BIGGER PICTURE: Is waste-to-energy a waste of energy?

Second of three parts

Editor’s Note: This featured study is prepared by Green Juris Organization of the Ateneo de Davao College of Law. We are publishing the entire study in a series showing this independent study on the Davao City Waste-To-Energy incineration project.



While Waste-to-energy facilities seem ideal, it does come with serious drawbacks: they are expensive. Incinerating waste requires costly infrastructure and highly trained staff to operate it, entailing significant financial outlay. In Davao City alone, the proposed WTE facility costs P6 Billion and calls for at least P3.5 billion counterpart from the government for its implementation.

According to GAIA (2021), building a waste-to-energy incineration is the most expensive in capital expenditure and operational expenditure compared to other waste management options such as composting, anaerobic digestion, and landfills. It provides that the operational costs is are generally comprised of the manual labor of the skilled workers, fuel, and equipment maintenance which also includes the Environmental Compliance Certifications (EECs) with respect to air emissions, wastewater treatments, and ash disposal.

Incineration facilities, by burning solid waste, constantly need to improve their pollution control equipment to comply with differing and changing emission regulations. In some countries, more waste-to-energy facilities have shut down and are starting to shut down due to costly upgrades and changing emission regulations, as the revenues from energy are not sufficient to cover the operational expenditures. In the United States, thirty-one (31) municipal solid waste incinerators closed between the years 2000, and 2020, due to financial burden caused by costly upgrades and maintenance to comply with pollution control requirements.

Operational expenditure of different waste management options (USD/Tonne)

Studies show that WTE incineration costs more than natural gas, solar and wind energy. Another point of contention is that Waste-to-energy incineration is an inefficient way to generate energy. Burning waste for energy costs more than most existing energy sources per same unit of energy. It costs 4 (four) times more than solar power and wind energy, and costs twice as much as natural gas. Waste-to-energy incineration is even more expensive than coal power by 25%.


The lingering concerns raised by the implementation of a WTE facility in Davao City spring further than the financial costs it would entail for its completion as it posits environmental hazards in the caused by emissions. ClientEarth Communications (2021) posits that “electricity generation at incinerators will soon become closer in carbon intensity to coal and gas than to wind and solar. This is because increasing the proportion of hard-to-recycle plastic waste sent to incinerators will increase the carbon impacts of incineration. Plastic is derived from crude oil and the carbon is released when burnt. So, while the electricity grid should be decarbonizing as a result of more renewable energy sources coming online, electricity produced at the incinerator will become a major climate issue”.

According to the study conducted by Global Alliance for Incinerator Alternatives (2019), each phase of the process of incineration, it results in pollution.

Most heavy metals cause environmental and atmospheric pollution and may be lethal to humans. Heavy metals can become strongly toxic by mixing with different environmental elements, such as water, soil, and air, and humans and other living organisms can be exposed to them through the food chain.
Even with modern particle filtering of the flue gases, a small part of fine particles are emitted to the atmosphere. These heavy metals and fine particles have been repeatedly correlated spatially to infant mortality in the United Kingdom.


There are many ways people may ingest or come in contact to airborne pollutants. Those that are present in air emissions, water and residues may enter our system through simply breathing the harmful air, consuming the contaminated water, eating the by-products of contaminated land and vegetation, and cooking fish, meat or other food products that were exposed to the pollutants.

While it is true that the WTE is not yet implemented, nor is it approved by the National Economic and Development Authority but there are data sources and existing epidemiological studies which provide sufficient evidence of the direct health impacts of incinerators. According to Rosenberg (2021), regardless of what is being burned (mixed municipal solid waste, plastic, outputs from “chemical recycling”), waste incineration creates and/or releases harmful chemicals and pollutants, including: (1) air pollutants such as particulate matter, which cause lung and heart diseases; (2) heavy metals such as lead and mercury, which cause neurological diseases; and (3) Toxic chemicals, such as PFAS and dioxins, which cause cancer and other health problems.

Due to increasing quantities of waste sent to incineration, incinerators will emit more toxins and pollutants that harm the local air quality. In this regard, WTE facilities will have a more significant negative contribution to air pollution as compared to sanitary landfills. Gaseous emissions from burning solid wastes are one of the major concerns with waste-to-energy incineration facilities. Gaseous emissions include nitrogen oxides, sulfur dioxide, hydrogen chloride, heavy metals, and fine particles. Furthermore, “nitrogen oxide, sulfur dioxide, Volatile Organic Compounds (VOCs), dioxins, and polycyclic aromatic hydrocarbons (PAHs) are all considered air pollutants that are harmful to humans. Carbon monoxide can even provoke direct poisoning when breathed in at high levels. Heavy metals such as lead, when absorbed into the human body, can lead to direct poisoning or chronic intoxication, depending on exposure. Diseases occurring from the said substances include principally respiratory problems such as Chronic Obstructive Pulmonary Disease (COPD), asthma, bronchiolitis, and also lung cancer, cardiovascular events, central nervous system dysfunctions, and cutaneous diseases”.

Moreover, Tait et al (2019) identified 61 (66%) papers that demonstrated a significant adverse outcome in relation to waste incineration. Of these, 34 (37%) showed exposure to elevated levels of known pollutants, nine (10%) identified an increased risk of developing some neoplasia, nine (10%) found a correlation with adverse reproductive outcomes, and nine (10%) found a link to other diseases such as hypertension or reduced lung function.


WTE undermines zero waste objectives, and the presence of incineration facilities encourages the production of more waste products within the city. For incineration facilities to operate effectively, it requires a constant supply of waste to burn. Thus, it diminishes the motivations of local or national governments to reduce waste at the source, because more solid waste means that the incineration facility can keep operating.

It is important to note that the onset of incineration will lead to a reduction in recycling efforts by the general populace as they become more aware of the fact that garbage and waste can be easily disposed of by burning rather than going through the effort of recycling.


Planned incinerator project would go against national laws such as the Philippine Clean Air Act, the Ecological Solid Waste Management Act and the Renewable Energy Act.
Republic Act No. 8749, otherwise known as the Philippine Clean Air Act, is a comprehensive air quality management policy and program which aims to achieve and maintain healthy air for all Filipinos. Philippine Clean Air Act has an explicit ban on Incineration, thereby defined as the burning of municipal, biomedical and hazardous waste, which process emits poisonous and toxic fumes is hereby prohibited. The exceptions merely included traditional small-scale method of community/neighborhood sanitation “siga”, traditional, agricultural, cultural, health, and food preparation and crematoria. The same section also outlines the mandate of local government units to promote, encourage and implement in their respective jurisdiction a comprehensive ecological waste management that includes waste segregation, recycling and composting. Finally, the same section emphasizes the promotion of the use of state-of-the-art, environmentally sound and safe non-burn technologies for the handling, treatment, thermal destruction, utilization, and disposal of sorted, unrecycled, uncomposted, biomedical and hazardous wastes.

On the other hand, Republic Act No. 9003, also known as Ecological Solid Waste Management Act of 2000, has as one of its policies the utilization of environmentally-sound methods that maximize the utilization of valuable resources and encourage resource conservation and recovery.

In addition, it makes express mention of the exclusion of incineration to the solutions to be implemented. To quote, “ It is hereby declared the policy of the State to adopt a systematic, comprehensive and ecological solid waste management program which shall ensure the proper segregation, collection, transport, storage, treatment and disposal of solid waste through the formulation and adoption of the best environmental practice in ecological waste management excluding incineration.”

As if it wasn’t more obvious, the Act further defines “resource recovery” to refer to the collection, extraction or recovery of recyclable materials from the waste stream for the purpose of recycling, generating energy or producing a product suitable for beneficial use with the explicit exclusion that such resource recovery facilities exclude incineration.

Finally, Republic Act No. 9513, or the Renewable Energy Act, while it indeed mentioned the exploration and adoption of waste-to-energy solutions, it made no mention of the use of non-recyclable and non-biodegradable waste as sources of energy. Said act clarifies what waste-to-energy technologies are covered: As used in this Act, waste-to-energy technologies shall refer to systems which convert to biodegradable materials such as, but not limited to, animal manure or agricultural waste, into useful energy through processes such as anaerobic digestion, fermentation and gasification, among others, subject to the provisions and intent of Republic Act No. 8749 (Clean Air Act of 1999) and Republic Act No. 9003 (Ecological Solid Waste Management Act of 2000).


An alternative to the waste-to-energy incinerator is to upscale recycling efforts at a local level. This prevents the introduction of harmful pollutants into the air and food chain starting with the individual consumer. It is clear that not all waste can be recycled; however, if recycling efforts are a success, it will likely result in a reduction in the amount of waste needed to be disposed of.

MRFs reduce the garbage streams from the households by simply segregating the recyclable materials such as glass, metals and plastics from the biodegradable materials. In an article by Colina IV (2023), it was mentioned that under Republic Act 9003 or Ecological Solid Waste Management Act of 2000, barangays need to establish materials recovery facilities (MRF) to receive, sort, process, and store compostable and recyclable materials. Out of 182 barangays in the city, only Barangays Tacunan, Mintal, Mahayag, Gumalang, Lapu-Lapu, Hizon, and Catalunan Grande have functioning MRFs.

If we exploited every available opportunity to recycle the plastic, metal, glass, rubber and other non-organic waste that gets discarded, and if we composted as much of our excess organic matter as we conceivably could, zero waste supporters say we could cut our garbage production by as much as 80 percent . Through reuse and repurposing, and detailed planning to reduce our creation of waste from the get-go, we could get rid of most of the rest, they argue—and for the most part they do so persuasively.


Waste Hierarchy Diagram: Mildred Williams

The Amended Waste Framework Directive of the EU (2018) ranks waste management options according to what has the best outcome for the environment. The waste hierarchy is a pivotal tool for policy making as it provides viable solutions on waste management. This is a tool for the framers of the law, national or local, to look into greener alternatives in the waste disposal.

First, prevention also includes reduction as it encompasses the utilization of less material. It technically entails not using anything at all which can contribute to the wastage. Thus, streamlining the design and manufacturing process and preventing large surplus or scraps and as a result excess waste. This stage includes the promotion of research and development into a cleaner, less wasteful products and technologies.

Second, on the reusing stage, it involves cleaning, repairing, repainting, refurbishing, and prolonging the use of the items in whole or in part.

Third, recycling. This is a very common term and the most popular among the stages. This involves the re-creation of solid waste materials into new substances or products.

Fourth, whenever waste backfills or replaces another material, this is recovery. This includes energy generation such as gasification and pyrolysis. Acid or base regeneration and reclaiming metals for re-use.

Finally, the disposal stage which comprises anything that could no longer be reused, recycled or recovered. This is where the landfills and incineration facilities fall.


Single use plastics are amongst the major culprits of the mass production of municipal wastes. A move from the local government banning the use of single use plastics for household, commercial and industrial use may reduce garbage in our locality.

The ban on single-use plastics has been implemented by several countries around the globe to reduce environmental pollution and promote sustainable practices. Single-use plastics include commonly used items such as plastic bags, straws, fast food cutlery, and packaging materials, designed to be thrown away after its first use.

Over 100 countries now have a full or partial ban on single-use plastic bags. Between 2010 and 2019, the number of public policies intended to phase out plastic carryout bags tripled. In Europe, 18 countries have imposed bans on thin plastic bags – including France, Germany, Italy, Iceland, and Albania.

With the proper utilization of the policy-making powers of the government and dealing with the violations with severity and imposition of penalties and taxes, businesses and individuals can help reduce plastic waste by embracing more sustainable options such as using reusable bags, bottles, and containers as well as proper disposal of reusable materials.


This paper is submitted as a reiteration of the Green Juris’ call for the protection, preservation, and conservation of our environment. The Organization believes that there is a need to divest and reject the option of putting up a WTE facility in Davao City as its negative impacts would far outweigh the positive.

There are already many environmental groups, Non-Governmental Organizations (NGOs), Farmers’ Groups and Academic Societies that are vocal about the proposed WTE facilities. We, at Green Juris also echo their sentiments. It is important to reinforce the notion that the environmental and health consequence we are yet to experience will not become mere isolated incidents by reason of underestimation. We highlight the probable impacts as we will not confront them only at one instance but in years and years to come and from generation to generation.

We believe that bringing about WTE technologies and facilities within our midst only present a band-aid solution as there have been studies already conducted that such post health and environmental risks. It also undermines community efforts on waste reduction, recycling, and recovery efforts. The support we need should be geared towards actual, sustainable solutions.

With these, we respectfully present our alternatives in place of the said project:
1. Upscaling segregation, recycling efforts and funding of material recovery facilities in the barangay and purok levels;
2. Approach policy-making directives through waste hierarchy; and
3. Ban on single use plastics.

Furthermore, we urge our Davao City Council to conduct thorough scientific an public consultations that would provide the citizens, stakeholders, interest groups, organizations and academic societies to raise their concerns, provide feedbacks and suggestions which will contribute to the decision-making process. The consideration of the diverse opinions as well as the technical and scientific schools of thought would be a great leap forward in taking into account the possible consequences of today’s actions.

To this end, we cite the landmark case of Oposa vs. Factoran, 224 SCRA 792, which stressed the right of the Filipinos to a balanced and healthful ecology which is associated with the twin concepts of “inter-generational responsibility” and “inter-generational justice”. We owe it to the future generations to act in a responsible and sustainable manner by way of preserving natural resources, protecting the environment, and on the fair distribution of benefits and burdens.

Green Juris, as an environmental arm of the Ateneo de Davao University Law Students, bears the intention of imparting to you our common yolk of inter-generational responsibility and inter-generational justice. It is our common duty to promote sustainability and equity across time, and we must acknowledge the interconnectedness and interdependence of generations.


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