Asia Pacific

15 June 2021

YONGPING ZHAI

Chief of Energy Sector Group

Sustainable Development and Climate Change Department (SDCC)

Asian Development Bank

Dear Dr. Zhai,

Congratulations on convening this virtual Asia Clean Energy Forum (ACEF) 2021 amid challenging conditions related to the ongoing pandemic. In this context, we write to raise specific concerns after having been informed on June 7th of a potential window within ACEF for a virtual discussion session on the ADB Energy Policy scheduled for June 15th.

We have been discussing the ACEF engagement with you since last year, and as we had hoped that we would be provided meaningful options for engagement, we were looking forward to your response. We regret to inform you that we are declining to engage in this dialogue based on our assessment of the platform, timing, and the lack of clarity in the way it is being rolled out. As a network of civil society groups and communities from across Central, South, and Southeast Asia as well the Pacific region and beyond, we do not consider this transparent, inclusive, meaningful opportunity for a consultation. 

Below, our key contentions related to the procedural lack of clarity and the limitations of the digital platform are elaborated.

On Process

Firstly, in regards to the process surrounding the coordination of this virtual session:

Forum member groups have been diligently checking the ADB’s website on the Energy Policy updates section over the past few weeks, waiting to see when more information would be available about scheduling civil society consultations, inclusive of all regions. Based on the stated intention by SDCC to designate a session during this year’s ACEF for an open, participatory civil society consultation during our dialogue on June 4th, Forum members have additionally been monitoring the ACEF website to remain alert as to when such a dialogue would be allocated and how they could participate in providing input from their respective groups. Disappointingly, despite the assurances provided at that time by SDCC, the given session within ACEF was not publicly identified on the website until Friday, June 11th.

Most significantly, it has never been clarified how the input provided during a moderated panel and moderated Q&A session would be duly accounted for and reflected as suggested revisions on the energy policy draft. Nor has it been clear if the SDCC intends to pitch it as the time when input from the Asian CSOs was provided, thereby limiting further engagement opportunities.

Consultation Platform Used

The chosen platform for the consultation is a conference app and thus has a minimal function if used for consultation. As per information from the technical coordinator of the event, the participants can only send their questions via chatbox and cannot participate via voice or dialogue. Also, quoting the technical advisor, ‘it is just one way and does not function like Zoom Meeting.’

In addition, the only individuals who will have access to microphones are the speakers, and those attending can only use the chatbox section of the platform, which the Bank moderates all incoming content. There is also the limitation of translation; the platform does not have translation options for local groups or impacted communities.

To continue our constructive collaboration around the ADB Energy Policy review, we hope to reconvene a consultation later. In the meantime, we are closely reading the draft policy and will be sharing with you our comments shortly. It would be effective to have a deeper dive after you have received our formal comments so we may have a more comprehensive and constructive discussion.

Respectfully,

Rayyan Hassan

Executive Director

NGO Forum on ADB

Endorsed by:

Aksi! for gender, social and ecological justice, Indonesia
Asian Peoples’ Movement on Debt and Development (APMDD)
Association Green Alternative, Georgia
Bangladesh Working Group on External Debt (BWGED), Bangladesh
Building and Wood Worker’s International, Asia Pacific
CEE Bankwatch Network
Center for Energy, Ecology, and Development (CEED) Philippines
Centre for Environmental Justice, Sri Lanka
Change Initiative, Bangladesh
CLEAN (Coastal Livelihood and Environmental Action Network), Bangladesh
Derecho Ambiente y Recursos Naturales, Peru
Environics Trust, India
Environmental public society, Armenia
Equitable Cambodia, Cambodia
Freedom from Debt Coalition, Philippines
Global Alliance for Incinerator Alternatives, Asia Pacific
Growthwatch, India
Indian Social Action Forum (INSAF), India
Initiative for Right View, Bangladesh
International Rivers
KRuHA – people’s coalition for the right to water, Indonesia
Nash Vek Public Foundation, Kyrgyzstan
Oyu Tolgoi Watch, Mongolia
Recourse, Europe
Rivers without Boundaries Coalition, Mongolia
Solidaritas Perempuan (Women’s Solidarity for Human Rights)
Youth Group on Protection of Environment, Tajikistan

—

Cc:

1. Office of the President
2. Vice-President for Knowledge Management and Sustainable Development
3. Vice-President for Private Sector and Public-Private Partnerships
4. Vice-President for Administration and Corporate Management
5. Vice-President for Finance and Risk Management
6. Vice-President Operations 1 & 2
7. Office of the Managing Director-General
8. Director-General, Sustainable Development, and Climate Change Department
9. Climate Change and Disaster Risk Management Division
10. Director, Safeguards Division
11. Director-General of Independent Evaluation Department
12. Director, Thematic, and Country Division
13. Chair, Compliance Review Panel (CRP)
14. Head, NGO and Civil Society Center
15. Deputy Director-General, Sustainable Development and Climate Change Department
16. Principal Safeguards Specialist, Portfolio, Results and Quality Control Unit
17. All Executive Directors
18. All Alternate Executive Directors

You may also read the letter in the NGO Forum on ADB website.

10 June 2021 – In line with  the  Asian Development Bank’s (ADB) annual Asia Clean Energy Forum in June 14-17 in which waste incinerators aka Waste-to-Energy (WtE) figures prominently as a renewable source of energy and a solution to a low-carbon future in its released  draft Energy Policy, the Global Alliance for Incinerator Alternatives (GAIA) Asia Pacific and #breakfreefromplastic gathered experts and representatives from civil society organizations (CSOs) to express their  opposition to the Bank’s support for WTE incinerators. 

Under its Strategy 2030, the ADB has envisioned to “achieve a prosperous, inclusive, resilient, and sustainable Asia and the Pacific, while sustaining its efforts to eradicate extreme poverty.” Moreover, it has supported cross-sectoral projects addressing water security and environmental conservation – including waste disposal services – in order to build livable cities. The ADB, however, maintains its endorsement of WtE  incineration, which it describes as a “circular economy solution,” contrary to the Bank’s commitment to a low-carbon and inclusive development.

Yobel Novian Putra, GAIA Asia Pacific’s Climate and Clean Energy campaigner stressed that, “Permitting WtE incinerators in its energy policy and considering it as renewable energy means ADB is offering a sham clean energy agenda  and  veering away from  the Paris Agreement’s 1.5° target.” He highlighted that, “WtE  incineration  is neither clean nor renewable and it is dirtier than coal-power plants (1). In Europe, it is recorded that  WTE incinerators generate twice the amount of direct CO2 emissions of the current EU28 average electricity grid intensity – significantly greater than conventional fossil fuel sources. (2)”   

In addition to  a high level of carbon intensity, a study conducted by Zero Waste Europe revealed that waste incinerators – despite being equipped with safety mechanisms, long-term tests show that they emit dioxin and other persistent organic pollutants (POPs) far beyond international standards (3).

Today, waste incinerators are heavily regulated in the EU and the US and  banned in the Philippines, Guam, and in Canberra, Australia. CSOs also said waste incinerators require a fixed amount of waste for incineration throughout the plant’s life – and as such – it undermines waste prevention, reuse and recycling policies and programs .

Hemantha Withanage, Executive Director of Centre for Environmental Justice in Bangladesh added that “the Stockholm Convention lists two  groups of POPS namely, dioxins and furans as byproducts of  incinerations which accumulate in living tissues. Long-term exposure can impair immune, nervous, endocrine and reproductive systems – and increase a person’s predisposition to cancer. Evidence suggests WTE also poisons  food systems and environmental quality.”  He also stressed that  waste incineration projects fail because in the long run, waste incinerators demand more resources both in terms of waste and cash. “Waste incinerators are expensive to build and maintain and companies lock cities in 20- or 30- year contracts demanding cities to supply trash to burn or otherwise – pay a fine.” 

Ahmed Afrah Ismail, Co-founder of Zero Waste Maldives, believes that waste incineration investments will sink the Maldives into further debt. “The Maldives already has a bad record in running waste incineration projects. Not only is it disastrous to our economy, but waste incineration, which needs a lot of waste feedstock for its operations, will ruin the government’s efforts to ban single-use plastics. Effective 1 June 2021, the Maldives banned the import of  single-use plastics, such as drinking straws, plates, cutleries, and disposable food containers.

In the Philippines, CSOs are actively pushing against a legislative bill proposing to repeal the incineration ban, which is enshrined under Philippine Clean Air Act of 1999, to address the country’s waste and energy problem.  To Atty Rose Liza Osorio, a Trustee  of the Philippine Earth Justice Center (PEJC), “The proposal is mimicking the ADB’s perspective that waste incineration is a green source of energy. “ADB is magnifying inequities, harming country regulations and offering a false solution to a low-carbon future.”  PEJC is working with communities affected by ADB’s WTE project in Cebu, Philippines on grounds of violations to national laws and social issues including health, pollution,  and job losses of waste pickers. 

Urging the institution to raise its ambitions by investing in just and cleaner energy systems  and waste management solutions, the group then advised the ADB to explicitly exclude waste incineration and other thermal-based technologies in its energy policy.  They also stressed that ADB’s decarbonization agenda must go hand in hand with achieving a more sustainable and equitable society.   

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Footnotes:

(1) ILSR (2018 December). Waste Incineration: A Dirty Secret in How States Define Renewable Energy.  https://ilsr.org/wp-content/uploads/2018/12/ILSRIncinerationFInalDraft-6.pdf 

(2) Zero Waste Europe (September 2019). The impact of Waste-to-Energy Incineration on Climate. https://zerowasteeurope.eu/wp-content/uploads/edd/2019/09/ZWE_Policy-briefing_The-impact-of-Waste-to-Energy-incineration-on-Climate.pdf

(3) Zero Waste Europe (2018 November). Hidden Emissions: a story from the Netherlands. https://zerowasteeurope.eu/wp-content/uploads/2018/11/NetherlandsCS-FNL.pdf 

Media Contacts:

Sonia Astudillo, Communications Officer, Global Alliance for Incinerator Alternatives (GAIA) Asia Pacific  I sonia@no-burn.org I +63 917 5969286

Jed Alegado, Senior Communications Officer, Break Free From Plastic (BFFP) Asia Pacific I jed@breakfreefromplastic.org I +63 917 6070248

About GAIA  |  Global Alliance for Incinerator Alternatives is a worldwide alliance of more than 800 grassroots groups, non-governmental organizations, and individuals in over 90 countries whose ultimate vision is a just, toxic-free world without incineration. www.no-burn.org and www.zerowasteworld.org

About Break Free From Plastic | www.breakfreefromplastic.org/ | @brkfreefromplastic The #breakfreefromplastic Movement is a global movement envisioning a future free from plastic pollution. Since its launch in 2016, more than 11,000 organizations and individual supporters from across the world have joined the movement to demand massive reductions in single-use plastics and to push for lasting solutions to the plastic pollution crisis. Break Free From Plastic runs the #WeChooseReuse campaign, calling for a global shift towards refillable and reusable products.

Related resources:

Media briefing: Zero Waste Asia – YouTube or https://www.facebook.com/GAIAAsiaPacific/videos/1192319227934497/ 

Notes/References: 

18th Congress of the Senate of the Philippines (31 July 2019). Gatchalian bats for the passage of the Waste-to-Energy bill. http://legacy.senate.gov.ph/press_release/2019/0731_gatchalian1.asp

Asian Development Bank (May 2021). Energy Policy Supporting Low Carbon Transmission in Asia and the Pacific. Mandaluyong City, Metro Manila, Philippines. https://www.adb.org/documents/draft-energy-policy-supporting-low-carbon-transition-asia-and-pacific

Asian Development Bank (19 May 2021) Key Figures in the Fight Against Climate Change. https://www.adb.org/news/features/key-figures-fight-against-climate-change

Asian Development Bank (November 2020) Waste to Energy in the Age of Circular Economy. Mandaluyong City, Metro Manila Philippines. waste-energy-circular-economy-handbook.pdf

The President’s Office, Republic of the Maldives (01 June 2021) President declares list of Single-use plastics prohibited to import from June 01, 2021. https://presidency.gov.mv/Press/Article/24211

Yang, A. (28 March 2021) ADB affirms support for waste to energy despite opposition. Business World Online, https://www.bworldonline.com/adb-affirms-support-for-waste-to-energy-despite-opposition/

World Health Organisation (04 October 2016). Dioxins and their effect on human health.  https://www.who.int/news-room/fact-sheets/detail/dioxins-and-their-effects-on-human-health

Zero Waste Europe (November 2018) Hidden Emissions: a story from the Netherlands. https://zerowasteeurope.eu/wp-content/uploads/2018/11/NetherlandsCS-FNL.pdf

12 May 2021

The Global Alliance on Incinerator Alternatives (GAIA) Asia Pacific welcomes the Asian Development Bank’s (ADB) rapid phaseout of coal towards a low-carbon transition in the region, as stated in its draft Energy Policy. It is a victory for environmental and social justice advocates and affected communities worldwide. 

Yet, we believe that the Bank’s continued support for Waste-to-Energy (WtE) or incinerators will significantly hold up its low-carbon transition. According to the draft Energy Policy, ADB will keep WtE in its energy portfolio, “provided that the feedstock for combustion prudently follows the waste management’s order of priority, which considers first reducing waste generation.” While ADB recognizes the need for caution when opting for WtE, the language is unclear with regard to preferences over higher-tier activities in the waste hierarchy, such as waste prevention measures, reuse schemes, and recycling programs.

As mentioned in the policy draft, the ADB needs to invest in low-carbon solutions and avoid regrettable climate-inducing decisions, in order to achieve sustainable development. This includes avoiding carbon lock-in and curbing fossil-fuel use. WtE will create a lock-in situation which undermines waste reduction measures of local governments – including plastic waste which is derived from fossil-fuel. In the islands of Madeira and Azores in Portugal, for example, incinerators required a constant amount of waste feedstock, thus stagnating recycling rates in the area. A U.S. study concluded that WtE incineration is the most emissions-intensive form of power generation when both biogenic and fossil CO2 are accounted for. 

The ADB, through various technical assistance projects, has provided policy advice to municipalities on the use of WtE, while ignoring national goals on waste recycling targets or regulations prohibiting incinerators. Promoting WtEs, even as a last-resort option, will discourage developing member-countries (DMCs) to improve waste collection, recycling, and composting programs. By investing in thermal WtE, cities are obliged to generate more waste to maximize the operational capacity of thermal WtE facilities, as well as to meet contract-bound feedstock quotas. It locks societies into a linear economy that justifies a throw-away culture. Prudence in waste management is not a possibility with WtE. 

WtE facilities globally are primarily intended for waste management, not for producing electricity. The Bank’s continuous categorization of WtE as renewable energy is a deception to leverage public resources through guarantees and subsidies to empower industry polluters. Elsewhere, the European Union prohibits member-states from using renewable-energy subsidies to support waste incineration activities. The US Environmental Protection Agency, meanwhile, does not consider energy recovery as a waste minimization activity and rather prioritizes waste reduction at source.

The draft outlines benefits of WtE, which is described as a potential source of centralized heating, a better option for open landfills, a source of livelihood and a means to achieve liveable and healthy cities. Yet, waste incineration is the most expensive way to handle waste and create the least amount of jobs. The abovementioned list of supposed benefits is a blatant manipulation of the narrative, which projects WtE as a progressive tool for improving the quality of life and well-being of communities. We strongly express that these objectives for the use of WtE does not reflect current policy trajectories on sustainable financing, scientific findings, and on-ground experiences. 

Lastly, we express solidarity with our members and allies that are resisting ADB-funded WtE projects in the Philippines, Maldives, and Thailand. While the Bank has acknowledged the need to mitigate  environmental and social risks in WtE projects, independent evaluations show that these DMCs lack environmental and social regulations to mitigate, avoid, or compensate for harm. 

We challenge the ADB to stop investing in Waste-to-Energy and delist it from its climate financing and other sectoral portfolios. Stop the deception and use of critical resources for false solutions to climate change. 

We demand ADB to withdraw from WtE! ###

Read the Vietnamese Translation

Media Contact:

Sonia Astudillo, GAIA Asia Pacific Communications Officer sonia@no-burn.org, +63 917 5969286

Campaign Contact: Yobel Novian Putra, GAIA Asia Pacific Climate & Clean Energy Associate yobel@no-burn.org, +62 821 2818 4440 

07 May 2021

Background. Asia’s leading development financial institution, the Asian Development Bank (ADB), held its 54th ADB Annual Government Meeting on 3-5 May 2021 to discuss priority investments and critical issues affecting the region, such as climate change, post-pandemic recovery, and environmental sustainability. The annual meeting, which serves as a policy-setting space, convenes representatives from finance ministries, the private sector, development institutions, and civil society organizations (CSOs). 

In a meeting between CSOs and ADB President on May 3, Hemanthana Winthanage, International Coordinator of NGO Forum on ADB, noting that ADB still affirms its support for thermal WtEs, challenged the bank to  show real climate leadership by excluding thermal WtE from all its financing instruments. Masatsugu Asakawa, ADB President, responded that WtE 1)  opens opportunities for integrated cross-sectoral projects; 2) it is an option in support circular economy; 3) enhances the livability and health of local communities (comparing it to the environmental hazards caused by open waste dumping, and; 4) will be considered as the last resort.  The recording of the session can be accessed here (check 28:20-29:35).

In another session organized by CSOs, “Reviewing Energy Policy to Meet Paris Goal of 1.5 degrees celsius,” leading scientist Dr. Jorge Emmanuel, representing GAIA, presented evidence on why WtE incinerators should be delisted in the bank’s climate financing. In his presentation,  Emmanuel revealed that scientific evidence has shown that thermal WtE is not a climate solution and communities around the world reject WtE due to its toxic emissions, such as dioxins and furans, and its financial burden on public funding.  At the end of his presentation,  Emmanuel  called for an immediate divestment from thermal WtE immediately. “There is no reason for adopting thermal Waste-to-Energy systems in the Bank policy,” he said. . ”Time is running out, precious resources are also running out.” His presentation can be seen here and the texts can be found here.  Recorded video can be accessed here (check 52:15 – 1:01:25). 

Together with other CSOs, the Global Alliance for Incinerator Alternatives (GAIA) has been pushing for the delistment of thermal Waste-to-Energy (WtE) in ADB’s climate finance and other investment policies. Below is our statement.

__________________________________________________________________________

Show Real Climate Leadership, Stop Support for Thermal Waste-to-Energy Facilities

The Global Alliance for  Incinerator Alternatives (GAIA) expresses solidarity with civil society organizations across the region demanding real climate action from the Asian Development Bank (ADB) and other international financial institutions. The Bank plays a major role in shaping economic, governance, and social agenda affecting its developing member-countries (DMCs) as a financier, policy advisor, and convenor of leaders in the region. Yet, during the three days of the Bank’s annual meeting, we have only seen political statements of “alignment” with Paris goals and achieving green, resilient, recovery, but without any clear commitments  to climate reform.  

As countries struggle in stemming the impacts of COVID-19, the ADB has kept climate reforms at bay, where changes in its policies, strategies, and programs are most critical. 

While ADB President Masatsugu Asakawa acknowledged concerns over greenhouse gas emissions and hazardous waste that are produced from waste incineration, he made  no clear commitments to drop WtE from the Bank’s portfolio.  The ADB, likewise, has maintained its categorization of WtE as a climate-mitigating measure. Moreover, it has justified the use of scarce public resources for WtE, describing it as an “option for supporting a circular economy.” 

On the contrary, more governments, especially in the EU, are moving away from WtE. In the latest EU Taxonomy Regulation, WtE has been excluded from the list of sustainable economic activities, due to its harm to the circular economy and climate objectives. WtE is also not part of other EU funds such as the Regional Development and Cohesion Fund and the Just Transition Fund. The European Investment Bank Circular Economy Guide, meanwhile, classified thermal WtE as an ineligible technology supporting the transition to a circular economy.

Denmark, for example, has announced plans to decommission 30% of its incinerator capacity to meet its mid-term climate targets.  Slovenia has dropped plans to build an incinerator in its capital Ljubljana to avoid being locked in a long-term put-or-pay contract, as well as to realize its circular economy potential.

Scientists and practitioners are speaking with communities on the impact of thermal WtE operations on circular economy and climate goals.  For a thermal WtE to operate at its full efficiency, it has to jeopardize the recycling of recyclable plastic waste because of its high heating values greatly desired by thermal WtE operators.  This creates a lock-in effect that will eventually undermine waste prevention, reuse and recycling policies and programs, as local governments are forced to send a fixed amount of waste to the thermal WtE operator or pay a fine.

DMCs should not welcome strategies that consider thermal WtE as an option of “last resort” from open landfills. Both open landfills and WtEs release a significant amount of GHG emissions that harm the environment and jeopardize the 1.5°C climate target.  Thermal Waste-to-Energy is a Waste-of-Energy—it burns public funds for 20-25 years that are better  invested in waste reduction, recycling, and composting programs.  These programs deliver higher climate mitigation benefits,  thus positioned – high in the  hierarchy of options for managing waste that protects the environment by preventing waste and preserving resources in the first place. 

Moreover, including thermal WtE as an option of “last resort” runs against national climate, recycling, and environmental goals and policies. Loan packages can conveniently include thermal WtE as part of its waste management programs even when there are other low-carbon and cheaper options available to manage waste.  

Therefore, we recommend that the ADB refrain from advising   countries to opt  for thermal WtE, as it is doing now in the Philippines and other parts of Southeast Asia.

We dispute the Bank’s statement that WtE enhances the livability and health of local communities. Thermal WtE are known to generate hazardous and toxic substances and are being approved by the Bank without communities’ consent. In Thailand,  Maldives, and the Philippines,  WtE is being resisted at various levels because of its potential environmental and social risks.  ADB’s technical assistance in the Philippines, for instance, has led to public-private partnership agreements amid a national ban on incinerators. These proposals presently face disputes on land claims, community health and safety, lack of meaningful consultation, and information disclosure.  In Thailand, an indigenous community is resisting a thermal WtE facility to be established in ancestral land devoted for agriculture and near a school.  In Maldives, a WtE incinerator project seen to endanger communities from the lack of environmental regulations to manage air, water, and land pollution has been approved without information disclosure and meaningful consultation. 

There is no air pollution control equipment which can remove  toxic content of thermal WtE emissions.  It only transfers the toxic emission from stack to toxic ashes and water effluents.  Communities resist because of the known lasting adverse impacts of these facilities on its long-term and irreversible consequences on  health, pollution, climate and environmental sustainability,

The aforementioned countries are facing severe climate risks and ADB’s support of carbon-intensive projects such as thermal WtE is unacceptable.  In its efforts to align with the Paris Agreement, we urge ADB to withdraw thermal WtE from its Energy Policy and other financial instruments.  Further, we demand ADB to stop all  thermal WtE technical assistance, projects and investments including those under climate and green finance. Instead of empowering polluters, we demand a rights-respecting Safeguards Policy Statement to enable communities to determine  the best options for a green, inclusive and resilient future. Time is running out. 

Media Contact: Sonia Astudillo, GAIA Asia Pacific Communications Officer sonia@no-burn.org, +63 917 5969286

Campaign Contact: Yobel Novian Putra, GAIA Asia Pacific Climate & Clean Energy Associate yobel@no-burn.org