Throughout the UK Local Authorities are approving planning applications and in many cases those decisions do not comply with Public Law.

In Trafford the Local Authority refused an application on the grounds that it is an Air Quality Management Area. This decision was overturned by the Secretary of State.

The purpose of an AQMA is for a Local Authority to take action to reduce pollution; how can it possibly be correct process for the Government to go against this ?

In London the Mayor has given permission for an Incinerator in Sutton. This is also an Air Quality Management Area, mainly due to the Mayor Of London’s failed Air Quality strategies.

How can it be correct process that he has now given permission for an Incinerator in an area which is already exceeding pollution limits?

Why Oppose Incineration

The alternatives to incineration are cheaper, more flexible, quicker to implement and better for the environment. Rather than incinerating waste, local authorities should focus on maximising recycling and providing a weekly separate food waste collection for treatment by composting or anaerobic digestion (AD). Recyclables and biodegradables should be separated from the small amount of residue material. This residue should be stabilised by composting and then sent to landfill.

The incineration of household waste

Incineration depresses recycling and wastes resources

Incineration reduces our ability to reuse or recycle potentially valuable discarded material. As WRAP notes in its recent report (Domestic Mixed Plastics Packaging Waste Management Options), there is currently a ‘Catch 22’ situation, with few Local Authorities prepared to collect plastic waste other than bottles, as there is limited potential for them to be recycled. However, this means there is a lack of such plastics available for companies to attempt to do so.

WRAP also reports that “recycling offers more environmental benefits and lower environmental impacts than other waste management options”. See Environmental benefits of recycling: An international review of life cycle comparisons for key materials in the UK recycling sector for more detail.

Waste PFI contracts that include incineration depress recycling rates. In Nottinghamshire it would appear that Veolia see it as more profitable to fall short of recycling targets, as their planning application for a waste incinerator to be built in Sherwood Forest indicates that Nottinghamshire’s recycling will be effectively capped at less than 47% for the next 25 years!

Incineration releases greenhouse gasses

Incineration involves the release of high levels of CO2, the main climate warming gas. Accounting for recovered energy, incineration is accompanied by twice or more the CO2 per unit of power than the same energy (as electricity or combined heat-and-power) produced from fossil fuel (Stop Trashing the Climatereport, June 2008). The Environment Agency’s WRATE software is used to claim energy-from-waste is beneficial, but this depends on faulty assumptions on efficiency and bio-carbon. Proper lifecycle calculations using the better ATROPOS model found that “scenarios using incineration were amongst the poorest performing” while those using MBT were much better (Greenhouse Gas Balances of Waste Management Scenarios, Eunomia Consulting report pluserrata to the Greater London Authority, January 2008).

Studies show that for electricity-only incinerators (incinerators that do not optimise the use of the heat they produce), energy production is so inefficient that, from a climate change perspective, incineration is worse than gas- or coal-fired power stations! See Dirty Truths: Incineration and Climate Change and A Changing Climate for Energy from Waste? for further details.

Incineration is often forced through against strong public opposition

Incineration is not the way that householders want their discarded material to be managed. Despite this, Defra was given a further £2 billion of funding through PFI credits in the 2007 Comprehensive Spending Review (including £600 million in 2008/09, £700 million in 2009/10 and another £700 million in 2010/11). Defra have issued guidelines for the granting of Waste Private Finance initiative (PFI) funding, but the process is not transparent. Although Local Authorities do not appear to follow Defra’s rules, public funding (in the form of PFI credits) is still being made available to them.

For example, Guideline 6 states: “Proposals should demonstrate that other relevant authorities, the public, and interested parties have been consulted and that there is a broad consensus supporting a recognised long term waste management strategy which is reflected in the proposed solution”, yet it would appear that, for instance, Waste Officers from Hull and East Riding Councils submitted an Expression of Interest for funding, and that Waste PFI funding was approved by Defra, without the knowledge of the democratically elected members (Councillors), and certainly without reaching “a broad consensus” to support their incinerator proposals.

Incineration relies on exaggerating future quantities of waste instead of strongly increased recycling and composting

Many Waste PFI contracts are entered into as a response to predictions of huge increases in the quantity of household waste (often calculated five to ten years ago) when in fact household waste has actually fallen in many areas. According to Defra statistics, the average annual increase in municipal waste from 2001/02 to 2006/07 was just 0.2%, far short of the 3% year on year rises that were predicted. These flawed and exaggerated predictions are still being used to try to justify the building of unnecessary incinerators.

Operators also say they could always ‘top up’ with commercial and industrial (trade) waste to make up for any ‘shortfall’, although in practice this has been shown to cause operational efficiency problems, e.g. for Veolia’s Sheffield incinerator – see our article entitled Did McDonald’s give Sheffield’s incinerator indigestion?

Incineration creates toxic emissions and hazardous ash

While everyone agrees that incinerators do not improve air quality, there is a great deal of controversy over that extent and nature of the harm resulting from releases into the air (and indeed releases to land and water). Although incinerator fumes pass through expensive filter systems, modern incinerators still emit significant levels of NOx and of ultrafine particles. The latter includes nano-particles which are of great concern because they can pass through the lung lining, causing internal inflammation and penetrating to organs (even to the foetus in a pregnant mother) [1].

Dioxins still an issue: officially these most toxic products are restricted to very low emission levels by incinerator filters. But studies overseas show that high levels are emitted during start-up and close-down when dioxins are not monitored in the UK [2].

Incineration poses significant health risks

UKWIN calls for the adoption of a more precautionary approach while better scientific research is conducted into the extent of the damage to human and animal health (and to ecosystems and fragile habitats) caused by the release of these harmful toxins. The scientific evidence is quite sufficient, UKWIN argues, to trigger the precautionary principle. Government and regulators should compel the waste industry to measure, assess and suppress all of their suspect emissions of harmful toxins.

There is plenty of evidence that emissions from incinerators and their ashes are potentially harmful. The licensed emissions of NOx and particulates cause a level of harm that is included in the EU assessments of industrial and traffic emissions. Incinerators also have emissions unlimited by license, during start-up and close-down, and from ash dispersing during transfer to landfill or construction sites [3].

5-7% of the mass of incinerated waste becomes “fly ash” (also known as APC). The fly ash is trapped by filters, and is classed as hazardous waste. Because fly ash is strongly alkaline and also high in dioxins and heavy metals, it has to be transferred to landfill. The Bishops Cleeve hazardous landfill site in Gloucestershire takes fly ash from many incinerators; the residents see the ash literally blowing around. UKWIN believe residents are fully justified in fearing the health impacts. Indeed, the health risks have been shown as significant by an official study (Duarte-Davidson et al.).

Grate-ash (bottom ash) forms another fraction, 25-30% of the mass of incinerated waste. This ash also contains levels of dioxins and metals. Because of their commitment to incineration, the authorities are encouraging the use of bottom ash as construction fill and as an aggregate substitute. But some of this ash spreads around during construction, and the toxins leach into groundwater. During new construction, in decades to come, the metals and dioxins will get into the environment.


[1] Nano-particles arise in huge numbers from vehicles, most being carbonaceous. But high temperature combustion processes such as incineration generate nano-particles with metallic, dioxin and aromatic hydrocarbon (PAH) coatings, which may be much worse for health. The review by Cormier et al (Origin and Health Impacts of Emissions of Toxic By-Products and Fine particles from Combustion, 2006) is strong evidence, while various research papers are establishing tangible public health impacts (Univ. of California study 2008 – Air Pollution may Cause Heart Disease; shows nano-sized particles are the most damaging). See FOE’s workshop paper for wider discussion and specific references.

[2] A 2007 Japanese study (Characteristics of dioxin emissions at startup and shutdown of MSW incinerators) implies that dioxins from a few start ups each year can be very significant, while incinerators operated in batch modes would emit a high proportion of the total when starting up. Other studies show dioxin-like products are also emitted, but again these are not controlled or monitored. Also see Peter Montague’s article entitled The Deadliest Air Pollution Isn’t Being Regulated or Even Measured.

[3] As the Royal Society state (in relation to the oft-quoted 2004 Enviros study into the health impacts of incineration): “In view of the large uncertainties associated with some of the data examined, particularly in the epidemiological studies, it would have been more appropriate to adopt a cautious approach, rather than use inadequate data in a quantitative framework. The latter may give a misleading impression of the robustness of the results. Caveats associated with the uncertainties in the results are not presented adequately, particularly in the quantification of the health effects, which could mislead the reader. The report’s relevance to waste management decision-making by Local Authorities is limited, as several important issues are not addressed. These include the effect of local environmental and health sensitivity to pollutants and the impact on emissions of specific waste management activities operating under non-standard conditions. Bias in the availability of good quality information means the report concentrates mainly on the effects of air pollution. Consideration of the potential effects of exposure to pollutants through other pathways is not consistent throughout the report and therefore prevents adequate comparison of the options”.