Response from the City of Edinburgh Council
Submitted to Developing the UK Emissions Trading Scheme (UK ETS)
Response ID ANON-93AN-B3NB-Z. Submitted on 2022-06-16 13:40:15
About you
1 What is your name?
Angus Murdoch
2 What is your email address?
angus.murdoch@edinburgh.gov.uk
3 What is your organisation?
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4 Please tell us which sector your organisation fits into:
Local authority
5 Region organisation HQ (or individual if not an organisation) is based:
Scotland
6 Are you happy for your response to be published?
Yes
7 Would you like to be contacted when the consultation response is published?
Yes
Reducing emissions from waste (Chapter 7)
124 Do you agree with the proposed timing for when waste incineration and EfW could be introduced into the UK ETS?
No
125 For operators of waste incinerators, EfW plants, and local authorities (LAs), please outline the steps that you will need to take, and the time required to prepare for the expansion of the UK ETS to waste incineration and EfW.
The proposal is to introduce ETS for the energy from waste and incineration sector by the mid to late 2020s. This sounds broadly reasonable but may in practice be ambitious.
As a local authority which does use energy recovery to dispose of non-recyclable waste, we have committed to Net Zero by 2030 and are committed to minimising emissions.
As a local authority we don’t directly operate an energy recovery facility but do send waste to one. This is a modern facility which already generates electricity and which we expect will be capturing heat (and so operate at the higher level of efficiency) within approximately two years. That would be the first key milestone which we assume will reduce the facility’s liability to an extent under the emissions trading scheme, although the detail of how this would work is not clear in the discussion paper.
Beyond this, the key issue is that we are not the waste producer. In our case, as we don’t operate a commercial waste collection, the waste producer is the householder. We have to accept the waste they produce and have only limited powers to require them to use alternative outlets (specifically recycling collections which we already provide for around 70% of routine household waste arisings) or to practice waste prevention. Therefore, we will have no