs of those residual waste management options?

5.1 Climate Change Impacts

Many stakeholders were concerned about the climate change impacts of residual waste management and options for managing them. This topic is discussed in Section 7 – Improving Carbon Performance along with the Review's initial thoughts on addressing decarbonisation of incineration.

5.2 Health Impacts

5.2.1 Incineration

A number of stakeholders raised concerns about the potential health impacts of incineration in all forms. Historically, the main issue has been air quality. The developments in regulation of incineration plants through European and Scottish law have continued to reduce emissions of most pollutants. However, increasingly, stakeholders are raising questions around ultrafine airborne particles (smaller than 2.5nm) as these are known to have negative health impacts and there is concern that modern air pollution control processes do not stop these from being emitted. Some stakeholders have also raised the wider mental health and wellbeing impacts of living near an incinerator.

The Review commissioned Public Health Scotland (PHS) to consider whether the conclusion from a previous Health Protection Scotland review on the health impacts of incineration[44] should be amended in light of more recent evidence. PHS undertook a Rapid Evidence Review ('the 2022 PHS Review'), which reaffirmed the original conclusions of the 2009 work:

"the body of evidence for an association with (non-occupational) adverse health effects is both inconsistent and inconclusive. However, more recent work suggests, more strongly, that there may have been an association between emissions (particularly dioxins) in the past from industrial, clinical and municipal waste incinerators, and some forms of cancer, before more stringent regulatory requirements were implemented.

For individual incineration waste streams (clinical, hazardous, industrial and municipal), the evidence for an association with (non-occupational) adverse health effects is inconclusive.

The magnitude of any past health effects on residential populations living near incinerators that did occur is likely to have been small.

The majority of research work in this field is of historical relevance but tells us little about the current risk of (non-occupational) adverse effects potentially associated with incineration plants in operation now.

Levels of airborne emissions from individual incinerators should be lower now than in the past, due to stricter legislative controls and improved technology. Hence, any risk to the health of a local population living near an incinerator, associated with its emissions, should also now be lower."

The 2022 PHS Review also stated that any risks to human health related to newer incinerators were very likely to be lower than they were previously. However it also confirmed that evidence continued to be absent, inadequate or limited. Additionally the 2022 PHS Review stated that:

"Commitment to limiting the total amount of waste destined for energy recovery via thermal treatment, as well as the use of existing planning controls, should also continue to minimise public exposure to potential adverse health impacts of incineration."

The Review has addressed the need to limit residual waste in Recommendation 1.

While the 2022 PHS Review did not consider the issue in detail, stakeholders raised concerns around the potential psychological or mental health impacts of living close to an incinerator. The Review did not find any specific studies considering this. One study looked at the impact of industrial activity on individual well-being, including mental health, and found that industrial activity is associated with "perceptions of individual powerlessness and neighbourhood disorder, leading to higher levels of psychological distress".[45] There is scope for further research into this area.

5.2.2 Landfill

The health impacts of landfill can be difficult to quantify as they vary based on location, design and waste composition for each location. A study considered the cancer risks of populations living close to landfills in Great Britain, finding that there were no excess risks of cancer for those living within 2km of landfill sites compared to those living more than 2km from a landfill[46]. An initial study of landfills in Great Britain in 2001 found a small excess of congenital anomalies and low and very low birth weight in populations living near landfill sites but noted that there was no apparent causal mechanism and that this result may be due to issues with the data or analytical technique[47]. A follow-up study of the risk of adverse birth outcomes in populations living within 2 km of special (hazardous) waste landfill sites found that there were no statistically significant excess risks of congenital anomalies or low birth weight in populations living near special waste landfill sites.[48]

A more recent study by Eunomia[49] on behalf of ClientEarth investigated the air quality impacts of landfill in comparison to incineration through a literature review and modelling and showed that, of the health impacts considered from landfill, ammonia has the greatest impact on human health. Biostabilisation reduced this impact slightly but also increased particulate emissions modelled as PM2.5. Overall, the report concluded that landfill had a smaller impact on local air quality than incineration.

5.2.3 Mechanical Biological Treatment and bio-stabilisation

Defra explains that no studies had specifically looked at the health effects of MBT facilities at the time of its guidance document being produced[50]. Within its document, Defra states that the health effects are expected to be comparable to those from in-vessel composting (IVC) facilities, primarily related to bio-aerosol emissions. Although studies on composting facilities have found no increase in cancer or asthma in populations nearby, there has been public concerns that open composting operations could in theory affect the health of those living in close proximity. Research undertaken by Defra suggests that communities located more than 250m away from composting facilities are unlikely to be exposed to harmful levels of bio-aerosols[51]. However, they may experience odours associated with the process as these can travel much further.

The possible health impacts from biostabilisation will be similar to those for MBT as MBT includes biological treatment processes. Therefore, the information above is relevant to biostabilisation as well.

5.2.4 Conclusion on the health impacts

The evidence suggests that all feasible options for managing residual waste in Scotland have some risks to public health that must be managed appropriately through robustly-enforced regulation. The evidence does not suggest that these impacts are more severe from incineration than from landfill, export or MBT. However, these conclusions need to be kept under constant review as the evidence on health impacts evolves.

5.3 Community And Social Impacts

This section focuses on considerations specific to populations in the areas local to waste treatment facilities.

Community groups and members of the public concerned about incinerators in their local areas have engaged with all elements of the Call[52]. While responses were focused on incineration, new waste facilities of whatever type are rarely welcomed by residents close to where the facility is to be located[53]. With the awareness that many may become engaged in the debate around waste management in their local community but not in the conversation at a national level, the Review has sought out additional information regarding the number of objections posed to SEPA and local authorities around specific plants, in order to better understand this level of engagement which may not have reached the Review directly. This showed a large range in the number of objections received depending on the site, with some receiving very low numbers and other receiving well over a thousand.

5.3.1 Local amenity

Impacts on local amenity are often cited as concerns relating to waste management facilities. These include light pollution, noise, odours, vibration, chimney plume and increases in local traffic.

In its response to the Call, SEPA noted it was more likely to receive complaints regarding dust, odour and vermin relating to landfills and more about noise for incineration facilities. The planning and permitting application processes consider the potential impacts on local amenity in the context of the specific location, type and size of the facility. However, a number of stakeholders raised concerns around the process of community engagement undertaken as part of planning. This is discussed further in Section 5.4.

5.3.2 Social deprivation

A frequently stated concern is that low income areas are more acutely exposed to the impacts of residual waste management as these facilities are more likely to be located in areas where these populations live. There is good evidence that socially deprived areas are disproportionally exposed to municipal landfill sites. This suggests that area deprivation may have preceded disproportionate siting to some extent, but landfill siting also preceded a relative increase in deprivation[54]. There is a similar distribution of incineration facilities in England[55], however, it is difficult to assess this in Scotland due to the small sample size of operational facilities. The location of operational and pipeline facilities in relation to the Scottish Index of Multiple Deprivation (SIMD) is in Table 3.

Table 3. Scottish Index of Multiple Deprivation ( SIMD) [56] deciles for areas and proposed areas of operational and pipeline facilities, respectively.
Facility Name Status SIMD Decile
GRREC Operational 1
Earls Gate In Construction 3
Lerwick Operational 3
South Clyde (Fortum) Fully Consented 3
Aberdeen Recycling & Energy Recovery (NESS) In Construction 4
Oldhall (Doveryard) Fully Consented* 4
Westfield In Construction 4
Drumgray (FCC) Fully Consented 5
DERL (MVV Baldovie) Operational 6
Dundee ERF* Operational 6
Glenfarg (Binn Group) Planning Granted 6
Inverurie (Agile Energy) Planning Granted 6
Millerhill Operational 6
Avondale EfW Planning Granted 7
Dunbar ERF Operational 7
Killoch EfW Planning Granted 7
Levenseat Operational 7
Levenseat 2** Planning Granted 7

*Same location as existing facility (DERL (MVV Baldovie)) assumed

** Same location as existing facility (Levenseat) assumed

This table shows that there is not a strong relationship between a location's decile on the SIMD and the likelihood that an incinerator will be located or planned in that area. Indeed, ten (56%) are in the less deprived half of the distribution.

5.3.3 Perception

Another element for consideration in terms of community and local impacts of waste treatment facilities is the perception of such facilities. The Review received evidence of lived experience, and contributions of community groups, regarding concerns relating to incineration in particular.[57] Examples given included concerns around a decrease in house prices local to incineration facilities, impacts on the ability of local businesses to sell products, and the potential psychological impacts of worry and anxiety about a local incineration facility. While some perceived harms may be difficult to verify with external evidence, the Review regards the perceptions themselves as essential to understanding the community and social impacts of waste treatment methods.

5.3.4 Employment

There could also be some positive impacts of residual waste treatment facilities on local areas. Employment opportunities in operating and constructing incineration facilities was raised by multiple stakeholders as an example of a positive impact[58], with some stakeholders highlighting that there are likely to be more employment opportunities generated from an incineration facility compared to landfill. However, one piece of evidence suggested that there were six jobs available in landfill for every one in incineration, while also indicating the opportunity for further employment within the circular economy[59]. In terms of MBT, a guidance document from Defra provides an employment guide based on current and proposed facilities (at the time of the report) of about one employee per 6-7000tpa processed[60].

5.3.5 Scottish Landfill Communities Fund

One vector for positive or mitigating impacts for communities local to landfill sites is the Scottish Landfill Communities Fund (SLCF). Established in 2015, it is funded by operators giving a percentage of their landfill tax liability to an 'approved body', which then distributes funding to community and environmental projects. A review of the performance of the fund was undertaken in 2020 by SEPA and found that 55% of landfill operators have contributed to the SLCF and it had funded over 1,400 projects with £32.7m of funding[61]. The SLCF is expected to receive declining contributions in future years due to a reduction in reliance on landfills and because of the Ban in 2025.

5.3.6 Heat and energy offtake

Heat and energy offtake are often cited as positive examples of the impact of incineration facilities on their local communities. In Lerwick, Shetland, heat from the energy recovery plant supplies approximately 1200 customers and, according to Shetland Heat Energy & Power, around £1,000,000 per annum of the income from these sales remains in Shetland[62]. However, stakeholders have expressed concern about the implementation of heat and energy from other waste incineration facilities and the likelihood of these benefits materialising in other areas (see Section 7)

5.3.7 Conclusion on community and social impacts

The planning and permitting processes for residual waste treatment facilities consider and seek to address a range of community and social impacts (but see also Section 5.4 – Planning Considerations for some issues with the former). Landfill facilities are more likely to receive complaints than incineration facilities, with the exception of noise. There is not a strong link in Scotland between the location of incineration facilities and deprivation. Perceptions of incineration facilities can though be quite negative. Residual waste management facilities can provide employment opportunities to local communities and some funding for community activities.

5.4 Planning Considerations

It has become clear from the Review's engagement with stakeholders that planning processes and poor engagement between operators and local communities present their own concerns.

Community stakeholders raised the fact that they had difficulty having their voices heard. Within the stakeholder events, roundtable meetings and subsequent meetings, stakeholders raised issues they had faced engaging with the planning processes. This included struggling to find information on how to engage effectively, feeling that their engagement was not regarded widely and frustration with the lack of a right to third party appeal.

Recommendation 8 As part of the strategic approach referred to in Recommendation 11, Scottish Government and Local Authorities should ensure that adequate time and resource is dedicated to local and community engagement.

This should include:

  • Providing greater clarity on how community and local groups can engage with waste planning processes effectively.
  • Ensuring opportunities for local and community groups to be heard within meetings where waste management is discussed and that they are given appropriate time and genuine consideration
  • Planning authorities reviewing commitments made in the planning process on a regular basis to ensure they are always upheld, especially in terms of community benefits

These proposals could be integrated into the final version of NPF4.

5.5 Effective Engagement With Local Communities

In addition to difficulties local communities may face engaging with planning processes, relations between operators themselves and the local communities, particularly around planned sites, can be poor.

It is clear from the response to the Call that among certain groups there is mistrust and concern around the operators of residual waste treatment facilities. Concerns were raised about gaps in data as well as the accessibility and clarity of information relating to emissions. There was also some concern that operators have failed or will fail to follow through on benefits promised at planning stages. Additionally, there was some frustration expressed at the use of language and branding by individual operators, with claims that it was misleading.

There are, however, positive examples available of community engagement from waste treatment operators. An example was provided verbally to the Review, in which an operator took a local community council to visit a site to explain its workings, which then provided reassurance to members of that council who could see the site from their homes.

Recommendation 9 Operatorsof all residual waste treatment facilities should work to significantly strengthen community engagement and trust before, during and after development. Clear guidelines for authentic and effective community engagement should be co-produced by Scottish Government with community groups and local authorities by the end of 2023.

This engagement needs to be genuine and it will not be viewed as such if promises are made which are then not kept. The guidelines should be determined within the co-production process, however the Review would recommend that the following elements are considered:

  • Transparency in construction processes and operations.
  • Follow-through on community benefits referred to in planning stages.
  • The accessibility of data around a plant's operations, including emissions data.
  • Ensuring local voices are heard at every stage of the process.
  • Engaging with local concerns, providing evidence and reassurance relating to impacts of waste management without being misleading or engaging in 'greenwashing'.



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