We Strongly Oppose The Proposed Remondis WtE Waste Incinerator At Swanbank, Ipswich

Here's Why:

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WASTE TO ENERGY (WtE) MIXED WASTE INCINERATION

– BAD FOR IPSWICH - BAD FOR QUEENSLAND

Waste companies, both Australian and international, regard Australia as a greenfield opportunity for the development of WtE incineration at a time when this method of dealing with waste is meeting concerted opposition in the northern hemisphere, both at governmental and community levels.
Australians have so far been fortunate to have avoided WtE incineration. Yet all the Queensland Government’s messaging indicates its determination to impose WtE incineration on the people, starting with Ipswich.

 

The State Government EfW discussion paper states:
"This discussion paper identifies a proposed role for EfW in Queensland and how it could support implementation of the waste strategy."

"The Queensland Government recognises that producing high-value fuels from waste materials could contribute to the biofutures vision by creating greater employment and economic opportunities, compared to the alternative of disposal in landfills. A clear EfW policy position will recognise the benefits of producing fuels from waste over other forms of energy."

Environmental and human health should never be subordinate to jobs and economic considerations,even if one subscribed to the idea that WtE plants are better for employment or the economy than landfills, which is doubtful.

"The discussion paper outlines a set of proposed principles to help guide EfW developments in a way that ensures human health and the environment are protected, and maintains the integrity of reuse and recycling activities."

". . . clear guidelines for proponents to follow, will help to ensure that EfW projects meet technical, environmental, regulatory and community expectations and are in the best interest of Queenslanders"

High aims indeed but sure to fail when reality does not meet expectation, as has happened with WtE incineration elsewhere in the world. WtE incineration will not negate the need for landfills, the toxicity of which will increase, and will only add another polluter to the landscape.

WtE mixed waste incineration pollutes
WtE incineration does not "reduce the impact of waste on the environment and communities", it simply replaces one set of impacts with another. WtE incineration runs counter the idea of a "zero net emissions" future. According to the Queensland Government’s discussion paper on EfW policy, the waste management sector was found to have contributed <2% of the State's emissions in 2016. That will not be the case in the future if there is a proliferation of waste incinerators.

Writing in the journal Environmental Health Western Australia (Vol 25, No. 1, 2019) Emeritus Professor Odwyn Jones AO and Clinical Professor Bill Musk AM made the following points about air pollution: . . . it is important to point out, that “it’s safe to say there is no safe level of air pollution” and
consequently it is dangerous and false to define health hazards based on threshold values (Barnett A.G, 2014). Unfortunately thresholds give the impression that levels below the quoted threshold levels are safe but, as far back as 2005 the WHO air quality guidelines state “there is
little evidence to suggest a threshold below which no adverse health effects would be anticipated . . . Globally, it is claimed that air pollution currently causes more deaths annually than tobacco and new studies identify increasing range of hazards of exposure to toxic air
such as huge reduction in intelligence and evidence of pollution particulates in mothers’ placentas.

A 2018 UK study led by Professor Frank Kelly, King’s College, London, (Carey, I.M. et al, 2018) suggested that “each extra microgram per cubic metre of PM2.5 (particles less than 2.5 microns in size) increased dementia risk by 7%”.

A 2018 study by researchers from Beijing University, Yale School of Public Health and Peking University, (Zhang X. et al, 2018) indicated that people living with air pollution are “not only suffering from increases in respiratory illnesses and other chronic conditions but are also losing their cognitive functions” and “increasing CO2 levels are degrading our ability to develop new ideas and formulate complex thoughts”.

In 2015 The New York Times reported that Baltimore’s Curtis Bay would be getting the largest WtE incinerator in the US which would be permitted to emit up to 240 pounds of mercury and 1,000 pounds of lead annually in a community containing 3 schools and which already suffered high rates of cancer and asthma. A 2013 MIT report had found that Curtis Bay ranked among the top postcodes in the US for release of toxic emissions and Baltimore had the highest emissions-related mortality rate of the 5,695 American cities in the study. (https://www.nytimes.com/2015/01/11/us/garbage-incineratorsmake-comeback-kindling-both-garbage-and-debate.html)

WtE incineration releases compounds such as dioxins and furans as well as metals such as mercury, lead and cadmium, acid gases, particulates (dust and grit) and carbon dioxide (CO2). Particulate pollution, particularly PM2.5, leads to decreased lung function, cardiac disease and death. Dioxins and furans are some of the most toxic man-made substances in existence and have an irreversible effect on humans and the environment. Dioxins (compounds containing chlorine) are classified by the World Health Organization as one of the most toxic chemicals on earth. They are highly carcinogenic, decompose slowly and enter the food chain by bio-accumulating in the adipose tissue of animals.

Dioxins may be destroyed by incineration if temperatures are high enough but can reform when emissions cool in the flue or on release to the atmosphere (Dr Bill Freeland, PhD environmental science, NT EPA, retired).

In January 2018, the Supreme Court of Indonesia ruled that use of thermal technology is against Indonesian law because it poses a threat to the environment and health by producing hazardous materials such as dioxins, furans, mercury, lead and cadmium. Despite this and the fact that Jakarta is one of the most polluted cities on Earth, the Indonesian government decided to press ahead with the installation of WtE incinerators in 6 cities and on Bali. And to facilitate this, the state-owned power company PT PLN agreed to sign 20-year purchase contracts to buy electricity generated by the plants at prices higher than other cleaner energy sources (Tempo.co, December 2018).

Mixed waste is an inhomogeneous feedstock producing variable levels of emissions when burnt. Unlike burning high-grade thermal coal, it is difficult to tune the boiler in a mixed waste incineration plant to remove emissions from burning mixed waste. There are spikes in dangerous emissions outputs due to the variability of the feedstock. It is a dirtier way of extracting energy than burning coal and instantly releases more CO2 to the atmosphere per megawatt-hour than coal-fired, naturalgas-fired or oil-fired power plants. Denmark recently discovered that its incinerators were releasing twice the amount of CO2 than originally estimated, causing it to miss its Kyoto Protocol greenhouse gas reduction targets. By comparison, a study by the United States EPA concluded that up to 42% of US greenhouse gas emissions could be mitigated through the implementation of zero waste strategies (Zero Waste Europe, February 2018).

WtE claims to be the solution to landfill methane gas emissions.

Methane is a potent greenhouse gas which forms within 1-3 years after dumping, peak gas production occurs after 5-7 years, almost all gas is produced within 20 years, and small quantities of gas continue to be emitted for 50 or more years (US Environmental and Energy Institute, 2013). The Australian waste industry claims that burning 400,000 tonnes of waste in the tax-payer supported Kwinana WtE facility, will result in an
equivalent annual reduction in CO2, that is, 400,000 tonnes per annum (WMRR EfW Thermal Treatment Fact Sheet, July 2019). ARENA which spent $23 million of taxpayer money to support this project also made this claim. Yet no data or rationale to support this statement is provided.
Burning over 1,000 tonnes of waste daily at Kwinana will immediately release the CO2 in the waste into the atmosphere rather than the waste emitting greenhouse gases slowly over years and decades.

That immediacy increases its potency. Methane in landfills can be and is often captured and either flared or used to produce energy. A better solution to the methane problem is diversion of materials from landfill through recycling which is more greenhouse friendly than incineration which is a hungry technology demanding as much waste as possible.

When pollution is not released to the air, it’s captured and concentrated in toxic bottom ash, air pollution control residues (fly ash) and spent precipitator bags. Around 1 tonne of bottom ash is produced for every 4 tonnes of waste input, hence volume is reduced but toxicity is increased. Fly ash is considered a hazardous waste and must be encapsulated in concrete and/or contained in specially engineered landfills. According to the US EPA, almost all WtE ash produced in the US is landfilled. Of the 30 million tons of MSW processed in WtE facilities in the US annually, approximately 7 million tons of ash and non-combustible materials remain (Environmental Leader, October 2016). Sweden was exposed for dumping their toxic incinerator ash on an island off Oslo in Norway, where the pollutants pose a serious health threat to local communities and marine ecosystems.

Bottom ash has been used in road construction though its properties limit the proportion in which it can be used and its applications. Where it is used, specific additional processing is required to reduce its undesirable properties and the proportion of it in mixes has to be limited to achieve desirable durability and behaviour of road surfaces (Municipal incinerated bottom ash (MIBA) characteristics and potential for use in road pavements, Lynn, Ghataora & Dhir, March 2017). Unwashed bottom ash presents critical issues for uses as alternative aggregates in construction due to excessive release of pollutants. Where bottom ash had been used to make concrete, crushing significantly increased the release of pollutants including heavy metals (Leaching behaviour of municipal solid waste incineration bottom ash: From granular material to monolithic concrete, Sorlini, Collivignarelli & Abbà, July 2017).

Performance of incinerators in Europe, some examples

The Thermoselect gasification incinerator in Karlsruhe, Germany, was closed in 2004 and there are numerous examples of other plants that have been shut down due to technical and financial failures. Other projects have failed in the proposals stage despite significant investment as a result of
community opposition and closer government scrutiny of operator claims.

The Scotgen gasification incinerator for municipal solid waste in Dumfries, Scotland violated dioxin emissions limits repeatedly. For three years, the Scotland Environmental Protection Agency (SEPA) considered it Scotland’s worst polluter. SEPA finally closed the facility in 2013 and then revoked
the incinerator’s permits.

The Isle of Wight gasification incinerator in the UK, breached dioxin limits significantly in several tests and continued to have serious problems despite significant public funding support. These problems contributed to the local government changing course to implement more reliable and
affordable recycling efforts.

Regular compliance breaches for dioxins and other pollutants were documented between June 2010 and 2012 at the Scilly Isles waste incinerator in the UK where dioxin emissions were found to be 65 times higher than the permitted limit.

In 2014, Air Products signed a contract with the UK Government for a waste gasification facility in Tees Valley. Two years later the company abandoned the technology due to design and operational challenges.

In November 2018, Reststoffen Energie Centrale (REC), the newest and most “state of the art “ incinerator in the Netherlands, was found to have been frequently emitting dioxin, furan and persistent organic pollutants (POPs) far in excess of EU limits over a protracted period. In June 2019,
the Netherlands Council of State stated that REC had incorrectly applied the provisions concerning the measurement of toxic emissions (Zero Waste Europe, June 2019). Testing had been unreliable and had seriously understated emissions levels.

In July 2019, the Danish Environmental Protection Agency released information that the Norfos incineration plant had violated dioxin emissions limits for 3 of the previous 5 years. Measurements revealed that the plant emits dioxins, furans, and toxic pollutants, far beyond the national and
European limits, impacting the surrounding environment. (Zero Waste, July 2019)

The history of incineration offers a cautionary tale and although cleaner than the incinerators of the past, new WtE incineration plants still emit mercury, lead, dioxins and a variety of other toxic substances. That is why communities slated to host these facilities object to them so strongly.
In July 2018, the Eastern Creek WtE incinerator in Sydney was rejected by the NSW Independent Planning Commission as not being in the public interest The reasons included concerns about feedstock and the plant's ability to safely handle waste stream variations, uncertainty about how
dangerous regulated wastes would be excluded, insufficient evidence that the pollution control technologies to be used would be capable of managing emissions, uncertainty about temperatures being sufficient to destroy harmful emissions, concern about the relationship between air quality impacts and water quality impacts, the possibility of cutting corners (on energy usage) leading to adverse environmental outcomes, and concern about site suitability and human health impacts.

The REMONDIS WtE proposal for Swanbank will merely redirect pollution from landfill to toxic emissions and ash dumps.

Far from solving the waste issue, the proposed REMONDIS waste-levy supported project risks encouraging the production of more waste to provide a continual fuel source. This will threaten the health of Queensland’s natural resources and ecosystems and put Queensland communities in harm's way (Queensland Conservation Council, September 2018).

Quenching – will it work to prevent the release of toxic compounds to the air?
The waste industry cites "quenching" systems which will remove all WtE residues including dioxins. Quenching in the last stage of the incineration process is supposed to stop toxic compounds destroyed during combustion from reforming in the flue. As gases leave the furnace they pass the
pressure vessel containing the water which boils to make the steam which drives the turbines which produce the energy. However if the energy production part of the process takes too much energy from the flue gases, toxic compounds could begin to reform prior to quenching and expulsion to the atmosphere.

Quenching needs to be done while the gases are above ~1,000 degrees Celsius whereas furnace gases may not rise above 600 degrees Celsius. Gas temperatures after driving turbines may not be suitable for quenching and therefore there is no guarantee that dioxins and furans would be removed from gases exiting the flue.

WtE incineration produces little energy despite massive inputs and what it does produce is expensive
Much of the energy produced by WtE incineration is used to run the plant. The remainder is expensive and contributes very little energy to the market. The Queensland Government’s EfW discussion paper recognises this, stating: In areas where electricity generation has been specifically incentivised, thermal EfW plants make a very small contribution to national electricity supply and are not discussed within national electricity policies.

The Kwinana plant in WA is expected to produce approximately 36MW base-load power for export to the grid each year. If this benchmark is attained, it will represent about one tenth of the electricity produced by a single turbine in a coal-fired power station.

WtE incineration is more about waste disposal than energy.

Efficiencies for energy recovery are in the  order of 72% for heat conversion, 68% for combined heat and power (CHP) and less than 25% for
electricity generation. Eurostat data for 2013 showed that total energy recovery from WtE represented just 1.5% of energy consumption of the 28 member states of the EU (Ricardo Energy Environment, March 2017).

Production of energy through WtE incineration compares even less favourably to other sources of generation when you consider the amount of energy required to extract raw materials and fabricate them into usable goods. Recycling and composting reportedly saves up to 5 times the amount of energy produced by burning waste while the amount of energy wasted in the US by not recycling aluminium and steel cans, paper, printed materials, glass and plastic, is estimated to equal the annual output of 15 medium-sized power plants (Zero Waste Europe, February 2018).

WtE incineration is not renewable and will not contribute to a zero net emissions future for Queensland
The EfW discussion paper states that EfW can contribute to a zero net emissions future in several ways including that:
The energy (fuels and power) generated from waste using some EfW technologies can reduce reliance on energy from fossil fuels and avoid the associated greenhouse gas emissions.

The argument that burning waste including that derived from petroleum will reduce greenhouse emissions and reliance on energy from fossil fuels is difficult to sustain. Nor do we agree with the characterisation of WtE incineration as renewable energy generation. Unlike wind, solar, wave or in
some circumstances, hydro generated energy, waste doesn’t come from infinite natural processes. It is sourced from finite resources – minerals, fossil fuels and forests that are cut down at an unsustainable rate. Plastic is a petroleum by-product. Burning it is the same as burning fossil fuel and produces similar emissions.

WtE incineration is not recycling and has been found to undermine recycling and reduction initiatives in other parts of the world. It will not support the Queensland Government’s aim of moving towards a zero-waste economy, quite the reverse.

The Queensland Government acknowledges in the EfW discussion paper that combustion and advanced thermal treatment technologies process a wide variety of materials including recyclables and therefore pose the greatest potential conflict with reuse and recycling, but still believes that
policy can be formulated to ensure that uptake of EfW does not impact on reuse and recycling activities. Experience in the northern hemisphere, shows that the opposite is true.

 

The EU set higher targets for organics management, recycling, waste reduction and waste diversion which resulted in incineration overcapacity in many European countries, meaning there are more incinerators than waste to be burned. This overcapacity produced a perverse incentive to create more waste while discouraging and removing incentives for genuine recycling and waste reduction. It also created strong competition for imported waste which is transported long distances to incinerators, adding to transport pollution. The fact that some countries are reliant on imported waste to ensure continued operation of large-scale WtE plants is acknowledged in the EfW discussion paper.

Incineration in Denmark has significantly reduced landfilling but it has also stunted the growth of recycling. According to Eurostat data, Denmark has the highest municipal waste generation rate per capita in the EU (781kg per annum), burns over 50% of its waste, and is still struggling to transition toward a zero waste economy (Zero Waste Europe, July 2019). Sweden boasts high recycling rates but Swedish waste statistics count toxic ash produced by incineration (much of which ends up in landfill) as industrial waste rather than municipal waste. This false accounting means that incinerator ash from burning municipal waste doesn’t get counted in municipal waste statistics.

 

Sweden incinerates up to 86 per cent of all plastics. Despite laws making producers responsible for recycling their products (Producer Responsibility), Sweden still struggles with plastics recycling. (ABC’s War on Waste, August 2018). However, the EU has issued a directive to member countries to move away from incineration and concentrate on reduction and recycling.

 

Sweden and Denmark are among a number of countries including Austria, Belgium, Finland, France, Germany and the Netherlands that will need to reduce the amount of waste burnt to below 35%, in order to meet new recycling targets.

In July 2017, the European Parliament released a report calling for a halt to subsidies for waste incineration. That year, the European Commission issued a communication on the role of waste to energy in the circular economy stating that “increasing waste prevention, reuse and recycling are key objectives both of the action plan and of the legislative package on waste”. The communication added that “mixed waste still accounts for a substantial share of the waste used in waste-to-energy processes, mainly incineration (52%)”. Existing legal requirements and the circular economy waste proposals are bound to change this situation. Rules on separate collection and more ambitious recycling rates covering wood, paper, plastic and biodegradable waste are expected to reduce the amount of waste potentially available for waste-to-energy processes such as incineration and coincineration (Zero Waste Europe, October 2017).

In 2018, a Chief Scientific Adviser of the UK’s Department for Environment, Food and Rural Affairs (Defra) warned that further investment in EfW would stunt the UK’s recycling rate. Professor Ian Boyd said that incineration would encourage the production of residual waste stating, “If you are investing many tens of millions, hundreds of millions, in urban waste incineration plants – and those plants are going to have a 30 to 40 year lifespan, you have to have the waste streams to keep them supplied. If there is one way of extinguishing the value in materials fast, it’s to stick it in an incinerator and burn it. Now, it may give energy out at the end of the day, but actually some of those materials, even if they are plastics, with a little bit of ingenuity, can be given more positive value.” (Resource, Sharing knowledge to promote waste as a resource, 8 May 2019).

In 2015, The New York Times reported that despite decades of incinerators, US recycling programs had stalled and the country was outputting record amounts of waste. A WtE incinerator in West Palm Beach, Florida combusts up to 4,000 tons of material per day and not just MSW but wood, tyres and floc from vehicle recycling which contains polyurethanes, vinyls and rubber which produce toxic gases when burnt. When it was commissioned, it was planned to accept waste from outside the county for at least 8 years when the county’s population was expected to catch up with the incinerator’s capacity. It would seem that incineration has made it easier and cheaper to produce more waste and incinerate it
instead of recycling and tackling waste reduction.

 

Some US municipalities have deemed recycling an expensive luxury, dispensing with it altogether and incinerating their waste while others such as
Seattle and San Francisco which mandates recycling and composting, divert 60-80% of their waste from landfill. Seattle also imposes fines on residents who fail to compost food waste.

At between $400million and $1billion dollars to build, WtE incinerators are a significant investment with a long asset life of between 20 and 30 years. They therefore require long-term municipal waste supply contracts to recoup the investment. Australian Paper and Suez recently received approval from the Victorian Government for a WtE incinerator in the Latrobe Valley. They stated, "There are still some significant hurdles for the project. The main one being that we need to develop a long-term supply of waste".

The Queensland Government states that it aims to reduce household waste by 25% and recycle 75% of all waste by 2050. Recycling includes composting and organic bio-digestion but not EfW. If 75% of waste is recycled, the remaining 25% of the waste stream will be processed using EfW which includes a variety of processes. That being the case, a fraction less than 25% will be sent to WtE incineration. Twenty-five percent is a percentage, not a volume. If the government achieves its reduction and recycling aims, one assumes the volume making up less than 25% of total waste will get progressively smaller. Putting aside environmental, health and social risks, a massive investment in WtE incineration will not stack up economically in the long-run.

So from a purely economic standpoint, the question would seem to be, does the Queensland Government want a sustainable recycling and re-manufacturing industry and a society which produces less waste, or does it want sustainable WtE incineration? Because far from being a
temporary fix, approval of WtE incineration in Queensland will ensure self-perpetuation of this technology through disincentive to produce less waste and diversion of waste from recycling and remanufacturing to incineration.

TWO HIGH PROFILE WtE INCINERATORS IN EUROPE
The Isséane WtE incinerator in Issy-les-Moulineaux, Paris
This plant is often used by the waste industry as an model exemplar. Commissioned in 2007 at an approximate cost of €540 million, the plant’s data sheet describes it as a 52MW energy producer with approximately half that output running the plant and the other half being exported to district energy networks. According to annual statistics reported by the operator (published by Zero Waste France), the plant is a consistent performer as regards heat (steam) sold to the heating network but the amount of electricity produced and the amount exported have been wildly variable. Between 2012 and 2017, annual power output ranged from 0–114MW. In 2015 the plant produced no electricity and had to purchase 48MW to keep running. In 2014 the plant purchased nearly 36MW while but sold only 9.5MW, meaning its net intake of power from the network that year was 26.5MW.

A large part of the plant including the receivals area is subterranean to limit odour emissions. The data sheet states that it inputs around 460,000 tonnes per year of municipal solid waste and produces 112,000 tonnes per year (tpa) of bottom ash, 6,300tpa of filter dust and 5,500tpa of flue gas treatment, so around ¼ of the waste that goes in comes out as toxic solid by-products. According to Zero Waste France, in 2017 this plant produced 80,000 tons of bottom ash which although highly loaded with pollutants, was subject to permissive legislation allowing it to be used for road-base while 12,000 tons of fly ash and and solid residual waste were sent to hazardous waste landfill (Zero Waste France, January 2019). The data sheet mentions methodologies to remove nitrous oxide but is silent on dioxins and furans. Atmospheric testing for 2017 showed that emissions concentrations were beneath regulatory limits. However as with all waste incineration plants, this plant still emits pollutants.

SYCTOM, the waste management consortium including Paris and 83 municipalities which built this plant states its recycling rate is 30%. In 2017, SYCTOM processed 2,313,363 tons of waste of which 1,881,817 tons (80%) was incinerated while 147,943 tons were landfilled. Zero Waste France states that the incineration bottom ash is counted as recyclable and that 42% of residual waste sent to the incinerator (up to 75% if organic waste is included), could be diverted through more efficient consumption and sorting. They say just 184,600 tons of waste or around 8% was actually recycled in 2017 (Zero Waste France, January 2019). https://www.zerowastefrance.org/en/isseane-incinerationplant/

The Amager Bakke incinerator in Copenhagen
The Amager Bakke plant boasts ski slopes, a climbing wall and a cafe, though why anyone would want to avail themselves of such facilities in this context is a subject for another discussion. The plant has been plagued with problems from its inception. The Danish publication Finans reported that Amager Bakke has been beset by multiple scandals since the 5 owner-municipalities gave the project the green light in 2012, including cost blowouts, political controversy, delays, a fatal explosion and the sacking of key executives associated with the project.

In 2010 a report by EA Energianalyse produced for Copenhagen City Council, warned against building a big, new expensive incinerator because recycling in Europe was growing while incineration was declining. EA Energianalyse recommended upgrading an existing plant in Amager. Germane to this advice was the fact that although Denmark burned 50% of all household waste (the highest percentage in Europe), it had set a target to recycle 50% of waste sent to incineration by 2018. At first the advice was heeded but according to the publication Finans, lobbying by a board member of the publicly-owned waste management company Amager Resource Centre (ARC), eventually secured a 4 billion kroner loan to help build the plant. Finans reported that the ARC board member sent a letter to the Ministry of Finance days before the vote on the development, seeking a public declaration that a new incineration plant would not compromise the government’s coming resource strategy.

 

The then finance minister also received a letter supporting the project from a company in his constituency in West Jutland, B&W Vølund, which happened to have won the contract to build the Amager Bakke incinerator. Several members of Copenhagen City Council, claim the finance minister pressured the Council to agree to the loan which was subsequently approved in September 2012. Denmark’s environment minister at that time, condemned ARC’s political lobbying stating, “The leadership has played politics instead of being civil servants who serve the public interest and decisions that are made in the City Hall and government. We now have a facility that – as expected – does not have enough trash and therefore has a massive deficit which Copenhagen taxpayers have to pay.” The original cost of the plant was equivalent to €500 million but technical issues causing commissioning delays increased the cost by 100 million kroner. Following commissioning in May 2017, the plant’s furnaces failed forcing the owner-councils to seek special permission to store tonnes of waste. By the end of June 2017, cost blowouts caused heads to roll at both ARC and B&W Vølund. (Finans, Denmark, August 2017). Technical issues continued. In September 2018, the plant shut down when it was discovered that compensators installed in the plant were too small. At that stage the roof project (ski slope) was still not complete (ING/, September 2018). The so-called “Copenhill” finally opened in 2019.

With an annual capacity said to be between 400,000 and 500,000 tons of waste, the plant’s capacity is far too high and it threatens to be economically unsustainable. If it runs under capacity and makes losses, it will be a financial burden for the municipalities that own it. Therefore in contradiction of both Danish and EU resource strategies, waste must be imported to make up the deficit.

The Danish newspaper The Murmur predicted in 2016 that the municipalities that own the plant would not produce sufficient waste to burn and that running the plant under capacity would potentially accumulate an operational deficit of 1.9 billion kroner by 2020 – a deficit for which taxpayers would be ultimately responsible. Therefore an estimated 20% of the plant’s capacity (90,000 to 115,000 tonnes) would have to be imported each year. The imported waste contains more plastic which releases higher levels of greenhouse gases such as CO2 when burnt, meaning the waste imports increase Denmark’s carbon footprint. Furthermore, importing waste will only work to prevent the plant being an economic burden as long as other countries produce enough excess waste for Denmark to import. (http://murmur.dk/copenhagens-dirty-white-elephant/). In this way, the efforts of     the EU to create an EU-wide circular economy, are subverted.

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A BETTER ALTERNATIVE - RECYCLING, PRODUCT STEWARDSHIP AND EXTENDED PRODUCER RESPONSIBILITY
WtE encourages over-consumption and wastefulness and is counterproductive to reducing waste by recycling and development of reusable, recyclable, compostable and just plain LESS packaging.

Governments in Australia need to have a conversation about strategies for reducing unnecessary and difficult to recycle packaging, product stewardship and extended producer responsibility (EPR). Manufacturers, supermarket chains, retailers and the hospitality industry all have a social obligation to assist in waste reduction. There is a proliferation of unnecessary single use plastic packaging, such as that around fruit and vegetables and too much packaging unnecessarily made of composite materials. Packaging manufacturers must look at reducing composite materials, clearer, easier to understand labelling to aid in waste separation and where possible make products and packaging out of compostabe materials. Queensland’s policy should align with the Commonwealth policy target of 70% of all packaging being compostable or recyclable by 2025. That’s compostable – not combustible.

It may be "easier" in the shorter-term to incinerate waste than develop products from recycled waste and markets for those products but this is short-sighted. Government bodies such as ARENA and the CEFC should be supporting true clean energy projects and the development of recycling and remanufacturing industries rather than WtE incineration.

The EU’s Action Plan for the Circular Economy has encouraged many European cities to lead the way. Capannori in Italy, the Slovenian capital Ljubljana and the Basque region of Spain (Gipuzkoa) are all internationally recognised models for the zero-waste movement. In Paris, the community organisation 3Rs and Zero Waste France support the citizens-led Plan B’OM which promotes incineration alternatives.

In Australia there are already examples of successful recycling industries. One such operation is Integrated Recycling which makes railway sleepers out of recycled plastic. This company and another like it, RePlas also make bollards, decking, pathways, fencing, retaining walls, architectural screens, fitness trails, street and park furniture, plastic sheeting, signage and traffic control products out of recycled plastic.
http://www.integratedrecycling.com.au/
https://www.replas.com.au/products/
http://www.integratedrecycling.com.au/railway-sleepers/

Both plastic bottles and aluminium cans can be recycled. However, only 10 percent of plastic bottles are recycled compared to 50% of cans which are more efficient to recycle than bottles. Once the aluminium has been produced, it can be recycled over and again. Plastic bottles use more energy because they require the use of petroleum, a limited resource that has demands in other industries.
https://sciencing.com/plastic-bottle-vs-aluminum-can-13636298.html

Recycled aluminium is the most valuable of all recyclable commodities whereas plastic water bottles are a scourge on a planetary level. They should be banned along with the plastic supermarket carry bag. Canada are banning all single use plastics in two years.
https://www.sbs.com.au/news/national-solution-canada-will-ban-all-single-use-plastics-from-2021

Australia produces about one million tonnes of glass waste every year, of which approximately half is recycled back into glass receptacles. The remaining half million tonnes is used for low grade products such as road aggregate or dumped into landfills. There are 300,000 tonnes of stockpiled waste glass in Victoria alone. Every tonne of recycled glass used in glass re-manufacturing, replaces 1.2 tonnes of the virgin material (sand, soda ash) used to make new glass. Unless fragmented, glass is 100 per cent recyclable and infinitely recyclable into re-manufactured glass receptacles. Glass fragments which are too small to make into new glass containers can be crushed for cullet and used to replace fine sand in
a variety of manufacturing processes.
https://www.abc.net.au/news/2017-05-22/can-all-glass-really-be-recycled-war-on-waste/8541048

Researchers at University of Melbourne have found that waste glass can replace sand, fly ash and slag in concrete to make stronger, more lightweight and cheaper prefabricated concrete construction panels. Being lighter, the panels cost less to transport and are cheaper to produce since waste glass is one third the cost of fine sand. The material has also been found to possess excellent sound, thermal
insulation and fire resistance properties. Researchers are also investigating the use of recycled tyre crumb in the manufacture of lightweight, ductile concrete which is highly acoustically insulating.
https://www.thefifthestate.com.au/innovation/materials/waste-glass-could-lead-to-cheaper-lighterstronger-prefab-concrete/