Scottish waste could be sent to England post landfill ban, finds new report

A new report from the Scottish Government has found that Scotland faces a 1 million tonne residual waste capacity gap, meaning that this waste may be sent to England.

A new report from the Scottish Government has found that Scotland faces a 1 million tonne residual waste capacity gap, meaning that this waste may be sent to England, upon the introduction of the landfill ban.  

From 1 January 2021, landfill operators in Scotland will be banned from accepting biodegradable municipal waste (BMW) for disposal in landfill.


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The Scottish Government commissioned Eunomia Research & Consulting to report on the current and future markets for the disposal and recovering of BMW. The aims of the work were: 

  • To consider the availability and costs of disposing Scottish BMW in other UK landfills or recovering energy in Energy from Waste (EfW) plants 
  • To consider the opportunities and costs of recovering Scottish BWM by exporting the material as refuse derived fuel to continental or Irish EfW. 

Despite the significant notice that has been provided on the ban, the alternative waste management options that will be needed may not be available at sufficient scale or at a good price at the point when the ban begins.  

Based on 2017 figures, 14 local authorities, accounting for 55.5% of residual household waste (744k tonnes), have already made the financial investment to ensure solutions are in place prior to the ban.  

However, three authorities (7.6% of household waste – 99k tonnes), have long term solutions in place post 2021, but no firm temporary solution, while six authorities (13.3% of household waste – 177k tonnes) have an interim, but no long-term solution secured.  

Nine authorities (23.6% of household waste – 315k tonnes) have no alternative arrangements. 

Commercial waste operators do not seem to have made adequate preparations for the ban, and where strategies are in development, they are mostly focussed on transporting waste, either to landfill or treatment facilities in Northern England or into thermal treatment capacity abroad, said Eunomia. 

The Scottish Environmental Services Association (SESA) has said that despite industry investment in around 950,000 tonnes of additional treatment capacity to help meet the 2021 ban, a poor residual waste policy framework linked to an uncoordinated approach to public procurement has proved the greatest hurdle to securing the additional investment needed to close the capacity gap even more.  

Eunomia’s national level capacity modelling found that there will be insufficient residual waste treatment capacity in Scotland available to deal with waste created once the ban is put in place. The extent of this gap will depend on the level of recycling achieved.  

From this, two options were examined to deal with any capacity gap that may occur: 

  • Option 1: Scotland could make use of spare capacity in residual waste treatment facilities in England or continental Europe, or landfills in Northern England. The treatment facilities have substantial capacity, but much of this is already in use, making it challenging for Scottish waste collectors to secure capacity without sustaining significant additional costs. Consented English landfill capacity is finite, and if such sites receive Scotland’s waste, the date when current landfill capacity in Northern England reaches capacity appears likely to move forward 2024/25 
  • Option 2: Scotland could construct its own additional treatment facilities, although it would not be feasible to bring on stream by 2021 sufficient capacity to bridge the capacity gap, meaning an interim solution would still be needed. 

The ban will mean that English landfill costs will replace Scottish landfill as the market cap post-2021, as long as the capacity remains available. The highest costs are likely to fall on a small number of authorities that have long-term solutions in place, but due to locations will have little option but to rely on exporting in the short-term. 

If Scotland builds additional thermal treatment capacity, this will result in a smaller increase in marginal cost per tonne than export options in the medium term, said Eunomia, although the option to export may become more favourable as the market stabilises.  

SESA policy advisor Stephen Freeland said: “To unlock investment in sufficient non-landfill capacity the industry needs more commitment from the Scottish Government than a fleeting reference to the landfill ban within regulation. This investment is reliant upon a strong and enabling waste policy framework for non-recyclable waste which has, up to now, been sadly lacking. We suggest that the Scottish Government provides details of a long term infrastructure and investment plan for Scotland to allow private and public-sector partners to adequately identify options for appropriate development.”  

“SESA members aim at all times to achieve cost effective regulatory compliance. Unfortunately, in this case, landfill in England is the only practical option available to the industry for dealing with the majority of the 1 million tonnes of waste that needs a new home in 2021.  This will be a £100m Landfill Tax gift to the English revenue.” 

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