| Power from waste and biomass


fuel sampling and compositional analysis to determine the fossil carbon inputs to the unit, which are then used for UK ETS reporting. For EfW, this option is far more challenging, given the heterogeneous nature of the inputs to EfW, which vary by location and season. Also, the routine and systematic sampling and analysis of municipal solid waste needed to achieve the certainty required under the UK ETS is resource- intensive and presents health and safety issues. The municipal solid waste processed by EfW facilities is typically comprised of a mixture of part-fossil (eg, plastics) and part-biogenic (eg, biomass, biofuels, biogases, etc) components. Under the UK ETS, waste incineration facilities will only need to purchase emission allowances for their fossil emissions, and not biogenic emissions. This distinction presents a specific challenge: how to develop a cost-effective MRV system that can distinguish between fossil and biogenic CO2


.


To answer this question, the UK Department for Energy and Net Zero (DESNZ) turned to the CS-N0W programme, led by Ricardo. DESNZ tasked the CS-N0W research team to establish an MRV system for EfW that is suitably accurate, rigorous and proportionate.


The delivery team worked with the department to understand the evidence gaps and mapped the current landscape. To understand key challenges and evaluate MRV options, the team engaged widely with EfW operators, trade associations, policy makers, technology suppliers and laboratories that provide biogenic/fossil carbon analysis services.


Through this process, several available MRV options were identified, including: The manual sorting method. A representative sample is collected from incoming waste or the waste bunker, sorted into fractions, sieved, dried, then aggregated into categories (biomass, non-biomass, inert, etc). The selective dissolution method. A representative sample of waste is collected and placed in a concentrated solution of sulphuric acid and hydrogen peroxide. The biomass materials will dissolve, while the fossil derived materials will not.


Flue gas sampling and radiocarbon C-14 analysis. Waste incineration generates a mixture of gases that are channelled into the atmosphere via a flue. C-14 analysis is conducted on flue gas samples collected from the stack. The half-life of C-14 is used to determine the biogenic and fossil fuel components of the emissions. Fossil fuel material will contain close to zero C1-4, whilst biogenic materials will contain trace levels. The balance method. Uses a mathematical model that establishes a set of mass and energy balances to describe the waste incineration system. Inputs to the model consists of real time operational data and values from literature for multiple input and output stream parameters.


For each method, information was gathered on:


Skelton Grange EfW plant, UK. Photo: enfineum


costs; likely sampling design/frequency to achieve different levels of uncertainty per approach; and practical considerations for each operator (eg, sampling access requirements). The team elaborated field-testing protocols to validate the different methodologies by reviewing available data and uncertainties in estimating fossil CO2


.


It was determined that continuous flue gas sampling using C-14 analysis is the preferred MRV method for EfW sites.


Alternative methods were deemed overly labour intensive and less accurate. EfW operators viewed C-14 sampling as simpler than alternatives and more transparent as it uses direct measurements. Several of the large operators either already have C-14 equipment installed or are trialling it with the intention to roll it out across their fleet. The costs of C-14 installation and operation were seen as minor compared to the upcoming cost of the UK ETS. The ability to distinguish between fossil and biogenic carbon dioxide in the flue gases requires specialist sampling and analysis techniques. Samples of flue gases are collected at the stack and sent to a lab for C-14 analysis. An important step in establishing this MRV system will be to build up the laboratory capacity with the accreditations to perform C-14 analysis of stack samples.


The analysis delivered by CS-N0W provided DESNZ policy teams with a baseline of institutional knowledge on the available methods for measurement, reporting and verification and the stakeholder engagement and workshop gathered insights from across the industry regarding the challenges and opportunities for implementing each option.


The final report fed directly into the UK government consultation on the UK ETS scope expansion to include waste.


What EfW operators should do to prepare for the UK ETS As already noted, expansion of the UK ETS in 2028 to include EfW facilities presents a series of challenges, including complex MRV requirements. Early engagement with MRV and CCS planning


will be critical to avoid compliance risks and cost shocks in 2028.


However, challenges can be overcome with careful analysis, evidence-based policy design and systematic stakeholder engagement. By proactively addressing the challenges, the expansion of the UK ETS provides an opportunity. The carbon price will create a market signal to promote more sustainable waste management practices and the uptake of CCS technology, without which, warns the UK Climate Change Committee, EfW facilities risk becoming stranded assets.


EfW operator readiness checklist for UK ETS


✓ Start planning for MRV compliance now


Review your current emissions monitoring systems and identify gaps against UK ETS requirements


✓ Engage with MRV solution providers Explore options for Carbon-14 flue


gas sampling and ensure access to accredited labs for analysis


✓ Budget for ETS costs and MRV implementation


Factor in allowance purchase costs and MRV system investment into financial planning


✓ Assess CCS readiness Evaluate technical and commercial


feasibility of connecting to CCS infrastructure to future-proof assets


✓ Participate in industry consultations Respond to government consultations


and engage with trade associations to influence policy design


✓ Train operational teams Ensure staff understand MRV


requirements, sampling protocols, and reporting requirements


Article contributed by Ricardo plc, a global strategic, environmental, and engineering consulting company providing specialist technical and consulting services at the intersection of transport, energy and climate agendas.


www.modernpowersystems.com | October 2025 | 17


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