In 2020, Zabalgarbi incinerated 230 000 tonnes of urban waste, collecting and incinerating almost 70% of them indiscriminately, without any pre-treatment (directly from the container to the furnace). The fact is that in 2020, between 27 March and 20 July, for 116 days, Zabalgarbi did not generate electricity, but during that time it continued to incinerate the waste. This incineration took place, therefore, without any energy recovery, i.e. 60-80,000 tonnes of urban waste, collecting the majority indiscriminately and incinerating without pre-treatment.

However, in 2020 this has not prevented Zabalgarbi from continuing to receive premiums for all the electricity it generates, thanks to the system of paying for electricity produced from renewable sources, cogeneration and waste. Zabalgarbi values the residues in a combined cycle that burns natural gas. It has therefore been able to collect around EUR 14 million in 2020 in exchange for electricity produced, although 70% or more of this electricity comes from the combustion of natural gas. In addition, according to the Ekopol study, Zabalgarbi offers very poor energy efficiency (40-43%) compared to other installations that work by combining cycles, but despite this, it has managed to charge on the Spanish day market a cassation price equivalent to the average annual price of electricity.

Another important source of income for Zabalgarbi is the bonuses of more than EUR 60 per tonne of CO2 generada.Como has been said, despite the fact that Zabalgarbi is basically a combined cycle, its inclusion in the category of waste recovery does not reach the CO2 Emissions Trading Scheme, so that by 2020 it will not have to buy EU greenhouse gas emission allowances, which would have a

First of all, the Zabalgarbi incinerator, despite being a combined low-energy cycle, has been able to obtain high premiums for its activity in 2020, on the one hand, EUR 14 million for producing 'on the excuse of waste recovery', mainly in spite of the burning of natural gas, and on the other EUR 3 million more because the authorities give it a surprising exception of payments for CO2 emissions. In Ekopol’s calculations, the Zabalgarbi incinerator is one of the companies with the highest CO2 emissions in the CAPV: 200,000 tonnes of CO2 per year.

The study by Ekopol provides a data that should immediately influence any liberal democracy, that is, a division of powers, a rigorous investigation by both the government and the judges. "If Zabalgarbi – says Ekopol- has left thousands of tonnes of waste unvalued in 2020 – has burned for 116 days without electricity generation – the cause has been neither technical nor environmental: in those days of electricity prices they did not give enough to cover the costs of natural gas that had to be burned to have a combined cycle."

At the end of the analysis, Ekopol researchers asked the environmental authorities in Bizkaia, the Basque Country and Spain to clarify the following issues:

- How many tonnes of waste were incinerated by Zabalgarbi in 2020 without energy recovery?

- How many residues (urban mixed) bearing the code LER 20 03 01 were burned in 2020 without energy recovery?

- How will the Provincial Council of Bizkaia – tax can be understood – act on the waste that was incinerated in 2020 without generating electricity?

- How will the fact that in the spring of 2020 action has been taken without producing electricity influence the Zabalgarbi R1 energy efficiency certification?

- How much does Zabalgarbi pay annually for CO2 emissions into the atmosphere?

- Why does the Register of Energy Production Facilities continue to explain that the main fuel used by Zabalgarbi is the residue and that natural gas is secondary?