‘Scotland’s incineration moratorium has more holes than Swiss cheese’, say activists

Environmental groups, including Friends of the Earth, have formally requested that Environmental Standards Scotland investigate the Scottish government’s “refusal to use its powers” to “curb” incineration.


Although the Scottish government created a moratorium on new waste incinerators in 2022, the environmental groups have said that its “failing” to stop incineration capacity from increasing.

In what is deemed as “loopholes”, the group has claimed that developers have continued plans to build incinerators, with Scotland’s largest incinerator permitted by SEPA to increase its tonnage by 17% (now 215,000 tonnes) since the moratorium was introduced.

The Scottish Government’s 2022 independent review on incineration found that, if plants are allowed to develop as planned, Scotland will have “more incineration capacity than waste to burn by 2027”.


The environmental groups have said that ministers have “repeatedly refused” to “use their legal powers” to temporarily pause the issuing of incinerator permits whilst measures to close loopholes in the moratorium are put in place.

Kim Pratt, circular economy campaigner from Friends of the Earth Scotland said: “The Scottish Government is turning a blind eye whilst Scotland’s waste burns, causing harmful pollution and blocking effective management of our resources. It has the power to halt the increase in incineration today, but it has repeatedly refused to act, despite the clear evidence of loopholes in its incinerator ban.

“This is a failure of the Scottish government to protect the people of Scotland from the harmful pollution and climate impacts of incinerators. This government is putting the profits of big businesses before the welfare of its citizens.

“Incinerators built now will prevent Scotland from meeting environmental commitments for decades to come so the Scottish Government must immediately stop incinerator permits being issued until it has set a cap on incineration as it promised to do.”

‘Leaky moratorium’

Ben Christman, in-house solicitor at Environmental Rights Centre for Scotland, said: “The Scottish government’s ‘incineration moratorium’ has more holes than Swiss cheese. Despite telling the public they wanted to reduce Scotland’s incineration capacity, ministers’ refusal to use their powers over the past two years means that capacity has got even bigger.

“The Scottish government’s unwillingness to stand up to these waste companies is bad news for climate change and people living near incinerators. We’ve asked Environmental Standards Scotland to investigate and force the Scottish government to patch up their leaky moratorium.”

Shlomo Dowen, national coordinator, the UK Without Incineration Network said: “Scotland is continuing to drift in the wrong direction. For the sake of the climate, air quality and the circular economy, the Scottish government should be publishing an incineration exit strategy, not allowing yet more damaging incineration capacity to go ahead.”

‘Local activists’

Rebecca Glen from Irvine Without Incinerators said: “We know that if every incinerator that is currently in development goes ahead, Scotland will be overcapacity by 2027. We believe that Irvine is the wrong place for such a project, due to the excessively high rates of deaths and hospitalisations due to respiratory disease in North Ayrshire.

“It shouldn’t be left to local activists to challenge the construction and operation of these incinerators without any support – the Scottish government should respect not only the letter, but the spirit of their moratorium on incineration and intervene before they completely lose the trust of people who recognise the need to move away from incineration and towards a circular economy model. Studies show a direct correlation between rates of incineration rising and rates of recycling declining and this is the opposite direction of where we should be headed.”

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