Thank you for your response to my previous letter regarding incineration and climate change. I am writing to you ahead of the publication of the CCC 6^th Carbon Budget advice to government to draw your attention to serious failures in your previous analysis of this issue.

I have three concerns:

1)     You have previously taken little account of the impact of Energy from Waste (EfW) incineration on recycling/reuse. The bulk of local authority waste that went to landfill prior to 2012 now gets burnt, rather than recycled, and as a result, more local authorities have become locked into long term commitments to EfW. This puts a significant brake upon meeting the 65% municipal waste recycling target for 2035.

2)     There is enough new EfW capacity being agreed through the planning system to double incineration in England and few people are asking where the fuel will be coming from? There is not enough useful landfill waste to meet this demand, which means we either import waste to burn, or recycling/reuse declines, as has already happened in several local authorities.

3)     Relying upon carbon capture and sequestration for EfW is a techno fix with no government plan for implementation. Ministers are very clear that contracts for new EfW plants is a matter for the individual local authority, rather than any strategic plan. New incinerators don’t require carbon capture and sequestration and I doubt that its introduction is part of any existing contracts. A better approach would be to have a straight forward moratorium on new build.

The carbon intensity of the grid has dropped in recent years, which means fewer greenhouse gases for every unit of energy used in the UK. This makes Energy from Waste four times more carbon intensive than the grid and the gap is growing as renewables expand. Incineration now sticks out like a sore thumb in a wonderfully long list of renewable energy technologies and we need a pro-active plan to run down the industry as recycling expands.

A new study from Zero Waste Europe shows where this leads with France being the biggest user of Energy from Waste and also having the one of the poorest recycling rates in Europe. The UK currently recycles 45% of its waste, while France manages a mere 25%. This is not because British people are naturally better at recycling than French people, it is purely down to how much municipal authorities are geared up to burning their waste.

The UK should set itself on the same path as Denmark, who have realised their mistake and are now making the transfer to cleaner technologies. The history of waste treatment in Scandinavian countries clearly shows the unfortunate consequences of starting at the wrong end of the material cycle and over investing in EfW, as we are now doing in the UK. Scandinavian countries now recognise that it will prevent them from meeting both recycling and net zero targets.

One defense of incineration is that we only burn the material that can’t be recycled. However, I’ve proved conclusively that local authorities using incineration continue to have poor recycling rates, while those that switch to incineration see recycling stagnate, or even decline. My research shows the way this has been replicated nationally, with the UK now burning more than it recycles and I attach my report: ‘going backwards on incineration’.

Another argument put forward to defend Energy from Waste is that it is better than landfill for greenhouse emissions. A new report from Zero Waste Scotland shows how marginal this advantage has become as a small increase in the percentage of plastic in the waste stream (from 15% to 17%) would cancel out that small upside. Given that the government has failed to update its England and Wales 2012 figures for the amount of plastic in the waste stream, we have no idea if this justification for incinerators still applies.

I very much look forward to the CCC report on 10^th December, I’m sure it will be full of great recommendations that I can support. However, on the topic of EfW I do hope the CCC give this far more serious attention than in previous years.

Best wishes, Jenny

Jenny Jones

Baroness Jones of Moulsecoomb

Green Party

House of Lords

SW1A 0PW