Waste-to-energy in Thailand comparative to other countries such as the UK and Singapore from the legal viewpoint and provide some recommendations.

1
(This page is for you to format in according with your faculty’ s/study’s guideline)

2
Abstract
Energy, undoubtedly, is of paramountcy for a multitude of aspects with regards to the human being.
However, its scarcity in conjunction with the concern over sustainability in the long-run with regard
to environment has posed a question of a reliable and alternative source of energy. Therefore, for
newly industrialised sovereignty like Thailand, waste-to-energy (WTE) source is an appropriate
substitution for fossil fuels, not only for its reliability in creating energy but also for its being a
solution to combat against the overwhelmed waste management system in Thailand. Nevertheless,
the country still encounters a series of bureaucratic problems with this matter, in particular legal
statutes, as Thailand does not have well-fitting laws regulating the WTE. Such might pave the way
to many loopholes that could jeopardise the country’s development of this energy source from waste.
This paper endeavours to conduct an ad-hoc comparative legislative analysis by analysing the
similarities and differences amongst Thailand, the United Kingdom in the pre-Brexit context, and
Singapore. The analysis will consist of the data interpretation for environmental issues in each chosen
jurisdictions; examination of relevant statutory documents, both in the national and international
contexts; and qualitative comparisons of legal text amongst those in order to propose possible
solutions for the Thai lawmakers on the WTE matters.
Keywords: waste to energy, Thailand, the UK, Singapore, EU, waste management law

3
List of tables
Table 1: The volume of municipal solid waste generated, suitable disposal, and MSW generation
per capita during 2008 – 2014............................................................................................................12
Table 2:Waste from Households, UK and country, split from 2015 to 2018 ....................................19
Table 3: Total waste generated by the commercial and industrial sectors, UK and England, 2010-18
............................................................................................................................................................20
Table 4:All waste at final treatment, split by method, UK and England, 2014 - 2016......................22
List of figures
Figure 1: Total primary energy supply by source of Thailand from 1990 to 2017 ...........................13
Figure 2: Waste generation split by source in the UK, 2016 .............................................................21

4
Table of Contents
Abstract ................................................................................................................................................2
List of tables.........................................................................................................................................3
List of figures.......................................................................................................................................3
1. Introduction of waste-to-energy (WTE) ......................................................................................6
1.1. Definition of WTE plants.....................................................................................................6
1.2. Mechanism of WTE plants ..................................................................................................7
1.3. Advantages and disadvantages of WTE plants ....................................................................7
1.3.1. Advantages...................................................................................................................7
1.3.2. Disadvantages ..............................................................................................................8
1.3.3. Comparison with other energy plants ..........................................................................8
1.4. Legal issues..........................................................................................................................9
2. Legality of WTE in Thailand.....................................................................................................11
2.1. Background ........................................................................................................................11
2.1.1. Amount of waste per year and waste management....................................................11
2.1.2. Energy production......................................................................................................13
2.2. Legislation with respect to WTE in Thailand ....................................................................14
2.2.1. Legal sources in Thailand ..........................................................................................14
2.2.2. Analysis......................................................................................................................18
3. Legality of WTE in the United Kingdom ..................................................................................19
3.1. Background ........................................................................................................................19
3.1.1. Amount of waste per year ..........................................................................................19
3.1.2. Waste management:...................................................................................................21
3.2. Legislation with respect to WTE in the UK.......................................................................24

5
3.2.1. National laws..............................................................................................................24
3.2.2. International treaties and conventions........................................................................27
3.2.3. Analysis......................................................................................................................30
4. Legality of WTE in Singapore...................................................................................................33
4.1. Background ............................................................................................................................33
4.1.1. Amount of waste per year ..........................................................................................33
4.1.2. Waste management ....................................................................................................34
4.2. Legislation with respect to WTE in Singapore ..................................................................36
4.2.1. Legislation..................................................................................................................36
4.2.1. Analysis......................................................................................................................37
5. Comparison amongst such jurisdictions regarding WTE system ..............................................38
5.1. The participation in international treaties ..........................................................................38
5.2. Localism.............................................................................................................................39
5.3. Hazardous materials...........................................................................................................39
6. Recommendation and possible solutions ...................................................................................40
7. Conclusion .................................................................................................................................41
Bibliography........................................................................................Error! Bookmark not defined.

6
Waste-to-energy in Thailand comparative to other countries such as the UK and Singapore from the
legal viewpoint and provide some recommendations.
1. Introduction of waste-to-energy (WTE)
1.1. Definition of WTE plants
A few decades ago, the original purpose of combustion of waste that has been to reduce the
disposal of waste and has not yet aimed for energy production. The waste that used to be burnt usually
still contained hazardous or recyclable materials which either threaten human health or are wastefully
disposed in lieu of generating energy1. In addition, the residual ash is then even buried in a landfill
site which may be deemed as a violation of local regulations in certain jurisdictions. For example, it
is commonly known that environment and relevant laws of many countries belonging to the European
Union (EU) appear very strict regarding waste management2. In the light of waste incineration without
producing energy, some certain restrictions might be applied to minimise the inefficiency3.
As a result, “waste-to-energy plant” (WTE plant, which can also be referred to as a trash-to-
energy, municipal waste incineration, energy recovery, or resource recovery plant interchangeably in
this paper) has brought about a solution for waste management. This modern system is different from
its predecessor, as it treats waste that “remains after waste prevention and recycling”4 by combustion
that eventually generates energy therefrom. A more detailed insight into WTE plants’ mechanism,
advantages and disadvantages as well as legal matters shall be elucidated in the following sections.
1 Maria L Mastellone, Waste management and clean energy production from municipal solid waste (Waste and Waste
Management, Nova Science Publishers, Inc 2014)
2 European Commission, ‘Waste - Environment: Waste management’ (Brüssels 15-May-20)
<https://ec.europa.eu/environment/waste/>accessed 24-Aug-20
3 ibid
4 Didier Bourguignon, ‘Understanding waste management: policy challenges and opportunities’(Brüssels 2015)
<https://www.europarl.europa.eu/RegData/etudes/BRIE/2015/559493/EPRS_BRI%282015%29559493_EN.pdf>
accessed 24-Aug-20

7
1.2. Mechanism of WTE plants
The various kinds of waste that WTE plants treat include municipal solid wastes (most
regularly), industrial wastes or hazardous wastes. The volume of waste that WTE plants are capable
of burning can go up to 80 to 90 per cent. The structure of WTE facilities shares certain similarities
with other steam-electric power plants such as biomass plants5. The process via which WTE plants
operate can be described as follows: (i) the transportation of waste to the facility, (ii) the categorisation
of waste, especially to separate waste that can be recycled and/or can cause hazardous effects to the
environment, (iii) the storage of waste that is pending for incineration stage, (iv) combustion of waste.
In the fourth stage, even though most WTE facilities have the tendency to combust waste directly, as
this technology is preferred for its efficiency, some others may exercise gasification. The process of
incineration can be executed continuously or in batches. It is estimated that a ton of waste burned by
WTE system can produce an amount of electricity of approximately 500 to 600 kWh6.
1.3. Advantages and disadvantages of WTE plants
1.3.1. Advantages
WTE plants operate its incineration process by burning the items that are no hazardous and
are not recyclable, by design or economically. This can be done by the WTE plants incorporating and
co-existing with recycling in terms of sorting materials to omit recyclable waste before burning them.
Hence, WTE plants shall affect the environment positively. First, WTE plants help remove the
harmful materials to the environment prior to the burning stage, which will significantly ameliorate
the detriments followed by the incineration. Second, such plants are carbon-negative, as they process
waste into biofuel, which considerably releases less carbon and methane into the air, in comparison
with burying waste decaying in landfills or the lake. Third, WTE offers a mechanism that operates
with high temperature, efficient combustion and effective pollution control measures; thus, it allows
5 Simona Ciuta, Demetra Tsiamis and Marco J Castaldi, Gasification of waste materials: Technologies for generating
energy, gas, and chemicalsfrom municipal solid waste, biomass, nonrecycled plastics,sludges, and wet solid wastes
(Academic Press, an imprint of Elsevier 2018)
6 P. J Reddy, Energy Recovery from Municipal Solid Waste by Thermal Conversion Technologies (Taylor & Francis Ltd
2016) 2–3

8
significant reduction air pollutants atmospherically emitted, e.g. nitrogen oxides, sulphur
oxides and other pollutant particulates7.
1.3.2. Disadvantages
Research shows that burning coal or natural gas discharges; however, less amount of
dioxin and furan emissions to the atmosphere in comparison with burning municipal waste during its
course of combustion. The chemical components, such as dioxins and furans, are likely to seriously
threaten human health. Odours pollution is also another factor that can cause public nuisance due to
the frequent vehicular transportation of municipal waste to WTE plant facilities. Typically, within the
WTE plant’s system, there are specific rules that help prevent unpleasant odours from emitting to the
atmosphere, such as opting for isolated industrial areas to build WTE plant facilities, constructing
waste storage in enclosed interior space with negative pressure, and running a boiler or a filter to treat
the air escaping from the storage area. In reality, not all plants take steps to reduce the odour, resulting
in complaints. Therefore, this requires absolute respect and careful organisation with the purpose to
isolate WTE plants in order to avoid the risk of odour pollution8.
1.3.3. Comparison with other energy plants
With the aforesaid analyses, it can be seen that:
 WTE plants cause lesser air pollution than coal plants; however,
 WTE plants cause more air pollution than natural gas plants.
The combustion process of both WTE plants and coal plants produce residual materials such
as fly ash and bottom ash9. In particular, WTE plants produce from 15% to 25% ash per an identified
number of weights of original waste, in which fly ash accounts about 10% to 20% of the total ash10.
7 ibid 3
8 ibid
9 “Fly ash and bottomash are fundamentally the products of the chemistry, petrology,and mineralogy of the input fuel,
both the coal and any noncoal fuel, and the nature of the combustion or gasification sys tem.”, according to J. C Hower
and others in Thomas L Robl, Anne Oberlink and Rod Jones (eds) (2017)
10 Reddy (n 6) 4–30

9
Meanwhile, it is shown that the fly ash is likely to cause health hazard due to toxic metals component
contained in fly ash; whereas, such a hazardous risk to human health less potentially occurs because
bottom ash may or may not contain significant levels of health-hazardous materials11.
Regarding natural gas plants system, there exists no significant amount of landfill gas
pollutants that have the potentials to result in environmental contamination. Natural gas plants have
many shortcomings in pollution controls during the burning process of landfill gas. The gas is usually
flared or used to run a reciprocating engine or microturbine, especially in digester gas power plants.
Nonetheless, it is less cost-effective to preserve the hygiene of the landfill gas because natural gas,
which it substitutes for, is relatively cheap12.
1.4. Legal issues
Generally speaking, energy recovery, especially energy from waste, can be a controversial
discussion that requires intensive research and analysis in terms of environment, energy, economic,
technical perspectives as well as legal aspect. Energy-from-waste generation through WTE plant
facilities become one of the cutting-edge solutions in the sector of renewable energy, which many
countries in the world start to implement for two advantages: facilitation of waste management and
energy recovery. The application of WTE plants does not only introduce an innovative solution of
treating residual waste, but also provide a potential strategy which is crucial for energy supply.
Notwithstanding, energy-from-waste is also seen as a heated-debated topic, consisting of
multidimensional recommendations and many underlying issues that need to be addressed. Such due
and careful consideration of the implication and imposition of obligations must be well regulated by
legal corpora to have a comprehensive instruction of waste treatment prior, during and subsequent to
WTE plant system operation.
One of the most noticeable legal issues is that the legislation concerning environment and
energy vary significantly from country to country. Admittedly, national legislation is one of the crucial
factors that have a direct and evident impact on ensuring how WTE plant facilities are practising its
activities to preserve the environment, optimise renewable energy recovery through energy-from-
11 ibid
12 Reddy (n 6) 4–30

10
waste generation, and to balance economic benefits with the public interest. However, many
developed countries, especially those who are pioneers in implementing WTE plants, have already
prepared and constructed solid and detailed laws and regulations that cover substantially the issues in
relation to WTE plant system; whereas some other developing countries still have a plethora of
shortcomings remaining their environmental legislation to supplement, amend and improve.
Another marked issue is that even though some economic and strategic communities in the
world such as the EU or the Commonwealth remain its position in providing comprehensive guidance
for national legislation, the cooperation and solidarity regarding environmental matters in some other
regions such as Association of Southeast Asian Nations (ASEAN) appears to be less efficient. The
latter can be seen with insufficient and fragmented sets of regional laws (i.e. bilateral or multilateral
directives, treaties, conventions). This challenges the autonomy of countries in South East Asia area
(ASEAN countries) in constituting and enhancing their national laws and regulations to deal with such
a novel area, which is WTE plant intervention in energy recovery.
There is currently an increasing number of countries that are interested in or already exercising
energy recovery and waste management by WTE plants system. This requires, indeed, intensive
elaborations and profound discussions regarding environmental and energy legislation. For such
matters, this dissertation will endeavour to present and analyse some specific jurisdictions which have
participated in waste-to-energy production for a certain period of time in the following structures:
- Waste management and energy recovery through WTE plant system and relevant legislation
in Thailand, the UK and Singapore.
- The comparison between such aforesaid legislations.
- The possible solutions to combat their shortcomings.

11
2. Legality of WTE in Thailand
2.1. Background
2.1.1. Amount of waste per year and waste management
Thailand generates an enormous amount of municipal waste, at approximately 26,850,000 tons
per annum.13 According to the report by the United Nations, Thailand is projected to produce most
of the waste in 2025 within the ASEAN region, from about 1.25 kg per capita a day in 1995 to almost
1.6 kg per capita a day in 202514. This projection is particularly alarming, as it is higher than the
weighted average figure of the region by nearly 600 grams per day.
The table in the following page would provide a more comprehensive insight into waste
generation in the Kingdom. Aggregated MSW (municipal solid waste) and total MSW with
appropriate disposal p.a., in conjunction with the rendering rate per head of MSW as three indicators
of waste producing can be prominently seen to be increasing steadily over the years. It is noticeable
to indicate, however, there was a reduction in total MSW rendered in 2014 in comparison to the
previous year by 280 thousand tonnes. This can also be said with the decline in individual MSW
generation rate per capita, as it was only 1.11 kg a day in 2014; while it was up to 1.15kg in 2013.
This deemed to be a positive outlook, as in 2014, there were almost 8 million tonnes of garbage that
can be suitably disposed, compared to only less than 7.5 million tonnes in 2013. Nevertheless, as the
table implies, the total MSW that has been inappropriately disposed was still of significant: about
more than 70% of all the year’s data collected.
With regards to waste management, Thailand is only able to recover 20% of the waste generated
by household, in which nearly 90% is used for recycling15, whereas only 4% is used to render energy.
13 Tsuruyo Funatsu,‘Municipal Solid Waste Management in Thai Local Governments: The State of the problem and
prospects for regional waste management’ in Michikazu Kojima (ed), Toward Regional Cooperation ofLocal
Governments in ASEAN (2019) 7
14 UN Environment Programme (UNEP), ‘Waste Management in ASEAN Countries: Summary Report’ (Bangkok,
Thailand 2017) 10 <https://www.unenvironment.org/resources/report/waste-management-asean-countries-summary-
report> accessed 27-Aug-20
15 Supat Wangwongwatana,‘3Rs and Waste Management in Thailand’ (Pollution Control Department of Ministry of
Natural Resources and Environment, Pollution Control Department of Ministry of Natural Resources and En vironment),
2 <https://www.uncrd.or.jp/content/documents/RT1_04_Thailand_rev.pdf> accessed 28 August 2020

12
Table 1: The volume of municipal solid waste generated, suitable disposal, and MSW generation per capita during 2008 – 201416
Moreover, Thailand creates as much industrial waste as its household leftovers, where in 2009, the
waste or by-product yielded from industries amounted to 21,5 million tonnes17, in comparison with
24,1 million tonnes non-industrially created. In 2009, it was reported that 90% of the industrial waste
were non-hazardous, which was in turn utilised as an input for recycling and raw material, up to 87%,
where only 10% thereof was brought to disposal site and 3% to exportation18. The waste that might
pose hazard to human, fauna, and flora only constituted 10% of the total industrial waste produced19,
in which more than 60 per cent was repurposed to reuse, recycle and even to provide energy.
16 Tharee Kamuang and Orawan Siriratpiriya, ‘Country Chapter: State of the 3Rs in Asia and the Pacific - The Kingdom
of Thailand’ (Hanoi, Vietnam 2017)
<https://www.uncrd.or.jp/content/documents/5695[Nov%202017]%20Thailand.pdf> accessed 28-Aug-20
17 Wangwongwatana (n 15), 3
18 ibid 5
19 ibid

13
Nevertheless, this figure also suggested that there are still about 40 per cent of such waste cannot be
either reused or recycled.
2.1.2. Energy production
Figure 1: Total primary energy supply by source of Thailand from 1990 to 201720
From the figure above, within 15 years, the energy generation productivity of Thailand has
grown threefold within only 25 years, from about 40 thousand kiloton of oil equivalent in 1990 to
almost 140 thousand kiloton thereof in 2015. Notwithstanding, fossil fuel is still an inseparable
component of the country’s energy scheme; where oil, coal, and natural gasses constituted more than
85 percent of total energy produced. The infinitesimal share of hydroelectricity throughout the years
could be deduced by the geography of the country, as it does not possess a mountainous or river-
covered profile. It is however an interesting finding that biofuels and waste were used to generate
energy were of a moderate importance in the country, where throughout the year they still held about
approximately 10 percent of the total energy supply. This suggests that WTE might be an optimal
choice to shift the country’s energy demand to a more sustainable option, in both costing as well as
20 Own illustration, based on International Energy Agency,‘Thailand - Countries & Regions - IEA’ (2019)
<https://www.iea.org/countries/thailand> accessed 28-Aug-20
0
20000
40000
60000
80000
100000
120000
140000
160000
1990 1995 2000 2005 2010 2015
Kilotonneofoilequivalent
Total primary energy supply (TPES) by source, Thailand 1990-2017
Coal Natural gas Hydro Wind, solar, etc. Biofuels and waste Oil

14
environmental friendliness in its characteristics. Therefore, such facilitation of WTE requires a
comprehensive, overarching, as well as thorough legislation, which will be presented hereunder.
2.2. Legislation with respect to WTE in Thailand
2.2.1. Legal sources in Thailand
The first legal basis of WTE is already stipulated in the Thai Constitution. In Article 58 of
Constitution 2560 BE (Buddhist era) (2017)21, the State shall be liable for the “impacts on people,
community, environment, […]”. As the principle of lex superior, this aforesaid Article shall be the
fundamental legal source for other provisions to follow. While being an active and founding member
of the Association of Southeast Asian Nations (ASEAN), Thailand is not bound by any legal corpora
regarding environmental or WTE issued by ASEAN22, as this association is a far cry from the
functionality of the EU. This differences will be further explained through the United Kingdom and
Singapore’s cases. Therefore, the Thai Constitution is the highest level of binding legal document
that is the fundamentals for WTE issue in this jurisdiction. The following germane provisions will
illustrate in more detail how WTE is regulated in the country.
First, concerning the legal sources on environmental issues, Thailand has three primary statutes:
a) Act on the Maintenance of the Cleanliness and Orderliness of the Country 199223 (พระราชบัญญัติ
รักษาความสะอาดและความเป็นระเบียบเรียบร้อยของบ้านเมือง พ.ศ. ๒๕๓๕– hereinafter shall be referred
to as MCOC):
With its self-explanatory name, the MCOC provides a wide array of provisions on the behaviours of
the country’s residents regarding the hygienic as well as the preservation of communal spaces. The
21 International Comparative Legal Guides International Business Reports, ‘Environment & Climate Change Law 2020 |
Thailand | ICLG’ (London 23-Aug-20) <https://iclg.com/practice-areas/environment-and-climate-change-laws-and-
regulations/thailand> accessed 23-Aug-20
22 There are in fact no binding environmental legal document at all laid down by ASEAN.
23 พพพพพพพพพพพพพ รักษาความสะอาดและความเป็นระเบียบเรียบร้อยของบ้านเมือง พ.ศ. ๒๕๓๕ - Act on Maintenance of the Cleanliness
and Orderliness of the Country 1992

15
law is written in six chapters with the transitory provisions section, where some of the essential
provisions on wastes can be found from chapter 1 to chapter 3.
Chapter 1 regulates the maintenance of the cleanliness in public areas, including both indoor spaces
such as pavements or park, and outdoor establishment, namely communal buildings and common
spaces in the residential area24. The chapter also provides a comprehensive guideline on collecting
waste from such places. Chapter 2 enforce the protection of floral coverage in public areas, i.e. trees,
bushes or vegetation, in general, having the function of beautification in public spaces25. Any floral
by-product of the ageing process is considered as waste. Chapter 3 is to prohibit the littering of waste
and refuse in the public area26. Such wastes can be understood under this provision as both recyclable
and non-recyclable waste. Moreover, the Act also enacts administrative penalties for any misconducts
that violate the aforesaid provision in Chapter 6, lie in Sec. 52 to Sec. 59.
b) Enhancement and Conservation of National Environmental Quality Act 199227
(พระราชบัญญัติส่งเสริมและรักษาคุณภาพสิ่งแวดล้อมแห่งชาติ พ.ศ. 2535 – hereinafter shall be referred
to as NEQA):
While the MCOC deals mostly with maintaining the sanitary of the public spaces’ façade, the NEQA,
on the other hand, lays out some of the most important environmental principles of the country. This
statutory document establishes some governmental apparatuses of paramountcy as well, such as the
National Environment Board28, the Environmental Fund29, and the Pollution Control Committee30.
With regards to WTE, the Environmental Fund holds a significant role as it subsidises the authority
in municipal level in order to procure and treat waste in the waste disposal facility31. A zero-interest
24 ibid Sec 6 - Sec 25
27 พพพพพพพพพพพพพ ส่งเสริมและรักษาคุณภาพสิ่งแวดล้อมแห่งชาติ พ.ศ. 2535 - Enhancement and Conservation of National
Environmental Quality Act 1992
28 ibid Chapter 1
29 ibid Chapter 2
30 ibid Chapter 4, Part 1
31 ibid Sec 23

16
loan for private persons or joint venture between the State and private enterprises operating in waste
management can also be granted as stipulated in Section 23. While chapter 3 of the law implements
a wide array of measurements to protect the environment, chapter 4 thereof particularly deals with
containment and reversal of pollution. Section 61 and 62 are of the essence, as they discourage the
usage of landfills and promote the waste or pollution treatment by means of constructing waste
treatment facilities. Akin to the MCOC, NEQA introduces a full range of penalties for individuals
who fails to comply in pursuant to this law. The statute also specifically accentuates on the civil
liability32, including the piercing of corporate veil which might result in administrative penalties,
criminal deterrence, or a combination of thereof.
c) Hazardous Substance Act 199233 (พระราชบัญญัติ วัตถุอันตราย พ.ศ. ๒๕๓๕ – hereinafter shall be
referred to as HSA):
The HSA codifies both substantive and procedural provision with regards to harmful material. The
statute establishes the Hazardous Substance Committee34, which will be responsible for producing,
transporting, handling, eliminating, converting the hazardous material, inter alia in Thailand. This
can be achieved by the regulations laid out in Section 18 of this law, where the economic ownership
of such substances must be reported according to four following categories:
(i) Hazardous substances that can be produced, imported, exported, or economically owned
by means of civil transactions require the agents who undergo such performance to follow
the guidelines set forth by the relevant governing bodies without the obligation to report,
unless
(ii) Hazardous substances in the first categories explicitly require the reporting obligation by
the agents performing such actions. (i) and (ii) category shall not apply if
(iii) Hazardous substances whose production, ex- or importation, or possession must be
licensed. These three categories shall be prevailed if
32 ibid Chapter 4, Part 8
33 พพพพพพพพพพพพพ วัตถุอันตราย พ.ศ. ๒๕๓๕ - Hazardous Substance Act 1992
34 ibid Chapter 1

17
(iv) Hazardous substances that are forbidden to be produced, ex- or imported, owned under
any circumstances.35
The Thai legislation also defines hazardous substances in Section 4, which includes explosive,
inflammable, oxidising, peroxidic, toxic, infectious, radioactive, corrosive, genes alternating, and
irritating substances. Failure to comply shall constitute either administrative penalties, criminal
penalties or a combination of both aforesaid punishments in pursuant to chapter 3 and 4 of this law.
Second, Thai legislature has also promulgated two other laws regarding energy and especially
renewable energy as below:
d) Energy Conservation Promotion Act 199236 (พระราชบัญญัติ การส่งเสริมการอนุรักษ์พลังงาน พ.ศ.
๒๕๓๕ – hereinafter shall be referred to as ECP):
The ECP, with its primary emphasis on energy-saving policies, has also set forth some crucial
provisions with regards to WTE. The definitions provided in Section 3 of this Act stipulates energy
as “ability to perform work that is inherent in the sources that may provide work, consisting of
renewable energy and non-renewable energy, and include sources that may provide such work”. It
can be derived therefrom that the WTE can constitute either energy or non-renewable energy.
However, the law does not explicitly state how WTE should be treated. Nonetheless, ECP recognises
that “garbage” might constitute a “fuel”, although it does not give any guidelines related thereto.
e) Energy Development and Promotion Act 199237 (พระราชบัญญัติการพัฒนาและส่งเสริมพลังงาน พ.ศ. 2535
– hereinafter shall be referred to as EDP):
The EDP, parallelly with ECP, introduces more overarching provision with regards to the
technological advancement in the electricity-generating field. In accordance with Section 4 of the
Act, the Thai Government has vested the power of the regulatory control regarding technical issues
and planning to the Department of Alternative Energy Development and Efficiency (abbreviated as
DEDE). In other words, the DEDE will be liable for any augmentation in electricity production in the
35 ibid Sec 18
36 พพพพพพพพพพพพพ การส่งเสริมการอนุรักษ์พลังงาน พ.ศ. ๒๕๓๕ - Energy Conservation Promotion Act 1992
37 พพพพพพพพพพพพพ การพัฒนาและส่งเสริมพลังงาน พ.ศ. 2535 - Energy Development and Promotion Act 1992

18
country. As a result, this legislative instrument seems to be more centralised with regards to WTE
plants planning and constructing. Moreover, Section 5 of the Act again accentuates the definitions of
item constituting “fuels”, “energy”, and “renewability”, which are almost identical with the
interpretation as in the ECP Act. However, it does not yet explicitly characterise WTE as one of the
sources creating energy.
2.2.2. Analysis
With the presented legislations, it can be prominently seen that the Thai Government has
introduced a well-functioning legal sources for WTE to be realised in the country, both substantively
and procedurally. Moreover, the laws do provide a wide array of practicing areas, both public and
private law. Within the area of administrative law, the Kingdom follows a rather sophisticated with
many caveats governing system, that is the separation of responsibilities between the central-local
authorities and the local self-government38. This has a momentous effect on the waste management
as well as energy providing matter at such subordinate administrative levels, as academic consider
that the autonomous authority would waive some of its power in turn to receive the funding from the
central government. Such right cession is to synchronise the goal of the local apparatuses with the
central government’s plan for the long-run environmental protection. This would establish a clear
guidelines on how to manage waste in the Kingdom, which might in turn facilitate the reliance on
WTE. It can also be said that environmental statutory documents (consisting of MCOC, NEQA, and
HSA) set forth a well-structured and adequately deterrent provisions to avert any misdemeanours that
might lead to severe consequences, environment-wise as well as waste management-wise.
Nevertheless, what the Thai lawmakers lack of is the clarity of WTE in the legal text. This
means that one can only surmise the tacit existence of WTE in the law, but actually find it in any legal
corpora as mentioned above. This can be further explained through the Section 5 of EDP and Section
3 of ECP, where the law only considered ‘garbage’ as a mean of ‘fuel creating energy by combusting’.
This is fatally flaw in two ways. First, by not disambiguating what might constitute a garbage and
what not, this could lead to the non-categorising amongst waste that might pose a threat to humans’,
animals’ and vegetations’ health and wastes that are acceptable to be reused as a source providing
38 Funatsu (n 13) 4

19
energy. Second, while the laws differentiate between renewable and non-renewable energy, there is
no framework indicating where energy from waste should lie. This might hinder the process of
phasing in WTE plants in Thailand by means of bureaucratic processes. Another explanation can be
deduced through the MCOC and NEQA. While both of those statutes provide comprehensive
instructions on how to handle waste in collecting, transporting, and disposing; they do not explicitly
stipulate how should the waste be treated if it were used for generating energy.
Notwithstanding, in fact, there are already six ways of converting waste into energy in
Thailand.39 However, as found by Boompa and Sharp, the governmental budget subsidising WTE
projects are highly insufficient, both by the technological limitations but also by the legal ambiguity.
Therefore, to best optimise the use of WTE plants in the Kingdom, a more overarching,
comprehensive legislation based on an ad-hoc process with intensive review is of expedience.
3. Legality of WTE in the United Kingdom
3.1. Background
3.1.1. Amount of waste per year
Table 2:Waste from Households, UK and country, split from 2015 to 201840
39 Siriporn Boonpa and Alice Sharp, ‘Waste-to-energy policy in Thailand’ (2017) 12(5) Energy Sources, Part B:
Economics, Planning, and Policy 434, 437
40 Taken from Department for Environment, Food & Rural Affairs, ‘ENV23 - UK statistics on waste’ (19 March 2020)
<https://www.gov.uk/government/statistical-data-sets/env23-uk-waste-data-and-management> accessed 25-Aug-20

20
The UK’s recycling rate of Waste from Households (WfH; including IBA metal) have stalled since
2013. According to Table 1, the UK generated 26.4 million tonnes of WfH in 2018, falling by 1.8%
in comparison of 26.9 million tonnes of WfH generated in 2017. In 2018, England’s amount of WfH
accounted for a major percentage (83%) of UK WfH, which is 22.0 million tonnes. Meanwhile, other
countries within the UK have recently seen a reduction in WfH generation. Moreover, WfH recycled
accounted for mostly half of the total volume of WfH. The UK’s WfH recycling rate was 45.0% in
2018, declining from 45.5% in 201741. 44.7% was the percentage of WfH recycling in England; and
47.7%, 42.8% and lastly 54.1% for Northern Ireland, for Scotland, for Wales respectively. From 2017
to 2018, England’s recycling rate falls 0.5%, Scotland 0.7%, and Wales 1.1%.
Table 3: Total waste generated by the commercial and industrial sectors, UK and England, 2010-1842
In all countries in the UK, commercial waste was decreasing during the period from 2010 until 2014,
whereas industrial waste has experienced a fluctuation in its trend. In England, the amount of waste
in these two sectors remains its stability. However, the period from 2014 to 2018 witnessed a
significant increase in commercial waste volume in England; meanwhile, industrial waste volume
41 Adam Vaughan, ‘Waste incineration set to overtake recycling in England, Greens warn’ The Guardian (16 July 2018)
<https://www.theguardian.com/environment/2018/jul/16/waste-incineration-set-overtake-recycling-england-greens-
warn> accessed 25 August 2020
42 Taken from Department for Environment, Food & Rural Affairs, ‘UK Statistics on Waste:Statistical notice on March
2020’ (London, United Kingdom 03/2020) 9
<https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/874265/UK_Statisti
cs_on_Waste_statistical_notice_March_2020_accessible_FINAL_rev_v0.5.pdf> accessed 25-Aug-20

21
remained stable. Commercial and industrial waste are considered to contain many hazardous
components, which are essential to take into caution while implementing the WTE process.
Figure 2: Waste generation split by source in the UK, 201643
C&I figures presented in this diagram resembles the Commercial and Industrial waste that was
introduced in Table 2. CD&E denotes Construction, Demolition and Excavation waste (including
dredging). Household indicates WfH as demonstrated in Table 1. The diagram in Table 3 shows the
participation of 3/5 CD&E (i.e. 62%) in total UK waste in 2016; whereas C&I accounted for almost
1/5 (i.e. 18%) of total UK waste. The rest was shared between WfH (12%) and other activities (8%).
3.1.2. Waste management:
a) General situation:
43 Taken from ibid 10

22
Table 4:All waste at final treatment, split by method, UK and England, 2014 - 201644
Since 2004, the UK practices its waste management through landfills towards the following
type of waste: (i) hazardous waste; (ii) non-hazardous waste; (iii) inert waste. In England, incineration
as a waste management solution, at present, appears to be much more popular than recycling activities
since it is recorded that there is a continuously increasing amount of waste to be burnt than to be
recycled according to recent study. The period of time between the year of 2010-2011 and 2016-2017
had seen a remarkable rise of amount of waste treated by incineration, in other word by WTE plants45.
London, the West Midlands and north-east already burn more than they recycle. A reliable report from
Green Party in the UK states that the continuity of incineration method will lead to the consequence
where the millions of tonnes of waste incinerated will overtake the amount sent for recycling by the
end of the current financial year. Nonetheless, incineration is apparently not supported by the Green
party due to its negative impact to environment46.
Indeed, many opinions indicate that some categories of materials can potentially satisfy
conditions to go through other waste treatment that belongs to precedent stages in the waste hierarchy,
such as waste prevention, re-use or most commonly recycling, prior to being treated in incinerators
within the WTE plants. Such argument can give rise to a legitimate concern. It should be taken into
44 ibid 12
45 ibid 13
46 ibid

23
consideration that WTE process is not originally the key issue, but the focus is placed mostly on the
task to separate recyclable waste from residual waste before being brought to WTE plant facilities. In
other word, the concern opens a discussion of the country’s consideration and preference to take right
action in order to ensure the categorisation, handling and treatment options towards recyclable waste
are optimised and effectively addressed. It is very interesting to notice that the UK considers its waste
management in a quite advanced perspective which introduce the idea that energy from waste can and
should co-exist, not eliminate, effective recycling.
b) WTE in the UK: new solution of waste management is introduced through a renewable energy
system which is WTE delivering economic value and creating a cost-effective contribution to the UK
environmental objectives in terms of waste management and energy goals as follows:
Economic value: the intervention of Government serves a purpose to create policies that
deliver economic value. However, Government’s supports to deliver value for money may be limited
in different ways, e.g. budget or meeting a specific target, but there will be a limit. Due to this reason,
despite the fact that surpassing the limit is a good thing from a perspective of government support
based on policy, but there exist certain restrictions with respect to Government’s funding provision –
that is to say in the circumstance the limit is reached, more expense shall incur. Energy incentives has
the target to offer more place for renewable technologies as well as investment in the renewable sector
in general. It aims to tackle market failures by the establishment of the development of technologies47.
Furthermore, Waste Infrastructure Delivery Programme (WIDP) programme plays an important role
in UK’s commitments to the EU Landfill Directive in the construction of biodegradable municipal
waste separation from landfill mechanism. This relates substantially to the UK government’s policy
as regard to WTE plant system because it provides a legal basis to deal with issues regarding recycling
process and facilities which is a stage prior energy from waste generation. However, the goal of WIDP
is limited; hence, it is not necessary that there shall be more facilities to be constructed than required
by obligations provided in Landfill Directive. This explains why despite that WIDP programme offers
financial supports, additional government funding with an intention to achieve more than what the
target determines shall not be supported. For instance, there exists certain projects for which
governmental funding was withdrawn. Nevertheless, energy from waste planning remain its essential
47 Avraam Karagiannidis, Waste to Energy (1st, Springer London 2012)

24
position during the course of the UK’s practicing and complying with obligations regulated in Landfill
Directive. There exists always an enormous amount of waste that needs to be handled which offers a
great potential of WTE plant system development. Therefore, there is a need for the continued
development WIDP to earn constantly economic benefits, besides the need for such programme to be
consistent with government policy.
Cost effective: WTE plant system in particular has the potential to deliver low carbon energy
yet remains its cost-effective and non-intermittent characteristic that ensures energy security. This
approach needs to be applied to waste as a form of bioenergy. These calculations for conventional
biomass need to contain the components such as land use change and the processes required to turn
the biomass into a useful fuel48.
3.2. Legislation with respect to WTE in the UK
3.2.1. National laws
a) The Environment Protection Act 1990 (EPA)49: This Act includes the provisions of matters
with respect to air, water and land pollution by stipulating waste management and emissions control.
The section about “Waste on land” is provided in Part II of this Act and presents violation relating to
controlled waste and requirement of a duty of care of business or person “who produces, carries,
keeps, treats, disposes of or imports-controlled waste”.
b) The Hazardous Waste Regulations 2005 (HWR)50: England, North Ireland and Wales has
officially seen the new Hazardous Waste Regulations came into force on 16th July 2005. The key
content provided by the Regulations indicates the requirement of registration with Environment
Agency when an organisation produces hazardous waste (with exceptions for organisations which
produce annually less than 500kg of hazardous waste). Accordingly, the definition of hazardous waste
is determined as “sharps, cytotoxic and cytostatic medicines and other clinical waste” and items which
contains hazardous materials “such as fluorescent tubes”. The very same definition of ‘Hazardous
Waste” is also found and is named as ‘Special Waste’ in the Special Waste Amendment Regulations
48 ibid 31
49 Environmental Protection Act 1990
50 Hazardous Waste (England and Wales) Regulations 2005 (Her Majesty's Government)

25
2004 (of Scotland). However, on the contrary, the Regulations exempt organisations who produce
‘Special Waste’ in Scotland from registration obligation with the Environment Agency, even if waste
is exported to England or Wales. According to the Regulations, if a person or a business produces
hazardous waste, holds or stores hazardous waste or has hazardous waste removed from its premises,
such person or business must follow the steps as follows: (i) categorise the waste to check if it
hazardous; (ii) categorise and store such hazardous waste safely; (iii) use authorised agent to be in
charge of hazardous waste collection, recycling and disposal, provided that such waste management
agents must be registered and their premise used for waste treatment must obtain environmental
permits; (iv) complete the consignment note; (v) remain and update the status of registration of waste
produced or stored at the premise.
c) The Producer Responsibility Obligations or colloquially known as Packaging Waste
Regulations 1997 (PWR)51: The Regulations were introduced in 1997 with an aim to reduce negative
impact of packaging to the environment. PWR concern businesses are involved with producing, using
and selling packaging or related-package products. In particular, a business that reaches £2 million
turnovers and produces more than 50 tonnes of packing in the previous year must comply with the
PWR. Following this, they are liable to recover and recycle a proportionate amount of materials used
for packaging in the market. The specific obligations imposed on these businesses include52:
 Produce less packaging.
 Bring less packaging waste to landfill.
 Recycle and recover more packaging.
d) Planning Act 2008 (PA)53: The Planning Act 2008 came into force in the UK with a target of
improving the approval schedule for significant infrastructure projects (certain ones of which can be
deemed as Nationally Significant Infrastructure Projects). The establishment of
the Infrastructure Planning Commission (IPC) through this Act with a function to authorise significant
new infrastructure projects, among which energy facilities belong to one category. The approval
51 Producer Responsibility Obligations (Packaging Waste)Regulations 1997 (Her Majesty's Government)
52 ibid Sec 3
53 Planning Act 2008

26
orders - with the removal of the Secretary of State’s ability to make the final decision - regarding such
projects help the process to obtain planning permission become faster and simpler. This plays an
essential role in many decisions concerning the largest plants for waste development, including the
facilities of WTE.
e) Localism Act 201154: This Act is constituted with an intention to assign greater powers and
control to local authorities and/or local communities over housing and planning decisions. This Act
incorporates the coordination between different tiers of councils and neighbouring authorities is of
paramountcy in determining how to manage the WTE plant’s system. Several key areas which relate
to waste management are demonstrated as follows:
 Power of competence;
 Right to opting for committee system of governance and for referendums for elected mayors
in certain authorities;
 Power to safeguard local organisations stipulated under the Localism Act, that may be exposed
to the risk of losing their premises,
 The right conferred to organisations and/or community to challenge local authorities over their
decisions or instructions in relation to local projects stipulated by the Localism Act.
f) Renewable Obligations (RO) scheme administered by Office of Gas and Electricity Markets
in the UK (OFGEM)55: Major renewable electricity projects in the UK have been supported by the
mechanism of RO which commenced to be implemented England, Wales and Scotland, then in 2005
in Northern Ireland. Currently, it is considered as the Government’s main policy instrument for these
major energy projects. According to RO, electricity suppliers owe an obligation to purchase a stable
amount of electricity generated from renewable sources; failing to comply with such obligation, they
will be subject to a penalty. The process of justification to Ofgem that their obligation is achieved
involves Renewables Obligation Certificates (ROCs) received from renewable electricity generators
(for the renewable fraction of waste or for municipal waste).
54 Localism Act 2011
55 Renewables Obligation Order 2005 (Her Majesty's Government)

27
3.2.2. International treaties and conventions56
a) EU Waste Framework Directive (2008/98/EC) (WFD)57: The Waste Framework Directive is
promulgated by the EU that came into effect on 17th June 2008. 1975 was the year when the first
WFD was introduced, and subsequently, its amendment occurred in 1991 and 2006 in a substantial
way. The aim of the WFD was to create a legal basis in order to encourage EU in its recycling
campaign. Accordingly, relying on the guidance of WFD, member states can regulate its waste
management policies to design a suitable and appropriate treatment within the waste hierarchy in order
to ensure these policies conforms with WFD provisions and to bring about an outcome that is
advantageous for environment. A serious life-cycle analysis that depicts the impact of waste
management in coordination with energy generation is essential for the implementation of these
obligations in question.
The definition of waste is provided in Article 3 (1) thereof as ‘any substance or object which
the holder discards or intends or is required to discard’. It is important to notice that the terms’
substance’ and ‘object’ are not construed the same as in provisions of EU chemicals legislation, but
in a broader perspective as either waste or non-waste. The Member States shall confer with the
European Court of Justice (ECJ) should ambiguity arise, where ECJ shall clarify and interpret how
waste shall be defined on several occasions, in the consideration of their definition under the previous
directives (Guidance on the interpretation of key provisions of Directive 2008/98/EC on waste).
WFD also introduces an approach of EU environmental laws through the new waste hierarchy
provided in Article 4 WFD which describes a priority order for waste management. This hierarchy
contains five methods of handling waste that can be considered as follows: (i) Prevention; (ii)
Preparing for re-use; (iii) Recycling; (iv) Other recovery, e.g. energy recovery; and (v) Disposal. To
be precise, ‘prevention’ is technically not a waste-management measure because it is originally the
substances and objects that it deals with, and not yet waste. According to the organisation of this
priority order, WFD has presented a preeminent environmental legislation and policy regarding waste
56 While the United Kingdom has ceased its membership in the European Union on 31st January 2020, the transitory
period, where the UK must adhere to every biding EU’s legal instrument, will last until the end of 2020.
57 Directive 2008/98/EC on wastes and repealing certain Directives 19 November 2008, WFD (European Parliament;
Council of the European Union)

28
management. The new waste hierarchy sees substantially modifications in comparison with the
previous waste hierarchy of Directive 2006/12/EC are: (i) The waste hierarchy currently includes five
steps; (ii) The new concept of ‘Preparing for re-use’; (iii) Equal regard towards the importance for re-
use, recycling and other recovery. The new WFD brings about a closer approach to recycling
community for the member states of this Directive (see Recital 28), in terms of differentiation between
these. It is compulsory for member states to comply with the waste hierarchy in order to ensure a
positive environmental outcome. However, in special circumstances where specific waste streams
whose life-cycle is justified harmless to environment, member states are authorised to be exempted
from implementing this hierarchy.
b) EU Directive on The Landfill of Waste (1999/31/EC) (Landfill Directive)58: The EU Landfill
Directive aims to weaken the possibility for member states to dispose their waste by the option of
landfill, in order to reduce its environmental impacts and its threat to human health by imposition of
a set of conditions and/or criteria to implement landfill option in the EU. The Landfill Directive
stipulates the organisations that produce, collect and dispose waste in the EU in terms of their landfill
location (i.e. disposal sites, waste deposit storage), construction and operation, Biodegradable
Municipal Waste (BMW) from landfill target, related-landfill waste controls, different kinds of waste
such as municipal waste, hazardous or non-hazardous waste and inert waste. The Directive also
concerns the pre-treatment solutions for waste before being brought to a landfill. The UK has mainly
opted landfill as its waste management option for an extended period of time. The UK must be subject
to obtaining targets set by the Landfill Directive to steadily and continuously decrease the amount of
biodegradable municipal waste that shall be treated and disposed in landfill. In order to achieve such
goals, Landfill Allowances Trading Scheme was also adopted by the UK.
Considerable changes regarding waste management, especially the categorisation of biodegradable
waste from landfill have been notified thanks to The Landfill Directive. Following the positive affect
that Landfill Directive creates, the UK has applied the requirements and obligations in relation with
waste management in landfill into its national legislation which is the Landfill (England and Wales)
Regulations 2002 (subsequently amended in 2004 and 2005), and later as part of the Environmental
Permitting (England and Wales) Regulations 2007.
58 Directive 1999/31/EC of 26 April 1999 on the landfill of waste 1999 (Council of the European Union)

29
c) The EU Renewable Energy Directive (RED)59: Unlike the pioneers in energy recovery field
such as Denmark and Germany who has reformed their energy legislation beforehand, the UK
commenced such reform later. The starting point of this period began with the EU Renewable Energy
Directive. Indeed, UK has implemented the transposition of the Directive’s principles and provisions
into its national legislation through the Renewable Transport Fuel Obligation (RTFO). Under the
RTFO, a set of criteria must be satisfied by those supplying biofuels in order for their fuels to benefit
Renewable Transport Fuel Certificates (RTFCs). Following the RED, the UK is legally required to
source 15% of its total energy from renewable sources by 2020. Energy from the biogenic part of
mixed residual waste is considered as a methodology that significantly brings the UK to the 2020
target in a cost effective and sustainable way, or even to the subsequent years. This Directive does not
consider WTE as an exclusive option to reach the goals of renewable energy.
d) Waste Incineration Directive (2000/76/EC) (WID)60: The Waste Incineration Directive laid
out standards and methodologies required by the EU for the practice of waste incineration. The WID
set a target to control what can be emitted into surrounding (such as air, soil, surface and ground water)
by WTE plants, thereby negative consequences shall be avoided when detrimental effects on human
health and environment resulting from these emissions can be minimised. The development of WID
proposed set of requirements to put in place modern incineration plants since such facilities can offer
stricter control with higher standards of emission more effectively.
e) Industrial Emissions Directive (2010/75/EU)61: The Industrial Emissions Directive replaces
effectively the WID in 2014. It provides for pollution prevention and control for industrial emissions,
with an aim to commits member states to optimally lessen the impact of industrial emissions on the
environment by decreasing emissions from industrial production through an integrated approach via
the plan of best available technology to help achieve the goals of the directive. The plan allows for
59 Directive 2009/28/EC on the promotion of the use of energy from renewable sources and amending and subsequently
repealing Directives 2001/77/EC 23 April 2009, RED (European Parliament; Council of the European Union)
60 Directive 2000/76/EC on the incineration of waste 04/12/200, WID (European Parliament; Council of the European
Union)
61 Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control) 24 November 2010
(European Parliament; Council of the European Union)

30
flexibility given the best available technology; exemptions to the directive can be granted to firms as
well if the cost is greater than the benefit.
3.2.3. Analysis
The relevant national laws of the UK enact some general environmental protection principles
regarding WTE plants system, in which precaution and sustainability, technical feasibility and
economic viability, protection of resources as well as the overall environmental, human health,
economic and social impacts have been well regulated62. The most crucial national law to WTE
regulations is the EPA 1990, which deals with issues relating to waste on land, identifying
comprehensive waste management aspects and waste collection of local authorities as well as their
obligations. It also stipulates businesses’ activities in handling waste produced in a safe and lawful
manner. This is considered as ‘duty of care’ that applies to any person and corporate who produces,
imports, transports, stores, treats or disposes of controlled waste from businesses or industries.
Regarding the intervention of the Localism Act, it participates crucially in the waste
management process in the UK. Indeed, local strategies support to deliver cooperation between
different levels of authority in dealing with waste management, create an opportunity for the local
community to be engaged in the process, and facilitate solutions with more efficiency. Localism Act
helps to ensure that such coordination is manifested in all processes of waste management. During the
course of development of WTE and similar waste treatment strategies, relevant issues are underscored,
debated and addressed, and potential sites identified, specific proposals are made. This is evident that
WTE solution is taken into consideration not as a sole factor but as part of a broader assessment of
options for the whole waste management process. However, there are two significant constraints63:
In the event of dual layers of local authority exist (which have differing planning
responsibilities), the management of residual waste will be delivered to WTE plants would fall into
the authority and responsibility of county council; whereas, the categorisation and collection process
will be authorised and responsible by the district or borough council. This can be seen as the division
of competence amongst the governmental apparatus.
62 David Pocklington, The law of waste management (Shaw 1997)
63 ibid 22.

31
Theoretically, WTE plant facilities must submit its planning to the county council or unitary
authority who are considered the Waste Planning Authority (WPA). The planning application shall
then normally present extensively and precisely the relevant issues, materials as well as
recommendations with respect to the WTE plant facilities’ local plan, thereby the WPA shall take into
consideration and make a decision in accordance with policies of National Planning Policy
Framework. The preparation of strategic plans by local authorities is the ground on which the National
Planning Policy Framework is established. National planning policy and local policy framework shall
be considered together for decisions on applications to be made, which is the reason why this process
typically also involves with elected Councillors. Upon the submission of the planning application,
local community’s and other consultees’ opinions, as well as relevant statutes, will be consulted64.
WPA requires that planning applications – which include the details should be constituted and
structured in earlier steps – must comply with the development proposal, unless material
considerations regulate otherwise. The development proposal is deemed as an ultimate assessment
step of the planning process, thereby solutions for waste management shall be developed in a
consistent way with the local plan. In particular, an application for planning permission demonstrates
a plan of applying energy from waste solution as a definitive result of the waste management process.
Furthermore, regarding the utilisation of land for the construction of WTE plant facilities in a
local area, the plan must determine suitable waste infrastructure location. The identification of waste
infrastructure location starts on a larger area and becomes more specific in the following step.
Location is determined based on a set of precise criteria, rely on which the option of energy location
will be estimated and decided. Moreover, the plan must clarify the intention to finalise the waste
treatment by a WTE process, particularly in terms of provision of sufficient sites, safety for the use of
heat through WTE plants operation. As a result, WTE plants are decided to be adopted when the
availability of sites and environmental benefits are assured. In the situation where WTE plants are
proposed as potential projects, the location and other factors will be considerably affected by these
local plans and other policies contained in the National Planning Policy Framework. The integration
of such planning throughout the waste hierarchy has proved it a preeminent approach of waste
management shall be presented: significant importance should be placed on local authorities having
64 ibid 22.

32
engagement with their communities about the need and locations for WTE plant facilities to serve
sustainable development – prior, during and subsequent to propose different options and develop WTE
plan accordingly. The engagement of the local community in developing these local plans is vital, as
it pays significant attention to WTE plant facilities as one of the preeminent solutions for waste
management and energy recovery. Local participation can be demonstrated by the local plans being
updated and integrated with national waste management strategies. However, it is undeniable that
complying with the requirements provided in these local plans that manifest local expectation and
need; there always exists opposition for developers. This is the occasion where local authorities
exercise its role to ensure communities are acquainted with the implementation of application for
WTE plants planning permission as well as are engaged in the process.
The UK has demonstrated its timely consideration to the future of energy from waste via its
national legislation, policies and its participation in international and regional environmental treaties.
The sector of energy from waste is initially rooted in waste management and currently yields many
positives outcome, not only on the productivity of energy generation but also on the general
improvement of the environment. Indeed, the evolution of the WTE plant system is based on the
development of waste management and the increasing significance of energy production.
Following this, waste management is no longer limited as it used to be construed of how waste
is disposed and discarded, but its modern concept has also been widened to how such waste will serve
the purpose of energy recovery, thereby contributing to environment and economy of the country65.
Consequently, it serves the purpose to ensure energy security via a WTE plant system’s energy
generation from waste66. Therefore, energy from waste is considered not only as an instrument to
manage waste but also as a source to extract energy. This translates to a crucial and exclusive position
to obtain energy-related objectives in different departments in the governments.Significant
consideration from the Government expresses the will to support the growth in the waste and energy
65 ibid 1.
66 Om P Kharbanda and Ernest A Stallworthy, Waste management: Towards a sustainable society (Auburn House
1990)

33
sectors through infrastructure development. The UK government has set out many targets for waste
policy and infrastructure development over the last ten years or so.
Undoubtedly, various environmental advantages for society benefit from WTE generation.
This requires, however, the efficient implementation of legislation and policies for energy from waste.
These policies will be an effective instrument of the Government to develop and control energy from
waste; hence, are determined as a mean for authorities to handle in the best way to maximise the
energy use from energy from waste67. Environmental legislation provides a platform where waste
management and energy generation companies have to navigate and manage their activity to ensure
its conformity with obligations provided in such laws and regulations. The active transposition of the
UK from the international treaties, where it is a contracting state, and responsive renewal within the
country legislation have fully illustrated the government’s long-term vision for the future regarding
WTE plants’ system utilisation.
4. Legality of WTE in Singapore
4.1. Background
4.1.1. Amount of waste per year
In 2014, the amount of waste generated stood at 7.51 million tonnes. According to the recent
statistics68 from the National Environment Agency (NEA), the amount of solid waste generated in
Singapore was 7.23 million tonnes in 2019, the such amount is decreased to 460,000 tonnes from
2018, equivalent to a 6 per cent reduction. The year of 2017 and 2018 saw a considerable fall of such
amount of waste created by 9,000 tonnes. The amount of waste generated last year was also 280,000
tonnes less than five years before.
The waste generated in both domestic and non-domestic sectors also witness a dip. For the
domestic sector, the waste generated last year was 1.87 million tonnes, down from 2 million tonnes
the previous year. This figure is also a reduction from five years before, when domestic waste made
67 John H Bates, U.K. waste management law (2nd ed. Sweet & Maxwell 1997)
68 Singaporean National Environment Agency,‘Waste Statistics and Overall Recycling’ (Singapore 15 March 2020)
<https://www.nea.gov.sg/our-services/waste-management/waste-statistics-and-overall-recycling> accessed 27-Aug-20

34
up 2.1 million tonnes. For the non-domestic sector, the waste generated last year was 5.37 million
tonnes, down from 5.70 million tonnes in 2018, but closer to the 5.4 million tonnes in 2014. The NEA
called the reduction in waste a “positive step” in Singapore’s journey to becoming a “Zero Waste
Nation” and to extending the lifespan of Semakau Landfill beyond its projected 2035 deadline.
4.1.2. Waste management
a) General situation: The amount of solid waste disposed has risen up seven times in 2016 in
comparison with 1970 due to the country’s population growth and rapid economic development. The
Government of Singapore expected to make 2019 the “Year Towards Zero Waste”, launching a
masterplan to reduce the amount of waste among three main categories of waste – (i) electrical and
electronic waste, (ii) food waste, and (iii) packaging waste including plastics69. As part of its plans,
the Government also announced its goal to reduce the waste sent to Singapore’s only landfill, Semakau
Landfill, by 30 per cent, by the year 2030 so that it can last beyond 2035. Among the various waste
streams, plastic, textile and food saw a drop in the amount of waste generated. Private domiciles and
corporates are the subjects that the Government of Singapore aims at to practice its solid waste
management campaign70.
b) WTE in Singapore: Similar to the UK, Singapore also put in place the methodology of
categorising and recycling waste before collecting them and process to next stages, with the purpose
of prolonging the life-cycle of recyclable materials as well as facilitating combustion process
conducted by WTE plants. Following this sorting of recyclable waste, the collection and delivery of
these residual solid waste to WTE plants shall be executed, then be treated by incinerators in the next
stage. The advantage of WTE plants is that waste incineration leads to a reduction of waste volume
by about 90% and electricity generation. The incinerated ash and other non-incinerable wastes are
69 Audrey Tan, ‘Parliament: New zero-waste law to compel big firms to take greater action’ The Strait Times (06-Sep-
19) <https://www.straitstimes.com/singapore/new-zero-waste-law-to-compel-big-firms-to-take-greater-action> accessed
27-Aug-20
70 Agamuthu Pariatamby and Masaru Tanaka (eds), Municipal Solid Waste Management in Asia and the Pacific
Islands: Challengesand Strategic Solutions (Environmental Science, 1st ed. 2014, Springer Singapore; Imprint:
Springer 2014)

35
then transported to the Tuas Marine Transfer Station (TMTS) for the barging operation to Semakau
Landfill where they are disposed of.
Currently, Singapore’s solid waste disposal infrastructure consists of four WTE plants: Tuas, Senoko,
Tuas South and Keppel Seghers Tuas Waste-To-Energy Plant as well as the Semakau Landfill71.
 Keppel Seghers Tuas Waste-To-Energy Plant (KSTP) replaced Ulu Pandan (which was the
first WTE plant facility in Singapore) and was improved based on Design, Build, Own and Operate
model in 200972.
 The Senoko Incineration Plant was taken over by a private organisation in September 2009
which led to its modification of name to Senoko Waste-To-Energy Plant (SWTE). During its course
of activation, it helped create a sustainable waste management framework where a need for future
landfill was reduced73.
 Tuas Marine Transfer Station (TMTS) is a facility of WTE plants that allows solid waste to
be unloaded directly from vehicles into long barges and non-incinerable solid waste are brought to the
facility74.
 Semakau Landfill: has an area of 350 hectares and commenced its activity on 1st April 1999.
It is currently Singapore’s only landfill facility and expected to meet the country’s solid waste disposal
needs up to 2035 and beyond. In 2016, the landfill received an average of 2,189 tonnes of WTE plant
ash and non-incinerable waste daily. In order to protect the marine environment of the country,
especially to preserve the coral reefs along Pulau Semakau’s western shore, the Government of
Singapore took certain measures75.
Furthermore, Integrated Waste Management Facility (IWMF) was considered by NEA satisfy
its waste management needs and achieve long term environmental sustainability. Indeed, innovative
71 ibid 42.
72 ibid 42.
73 ibid 42.
74 ibid 42.
75 ibid 42.

36
solutions that optimise energy and resource recovery from waste, such as WTE plant facilities will be
developed. Singapore has constructed new IWMF with the ambition to make it the largest energy
recovery facility in the world. The most advanced technology in relation with WTE plants structure,
design and equipment was utilised to benefit this construction. By co-locating the facility next to a
new water reclamation plant (Tuas WRP) it will be possible to achieve the highest energy efficiency
and lowest greenhouse gas footprint76.
During the development of Singapore, the principal reason that urges the Government to be
determined to proceed the construction of this new WTE plant system: that is the rapid raise of the
nation’s population on a limited area of the country which, consequently, results in a challenge of
clean water and waste management. Due to this reason, Singapore has an urgency to come up with
one sustainable approach to tackling such challenges. The IWMF is result of the Government’s
resolution thereto. It consists of a WTE plant, which exists also an incineration plant therewithin77.
4.2. Legislation with respect to WTE in Singapore
4.2.1. Legislation
a) Environmental Public Health Act (General Waste Collection Regulations) 198778: This Act
consolidates the law relating to environmental public health and to provide for matters connected
therewith such as general waste collection and food hygiene. Following this, Chapter 95 of the Act
provides for the licensing, transportation and disposal of industrial and domestic waste from land.
This Chapter tackles the issues such as the assignment of waste collection worker and disposal
facilities to collect and dispose industrial waste, processes of recycling and reusing hazardous or toxic
materials, waste treatment prior to disposal by waste producers, procedures to obtain a permission for
waste disposal subsequent to the treatment, and competent authority.
76 State of Green, ‘World’s largest waste-to-energy facility in Singapore’ (2020)
<https://stateofgreen.com/en/partners/ramboll/solutions/combining-waste-and-used-water-in-a-singaporean-mega-
project/> accessed 27-Aug-20
77 Pariatamby and Tanaka (eds) (n 70)
78 Environmental Public Health Act 1987

37
b) Environmental Protection and Management Act 1999 (2004)79: Air, water and noise pollution
control as well as hazardous waste management and licensing of industrial plants are the matters
regulated in this Act with an aim to protect the environment and conserve resource.
c) Regulations concerning hazardous waste:
- The Environment Protection and Management (Hazardous substances) Regulations (No.
S159/1999)80: introduced in 1999 (2011) provide regulations for the transport, import, storage and
supply of hazardous substances. In particular, regarding transportation branch, the safety requirements
and the actions taken by the transporter must be included in the transport documents that relates to
hazardous materials. Besides, the regulations provide for consignor’s responsibility, carrier’s
obligation to obtain information about consignment, instructions for garbage truck drivers as well as
their responsibilities, transport routes, hazard warning, precaution of fire and explosion, ban of
overfill, carriage of multi-loads of hazardous materials, supervisions of vehicles of carriers. With
respect to import provisions, both import activities and activities of collection of imported hazardous
substances are stipulated, in which a license shall be required to import hazardous waste in Singapore.
The same principle of license requirement shall be applied for the person to be authorised to store and
use hazardous substances.
- Hazardous Waste (Control of Export, Import and Transit) Act 200381: The Chapter 122a of this Act
regulates the hazardous waste-related activities including export, import and transit of waste on the
following aspects: application, grant and revocation of permits to exercise these activities, violations
regarding orders from directors in relation to hazardous and other wastes. It also stipulates some
situations where waste import and export are prohibited and situations where Singapore prohibits of
carrying waste into the country in course of transit.
4.2.1. Analysis
Admittedly, Singapore has a thorough legal structure and legislation in almost every aspect of
environmental protection. These laws cover from general regulations regarding environmental
79 Environmental Protection and Management Act 1999
80 ibid
81 Hazardous Waste (Control of Export, Import and Transit) Act 1997

38
protection to specific sets of rules stipulating a broad range of issues about carbon pricing, hydrogen
cyanide fumigation, infectious diseases, radiation, vectors and pesticides, resource sustainability,
smoking prohibition, transboundary haze pollution, energy conservation act, amongst other
provisions. With respect to the field of energy, the legislation of Singapore specifically provides
energy labelling and performance standards for registrable goods, corporations transport facilities
operators, fuel economy labelling, motor vehicles subject to fuel economy, etc. However, there is an
absence of regulations that stipulates and controls the operation and practices of WTE plants within
waste management system.
According to the content of Environmental Public Health Act (General Waste Collection
Regulations) 1987 presented above, even though waste management subject-matter is provided in
certain parts of Singapore’s legislation, there exists significant lacking comprehensive and specific
rules stipulating the matters that are directly related to WTE plants. Specifically, the General Waste
Collection Regulations merely provides for licence, transportation and disposal of waste (including
incinerable and non-incinerable waste), but regulations for subsequent process of energy generation
from incineration are absent. This is a surprising finding as Singapore has developed a considerable
amount of solid waste disposal infrastructures, among which there is one considered the world’s
largest WTE facility.
On the other hand, hazardous waste seems to of a vital concern with respect to waste
management in this country as legislation clarifies with precision this matter in a much more
meticulous manner and places many obligations on businesses that produce waste containing
hazardous substances. Such consideration vis-à-vis hazardous waste constitutes an important
safeguard when during the course of practicing waste treatment by WTE plants, because this system
operates based on the preference to eliminate as much hazardous and recyclable waste as possible.
5. Comparison amongst such jurisdictions regarding WTE system
5.1.The participation in international treaties
As a matter of fact, the UK is a member state of many regional environmental conventions
and treaties whereas Thailand and Singapore face certain shortcomings due to the absence of regional
laws that binds the countries to well-written and more comprehensive environmental schemes. Indeed,
regional treaties play an important role in encouraging implementation and enforcement of national
laws, specifically in this case for relevant matters of environment protection. The reason is because

39
certain national laws in some areas, such as environment-related fields, are amended to meet the
requirements of certain targets set out by regional or international convention and treaty. Such legal
harmonisation would lead to greater the environmental protection by the mean of multilateralism,
where the countries may utilise the comparative advantages of their neighbouring country.
5.2.Localism
In the UK, waste management strategies are considered to be evolved from local level. Indeed,
Localism Act provides to allow local authorities to make decisions as to whether WTE solution shall
be adopted (in accordance with the waste hierarchy) and in which circumstances. The advantage from
this is that local authorities understand which circumstance their community is under and thus, can
integrate WTE option with other solutions in a reasonable and profitable hierarchy of waste
management such as reusing, recycling and composting can be explored first.
This also applies for the situation in Thailand, where it can be seen that there is a decentralisation
at the upper echelon governmental body, as explained in subsection 2.2.2. of this paper. However, the
central government thereof still holds some certain rights with regards to coordinating waste
management and energy generation; whereas, the local authority has a degree of autonomy to
implement such centralised decision in their own regions. This is akin to the direct effect of EU legal
documents laid out to its Member States. In the case of Singapore, having the geopolitical status a
city-state, the city does not need any degree of localism.
5.3.Hazardous materials
Thailand, the UK, and Singapore value highly the task to provide comprehensive and exhaustive
regulations regarding hazardous waste and the duty of care of businesses during the course of waste
management to treat hazardous waste in an appropriate and lawful method. Singapore has established
many regulations within its source of national laws such as The Environment Protection and
Management (Hazardous substances) Regulations (No. S 159/1999) and Hazardous Waste (Control
of Export, Import and Transit) Act 2003 which cover in a comprehensive manner the content of
transport, import, storage and supply of substances. This creates a solid legal basis as hazardous waste
is a subject-matter – besides recyclable waste – that is connected with the waste treatment prior to
incineration/combustion process of WTE plant operation.

40
6. Recommendation and possible solutions
First, similar to Singapore, Thailand seems to face the same disadvantage: that is regional
legislation is unable to function in the most efficient way to facilitate the participation in regional
treaties of between member states and to provide the common protection to ASEAN countries. It is
commonly known that ASEAN countries have not developed in homogenous manner; hence unlike
Europe, regional legislation such as bilateral or multilateral agreements occasionally fail to
demonstrate their uniform role and function in implementation of legal rules throughout the region.
The regional conventions between ASEAN countries regulating WTE plants system have not yet
considered, constituted and shall see a long process to be agreed between the countries. Therefore, it
is important for Thailand to propose and motivate ASEAN to pay more focus on the environmental
policies in general, and especially on WTE plants system as innovative solution of modern waste
management and disposal mechanism which can generates energy in the end. These countries may
need to deepen their discussion regarding such issue to strengthen the connection between the ASEAN
countries, to exchange ideas and solutions in handling environmental and energy matters, and to get
support in regulating such issues together.
Second, localism and local planning have supported the UK in establishing an efficient
intervention in an efficient way of local authorities and communities which brings the UK certain
success in WTE process. Thailand can do further research how such idea is structured, organised and
implemented for the application of such idea for the future.
Third, Thailand should take reference from the UK or Sweden, those countries that have been
exercising energy-from-waste activities, in order to establish and incorporate into its national
legislation the important criteria and conditions regarding the planning permission, preparation,
construction and operation of WTE plant facilities. For instance, Thailand can set out regulations to
demand organisations that are in charge of WTE plant facilities to comply with obligations in relation
to consultation of local communities, waste management methodologies regarding transport, import,
export, collection and/or categorisation and division of waste such hazardous and recyclable waste,
organising pre-treatment of waste prior to combustion process, opting for WTE plants location,
controlling air and odour pollution, etc.

41
7. Conclusion
There are several key questions for the energy from waste debate which this dissertation aims to
facilitate. This discussion should take into account the issues and information and assumptions around
waste growth and the likely development of activities relating to waste management in terms of
environment, economy, technology and especially national legislation. Regarding legal aspects, there
exist the current regulations and other principles underpinning future environmental policy
development that affect the construction, exploitation and expansion of WTE plants system in every
country. The countries that are starting to apply this system to their waste management solution should
consider legal regulations stipulating such matter in other countries that have certain success in order
to facilitate the process, ensure its legality and respect from waste producer as well as energy
generator.
Bibliography
Book
Bates JH, U.K. waste management law (2nd ed. Sweet & Maxwell 1997).
Ciuta S, Tsiamis D and Castaldi MJ, Gasification of waste materials: Technologies for generating
energy, gas, and chemicals from municipal solid waste, biomass, nonrecycled plastics,
sludges, and wet solid wastes (Academic Press, an imprint of Elsevier 2018).
Karagiannidis A, Waste to Energy (1st, Springer London 2012).
Kharbanda OP and Stallworthy EA, Waste management: Towards a sustainable society (Auburn
House 1990).
Mastellone ML, Waste management and clean energy production from municipal solid waste
(Waste and Waste Management, Nova Science Publishers, Inc 2014).
Pocklington D, The law of waste management (Shaw 1997).
Reddy PJ, Energy Recovery from Municipal Solid Waste by Thermal Conversion Technologies
(Taylor & Francis Ltd 2016).

42
Book, Edited
Pariatamby A and Tanaka M (eds), Municipal Solid Waste Management in Asia and the Pacific
Islands: Challenges and Strategic Solutions (Environmental Science, 1st ed. 2014, Springer
Singapore; Imprint: Springer 2014).
Contribution
Funatsu T, ‘Municipal Solid Waste Management in Thai Local Governments: The State of the
problem and prospects for regional waste management’ in Michikazu Kojima (ed), Toward
Regional Cooperation of Local Governments in ASEAN (2019).
Hower JC and others, ‘2 - Generation and nature of coal fly ash and bottom ash’ in Thomas L Robl,
Anne Oberlink and Rod Jones (eds), Coal combustion products (CCPs): Characteristics,
utilization and beneficiation/ Tom Robl, Anne Oberlink, Rod Jones (Woodhead Publishing
2017).
Journal Article
Boonpa S and Sharp A, ‘Waste-to-energy policy in Thailand’ (2017) 12(5) Energy Sources, Part B:
Economics, Planning, and Policy 434.
Internet Document
State of Green, ‘World’s largest waste-to-energy facility in Singapore’ (2020)
<https://stateofgreen.com/en/partners/ramboll/solutions/combining-waste-and-used-water-in-
a-singaporean-mega-project/> accessed 27-Aug-20.
Newspaper Article
Tan A, ‘Parliament: New zero-waste law to compel big firms to take greater action’ The Strait
Times (06-Sep-19) <https://www.straitstimes.com/singapore/new-zero-waste-law-to-compel-
big-firms-to-take-greater-action> accessed 27-Aug-20.
Vaughan A, ‘Waste incineration set to overtake recycling in England, Greens warn’ The Guardian
(16 July 2018) <https://www.theguardian.com/environment/2018/jul/16/waste-incineration-
set-overtake-recycling-england-greens-warn> accessed 25 August 2020.

43
Presentation
Wangwongwatana S, ‘3Rs and Waste Management in Thailand’ (Pollution Control Department of
Ministry of Natural Resources and Environment, Pollution Control Department of Ministry of
Natural Resources and Environment)
<https://www.uncrd.or.jp/content/documents/RT1_04_Thailand_rev.pdf> accessed 28 August
2020.
Statute or Regulation
Directive 1999/31/EC of 26 April 1999 on the landfill of waste 1999 (Council of the European
Union).
Directive 2000/76/EC on the incineration of waste 04/12/200, WID (European Parliament; Council
of the European Union).
Directive 2008/98/EC on wastes and repealing certain Directives 19 November 2008, WFD
(European Parliament; Council of the European Union).
Directive 2009/28/EC on the promotion of the use of energy from renewable sources and amending
and subsequently repealing Directives 2001/77/EC 23 April 2009, RED (European
Parliament; Council of the European Union).
Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control) 24
November 2010 (European Parliament; Council of the European Union).
Environmental Protection Act 1990.
Environmental Protection and Management Act 1999.
Environmental Public Health Act 1987.
Hazardous Waste (Control of Export, Import and Transit) Act 1997.
Hazardous Waste (England and Wales) Regulations 2005 (Her Majesty's Government).
Localism Act 2011.
Planning Act 2008.
Producer Responsibility Obligations (Packaging Waste) Regulations 1997 (Her Majesty's
Government).

44
Renewables Obligation Order 2005 (Her Majesty's Government).
พระราชบัญญัติ การพัฒนาและส่งเสริมพลังงาน พ.ศ. 2535 - Energy Development and Promotion Act 1992.
พระราชบัญญัติ การส่งเสริมการอนุรักษ์พลังงาน พ.ศ. ๒๕๓๕ - Energy Conservation Promotion Act 1992.
พระราชบัญญัติ รักษาความสะอาดและความเป็นระเบียบเรียบร้อยของบ้านเมือง พ.ศ. ๒๕๓๕ - Act on Maintenance of the
Cleanliness and Orderliness of the Country 1992.
พระราชบัญญัติ วัตถุอันตราย พ.ศ. ๒๕๓๕ - Hazardous Substance Act 1992.
พระราชบัญญัติ ส่งเสริมและรักษาคุณภาพสิ่งแวดล้อมแห่งชาติ พ.ศ. 2535 - Enhancement and Conservation of National
Environmental Quality Act 1992.
Report or Gray Literature
Bourguignon D, ‘Understanding waste management: policy challenges and opportunities’ (Brüssels
2015)
<https://www.europarl.europa.eu/RegData/etudes/BRIE/2015/559493/EPRS_BRI%282015%
29559493_EN.pdf> accessed 24-Aug-20.
Department for Environment, Food & Rural Affairs, ‘UK Statistics on Waste: Statistical notice on
March 2020’ (London, United Kingdom 03/2020)
<https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_dat
a/file/874265/UK_Statistics_on_Waste_statistical_notice_March_2020_accessible_FINAL_re
v_v0.5.pdf> accessed 25-Aug-20.
—— ‘ENV23 - UK statistics on waste’ (19 March 2020)
<https://www.gov.uk/government/statistical-data-sets/env23-uk-waste-data-and-
management> accessed 25-Aug-20.
European Commission, ‘Waste - Environment: Waste management’ (Brüssels 15-May-20)
<https://ec.europa.eu/environment/waste/> accessed 24-Aug-20.
International Comparative Legal Guides International Business Reports, ‘Environment & Climate
Change Law 2020 | Thailand | ICLG’ (London 23-Aug-20) <https://iclg.com/practice-
areas/environment-and-climate-change-laws-and-regulations/thailand> accessed 23-Aug-20.

45
International Energy Agency, ‘Thailand - Countries & Regions - IEA’ (2019)
<https://www.iea.org/countries/thailand> accessed 28-Aug-20.
Kamuang T and Siriratpiriya O, ‘Country Chapter: State of the 3Rs in Asia and the Pacific - The
Kingdom of Thailand’ (Hanoi, Vietnam 2017)
<https://www.uncrd.or.jp/content/documents/5695[Nov%202017]%20Thailand.pdf> accessed
28-Aug-20.
Singaporean National Environment Agency, ‘Waste Statistics and Overall Recycling’ (Singapore
15 March 2020) <https://www.nea.gov.sg/our-services/waste-management/waste-statistics-
and-overall-recycling> accessed 27-Aug-20.
UN Environment Programme (UNEP), ‘Waste Management in ASEAN Countries: Summary
Report’ (Bangkok, Thailand 2017) <https://www.unenvironment.org/resources/report/waste-
management-asean-countries-summary-report> accessed 27-Aug-20.

Waste-to-energy in Thailand comparative to other countries such as the UK and Singapore from the legal viewpoint and provide some recommendations.

Recommended

Recommended

More Related Content

Similar to Waste-to-energy in Thailand comparative to other countries such as the UK and Singapore from the legal viewpoint and provide some recommendations.

Similar to Waste-to-energy in Thailand comparative to other countries such as the UK and Singapore from the legal viewpoint and provide some recommendations. (18)

More from MattThird

More from MattThird (9)

Recently uploaded

Recently uploaded (20)

Waste-to-energy in Thailand comparative to other countries such as the UK and Singapore from the legal viewpoint and provide some recommendations.