Monksleigh's response to the UK ETS Authority request for views on the expansion of the UK Emissions Trading Scheme to energy from waste and waste incineration is posted in its entirety.

The latest published data on the amount of clinical waste incinerated has revealed a number of inconsistencies which could lead to potential ramifications for the measurement of this material for UK ETS, if it is to be included as proposed in the recent consultation.

Monksleigh's analysis of the reporting by EFW plants in Englandshow that there is no consistency in the approach to the way biogenic carbon emissions were measured by the 51 operational EFW plants in England.

Biomass by Energy Content, Biomass by CV, the 'Selective Dissolution Method (SDM)' are all differing terminologies for the same test, which seems to have become the default test to determine the level of biogenic material in residual waste...... but does it?

With Landfill Tax due to step up to £126.70 in April 2025 the gate fee trajectory of landfill and EFW going forwards looks ominous - and may lead to some unintended consequences of Landfill tax and UK ETS policy in the future.

Monksleigh's recent analysis of the 51 operational EFW plants in England shows that only 24% of EFW facilities rely on direct measurement of carbon emissions from their stack to estimate their overall emissions of biogenic carbon to the atmosphere.