The Inflation Reduction Act (IRA) channels $270 billion in tax credits for climate investments but raises concerns about incineration—a false solution to waste disposal that could generate 637.7 million tonnes of CO2e emissions over two decades, further harming the environment and disadvantaged communities. This resource highlights the key points of our recent article, including available funds for EJ organizations.
REDUCCIÓN DE PLÁSTICOS: EL CASO DE SAN PEDRO LA LAGUNA
Latin America & the Caribbean - -
El Municipio de San Pedro La Laguna se ubica en el Departamento de Sololá, en Guatemala. De población indígena, Tzutuhil, es uno de los 14 municipios que integran la cuenca del Lago Atitlán, uno de los cuerpos de agua más bellos del país. En septiembre de 2016, el Alcalde Municipal tomó una propuesta ciudadana y aprobó mediante Acuerdo Municipal (ordenanza municipal) una prohibición al uso y comercialización de pajillas y bolsas plásticas de un solo uso, así como de productos de poliestireno (conocido localmente como duroport). La prohibición levantó inmediatamente una serie de reacciones que llegaron a casi todos los alrededores del país. Tres años después, tras haber ganado una demanda que interpusieron los industriales del plástico, la norma sigue vigente y cuenta con aceptación de buena parte de la población. Los habitantes del pueblo considerando que han cambiado e, indican, ese cambio es para siempre. Como corolario, la iniciativa de San Pedro La Laguna y de al menos otros 17 municipios del país ha escalado: en septiembre de 2019 el gobierno de Guatemala prohibió el uso y distribución de bolsas, pajillas, vasos, platos, mezcladores y recipientes para alimentos hechos de plásticos desechables a partir de 2021.
En 2021 el equipo regional de GAIA LAC junto al ingeniero agrónomo y miembro de GAIA Javier Souza idearon una fórmula de trabajo que explora en dichas intersecciones y promueve la interacción y el diálogo entre actores diversos, desde temáticas diversas que en el diálogo y el aprendizaje encuentran poderosos puntos de encuentro. Este primer proceso se desarrolló durante 8 meses y este documento relata la experiencia para recoger aprendizajes y ser replicada en el futuro. Hasta el momento, este taller ha sido ofrecido ya 2 veces, y en 2023 vamos con la tercera versión.
Asian Development Bank (ADB) regressing on climate commitments in Asia
Manila, Philippines – June 16, 2023 – In an online forum with the National Press Club of the Philippines, the Global Alliance for Incinerator Alternatives – Asia Pacific stated that the amount of climate finance and complex facilities are on the rise but may end up fuelling the poly-crises shaping the majority of poor people in the region.
GAIA Asia Pacific said that the region is still suffering from a continuing pandemic, an energy and food crisis stemming from a war in Europe, and heavy debt burdens in which environmental risks are at the top of the crises. “Talks on clean energy and just transition are bereft of this regional context. We are merely being offered more loans for expensive and dirty techno-fixes in developing countries”, Miriam Azurin, Deputy Director of GAIA Asia Pacific said.
The group said that the continued financial and policy support of international financial institutions (IFIs) for Waste-to-Energy (WtE) incinerators will deepen the multiple crises as these projects pose complex environmental and social risks, Since 2009, the Asian Development Bank (ADB) alone has invested more than US $700 million of public money on WtE incinerators and has since convinced the public that it is a source of clean energy and cost-efficient waste disposal system.
“A plan for a just transition should include payments for compensation for the communities as a result of investing in this harmful technology. We are merely being offered an energy plan without provisions on how to recognize, protect and fullfil human rights including the right to a clean and healthy environment”, Azurin said.
Yobel Novian Putra, GAIA Asia Pacific’s Climate and Clean Energy Campaigner, said that numerous longitudinal studies have shown that WtE is an environmentally hazardous method for both energy generation and waste disposal. “Incinerators with or without energy recovery release harmful pollutants such as dioxins, heavy metals, microplastics, greenhouse gases, and other toxic residues.
“Many of these pollutants are poorly regulated or not regulated at all, posing risks to environmental protection and public health. Additionally, incineration is a carbon-intensive and energy-intensive process that heavily depends on plastic waste which is a fossil fuel-derived material, studies show incinerators are four times more carbon-intensive than coal,” he added.
GAIA Asia Pacific also warns the public of increased interest in policy lending by ADB saying this could pose permanent harm when it proposes and lends for false solutions like WtE incinerators. “ADB wants to provide security for the private sector when they participate in energy projects. A critical component is by creating laws that would ensure the sustainability of the operation of WtE plants which include a subsidy for capital outlay and operational costs thereby creating the policy and investment infrastructure for permanent damage from this technology”, Putra said.
In the Philippines, the ADB was instrumental in providing policy advice in favor of WtE which undermines the national ban on incinerators as stated in the Clean Air Act. It also provided support for marketing and assisting local government units to accept and review bids through various technical assistance projects. “Today, there are already four proposed WtE plants in the pipelines set to be constructed in protected environmental areas and near marginalized communities”. Teody Navea, Ecowaste Coalition Cebu said. He added there were no meaningful consultations to integrate communities and local experts’ insights on risks associated with the projects and examine practical alternatives.
Sonia Mendoza, Chairperson of the Ecowaste Coalition said the WtE facilities will be a financial burden to Filipinos and will only turn the garbage problem into a more persistent environmental problem. A WtE bill is being proposed in the Senate and Congress despite the European Union’s shift away from technology.
The European Union (EU), despite its advanced technology and monitoring systems, has excluded burning waste as part of the transition towards a circular economy, highlighting that it does significant harm to its environmental objectives of waste prevention and recycling.
Afrah Ismali, Zero Waste Maldives co-founder said that a lot of communities and non-profit organizations are working on zero waste systems. He appealed to IFIs to withdraw their financing for the WTE plant. “We do not need more debts and dirty technologies”, he added.
Yobel Novian Putra, GAIA Asia Pacific Climate and Clean Energy Officer | firstname.lastname@example.org | +62 821 2818 4440
Communities hold a Day of Action Against Incineration as the Asia Clean Energy Forum goes underway
Manila, Philippines – June 10, 2023 – The Global Alliance for Incinerator Alternatives (GAIA) in Asia Pacific will hold a Day of Action Against Incineration during the Asian Clean Energy Forum (ACEF) happening from June 13 to 16, 2023 at the Asian Development Bank (ADB) Headquarters in Manila. Seeing this year’s ACEF as another venue for promoting false solutions such as waste-to-energy (WtE) incineration, the event aims to bring attention to the urgent need to stop WtE incinerators and raise awareness on its impact on people’s health, livelihood, and the environment.
GAIA Asia Pacific Climate and Clean Energy Campaigner, Yobel Novian Putra, stresses, “Incineration is a dirty and dangerous way both to generate energy and dispose of waste. Incinerators emit harmful pollutants such as dioxins, heavy metals, microplastics, greenhouse gases, and other toxic residues. Many of these pollutants are under-regulated or not regulated at all, placing the protection of the environment and public health at risk. It is also a highly carbon-intensive and energy-intensive process that heavily relies on fossil fuels to function.”
Recognizing the detrimental effects of WtE incineration, the European Union (EU), despite its advanced technology and monitoring systems has excluded burning waste as part of the transition towards a circular economy, highlighting that it does significant harm to its environmental objectives of waste prevention and recycling.
However, in the Asia Pacific region, international financing institutions (IFIs) such as the ADB continue to put forward WtE incineration as a single solution to waste and energy issues. Mayang Azurin, GAIA Asia Pacific’s Deputy Director states, “IFIs including the ADB should stop investing in technologies that are not only harmful to the environment but are also against people’s fundamental rights to health and livelihood. Support for waste incineration is against the goal of a just energy transition that the bank proudly claims it champions.”
She adds,” WtE incinerators not only create debt traps for cities as maintenance and other operational costs are too costly to sustain but WtE incinerators also displace waste pickers and workers from the waste supply chain both physically and economically. Waste-burning facilities are often built at landfills and in so doing, uproot waste pickers from their communities and deprive them of their source of livelihood. This will happen for at least two decades once a plant is operational and will suck public funds away from improving their livelihood.”
In the Philippines, ADB was instrumental in providing policy advice in favor of WtE, marketing and assisting local government units to accept and review bids despite a standing ban on incinerators through various technical assistance projects. Cebu City was one of the city recipients of technical assistance from ADB which results in an increasing number of WtE incinerator proposals in the City endangering protected areas and communities.
“The ADB is the largest development investor on WtE incinerators and we strongly recommend the cessation of their support. They are burning the planet, our money, and our lives.” Azurin asserts.
This week, it’s time for action and to stand against waste incinerators, GAIA Asia Pacific and allies are calling out governments and businesses, the ADB in particular, to phase out incineration and invest in clean energy solutions. Incineration is a false solution to the waste problem. It is dirty, dangerous, and too expensive for developing countries to afford. We need to move forward to a Zero Waste future.
GAIA is calling on to immediately:
Have a moratorium and retirement of all existing incinerators;
Cancel all planned incinerator projects; and
Stop all support for new incinerators.
The Day of Action Against Incineration will feature a variety of events and here are some ways you can participate in the Day of Action Against Incineration:
Write to your elected officials and tell them to stop funding incinerators.
Contact financial institutions and tell them to stop investing in incinerators.
Spread the word about the dangers of incinerators on social media and in your community by joining us using these hashtags: using the hashtags #FalseSolutionsExposed, #Burnt,and#DayofActionAgainstIncineration
Together, we can create a better future without incinerators.
For photos and videos of the Day of Action Media Briefing at the Saturday News Forum, click here.
Yobel Novian Putra, GAIA Asia Pacific Climate and Clean Energy Officer | email@example.com | +62 821 2818 4440
No More Excuses, ADB! Prioritize Sustainable Solutions and Stop Funding Harmful Waste-to-Energy (WtE) Incinerators
02 May 2023 – The Asian Development Bank (ADB) is increasingly promoting waste-to-energy (WtE) projects in its energy and urban development portfolios as a way to achieve low-carbon economies and sustainable cities. However, according to GAIA Asia Pacific, this approach will have negative consequences for the environment and informal workers in the waste sector in the region. They are likely to be the hardest hit by the Bank’s preference for WtE incinerators as a waste and climate solution.
After months of civil society campaigning on the environmental and social risks of WtE, ADB has approved its Energy Policy aimed at supporting low-carbon transition in the region still identifying WtE as a priority investment but emphasizing that priority goes to reducing waste generation, then exploiting the options for reusing and recycling materials, then using waste to recover energy or usable materials and securing livelihoods . However, ADB approved a 20 million USD loan for a WtE project in Binh Duong Province, Vietnam without clearly following the order of priority. This is very disappointing because ADB’s previous 100 million loan WtE project in Can Tho (Vietnam) has failed to comply with its safeguards policy, particularly on dioxins monitoring — a highly toxic substance acknowledged by the Stockholm Convention and the World Health Organization (WHO). WtE incinerators also figure as a replacement fuel in ADB’s Energy Transition Mechanism (ETM) for repurposing of early-retired coal-fired power plants.
WtE incinerators displace waste pickers that provide important roles in the segregation, collection, transport, storage, and recycling of waste. WtE plants are designed to operate and burn resources for at least 20 years. They are highly dependent on dry, mostly recyclables, especially plastic — which is derived from fossil fuels. They rely on income from selling recyclables and as a result, divert waste from landfills causing environmental pollution and methane emissions. “In some cases, the establishment of WtE incinerators can also lead to the displacement of waste pickers from their homes and communities, exacerbating their already precarious economic situation,” said Yobel Novian Putra, GAIA Asia Pacific’s Climate and Clean Energy Campaigner.
The ADB must prioritize sustainable waste management solutions such as composting, recycling, and waste reduction programs. These solutions not only reduce the amount of waste sent to landfills or incinerators, but they also create local job opportunities and reduce greenhouse gas emissions. Furthermore, prioritizing sustainable solutions empowers communities to manage their waste and supports the informal waste sector, creating a more equitable and just transition.
“Financing for WtE incinerators works against waste pickers. ADB must recognize the rights of waste pickers including their historical, social, and economic contributions they provide to society. To date, ADB’s WtE incinerator and waste management projects have not considered the impacts of their interventions on waste pickers’ livelihoods,” said Kabir Arora, National Coordinator of the Alliance of Indian Waste Pickers. “Instead, they must support communities’ efforts towards recognition of waste pickers and a full range of programs to ensure that interventions are fair for waste pickers.
AIW stressed that ADB’s just transition program must emphasize supporting waste pickers and other workers who are most vulnerable to occupation disruption from waste management investments and climate change. It must build and improve upon systems that waste pickers have already established while guaranteeing, better and decent work, social protection, more training opportunities, appropriate technology transfer, support for infrastructure and organizing of workers, and greater job security for workers at all stages of the waste sector. Arora further added that waste pickers groups must be part of the design, monitoring, and evaluation of projects.
Putra stressed, “WtE incinerators are not a solution to the pressing issues of waste and energy. They release nearly 1.1 tonnes of carbon dioxide (CO2) into the atmosphere for every tonne of waste burnt. In many studies, an incinerator emits more greenhouse gas than a coal-fired power plant.”
These emissions also pose serious health risks to nearby communities, emitting harmful pollutants such as dioxins, furans, and heavy metals, which can cause respiratory problems, cancer, and developmental disorders. Moreover, the toxic ash and other waste products generated by such facilities pose a significant challenge to safe disposal.
Investing in WtE incinerators comes at a significant financial cost, increasing waste management expenses, and posing a significant financial risk to cities and municipalities. Taxpayers bear the burden of these costs through false subsidies taken from national and local government budgets to sustain the operation of incinerators for 20-25 years.
Further, Deputy Director of GAIA Asia Pacific Mayang Azurin argued for the urgent need to redirect funding towards sustainable solutions. “Continued financing of WtE incinerators, carbon storage, and other false solutions is not the path to decarbonization and Asia’s recovery and energy transition,” she said. “There is no time to waste. It is urgent that we prioritize the health of our planet and communities over corporate interests.”
GAIA AP urges ADB to reaffirm its commitment to sustainable development and shift funding towards proven zero waste solutions. GAIA calls ADB to cease funding harmful waste-to-energy incinerators and prioritize sustainable waste management solutions that empower communities and protect the health of the environment and communities.
Dear ADB President Asakawa, Managing Director Woochong Um, VP Ashok Lavasa (Private Sector Operations), and Members of the ADB Board of Directors,
We are writing to collectively urge an immediate reconsideration of the proposed financing for a new waste-to-energy (WTE) incineration project in Binh Duong Province, Viet Nam (Project Number: 56118-001). Formally reported as “Viet Nam: Binh Duong Waste Management and Energy Efficiency Project”, once operational, this project is expected to burn 200 tons of industrial and municipal solid waste per day.
This letter outlines the key reasons why the project should be urgently put on hold until it is revised rather than proceeding to the Board for approval, specifically: 1) in light of the absence of a finalized guidance note on WTE as mandated by the new 2021 Energy Policy (required to provide specific screening measures at all stages of the project cycle) to meet the requirements of paragraph 71 of the policy that the choice of feedstock is a result of a prudent order of waste management and WTE will be the last option, approving this project would be a breach of due process; 2) the lack of any evidence-based information to illustrate how the project will actually tackle climate change and support making cities more liveable as per operational priorities of ADB’s Strategy 2030 (see the Project’s Initial Poverty and Social Analysis); 3) the unsubstantiated claim that WTE incineration is a viable source of renewable energy source; 4) high risk of safeguards violations in light of the lack of clarity how the implementing company’s own ESMS can be relied upon when across the region, WTE incineration plants systematically circumvent national pollution control laws while undermining standards upheld by international conventions.
Below, we elaborate why deploying the ADB’s limited resources to facilitate the building of such an unnecessary, risky, and resource-intensive project lacks foresight — most especially given the urgent need to support borrowing member countries to rapidly scale up options for reliance on locally relevant, decentralized renewable energy generation, and waste management systems.
Background: Missing guidance notes on WTE incineration
We are alarmed by the fact that this project is proposed in the absence of the staff guidance note on WTE. Until today, the guidance note has not been finalized and made publicly available. In our latest conversation with senior management-level staff in the Sustainable Development and Climate Change Department, it was made clear that the guidance notes will be applied before the approval stage of a project cycle. As mandated by the new Energy Policy, the staff guidance will elaborate upon the screening criteria for ADB operations involving natural gas, large hydropower plants, and WTE plants. On WTE, the guidance note should provide criteria to ensure that the feedstock used in ADB’s proposed projects on WTE incineration will follow “a prudent order of waste management priorities”. This means, before WTE incineration is considered to be installed, ADB operations must ensure first the reduction of waste generation, material reuse, and recycling to take place.
The guidance note on WTE must reinforce and not undermine paragraph 71 of the new Energy Policy, ensuring prioritization of waste management options in which WTE incineration is the last option. WTE incineration is an end-of-pipe solution to waste. Its existence does not stimulate higher and more important solutions for waste management which are reduction, reuse, and recycling. In fact, it disincentivizes upstream solutions due to its huge financial implications for local governments’ budgets through the high cost of construction and operational costs. In many cases, national governments need to subsidize the tipping fee, feed-in tariff, or false renewable energy subsidy.
There is no clear evidence-based rationale for the Board to approve the WTE incineration component of this non-sovereign loan worth USD 7 million before the guidance note is in place and duly adhered to by ADB staff. The project does not indicate any means to reduce waste generation, such as first supporting the implementation of a ban on single-use products and packaging, a deposit-refund system, or local programs to promote reuse and refillable containers, food loss and food waste prevention — all of which could in fact help make the cities in the project area more livable. The project also does not include a component of material recycling for recyclable metal, plastic, paper, and cardboard. Additionally, it is also unclear whether the composting plant will treat source-separated waste or mixed waste — a critical factor in ensuring a high-quality organic management process. Lastly, there is no initial analysis on waste composition and generation conducted to justify that the WTE component has followed a prudent order of waste management priorities.
Given the absence of a guidance note, there is no way for civil society to verify how the implementing company, BIWASE, will adopt the best internationally available standards in accordance with international conventions as mandated by the new Energy Policy. In this regard, we note with concern that the company’s website also does not list any intent to follow international guidelines for emissions or other environmental, health, and safety standards.
Support for WTE incineration would also hamper efforts to avoid harming livelihood opportunities for the poorest of the poor working along the waste value chain as required in the new Energy Policy. WTE incineration facilities create the least jobs compared to composting, recycling, remanufacturing, and repair. Therefore, it will most likely lead to an extensive loss of employment and loss of livelihood for those working in the informal waste sector. Furthermore, the presence of incineration plants also typically lead to a drastic loss of income for the informal waste sector. This happens because incinerator plants demand a constant and huge amount of waste with high-calorific content which is found in recyclables. Expansion of WTE incineration capacity would also contradict Viet Nam’s national recycling targets.
WTE incineration is not a low-carbon investment
The claim that this project is aligned with the operational priorities of ADB’s Strategy 2030 —in particular the key operational priority on tackling climate change— is very concerning to us as civil society organizations directly advocating for climate, energy, social and economic justice. Waste incineration projects are heavily reliant on burning plastic. This makes WTE incineration plants no different than any other fossil-powered energy generation system. Incinerating plastic which is 99 percent made of fossil fuels emits 2.7 tonnes of CO2e for every tonne of plastic burned. Further, when energy is recovered, incinerating one tonne of plastic still results in 1.43 tonnes of CO2e — way higher than real renewable sources such as wind and solar.
WTE incineration is not a low-carbon technology; in fact, it is more emission-intensive than the average emission intensity on the grid, including coal-fired and gas-fired power plants. In both the U.S. and the E.U., WTE incineration is considered among the dirtiest sources of energy and the most emissions-intensive form of power generation on the grid. The US Environmental Protection Agency states that incinerators emit more carbon dioxide per megawatt-hour than coal-fired, natural-gas-fired, or oil-fired power plants. A recent scientific paper further proves that incinerators emit more greenhouse gas emissions per unit of electricity produced than any other power source. This finding is corroborated by a study on European incinerators which shows that the carbon intensity of electricity produced from WTE incinerators is twice the current European Union average electricity grid intensity — significantly greater than energy produced through conventional fossil fuel sources.
Lastly, waste incineration has no place in any decarbonization plans. WTE incineration facilities are expected to operate for about 25 years with significant GHG emissions as explained above — causing both carbon lock-in and feedstock lock-in effects. This hinders countries from achieving their climate targets and improving their waste prevention and recycling rate. This process would also encourage more extraction of resources, since discarded materials have been destroyed rather than recovered, thus indirectly contributing to more emissions.
Municipal and industrial solid waste is not a renewable energy source
The Intergovernmental Panel on Climate Change (IPCC) defines renewable energy as energy created from natural processes that do not get depleted, such as bioenergy, direct solar energy, and those derived from wind, or ocean. IPCC also states that only the organic component of municipal solid waste is considered renewable. Hence, fossil components of waste streams such as plastic materials are non-renewable. In the case of this project, 840 tons per day of organic waste would be taken by the composting facility. Thus, it is likely that WTE will rely on burning non-organic waste fraction, especially fossil-derived plastic.
Additionally, both municipal and industrial solid waste contains recyclable and reusable materials lost from the economy that needs to be re-mined, re-grown, and re-manufactured which incinerators destroy. Reuse and recycling also save more energy and prevent more greenhouse gas emissions compared to waste incineration. Therefore, investments in burning discarded materials such as plastic, paper, and glass that are derived from finite natural resources undermine climate goals.
Labeling WTE incineration as a renewable energy source project has severely unjust energy transition implications. This fact is well reflected in the U.S. where waste incineration is considered one of the most expensive ways to generate energy. A more recent study also shows that WTE incineration is nearly four times higher than solar power and onshore wind energy and 25 percent more expensive than coal-fired power plants. WTE incineration also reflects the weak financing model for an industry that has become increasingly dependent on renewable energy subsidies to stay afloat.
Potential safeguards violation of WTE incineration projects
We question the project environment safeguard categorization as well as the suggestion in the Project Initial Poverty and Social Analysis that it will make surrounding cities more livable. The project is currently categorized as a Category B. WTE incinerators cause long-term public health and environmental damage. Case studies of waste incineration projects throughout Asia and the Pacific have unequivocally demonstrated causal connections to adverse and irreversible environmental impacts. Paragraph 36 of ADB Safeguards Policy 2009 (SPS 2009) requires borrowers to avoid any release of hazardous substances and materials subject to international bans and phaseouts. This clearly conflicts with two international conventions. Both Minamata and Stockholm conventions have identified waste incineration as a major source of mercury and dioxins which are highly toxic and must be phased out immediately.
This project also does not reflect compliance with SPS 2009. In paragraph 35, the borrower is mandated to minimize the generation of hazardous and non-hazardous waste resulting from project activities. WTE incineration does not eliminate waste as it only converts domestic waste into toxic waste in the form of ash. For every four tons of waste burnt, it is expected that there will be at least one ton of toxic incinerator fly ash and bottom ash. Furthermore, paragraphs 34 and 35 also require borrowers to prioritize waste prevention, reuse, and treatment (i.e. composting and recycling) — compliant with resource conservation principles and a prudent order of waste management priorities. Similarly, Viet Nam national law on Environmental Protection also mandates all organizations to prioritize upstream preventive measures.
A report by IPEN shows that toxic ash and other residues from waste incineration around the globe contain dioxins, furans (PCDD/Fs), and a range of other highly toxic Persistent Organic Pollutants (POPs), which occur at levels threatening to human health and the environment. Also, WTE incineration emits fine and ultra-fine particles that contain high amounts of toxic compounds and pose a serious threat to the environment and human health.
The Danish Environmental Protection Agency released findings showing that the Norfos incineration plant has repeatedly exceeded the limit value for toxic emissions for dioxins and furans since 2014. More recent research conducted in Kaunas (Lithuania), Pilsen (Czech Republic), and Valdemingomez (Spain) show that WTE incinerators contribute to high dioxin levels in the vicinity of the plants. Long-term studies from state-of-the-art WTE incinerators in Harlingen (the Netherlands) and Sant Adrià de Besós (Spain) reveal emissions of toxic pollutants far beyond the limits set by EU laws. A similar long-term study in 2019, showed that UK incinerators breached their air pollution limits 127 times — with five different facilities reporting more than 10 permit breaches. There were 96 hours of abnormal operations where toxic pollutants such as dioxins are very likely to be released and not monitored.
The toxic contamination is not incidental, but systemic as shown by the recent news of Lausanne dioxin contamination in Switzerland. The country’s fourth-largest city is currently trying to cope with the effects of a recent discovery of wide-scale soil pollution caused by toxic compounds from an old garbage incinerator. This incident has caused an EU-wide investigation into impacts at other incinerator locations and should be a wake-up call for the ADB management – it is time to end support for WTE incineration.
Incinerator bottom ash from burning waste also contains significant total concentrations of elements that are a ‘high level of concern’ based on EU REACH hazard classifications. For example, studies from a municipal solid waste incinerator in Phuket (Thailand) have shown that the ash emitted contains high concentrations of dioxins. The accumulated ash is stored adjacent to the plant and near the coastline, without protective barriers to prevent dioxins from leaking into the sea. Close to the plant, it was found that some of the fish and shellfish samples, also wild bird eggs, had elevated POPs levels. Furthermore, there is growing evidence that waste incineration exacerbates microplastic contamination in surrounding areas, for example, up to 102,000 microplastic particles are found per metric ton of waste incinerated.
The national regulation on industrial waste incineration also uses lower safeguards standards on dioxins emission in flue gas (QCVN 30: 2012/BTNMT). The emission standard for dioxins in flue gas is 0.6 ng TEQ/Nm3. That is six times lower than the Industrial Emissions Directive (2010/75/EU) of the European Parliament (EU IED) standard which set 0.1 ng TEQ/Nm3 for dioxins emissions in the flue gas. Additionally, the national law on Environment Protection also only requires once a year dioxins and furans monitoring in incinerator wastewater and flue gas — which is less than what is required by the EU IED on the monitoring frequency.
We note with concern that in the past, ADB has also supported one WTE project in Viet Nam which has been reported as non-compliant with ADB SPS yet remains to be in operation to this day. This first ADB-funded WTE plant in Viet Nam (Project Number: 50371-001) is located in the solid waste treatment area of Xã Trường Xuân Commune of Thới Lai District, which is 36 km from Cần Thơ City. According to the ADB’s own Environmental and Social Monitoring Report and Annual Environmental and Social Performance Report, there are several instances of significant safeguards violations (SPS 2009; Safeguard Requirement 1: Environment; paragraphs 33, 34, 35, and 36).
Lack of monitoring of toxic persistent organic pollutants
In 2019, the operator of Cần Thơ WTE plant has signed an MoU with ADB providing assurances that the Plant shall meet the emissions limits based on the EU IED. This directive is often referred to as the best international standard on WTE incineration.
In the reports, dioxins and furans are not monitored continuously, but rather only monitored once every three months by third-party laboratories. Moreover, these toxic pollutants are only measured over an average sampling period of two hours. In practice, this would only represent 0.1% of the total operation time per year. Even if the measurement of dioxins and furans meets the limitations stipulated in the EU IED, the sampling period is recorded for only six to eight hours; i.e. representing 0.4% of the annual operation at best.
Lack of testing parameters for toxic pollutants
The Environmental and Social Monitoring Report has highlighted several missing testing parameters for the incinerator bottom ash, including those related to heavy metals, dioxins, and furans. It also underscored the lack of capacity of local government authorities to manage toxic incinerator ash adequately. In fact, Cần Thơ City Government does not have any safeguard measures for securing incinerator toxic ash. Currently, the city government is still in the planning stages for developing a fly ash landfill within the solid waste treatment area in the Thới Lai District. Notably, the EU IED also requires monitoring of dioxins contained in WTE incineration wastewater. Yet, no such measurements are reported from Cần Thơ WTE.
Lack of meaningful consultations and insufficient information disclosure
Crucially, ADB’s own Environmental and Social Monitoring Report of the respective project also indicates the need to conduct additional consultation to ensure affected communities around the site are fully informed of the project. The report highlighted that the project needs to inform local communities about the grievance system. From our perspective, it is also critically important that ADB and project staff communicate the potential risks of toxic emissions and ash released from the plants to surrounding households in a language they understand.
These three concerns are indicative of the serious risks from WTE incinerators, which as recognized by international laws and growing evidence even in countries with superior regulatory environment, has to be avoided than mitigated. Without any requirement that mandates continuous sampling and information disclosure from emission monitoring activity, WTE incineration plants pose significant health risks to local communities. It is crucial to ensure the establishment of working project grievance mechanisms that enable secure, independent reporting channels to avoid risks of reprisals and retaliation. This should be accompanied with regular meaningful consultations with the affected communities, conducted in a language they understand, in spaces where they can express concerns and raise questions free of fear of reprisals. In cases where serious safeguards requirements are not fulfilled, the Board must withdraw from these projects.
In light of the above information, we are calling on the ADB to 1) decisively withdraw the WTE component from the proposed Binh Duong Waste Management and Energy Efficiency Project (56118-001); 2) publicly disclose the guidance note on WTE online; and 3) include compliance with the guidance note as a mandatory provision on the project data sheet if/when new WTE projects are proposed — allowing civil society groups and local communities to follow up accordingly. At a minimum, taking these steps would help provide a basis for clarity for civil society and community groups to evaluate whether and how the Bank is diligently prepared to follow a prudent order of waste management priorities in its project investments and ensure a transparent set of screening standards are firmly in place for staff and project proponent guidance.
We look forward to your timely response. Thank you.
Won Myong Hong, Project Officer, Private Sector Operations Department
Suzanne Gaboury, Director General, Private Sector Operations Department
Christopher Thieme, Deputy Director General, Private Sector Operations Department
Priyantha Wijayatunga, Chief of Energy Sector Group, Sustainable Development and Climate Change Department
Bruce Dunn, Director, Safeguards Division
Manila – The Global Alliance for Incinerator Alternatives (GAIA) – Asia Pacific condemns the continued promotion and commitment of the Asian Development Bank (ADB) to invest in Waste-to-Energy (WTE) incinerators. It has also relentlessly shaped country and regional energy and climate policies and guidelines to include this polluting technology as a renewable or clean source of energy.
The ADB has conducted the last four days of the Asia Clean Energy Forum (ACEF) as a virtual marketing platform for the WTE industry and its backers to sell this technology to governments and development planners. While WTE promoters enjoyed speaking spaces to promote its false solutions, there was no space provided for communities and grassroots organizations to challenge the purported promises of environmental, social, and financial opportunities from WTE incinerators and to be heard on how these technologies impact their health, jobs, and their environment. In summary, the ACEF has been nothing but an arena for industry polluters in shaping the narrative of what a low-carbon energy mix should look like for the region.
Investing in WTE incinerators undermines national and global goals to keep temperatures at 1.5 degrees and achieve resilience amid the urgency to act strongly on climate, health, and fiscal emergencies in the region. Incinerators are dirtier than the rest of the grid. Per unit of electricity output, they emit 3.8 times as much greenhouse gases — 1.9 times as much carbon dioxide, 15 times as much nitrous oxide and methane, and 66 times as much biogenic carbon dioxide as the grid average. WTE incinerators are also known to create persistent organic pollutants as byproducts of their operations.
The ACEF’s silence on the impacts of WTE incinerators on poor and marginalized communities. WTE incinerators are always placed beside low-income communities that cause long-term, multi-generational health impacts from toxic air and groundwater pollution. WTE also threatens informal workers in the waste sector and poses a threat to the generation of green jobs as these facilities wipe out opportunities by burning waste that should have been up for recycling. WTE destroys the resilience of the poor and marginalized communities and should have no place in the just transition.
Instead of bringing toxic energy and unsustainable debts, we urge the ADB to invest more in environmental waste management priorities which begins with waste reduction, reuse, to recycling instead of incinerating precious and finite resources.
The ADB, as a development bank, whose aim is to eradicate poverty and achieve sustainable development in the region should also cease in shaping the narrative that industry polluters are the drivers of innovation on energy, waste, and inclusion. This narrative negates the existing Zero Waste practices and communities that sustainable waste management patterns in the Asia Pacific.
We are also deeply concerned that the newly-adopted ADB Energy Policy 2021, which states that investments in WTE incinerators shall flow only after meeting the following requirements 1) after careful consideration of their political, social, and environmental contexts and in accordance with international conventions, 2) provided that the feedstock for combustion results from a prudent order of waste management priorities, and lastly 3) first reducing waste generation, then exploiting the options for reusing and recycling materials, remains to be an empty promise. To date, we have not seen any guidance framework to ensure that these precautionary measures and priorities are in place. We strongly call for the immediate implementation of this policy requirement immediately.
We call on the ADB to stop undermining national and global development objectives and align its investment policy to the requirements of the Paris Agreement, international instruments, and other development objectives for a truly just and resilient path to net zero. ####