Waste-to-energy (WtE) technologies should be treated as waste-management infrastructure rather than renewable energy (RE), with fiscal incentives tied to low-carbon performance and strong environmental safeguards, according to state-run policy think tank Philippine Institute for Development Studies (PIDS).

In a March 4 position paper, PIDS senior research fellow Adoracion M. Navarro examined the proposed Senate Bill (SB) Nos. 64, 292, 365, 884, and 1465. She warned that the bills risk policy incoherence by granting RE incentives to incineration technologies. Navarro noted that current laws, including the Clean Air Act of 1999 under Republic Act (RA) No. 8749 and the Ecological Solid Waste Management Act of 2000 under RA 9003, prohibit incineration of municipal, biomedical, and hazardous waste due to toxic emissions.

“The incineration of municipal waste is not inherently renewable,” Navarro explained. Municipal waste contains plastics and other non-biodegradable materials, and burning it produces both fossil and biogenic carbon dioxide. In contrast, the Renewable Energy Act of 2008 under RA 9513 allows only biodegradable organic by-products as feedstock for RE. Granting WtE technologies incentives similar to those for RE, Navarro warned, could create conflicts with environmental law and face opposition from environmental advocates.

Navarro recommended that WtE facilities be classified as waste-management infrastructure rather than RE projects. She said, “Fiscal incentives could be tied to measurable low-carbon performance improvements such as carbon capture, storage, and reuse, or significant landfill diversion. In effect, the revenues from WtE facilities can come from at least three sources: tipping fees for waste collection and management; electricity sales; and fiscal incentives.”

She also noted that public-private partnership (PPP) provisions in the SBs should align with the current PPP Code under RA 11966 rather than the outdated RA 6957.

In a separate paper dated March 9, PIDS senior research fellow Sonny N. Domingo and research analyst Roselle F. Guadalupe focused on operational, regulatory, and social aspects of WtE adoption. They noted that the Philippines generates roughly 14.6 million tons of municipal solid waste annually, ranking 27th globally, with volumes expected to rise steadily. Gaps in adequate waste disposal and treatment infrastructure underscore the potential role of WtE as a residual waste solution.

Domingo and Guadalupe praised the SBs’ delineation of responsibilities among the Department of Environment and Natural Resources (DENR), the Department of Energy (DOE), the Department of Health (DOH), local government units (LGUs), and the National Solid Waste Management Commission (NSWMC). “The Department of Science and Technology (DOST) may be considered for inclusion among the implementing agencies to provide technical assistance, technology assessment and validation, and research and development support for waste-to-energy systems, consistent with its mandate,” they recommended.

They also emphasized legal alignment. “It may therefore be useful to explicitly reiterate that waste reduction, reuse, recycling, and composting remain the primary strategies under the ecological solid waste management (RA 9003) framework, and that WtE should apply only to residual waste that cannot be recovered through higher-value processes,” they said.

Regarding environmental and social concerns, they added, “Opposition to WtE projects often arises from concerns about emissions, as well as potential environmental and community health impacts. To address these concerns, the bills should strengthen provisions on public consultation and social acceptability, community participation and stakeholder engagement, ecological integrity compliance monitoring, and accessible grievance and redress mechanisms.”

They also stressed operational standards. “Effective implementation will require strong monitoring and enforcement capacity. Adequate funding for monitoring systems, provisions for independent verification of emissions data, and clear enforcement procedures and guidelines, including timelines for corrective action, must be ensured. Strict evaluation of environmental performance and operational efficiency, as well as securing of an environmental compliance certificate (ECC), must be ensured prior to the approval and deployment of specific WtE technologies. The consolidated bill must also require greenhouse gas (GHG) emissions accounting in support of the country’s low-carbon development objectives and climate change-related commitments.”