Memorandum submitted by the Gloucestershire
Friends of the Earth Network (Waste 68)
EXECUTIVE SUMMARY
Flexibility is fundamental to meet the changing
world of the future in which climate change increases, raw materials
diminish and emerging industrialising nations add to the volatility
of markets and global economies. Flexibility should be fundamental
to the handling of waste as to any other industry.
Waste is also an area in which local communities
can positively contribute to achieving the government set target
of achieving 80% reduction of our carbon footprint by 2050.
Gloucestershire Friends of the Earth Network (GFOEN)
believe that a new approach to dealing with waste is needed. By
enabling the responsibility of decision making and action on waste
to remain within small local communities, it enables them to take
on the responsibility of dealing with their own waste. This principle
should be extended to the development of small local residual
waste management projects of proven need, after maximising recycling,
that match the scale, form and size of their surroundings and
that are acceptable to local communities. It is working on a small
community scale so that there is direct participation and action
at the local level that is the key. This would minimise the waste
carbon footprint and stimulate small and medium enterprises in
the recycling and in the recyclates industry.
In studying the process and procedures in the
handling of waste GFOEN has become increasingly concerned that
the PFI system established to meet the challenge of the EU Landfill
Directive, has led to the focus of PFI funding on residual waste,
to the detriment of financially encouraging local authorities
to achieve high recycling rates. Furthermore, the PFI system appears
to discourage public participation and innovation, all underlined
by the lack of transparency in critical areas of modelling which
directly influence outcomes leading to the critical decisions
of site, size of facility and technology of a residual waste facility.
For consideration by the Select Committee and
other communities GFOEN recommends:
— an increase in recycling targets
to 70% by 2013 and at 2013 to reassess 2020 targets upwards preferably
to 80%;
— greater separation of waste at kerbside;
— small local residual waste management
facilities that match the scale, form and size of their surroundings
and acceptable to local communities (5,000-45,000tpa, size dependent
on proven need) preferably MBT with Anaerobic Digestion on a few
local sites, for the benefit of local communities guided by variable
short term contracts. Development staggered to allow recycling
rates to increase over a period of time covered by LATS purchase
and brought on line with population growth. There should be several
small local contractors involved on different sites; and
— reforming the PFI criteria, contract
system and guidance with regard to waste to enable innovation
by:
1. widening PFI funding to reduction and
recycling;
2. removing the floor level minimum cost
for a residual waste project of £20 million;
3. removing the long term contract requirement
and providing the alternative of short term contracts of five
to 10 years;
4. requiring inclusion within an Outline
Business Case (OBC) reference project modelling small residual
waste facilities;
5. if contested, requiring projected waste
arisings to be tested at public inquiry before a residual waste
project proceeds to ministerial approval;
6. requiring all information and modelling
processes used to advance a residual waste project be available
for public inspection for transparency and for the greater public
interest;
7. requiring public consultation to take
place at each stage of procurement; and
8. removing the requirement for the output
specification to be "technology neutral" for PFI funding.
MEMORANDUM
Flexibility is fundamental to meet the changing
world of the future in which climate change increases, raw materials
diminish and emerging industrialising nations add to the volatility
of markets and global economies. Flexibility should be fundamental
to the handling of waste as to any other industry.
Gloucestershire Friends of the Earth Network(GFOEN)
have made representations to the Gloucestershire County Council
(GCC) that flexibility can be achieved by:
— an increase in recycling targets
to 70% by 2013 and at 2013 to reassess 2020 targets upwards preferably
to 80%;
— greater separation of waste at kerbside;
and
— small local residual waste management
facilities that match the scale, form and size of their surroundings
and acceptable to local communities (5,000-35,000tpa, size dependent
on proven need) preferably MBT with Anaerobic Digestion on a few
local sites around Gloucestershire, for the benefit of local communities
guided by variable short term contracts. Development staggered
to allow recycling rates to increase over a period of time covered
by LATS purchase and brought on line with population growth. There
should be several small local contractors involved on different
sites. GFOEN regards inflexibility to be a single large facility
with a long term contract that will dominate the waste market
with a single contractor with no competition.
In April 2008 the Cabinet of GCC made the decision
to look in depth at this dispersed solution (small local facilities
on several sites) however so far no appraisal work has been undertaken.
RECYCLING AND
COMMUNITY PARTICIPATION
In St. Arvans, Monmouthshire, a "Zero Waste"
project which promotes waste separation kerbside collections of
paper, glass, cans, foil, textiles, plastics, tetrapak cartons,
green waste and food waste, has diverted from landfill 73% of
household waste and has achieved a 95% participation rate in just
over a year by a dedicated waste team informing and enthusing
local residents. The Stanleys Waste Trial in the Stroud District,
Gloucestershire also achieved a good success rate.
These projects have shown that greater kerbside waste
separation can reduce the amount of residual waste going to landfill,
quickly and effectively, by building up enthusiasm and thereby
participation of small local communities by dedicated waste teams.
This underlines the importance of actively involving local communities
by enabling the responsibility of decision making and action on
waste to remain within local communities to enable them to take
on the responsibility of dealing with their own waste. This principle
should be extended to the development of small local residual
waste management projects of proven need and acceptable to local
communities on a few local sites around a county like Gloucestershire.
It is working on a small community scale so that there is direct
participation and action at the local level that is the key.
The Consultation on the Gloucestershire Joint
Municipal Waste Management Strategy revealed an overwhelming support
from residents and Parish Councils for greater recycling. Rural
areas like Gloucestershire, comprising of villages and market
towns are ideal for this approach and even Cheltenham and Gloucester
are made up of neighbourhoods. In addition this would minimise
the waste carbon footprint.
Waste separated to kerbside is good quality
waste that is acceptable to a wide range of industries that use
kerbside recyclables. Municipal Solid Waste (MSW) has the potential
to create new jobs in the collection and use of recyclables. The
rubbish that makes up MSW is made from raw materials and the energy
already used in its manufacture, so it makes economic sense to
recycle rather than start from scratch in making products to sell.
RECYCLING AND
INDUSTRY
Until the global economic crisis, increased
demands from the industrialising nations such as India and China
had forced up prices for raw materials eg metals. The London Metal
Exchange (LME) is promoting steel and plastics futures because
of the intense price volatility in these industries. It states
that the LME steel billet contract should also correlate with
the scrap metal sector. With economic stabilisation demand for
dry recyclables will increase in value and stimulate new small
businesses.
As little as ten years ago recycled paper was not
readily available, now it is quite commonly used in all kinds
of products, the same with recycled glass. Soft plastics are being
turned into all kinds of rigid products, even fence posts and
B&Q are advertising loft insulation made from recycled plastic.
Britain is good at innovation and it is an ideal area of development
for small new businesses thus providing new jobs and employment.
The work for the National Assembly for Wales
2007 by consultants, Eunomia showed 93.3% of the municipal waste
stream could be recycled yet a large scale incinerator can inhibit
the development of high recycling rates by long term contract
requirements. This places an artificial ceiling on recycling levels
and a quick and effective response to trading opportunities and
innovation. This is exampled by Kent County Council, who ten years
ago, signed a 25-year contract with Kent Enviropower to provide
them with 320,000 tonnes of waste to burn each year.
Quote from KentOnline news article about the
Allington incinerator, Kent.
Councillor Keith Ferrin, the council's environment
spokesman, said it had been a "stupid" decision in hindsight,
but there had been no way to predict changes to the industry.
He said:
"The people who thought they were being
very clever and economical with people's money 10 years ago have
produced a situation where the reverse is true, as KCC is now
committed to a contract we can't get out of."
"What seemed a very wise decision a very
long time ago is a very stupid one today."
He added:
"At the time, people were saying nationally
that this was the only way ahead."
"But if you make a prediction for 10 years'
time, the only thing you can be certain of is that it will be
the wrong decision."
Industry particularly small and medium sized
businesses tend to plan ahead on a 2/3 year basis because of the
fast changing nature of the competitive business market place,
in terms of innovation, changing demands, costs of labour, materials
and access to credit for expansion etc. Waste is an industry in
which County Councils need to have the same opportunity of short
term contracts to be able to realise the true value of waste and
to open this potentially innovative market to small and medium
sized enterprises (SME's) and thereby stimulate more employment
opportunities.
In Business First (issue 2, Summer 2008) John
Hutton, then the Secretary of State, Department for Business,
Enterprise and Regulatory Reform (BERR) stated that innovation
is the key to the Department's Enterprise Strategy and wished
to stimulate innovation through opening up government procurement
to SME's so that the government can benefit from the innovation
they bring.
The just released Glover Report, "Accelerating
the SME economic engine: through transparent, simple and strategic
procurement" states:
"Action is needed by Government to address
the concerns identified in this report. By ensuring open and fair
competition for public sector contracts, whilst minimising burdens
on potential and successful bidders, Government could not only
help SMEs directly but also save money for the taxpayer. SMEs
have an important role in supplying goods and services and the
increased competition and innovation they bring has an important
role in ensuring that the Government can deliver world-class public
services that are value for money."
THE PFI FUNDING
CRITERIA, CONTRACT
SYSTEM AND
GUIDANCE
The PFI funding, contract system and guidance
with reference to waste, is long overdue for revision, particularly
with regard to:
Transparency and Consultation
The Glover Report makes transparency an important
issue for supporting SME's with regard to local authority procurement
which includes waste. Full transparency in the processes, particularly
modelling processes and procedures in developing PFI residual
waste projects for procurement is also an important issue for
councillors, stakeholders and the public.
The Gloucestershire County Council have said that
it is required by the PFI process to make the output specification
"technology neutral" so that the bidders will come forward
with their own suggestions and that they will be assessed in particular
by the use of the Evaluation Framework.
The interests of the waste industry are likely
to be very different to what people feel is best for Gloucestershire,
particularly as the reference project in the Outline Business
Case (OBC) is a large incinerator with a 25 year contract which
is likely to give a bidder the best profit return. In the face
of such tempting guaranteed profits it is unlikely that a business
man is going to put in a bid for small facilities on short term
contracts no matter how good it would be for the Gloucestershire
and however much it is supported by local residents. GFOEN question
whether the technology neutral approach provides value for money
in terms of public consultation and in outcomes.
The stated requirement for the "technology
neutral" approach for PFI requires the use of modeling to
narrow down the selection to preferred technologies in the OBC
and an Evaluation Framework containing Key Criteria, sub criteria
and weightings, in conjunction with the use of selected modeling
tools with their inherent weightings. This is the process which
will select from the methods put forward by the waste industry
by which residual waste will be handled in Gloucestershire. The
whole process is largely shrouded in secrecy by the caveat of
commercial confidentiality and is going forward without the testing
by public inquiry of basic assumptions, such as the amount to
waste to be dealt with by 2020.
In Gloucestershire GFOEN has expressed growing
concerns with regard to the lack of transparency and full access
for all parties to the modelling used by officers to arrive at
conclusions that are subsequently recommended to councillors for
scrutiny and Cabinet decision on the residual waste project. For
example, despite an environmental information request from GFOEN
many of the appendices of the Gloucestershire OBC that contain
modelling are withheld citing commercial confidentiality. The
stakeholder consultation on the Evaluation Framework experienced
by GFOEN with no pre-briefing papers or detailed definitions of
terminology rendered the exercise flawed. Despite being the first
tier of local government, Parish and Town Councils, or their Association
were not invited to a stakeholder meeting.
Councillors of the Budget and Performance Scrutiny
Committee were informed that commercial confidentiality precluded
the officers from providing details of the consultation and the
sub criteria from which the Evaluation Framework was derived and
on which they were required to make a recommendation of its soundness.
The Report to the Overview and Scrutiny Management Committee Nov
2008 states:
"We would have liked to have received more
detailed information on the evaluation criteria but, in the main,
understood that maintaining and protecting the integrity of the
project meant that this was not possible,".
It is not appropriate to withhold any information
with regard to the OBC or the Evaluation Framework as these are,
in principle, documents that are frameworks which should be an
expression of the desires as to how the residents of Gloucestershire
wish to see their waste handled and how they wish to see selection
progressed. The modelling processes used to arrive at these documentary
conclusions must be transparent and open to scrutiny by councillors,
stakeholders and the public, otherwise how is anyone able to assess
the robustness of the modelling processes and procedure from which
the solution of dealing with residual waste in Gloucestershire
is derived.
The weightings given in an Evaluation Framework
are crucial as they have the ability to change the outcome in
the procurement process. "Data Deficiencies in Waste Management
Policy and Practice" (available on the DEFRA website) underlines
this point and adds that the modelling tool used can also have
a similar dominating effect because they directly affect the scoring
of the appraisal of options.
Limitations of assessment tools
There are various assessment tools available
for Local Authorities to use to compare different management systems
treating MSW. However it would appear that these software tools
do have their limitations in terms of the parameters in which
they function. For instance GFOEN understand from "Data Deficiencies
in Waste Management Policy and Practice" that WISARD is unable
to take account of reduced biodegradability, therefore when using
the software system for the comparison of differing residual waste
technologies there is a danger of overestimating the environmental
impact for landfilling stabilised material from an MBT whilst
potentially providing a overestimate of the benefit of incineration
through the replacement of coal for the generated energy.
The Waste Strategy for England 2007 and in the government's
practice guidance for municipal waste management strategies and
waste planning, suggest the use of the modelling tool WRATE, developed
by the Environment Agency, but it is not mandatory. Because WRATE
is concerned solely with waste management, it starts from the
point at which we throw things away, so it has nothing to say
about emissions associated with producing things originally or
about waste minimisation.
GFOEN believe that the various assessment tools
available are not able to pick up the full potential development
for small new businesses providing new jobs and employment which
could arise from a change in emphasis, from providing PFI funding
solely at the end of the process to maximising recycling at the
front end thereby lowering the carbon footprint and the use of
small residual waste facilities on several local sites with a
PFI support package.
Government has placed at the centre of its planning
reforms the principle of pre-planning application public consultation.
This principle needs to be adopted and made clear, transparent
and evident in every stage of the development of the waste PFI
process including each stage of procurement to enable full information
to be available for public consultation.
Long terms contracts
A key policy of the Government for PFI investment.
Where waste is concerned GFOEN would argue that this approach
is actually detrimental for Value for Money. Local government
cannot respond to changing circumstances once having signed a
long term contract which can become onerous as shown by the Kent
example. The Kent scenario long term contract inadvertently set
a ceiling on how much recycling could take place, in that having
agreed to supply the Allington Incinerator 320,000 tpa it now
cannot take full advantage of the growing recyclates market. Rightly
the councillor said how was it possible to foresee such changes
10 years ago. Other examples of unforeseen consequences of long
term contracts are Nottingham City Council is underwriting heat
produced by the incinerator. Due to energy efficiency improvements
the income from heat reduced with a shortfall of about £100,000
per month, which the City Council is now required to pay until
2016. By contract they are also responsible for maintenance work
and may have to pay up to £20 million to upgrade boilers
and grates to meet Environment Agency (EA) standards after the
EA issued an enforcement notice and formal warning because of
failings in the maintenance system. The contract also allows the
operator to demand that up to 100% of all municipal waste collected
by the City Council to be brought to the incinerator until 2032.
PFI funding restricted to residual waste
The emphasis on only offering PFI investment at the
back end of the waste market, ie residual waste, is to the detriment
of encouragement where investment should take place which is at
the front end of the waste market to reduce, reuse and recycle.
MSW is no longer poor value rubbish just to be black bagged and
incinerated, it is a valuable resource. If separated at kerbside
to retain quality, it has the potential to rival raw materials
on cost to industry. Local Authorities need assistance to maximise
separated kerbside collections to gain maximum value out of recyclables
and stimulate local small industries in the collection and reuse
of wet and dry recyclables. This could be achieved by expanding
the areas of PFI investment to include recycling. The present
restriction of PFI investment solely to residual waste infrastructure
encourages LA's to chase the lure of residual waste PFI capital
investment to the detriment of maximising recycling.
Size is an important issue in terms of flexibility
PFI investment appears to be more readily offered
to large scale single facilities because it is claimed that they
are more efficient through economies of scale. GFOEN believe that
this approach is short sighted, as it precludes the inherent value
of the flexibility of small scale developments with short term
contracts, the potential for stimulating small scale new businesses,
the lowering of the carbon footprint by dealing with waste where
it arises and more able to take advantage of new technologies
whereas the larger the project the greater the vested interest
in maintaining the life of that investment and thereby requiring
a long term contract.
The size of a facility relates to the amount of residual
waste. In many areas the justification for a large scale facility
is also based on figures "plumped up" by green waste,
by the inclusion of DIY builders waste and a general over estimation
of percentage increase over time to 2020.
This is exampled by the evidence presented in
the submission by Alan Watson, Consultant, on behalf of Gloucestershire
Friends of the Earth Network to the Gloucestershire Waste Core
Strategy Preferred Options. Yet the Gloucestershire PFI bid has
been accepted by DEFRA despite being in receipt of the evidence
presented in the submission by Alan Watson of the significant
discrepancy.
1. From 1.30 to 1.35 in text and tables
set out below the actual growth rate in the recent past is considered
and it can be seen that the waste growth from 2006 to 2007 was
actually at the 2020 target—assuming a 3%—or even
a 1.6% growth, simply does not reflect the real data and should
not be used to extrapolate future waste growth tonnages and costs.
Since 2004 the average annual growth has been just 0.8%.
| January | February
| March | April |
May | June | July
| August | September
| October | November
| December | Total
|
2002 | |
| | 24,977 | 25,405
| 23,158 | 25,701 | 25,493
| 23,521 | 24,843 | 22,178
| 20,158 | 215,435 |
| 2003 | 24,660 | 19,864
| 23,535 | 25,352 | 26,495
| 25,675 | 26,438 | 25,788
| 24,723 | 24,801 | 21,770
| 21,522 | 290,621 |
| 2004 | 24,435 | 21,096
| 23,884 | 28,595 | 27,729
| 28,075 | 27,342 | 26,935
| 27,954 | 24,865 | 24,952
| 21,677 | 307,539 |
| 2005 | 24,710 | 20,649
| 26,003 | 27,637 | 28,686
| 29,507 | 26,679 | 27,794
| 26,638 | 25,083 | 24,046
| 21,711 | 309,143 |
| 2006 | 25,508 | 20,807
| 23,225 | 27,761 | 29,854
| 30,183 | 26,867 | 28,446
| 27,721 | 27,323 | 25,568
| 21,228 | 314,491 |
| 2007 | 26,989 | 21,861
| 25,522 | 29,027 | 28,837
| 28,186 | 27,715 | 31,277
| 26,400 | 23,935 | 24,766
| 20,077 | 314,592 |
| |
| | |
| | | |
| | | |
|
|
| Year | Growth
|
|
| 2002 | |
| 2003 | 3.3% |
| 2004 | 5.8% |
| 2005 | 0.5% |
| 2006 | 1.7% |
| 2007 | 0.0% |
| 2008 | |
|
| |
2. On the financial year basis, from 1.36 to 1.38 inclusive,
including a detailed breakdown of total waste arisings in Gloucestershire
in the table below, the case is made that most of the increase
in total waste arisings is from green waste and DIY/ hardcore
waste.
(a) 1.12 "the green waste is practically all `new' waste
which would previously have been left in gardens or composted
at home. It should not be used as a basis to project overall growth
rates. When green waste is removed it can be seen that over the
period from 2002-03 reduces to just 0.87%—much closer to
the national average of c.0.5% indicated in Waste Strategy 2007."
(b) 1.13 "The increased emphasis on collection of DIY/hardcore
wastes at HRCs has also almost certainly generated mainly `new'.
Hardcore would have rarely have been put out with residual domestic
waste and, if produced and disposed of at all, would have been
collected in skips and would then most likely have been recycled
as part of the C & D stream. If hardcore waste growth is removed
from the equation then it can be seen that the average growth
rate since 2002 is only 0.09%.
| 2002-03
| 2003-04 | 2004-05
| 2005-06 | 2006-07
| Average |
| WCA Municipal Waste | 211,989
| 206,296 | 207,870 | 189,519
| 180.458 | |
Annual growth
| | -2.64%
| 0.71% | -8.83% | -4.78%
| -3.88% |
| Recyclables (via Districts) |
| | | |
| |
| Green | 2,401 | 6,426
| 9,921 | 20,407 | 28,951
| |
| Dry Recyclables | 26,972 |
32,354 | 36,162 | 39,873
| 42,543 | |
| Total Recyclables | 29,373 |
38,780 | 46,083 | 60,280
| 71,494 | |
Annual growth
| | 32.03%
| 18.83% | 30.81% | 18.60%
| 25.07% |
| Household Recycling Centres |
| | | |
| |
| Recyclables | 5,698 | 7,739
| 10,967 | 13,062 | 12,601
| |
| Green Waste | 9,995 | 11,030
| 12,853 | 11,869 | 12,652
| |
| Residual Waste | 23,813 | 22,119
| 20,543 | 18,936 | 29,690
| |
| DIY/Hardcore | 2,359 | 5,480
| 10,586 | 12,870 | 11,232
| |
| Total | 41,865 | 46,368
| 54,949 | 56,737 | 66,175
| |
| 3rd Party Recyclables | 267 |
434 | 585 | 785 |
1,196 | |
| | |
| | | |
| Total Arisings | 283,493 |
291,978 | 309,486 | 307,322
| 319,323 | |
Annual growth
| | 2.99%
| 6.00% | -0.70% | 3.91%
| 3.05% |
| Subtract Greenwaste | 281,093
| 285,552 | 299,565 | 286.914
| 290,372 | |
Annual growth
| | 1.59%
| 4.91% | -4.22% | 1.21%
| 0.87% |
| Subtract Hardcore | 278,733 |
280,072 | 288,979 | 274,044
| 279,140 | |
Annual growth
| | 0.48%
| 3.18% | -5.17% | 1.86%
| 0.09% |
| |
| | | |
|
Gloucestershire Joint Municipal Waste Management Strategy (JMWMS)
Objective 5: "Residual Waste as a Resource" states:
Subtext: "After we have reduced, reused, recycled and
composted as much as we can there will still be some waste left
over. This is referred to as residual waste."
This implies that residual waste is waste that cannot be
"reduced, reused, recycled and composted. Green waste is
easily recyclable, DIY/hardcore waste can be recycled, yet the
tonnages per annum of these new collections, which can be recycled,
are being used to justify a large residual waste facility of 130-200,000tpa
which would lock up potential recyclable material into a 25 year
contract. The building of overly large facilities to burn waste
that could be recycled does not offer value for money as pointed
up in the Audit Commission Report on Waste.
CLIMATE CHANGE
In the Eunomia Report "Greenhouse Gas Balances of Waste
Management Scenarios" written for the Greater London Authority
it states: "The most critical new driver for London's waste
management is climate change."
and
"Perhaps surprisingly, when compared to many LCA studies,
MBT(`biostabilisation') process performs better than many of the
configurations generating energy due to both the lack of any release
of GHGs associated with fossil carbon from energy generation and
reduced emissions of methane in landfill.
Whether preceded or not by MBT (`biodrying'), scenarios incorporating
traditional incineration technologies perform poorly. This is
the result of significant emissions from wholesale combustion
of plastics at relatively low efficiencies, which negates the
benefits derived from avoided emissions associated with energy
generation."
MBT and AD are proven technologies and in the light of this
report GFOEN recommends small MBT and AD plants for Gloucestershire.
TABLE A PERFORMANCE OF CORE TECHNOLOGY TYPES UNDER CENTRAL
ASSUMPTIONS
Gloucestershire Friends of the Earth Network
November 2008
|
