Scotland's Circular Economy and Waste Route Map to 2030 : Analysis of consultation responses

4. Decarbonise disposal

This chapter provides analysis of responses to Question 5 and 6, which explored views on the priority and further actions identified under the Decarbonise disposal strategic aim.

4.1 Decarbonise disposal: priority actions

Q5: To what extent do you agree with the priority actions proposed within the Decarbonise disposal strategic aim? Please provide evidence to support your answer if possible.

Among those who answered Q5, 78% agreed to some extent with the priority actions proposed in the Decarbonise disposal strategic aim; 32% strongly agreed and 46% agreed. A further 6% were neutral and 15% disagreed.

Two thirds (66%) of individuals who answered expressed support for the priority actions, with half (49%) strongly agreeing. Although strong agreement was lower among organisations (23%), a clear majority (85%) agreed to some extent. All public bodies, retail and packaging and construction and development organisations who answered supported the proposals, as did most local authorities and other organisations (93% and 92% respectively). However, just over half of third sector organisations agreed to some extent, with 20% neutral and 27% strongly disagreeing. This was the highest level of strong disagreement across the closed questions. Only two of these third sector organisations left comments elaborating on their disagreement; both are noted below.

Question 5 received 83 open text comments. Some respondents provided overall feedback on the Decarbonise disposal strategic aim. For example, some expressed broad support, with RMAS describing this section of the Route Map as an “essential component of the strategic framework necessary to transition to a circular economy.”

However, a few individuals disagreed with the inclusion of this strategic aim altogether, arguing that the actions in the Route Map should focus on cutting consumption and avoiding waste at source. Conversely, others recognised that there are currently residual waste materials that cannot be avoided, reused or recycled, and felt it is therefore important to ensure that these are disposed of in a way that minimises environmental and climate impacts.

As with other questions, some expressed the view that the proposals lack urgency and ambition, and a few respondents discussed the importance of ensuring that the actions contained within this strategic aim work cohesively alongside upcoming Deposit Return Scheme and Extended Producer Responsibility initiatives.

Develop and deliver a Residual Waste Plan to 2045.

There was broad support for this priority action, with several respondents from different sectors welcoming plans to develop and deliver a long-term Residual Waste Plan. A few described the potential benefits of the plan, suggesting that it will provide strategic direction, allow better understanding of waste volumes and compositions and lead to more informed decision-making on how best to allocate resources. A few respondents were particularly supportive of plans to explore new technologies and innovation aimed at reducing the environmental impact of waste disposal, and others welcomed the proposal to convene a diverse Residual Waste Panel to provide expert development, coordination and delivery of the plan.

“Fife Council support measures for a long-term strategy on residual waste. The Council want as little as possible going to landfill or Energy from Waste (EfW) so reporting on investigation of new technologies that could deal with hard to recycle materials or how to manage unavoidable wastes would help local authorities in their long-term disposal aims.” – Fife Council

CIWM Scotland expressed approval for this priority action but emphasised the importance of establishing clear and tangible carbon measurements to establish baseline costs which will assist understanding the benefits and challenges of decarbonising waste streams.

Keep Scotland Beautiful advised that the Residual Waste Plan should identify a clear pathway for the appropriate composting of single-use packaging that is promoted as being compostable but often ends up in landfill due to a lack of appropriate composting facilities.

A few respondents called for a more ambitious timeframe to be implemented for this action, and a small number requested the inclusion of detailed action plans, costs and visible timelines within the Residual Waste Plan.

Facilitate the development of a Sector-Led Plan to minimise the carbon impacts of the Energy from Waste Sector.

Several respondents expressed support for this priority action, with a few commenting that industry bodies will have valuable and necessary insight into the development of a plan to minimise the carbon impacts of the Energy from Waste^[6] sector.

“HIE supports the facilitation of the development of a Sector-Led Plan as a specific strand of the residual waste plan to minimise the carbon impacts of the Energy from Waste Sector. We acknowledge that Waste industry ownership of this sector-led plan is important to ensure the economic and environmental viability of the plan and that a significant impact can be achieved on a voluntary basis.” – Highland and Islands Enterprise

However, some respondents, including a few individuals and third sector organisations such as United Kingdom Without Incineration Network (UKWIN), raised concerns about the ‘sector-led’ aspect of this proposal, advising that the vested interests of the incineration/waste disposal sector, such as desire to protect commercial profits, may lead to insufficient action being taken.

“We feel there is a terrible risk in allowing the waste disposal sector to determine the policies that will affect it, as for-profit corporations will prioritise their profits and market share, and the direction of policy overall, for their own, rather than societal and global benefit as a whole.” – Parents for Future Scotland

Some discussed the need for a collaborative approach, advising that different bodies including operators within the resource/waste management sector, environmental non-governmental organisations (eNGOs) and community groups should be involved in the process. For example, RMAS proposed an approach which involves a group with network-wide representation from incineration service providers, an independent Chair and an independent carbon analyst.

Some strongly endorsed the proposed measures to end the unnecessary incineration of plastics. However, two respondents noted that existing long-term contracts between Energy from Waste operators and local authorities may pose challenges, advising that consideration should be given to how these contracts can be adapted in the future.

While most respondents who commented on this strategic aim were generally supportive of efforts to minimise the carbon impacts of the Energy from Waste sector, a few questioned whether this sector should be considered within the Route Map at all, arguing that incineration is not part of a circular economy.

CircularChem raised concerns about the proposal to explore carbon capture utilisation and storage (CCUS) as an option for Energy from Waste noting that such technologies are currently still in their infancy and are not close to commercial readiness on the scale needed.

Suggestions for additional priority actions

Scottish Environmental Services Association criticised the absence of a specific, costed measure on removing plastic from residual waste, which they described as key to decarbonising waste disposal.

Friends of the Earth Scotland felt that this aspect of the Route Map does not adequately reflect the conclusions and recommendations from the recent independent review on incineration. While supportive of the overall strategic aim, Anaerobic Digestion and Bioresources Association felt that greater recognition and support for Anaerobic Digestion is warranted within this section of the Route Map.

Other suggestions for additional priority actions under the decarbonise disposal strategic aim included: preventing new permits being issued for new or expanded incineration capacity; introducing the capacity cap for incineration; and adopting a more intensive advanced sorting all-in plastics collection approach.

4.2 Decarbonise disposal: further actions

Q6: To what extent do you agree with the further actions to 2030 listed across the Decarbonise disposal strategic aim? Please provide evidence to support your answer if possible.

Agreement with the further actions to 2030 across the Decarbonise disposal strategic aim was also high; 78% agreed to some extent, including 27% who agreed strongly.

Levels of support for the further actions were similar to those for the priority actions among individuals and organisations who answered Q6, with 65% and 85% respectively agreeing to some extent. All retail and packaging, waste management, public bodies and other organisations agreed to some extent with the proposals. While lower, a majority of those in other sectors were also in agreement, including 67% of local authorities, 71% of third sector organisations and three quarters (75%) of construction and development organisations.

Question 6 received 69 open text responses. Overarching comments on this set of further actions were mostly positive; for example, Industry Council for Packaging and the Environment (INCPEN) expressed strong support for the further actions outlined up to 2030, describing them as “a well-considered list of actions which look set to minimise the impact of disposal in Scotland if delivered successfully.” However, Fife Council raised concerns that the timescale for the further actions is unrealistic and should be delayed to give sufficient time to plan targets and implement measures.

Support the inclusion of Energy from Waste in the UK Emissions Trading Scheme (ETS), and investigate other fiscal measures to incentivise low carbon disposal.

There were mixed views on this further action. Some respondents expressed support for the proposal to include Energy from Waste in the UK ETS as part of a wider drive to reduce the carbon impact associated with residual waste. Scottish Water advised that Energy from waste in the Route Map should also include energy generated from biosolids.

However, some concerns were raised about the inclusion of Energy from Waste in the UK ETS, including:

• Energy from Waste operators may seek to pass on any associated costs to their customers, many of which will be Local Authorities
• Compliance with the ETS and investment in new low-carbon disposal technologies could result in significant costs for local authorities
• The ETS will defer investment in low carbon infrastructure
• The proposed changes may require renegotiations or adjustments to existing waste contracts, which could entail legal complexities and potential disputes
• Lack of alternatives to Energy from Waste for some items such as POPs
• Specific challenges for rural areas and islands, including transportation distance, cost and capacity issues

The proposal to investigate other fiscal measures to incentivise low carbon disposal was welcomed, and some fiscal measures were suggested by respondents. These included: measures to support the demand for recycled materials, including a long-term escalator on the plastic packaging tax and a 50% recycled content mandate; the introduction of a middle band of Landfill Tax that rewards biostabilisation prior to landfill; zero VAT rating plastic only residual waste collections; and a review of Scottish Landfill Tax rates post-2028 to maintain an appropriate balance between unit cost of Energy from Waste and landfill in the medium term.

Review and target materials currently landfilled to identify and drive alternative management routes.

There was broad support for this further action; it was strongly endorsed by various organisations including the Scottish Ecological Design Association and British Glass. A few requested clarity on which waste streams will be considered for alternative management routes for landfill, and others welcomed the opportunity to respond to the upcoming call for evidence.

The 'One Bin to Rule Them All' Team at the University of Manchester recommended consideration of the ‘plastics hierarchy of fates’, which was created as part of research at University of Manchester, advising that this could help in the identification of alternative treatment options for waste streams that have high amounts of plastics.

However, United Kingdom Without Incineration Network (UKWIN) did not support pursuing a targeted approach, suggesting that effort should instead focus on all residual waste sent to either landfill or incineration in order to reduce the overall volume of residual waste. In addition, The Highland Council expressed concern about the potential loss of most landfill capacity in Scotland, and what this would mean for dealing with material exempt from the Landfill Ban, which is unsuitable for shredding and sending to Energy from Waste. They advised that an appropriate level of landfill capacity must be maintained across Scotland into the future.

Facilitate the co-production of guidelines for effective community engagement.

Most comments on this further action were supportive, with respondents from a mix of sectors welcoming efforts to enhance and increase community engagement. A few recommended that communities and third sector organisations should be involved in the process of producing the guidelines. As with other actions related to community engagement, a few respondents advised that engagement with the public must take place through multiple channels, including a mix of online and in-person opportunities.

United Kingdom Without Incineration Network (UKWIN) questioned the placement of this further action within the Decarbonising disposal section of the route map, noting that the recommendation cited from the incineration review report related more broadly to waste management as a whole, not incineration.

Increase the capture of landfill gas.

Comments on this further action were mostly supportive. Organisations including a few local authorities, LARAC, Highlands and Islands Enterprise and SUEZ Recycling and Recovery UK Limited expressed support for plans to increase the capture of landfill gas, with Stirling Council noting this is of particular importance in the context of large scale site closures across Scotland. The Association for Renewable Energy and Clean Technology recommended that this further action should be upgraded to a priority action.

“We also ask the Scottish and wider UK Government to investigate and announce how they intend to support existing energy from waste capacity once projects begin to reach the end of their Renewables Obligation (RO) support. This applies to both waste wood sites and energy from waste with CHP. One suggestion on this would be increasing the priority level of action ‘Increase the capture of landfill gas’.” – The Association for Renewable Energy and Clean Technology

A few respondents warned of the potential costs associated with this proposal, and Comhairle nan Eilean Siar recommended that further work should be carried out to minimise the release of landfill gas and maximise the use of gas for energy generation rather than being flared.

CircularChem recognised the importance of increasing gas capture from existing landfill in reducing methane emissions to the atmosphere, but cautioned that increasing landfill capacity is at odds with the vision of the Route Map.