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

1 Introduction

1.1 Background To The Review

In May 2021, the Cabinet Secretary for Net Zero, Energy and Transport announced that an independent review of the role of incineration^[1] in Scotland's waste hierarchy would be commissioned, with the aim of ensuring that how residual waste is managed in Scotland aligns with Scotland's carbon reduction ambitions. This followed the Scottish Government's update to the Climate Change Plan, which set out the Government's intention to "end landfilling of biodegradable municipal waste by 2025, reduce the percentage of all waste sent to landfill to 5% by 2025 and recycle 70% of all waste by 2025."^[2]

A statement to Parliament by Lorna Slater, Minister for Green Skills, Circular Economy and Biodiversity, in September 2021^[3], set out the intention for this review to:

• Be led by an independent chair.
• Prioritise consideration of national capacity requirements for incineration.
• Have scope to consider how emissions from existing incinerators can be reduced and residual heat may be reused; and consider the societal impacts of residual waste treatment, including health and community impacts.

In addition, the Minister set out the timeline for this review to be undertaken between December 2021 and March 2022.

In November 2021, the Minister appointed Dr Colin Church to act as independent Chair of the Review of the role of incineration in the waste hierarchy in Scotland ('the Review'). Dr Church is CEO at the Institute of Materials, Minerals and Mining (IOM3) and is Chair of the Circular Economy Task Force, a business group led by the Green Alliance. He has previously been the CEO of the Chartered Institution of Wastes Management (CIWM), which is a professional body for the waste management industry in the UK and has been a non-executive director for WRAP, a leading UK sustainability charity. Prior to that, he held several senior roles in Defra, DECC^[4] and the Cabinet Office.

As independent Chair of the Review, Dr Church determined the scope and process for the review within the overall parameters and timescale set by the Minister, which are outlined above. Dr Church was supported in the Review by a secretariat consisting of individuals detached from Scottish Government and the Scottish Environmental Protection Agency (SEPA).

1.2 Structure And Process Of The Review

1.2.1 Scope of the review

The Review, through an initial Call for Evidence ('the Call') and a number of stakeholder events, sought input into five main topics which were considered in the context of treatment of household (HH) and commercial and industrial (C&I) waste streams. These waste streams were chosen as they are likely to be captured by the forthcoming ban on sending certain biodegradable waste streams to landfill (see Annex B), they comprise a large proportion of waste incinerated, the incineration of these waste streams has increased significantly since 2013^[5], and municipal waste incinerators are often the object of stakeholder concerns.

The five main questions highlighted in the Call were:

1. Given Scotland's waste management 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 impacts?

Certain elements have been excluded from the scope of the Review. These include:

• The incineration of biomass for energy, since the goal of biomass facilities is likely to be energy production (for example, through energy crops), rather than waste treatment.
• Consideration of high-temperature incineration for the treatment of some healthcare and hazardous wastes^[6].
• An in-depth review of health impacts of residual waste treatment.

This report largely follows the structure of the five topics. It should be read as a whole; in particular, its Recommendations draw on all of the work of the Review, not just the aspects relevant to their placement in the document.

While the Call encouraged submission in relation to all the topics, the Review prioritised Topics 1-4, with the assessment of national capacity requirements (Topic 1) at its centre. Separate work has been commissioned to inform further consideration of opportunities to decarbonise the residual waste treatment infrastructure sector in Scotland, with the main focus on waste incineration (Topic 5). In the meantime, a brief outline of some of the issues and some provisional conclusions and recommendations are included within this report.

In accordance with its remit, the Review has primarily looked at incineration. However, the Review has also considered options for residual waste treatment beyond incineration, including, but not limited to, landfill, mechanical biological treatment (MBT), and biostabilisation.

Because of the potential extension^[7] of the Ban ('the Extended Ban') to non-municipal biodegradable waste, some aspects of construction and demolition (C&D) waste have also been considered.

1.2.2 Evidence collection and analysis

While there was some evidence and data on the key topics already available to the Review at its commencement, the Review was aware that further important information may be held by stakeholders. Additionally, many groups feel strongly about waste management in their local areas as well as environmental issues on a wider scale. The Review therefore issued a Call for Evidence ('the Call') and organised a series of meetings, which together enabled stakeholders to provide written and verbal evidence, viewpoints and considerations for the Review.

The Review commissioned additional information, research and analysis where necessary. This included capacity modelling and options appraisal by Ricardo and a rapid review of evidence relating to the health impacts of incinerating waste since 2009 from Public Health Scotland. Additionally, the Review has sought extra information and sense checks from stakeholders where appropriate and necessary.

More information on the evidence gathered can be found within the evidence document.

1.2.3 Limitations

The Review has endeavoured to be open and thorough in its scope and process. However, there have been a number of limitations caused by the Review's timeframes and the impacts of Covid-19, both on the Review's activities and other organisations' ability to contribute to the Review.

The Minister for Green Skills, Circular Economy and Biodiversity requested that the Review was delivered as soon after the end of March as possible in order to take account of the need for Local Authorities to make arrangements for the Ban and consider planning applications as well as for the waste management industry to make investment decisions. This timescale has meant that certain parts of the Review had to be prioritised, particularly the capacity analysis and consideration of the social, health and economic trade-offs for various waste management options. In order to allow the Review to give appropriate consideration to the matter of decarbonising existing infrastructure, an additional piece of work has been commissioned for this, which is expected to take a further six to nine months. The Review and its Chair do not expect this to delay the publication of the existing Report or accompanying evidence document, nor inhibit the Scottish Government's decision making ability based on this Report.

The Covid-19 pandemic has also impacted on the Review. While many of the impacts, such as the inability to hold in-person meetings and stakeholder events, have been mitigated through the use of video calls, other limitations in terms of the capacity of other organisations have resulted in minor adjustments to the scope of the Review and the evidence available for analysis. Additionally, the Review has taken care with the data used for the capacity analysis, due to the potential for the 2020-22 data to not be representative.

Finally, some data that the Review would have preferred to assess (such as full data on waste arisings and fate since 2018) has not been available due to the impacts of the recent cyber-attack on SEPA.

1.2.4 Review publications

There are currently five elements to the Review's outputs:

• Call for Evidence, December 2022^[8] – This invited stakeholders to provide comments on initial analysis from ClimateXChange (CXC) and evidence on a range of questions relating to the Review.
• Review Report, submitted April 2022 – This document outlines the key considerations of the review and the recommendations the Review is making.
• A summary of the main recommendations of the Review to date (to follow).
• Evidence Report, submitted April 2022 – This report summarises the evidence considered by the Review, including responses to the Call and further evidence.
• Call for Evidence responses – As far as possible, the Review has published in full the responses received to the Call. Further information on the publication of responses can be found within the evidence document.