Minutes of the ForumZ web talk on 14.08.2024

“EU ETS - Does increasing the cost of waste incineration in Europe promote global methane emissions?”

by Dipl.-Ing. (TU) Werner P. Bauer

Introduction with a view to global warming

In order to focus on the effects of global warming, W. Bauer provided information on the current situation of the devastating forest fires north-east of Athens. Although these have now been extinguished with international help, the images from St. Anton are once again dominating media coverage of a natural disaster. The warnings of climate experts about the effects of too many greenhouse gases in the atmosphere are increasingly being replaced by real events.

But how do we deal with this information?

Does it affect us? Are we resigned? Or can we, as representatives of the waste management industry, contribute to the solution? The following quote can put our aspirations and individual expectations into perspective:

"He (Macron) made himself a witness to the unjust conditions. This role, in which he names the frustrating state of affairs and thus counters the silent violence with enlightenment through public naming, is not a resignation to powerlessness, but a promise of better times to come.” ¹

With this motivation, the 2nd ForumZ Webtalk aims to provide information about underestimated connections between waste management and climate protection. The EU ETS and the possible future inclusion of waste incineration in European greenhouse gas trading is a current and urgent issue.

Initial thesis:
It is generally feared that making waste incineration more expensive by incorporating it into the EU greenhouse gas trading system will lead to even more untreated waste being dumped in landfills or even dumped in the countryside in a completely disorderly manner - especially in the eastern countries of the EU. Will these EU regulations make the transition to sustainable waste management with significantly lower emissions more difficult?

Contradictions:
A lot has changed in Germany's waste management sector since the ban on landfilling untreated waste was introduced long in advance at the end of June 2005. The Federal Environment Agency summarized the key studies at the beginning of 2011² as follows:

By phasing out the landfilling of untreated municipal waste, emissions of climate-damaging gases from waste management have been reduced by a total of around 56 million tons of CO₂eq.

Interesting in our context are the calculations³ cited by the Federal Environment Agency (2011) of the effects of a similarly acting European Union on climate-relevant greenhouse gases in the EU:

"Thermal or mechanical-biological waste treatment, increased recycling and technical optimization could save up to 192 million tonnes of CO₂eq in the EU in 2020.
This corresponds to 32% of the remaining 600 million tons of CO₂eq, to which the EU 27 (EEA 2009) has voluntarily committed itself.”
"A strict landfill ban for untreated waste along the lines of Germany, Austria or Switzerland would make a decisive contribution to improving the waste management sector's climate protection record and is a necessary prerequisite for significant optimization in the EU 27.
An equally successful steering function is achieved through landfill taxes, e.g. in the Netherlands⁴.
A minimum target should be strict compliance with the EU Landfill Directive, which sets specific targets for reducing the amount of biodegradable waste in landfills.”

Contrary to these scientifically prepared findings from Germany⁵ , the European Commission presents waste incineration and thermal recycling in a clearly negative light in its regulations. The EU believes that landfilling can be overcome solely through its circular economy strategy (EU's Circular Economy Action Plan). If this does not happen quickly enough, the EU will even allow landfills to be operated for longer than stipulated in the Landfill Regulation. As a result, the Commission classifies waste incineration plants as "unsustainable” in the EU Taxonomy Regulation.

Presentation by Dr. Bärbel Birnstengel, Principal Prognos AG:

Is the MV really "unsustainable”? Dr. Bärbel Birnstengel presented the study (slides attached) prepared by Prognos AG together with CE-Delft from 2021 on "CO₂ avoidance potentials in the European waste management sector”. The study focused on 10 waste streams with high resource potential as well as mixed municipal waste and residual waste from sorting and processing and determined the potential contribution of waste management to resource conservation and the reduction of CO₂ emissions. The analysis was based on the reference year 2018 and examined two (2) projections.

Projection 1: "CO₂ reduction potential due to the waste targets set by the EU and extension of the targets for municipal waste to industrial and commercial waste”:

Potential CO₂ savings of 163 Mt CO₂eq can be achieved.

Projection 2: "Increased recycling efforts and minimization of landfilling”:

Potential CO₂ savings of 296 million t CO₂eq can be achieved.

Projection 2 assumes that waste incineration plants (as in Germany, Austria,Switzerland) recycle residual waste thermally and that untreated waste is no longer sent to landfill. Dr. Birnstengel emphasized that both scenarios require the cooperation of many stakeholders, from the population to industry (product design, Green Deal).

Beyond these complex assumptions, their statement that the CO₂ savings potential of residual waste + sorting residues can only be significantly increased if all combustible sorting residues are used for energy recovery instead of landfilling (see excerpt from slide 17) is essential:

The potential of a comprehensive
consideration of waste incineration
in EU strategies and regulations
would therefore result in an annual
CO2 savings potential of
233 million tons of CO₂eq.

Remarks W. Bauer:
In order to better visualize this amount, a calculation by Deutsche Umwelthilfe (DUH)⁶ is quoted here:
The introduction of a speed limit in Germany of:

100 km/h on highways,
80 km/h outside built-up areas and
30 km/h in urban areas

results in

Annual savings of 11.1 million tons of CO2

Presentation by Prof. Dr. Gerhard Rettenberger

Professor Rettenberger began by reporting that there are different approaches to the assessment of emissions from landfills and that it would make sense to bring about a standardization with a focus on the masses.

His following statement seems essential to me:

In various studies, emissions from landfills account for between 17% and 19% of global greenhouse gases. ...

Prof. Rettenberger subsequently provided his slides from a presentation at the DWA on "Climate protection - the role of landfills beyond German borders” on September 13, 2022. Excerpts from it are reproduced here.

The formation of landfill gas in landfills is a worldwide phenomenon. Only exceptional conditions (extremely low or high temperatures) may cause deviations.

The amount of landfill gas is a function of the mass of waste sent to landfill.

So the facts are quickly put together:

World population: 7,948 billion, municipal waste, roughly estimated: 3.2 billion Mg FM,

Landfill gas/a: 6.4 billion Mg CO2 equivalents, => 0.81 Mg/E

For comparison:
total emissions worldwide: 36.7 billion Mg CO2 equivalents (2019) => 17.4% => 4.62 Mg/E

Reiser⁷ (2022) estimates the "contribution of managed and unmanaged landfills to global anthropogenic methane emissions at around 12%. This figure is frequently cited in the literature. The resulting methane mass flow averages 65 Tg/a⁸ [Earth Syst. Sci. Data, 2022]. Converted, this means that over 10 million m³ of methane per hour escape from landfills globally.

Reiser cites the following data for comparison with Germany:
The methane load emitted from the landfills recorded as part of the national greenhouse inventory in Germany in 2021 was still 0.3 Tg/a [UBA, 2022] or the equivalent of just under 50,000 m³/h. => approx. 0.094 Mg/E

This clearly shows where methane emissions are generated.

Question: How much waste is generated per inhabitant or how much organic, degradable waste?

Municipal waste in Germany amounted to approx. 613 kg/E in 2013. The global average is estimated at 400 kg/E. The organic, degradable portion is relevant for landfill gas formation (mainly dependent on eating habits and horticulture).

Question: How much of the organic matter in the waste sent to landfill is converted under landfill conditions? => Approach in the models 50 %, (wood is almost not converted, vegetation almost 90 %).

Picture from lecture by G. Rettenberger:
CH4 emissions (Tg CO2 eq) from landfill
in different regions in the Baseline scenario
(Manni et al. 2006)

Question: How many landfills have a degassing system and what is the degree of capture?

Many of the large municipal landfills have a degassing system.
In relation to the total number of landfills, this is likely to be in the lower single-digit percentage range.

Capture rates at degassing plants in Europe are around 20-30%.

In exceptional cases and in the case of closed and sealed landfills, collection rates can also approach 100%.

Question: How much waste goes to landfill and how much to incineration (if available)?

Incineration requires costs of 100 €/Mg or more. Therefore, the proportion of incineration is not relevant internationally except for Europe.

End of presentation G. Rettenberger

Remarks by W. Bauer:

The greater the difference in disposal costs between landfilling and energy recovery, the more difficult it will be to overcome landfilling. According to a study by the World Bank (2018), 69.7% of the world's waste is deposited in landfills or landfilled.

Contributors and discussion:

With representatives from associations (InwesD, CEWEP, ITAD) as well as from municipalities, science, industry and law, the topic could be examined from different angles.

The discussion quickly moved in the direction that the waste sector should be considered holistically when discussing the inclusion of waste incineration plants in the EU ETS in order to avoid promoting counterproductive developments (e.g. incentives for landfilling or waste exports). The aim must therefore be to ensure that

landfills and other relevant waste treatments are also included in the EU ETS and
the revenues should be used for the expansion/closure of landfills.

It was subsequently discussed that it would be difficult to define the parameters for calculating the certificates required for landfilling waste - also in comparison to waste incineration. The question also arose as to whether a retroactive inclusion of emissions was conceivable.

B. Enderle, a lawyer specializing in environmental law, explained that the parameters for the inclusion of landfills (and waste incineration plants) in the European Emissions Trading System (EU ETS) are proposed by the European Commission. For such a new regulation, there are always so-called stakeholder consultations in which the affected parties can present and contribute their views. A retroactive inclusion of emissions has not yet taken place and would also be viewed critically in the case of new emitters. For the parameters ultimately developed, which would then also be regulated by law in the EU ETS, it is fundamentally the case that these must be subject to the participation of all stakeholders and be appropriate and proportionate in order to be legally sound.

M. Baur, HZI, noted that the technology for capturing CO2 at the stack of a waste incineration plant has already been developed and that capture also makes sense if the equivalent value for the ton of CO2 is enshrined in international law through the EU ETS.

G. Rettenberger mentioned the still insufficient public pressure to really tackle the 17 - 19 % reduction in greenhouse gases that could be achieved by banning landfilling (as in Germany, Austria, etc.). A political push at EU level would be necessary.

B. Enderle deliberately motivated and encouraged - instead of allowing frustration to set in - to try a multi-layered approach on "every conceivable path”. We should initiate a discussion in academia, among law faculties and elsewhere. Ch. Rasquin suggested doing this at European level....

H. Häming emphasized that we must "lose no more time”. Instruments such as BATs⁹ take decades to be implemented.

R. Reitz called for "more speed” and "public attention”

Summary and outlook: W. Bauer:

I assume that a common understanding of the importance of "CO2 avoidance potential in the European waste management sector” was achieved among the participants of the web talk.

The difference between projection 2 with potential CO2 savings of 296 million t CO₂eq compared to projection 1 with CO₂ savings of 163 million t CO₂eq may be even greater, as the forecast according to EU regulations after the report from Brussels of 8.6.2023.

Early Warning Report¹⁰ in the annex) and the early warning report referred to an option¹¹ according to which individual states may continue to deposit "under certain conditions”.

I assume (hope!) that with a continuous "public naming” of the
"CO2 avoidance potential in the European waste management sector”, the need for a readjustment of national and international waste policy will be discussed and, if necessary, can be enforced through public pressure.

How could this happen? Real public pressure can arise if it succeeds,

1) make the obviously enormous potential of sustainable waste management understandable with reference to the limited influence of other measures (see footnote 5),
2) to act outside known echo chambers and, for example, invite environmental associations into the discussion and use social media for dissemination,
3) to remind people of the need to act quickly (H. Häming: no time to lose),

Note: If you would like to delve deeper into the significance of the aspect of "time”, you can do so by watching the web talk¹² by Johan Rockström¹³ "The Tipping Points of Climate Change - and Where We Stand”. Here is an excerpt from the talk, in which he refers to the increased importance of the 1.5 degree target in the course of the IPPC reports 2001 to 2022:

4) formulate a simple challenge; e.g. the sentence:
"Energy recovery is not the problem, it is part of the solution!”

5) to justify this in a striking way; here using the example of comparing the results of waste management in the EU countries with Switzerland, Norway and Iceland according to the following graphic:

This begs the question:

why no measures are propagated or subsidized that cover the area between the 65% recycling rate and the specified maximum landfill rate of 10%
why a maximum landfill rate of 10% is permitted when more is obviously possible (as achieved in the countries on the left: Switzerland, Finland, Belgium, etc.) and optimal degassing is only possible in closed landfills.

Relation to the EU ETS

The discussion developed in such a way as to not oppose the integration of waste incineration into European greenhouse gas trading, but to call for the complete integration of waste management (or at least landfill).

If this were linked to the fact that the revenue from the purchase of greenhouse gas certificates would flow directly into the development of a modern, sustainable waste management system, this would be a fascinating strategy.

However, as part of this strategy, legislators at national and EU level must be made aware of how much

the inclusion of waste incineration in the EU Taxonomy Regulation and
At German level, the draft amendment to the TEHG "Act on the Adaptation of the Greenhouse Gas Emissions Trading Act14 to the Amendment of Directive 2003/87/EC” (TEHG European Law Adaptation Act 2024) stands in the way of a significant reduction in greenhouse gases at European level.

In my opinion, the suggestion already formulated in the invitation that we need a broad public dialog in addition to the European Commission's "Impact Assessment” has been confirmed!

Munich, 26.8.2024 / 02.09.2024 /08.10.2024

Dipl.-Ing (TU) Werner P. Bauer,
Managing Director
ia GmbH - Knowledge Management and Engineering Services, Munich

Operator of the municipal network ForumZ
(www.forumZ.de), which represents around 20 million inhabitants of Germany

with its municipal partners as licensees.

1 Aus SZ-Feuilleton 25./26. Mai 2024 mit der Überschrift: Das Wort hat der Präsident
2 Januar 2011, Umweltbundesamt Klimarelevanz der Abfallwirtschaft / Hintergrund https://www.umweltbundesamt.de/sites/default/files/medien/publikation/long/4061.pdf
3 ebenda
4 Ergänzung durch M. Baur: „auch UK arbeitet erfolgreich mit Deponiesteuern"
5 Ähnliche Erfahrungen gibt es in Österreich, Schweiz, den Niederladen, etc.
6 https://www.duh.de/tempolimit/
7 Dr. Ing. Martin Reiser Arbeitsbereichsleiter "Emissionen" (EMS), Institut für Siedlungswasserbau, Wassergüte- und Abfallwirtschaft, Abteilung Umweltmikrobiologie
8 Tera => 1 Billion, Tg => Mt
9 BVT-Merkblättern zur Besten Verfügbaren Technik den Deponierichtlinien Regularien verankern
10 „Trotz erheblicher Verbesserungen seit der Annahme der Deponierichtlinie und Stilllegungen vorschriftswidriger Deponien in der gesamten EU gibt es immer noch besorgniserregend viele Deponien, die den Anforderungen der Abfallrahmenrichtlinie und der Deponierichtlinie nicht entsprechen. Ende 2021 waren noch 1995 illegale oder minderwertige Deponien in Betrieb, die saniert oder an EU-Standards angepasst werden mussten." Wobei diese Zahl auf der Anzahl der illegalen oder minderwertigen Deponien basiert, die Gegenstand laufender Vertragsverletzungsverfahren sind."
11 „Schließlich wird einigen Mitgliedstaaten in Anbetracht der großen Unterschiede bei der Abfallbewirtschaftung durch die EU-Rechtsvorschriften die Möglichkeit eingeräumt, die Einhaltung unter bestimmten Bedingungen über die Zieljahre hinaus aufzuschieben."
12 https://www.youtube.com/watch?v=Vl6VhCAeEfQ
13 Prof. Dr. Johan Rockström, einer der beiden wissenschaftlichen Direktoren des Potsdam-Instituts für Klimafolgenforschung (PIK)
14 Referentenentwurf des Bundesministeriums für Wirtschaft und Klimaschutz
Das Bundesministerium für Wirtschaft und Klimaschutz (BMWK) hat die Länder- und Verbändeanhörung zum Entwurf eines Gesetzes zur Anpassung des Treibhausgas-Emissionshandelsgesetzes an die Änderung der Richtlinie 2003/87/EG (TEHG-Europarechtsanpassungsgesetz 2024) siehe: https://www.bmwk.de/Redaktion/DE/Artikel/Service/Gesetzesvorhaben/20240730-entwurf-anpassung-treibhausgas-emissionshandelsgesetz.htm

Find here the original document in german.

published: ForumZ, 10|2024
Keywords: Energy Recovery, Pollution Control, Sustainability, Climate, Mixed Waste, Methods, Analyses, Data, Germany

Dipl.-Ing.(TU) Werner P. Bauer
WtERT Germany GmbH