Frequently Asked Questions

1. Introduction and Background

A: Agile Energy Recovery (Inverurie) Limited is developing a low carbon energy park in Thainstone near Inverurie in North East Scotland. The catalyst is an Integrated Resource Recovery Facility (IRF) power plant that, subject to planning, is due to come online in 2025. Our directors are from Aberdeenshire and the North East of Scotland and come from a varied background in engineering, project development and management, waste management and technology.

A: The Waste (Scotland) Regulations were passed by the Scottish Parliament in May 2012, with the express intention of implementing the requirements of the Zero Waste Plan. The plan includes a ban on the landfilling of food, paper, garden and any other biodegradable waste before the 1st January 2021. This ban was recently extended to 2025 to allow both the public and private sectors additional time to prepare further initiatives and develop infrastructure to achieve this. It has been estimated that 1.2 million tonnes of residual waste will have to be landfilled, managed or exported outside of Scotland if new projects do not come onstream by 2025. In order to make up this shortfall, it will be necessary to develop more residual waste facilities within Scotland, including the one proposed at the Thainstone Energy Park.

A: The catalyst for the Thainstone Energy Park is the development of the power plant, capable of treating up to 200,000 tonnes of non-hazardous residual waste each year, exporting circa 30MW of electricity (enough to power approximately 50,000 homes). The facility would also have the potential to supply heat to at least 32,000 local homes as well as businesses through a district heat network and distribution of heat batteries.

A: The Inverurie Paper Mill closed in 2009. It was once one of Aberdeenshire’s largest employers.

A: In 2012, a Proposal of Application Notice (PoAN) was submitted to Aberdeenshire Council for plasma gasification based plant on the site of the Inverurie Paper Mill. Consultation events were held with the local community throughout 2012, however, the application was not progressed for a number of technical and commercial reasons.

2. Site and Proposal

A:  No, Kirkwood Commercial Park Limited own the land and the project has an exclusive partnership with Kirkwood to develop the project on their site – click HERE to see the site location drone footage.

A: Agile Energy has a committed ambition to turn the Thainstone Energy Park into a world-leading hub for low-carbon energy generation and business operations. The project has an ambition that includes leveraging the power plant to create new business opportunities and employment including district heating, hydrogen production and distribution, advanced horticulture and aquaculture, and carbon capture and utilisation to name but a few.

A: During construction, the power plant itself would create up to 300 construction jobs at its peak, with a further 40 permanent, operational jobs once in full operation. Additional employment will be created by the complementary businesses that will evolve once the plant is built.

A: This type of facility will take approx. three years to construct. This includes full commissioning and testing.

A: The investment value of the power plant is in the region of £200m.

3. Integrated Resource Recovery Facility Process (IRF)

A: The type of waste used in the facility will be commercial and industrial (C&I), along with some domestic.

A: The waste will come from the North East and Highlands.

A: Yes. In order to operate, the facility must have a PPC permit from SEPA. The permit will control all operations at the facility and will only be granted if SEPA is sure that local people and the environment will be protected. SEPA has stated that ‘appropriately located and well managed energy from waste facilities will meet modern requirements. These are principally stringent emission standards contained in the Industrial Emissions Directive (IED) and promulgated in Scotland as the Pollution Prevention Control (PPC) Regulations and require that the plant does not cause significant pollution of the environment or harm human health.’

When consulting on a permit SEPA asks local NHS Health Boards to comment on any potential health impacts and takes their views into account when deciding whether to grant a permit.

A detailed Air Quality Assessment which looks at all potential air quality impacts, including emissions from vehicles using the site, will be undertaken as part of the planning application. The assessment will show how local air quality will be protected and identify any measures that will be put in place.

A: All combustion processes create emissions which can contribute to airborne particulate levels. The gases created in the power plant are cleaned using highly sophisticated technology before being released. All facilities using energy recovery technology must comply with strict emissions standards, which are designed to protect public health. Controls on emissions from ERF are tighter than other large industrial plants such as coal-fired power stations. The project has selected the very best emissions control technology.

The Scottish Environment Protection Agency (SEPA) governs the operation of all ERF’s and states that the potential effects of emissions from modern facilities “would be very small – if detectable at all” (Health Protection Scotland, 2009). Before it can operate, the Energy Recovery Centre must have a Pollution Prevention and Control (PPC) Permit from SEPA which will state the emission limits that are allowed and the project technology will ensure that the emissions from the plant fall well below the limits stated in the permit . The emissions will be continually monitored to ensure that the facility is always operating well within these limits.

A: No. We are anticipating our integrated resource recovery plant will (without district heating implemented) displace in the region of 70,000 tons of greenhouse gases (GHG’s) every year. The difference between using waste and other fossil fuels is simply that the carbon released through burning waste has only very recently been absorbed from the environment so is part of the existing carbon cycle, while the carbon from fossil fuels was absorbed millions of years ago, so when released adds to the carbon in the atmosphere.

Carbon Emissions Compared to Landfill

Since the project is diverting biogenic waste from landfill it is relatively easy to calculate the production of methane which will be prevented by the plant. It is also easy to calculate and prove that given the prevention of methane production and an assumption that methane has 28 to 32 times more global warming potential (GWP) than CO2 over a 100 x year time frame as an atmospheric greenhouse gas (1), the plant is in effect carbon neutral by this fact, up to a point where the plastic content exceeds around 16% by weight. This impact would be further enhanced if we were to calculate from first principles based on the GWP over 20 years (at which timeframe the CO2 equivalent multiplier rises to around 85 times that of CO2) which is more akin to the lifetime of the plant but almost all the literature on the subject uses the IPCC timeframe of 100 x years and for the purposes of this level of paper we have remained with the 100 year timeframe.


1) CO2 emitted as a consequence of burning biogenic material which has its origin in the current ecosystem, such as wood, paper, cardboard, cotton fibres etc is considered carbon neutral and also by some definitions renewable.
2) CO2 emitted as a consequence of burning residual plastic materials is fossil carbon and thus is adding fossil carbon to the existing eco-system CO2 loading in the atmosphere, considered by many scientists as the cause of global warming. Such fossil carbon is often referred to as anthropogenic or in other words man-made.
3) The mix of current ecosystem biogenic material and residual plastic in the fuel stream will be around 90%:10% by weight. Note the use of the term “fuel stream” as opposed to “waste stream”, as the plant first removes most recyclates, inert materials and hard plastics from the waste as-received, before sending the remaining material as fuel to the furnace/boiler.
4) Greenhouse gases, emitted from landfills (with no methane capture), primary approximate constituents, are methane (CH4) 60% and carbon dioxide (CO2) 40% (2).
5) The plant will prevent and displace the production of methane from landfill at a rate of around 1.588Te carbon dioxide equivalent (CO2e) for landfills with a moderate methane capture system in place – see Figure 7 and (3) and (4) and (5). The largest and only active landfill site displaced by the proposed EfW plant is Stoneyhill near Peterhead and it captures methane and uses the methane to produce electricity (6), and thus we apply the 1.588Te CO2e when calculating methane displacement from this landfill site.

Of the 450,000 tonnes of waste placed in live landfills in the region only Stoneyhill and Black Dog capture methane. Black Dog is not an operational landfill and therefore we account only for the 140,000 tonnes of waste that went to Stoneyhill (in 2019) in the calculation of CH4 emissions in terms of CO2 equivalent. We have assumed on a range of values to be found in the literature and with reference to Figure 7 that 1.588Te CO2e of the GHG’s produced in the Stoneyhill landfill escapes to atmosphere. This is in the form of non-collected methane, oxidised CO2 emission, collected and combusted methane emitted as CO2 (from the generator engine exhaust), and CO2 emission from decomposition of the waste. Methane produced (as CO2 equivalent) is removed by the capture process and subsequently flared or converted to energy plus carbon dioxide, oxidised within the landfill and emitted as CO2 (7).

Figure 7 – GHG Emission from Landfill (source: Evaluation of landfill gas emissions from municipal solid waste landfills for the life-cycle analysis of waste-to-energy pathways. Uisung Lee*, Jeongwoo Han, Michael Wang Systems Assessment Group, Energy Systems Division, Argonne National Laboratory, 9700 South Cass Avenue, Lemont, IL 60439.)

6) The plant fuel will be around 200,000 tonnes (Te) annually, secured from separating up to 220,000 tons of waste received at the plant into recyclates (up to 20,000 Te) and fuel (200,000Te).
7) The fossil carbon emission to atmosphere will come from a maximum of 20,000 tonnes annually of mixed soft plastics.
8) CO2 emission from burning mixed plastic is 2.5Te/Te of plastic (8).
9) Transport emissions are negated in the context of the comparison between landfill and the IRF by assumption that transport to the plant produces no more emissions than transport to landfill. In reality emissions will be less to the plant located at Thainstone (14 miles from Aberdeen) compared to landfill at Stoneyhill landfill near Peterhead (30 miles from Aberdeen) which is the default biogenic material landfill site for the region. Post 2025, the comparison shifts even more in favour of the plant since the only viable option for waste collectors will (in the short/medium term) be to transport their waste to England for disposal in landfill.

1) The Thainstone plant (the plant) will displace gas-fired power generation at a rate of 8,000hrs x 30MWe x 0.18kg/kWh = 43,200 Te CO2e (9)
2) The plant will displace around 294,320 Te CO2e/annum (CO2e is in the form, almost entirely of methane and carbon dioxide), by virtue of diverting a minimum of 180,000Te (140,000 (Stoneyhill) x 1.588Te (10) CO2e, plus 40,000 x 1.8Te (11) CO2e (other landfills with no methane capture) of biogenic material from landfill while the balance of fuel will be residual mixed soft plastics.
3) The CO2 produced by burning the plastic content within the fuel stream will be 20,000 x 2.5 = 50,000 Te CO2.
4) The CO2 produced by burning 180,000 Te of biogenic waste according to the IPCC (12) is between around 0.7Te to 1.2Te per tonne of waste. However, since the plant waste processing package removes inert materials and creates a fuel, the value will be toward the higher end of the range and thus 1.2Te. By comparison, biomass in the form of wood chips with a similar moisture content of 25% to the fuel stream, produces around 1.37Te CO2e per tonne of fuel (13). In this calculation, we use 1.2Te CO2e = 216,000 Te CO2 (180,000 x 1.2Te). This is argued by many, but the carbon sequestered in managed forests (FSC Certified) is generally achieved within a cycle that is shorter that an average human lifespan and can thus be reasonably considered renewable. We acknowledge however that the Local Development Plan (LDP) does not include biogenic wastes as “renewable” within the formal definition provided within the document.   is around 324,000 Te CO2 but is ignored in the carbon balance equation here since it is current ecosystem carbon. This is argued by many, but the carbon sequestered in managed forests (FSC Certified) is generally achieved within a cycle that is shorter that an average human lifespan and can thus be reasonably considered renewable. We acknowledge however that the Local Development Plan (LDP) does not include biogenic wastes as ‘renewable’ within the formal definition provided within the document.
5) The carbon balance equation for the plant thus becomes:

CO2 from burning plastic (+50,000Te), plus biogenic content emissions from burning the biogenic waste (+216,000Te), minus CO2 emissions displaced from a gas-fired plant equivalent (– 43,200Te), minus CO2 equivalent GHG emissions displaced from landfill (– 294,320Te) = negative 71,520 Te CO2e per annum.

NOTE: The carbon balance figure is necessarily approximate but takes account of some plastic content contained within and upon paper/cardboard waste such as plastic films and tapes and synthetic materials content within mixed textiles and leather/rubber wastes. Values and results have been confirmed by modelling using the Institute for Global Environmental Strategies’ ‘Estimation Tool for Greenhouse Gas (GHG) Emissions from Municipal Solid Waste (MSW) Management in a Life Cycle Perspective’ by Nirmala Menikpura and Janya Sang-Arun (14).

A recent study by Zero Waste Scotland concluded that emissions from landfill was 341kg CO2e per tonne of waste while emissions from an average energy-from-waste facility (EfW) was approximately 282 kg CO2e. These numbers were challenged by Fichtner (15) who stated that the corrected figure for landfill should be 419 kg CO2e and thus a net result of 33% less GHG emissions by handling the waste by EfW rather than landfilling. The subsequently revised ZWS report (16) states that the net result is 27% less GHG emissions based on a revised emission figure for EfW of 246 kg CO2e and that ‘….in terms of composition, if the proportion of plastic in residual municipal waste increases from 15% to 17%, greenhouse emissions per tonne for incinerators rises to the same level as landfill.’

A: If there is any risk to public health SEPA will shut down a facility.

Energy Recovery Facilities (ERF) must comply with stringent emissions standards, which are designed to protect public health. The Scottish Environment Protection Agency (SEPA) controls the operation of all ERF’s and states that the potential effects of emissions from modern facilities “would be very small – if detectable at all”.

SEPA’s position on ERF’s is clear: “Appropriately located and well managed energy from waste facilities, that meet modern requirements such as the stringent emission standards contained in the European Industrial Emissions Directive (IED) and Pollution Prevention Control (PPC) Regulations, should not cause significant pollution of the environment or harm human health”.

This followed a report carried out by Health Protection Scotland (2009) which reviewed previous studies into the potential health effects of ERF’s and is in line with the Health Protection Agency’s position:

“Modern, well managed incinerators make only a small contribution to local concentrations of air pollutants. It is possible that such small additions could have an impact on health but such effects, if they exist, are likely to be very small and not detectable.” (Health Protection Agency Feb 2010)

A: No.  Once operational, environmental issues will be controlled through the site’s Environmental Permit which will be regulated by SEPA, with all operations from receipt of the waste managed within a sealed building.

All waste will be unloaded and treated within the building which is sealed and maintained under negative pressure.  As a result, when a door opens to allow a vehicle to enter or exit the waste bunker, clean air is drawn into the building rather than leaving.  This air is then used in the thermal treatment process so that any potential smell is destroyed before being emitted via the stack.

A: The facility will be designed and operated to minimise noise impacts.

Noise monitoring will be undertaken to understand background noise conditions and a detailed noise model has been used to predict noise levels at nearby residential properties close to the site. The model considers noise generated by HGVs entering and leaving the site, with mitigation measures used to reduce noise impacts from the facility.

A: No. All waste delivered to the facility will be unloaded and handled within the buildings under negative pressure.

A: Waste will be delivered directly to the facility in sealed municipal waste vehicles. These vehicles will access the site from the A96.

A:  Yes. The plant will include equipment designed to ensure that any recyclable materials that remain in the waste stream can be recovered.

A: No. All waste delivered to the facility will be classified as non-hazardous business, commercial and municipal waste. Specialist facilities exist throughout the UK to receive and treat hazardous or clinical waste. This facility will not be one of these.

A: Yes, this is likely. A wide range of plastics and all paper products, once recycled a number of times, cannot be recycled again. As businesses are driven by cost it makes more sense to remove as much recyclable material from the waste stream as possible, before paying for it to be thermally treated in an energy from waste facility. An example includes a pizza box which is cross contaminated with food waste and can no longer be recycled.

A: The technology to be used will start with front end processing of the waste so that any remaining recyclables can be removed and the homogenous fuel material is produced to go into a circulating fluidised bed (CFB) furnace where it is burned under computer managed conditions to raise steam which in turn drives a steam turbine generator to produce electricity. Flue gases are treated using the latest technology from Sweden, arguably the World’s leading experts in this area, and the gases, mostly nitrogen and carbon dioxide are then returned to the atmosphere.

A: The technology comes from a wide variety of market-leading suppliers such as Foster Wheeler and General Electric while the overall design will be delivered by design houses in the UK and continental Europe.

A: 850 degrees centigrade for a minimum of 2 seconds. This temperature and residence time is laid down by UK and European legislation.

A: There are many ERF’s in operation throughout the UK, including a number in Scotland.

Our technology partner has supplied a full range of CFB boilers totalling 36 GWe in power capacity and have 30 million hours of operational experience including in Scotland.

A: Yes – central to the development of the ERF and Agile Energy’s vision for the energy park is the development of a District Heat Network. Agile are also investigating the feasibility of employing waste heat from the power plant to heat greenhouses, grow warm water prawns and recharge heat batteries that could extend the reach of the conventional pipeline network to the whole of Aberdeenshire.

A: The normal route for disposal of incinerator bottom ash (IBA) is to landfill. This however will be a last resort for the project and we are looking at a number of initiatives that will allow us to transform IBA into useful products such as bricks and paving slabs.

A:  The project is targeting a stack height similar to the existing former paper mill stack which still sits on the site.

4. Planning Application and PPC Permit

A: At this point in time the project is applying for planning permission for a power plant to be sited on the 10-acre site inside the former Inverurie Paper Mill which is now Kirkwood Commercial Park. The planning application will also request permission for an Education / Visitor Centre to be located within the facility.

A: Yes – the Pollution Prevention and Control (PPC) permit application will be submitted at the same time as or shortly after the planning application. The PPC permit will be issued by SEPA and will lay down all the legislative limits within which the plant must operate. The conditions contained within the PPC permit are subject to on-site verification by SEPA during commissioning and at regular intervals thereafter during the life of the plant. SEPA cannot issue a permit unless any necessary planning permission is in place. There is no such requirement in England.

More information is available in this document: The role of the Environment Agency and the Scottish Environmental Protection Agency in waste incinerators: Briefing

5. Other Questions

A: The Collins English Dictionary states that ‘An incinerator is a special large container for burning rubbish at a very high temperature.’ So, simplistically the Thainstone plant is indeed an incinerator. However, strictly speaking, the plant does much more than the simple connotation and historical meaning of an incinerator which was simply a means of destroying unwanted material (rubbish) rather than dumping it in the environment. In the early days, and still today, incinerators are still in use to destroy potentially harmful materials such as contaminated clinical and other hazardous waste. The Thainstone plant, however, is much more sophisticated, does not use hazardous waste as fuel, and produces a useful product in the form of electricity and heat, neither of which a true incinerator does.

A: Efficiency of power plants such as Thainstone is generally measured in terms of electrical efficiency and overall thermal efficiency. The Thainstone plant will provide around 35% electrical efficiency (that means the plant will convert 35% of the energy in the waste (fuel) into electricity) and a gradually increasing thermal efficiency as waste heat is delivered to the proposed district heating system which will be developed over a period of years.

The facility is designed to provide continuous gross production of 32MWe at the generator at 0.85 power factor. Plant net electrical efficiency to the grid is about 31% with a degree of variability depending on what power is needed to run the plant itself at any one time. Boiler heat-to-steam efficiency (EN12952) is circa 90% in all operation regimes with the main fuel.

The project is considering a number of initiatives to enhance the take-up of district heating in order that the overall efficiency of the plant can be raised to above the government guideline of at least 60%.

More information: The R1 Energy Efficiency Formula

A: Some materials cannot be recycled indefinitely. The degradation of fibres which occurs when a paper is made using repeatedly recycled material is one example. For instance, the high-quality paper has long fibres which shorten every time the paper goes through the recycling process. At best, office paper can be recycled into new paper products around five to seven times but with a general downgrading of the paper product each time until eventually it must be either landfilled or used as a source of energy. It is not possible to turn egg cartons back into writing paper.

In 2016, 2.5 billion tonnes of waste (or about 5 tonnes per capita) were generated in the European Union. While the greater part came from the construction (37 %), mining (25 %), and manufacturing (10 %) sectors, households represented 9 % of the total. Of the 5 tonnes of waste generated per capita, 4.5 tonnes were treated. Measured by weight, packaging accounts for over 3 % of all waste generated in the EU. Packaging is made up of paper and cardboard (41 %), plastic (19 %), glass (19 %), wood (16 %) and metal (5 %).

In 2016, 67 % of packaging was recycled in the EU-28, although recycling rates for specific materials varied a great deal: 85 % for paper and cardboard packaging; 78 % for metallic packaging; 74 % for glass packaging; 42 % for plastic packaging; and 40 % for wooden packaging. (source:


A: We believe that is the wrong way to ask the question. One of the widely propagated arguments against EfW plants is that since waste being the fuel for the waste-to-energy facilities, the establishment of more EfW facilities will necessitate more waste generation and waste supply lock-in arrangements, and thus, will discourage recycling efforts. Statistics, however, show that EU countries with the highest recycling rates also are the countries with the greatest number of operational EfW facilities and the least amount of material landfilled. Since 2014 countries like Germany, Denmark, the Netherlands, Belgium and Sweden landfill less than 1% of their waste.

CEWEP calculations show that 142 million tonnes of residual waste treatment capacity will be needed by 2035 in order to fulfil the currently set EU targets on municipal waste and (see also UK targets) assuming that ambitious recycling targets will be achieved for commercial and industrial waste. Current Waste-to-Energy capacity is 90 million tonnes and the capacity for co-incineration is around 11 million tonnes. This leaves a gap of around 40 million tonnes. (source:


A: There are two main technologies used for treating residual waste and recovering energy – Established Thermal Treatment (ETT) and Advanced Thermal Treatment (ATT). These technologies are different in how the waste is processed and the energy liberated for recovery, i.e. incineration or combustion (ETT) directly releases the energy in the waste, whereas pyrolysis and gasification (ATT) thermally treat the waste to generate secondary gases from which energy can be generated.

Incineration usually involves the combustion of unprepared (raw or residual) MSW. To allow the combustion to take place a sufficient quantity of oxygen is required to fully oxidise the fuel (waste). Typically, incineration plant combustion temperatures are in excess of 850 C and the waste is converted into carbon dioxide and water. Any non-combustible materials (e.g. metals, glass) remain as a solid, known as Bottom Ash, which contains a small amount of residual carbon.

The standard approach for the recovery from the incineration of MSW is to utilise the combustion heat through a boiler to generate steam, which can be used for the generation of power via a steam turbine and/or used for heating. An energy recovery plant that produces both heat and power is commonly referred to as a Combined Heat and Power Plant (CHP) and this is the most efficient option for utilising recovered energy from waste via a steam boiler. (source:

A: Yes.

For those interested in the details, please visit FEAD website (European Federation of Waste Management and Environmental Services) click here for further information.

The legal analysis that was conducted deployed all the methods applied in interpreting provisions of Union law, taking into account the European waste law and political framework and concluded that (a) waste incineration must be viewed in a differentiated manner, (b) a distinction must be made between incineration for disposal and incineration for energy recovery (R1), and that (c) WtE (R1) is consistent with the circular economy, while also fulfilling other environmental objectives, as long as it complies with the waste hierarchy. Therefore, recovering the energy from non-recyclable waste for energy recovery must be regarded as an environmentally sustainable economic activity.


A: First of all it is crucially important to understand what fossil fuel is in the context of an IRF such as Thainstone. Fossil fuel in this context is residual waste plastic that cannot be recycled and becomes part of the fuel. Plastics are almost entirely made from oil and gas feedstock. As a consequence, when this material is burnt it releases carbon dioxide and that carbon content is not current eco-system carbon. It was locked up in the oil and gas millions of years ago and we humans by our actions have taken it out of the ground and brought it into the ecosystem where it becomes an artificial additive. This artificial manmade addition of carbon to the atmosphere is what many scientists believe is causing global warming. Natural caution should tell us to minimise this at least and Thainstone would prefer not to see any plastic waste. However, residual plastic in the waste stream is an inevitability for the present and until packaging designers ensure that all plastic produced is easily recycled, we must make provision to store it or turn it into energy. We certainly cannot continue to export our waste to Asia where much of it ends up in the rivers and seas and has been found in seabirds and sea mammals. It has been estimated that 8 million tonnes of waste plastic ends up in the world’s oceans annually and this is not sustainable.

A: Wide differences exist between EU member states regarding the treatment of municipal waste. Municipal waste and its various fractions are generally landfilled, incinerated (i.e. burnt, in most cases with energy recovery), recycled (for instance paper, glass or metal) or composted (turning garden waste or food waste into compost or biogas). Some waste management options are preferable to others. For instance, recycling and producing biogas are generally preferred over incineration. Landfilling and composting is the least preferred option because they both produce methane (natural gas) which is released to the atmosphere where it is 25 x more potent than carbon dioxide.

The share of recycling and biogas production among waste treatment methods ranges from 67 % in Slovenia to 8 % in Malta (the EU average is 46 %); eight Member States landfill less than 5 % of their municipal waste, while eight Member States landfill over 60 % of their municipal waste (the EU average is 25 %). (source:

Please view the summary household waste data of 2018 for Scotland on the SEPA website.

A: In 2018, 47 incinerators generated just over 6,000 GWh of electricity or 1.9% of the UK total. In a report for the Scottish government, the Eunomia consultancy provides estimates for carbon dioxide emissions per tonne of waste for UK and European “thermal treatment” plants. UK plants emit 0.28t CO2e per tonne of waste while those in Denmark, Netherlands and Sweden emit 0.13t CO2e. The difference is accounted for by the fact that European plants typically use their waste heat to supply district heating whereas most UK plants do not. In other words, operating as a combined heat and power plant (CHP) roughly halves carbon intensity of processing each tonne of waste.

The real issue with CO2 is whether it is fossil CO2 (bad for the atmosphere) or current ecosystem CO2 (essential for all life on the planet) and this translates where waste to energy plant is concerned into what percentage of the waste (fuel) that is burned is plastic (fossil fuel since it is made from oil/gas) and what is paper, cardboard, natural textiles, wood etc (all current ecosystem carbon). The average plastic content in residual waste in the UK is around 8% and thus around 16,000 tonnes annually in the case of the Thainstone plant. This equates to emissions of 32,000 tonnes of fossil CO2 while the remainder of the fuel emits 330,000 tonnes of current ecosystem CO2. In other words, fossil CO2 emissions account for 10% of the emissions of CO2 from the plant. However the plant displaces the production of methane in a landfill of around 0.2Te CO2 equivalent per tonne of biodegradable waste, so the equivalent of 36,400 tonnes of CO2e and thus it is fair to say that the plant is (fossil) carbon neutral.

The planned Thainstone IRF facility is a carbon capture ready plant in terms of the EU Industrial Emissions Directive (IED). Space has been reserved for a technically feasible carbon capture solution. At this point in time, it is too early to commit to any specific carbon capture technology as this sector is rapidly advancing and new exciting technical solutions are being tested.

There is also a potential infrastructure for carbon sequestration in the proximity of the plant (National Grid Gas National Transmission System (NTS) No. 10 Feeder) which has been studied as a route to deliver gaseous CO2 to the North Sea, via St Fergus as part of Scotland’s carbon capture and storage (CCS) strategy.

However, we will ensure that the Thainstone IRF once approved will utilise the best available and economically viable technology.

A: The primary need for the facility is to divert waste away from landfill and fulfil the legal requirement of government and the Waste (Scotland) Regulations 2012 which require that all biodegradable waste is banned from being landfilled from 2025. However, it should also be understood that gas-fired CCGT power stations, while they are very efficient, are emitters of fossil CO2 while an IRF like Thainstone is a net-zero emission plant because it displaces the emission of methane from landfill and the majority of the carbon emissions are current ecosystem carbon which is not harmful to the ecosystem.

A: Simply put, because Agile Energy will not own and operate the planned DH network – the established COOP (Inverurie Community Energy Society) will. The project developer has been very clear about this in its communication with the public. We want the district heating network to be at least in part, if not wholly, owned by the local community and for the benefit of the local community.

A: The primary economic driver would have been the Renewable Heat Incentive or RHI (see Non-Domestic RHI). However,

“The Government announced on Tuesday (28 April 2020) that the non-domestic RHI scheme would close for new applicants from April 2021. As promised in the Budget, the RHI for households and organisations has been extended to March 2022.

A consultation had been launched to formalise the replacement scheme for the RHI. The Government is proposing a Clean Heat Grant that would commence in 2022, offering funding support of up to £4,000 for each household or business that integrates heating technologies such as heat pumps. An eligible list of technologies applicable for funding support will also be outlined.” (continue reading)

Agile Energy is assessing the impacts of this government decision to discontinue the non-domestic RHI scheme and is exploring alternative ways to compensate costs of forecasted heat demand and production.

A: As the name suggests it is a battery that is designed to store heat. Contrary to common belief, heat storage battery technology is not only well proven but also scalable. A good example would be a Scotland based company called Sunamp:

“We have created intelligently designed Thermal Storage to facilitate large community and commercial scale heat and cool, to enable demand management and reduce grid constraints.

This technology provides large scale static or transportable energy storage (200 kWh to multiple MWh) that can store energy from waste heat sources or electricity from grid constrained assets, such as wind farms and solar parks, and use it when or where demand requires.

Alternatively, it can deliver stored thermal energy to offices, housing developments, leisure facilities, district heating networks and any other site with hot water, heating or cooling requirements. Our integrated approach means we provide a bespoke design service and assistance with moving heat within rural or urban environments.” (source: Sunamp website)

A: Thainstone IRF is a privately developed and funded project. Currently, given the lack of continuing support through the medium of the RHI for district heating, we do not envisage any type of government subsidies and/or support schemes to be applied to our business plan. That said, should applicable support mechanism become available, then any future plant owner/operator will be entitled to take full advantage of any legislative support offered by the Scottish government to achieve its national renewable targets.

A: Project’s Flood Risk Assessment Report (FRA) forms an integral part of our planning application. The study was carried out by Fairhurst in accordance with Scottish Planning Policy. Interested parties can view and download the document here. The FRA together with the environmental report takes full account of the detailed work carried out by Fairhurst, the recent work commissioned by Aberdeenshire Council and their consultants and the recommendations from SEPA contained in the Scoping Opinion, and implements the flood risk mitigation measures in full. So for example, SEPA recommended that the finished floor level of the plant buildings should be a minimum of 600mm above the 1 in 200 year plus climate change predicted level and the project designers have subsequently placed the floor levels at twice the minimum recommended level above the predicted flood level. It should also be understood that the former paper mill site within the plant boundary has never flooded in living memory.

A: Firstly, our plant’s design and business model is not based on large scale residual waste imports e.g. as in some Nordic countries, nor do we use moving grate incineration technology where MSW pre-sorting and shredding does not normally take place. The plant is designed to deal locally with locally produced waste and that means from the North-East of Scotland. As a consequence, rail transport would be both uneconomic and costly in terms of the environment as any logistics expert knows.

A: The term BAT stands for Best Available Techniques/Technology.  There is a document called The Best Available Techniques (BAT) Reference Document (BREF) for Waste Incineration that can be viewed and downloaded here. (please note: 2019 edition is 23 MB in size and 764 pages long). In simple terms, the project is ensuring that we always select and use the best technology and the best engineering/design techniques to deliver the facility.

A: We would like to engage and educate people about what energy-from-waste means; what recycling is, and more importantly what it is not; what can we collectively do to minimise the effects of planned obsolescence; to think about how much food we waste on average per annum; how to distinguish the true eco-friendly approach and greenwashing. Or for instance how certain types of renewable energy are defined today and why they might be re-defined in the future – please read Commentary by the European Academies Science Advisory Council (EASAC) on Forest Bioenergy and Carbon Neutrality:

“Our report (inter alia) analysed current trends to substitute fossil fuels by forest biomass at a large scale, and the relevance of the concept of carbon neutrality to its justification. We highlighted, for example, that carbon emissions per unit of electricity generated from forest biomass are higher than from coal and thus it is inevitable that the initial impact of replacing coal with forest biomass in power stations is to increase atmospheric carbon dioxide levels. Regulations thus need to be carefully designed to ensure that only uses making a positive contribution to climate change mitigation are allowed to be regarded as “renewable energy”. (source:”

“The classification of forest biomass as ‘renewable’ is based on the reasoning that, since biomass carbon came from atmospheric CO2 and regrowth absorbs CO2 over time, it can be regarded as ‘carbon neutral’ with net emissions over the harvesting/regrowth cycle of zero. The ‘carbon neutrality’ concept is, however, a gross misrepresentation of the atmosphere’s CO2 balance since it ignores the slowness of the photosynthesis process which takes several decades for trees to reach maturity. Nevertheless, its simplicity brought with it political and economic advantages and led to the inclusion of biomass in the European Commission’s definition of renewable energy in its 2009 Renewable Energy Directive (RED; EC, 2009), being treated as ‘part of the package of measures required to reduce greenhouse gas (GHG) emissions.’ (source:”

Clearly, there seem to be many misconceptions and false narratives that need to be openly discussed. A well thought through visitor centre will encourage people to ask questions and get them answered. Our project has nothing to hide and no agenda to promote. We wish to initiate a sensible and intelligent debate that does not involve trying to apportion blame. Our visitor centre will focus on the environment, ecology, history of the site, production of waste and how society can minimise that. And last but not least, how our project will help to build a sustainable mindset in our society.

A: Nine sites were given serious consideration during the long process of site selection which began in early 2016. It was always clear to the experienced team at Agile that the best location for the facility was the former paper mill at Thainstone. However, options are always necessary in choosing a site for a project such as this. Careful consideration of each site was made including geographic location with respect to the centres of waste production and thus the relevant impact of transport; ecology and the local environmental impact, visual impact, availability of a local workforce and other potential impact and benefits. The Thainstone site benefits from being a historical brownfield site, having a well educated and trained workforce close by; it enjoys a low level location with minimal visual impact, has never flooded in living memory, and has significant local outlet for a district heating system that will benefit the local population and contribute to the Scottish Government’s Energy Strategy and Zero Waste plans. No other site in Aberdeenshire has the unique set of potential benefits and minimal impact as Thainstone.

A: There may be a perception that this would be the case. However, one has to understand that the direct competitor for the disposal of waste is landfill. Thus, the jobs that will be displaced will be those jobs currently employed at landfill sites where the waste currently goes. The number of jobs displaced in landfill are very few. Only a handful of machine operators and administration personnel are needed to run a landfill site and on a single dayshift basis. On the other hand, the Thainstone project needs highly skilled personnel and can employ production operators and technicians who have been made redundant from the failing oil and gas industry and whose skills are directly transferable to a plant of this type. Peterhead power station is a large plant sending its power to the national grid while Thainstone is a local generator of power, sending its power into the local grid for local consumption and the two are complementary not competing.

A: Yes. The Ness Energy Plant in Aberdeen is owned by the three councils of Aberdeen City, Aberdeenshire and Moray and will use 150,000 tonnes of municipal black bin waste as its source of fuel. This is most of the black bin waste produced in the three council areas but none of the commercial and industrial waste. There is around three times as much suitable bio-degradable C&I waste produced compared to black bin waste and it is this C&I waste that the Thainstone Plant will use as its fuel.

A: Yes. Apart from the value in some recycled plastics, there is a legal requirement, specifically Regulation 29 of the PPC Regulations (Scotland) 2012, which require that hard plastics are not incinerated. The project has invested heavily in processing equipment to ensure that any heavy plastics that can be separated from the waste streams that have not already been removed by the waste collection companies are removed for recycling and not included in the fuel.

A: Yes. We are always delighted to discuss the details with anyone who wishes to engage at a more detailed level than is possible in the general public consultation. Details of how to contact us are provided on our website.

6. Additional Information

A: No worries. You can submit your question using our Contact Us page – just click the button below and it will take you there.

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