Based on the background studies the Commission had carried out, it was expected that the Commission would be able to give a new direction for the energy recovery. Unfortunately, this was not the case.
The paper put the waste hierarchy as the basis. This is an undisputed principle that I guess nobody is challenging. The interpretation the Commission gives to it is stuffy; the role of energy recovery of waste should be as limited as possible by making it difficult, unwanted, expensive and, in many ways, complicated. I was expecting a different approach: how to ensure that non-recyclable waste is destined to energy recovery instead of landfills and generated energy is used efficiently to satisfy power and heat demands of customers, and what kinds of EU policies should be in place to ensure that.
Let’s make the internal market work properly
The strength of the EU lays in its internal market. However, the Commission clearly denies that in this paper by taking a national approach to waste management. The European Commission points out that in some countries there is overcapacity in waste-to-energy, while other countries have practically no such capacities. Furthermore, the capacity issue is poorly analysed in the paper. It only refers to “dedicated incineration capacity for municipal waste” – even though there are certain and relevant commercial and industrial non-recyclable waste streams destined to energy recovery as well.
As a solution to this issue, the Commission is suggesting that countries with overcapacity (which we think is debatable) should close their capacities and others should build new waste-to-energy capacity! Why not make the internal market work properly in this matter and use the existing capacities in an efficient manner? This is not done, even in spite of the fact that the paper clearly recognises that at the EU level overcapacity does not exist or is foreseen. Taxing waste-to-energy operations is one of the solutions proposed to limit capacities. Such a tax would clearly put an additional financial burden on energy recovery of waste and increase the economic viability of landfilling without really boosting quality recycling.
It is true that waste is transported even very long distances for recycling operations and that is considered perfectly normal. Transportation of waste for energy recovery would be well justified from environmental and economic point of views if the alternatives are landfilling or incineration with low or no energy recovery domestically. The paper also omits the mutually supportive roles of recycling and energy recovery of waste.
More energy recovery and less landfilling
In my view, the paper and the thinking behind it positions energy recovery of waste against recycling and other recovery methods. A better way would be to see energy recovery of waste against landfilling, which is lower on the hierarchy and a primary challenge for the circular economy. Eurostat statistics does not support the claim that countries with higher rates of energy recovery would have low recycling rates. On the contrary, countries with high energy recovery rates tend to have high recycling rates, too, and very low landfilling rates.
The paper also omits the mutually supportive roles of recycling and energy recovery of waste. Both of them support high-quality waste management operations; for instance, metals and minerals are collected from bottom ash for recycling after energy recovery. Increasing recycling rates as well as quality requirements for recycling would lead to increasing sorting rejects and recycling residues. Energy recovery could be the ideal solution for these and many other waste streams.
If I had been in the Commission…
…my paper would have looked very different. I would have started from the waste hierarchy, but my interpretation of it would have been very different and it would have looked for ways to ensure that non-recyclable waste is destined for energy recovery instead of landfills. I would have studied how the well-functioning internal market could contribute to the efficient use of existing and possibly new energy recovery of waste capacities, rather than closing capacities in some countries and building new capacities in others.
Limiting the approach only to mixed municipal waste does not give a full picture of the situation, as many commercial and industrial waste streams are generating non-recyclable waste streams. And I would have put a lot of emphasis on understanding and promoting mutually supportive measures for both recycling and energy recovery. Without question, I would have also focused strongly on improving definitions and statistics. Depending on if the recycling rate of municipal waste is defined as waste collected for recycling instead of as waste that is actually entering to recycling, the outcomes vary considerably and, in fact, are not comparable.
Esa Hyvärinen
Vice President, Public Affairs, Fortum