The RDF Industry Group argues that, to ensure that waste management costs are minimised and infrastructure across Europe is used efficiently, it is important that the residual waste market across Europe has a level playing field.
The separate Emissions Trading Schemes (ETS) adopted by the UK and the EU complicate this aim â and so the RDF Industry Group will be arguing strongly for robust border adjustment measures to account for any national differences in ETS implementation.
Andy Jones, Chair of the RDF Industry Group, said: âAny treatment of residual waste will have a carbon impact, and both the UK and EU are seeking to re-design their emissions trading schemes (ETS) to tax this impact and incentivise its reduction. We need to ensure the financial burden of such schemes is broadly aligned across Europe to allow the residual waste market to continue to function efficiently, as it does now. Mechanisms such as free allowances or carbon border adjustments are already used to take account of global trading in other areas, and there is no reason why the same canât be done in the UK in relation to energy from waste (EfW) and the ETS.â
Jones highlighted the potential for exports to result in lower greenhouse gas (GHG) emissions, despite the waste having to be transported further. This is because most of the northern European plants that receive RDF exported from the UK are efficient âcombined heat and powerâ (CHP) facilities, where the surplus heat left over from electricity generation is used by industrial or domestic customers. This avoids the need for heat to be generated from fossil fuels. By contrast, few of the UKâs EfW facilities have suitable heat users nearby, and instead vent the left overheat to the atmosphere.
Jones contrasted the RDF Industry Groupâs position with that of the Environment Services Association (ESA), the body that represents the interests of the UKâs waste management industry. In a recent strategy document, the ESA calls for a ban on RDF exports once there is sufficient UK EfW capacity. But Jones regards the ESAâs position as shortsighted: âIn the last 10 years, operational incinerator capacity in the UK has increased from 5 to 20 million tonnes a year â more than in the rest of Europe combined, Whilst much of this is needed to reduce landfill, ESA has been repeatedly warned that too much capacity will compete with recycling â or with other applications, such as production of aviation fuel. Despite the UK government setting new, stretching recycling targets, the free-for-all building spree is continuing, with a further 5 million tonnes capacity currently under construction. ESA members are simply over-competing with one another as if waste is limitless, leaving them staring into a waste supply blackhole in the futureâ.
RDF exports have for over a decade provided access to spare EfW capacity in places like The Netherlands, Germany, and Sweden. This allowed the UK time to transition from landfill to a recycling-led waste system, without building its own EfW capacity that would be rendered redundant as recycling rates increased. Instead, UK recycling rates have stagnated while EfWs have proliferated. Now, faced with increasing competition for declining tonnage, the ESAâs call for a ban on exports strikes Jones as protectionist. Jones concluded:
âUnfortunately, instead of seeing exports as part of the transition to a circular economy, the UK waste sector â still dominated by disposal and treatment rather than recycling â has ploughed on building what will soon become some of the most expensive stranded assets in Europe.
At a time when we need the best environmental solutions at affordable prices, the ESAâs proposal would reduce choice for cash-strapped local councils and artificially inflate UK EfW gate fees. The Government should disregard calls for protectionism and ensure that the ETS allows all forms of EfW to compete on a level playing field.â