GAIA Global Alliance for Incinerator Alternatives

Transcription

1 GAIA Secretariat Unit 330, Eagle Court Condominium 26 Matalino Street, Barangay Central Quezon City, Philippines 1100 Contact: Intergovernmental Panel on Climate Change (IPCC) Working Group III - Mitigation of Climate Change (WG III) c/o Potsdam Institute for Climate Impact Research (PIK) PO Box Potsdam Germany Manchester, 13 th April 2014 To the attention of the IPCC WG III, GAIA 1 would like to commend the extraordinarily important work of the Intergovernmental Panel on Climate Change in providing science-based facts around the most important challenge faced by our society nowadays, that of climate change. Particularly through the reports published by WG II and I in last months but also throughout its entire excellent trajectory since its creation, the contribution of the IPCC to support adequate action for climate change mitigation and adaptation has been paramount and undoubtedly instrumental to protect our common future. Moreover, GAIA would like to congratulate WG III for its admirable accomplishment with the recently launched report and agrees with most of its general conclusions, emphatically those pointing at the need to stop catastrophic climate change by transforming our energy systems and phasing out fossil fuels use. However, GAIA feel compelled to also express its deepest concerns in regard to specific claims about GHG emission reduction in the field of solid waste management included in the recently published Summary for Policy Makers from WGIII Report. Not only some of these claims are incorrect and therefore misleading, but they also indicate that the ample evidence provided in extensive comments to the SOD in April 2013 by GAIA 2 and other experts from the field have been ignored without explanation. In this regard, the IPCC may also want to revise the disproportionate influence of a limited and non-representative list of authors that were at least quoted in the Second Order Draft of the report. According to the Summary for Policy Makers, the Report states that: Important options for mitigation in waste management are waste reduction, followed by reuse, recycling and energy recovery. Waste and wastewater accounted for 1.5 GtCO2eq in As the share of recycled or reused material is still low (e.g., globally, around 20% of 1 GAIA is a worldwide alliance of more than 800 grassroots groups, non-governmental organizations, and individuals in over 93 countries whose ultimate vision is a just, toxic-free world without incineration. 2 Comments provided by GAIA to the WGIII AR5 SOD review can be made available upon request at: mariel@no-burn.org

2 municipal solid waste is recycled), waste treatment technologies and recovering energy to reduce demand for fossil fuels can result in significant direct emission reductions from waste disposal. [10.4, 10.14] In the spirit of contributing positively to the IPCC s efforts against catastrophic climate change, GAIA would like to provide the following analysis below. 1. Important options for mitigation in waste management are waste reduction, followed by re use, recycling and energy recovery Firstly, it must be noted that an earlier version of the text presented at the beginning of the negotiations in Berlin included the reference to the Waste Hierarchy, which is the scientific and policy milestone guiding waste management options worldwide. On that earlier version, the sentence was The hierarchy of waste management places waste reduction at the top, followed by re-use, recycling and energy recovery. The elimination of the Waste Hierarchy concept lacks rigour guided by scientific expertise. This is the concept that leads the overall waste management policy in the European Union, for example, and it s the fundamental reference in any waste management report globally. There is indeed widespread consensus and support for considering waste reduction, reuse and recycling at the top of the Waste Hierarchy, including support from earlier IPCC publications in regard to their climate mitigation potential. 3 The Waste Hierarchy is a concept that evolves over time according to updated research, and the latest and most accurate version of the Waste Hierarchy is the one provided by the World Bank in its latest report on waste. 4 This report explains that (Fig.14, page 27) even if Recovery is the next best option to Recycling, it only includes technologies of Anaerobic Digestion and Composting for organic waste treatment. It excludes energy recovery by substituting waste for fossil fuels, which typically happens with waste incineration technology or using the industry term, waste-to-energy. After Recovery, the following options fall under the domain of Waste Disposal. Within this category, the best option is Landfill, which is coherent with increasing evidence in Europe that landfilling of pre-treated and stabilised MSW is better than most incineration options with or without heat recovery. 5 According to DEFRA, MBT (mechanical biological treatment)-landfill provides the best emissions performance in terms of the treatment/disposal of residual waste. 6 Also in the United States there is evidence that with proper waste management MRBT (mechanical and 3 IPCC, 2006 IPCC Guidelines for National Greenhouse Gas Inventories. Waste Generation, Composition, and Management Data, Ch. 2, World Bank. What a waste. A Global Review of Solid Waste Management Balinger, Climate Change Impacts of Residual Waste Treatment. Eunomia Research and Consulting. Accessible here: 6 Department of Enviornment, Food and Rural Affairs, Economics of Waste and Waste Policy. June 2011

3 biological recovery plant) with biological stabilisation works better than waste incineration not only from an economic but also from a climate perspective. 7 In conclusion, the Waste Hierarchy is a key concept to guide the preferred environmental options for solid waste management and it s critical that the IPCC WGIII Report refers to the correct one below: The Waste Hierarchy according to the report What a waste. A Global Review of Solid Waste Management. World Bank, As the share of recycled or re-used materials is still low (e.g., globally, around 20% of municipal solid waste is recycled) Recycling percentages around the world have much room for improvement, indeed. However, empirical data and case studies show cities and regions that have reached recycling rates levels above 80% (see references below), so the previous statement cannot be assumed to be generally true without further geographical specification. Waste management is a dimension of public policy generally dealt with at the local level, and there is a really high variation in recycling and re-use levels. For example, whereas the region of Contarina, which gathers 49 villages in Italy, has achieved recycling rate of 83% and shows one of the lowest rates for waste generation in the whole EU, 8 the recycling percentage in Italy is only 38%, even below the EU average. In this sense, taking a global percentage as a guide is extremely 7 Morris J., Lombardi E., Favoino E., Bailey K, What to do with the "leftovers of zero waste. Accessible here: df 8 Zero Waste Europe, European Champions Priula and Treviso join the Zero Waste Europe Network. July Accessible at:

4 inappropriate and misleading and it should not be used to justify any subsequent recommendation. Most importantly, the fact that the 3-R levels are still low in many places cannot be taken as a valid reason to suggest that recycling and re-use (and obviously waste reduction in the first place) should not prevail as the preferred options for climate change mitigation strategies in the waste sector. The IPCC should instead advocate for investment in improved waste diversion and reduction. Case studies about materials efficiency policies in Taiwan, Flanders, San Francisco, and Guipuzkoa (Spain) among others, show how some cities have achieved a successful change of consumer attitude towards producing less waste and increasing recycling rates. Aggressive standards and incentives for both individuals and businesses in the Flanders region of Belgium, for example, have achieved 73% diversion of residential waste from landfill, the highest regional rate in Europe. Likewise, through incentives and extensive public outreach, San Francisco has achieved an 80% of separate collection rate in 2013 the highest diversion rate in the United States and is on track to reach 90% by Peer-reviewed research has suggested a zero waste index looking at the amount of virgin materials, energy, water and greenhouse gas emissions substituted by the resources that are recovered from waste streams. 10 Applied to three high consuming cities such as Adelaide, San Francisco and Stockholm, it ranks San Francisco as the best one in which 51% of resources were recovered and potentially saved virgin materials, compared to 23% in Adelaide and 17% in Stockholm, the latter with high reliance on waste-to-energy plants. As previously mentioned, Italy is undoubtedly showing the best pioneering results with their Zero Waste approach. Not only there are towns such as Capannori, which has reduced its waste generation rate by 39% and increased their source separation rate above 90% since declared its Zero Waste commitment, 11 but it also counts with the large region of Contarina that shows excellent result in recycling waste prevention 12, and a large network of more than 200 municipalities committed to Zero Waste. Moreover, there should be an explicit reference to the experience of decoupling material consumption and material efficiency from economic growth in Taiwan, where this has been specially successful: waste generation dropped from 8.7 to 7.95 million tons between 2000 and 2010, despite a 47% increase in GDP in the same period. Amongst the key factors that made that possible, the IPCC should note: (a) higher awareness and motivation on the part of individuals and community groups to 9 GAIA Global Alliance for Incinerator Alternatives, On the road to zero waste. Successes and Lessons from Around the World, Zaman, A. U., & Lehmann, S. (2013). The zero waste index: a performance measurement tool for waste management systems in a zero waste city. Journal of Cleaner Production, 50, doi: /j.jclepro , p Van Vlieet, Aimee, The Story of Capannori. A Zero Waste champion. Global Alliance for Incinerator Alternatives/Zero Waste Europe. September, Zero Waste Europe, European Champions Priula and Treviso join the Zero Waste Europe Network. July Accessible at:

5 work towards waste prevention and recycling; (b) successful waste prevention policies, including: 1. Minimizing Packaging and Disposables: TEPA s approach to waste prevention put a strong emphasis on Extended Producer Responsibility (EPR) making producers responsible for changes in design and production to reduce the waste generated by their products and packaging, by: a. Restricting the weight of boxes. b. Banning disposable tableware at schools and government agencies. c. Reducing plastic bags and plastic packaging. d. Encouraging a reduction in disposable chop-sticks. e. Reducing disposable cups. 2. Maximizing Recycling: TEPA created the Resource Recycling Management Fund. Manufacturers and importers of mandatory recycling items report them, label them, and pay a fee to the Resource Recycling Management Fund, which covers collection and recycling costs and provide subsidies to companies and governments to develop reuse and recycling systems. a. Mandatory beverage container take-back. b. Mandatory e-waste take-back. In 2010, the government passed legislation that requires retailers selling electronics and electric products to take back and recycle these products. 3. Separation at Source: in 2005, Taiwan adopted a two-phase program under the Waste Disposal Act, which required people to separate waste into recyclables, food waste, and residual waste. 4. Food Waste Recovery: By 2009, 319 townships had food waste recycling systems. The total volume of food waste collected per day rose from 80 tons in 2001 to 1,977 tons in Approximately 75% of the recovered food waste is sold to pig farms for about NT $400 (US $13.70) per ton. Furthermore, the European Commission is currently considering raising the statutory recycling target for Member States to in excess of 60% by the start of the next decade rising to as much as 75% by A similar signal from IPCC is crucial to raise the share of recycled or re-used materials, which have much grater climate change mitigation potential than waste-to-energy or co-processing. There is no reasonable explanation why the reference to the waste sector included in the IPCC WG III Report should not make mention of these experiences as successful strategies to increase rates of upstream solutions in the Waste Hierarchy and corroborate previous statements made by the same IPCC acknowledging the fact that the climate benefits of waste avoidance and recycling far outweigh the benefits from any waste treatment technology Let s Recycle, EU to unveil higher recycling target within weeks. Accessed 11 April IPCC, 2006 IPCC Guidelines for National Greenhouse Gas Inventories. Waste Generation, Composition, and Management Data, Ch. 2, 2006.

6 3. waste treatment technologies and recovering energy to reduce demand for fossil fuels can also be significant and result in direct emission reductions from waste disposal. As mentioned earlier with regard to our first point, energy recovery from waste can be considered as a positive climate mitigation strategy as long as it strictly refers to the treatment of organic waste in anaerobic digestion technology or in composting plants. Unfortunately, the IPCC WGIII Report Summary for Policy Makers does not establish this distinction and it refers to energy recovery from waste aimed at reducing fossil fuels (ie, substituting fossil fuels, presumably in combustion plants). It further argues that this strategy emits less than waste disposal, which is a strange contradiction since burning waste as a fuel in combustion plants can only be understood as a form of waste disposal. Using waste as a fuel to reduce the demand for fossil fuels is not a sustainable climate mitigation strategy, for the following reasons: Using waste as fuel emits more GHG emissions than coal per unit of electricity produced. Using waste as a replacement for fossil fuels in combustion or incineration processes actually increases GHG emissions, as producing energy with waste in incinerators plants is more energy intensive than producing energy in coal plants. 15 Recent research has pointed that Municipal Solid Waste is a particularly carbon intensive fuel due to GHGs avoidable when readily recyclable materials in MSW are used in manufacturing new products rather than used to generate electricity. 16 In this sense, the consideration of using waste as fuel is contradictory with one of the most important conclusion of the same IPCC WG III report: emission reductions require the decarbonisation of the electricity supply. In this sense, burning waste cannot be considered a low-carbon source of energy. Using waste as fuel depletes non-renewable resources (including fossil fuels). One of the main reasons why waste cannot be considered a low-carbon source of energy is its very own composition, mostly consisting of biogenic carbon (which can be recycled in the case of paper or treated in anaerobic digestion or composting in the case of food and agricultural waste) or fossil carbon (in the case of plastics). In any case, most of the materials in municipal solid waste are non-renewable or limited resources, a variety of products made of fossil fuels that should be saved, reused and recycled instead of disposed in highly contaminating installations. As mentioned earlier and according to previous statements by the IPCC, 17 there is general global consensus that the climate benefits of waste avoidance and recycling far outweigh the benefits from any waste treatment technology, even where energy is recovered during the process. Additional energy (and associated emissions) are saved in the manufacturing process itself, as recycled materials generally require less energy to be turned back into 15 Hogg, D,. 2006, "A changing Climate for Energy from waste?". Eunomia Consulting. 16 Morris, J Bury or Burn North America MSW? LCAs Provide Answers for Climate Impacts & Carbon Neutral Power Potential. Environmental Science & Technology, 44, IPCC, 2006 IPCC Guidelines for National Greenhouse Gas Inventories. Waste Generation, Composition, and Management Data, Ch. 2, 2006.

7 products. 18 In this way, recycling can save three to five times as much energy as incineration captures by burning. 19 Specific comparison analysis on the energy conservation potential in various treatments options has been carried out and concludes that for 24 out of 25 solid waste materials, recycling saves more energy than is generated by incinerating mixed solid waste in a combustion facility. 20 This is particularly notable in products such as aluminium, where the direct energy required to recycle it is 88% less than that required to produce primary aluminium. 21 Likewise, it should be noted that for every kg of plastic recycled, around kg CO2-eq is saved, 22 whereas if it is burned around 1kg of CO2- eq is released into the atmosphere. Phasing out waste incineration especially incineration of recyclable materials has recently been included as one of the goals for the Resource Efficiency Roadmap by the European Commission, which hopes to achieve zero waste incineration of recyclable products by Such a move, indeed, would provide co-benefits as in the reduction of air pollution and in energy conservation. With this in mind, the promotion of substituting municipal solid waste for fossil fuels jeopardises policies pursuing materials efficiency and ultimately increases GHG emissions. Using waste as fuel generates hazardous waste and highly toxic emissions. Toxic emissions resulting from waste incineration pollute the air and have been reported in peer-reviewed research regarding their carcinogenic potential They are also disproportionately sited in marginalized communities and thus creating a situation of environmental injustice. In many of these places, communities face cumulative impacts from added sources of pollution. 27 Air pollution resulting from activities such as waste incineration in combustion plants, amongst others, has recently been described as the world's single biggest environmental health risk, linked to around 7 million or nearly one in eight deaths in 2012, by the World Health Organization. 18 IPCC, 2006 IPCC Guidelines for National Greenhouse Gas Inventories. Waste Generation, Composition, and Management Data, Ch. 2, Morris, J. Comparative LCAs for Curbside Recycling, Versus Either Landfilling or Incineration With Energy Recovery. International Journal of Life Cycle Assessment, Morris, J., Recycling versus incineration: an energy conservation analysis. Waste Management, 3894(95). 21 M. Schlesinger, Aluminum Recycling, CRC Press, UNEP, Waste and climate change. Global trends and strategy framework. 23 García-Pérez, J. et al., Cancer mortality in towns in the vicinity of incinerators and installations for the recovery or disposal of hazardous waste. Environment international, 51, pp García-Pérez, J. et al., Mortality due to lung, laryngeal and bladder cancer in towns lying in the vicinity of combustion installations. The Science of the total environment, 407(8), pp Medicine, B.S. for E., The Health Effects of Waste Incinerators 4th Report of the British Society for Ecological Medicine., (section 8), pp Cheng, H. & Hu, Y., Curbing dioxin emissions from municipal solid waste incineration in China : Re-thinking about management policies and practices. Environmental Pollution, 158(9), pp Environment Agency, Addressing environmental inequalities: cumulative environmental impacts. May 2004.

8 Using waste as fuel creates a market incentive to burn recyclable materials, which have the greatest calorific value. Moreover, applying long-term contracts for the supply of MSW (either untreated or in the form of Refuse-Derived Fuel/Solid Recovered Fuel) to be used as a fuel in incinerators, cement kilns or biomass plants creates a lock-in situation in the flow of materials, effectively undermining initiatives to pursue 3R and zero waste policies. 28 In the case of incinerators, a recent study proves how this lock-in effect in places such as Denmark, Sweden, Germany or Holland has created a situation of incineration overcapacity more capacity to burn than waste is or will be available with at least 80% of MSW being recyclable. 29 In those countries, waste incineration is threatening recycling and encouraging the shipment of waste that otherwise could be treated locally with less environmental cost. 30 This concern has also been reported in Greater Manchester, United Kingdom, at the time of a thorough revision of the waste management system to foster materials efficiency strategies. 31 In fact, waste incineration technology has been identified as an obstacle for upstream waste management options all over the world. 32 In brief, waste incineration requires large sums of money for large infrastructures with few returns in the labour market and contributes to a lock-in situation that undermines the waste management options at the top of the Waste Hierarchy. Finally, it should be mentioned that the use of waste as fuel competes with and displaces the jobs in the recycling sector. In many cities in the Global South, the informal recycling sector makes a significant, but typically ignored, contribution to resource recovery and GHG savings. 33 The informal recycling sector typically represents a work force of about 1% of the urban population in the Global South that relies on access to waste to do their job. While grassroots recyclers often face challenges of poverty, exploitation by those to whom they sell recyclables, they are increasingly organizing into cooperatives or unions that strengthen their negotiating capacity within the public and private sectors, and in some countries gaining official recognition and inclusion in national waste legislation and planning. 34 Essentially, the IPCC s recommendation for the use of waste as alternative to fossil fuels as a climate mitigation strategy is highly controversial and ultimately misleading. In fact, the promotion of waste as replacement for fossil fuels is being pushed by the cement industry, amongst others, as one of its fundamental climate mitigation 28 Tan, A.L., Liss, G. and Leonard, M. Burning Recycling. Resource Recycling Journal; May 2013, Vol. 32 Issue 5, p Altair, 2013, Characterisation of households residual fraction in Gipuzkoa, Spain. 30 Jofra M., Ventosa I., Incineration overcapacity and waste shipping in Europe: the end of the proximity principle?, Uyarra, E. & Gee, S., Transforming urban waste into sustainable material and energy usage: the case of Greater Manchester (UK). Journal of Cleaner Production, pp Global Alliance for Incinerator Alternatives, Waste Incinerators: Bad News for Recycling and Waste Reduction. October, UNEP, Waste and climate change. Global trends and strategy framework. 34 Global Alliance of Waste Pickers:

9 strategies, 35 and the consequences are already having a serious impact on the environment, economy and wellbeing of local communities around the world. Some notable examples are found in Spain, where incineration of waste in cement kilns has mostly served the economic interests from the cement companies, which are currently under much pressure due to the crisis faced in the construction sector. 36 Ironically, the use of waste as fuel in cement plants is being considered by a Court of Justice in Italy to be the reason behind low quality cement that has caused the collapse of buildings in Italy, including a primary school, in recent years. 37 The cement industry has clearly stated that [t]o increase use of alternative fuels, access to waste and biomass must also increase. 38 However, incineration of waste in cement kilns is still at the bottom of the Waste Hierarchy, even if it replaces fossil fuels. Interestingly enough, waste disposed in cement plants includes a high percentage of fossil materials, as for example used tires or other household waste plastics. In conclusion, it undermines waste prevention, reuse and recycling efforts and will put more pressure on biomass production. Other notable examples have been found in Mexico, where the incineration of waste from the Mexico City in cement kilns in the neighbouring state of Hidalgo has stopped after it was found to be in violation of local and national law. Since the incineration of waste started in March 2012, the local community organised and filed formal complaints to the local authorities and the Clean Development Mechanism for their support to the project. 39 A recently launched Atlas of Environmental Conflicts elaborated by the Universitat Autònoma de Barcelona with EU Research funds, has identified a number of conflicts involving waste incineration in cement kilns, biomass power plants and conventional incinerators, with such conflicts to be found in almost every region in the world. 40 In conclusion, the IPCC report should acknowledge that even if materials recovery levels may be still low, strategies aiming at reducing, reusing, and recycling municipal waste remain the most effective and high-impact means of reducing greenhouse gas (GHG) emissions in the waste sector, with advantages that carry into other sectors as well. 41 However, although waste prevention is found at the top of the Waste Hierarchy, it generally receives the lowest allocation of resources and effort. 42 The IPCC s promotion of waste as fuel will only worsen this situation. 35 See for example: Cement Technology Roadmap Carbon Emission Reduction up to Cement Sustainability Initiative. World Business Council for Sustainable Development. 36 For further information about waste incineration in cement kilns in Spain see: Puig, I., Jofra, M. Calaf, M., La puerta de atrás de la incineración de residuos. 37 Treviso, Abitazioni costruite con la cenere anzichè con il calcestruzzo. 12 April Accessed 13 April 2014: 38 Cembureau. (2013). The role of cement in the 2050 low carbon economy. 39 Vargas, J.T. and Vilella, M. From Bordo Poniente to CEMEX: the CDM s support for waste incineration in cement factories. Global Alliance for Incinerator Alternatives GAIA, Environmental Justice Atlas. Environmental Conflicts about landfills, toxic waste treatment, uncontrolled dump. Accessed on 2 nd April 2014: 41 US EPA, Solid Waste Management And Greenhouse Gases: A Life-Cycle Assessment Of Emissions And Sinks, 3rd Edition UNEP, Waste and climate change. Global trends and strategy framework.

10 Using waste as fuel should not be emphasized as a climate mitigation strategy as this will pose an incentive to increase incineration of waste rather than to promote materials efficiency, which is de facto a much better mitigation strategy. The IPCC s promotion of using waste as fuel can only exacerbate this misleading tendency and therefore the IPCC is urged to amend this troubling and inaccurate recommendation. GAIA remains committed to the very valuable work of the IPCC and the challenges posed by climate change to our society. We look forward to your response and will remain available for any further clarification. Thank you very much for your consideration. Sincerely, Global Alliance for Incinerator Alternatives With the support of: United Kingdom without Incineration Network Earthlife Africa Cape Town Institute for Zero Waste in Africa Alliance for a Clean Environment Zero Waste Western Australia Zero Waste Europe The National Toxics Network from Australia Eco Sitio Argentina Lic. Francisco C. Amaya - Espacio Intercuencas RRR Jeffrey Morris, Ph.D. - Economics Fronteras Comunes Mexico Red Nacional de Acción Ecologista - Argentina Indian Ocean Islands Network (DION) Confederación de Ecologistas en Acción - España Taller Ecologista - Argentina Econexus United Kingdom Red de Coordinación en Biodiversidad - Costa Rica Pesticide Action Network, Mauritius Jóvenes Ambientalistas - Nicaragua Frente de comunidades en contra de la incineración Mexico Taller de Comunicación Ambiental - Argentina