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ESA: ‘Policy trajectory could undermine waste hierarchy’

The Environmental Services Association (ESA) has found that current policy trajectory around Energy from Waste (EfW) could put investment in CCS at risk and undermine the waste hierarchy.

The association warned that, without further government intervention, the development of CCS will not be financially viable for the majority of EfW facilities.

However, it added that EfW plants fitted with carbon capture (CCS) technology offer the most reliable and lowest-carbon solution for treating residual waste in future.

This is including a consideration for the avoided Emissions Trading Scheme (ETS) costs which are due to come into effect in 2028.

The independent report was authored by SLR Consulting and appraises the future of residual waste treatment on three grounds: cost, carbon emissions performance, and reliability and technological readiness.

Sustainable Aviation Fuel

It also found that the proposed government subsidy support for producing Sustainable Aviation Fuel (SAF) from residual waste could allow EfW facilities to offer the cheapest waste disposal route for residual waste.

This could divert waste from existing infrastructure despite the fact that SAF production via gasification and other processes has a low degree of demonstration at scale and is unlikely to outperform EfW with CCS on carbon emissions unless the waste has a very high organic content.

The report also found that EfW with CCS is able to achieve net-negative carbon emissions and modelling suggested that this solution could be more beneficial than SAF on carbon emissions. It is important to note, however, that the application of CCS at scale is also in its early stages.

Development of other waste treatment technologies

Finally, the report concluded that large-scale development of less reliable or unproven waste treatment technologies poses a risk to established infrastructure, which is essential to the sanitary management of waste.

The ESA said that unless suitable market adjustments are made to constrain landfill, the application of the ETS to energy recovery holds the potential to incentivise treatment by landfill under current policy considerations.

‘Residual waste management could fall down the waste hierarchy’

Head of climate and energy policy at the ESA, Charlotte Rule, said: “Under current policy trajectory, there is a risk that residual waste material could fall down the waste hierarchy and that the treatment solutions favoured by present policy conditions – whether fully intended or not – risk becoming white elephants that strain essential public sanitation services, while not fully realising the maximum carbon emissions savings potentially on offer.

As highlighted in the recommendations of the report, there is a need for more joint working across Government to ensure that the push and pull of various government departments with a stake in this issue – Defra, DESNZ, DfT and The Treasury – doesn’t result in unintended consequences that undermine the UK’s existing high-performing infrastructure, as well as the recycling and waste sector’s Net-Zero pathway.

Building on the work set out in this report, we would like to see Government, along with the Climate Change Committee (CCC) produce a robust independent evidence base to inform relative support for EfW with CCS and SAF production for waste, by exploring the relative greenhouse gas emission impacts of each solution as well as issues around deliverability risk.”

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