Confederation of European Waste-to-Energy Plants Backs EU Circular Economy Plans

The Confederation of European Waste-to-Energy Plants (CEWEP) has published a response in which it embraces the EU Commission’s ambition to phase out landfilling of recyclable, and eventually recoverable, waste and urged the decision makers to promote Quality Recycling. The full response can be read below… Waste-to-Energy (waste incineration with energy recovery) is complementary to Quality Recycling, helping to achieve a Clean Circular Economy. If waste is too polluted for Quality Recycling, it should be used to generate local, affordable and secure energy in Waste-to-Energy plants. CEWEP endorses the Commission’s proposal to phasing out landfilling of recyclable - and eventually recoverable - waste. However, we would have preferred a more ambitious deadline: by 2020 rather than 2025 and 2030 respectively. This delay is a lost opportunity for improving resource use, considering that more than 80 million tonnes of municipal waste is still landfilled in the EU 28 each year. A ban on landfilling would unleash the full potential of waste as a resource. This will increase material recycling rates and energy generation from the remaining waste. CEWEP hopes that the vital issue of Quality Recycling, rather than just focusing on quantity, will receive greater attention in the on-going revision in order to achieve an evidence-based circular economy. For this we need: accurate measurement, better data and transparency about what goes in and what goes out of Recycling facilities. Greater transparency is also necessary in order to avoid that the EU’s “recycling” targets are achieved simply by shipping the waste to countries with poorer environmental and social standards than those in Europe. Quality Recycling is key in order to enable industry and consumers to have greater confidence in recycled materials, and to actually use them. CEWEP would like to stress that Waste-to-Energy plants act as a driver for Quality Recycling by treating polluted and complex waste, keeping harmful substances out of the Circular Economy. Sometimes materials are bonded and can be extracted only by means of thermal treatment. Ferrous and non-ferrous metals can be extracted from the bottom ash of Waste-to-Energy plants and further recycled into new products such as aluminium castings for the automotive industry. Additionally Waste-to-Energy plants generate affordable local energy from residual waste and contribute to security of energy supply and reduction of greenhouse gas emissions. In some cities they cover 50% and more of the local heat demand - at a very cost-effective price. Considering that in 2012 the EU 28 imported 106 billion m3 of natural gas from Russia (Eurostat), it is worth noting that the energy content of the waste treated by Waste-to-Energy plants in the EU equals 19% of Russian gas imports (2012). Circular Economy without circulating harmful substances Waste-to-Energy (WtE) acts as a sink for pollutants. It destroys the bio pollutants, e.g. viruses and bacteria, through the combustion process. By extracting the chemical pollutants from the waste, via the sophisticated flue gas cleaning system, WtE prevents dirty/contaminated waste from entering the recycling chain and adversely impacting quality. WtE makes sure that the rejects from recycling and sorting facilities, i.e. wastes that are not good enough for quality recycling, are treated in an environmentally sound way. WtE guarantees that harmful substances are captured and kept out of the Circular Economy. The amount of waste sent to WtE incineration is determined by Quality Recycling, and the acceptance of recycled materials on the market. Only remaining waste that is not suitable for Quality Recycling will go to WtE plants. Boost Quality Recycling CEWEP welcomes the Commission’s approach to harmonise the monitoring of recycling. However, regarding the recycling targets the Commission’s proposal is doubly ambitious, firstly with the change of monitoring to an output oriented approach and secondly with the quantitative target of 70% recycling rate for municipal waste. While being eager to propose ambitious quantitative targets, the Commission should also draw some attention to quality criteria. The Commission’s Impact Assessment was based on the former monitoring of recycling, which was in practice often an input led approach, i.e. counting the input into a recycling facility as recycled, although a significant amount is rejected by recycling facilities, e.g. because it is too contaminated or degraded. In order to set evidence based targets we need better data, including mass balances, harmonised monitoring of the targets and quality recycling, considering life cycle thinking. Recycling rates should be based on detailed data analysis on which waste streams and waste compositions are suitable for sustainable recycling and to what extent it can be expected that the recyclates will actually replace virgin materials. Quality criteria for recycling, similar to the R1 Energy Efficiency formula introduced in the Waste Framework Directive 2008/98/EC for WtE, would be useful. The latter has proven to be instrumental in driving improvement of the energy efficiency of WtE plants. Also regarding mass balances, information is widely available for WtE plants as they strictly document what goes into the plant and what goes out, i.e. energy and residues. From the latter precious metals are recycled. Considering Life Cycle Thinking The waste hierarchy set in Art. 4 Waste Framework Directive 2008/98/EC opts for the best overall environmental outcome and the application of Life Cycle Thinking. Recent studies show, e.g. for plastics waste, “that recycling is only more preferably over (energy) recovery if it could replace a minimum of 70 – 80 % of virgin plastics (Rajendran et al., 2013). A closed loop recycling is frequently possible in case of PET (from bottles) but hardly for other plastics. Recycling is further complicated by a diversity of materials. Thus, in many cases incineration with energy recovery represents the better solution than recycling”. Also the results of the stakeholder consultation on plastics waste showed that stakeholders overwhelmingly recognise that “Energy recovery is sometimes better for waste management”. “Indeed, it is impossible for many products to have a mechanically recycling, due to the contamination with other materials or to recycle complex”. New definition of Municipal Waste (Art. 3 (1) a and Annex VI) We wonder if the new definition of Municipal Waste brings more clarity. We do not understand why “waste from sewage network and treatment, including sewage sludge” is excluded in the newly proposed definition. It should stay under the definition of municipal waste. WtE overcapacities? In the EU as a whole there is no overcapacity! There are still more than 80 million tonnes of municipal waste landfilled The Commission’s Impact Assessment discusses a great deal about so called overcapacities for WtE in some regions. It also rightly states that some Member States have practically no WtE capacity, but landfill most of their municipal waste. It must be considered that the Member States where there is some spare WtE capacity achieve the highest recycling rates in Europe. They have progressive source separation systems and work to ensure that only waste that has gone through this system enters a WtE plant. The Commission’s Impact Assessment mentions a WtE overcapacity of 25 % in Germany. We are very surprised about this figure as to our knowledge this is not correct. The reason for this “overestimation” could be that the authors only took into account the national Municipal Solid Waste (MSW) generation. However, WtE plants also treat other waste apart from MSW, such as commercial and industrial waste similar to household waste. It must also be considered that WtE plants take the rejects from recycling facilities, as normally not 100% of the input into recycling facilities become recycled products in the end, e.g. due to poor quality, but have to be treated in WtE plants. A recent EEA report (June 2014) states in its Executive Summary: Taking into account the availability and quality of publicly available data, this report can neither give a complete overview of how much non-MSW is incinerated in plants originally dedicated to MSW, nor is it possible to define how much MSW is incinerated as refused-derived fuel (RDF) or in co-incineration plants, making it extremely difficult to finally assess the appropriateness of existing capacities. Therefore the partial analysis in this report can only be a starting point in the assessment of the total European waste incineration market. WtE: Not a candidate for further taxes or bans The Commission proposes in Annex VIII some economic instruments that shall be applied by Member States that are struggling to meet their waste management obligations. They mention, inter alia, “introduction or increase of incineration taxes or specific bans for incineration of recyclable waste”. Taxes on incineration would make waste treatment more expensive for citizens and industry, without providing benefits for the environment. Incineration taxes have not succeeded to increase recycling rates. In Sweden, where waste incineration taxes had been introduced with the aim to increase recycling rates, this did not happen, and so the Swedish government decided to withdraw their incineration tax. Anyway, taxes and bans for incineration of “recyclable” waste is not workable in practice without a legal definition of what is “recyclable”. Such a definition would have to consider if recycling is environmentally sound (no contaminated waste) and technically and economically feasible. Last, but not least incineration taxes or bans would be counterproductive in Member States that are lagging behind as these countries still rely heavily on landfill and do not have significant or even any WtE capacity, which could help to divert waste from landfills. The progressive Member States that have significantly reduced their dependence on landfills have done this hand-in-hand with capacity building for both, Recycling and WtE plants, the latter treating the residues from Recycling facilities, please see figures from EUROSTAT below. Conclusion: CEWEP embraces the idea of a Circular Economy, phasing out landfilling and optimizing Recycling. Waste-to-Energy is complementary to achieve a Clean Circular Economy, helping to reach Quality Recycling. If waste is too polluted for Quality Recycling, it should be used to generate local, affordable and secure energy in Waste-to-Energy Plants, thus contributing to security of energy supply. For more information please contact Dr. Ella Stengler, CEWEP Managing Director, Tel. +32 2 770 6311: mailto: ella.stengler@cewep.eu Read More CEWEP Congress - Local Energy from Local Waste The theme of the 7th Confederation of European Waste-to-Energy Plants (CEWEP) Congress, which took place on 24-25 September 2014 in Brussels, was ‘Local Energy from Local Waste: Affordable, Secure & Sustainable’. CEWEP: End of Waste Criteria Must not be Applied to SRF With a number of EU states developing their own end-of-waste criteria for waste derived fuels, European associations with a stake in waste management, including the Confederation of European Waste-to-Energy Plants (CEWEP), have urged the European Commission to ensure that Refuse Derived Fuel (RDF) and Solid Recovered Fuel (SRF) from waste remain under the control of waste legislation. 'Warmth from Waste' Project to Expand Combined Heat & Cooling from Waste to Energy An initiative to use waste to energy technology to assist Europe in meeting its objectives to decarbonise its energy supply system through district heating and cooling has been launched.