‘Waste-to-energy is contradictory to clean air, protection of public...

‘Waste-to-energy is contradictory to clean air, protection of public health’


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I hope that today and in the coming months, we can have conversations on climate solutions applicable at the local level.

Since representatives of the World Bank representatives are here in Dumaguete, I will take this opportunity to comment on their Country Climate & Development Report for the Philippines. The report offers a deep dive into the impacts of climate change on agriculture, water, energy, and transport, and recommends priority actions. The description of the range of impacts of climate change on the Philippines is worth the read.

There is value in a multilateral institution highlighting the urgency and the range of potential impacts of climate change, if it can move national and local governments to take urgent action, instead of the lip service or ineffective response that is often proffered.

I remember in a previous Climate Action Tracker assessment, the country’s Nationally-Determined Contribution, of which 72.29 percent is conditional, was compatible to a 1.5°C target, but planned policy projections were way off.

Even when the Philippines submitted its NDC in April 2021, the Philippine Energy Plan envisioned an additional 2.64 gigawatts of new coal-fired power plants, and had no plan to phase-out coal-fired generation.

In October 2022, the Department of Energy announced a much-welcome moratorium on new coal-fired plants, but that was after a rash of approvals that ensured the dominance of coal in the power mix for many years to come.

The climate agenda is coordinated by the Climate Change Commission but implementation relies on more powerful departments like DOE, and increasingly on local government units with limited resources and technical capacity.

Thus, the NDC is aspirational, and a lot more has to happen for a net reduction in emissions by 2030.

The prominent role of coal in our primary energy mix makes me concerned with one specific recommendation of the World Bank’s CCDR: accelerating the adoption of electric vehicles (on p. 37) while reducing urban pollutant emissions from mobile sources will support a net carbon reduction if solar and wind power with energy storage can increasingly displace coal sooner than later. That is a big if.

At the local level, Silliman University has taken actions consistent with some recommendations in the CCDR. For example, Silliman installed about 100 kilowatts of rooftop photovoltaics in 2016, and even then, was prepared to expand to one megawatt of solar, but was limited by the 100-kilowatt limit set in the Renewable Energy Act — a barrier to rooftop solar in the commercial and institutional sectors for years until the barrier was removed only a few months ago.

Today, the University is powered by renewable energy through a clean energy contract. Silliman’s research on climate adaptation for communities along flood-prone rivers, its participation in the Fish Right Program to increase fish biomass in marine key biodiversity areas, its research on coastal resource management, mangrove conservation, and other projects deal with both climate mitigation and adaptation.

There is a lot in the 82-page CCDR for national and local decision-makers to study. I would like to focus my comments on three issues. I hope my critique is accepted in the spirit it is given, with the intent of being constructive as we all strive for solutions.

1) Ecosystem-based solutions. In our work at Silliman, we have found that ecosystem-based mitigation and adaptation have much to offer. The CCDR makes bare mention of nature-based solutions but I hope future versions of the CCDR could expand on these further.

2) Just transition and social safeguards. The CCDR recognizes the importance of a “just transition”. But the just transition process should not just be an add-on after decisions have been made (such as re-skilling or relocation after workers have been displaced) but should also mean the involvement of affected communities in the decision-making process itself.

For example, the CCDR recommends revising the Free Irrigation Service Act (p. 23) which waived irrigation service fees for farmers with less than eight hectares. The CCDR argues that the Irrigation Act discourages water conservation.

But the Irrigation Act is a social equity issue since most of the beneficiaries are poorer than the average household, although not all are poor.

Under a just transition process, affected farmers should be consulted, and from them may come other approaches to scaling up alternate wetting and drying technologies, and other climate-smart approaches without putting a disproportionate burden on the poorest farmers.

3) Other Planetary Boundaries. Today, we are beginning to understand the safe planetary boundaries within which humans thrive; these are biophysical/chemical thresholds which, if exceeded, puts us at great risk of triggering abrupt, rapid, and non-linear environmental changes with disastrous consequences.

These planetary boundaries are linked. One such boundary we have exceeded is CO2 concentration, resulting in climate change.

But we are also faced with an unprecedented global crisis of massive and rapid loss of biodiversity, so much so that we may be facing a sixth mass extinction event.

We are also seeing biogeochemical flows of phosphorus and nitrogen, causing dangerous changes to aquatic and marine systems.

Other planetary boundaries we have exceeded relate to global fresh water overconsumption, land-system changes with massive destruction of forests and other ecosystems due to agricultural expansion and intensification, and the planetary boundary for novel entities (i.e., hazardous chemical waste, persistent organic pollutants, plastic waste, forever chemicals, endocrine disruptors, and other environmentally-persistent bio-accumulative toxic substances now widespread in our environment).

I mention these because I believe that policy recommendations must always be conscious of other global threats, otherwise, we risk addressing one problem while exacerbating another.

For example, the CCDR mentions financing of dams for energy generation, and managing water flows due to rainfall changes (p. xxiii). But this [goal] ignores the massive contribution of large dams to biodiversity loss and land-system changes.

I would like to focus on one final example of the CCDR which calls for private sector promotion of waste-to-energy incinerators (p. 40), and recommends rescinding Sec. 20 of the Philippine Clean Air Act .

The total carbon dioxide equivalent of thermal waste-to-energy incinerators is 1.7 times more than coal-fired plants per kWh of energy generated, especially if much of the waste are high-caloric-value plastics virtually all of which are fossil-based.

The fossil carbon intensity of waste-to-energy in the European Union is 1.9 times higher than that of the average EU electrical grid.

Thus, waste-to-energy solutions undermine decarbonization, and shift investments away from low-carbon solar and wind.

Furthermore, promoting waste-to-energy ignores its major contribution to transgressing the planetary boundary for novel entities, especially persistent organic pollutants like dioxins, which the Philippines has no technical capacity to monitor continuously.

The lock-in effect of waste-to-energy incentivizes the consumption of more plastics, and the creation of waste to feed the technology, thus, undermining efforts at Zero-Waste and pollution prevention, waste- reduction, reuse, recycling, and composting, hence, undermining the move to a circular economy.

This was the same conclusion of the European Union’s Technical Expert Group on Sustainable Finance when they agreed in their EU Taxonomy report that waste-to-energy is not sustainable finance.

Ocean Conservancy made the same conclusion recently, rescinding their 2016 recommendation promoting waste-to-energy, and issuing an international public apology for undermining decarbonization and Zero- Waste.

This issue is of particular local concern because of the pyrolytic incinerator recently installed in Dumaguete. Not only does the pyrolitic incinerator worsen climate change, and undercut our local work on Zero-Waste, but the potential health impacts of the incinerator will affect all of Dumaguete, as well as large parts of Sibulan, Valencia, and Bacong.

I hope future CCDR versions evaluate all recommendations in relation to other planetary environmental crises, promote more ecosystem-based solutions, and remove waste-to-energy recommendations that are contradictory to decarbonization, a circular economy, clean air, protection of public health, and zero-waste.

On this Valentine’s Day, I leave you with a personal recommendation: Let us all show our love for Mother Earth by breaking off our love affair with plastics.

Dr. Jorge Emmanuel



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