Response to UK ETS Consultation—August 2024
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
In 2024 the Department of Energy Security and Net Zero (DESNEZ), along with the governments of the Devolved Administrations in Scotland, Wales and Northern Ireland issued a sector wide consultation on a number of proposals to expand the UK Emissions Trading Scheme (UK ETS) to include energy from waste and waste incineration.
The consultation requested views on:
The scope of the scheme, including which activities are covered, thresholds for inclusion and exemptions
Participating in the scheme, including requirements for operators, monitoring, reporting and verification, and guidance
Impacts of the scheme and risks, including diversion of waste to landfill and waste export, decarbonisation pathways for customers, cost pass through to customers and equality considerations
How to adjust the UK ETS cap for waste
How the UK ETS could potentially incentivise investment in heat networks
Our response to this consultation is available to view in full below including our opinion that whilst the principle of taxation to reduce emissions from incinerators is supported, the requirements outlined within the consultation are becoming increasingly complex; waste is incredibly heterogeneous and varies between its source (business, household, level of deprivation, rural v urban settings, seasonality – summer, Christmas etc). Furthermore, there is limited scope for an operator of an incinerator to ‘change or alter’ their feedstock to reduce emissions, this remains the responsibility of the supplier (and even for those operating further down the supply chain this will be difficult).
Our main concern surrounds the system (or current lack of it) of passing the cost of fossil carbon in waste down through to the suppliers of the waste and that the system will not necessarily reduce waste arisings tonnage. We fear that creating an ever-more complex system for measurement and compliance will not deliver the overarching carbon emission reduction objective in the manner that the government suggests nor will it be uniform across the sector (see our previous article on Lab Dissolution Testing on Waste – Does it Work).
Our opinion is that guidance should be developed centrally that is consistent, unambiguous and simple to limit confusion and potential disputes between all parties – and that might actually be the biggest challenge of it all.
About Us
Monksleigh provide flexible and tailored consultancy services designed to support your waste management needs. Our services help organisations optimise operations, compliance, and manage emissions through strategic support and tailored solutions designed to achieve your own sustainability goals.
We provide a range of resources on our website and in WikiWaste, an online encyclopedia created and supported by Monksleigh focused on the UK waste and resources industry as well as a range of bespoke and tailored paid-for services and products for Investors, Developers, Waste Companies, Local Authorities and Businesses producing waste.
