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Analysis: Eunomia and Suez at odds over treatment capacity

Battle lines have been drawn over the UK’s future need for energy-from-waste plants, but how did two reports end up with such widely different figures for future treatment capacity?

The Eunomia consultancy’s latest Residual Waste Infrastructure Review claimed EfW business failures were “likely to increase” by 2030-31 because there will be too many treatment facilities to deal with too little waste.

Suez decided to release headline figures from its own infrastructure review weeks early in order to rebuff the findings. The company said the UK in fact faces a shortfall of capacity of 2.4 million tonnes by 2030.

On the one hand, we have a report claiming the UK EfW industry is heading for a major crash. On the other, waste management businesses themselves are pleading for billions of pounds of investment to build new incinerators, tout suite.

As we can see from the chart below, the reports differ on almost every point. They are also compiled in very different ways, use or exclude different variables and make different assumptions. To the outsider, it’s a bewildering situation.

Here, we present the figures side-by-side, along with justifications straight from the horses’ mouths.

Whose figures are you most persuaded by?


Current residual capacity gap

7 million tonnes

13.8 million tonnes

2030-31* capacity

Scenario 1: an excess of 5.9 million tonnes if RDF exports cease.

Scenario 2: a broad balance between waste arisings and treatment capacity

A deficit of 2.4 million tonnes

Current residual waste arising

27.5 million tonnes

32.3 million tonnes

2030-31 residual waste arising

Scenario 1: 15,775,474 

Scenario 2: 21,833,868

30.3 million tonnes

Current treatment capacity

18.3 million tonnes per annum. (13.5 operational)

(excludes RDF for export)

18.6 million tonnes per annum.

(Includes RDF for export)

2030-31 treatment capacity

21.4 million tonnes per annum. (15.8 operational)

(excludes RDF for export)

28 million tonnes per annum.

(Includes RDF for export)

Exports of RDF

3.5 million tonnes

3 million tonnes

Recycling rate by 2030

Scenario 1, England and Northern Ireland, 65% household recycling rate, 75% commercial and 80% industrial 

Scotland and Wales, 70% rate by 2025. 

Scenario 2, England’s recycling rate by 2030 is kept at 50%

55% municipal

*For Suez, predictions are for 2030. Eunomia uses the financial year 2030-31.


Peter Jones, senior consultant for Eunomia:

Our numbers exclude ‘other’ waste, which is material suitable for low cost management routes (e.g. land-spreading), with which incineration can’t compete; and material that requires specialist treatment, and is therefore unsuitable for residual waste treatment.

There is an interesting difference is between our and Suez’s 2016/17 figures. Ours broadly squares with the following data: around 11.0 million tonnes material landfilled across the UK at standard rate Landfill Tax; around 12.0 million tonnes capacity of operational incinerators (10mt) and MBT (2mt) (there is also capacity from cement kilns and IED compliant biomass plant, which may not currently be used for waste); around  3.5 million tonnes RDF exports.

It may be that Suez are basing their estimates on non-inert household/industrial/commercial (HIC) landfill inputs reported by the EA and other regulators. These are figures recorded more or less ‘at the gate’, so don’t necessarily take account of any material that is pulled out on site for recycling or other diversion (e.g. metals, rubble).

The HIC figure is around 6 million tonnes higher than the Landfill Tax figure, and our view is that the latter is a more accurate estimate of the amount of residual waste available and suitable for treatment. Dominic has blogged about how peculiar it is that we have two such different figures for landfill tonnage, and little apparent interest from Defra in explaining the variation.

Clearly, where we will be in 2030 is a rather more speculative issue, and of course it is intimately tied to the question of what the recycling rate will be. Our assumptions for our two scenarios are set out in the report.

We would say that Suez’s assumption that we will only be at 55% overall seems rather unambitious – and assumes that the UK will not be bound by the EU’s circular economy package targets. Wales and Scotland are both aiming for 70% by 2025, and the mayor of London’s draft environment strategy proposes a 65% recycling rate for municipal waste by 2030. So, where there is clear policy, it is, we are glad to say, pointing towards much higher recycling rates than Suez (or our Scenario 2) assumes.

Both we and Suez agree that a clear policy direction would be an enormous help in ensuring that the waste industry builds the collection systems and treatment infrastructure that are really required – as would better data on commercial and industrial waste arisings and treatment.

Suez spokesperson:

We are targeting materials that would or could normally be treated in facilities that treat municipal waste, however unlike Eunomia (and others) we try to include all likely wastes that meet this criteria today and tomorrow, such as inactive waste to landfill that would normally be excluded but where we and HMRC think is incorrectly classified and should be active waste

We include the following:

  • waste passing through exempt sites where no data is collected by Suez or others but where there is general agreement that this is probably 2 million tonnes per annum (some of which will be recycled and some to residual treatment).
  • an allowance for materials that are classified as recycled (they are sent and classified as recycled - not rejected at the gate) but where the materials are not actually recycled (process waste or unsuitable materials that varies between 10% and 30% for sorting MRFs and Plastic Recovery Facilities and which then return for residual waste treatment) also composting and anaerobic digestion streams where materials are rejected at the first process stage.
  • add back in the refuse-derived fuel (RDF) outputs from mechanical biological treatment plants - there is a fair amount from that.
  • some fines from the production of RDF and solid recovered fuel which should be treated as active residual waste but is treated illegally or inaccurately described as inactive to landfill - as we reduce the volume of RDF in some of our models you need to add back these materials
  • an allowance from construction and demolition waste that matches municipal solid waste (1.6% of the total arising and then assume some goes to recycling and some to residual ) think of the waste from the worker bins for example and small construction sites.
  • an allowance for illegal waste (that appearing in farmers’ fields or other) or without treatment is sent to landfill as inactive, incorrectly.
  • an allowance for materials currently sent to land that in the future may not be allowed (this is relatively small).

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