1. science
2. ecology
3. waste management
4. recycling

CABINET - 8 JANUARY 2009
PUBLIC FORUM BUSINESS
A.
PUBLIC FORUM REPRESENTATIONS RELATING TO AGENDA ITEMS:
Item 3 - West of England - phase 3 outline business case to support
DEFRA PFI funding
A(3)1
Cllr Spud Murphy
A(3)2
Adam Shore (to be presented by David Sweeting)
A(3)3
Paul Harrod
A(3)4
Marcia Pepperall
A(3)5
Roger Symonds
A(3)6
Alan Watson
A(3)7
Cllr Steve Comer
A(3)8
Cllr Dennis Brown
A(3)9
Jane Stevenson
A(3)10
Dr A Tubb
A(3)11
Charlotte Leslie
A(3)12
Peter Goodwin
A(3)13
Mike Roberts
A(3)14
Cllr Gary Hopkins
A(3)15
Cllr Jon Rogers
B.
QUESTIONS FROM RESIDENTS & COUNCILLORS
None received.
C.
PUBLIC FORUM REPRESENTATIONS NOT RELATING TO AGENDA ITEMS
Please note: these items will be taken at the end of the meeting, after the main
business, as detailed on the agenda, has been transacted.
C1
Rowena Hayward - subject: caretaking review
C2
Jeff Sutton - subject: caretaking review
1
STATEMENT A (3) 1
Public Forum Statement from Councillor Spud Murphy to the Cabinet convened for
Thursday, 8th January 2009
WEST OF ENGLAND - PHASE 3 OUTLINE BUSINESS CASE TO SUPPORT DEFRA PFI
FUNDING
I cautiously welcome the Call-In Panel's recommendations which Cabinet is asked to
consider today.
However, I think it is important to place on record my continuing concern as Ward
Councillor for the area most affected by any decision taken in this matter, that the Authority
still seems wedded to or closely associated with the idea of mass burn incineration as a
solution to the region's waste problem.
It is essential that the interests of local residents are properly represented and protected
on this issue and not just ignored, outweighed or dismissed as being of little consequence.
As I understand it, to secure DEFRA funding for a future waste treatment facility requires a
proven technology for handling significant volumes of material to form the basis of the
West of England Outline Business Case. I appreciate that some flexibility remains within
the submission to allow competing technologies to incineration to be evaluated or
considered.
I hope Cabinet recognises the huge benefits of considering alternative methods of
handling residual waste and will commit itself to renew citywide efforts to boost recycling
rates and promote the reduction and re-use of finite resources and materials
Nevertheless, residents fear Avonmouth, Shirehampton and Lawrence Weston will still end
up being used as a dumping-ground for a waste facility no-one else would tolerate in their
midst. Some Members may recall that this part of Bristol used to have an incinerator which took years of campaigning to shut down and, I can assure you, we are in no hurry to
find a replacement.
Aside from the pollutants emanating from a new plant, I remain extremely concerned over
the impact that an increase in commercial traffic to and from such a waste treatment
facility will have on the quality of life of local people.
I remain hopeful that more environmentally-friendly solutions will be found to make
incineration redundant.
If a viable alternative is not found in the tight time scale imposed by DEFRA, Cabinet can
be assured that I will continue to oppose any attempt to foist any so-called energy from
waste (EfW) technology on my Ward, which to the people I represent is still an incinerator
by another name.
Cllr SPUD MURPHY
Conservative Councillor
Avonmouth Ward
Cllr S Murphy
C/o The Council House
Reply to
Telephone
Minicom
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Our Ref
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Date
Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT A (3) 2
To be read by David Sweeting, Ethos Energy on behalf of Adam Shore, Ethos Energy.
Dear Sirs,
On 9th September 2008 I made a public statement in writing and person at the Full
Council meeting. This statement detailed difficulties Ethos had been experiencing in being
granted a lease by the Council of land at Avonmouth, on which Ethos wishes to construct
a municipal waste to energy plant. I noted with interest Cllr Bradshaw's response that "We
have been thoroughly supportive of this project. There is no suggestion of a lack of cooperation." Subsequent events have shown this statement to be false.
Four months later, we are no further forward with discussions with the Council. The only
engagement from the Council has been via Stephen McNamara, who simply states that
the Council wishes to clarify the legal relationships concerned and the status of the
relevant contracts. We have provided all of the information requested back in September
and again via our lawyers in November. All of this information and documentation has
always been fully available to the Council as it is public information and/or they are
contracts which the Council is a party to. The analysis could have been undertaken at any
stage during 2008 when detailed discussions continued between Ethos and the Council.
Save for the lease of land at Avonmouth, our project is still completely ready to
commence. The last remaining pre-commencement planning condition has been
discharged and our bank, Nord LB, continues to offer full support even in the present
market. As always, no public funds are required by Ethos and the proposed lease terms
are at arms-length. All we require from the Council is 34,000 tonnes of waste, which has
been provided for in the Council's waste supply agreement with Cory/WRG. Such supply is
not for commercial purposes - we need it to commission and test the plant. Each tonne
would be subsidised by the operating company, and we would report the results in full to
Bristol and DEFRA. It is a genuine Research and Development contract (and therefore
exempt from procurement regulations), as it has always been.
Since Ethos Group acquired Compact Power in January 2008, the fortunes of its main
operating company have continued to prosper. It has just been awarded a major London
tunnelling spoil contract for EDF, which will take the 2009 projected turnover to £34M. In
addition an alliance has been formed with an experienced and highly reputatable
international engineering contractor (TBA) which will act as principle engineering and
installation contractor on all Ethos large scale waste to energy plants, including any at
Avonmouth. This will remove any remaining doubt Bristol or other prospective customers
may have about Ethos' financial position or its ability to deliver projects.
We remain completely willing to enter into discussions with the Council to conclude the
lease and get on with building the plant. However, it is clear that the Council does not wish
to engage in any such discussion. As a direct result of being unable to clarify a start and
end date, we have been forced to withdraw from the DEFRA New Technologies
Demonstration Programme. The lost revenue will be greater than £3M directly and the lost
opportunity of having our successful plant effectively endorsed by DEFRA will be
considerable. At this stage Ethos has £3M of costs and time in the project, which may now
be wasted.
The PTQ criteria for the West of England Waste Partnership and the timing of the
associated process has served to effectively exclude us, and, in my view, similar advanced
technologies. If we had been permitted to commence the Avonmouth project when we
were ready to do so, and given the financial and engineering improvements mentioned
above, Ethos would be much better placed to successfully tender.
We have instructed solicitors to advise us of potential causes of action and remedies
against the Council. They have initially advised that we have a claim in public law against
the Council which was communicated formally to the Council prior to Christmas. Papers
are now before Queens Counsel prior to further action being pursued. It is a regrettable
that this course of action must be taken.
In the meanwhile, Ethos continues to receive enquiries about the supply of it's waste to
energy technology from private and public bodies throughout the UK. Several such
discussions are advanced. One is for a 160,000tpa MSW facility. The price of supply will
be below £40M.
Yours truly,
Adam Shore
Managing Director - Ethos Energy
Adam Shore
By e.mail a.shore@ethosenergy.co.uk
Reply to
Telephone
Minicom
Fax
Email
Our Ref
Your Ref
Date
Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT A (3) 3
I have made previous statements to the Council detailing my opposition to
proposals for a mass-burn incinerator which would almost certainly be
situated in Avonmouth, part of Bristol North West.
Not only would this be an expensive, wasteful and environmentally damaging
solution, but there is increasing evidence that it is not wanted by the
people of this City.
Bristol aspires to be Europe's "Green Capital" and a mass-burn incinerator
would make a mockery of that aspiration and more than offset the efforts
dozens of community environmental groups across Bristol make to reduce their
carbon footprints.
It would send out the wrong message to residents about the importance of
recycling, thereby undermining the great efforts Bristol has made in the
recent past to boost recycling levels. A mass-burn incinerator, situated at
Avonmouth, would also lead to a rise in lorry traffic bringing in waste from
across the region to burn. Surely the Cabinet does not wish to subject the
people of north Bristol to more congestion to add to already high traffic
volumes. Nor must the Cabinet wish to see high calorific waste transported
by road to be incinerated at great cost and with little useful energy
harnessed.
I also share the concerns of my Lib Dem colleagues about the way smaller
scale businesses and more innovative environmental technologies are being
excluded from this process. Bristol Friends of the Earth have highlighted
how other cities in the UK who have submitted bids to DEFRA highlighted the
role a range of technology types could play in residual waste disposal. It
is regrettable that the Cabinet appears so wedded to an outdated and
expensive mass-burn incineration when better solutions exist that are
already funded through other means.
The fact that the Cabinet is considering a PFI funded solution during a
credit crunch brings heightened risk, uncertainty and expense to the
process. We accept that, even after greater efforts to reduce waste and
increase recycling, residual waste disposal is essential. Therefore the
Cabinet's approach seems to be very high risk as well as one of
environmental vandalism.
Paul Harrod
Paul Harrod
By E.mail paul.harrod@googlemail.com
Reply to
Telephone
Minicom
Fax
Email
Our Ref
Your Ref
Date
Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT A (3) 4
South Gloucestershire, North Somerset and perhaps – after this meeting, Bristol as well,
will give the go ahead to The W of E Partnership to apply for a grant and pfi.
Unfortunately The W of E Partnership seem fixed in their idea of of one big incinerator,
even though public consultation left us in no doubt that voters would prefer several small
units.
Obviously incinceration – or gasification – is the answer for waste disposal,
and we are very fortunate because we have a local company, with proven expertise to
build and commission units for us. The cost - at about £20m per 40,000 tonne unit,
would only come to about £80m
What completely mystifies me, and several other Councillors, and members of the public,
is why W of E want to go off to Europe and spend nearly a £billion – a thousand million
pounds – of public money – on one massive, experimental, imported incinerator – talk
about putting all our eggs in one basket! If we take this route, how can we justify it to our
electors?
But surely - at this recessionary time – we want to encourage British industry.
So here is our chance to prove it.
The local Company is Ethos – and I understand that amongst their customers are the
Ministry of Defence, Local Authorities and the NHS.
Lets add our name to that list – and save a great deal of money.
Marcia Pepperall cllr
Marcia Pepperall
By e.mail marciapep@aol.com
Reply to
Telephone
Minicom
Fax
Email
Our Ref
Your Ref
Date
Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATENEBT A(3) 5
Statement from B&NES Liberal Democrat Group on
Mass Burn Incineration
Bath and North East Somerset Council has withdrawn from part 3 of the West of
England Partnership’s Waste Srategy because this involves procurement of a
mass burn incineration unit.
B&NES’ Zero Waste policy means that this type of mass burn cannot be
acceptable in terms of environmental sustainability. Our aim is to eliminate
waste, which will make the need for landfill and incineration unnecessary.
Already B&NES residual waste has decreased from 63,000 tonnes to 48,000
tonnes since 2000.
Clearly Zero Waste will not be achieved overnight, but there is now a great
opportunity with the switch from landfill to make real progress. To change from
landfill to another environmentally unsustainable option, mass burn, is to
squander that opportunity. It makes no sense to destroy products, which have to
be instantly recreated
Mass Burn will discourage recycling, destroy recyclable material which would
otherwise be used to produce goods at much lower energy costs than from virgin
materials. It has been proved, despite assurances that there are health risks
connected with mass burn (in Byker ash dumped from incineration on allotments
led to allotment holders being banned from eating the produce of their
allotments). Zero Waste will encourage designers to design out waste from their
products, and encourage Reduction, Reuse, Repair and Recycling.
The Western Partnership seems to be ‘dumbing down’ to the lowest recycling
targets of the four CUBA unitaries, with their unambitious recycling targets of
below 50%.
In Bath and North East Somerset 77% of residents take part in our successful
kerbside recycling collections. To take part in any strategy which included mass
burn incineration would be to betray our residents, who are asking for more
recycling with no upper limit. In fact Zero Waste means a target of 100%
recycling.
I urge Bristol City Councillors to drop this ‘hair brained scheme’, and for the West
of England Partnership to show vision and leadership by declaring their longer
term objective to be Zero Waste.
Cllr Roger Symonds – B&NES Lib Dems
Roger Symonds
By e.mail mail@rogersymonds.org.uk
Reply to
Telephone
Minicom
Fax
Email
Our Ref
Your Ref
Date
Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT A (3) 6
West of England Waste Management Partnership
Brief Comments on the Outline Business Case
For the Bristol City Council Cabinet Meeting
8th January 2009 By Alan Watson C.Eng, Public Interest Consultants, Swansea It is clear that the current Outline Business Case and supporting papers leave the authorities vulnerable to higher costs; compromised recycling rates and poor environmental performance in relation to the proposed grate incinerator based waste management strategy. Key concerns include: Excessive Waste growth Assumptions: The whole OBC is predicated to a scenario where waste is growing rapidly and consistently over the next thirty years. This can be seen in figure 2.1of the OBC: Yet in the Joint Position Statement at Appendix 3‐2 it can clearly be seen that the waste arisings have been falling rapidly (in this case for North Somerset). There is only an increase from 2006‐7, which is small compared with the fall over the previous years in any case, because the authority started collecting green waste. This is largely ‘new’ waste that would previously generally have been composted or left on the garden and which has long been established is a way of increasing total waste arisings. Although presented less clearly (perhaps deliberately?) the North Somerset fall can be seen on the figure 8 of Appendix 4‐1 combined with projections. It will be noted that the BCC arisings have fallen even more steeply. Whilst there has been a slight rise in the SG arisings this has also fallen recently. Overall the combined trend since 2002 is strongly downwards but the OBC never presents this data in a clear way: Great emphasis is instead placed on the projected future waste growth for which there is no logical explanation. This cannot be linked purely to household numbers growing as these have increased substantially over the period since 2002. The consequences would be that the ‘headroom’ required to allow higher recycling would not materialise and waste would be tied to the incinerator with an inflexible ‘put or pay’ contract. Likely Revision of the Landfill Directive Targets The Government is recognising that the biodegradable element of waste, currently set at 68% in England, is probably actually lower than this. The assumption of the BMW element for waste in Ireland has just been reduced from 71% to 64%. (ENDS 2008). The level in Scotland is set at 63% (Scottish Executive 2007) and Wales currently uses 61% (Environment Agency Wales 2008) so it is likely that England has a level which is too high. It is therefore likely that the BMW targets for the Landfill Directive will become about 10% easier to meet in the near future. The OBC is silent on these changes. Inadequate Climate Change Assessments The highest weighting in the OBC is given to climate change impacts yet the option proposed has been demonstrated to be one of the very worst for climate change. Figures 4.5 and 4.6 of the OBC show that CHP is essential to making a significant climate change impact but the background documents show that the site is unsuitable site for CHP as there is an inadequate year round heat load. It is made clear from discussions with contractors that they have very strong reservations about securing a CHP facility or heat contracts for the site. A recent assessment by RPS for a current incinerator application by Veolia at Rufford, Nottinghamshire is attached as Appendix A and shows then when using a more sophisticated model than WRATE energy from waste performs very badly. The more negative the result the greater the saving – it can be seen that high levels of Mechanical Biological Treatment (MBT) with landfill of residual s nearly quadruples the climate savings compared with incineration and is cheaper, faster to build and much more flexible. This approach would also be more compatible with very high recycling. This is important now that the targets being set in Scotland and Wales are upto 70% recycling. It is important to note that the consultants for the Welsh Assembly showed that these levels of recycling would actually be cheaper than lower levels. Inadequate Assessment of the market and financial Risks Associated with bottom ash: A report on “Markets for EfW Process Outputs” supporting the OBC is included at Appendix 5‐4. This report is completely silent on the increasing body of evidence that some, perhaps most, bottom ash is, like the fly/ APCD ash, a hazardous waste – and they could easily end up generating 22% hazardous bottom ash plus 3% hazardous fly ash from an incinerator. This would have a profound impact on the economics of a grate incinerator – and the authorities would probably have to meet the extremely high additional costs of hazardous waste landfill or treatment. Conclusions: This is a brief review of a few key points but it has become very obvious that there are some major deficiencies, errors and omissions in the data provided by the Authorities to DEFRA. I would strongly recommend that the Cabinet should seek an independent peer review of the OBC before the application proceeds further. Alan Watson C.Eng 7th January 2009 References: ENDS (2008). ʺBiodegradable content of waste to be reassessed.ʺ Environmental Data Services (ENDS) Report(407): 48‐49. Environment Agency Wales (2008). ʺReport on the Landfill Allowances Scheme (LAS) Wales 2007/8 September 2008 ref: GEWA0908BOMQEE.ʺ Scottish Executive (2007). Landfill Allowance Scheme (Scotland) Regulations 2005 Scottish Executive Guidance: March 2007. Edinburgh. Appendix A: Climate Change impacts of the Scenarios modelled by RPS: The electricity only incineration option is highlighted in red ENDS Report 407, December 2008, pp 48-49
© 2008 Haymarket Business Media
Biodegradable content of waste to be reassessed
The assumed biodegradable content of municipal waste could be lowered from its current 68%
depending on work commissioned by the Environment Department (DEFRA). Northern Ireland will
lower its assumed rate in April.
The Environment Department (DEFRA) is reviewing default assumptions on the biodegradable
content of municipal waste - a move that could make it easier for English and Welsh councils to meet
EU landfill targets.
Under the landfill allowance trading scheme (LATS), councils have annual caps on the amount of
biodegradable municipal waste (BMW) they can landfill. These have been set to ensure the UK
meets targets under the EU landfill Directive.
LATS assumes municipal waste is 68% biodegradable. However, many councils have questioned
the level due to changes in consumption and the proliferation of home composting.
In November, it was revealed that the government’s own "nuts and bolts" review of LATS (ENDS
Report 389, p 43 ) had called for the 68% figure to be reassessed.1 The review was completed in
January, but DEFRA did not publish it until November. The 68% level is based on 2000/01 data, it
says. "Continuing to assume 68%... could be slowing down England’s progress towards achieving
landfill Directive targets."
England appears set to meet its target for 2010 (ENDS Report 406, pp 21-22 ), but could struggle
to meet 2013 targets if infrastructure is delayed (ENDS Report 405, p 16 ).
Northern Ireland’s Environment Department has already moved to change its assumed level due to
changes in consumption and improvements in waste management. In December it finished
consulting on a proposal to lower the assumed biodegradable content of municipal waste under its
landfill allowance scheme from 71% to 64%. This followed compositional analyses undertaken by
RPS Consulting Engineers.
DEFRA issued its response to the LATS review in November.2 The Department has commissioned
a study to review evidence on the current BMW level, the response says. This is due to report in
December and will either recommend further work is needed or call for a change.
If there is a need for change, DEFRA and the Environment Agency will work together to either
revise the national level or produce guidance for local authorities to commission their own
compositional analyses so that levels can be set locally. However, this is unlikely to be done before
2010.
The Agency has said the composition analyses so far undertaken by councils like Essex have not
been sufficiently robust.
Most of the other recommendations from the LATS review are concerned with improving guidance
around the scheme or the ease and timeliness of reporting. However, it does call for DEFRA to
develop a mechanism to allow home composting to count towards councils’ LATS targets.
Earlier this year DEFRA rejected a model developed by Waste and Resources Action Programme
(WRAP), which said home composting diverts 220kg of BMW from landfill per year (ENDS
Report 397, pp 17-18 ). The Agency and WRAP are now working on a new model. A decision
will not be made before 2010, DEFRA’s response says.
The Environment Agency has written to all English local authorities asking them to provide
justification of the reject rates they report from materials recycling facilities (MRFs). Some 29
councils said no materials were rejected from MRFs in the first quarter of 2008/09, with a further 81
stating less than 1% were. The Agency says a typical rate is 10.8%
.
Further information
1. LATS operational review
(http://www.defra.gov.uk/environment/waste/localauth/lats/pdf/lets-report081110.pdf)
2. Government response
(http://www.defra.gov.uk/environment/waste/localauth/lats/pdf/lets-actionplan081110.pdf)
ENDS Report 407, December 2008, pp 48-49
© 2008 Haymarket Business Media
FUTURE DIRECTIONS FOR MUNICIPAL WASTE MANAGEMENT IN
WALES - A PAPER FOR DISCUSSION
Contents
Page
Purpose
2
Background
•
•
•
Welsh Assembly Government
Local Government
Role of this paper and next steps
2
3
4
Options for targets
•
•
•
•
Outcome sought through the setting of targets
Rationale for options for targets
Options for targets
Type of recycling system modelled and
constraints/assumptions
4
4
5
5
Appraisal results
•
•
•
Environmental impact - Global Warming Potential (GWP).
Meeting EU Landfill Directive targets.
Financial appraisal.
6
7
8
The practicalities of implementing and delivering the targets
•
•
•
Service delivery steps that need to be taken to reach
high recycling rates
Assessment of potential barriers to high recycling and
methods of addressing them
Other issues
Proposed supporting actions
10
12
19
24
Conclusion and proposals
Conclusions
26
Proposals
27
ANNEX 1 Options for targets
ANNEX 2 Recyclable materials in municipal waste
29
31
1
FUTURE DIRECTIONS FOR MUNICIPAL WASTE MANAGEMENT IN
WALES
PURPOSE
The purpose of this document is to make an appraisal of options for sustainable municipal
waste management beyond 2009/10. It seeks to identify:
•
•
preferred options for municipal waste management targets to 2025 and
actions needed to achieve the targets.
BACKGROUND
The need to clarify targets post 2009/10
The drivers for the Welsh Assembly Government
‘Wise About Waste, The National Waste Strategy for Wales’, set the following twin
overarching objectives: i) to make Wales a model for sustainable waste management
including maximising the use of unavoidable waste as a resource and minimising, where
practicable, the use of energy from waste and landfill; and ii) to comply with the
requirements of relevant EU waste Directives.
The Strategy included a key policy that “recycling is the preferred way to manage
unavoidable waste”. It also stated that “the Assembly Government considers that there
must be a significant increase in municipal waste recycling and composting in order to:
…..achieve the Landfill Directive targets without a major reliance on energy from waste”.
The challenging Landfill Directive targets to substantially reduce the landfilling of
biodegradable municipal waste can be partially, or possibly wholly, met through the source
separation and collection of biodegradable material (e.g. paper, card, garden waste, and
food waste) and subsequent recycling, composting or anaerobic digestion. They could also
be met through less sustainable methods involving the treatment of municipal waste,
including the use of energy from waste, although this is not the preferred approach in the
Strategy, for environmental and economic reasons
Wise About Waste identified recycling targets for municipal waste to 2009/10. The 40%
recycling/composting and 15% composting targets were identified as minimum targets for
local authorities to meet and exceed by 2009/10. It was calculated that authorities
achieving the 40% recycling target would also meet the 2009/10 Landfill Directive target.
The Strategy identified the Assembly Government’s wish to see recycling and composting
rates increase significantly above 40% after 2010 where this is practicable; a decision on
increasing the recycling and composting targets after 2010 would be made when the
strategy is reviewed by 2007.
Pressure to increase recycling rates has come from the public, political parties, green
groups and others who feel that Wales can do more to match best practice in Europe and
other parts of the world. The Flanders region of Belgium leads the way with a 70%
2
recycling rate for its municipal waste1 . There is also a commitment by the Minister for
Environment, Sustainability and Housing that all policies within her portfolio should
maximise their contribution towards reducing the impact on climate change. Modelling
studies of the carbon emissions of different types of waste management indicate that most
types of recycling have significant climate change benefits over energy from waste and
landfill, and that the anaerobic digestion of source separated food wastes is more
beneficial than composting, incineration or landfill.
Increased recycling and composting can make a significant contribution towards helping
Wales as a whole meet the 2009/10, 2012/13 and 2019/20 Landfill Directive targets. This
is particularly pertinent for the 2012/13 target, where it is now virtually too late for local
authorities to rely on residual waste treatment to meet the Directive’s targets. This is
because of the time taken for procurement, planning, building and commissioning of
residual waste treatment plants. The services and infrastructure needed for recycling and
composting (or AD) are much cheaper and more easy to set up than infrastructure needed
to treat residual municipal waste. It is now the case that most Welsh authorities will only
be able to meet the 2012/13 target through extra effort on recycling, composting and/or
anaerobically digesting biodegradable materials collected separately from households.
Most local authorities in Wales are in the process of procuring, or contemplating procuring,
contracts for the management of their municipal waste. Many of these contracts are likely
to be of a 25 year duration. Given the contract tender process can take anything up to 4-5
years (or more) to complete, this means that our local authorities are looking to plan ahead
to 2037 (or later) when they are fixing their contracts. The contracts will need a degree of
flexibility to respond to changes but any unforeseen changes in targets set for local
authorities over this period would impact on the contract signed with the contractor. It is
important therefore, in respect of long term targets, that as much certainty as possible is
provided to both local authorities and the market place.
When setting long term targets it is difficult to predict exactly what the world will be like in
20-30 years time, particularly in respect to the composition of household waste. Signs are
emerging already that household waste composition will change significantly in the next 510 years, with all the major supermarkets increasingly committed to changing packaging
quantities and types. They are also taking into account more the carbon footprints of their
products. Consumer and Government pressure are driving this change.
Given current procurement activity and the need for local authorities to progress
procurement quickly in order to meet 2012/13 and 2019/20 Landfill Directive targets it is
recognised that the Assembly Government needs to signal as soon as possible its
intentions on recycling targets after 2009/10.
Local Government needs
The WLGA have identified that what local government requires is:
• “a clear direction of travel (i.e. clarity on targets and time-scales to include whether the
targets are for Wales, for individual LAs, or differentiated spatially [urban/valley/rural
etc.], how they will be monitored/measured/apportioned, scope for sharing etc). This
1
The 70% recycling figure in Flanders does not include the recycling of C&D waste, nor the recycling of
incinerator bottom ash.
3
•
•
needs to be backed with a reasoned justification as to why the targets have been
chosen;
a ‘route map’ that identifies steps that need to be taken to achieve the targets and by
whom (i.e. the whole issue of shared responsibility – WAG must not set ambitious
targets and then walk away). If we are serious about higher recycling/composting
targets then WAG will need to look at whether it has the tools to assist (e.g. producer
responsibility, introduction of variable charging etc.)
clarity on funding and steps to address the affordability gap – again it is not sufficient
for WAG to set ambitious targets and then fail to assist with the necessary resources to
deliver.”
Role of this paper and next steps
A commitment has been given to scope out options for targets and identify a preferred
option by October 2007. This paper proposes preferred options for discussion with Local
Government. It includes an environmental and financial appraisal of different options2 and
identifies steps likely to be needed to deliver the proposed preferred options.
The preferred options and proposed actions will then need to be put out for public
consultation as part of the planned review of Wise About Waste to meet the requirements
of the EU Public Participation and Strategic Environmental Assessment Directives.
OPTIONS FOR TARGETS
Outcome sought through the setting of targets
The main outcomes sought through the setting of targets for municipal waste are:
•
•
•
•
the reduction of the impact of waste on climate change through reducing greenhouse
gas emissions associated with the production and management of municipal wastes;
the more efficient management of secondary materials resources derived from
municipal waste in order to contribute to the reduction of Wales’ ecological footprint;
the effective use of public funds and delivery of value for money;
compliance with the EU Landfill Directive targets to limit the amount of landfill of
biodegradable municipal waste.
Rationale for options for targets
Evidence suggests that the greatest climate change and ecological footprint benefits can
be obtained through increasing the closed loop recycling of dry recyclables and the
composting and/or anaerobic digestion of garden and food wastes. Reducing the amount
of residual (i.e. unrecycled / uncomposted) waste that has to be landfilled or subjected to
further treatment, particularly in respect of the biodegradable faction, has very significant
climate change benefits.
There is the potential for targets set for recycling and composting to have the adverse
effect of increasing the amount of waste collected, particularly in respect of garden waste
2
References: Scoping New Municipal Waste Targets for Wales, Eunomia Consulting, 2007; Lifecycle
Assessment of Municipal Waste Targets, Environment Agency Wales, 2007.
4
that would otherwise have been managed by the householder in their garden. Therefore,
included in the appraisal has been a consideration of the benefits of converting recycling/
composting targets into corresponding “residual household waste” targets expressed as kg
per person per annum. This would have the potential benefit of encouraging local
authorities not to collect waste materials (e.g. green waste) just to meet recycling/
composting targets, and would focus attention on reducing the amount of waste that is not
put to beneficial use.
The policy focus is to prioritise sustainable resource efficiency and waste management
through recycling and composting as well as meeting EU Landfill Directive targets.
Options for targets
A series of different target options were identified and modelled (see Annex 1 for details).
Options for minimum recycling targets for 2024/25 ranged from 40% to 80%, with stepped
increases from the current rate of 40% in 2009/10. Included were complementary targets
for the separate collection and treatment of food waste (with a maximum rate ranging from
10 to 15% in 2024/25, rising in a stepped fashion from 2009/10). Complementary options
for a maximum level of energy from waste for the whole period from 2009/10 to 2024/25
ranged from 20% to 60%. Options for setting a maximum target for residual household
waste per person for 2024/25 ranged from 100 to 300 kg per person per annum.
Type of recycling system modelled and constraints/assumptions
Modelling was based on existing systems and levels of performance currently being
delivered in the three types of authority – rural, urban and valleys. Modelling did not look
into optimised systems that might yield greater value for money.
One of the main issues associated with modelling high recycling targets is the identification
of the components of the municipal waste stream that can actually be recycled, and how
these materials can then be collected and recycled to meet high rates.
The results of a municipal waste compositional study carried out in Wales in 2002/03
showed that 64% of waste was readily recyclable or compostable. During the recent
modelling exercise (referred to above) and based on detailed scrutiny of the data, it was
estimated that up to 93.3% of Welsh municipal waste could either be recycled or
composted/ anaerobically digested (see Annex 2 for details).
Although there is unlikely to be one specific collection system that is capable of delivering
high recycling rates by 2024/25, the chances of this are enhanced if the extent of comingling of dry recyclables and co-mingling of different biowastes is limited. Increasing the
extent of co-mingling tends to lead to an increase in the level of material being rejected at
the reprocessing facility, and/or additional costs (eg when green and food wastes are cotreated). Given the high capture rates required to meet higher recycling rates, it has been
assumed that collection systems should be based on source-segregation of materials.
The Environment Agency’s life cycle assessment (LCA) tool WRATE was used to analyse
and compare the greenhouse gas (as CO2 equivalents) and resource utilisation aspects of
each of the different recycling targets options (using a 1% per annum growth rate). The
analysis was done for the different target options for the year 2024/25.
5
In the WRATE modelling, recycling is delivered via source separated collection and bring
bank systems, with all of the residual sent to incineration with high energy recovery
(bottom ash is recycled but does not count in this model towards the recycling figures it
does not count under the current NAWPI definition of recycling). The landfill component is
minimal, and is used only for rejects from recycling and composting.
The options were modelled on an all Wales basis and for rural, valleys and urban
authorities.
APPRAISAL RESULTS
Environmental impact - Global Warming Potential (GWP)
In all options there is a net benefit in terms of a reduction in greenhouse gas emissions. As
the recycling rate increases, the benefit increases. At 80%, WRATE forecasts that
municipal waste management will result in a displacement of emissions of greenhouse
gases equivalent to just over half a million tonnes of CO2 per annum.
Figure 1 – Global warming potential for each recycling target option for 2024/25 (a negative figure
means greenhouse gas emissions are displaced).
300,000,000
200,000,000
100,000,000
0
80%
70%
60%
50%
-100,000,000
40%
Collection
kg CO2 eq.
Transportation
-200,000,000
Intermediate Facilities
Recycling
Treatment and Recovery
-300,000,000
Landfill
Total
-400,000,000
-500,000,000
-600,000,000
-700,000,000
-800,000,000
Recycling rate
6
Meeting EU Landfill Directive targets
The EU Landfill Directive targets limiting the amount of biodegradable municipal waste
landfilled translate through Welsh legislation (The Landfill Allowances Scheme (Wales)
Regulations 2004) into the following targets (termed “allowances”) for Welsh local
authorities. Within this each Local Authority has its own specific allowance. The targets for
Wale are:
by 2009/10 no more than 710,000 tonnes of BMW can be landfilled
by 2012/13 no more than 470,000 tonnes of BMW can be landfilled
by 2019/20 no more than 330,000 tonnes of BMW can be landfilled.
•
•
•
The graph below (Figure 2) plots whether Wales is in credit each year in respect of
whether the different recycling levels in the different options allow the Landfill Directive
targets to be met. A positive figure means that less BMW is landfilled than the target
requires and hence there is a surplus of allowances. The graph clearly shows how the
balance of allowances improves as the recycling rates increase. However, for all bar one
of the options, there is a deficit in the years 2011/12 to 2015/16 (and in most cases, the
period beyond). Only the option “70% LAS compliant” stays in credit each year. This
suggests that, if the intention is to stay in the black for as long as possible, then whatever
the ultimate target, the targets in earlier years should be higher. The fact that the rate of
reduction in the quota of allowances is fastest between 2009/10 and 2012/13 suggests
that the rate of increase in recycling targets would need to be faster between these years
to overcome this reduction in quota. A profile of 40% (2009/10) to 52% in 2012/13 to 58%
in 2015/16 and 64% in 2019/20 would be more appropriate – as per the option “70% LAS
compliant”.
Figure 2: Balance of Landfill Allowances, All Recycling Scenarios (positive means targets exceeded,
negative means a shortfall with targets not being met)
200,000
100,000
0
06/07.
07/08.
08/09.
09/10.
10/11.
11/12.
12/13.
13/14.
14/15.
15/16.
16/17.
17/18.
18/19.
19/20.
20/21.
21/22.
22/23.
23/24.
Tonnes
-100,000
-200,000
-300,000
-400,000
-500,000
Year
40% Recycling
50% Recycling
60% Recycling
70% Recycling
7
80% Recycling
70% Recycling LAS Compliant
All of the recycling/composting targets in the 40%, 50%, 60%, 70% and 80% options will
require the additional treatment of residual municipal waste in order to meet EU Landfill
Directive target for 2012/13. It is only the option “70% recycling LAS compliant” (i.e. 52%
recycling/composting in 2012/13) that will meet the corresponding EU Directive target.
This is even with the accelerated collection of kitchen waste in the options 40% to 80%.
Financial appraisal
All Wales basis
The trajectories for costs on an annual basis (in real 2006/7 terms and excluding inflation)
are shown in Figure 3. These show how the costs in the early years are lower for the lower
recycling rate scenarios as:
•
•
new residual waste treatments – more expensive than landfill – have not yet come
on stream; and
the short term costs of recycling are higher, and worsen the net financial position as
long as the avoided cost of disposal remains low.
Figure 3: Evolution in Annual Increases in Cost Relative to 2006/7 (annual increase in real £ 2006/7)
£100,000,000
Increase in Cost Relative to 2006/7 (annual £, real 2006/7 terms)
£90,000,000
£80,000,000
£70,000,000
£60,000,000
£50,000,000
£40,000,000
£30,000,000
£20,000,000
£10,000,000
£0
07/08.
08/09. 09/10.
10/11.
11/12.
12/13.
13/14. 14/15.
15/16.
16/17.
17/18.
18/19. 19/20.
20/21.
21/22.
22/23.
23/24. 24/25.
Year
40% Recycling
50% Recycling
60% Recycling
70% Recycling
70% Recycling LAS Compliant
80% Recycling
In later years, however, higher recycling rate options fare much better because recycling
will be cheaper than the costs of treating the residual. The 40% recycling option is the
most expensive over the longer term (with an additional cost of some £92 million in
2024/25). The most cost effective options for 2024/25 are the 60% and 80% options (at
around £73 - £77 million above current costs), followed by the two 70% options (some £88
million). However, the 70% options in 2024/25 offer better environmental outcomes than
the 60% option and are considered more achievable in the timescale than the 80% option.
8
The 70% option is more expensive than the 60% option because: a) it is necessary to start
getting at some materials from less straightforward waste streams and b) there is the
introduction of a second pass on the dry recyclables service which cuts in in the 70% and
80% scenarios. These also have lower revenues from collected material because they
imply 'degrees of mingling' eg fibres, plastics etc. are collected as 'groups' rather than
being collected entirely segregated - in other words, fibres are collected separately, and
plastics separately, and then sorted centrally (and this has been allowed for in revenue
calculations).
Wales faces a choice: whether to spend large amounts of money on residual waste
treatment, at relatively high cost, or whether to maximise the potential of existing and
future systems to capture materials for recycling, so avoiding the costs of disposal. The
more successful it becomes in doing the latter, then the less it will pay. The figures below
clearly indicate that at lower recycling rates, the vast proportion of the (higher) additional
cost is spent on residual waste treatment and disposal. At the highest recycling rates, the
amount spent on disposal is actually less than is spent on residual waste today.
Differences between types of authorities
Tables 2 and 3 below show how the costs of kerbside recycling have to change in order to
meet the different targets in the years 2012/13 and 2025/26. Costs are expressed in real
terms, and are expressed relative to the current system. The costs are kerbside collection
costs only and they do not include disposal or the costs of bring and CA sites. Higher
recycling rates imply lower disposal costs.
Table 2: Increase in Costs (collection only) Relative to Current Kerbside Systems, 2012/13 Targets (£
per household). % are for recycling/composting rates
Urban
Valley
Rural
2012/13
40%/0%
2012/13
43%/10%
2012/13
44%/10%
2012/13
46%/10%
2012/13
48%/10%
£6.43
£8.45
£33.80
£12.93
£8.99
£43.49
£13.01
£9.93
£44.12
£15.22
£11.45
£44.44
£18.80
£17.87
£39.85
Table 3: Increase in Costs (collection only) Relative to Current Kerbside Systems, 2024/25 Targets (£
per household). % are for recycling/composting costs
Urban
Valley
Rural
2024/25
40%/0%
2024/25
50%/10%
2024/25
60%/12%
2024/25
70%/15%
2024/25
80%/15%
£5.80
£7.72
£33.16
£18.07
£17.26
£42.88
£20.09
£17.95
£45.52
£41.85
£37.99
£50.75
£43.91
£35.82
£50.93
The analysis shows that the cost of kerbside recyclate collection is significantly higher for
rural authorities. However, rural authorities can place a greater emphasis on bring sites
and HWRCs which are significantly cheaper to operate. The “sparsity” element in rural
authorities is also incorporated into the SSA formula.
9
THE PRACTICALITIES OF IMPLEMENTING AND DELIVERING THE TARGETS
Service delivery steps that need to be taken to reach higher recycling rates
Local authorities will need to undertake the following actions, or ones that have the
equivalent effect, in order to meet higher recycling rates:
For lower targets in earlier years (ie 40% in 2009/10 and 52% in 2012/13):
•
•
•
•
•
•
Invest additional funds in scheme promotion and general awareness raising activities
Enhance recycling rates at CA sites to a level around 68-75% (depending on the
target) focussing on increasing the capture of all currently targeted materials
Enhance the capture of materials currently targeted by door-to-door and bring recycling
schemes
Develop door-to-door food waste collections for households. An overall capture rate of
55% of food waste would be necessary to deliver the 52% target and
Change from fortnightly dry recyclate collection to weekly collection (or in some areas it
may make more sense to provide additional or larger containers for fortnightly
collection especially in rural areas)
Enhance the recycling of bulky and trade waste – currently collected materials (WEEE,
furniture and wood)
For higher targets in later years (ie 56% in 2015/16 and 70% 2024/25)
•
•
•
Invest further funds in scheme promotion and general awareness raising activities
(though the focus of this is likely to switch to waste prevention over time)
Increase recycling rates at CA sites to at least 80%, maximising capture of all currently
collected materials and seeking to capture additional materials (such as non-packaging
glass, mattresses and carpet) over time
Aim to capture around 60%, 70% and 80%, respectively (depending upon CA site
performance), of all doorstep collected waste through source separation schemes. This
will require
−
−
−
Further improvement in captures of material for recycling;
The broadening in scope of the materials targeted for collection from households;
and
Possibly, additional passes for the collection of dry recyclables in recognition of the
breadth of scope of materials being targeted. This is most likely for the 70% and
80% scenarios where all fibres and all plastic fractions would need to be targeted
Several materials would need to be captured at very high rates (85-90% to meet the 70%
target, and 90%-95% to meet the 80% target), whilst materials which are not widely
collected today would also have to be captured reasonably effectively (eg mattresses,
carpets). To get to 70%, the latter type of material would need to be captured at rates
between 20-40% or so, whilst to achieve the 80% target, these materials would also need
to be captured at rates around 70% and above.
All of these rates imply, at least for some materials, high levels of participation in recycling,
and high recognition rates by all participants. For other materials, at lower recycling rates,
10
participation and recognition may be lower, but increasingly, as the targets increase, so all
materials have to be captured at higher rates through more or less universal participation
and high recognition rates. This would require:
•
•
•
•
Further enhancement of recycling of collected bulky and trade waste, though
maximising currently collected materials and introducing new materials (recycling all
types of WEEE at high rates, including dense plastic materials, carpet, etc.)
Introduction of separate recycling bins for litter (or very dense bring networks)
At the highest recycling rates, the introduction of systems for extracting materials from
street sweepings
Effective recycling of any collected trade waste is recycled
There are good examples, for example, in Upper Austria, of whole regions achieving high
recycling rates through bring site infrastructure. This generally occurs through dense
provision of hybrid bring/CA sites, and in Upper Austria, a central logistics depot has the
responsibility of dismantling products to enable their constituent components / materials to
be sent for reprocessing with maximum value obtained through primary processing.
However, in the experience of the consultants doing this work, it has proved difficult to
exceed 50% recycling across a wide area through use of bring infrastructure alone.
A critical part of increasing recycling rates is the level of spend required on education and
awareness raising. There is no currently available figure for all Wales. We estimate that
the level of spend on this would need to increase by at least £3 per household in the long
term (to meet higher recycling rates). In the financial modelling, a figure of £3.50 per
household has been used for 2024/25 at the highest rate and a straight line increase has
been allowed for between 2007/8 to 2024/25 for education and awareness raising from:
•
•
•
•
•
Increase of £1.00 per household to meet the 40% recycling target
Increase of £1.50 per household to meet the 50% recycling target
Increase of £2.00 per household to meet the 60% recycling target
Increase of £2.50 per household to meet the 70% recycling target
Increase of £3.00 per household to meet the 80% recycling target
11
Assessment of potential barriers to high recycling and methods of addressing them
Summary of barriers and ways to address them
The achievement of high recycling targets is only possible by identifying and overcoming
potential barriers. Table 4 summarises potential barriers and how these might be
overcome. Further detail on key issues is provided below.
Table 4 - Potential barriers to achieving very high recycling targets and measures that could be
employed to address them:
POTENTIAL BARRIER
Not all householders
segregate their wastes for
recycling
Householders do not
segregate their wastes
effectively
POLICY INSTRUMENTS,
INTERVENTIONS OR
MEASURES TO ADDRESS
BARRIER
Local authorities to introduce
fortnightly collection of residual
household waste. Evidence
has shown that, coupled with
weekly dry recyclables and
food waste collection, this
significantly increases
recycling rates
Introduce powers for local
authorities to directly charge
for the amount of residual
waste
Introduce a householder
obligation to segregate their
wastes and use the containers
supplied by the local authority
Better education and
awareness raising
Identify and promote best
practice collection system(s)
that secure(s) greatest yield of
high quality recyclate (ie. the
ones that work best for the
public and reprocessors)
12
RISKS / CONSTRAINTS/
DEPENDENCIES FOR
MEASURE(S)
Needs to be supported with a
campaign of public education
and awareness to get across
the value and importance of
this change
Needs to be supported with a
campaign of public education
and awareness to explain
reasons and benefits.
Charges are widely used
throughout Europe
Likely to be quite resource
intensive to enforce,
particularly in those areas that
are demographically less predisposed to recycle
Cost but proven to be very
effective (eg Flanders)
Promotion of best practice is
constrained by issue of local
determination & ‘one size
doesn’t fit all’. Nevertheless,
there is scope for
standardisation
Not enough of the
municipal waste stream
can be recycled to meet
required target
Lack of markets for
recyclate / compost
Perceived costs and
potential lack of funding
Impose producer responsibility
requirement on items sold in
Wales to ensure greater
degree of recyclability
Examine and disseminate best
practice elsewhere (eg identify
and promote what Flanders &
Upper Austria do to reach high
levels of recycling)
Some markets are inhibited by
the lack of an adequate local
supply of recyclate. Increasing
recycling rates may help to
create new local Welsh
markets, investment and jobs
Further support for market
development through an
enhanced Wales focussed
market development
programme.
Green procurement by the
public sector in Wales,
including minimum levels of
recyclate in goods purchased,
together with support for Welsh
businesses to enable them to
compete for contracts
Greater focus on costs and
rigorously pursue efficiency
savings through the
identification and
dissemination of good practice
Greater degree of
standardisation across all
Welsh local authorities and
VFM benefits of central call off
contracts
Secure greater degree of
provision of joint services
between neighbouring local
authorities through Joint
Service Boards etc
13
Likely to be very difficult
though there are encouraging
signs that the major retailers
are starting to increase the
recyclability of their products
and packaging
Straightforward but requires
capacity and willingness to
adopt best practice
Will need business support, as
there is no guarantee that this
will happen naturally
Funding although
Convergence funding can help
in the Convergence Region
May require a degree of
compulsion and initially cost
more until market forces bring
down costs
Existing inadequate financial
management systems, a lack
of standardisation of service
delivery and a resistance to
perceived prescription from the
Assembly Government
Potential resistance to taking
away local authority freedom
Need to promote further
collaborative ways of working
through Making the
Connections, etc
Addressing specific barriers
Limits in respect of the amount of municipal waste that is recyclable
Annex 1 shows the assumptions made in this study in respect of the types and proportions
of municipal waste that could be targeted for collection and recycling in order to meet the
different recycling target options. The materials that could be recycled make up 93.3% of
the municipal waste stream. This excludes disposable nappies (2.5% of the municipal
waste stream) which could be re-designed to become fully biodegradable, and which could
then be co-collected with food waste and subjected to in-vessel composting or anaerobic
digestion. It also excludes the recycling of combustion plant bottom ash, which typically
makes up around 10% of what is subjected to combustion with energy recovery.
High recycling rates will be made slightly more achievable if the recycling of combustion
plant bottom ash were to be counted towards the recycling figures. If there is a maximum
energy from waste rate of say 30%, then the recycling of bottom ash could add 3% onto
each local authority’s recycling effort. This would also incentivise the recycling of
combustion plant bottom ash – eg as a secondary aggregate.
Increasing householder participation
A 70% recycling rate, for example, will require “capture rates” from around 30% for some
materials up to around 90% for others for the individual materials that need to be recycled
(see Annex 2 for further details).
There are two factors that determine the effectiveness of recycling and composting
services:
•
•
The quality of the service
The way the public use the service
It is quite clear that providing an excellent level of bring sites and kerbside collection
services is a fundamental pre-requisite for high recycling. However, without enthusiastic
public participation recycling rates will not necessarily be more than moderate.
Helping to create the social and cultural conditions that will increase the likelihood of
achieving high recycling rates will require a range of approaches. These range from
persuasion to obligation. Both approaches include a greater emphasis on education and
awareness raising, not just exhorting people to act, but showing them the benefits to
themselves and their communities as well as the environment of doing so. These benefits
include job creation, increased training, development of industries based on
recycling/composting (AD) and new categories of employment - so called ‘green collar’
jobs (and thus contributing towards the One Wales commitment to “Green Jobs”).
At the other end of the spectrum is the use of penalties against those who do not recycle
as required (some local authorities, eg Swansea CC, have already taken such action)
through to charging households according to the quantities of residual waste they produce.
Charging for residual waste collection is commonplace in continental Europe where it is
accompanied by high recycling rates.
14
Growth in municipal waste
One of the key variables to be considered in setting future recycling and composting
targets is the potential change in the quantity of municipal waste produced in Wales. It is
anticipated, based on analysis of trends, that the rate of growth in the amounts of
municipal waste generated will probably stabilise to average 1% over coming years. More
work needs to be done on modelling future waste growth to better understand the
influences upon it, but there are signs that some kinds of consumer goods are becoming
lighter and also that waste prevention measures may be having an impact.
Early signs of a reduction in consumer waste may in part be due to the “Courtauld
Commitment” and because of action by consumer groups, including the Women’s Institute.
The Courtauld Commitment sets out an agreement between Government, WRAP and the
majority of the leading UK grocery retailers, as well as the British Retail Consortium to:
•
•
•
design out packaging waste growth by 2008
deliver absolute reductions in packaging waste by 2010
identify ways to tackle the problem of food waste
All signatories are working on reducing their packaging and some have developed their
own waste reduction targets, for example:
•
•
•
•
•
•
•
•
•
ASDA: 25% packaging reduction target for own label food products by 2008
Cadbury Schweppes: 10% reduction in packaging used per tonne of product and 25%
in the more highly packaged seasonal and gifting items
Marks & Spencer: a 25% reduction in non-glass packaging by 2012
Morrisons: 15% packaging reduction target for own brand by 2010
Musgrave Group (Budgens and Londis) are in the process of revising their packaging
guidelines to incorporate the need for packaging reduction
Sainsbury's: 5% overall packaging reduction target by 2008 and a 25% packaging
reduction target for fresh produce by May 2008
Somerfield: redesigning their ready meal packaging to extend shelf life and cut food
waste
Tesco: 25% reduction across all packaging including brand and own label by 2010
Waitrose: put in place targets to keep future packaging levels below those of 2002, and
have cut packaging waste growth by 15% in 2006
The most effective activity to reduce municipal waste is home composting. The Assembly
Government has been promoting home composting very strongly (including distributing
40,000 home composting units to Welsh local authorities so far this year). Continued
promotion of home composting and other waste prevention techniques should help
contribute to maintaining the growth in Welsh municipal waste arisings at less than 1%.
Changes in the composition of municipal waste
There are likely to be significant changes in the composition of municipal waste in future,
including changes in materials such as plastics (ie. a greater proportion will be
biodegradable and/or more easily recycled) and food wastes. The Assembly Government
is part sponsoring the WRAP study of the composition of food wastes, which includes
15
analysis of food wastes in two Welsh local authorities. The findings will affect the
assessment of how much might be recycled and composted (or treated by anaerobic
digestion [AD]) in future. Preliminary data from some authorities collecting food wastes
suggests that there may be a higher proportion of food wastes in municipal waste in some
authority areas than the 2003 study has indicated. The treatment of these wastes and
kitchen cardboard through composting or AD might make a greater contribution towards
overall targets than previously estimated.
Potential markets for recyclate and compost/AD residues
Markets for recyclate and compost/AD residues are very important, especially indigenous
markets that use secondary materials to develop the reprocessing sector and create jobs
based on sustainable resource management. Whilst there are good markets for most
types of clean recyclate, there are still materials being sent to the Far East that could be
used to develop Welsh industries. A key example of this is plastics.
Plastics collected by many local authorities are exported to the Far East because of the
high prices offered and the lack of facilities for sorting in Wales. The Assembly
Government has awarded a grant to help establish a plastics sorting facility in Wales as
part of its Regional Capital Access Fund (RCAF). This will enable Welsh local authorities
to send mixed plastics to a facility in Wales that will sort and send on a range of polymers
for use by Welsh or UK businesses.
The revision of the Business and Environment Action Plan and the Wales Waste Strategy,
together with the introduction of the Convergence Programme’s Strategic Framework for
Materials Efficiency are likely to lead to greater effort and focus on the creation of markets
for recyclate in Wales.
As part of an Assembly Government sponsored programme, regional composting projects
are trialling the use of compost in a range of applications, including landscaping and
agriculture. Such materials offer the opportunity to substitute for peat based products and
thus contribute to protection of habitats and biodiversity. There is already the PAS100
standard for compost and there are plans to extend this to covered residue. There is also a
Quality Protocol for compost agreed between WRAP and the EA, and again there are
plans to extend this to cover AD residue.
The public sector in Wales procures a large quantity of goods and services and has the
potential on its own to create major markets for recyclate and compost. This is
recommended as an area for significant action.
Possible local factors that need to be addressed and whether differential targets are
justified
It has been suggested that instead of the same targets applying to all 22 local authorities
in Wales that there should be some sort of account taken of local authority types, eg
valley, rural and urban. A summary of some different factors positively and negatively
affecting recycling rates in the three different types of authority is provided below (Table 5).
It also highlights the point that sustainable housing will require homes to be built with
adequate facilities for domestic segregation of recyclable materials.
16
Table 5 – Meeting high recycling targets - comparison of opportunities and constraints in different
demographic areas of Wales
Rural
POSITIVE ASPECTS
Strengths/opportunities
Population more receptive to
environmental issues
More space inside and outside houses
NEGATIVE ASPECTS
Potential weaknesses/problems
Access to households (eg where some
distance from the main road)
Access to households (eg where some
distance from the main road)
Distance between properties
How to capitalise on the strengths and
opportunities
Householders more willing to participate,
and “go the extra mile”, literally when it
comes to using cheaper bring bank systems
Allows greater degree of source separation
through increased number of different
recyclate containers. This reduces sorting
costs by the councils and leads to a higher
quality recyclate and higher income, thus
offsetting collection costs
How to address or overcome the
weaknesses/ problems
All properties have existing arrangements
for the collection of their residual waste.
Separate 200 litre “Point Bins” could be
used for recyclate/food waste where private
roads connect with adopted highways.
All properties have existing arrangements
for the collection of their residual waste
(black bags). Separate 200 litre “Point Bins”
could be used for recyclate/food waste
where private roads connect with adopted
highways (like the old milk churn platforms)
There is an allowance for the “sparcity”
factor in the Standard Spending
Assessment formula for LA funding.
Urban/city
POSITIVE ASPECTS
Strengths/opportunities
More dense housing leading to reduced
collection costs
Shorter distances to neighbourhood /
street corner bring banks
How to capitalise on the strengths and
opportunities
Reduced costs for collection through
economies of scale and shorter rounds
Could prove a very cost effective way of
collecting recyclate, and would emulate very
successful systems in urban areas in other
parts of Europe. Would be particularly
effective for multiple occupation buildings,
especially blocks of flats / apartments
17
NEGATIVE ASPECTS
Potential weaknesses/problems
Significant numbers of apartment blocks
with restricted space within each
apartment
Transient populations, especially in
University areas
Less sympathetic to environmental issues
How to overcome the
weaknesses/problems
Ensure all new apartments have adequate
space for recyclate containers (via Building
Regulation). Recyclate could be collected
centrally in 200 litre “point bins”
Targeted educational effort at students /
landlords
Greater educational / awareness raising
effort. Use of incentives. Create competition
between neighbourhoods through a “league
table” of recycling rates
Valleys
POSITIVE ASPECTS
Strengths/opportunities
Strong sense of community
More dense housing leading to reduced
collection costs
Shorter distances to neighbourhood /
street corner bring banks
How to capitalise on the strengths and
opportunities
Enhanced awareness and education
programmes specifically tailored to the
community and using community champions
Reduced costs for collection through
economies of scale and shorter rounds
Could prove a very cost effective way of
collecting recyclate, and would emulate very
successful systems in urban areas in other
parts of Europe
NEGATIVE ASPECTS
Potential weaknesses/problems
How to overcome the weaknesses/
problems
Social deprivation/exclusion leading to lack Create specific incentives for deprived
of motivation
/excluded communities as part of an overall
urban/social regeneration (eg Communities
First)
Some officers in valley communities contend that due to the demographic features of their
authorities and attendant social and cultural mores that it is more difficult for them to
achieve high recycling rates. Some officers in rural communities contend that due to the
distances involved that their costs will be higher and that it is consequently more
expensive (thus difficult) for them to achieve high recycling rates. Some officers in urban
communities point to other factors, including a large proportion of students and the fact
that some urban authorities host many of the residents of other authorities as they arrive to
work each day – making it more difficult for them to achieve high recycling rates.
The published recycling rates show high and low performers from each authority type and
that the RPS report showed little variation in kerbside recycling collection costs across
authority types. There is no evidence to support having different targets for different areas.
Working to the same targets is also more equitable and ensures all areas come up to the
same good practice standard.
18
Other issues
Benefits of source separation and kerbside sorting over reliance on technologies
There has been a long debate over the relative merits of the kerbside sorting of
recyclables versus the co-mingled collection of recyclables and processing in a materials
recovery facility (MRF). Similarly there is a debate over the merits of the separate kerbside
collection of recyclate versus extraction of recyclables from mixed municipal waste through
the use of mechanical heat treatment and/or other “dirty” MRFs. There is also a debate
about the merits of recycling versus energy from waste.
What ever route is chosen will have to be flexible and adaptable in order to accommodate
the following likely changes over the next 20-30 years. The less reliance there is on large
scale plant, the more likely it is that the system will be adaptable to the likely changes that
will occur, such as:
•
•
•
•
•
changes in the quantity of municipal waste produced
changes in the composition of municipal waste
changes in the recyclability of materials in the municipal waste stream
changes in the chemical composition of waste materials (eg possible increase in the
use of biodegradable polymers)
changes in legislation
on the evidence available, the conclusion is that the kerbside sorting of separated
recyclables, together with the use of bring sites and Household Waste Recycling Centres
(HWRCs) is the most “future proof” approach. Some technologies are also poor
performers in terms of their carbon footprint and produce poor quality (ie contaminated)
recyclate.
Benefits of anaerobic digestion of source separated food waste
The identification of anaerobic digestion as a sustainable technology for the management
of food waste is not new. Wise About Waste included anaerobic digestion as an eligible
method to meet composting targets in 2002 and the NAWPI definition for composting was
amended to include anaerobic digestion in 2005.
Subsequently several studies commissioned by DEFRA and WRAP have concluded that
anaerobic digestion has the greatest greenhouse gas reduction benefits for the
management of food waste over in-vessel composting and incineration with energy
recovery.
A recent study3 of food waste anaerobic digestion systems used extensively across
Europe indicates that this is a mature technology that has significant benefits, particularly
the production of a renewable fuel/energy.
3
Anaerobic Digestion of Biodegradable Municipal Waste: A Review carried out by the University of
Glamorgan with support from the Assembly Government.
19
Assessment of the desirability of recycling targets for specific materials
General recycling targets are often criticised for encouraging the recycling of materials with
high bulk density (ie heavy), including glass and paper, whilst discouraging recycling of
materials with low bulk density (ie light), including plastics and cardboard. Materials
specific targets for plastics and cardboard would ensure that all local authorities collected
these materials and would probably also see an enhanced recycling performance for nontarget materials.
The collection and treatment of food waste is also fundamental to any high recycling/
composting/AD strategy. Not only is food waste quite easy to collect (high bulk density),
but experience shows that collecting food waste has the incidental effect of increasing the
recycling of other materials too. This has been observed in areas of Rhondda Cynon Taf
CBC where food waste collections have recently been introduced.
Time constraints have precluded the analysis of other potential material specific targets,
though these will be considered during the review of the Wales waste strategy.
Assessment of the potential to set residual household (or municipal) waste targets
There are circumstances where high recycling/composting rates can actually result in a
worse environmental performance than lower recycling/composting rates. In particular, it is
better to recycle/compost a slightly lower proportion of lower total arisings than to recycle/
compost a very high proportion of much higher arisings, eg driving up green waste
composting. This potential anomaly can be addressed by introducing residual waste
disposal targets. With these, every local authority is given a per capita threshold of the
quantity of non-source segregated residual (ie non-recycled) material that may be treated
or disposed of (to landfill, incineration with energy recovery or other). To meet this target
LAs could focus on waste reduction as well as pursuing high recycling/composting rates
including the recovery of energy from source segregated bio-waste, eg production of biofuel from used vegetable oil.
This idea is predicated on the assumption that it is better to prevent/reduce waste rather
than recycle/compost it after it has been created. It does not reduce the pressure for
recycling/composting and has considerable merits.
Figure 4 demonstrates that the total household waste quantities per person across the
three types of local authorities are roughly similar. Therefore there are no clear “winners”
or “losers” if the same residual target is set for each authority.
20
Figure 4 - Average total household waste per person in 2006/07 in each local authority type
Average (mean) household waste arisings by authority type 2005-06
600
500
kg/person/year
400
300
200
100
0
Rural
Urban
Valley
Local Authority Type
Assessment of maximum targets for energy from waste
High recycling/composting targets (ie higher than 64% by 2019/20) will, according to
models, ensure that Welsh local authorities meet all their Landfill Allowances Scheme
targets including the 2019/20 target. In this scenario there is no need for consideration of
incineration or other combustion technologies to meet LAS targets. However, as landfill
capacity runs out, and the environmental benefits of recovering energy from waste rather
than sending it to landfill become a higher priority, the development of energy from waste
capacity will become more important. A provision of a modest level of energy from waste
capacity will also serve to help Wales become more resilient in the face of potential future
emergencies such an outbreak of avian flu.
On the assumption that landfill will be reduced eventually to as close to zero as possible
(because of policy drivers and costs), maximum levels of energy from waste automatically
will mirror minimum recycling levels. Thus if the recycling target for 2024/25 is set at 70%,
the maximum amount of energy from waste allowable should be 30%.
There seems little benefit in allowing individual local authorities to exceed the 30% energy
from waste threshold, even in the “early” years when energy from waste plants are first
commissioned (which may not be until 2014). There is a danger that initially higher levels
of energy from waste will subsequently prove difficult to reduce thus potentially crowding
out increases in recycling. Also, operators usually require a constant minimum tonnage
and it is unlikely that they would welcome a scenario of decreasing quantities and
potentially decreasing revenue in future years. Replacing lost municipal waste with
commercial and industrial waste cannot be guaranteed and would represent a significant
risk for operators (and their bankers). It is also considered that 30% EfW is a defendable
position during the planning stage whereas anything higher will mostly likely receive a far
greater degree of challenge.
21
Contracts for energy from waste usually last around 25 years. Because landfill will be
cheaper in early years, it makes little sense to have an initially higher proportion of
municipal waste subjected to energy from waste in the early years, with a tapering level
over time. It would make more sense to keep the level of energy from waste constant, and
use a higher proportion of landfill in the earlier years to fill the gap not filled by recycling.
Then as recycling increases, the amount of landfill can decrease.
It is also important that energy from waste capacity is not developed to the extent that it
crowds out recycling. Consequently, if long-term high recycling/composting targets are to
be set then appropriate long-term energy from waste targets should accompany them. An
example would be:
•
•
•
Recycling/composting in 2025 to be 70% or above
Landfill not to exceed 5%
Energy from waste not to exceed 30%
Due consideration needs to be given as to whether a maximum level of 30% EfW and a
minimum level of 5% landfill is achievable in a rural authority. This would mean that by
2024/25 each rural authority would need access to an energy from waste plant that could
take between 25-30% of its municipal waste. There could be issues with poor economies
of scale because of the low tonnage and whether any private sector operator would be
prepared to tender for a low tonnage. However, small scale EfW plants are commonplace
in Europe, particularly in Denmark, and even exist in the UK (although mostly in an island
context). Also, gasification and pyrolysis plants operate on a small scale. Small scale
plants are viable for CHP and suitable for a range of public sector and commercial
developments t take the heat and this would help offset any higher costs due to poor
economies of scale. EfW can therefore, be a viable option for rural authorities, even at a
level of 25-30%.
Assessment of changes to Landfill Allowances Scheme targets
There have been representations from some local authority officers to the Assembly
Government that it should change the way that Landfill Allowances Scheme targets are
set. The argument is based on a perception that in the regions of Wales some local
authorities are better placed to provide energy from waste whilst some are better placed to
recycle/compost. So, it is argued, pooling their individual efforts means achieving overall
recycling/composting targets and LAS targets.
However, there is no evidence to justify any area not meeting the same sustainable waste
management targets as another. It is recommended that the LAS targets remain with
individual local authorities and are apportioned on the same basis as they are now. This
maintains the principle of equity in sustainability terms, whereby all communities receive
an equal level of recycling/ composting service and an equal decrease in the amount of
their waste landfilled.
Assessment of other options to treat residual municipal waste
Some local authorities and waste management companies are exploring the option of
meeting Landfill Directive targets through the mechanical and biological treatment (MBT)
22
of mixed residual municipal waste with the resulting organic rich residue potentially spread
on land and another fraction (usually refuse derived fuel or RDF) sent for energy recovery.
The MBT residue that may be spread on land is classified as a waste and can only be
spread on non-agricultural land under an exemption from the Waste Management
Licensing Regulations. This requires Environment Agency approval. They have to be
satisfied that the material will benefit the land and not harm the environment or human
health.
MBT residue is derived from mixed municipal waste that in itself is composed of a huge
variety of substances, some of which are hazardous (since householders are legally
allowed to dispose of most hazardous household waste in the household waste bin).
Operators of MBT plants claim that the physical and biological processes that sort treated
municipal waste into fractions according to size and density produce a residue that has a
low hazard. Research is currently underway to assess the effects of spreading MBT
residue on land. This needs to take account of likely long term toxicological and bioaccumulation effects on soil biota.
The practice of spreading MBT residue on land has been banned in Scotland by the
Scottish Environment Protection Agency (SEPA). In England, there is only one case where
the Environment Agency have allowed MBT residue to be spread as a waste on land. This
has been from a sophisticated MBT plant with a high degree of separation and processing
of the residue.
With due regard to the precautionary principle, it is recommended that treated mixed
municipal waste is banned from being spread on land in Wales. This ban should remain in
place until suitable toxicological standards are set that will protect soil biota. This would
mean that the only viable option for MBT residue would be landfill at considerable cost.
Given that the outputs from MBT (ie RDF and the residue) have limited markets and can
be expensive to deal with, it is recommended that contract tenders do not specify that MBT
must be used.
Another form of treatment of residual municipal waste is mechanical heat treatment (MHT).
This is claimed to yield high quantities of both recyclate and of a fibre that can potentially
be used as a fuel (possibly with a very high renewable waste content). These claims have
yet to be substantiated in a European or UK context, and local authorities are not advised
to go down the MHT route until the technology and markets for the outputs become more
proven in a UK context.
Assessment of landfill level and future need
There are compelling arguments in the longer term to decrease landfill to an absolute
minimum on the grounds of cost, environmental impact (especially greenhouse gas
emissions), international law and current Assembly Government policy (Wise About Waste
and Environment Strategy).
The Landfill Tax is set to double in the next three years from the current rate of £24 to £48
in 2010/11. It may increase further from 2010/11. In addition it is predicted that landfill gate
fees excluding Landfill Tax will also increase significantly over the next few years. An gate
23
fee of £52 excluding Landfill Tax by 2010 is considered likely in North Wales, making a
total landfill cost of around £90 per tonne for North Wales authorities.
The sustainability appraisals carried out as part of the review of the three Regional Waste
Plans has identified that landfill is the least sustainable option. Landfill performs the worst
in terms of greenhouse gas emissions.
The European Union is committed to reviewing targets set in the Landfill Directive and
there is an expectation that further controls will be set on what can be landfilled.
Wise About Waste has an overarching objective that includes reducing landfill to a
minimum, where practicable. The Environment Strategy for Wales includes a target for
there to be no more landfill of municipal waste by 2025.
However high the recycling/composting target is set and however much energy from waste
is developed there will always be some need for a small amount of hazardous and nonhazardous landfill for municipal waste. This would be for some hazardous waste (eg fly
ash from pollution abatement processes at energy from waste facilities) and some nonrecyclable materials that cannot be combusted (although this is likely to be very small).
PROPOSED SUPPORTING ACTIONS
i)
Action to address the increased cost to Local Authorities of waste management
Municipal waste management will cost more in the future. Central and local government
will need to work together to identify costs and sources of funding in partnership with the
private sector where appropriate.
ii) Introduce legislation to provide a statutory duty for local authorities to recycle municipal
waste and to make the recycling(and possibly EfW) targets statutory.
Subject to the necessary legislative powers being obtained through the LCO, and following
consultation, it is recommended that the Assembly Government introduces legislation to
create a statutory duty for local authorities to recycle municipal waste, and to make
recycling and food waste (and possibly EfW) targets statutory to 2019/20. There would
need to be adequate penalties for non compliance, eg similar to the LAS scheme.
iii) Programme of more focussed, action specific funding to deliver particular elements of
the recycling service (starting with food waste).
This programme will include targeting funding for the separate collection of food wastes
from households, institutions (eg schools) and commercial premises. It is most
economically and environmentally beneficial to anaerobically digest (AD) separately
collected food waste. In addition to extra funding for food waste collections, local
authorities should be encouraged to procure AD treatment without delay and to specify a
preference for zero capital cost options, provided that payment for the facilities through
gate fees as part of long-term contracts is an affordable option. There are currently
European companies offering such terms at costs that are lower than the costs of landfill.
24
iv) Scoping of, and consultation on, powers to introduce direct and variable charging for
municipal waste collection.
Across much of Europe high recycling performance is accompanied by schemes for direct
and variable charging for the collection of residual municipal wastes. Consultation on this
issue will form part of the forthcoming consultation on the Wales Waste Strategy.
v) Scoping of, and consultation on, possible powers to place an obligation on
householders to recycle.
Consultation on this issue will form part of the forthcoming consultation on the Wales
Waste Strategy.
vi) Scoping of, and consultation on, on a potential minimum efficiency target for energy
from waste.
The revision of the EU Waste Framework Directive includes the potential inclusion of a
minimum threshold for the thermal efficiency of an energy from waste plant in order for its
use to be deemed to be a “recovery” operation rather than a “disposal” operation. If
introduced, this would not mean that all energy from waste plants would have to meet the
minimum efficiency requirements, unless a cap was set on the proportion of municipal
waste that could be disposed of. A high thermal efficiency would help ensure that an
energy from waste plant makes a greater net contribution to reducing green house gas
emissions. There are strong grounds to require all energy from waste plants in Wales to be
set a minimum thermal efficiency. This would need to be subject to consultation and
could form part of the consultation on the revision of the Wales Waste Strategy.
vii) Scoping of, and consultation on, possible powers to ban the landspreading of nonsource separated treated municipal waste.
This could form part of the consultation on the revision of the Wales Waste Strategy.
viii) Increased public awareness raising and communications campaign.
More effort will need to be applied to awareness raising and this is likely to require an
increased proportion of expenditure to be applied by both local authorities at a local level
and the Assembly Government at a national level.
ix) Identification and dissemination of good practice / value for money services, and
annual reporting of financial performance data.
Achieving a high recycling and composting/AD performance will not be easy. For many
local authorities service delivery improvements will have to take place against a
background of funding constraints. It is therefore critically important that local authorities
optimise the efficiency of expenditure. Monitoring performance, including relevant financial
aspects, must be a top priority in future years and may become a condition of any
additional funding. Benchmarking against such data and exchanging good practice is one
way that the whole of ‘Team Wales’ can contribute to progress.
25
x) Actions to introduce more standardisation of collection systems, including creation of
framework contracts for common equipment in order to secure better value for money.
There are existing framework contracts available through Value Wales that aim at
improving value for money. Value Wales is exploring the potential to do more in this area.
Local authorities procuring and providing facilities and services through co-operative
consortia have the potential to realise savings that can be used to re-invest in other
initiatives to help achieve high recycling rates
xi) Scoping of, and consultation on, possible enhanced producer responsibility powers to
ensure that less waste is produced, and that what is produced is recyclable.
This could form part of the consultation on the revision of the Wales Waste Strategy.
xii) Compulsory green procurement by the public sector in Wales, including specification of
recycled content in key products procured by the public sector, in order to stimulate
greater markets for recycled and composted municipal waste.
To be discussed with Value Wales.
xiii) Enhanced support for and better integration of, the development of recyclate markets
in Wales.
The Assembly Government has employed consultants to produce a Recyclate Market
Development Plan for Wales, to replace the existing plan in Wise About Waste. A draft
plan is expected shortly and will then be put out to consultation. Also, there are proposals
to re-focus and better integrate support for materials efficiency in business, and this will
include the better provision of support for recyclate market development.
xiv) Enhanced effort to reduce the quantities of municipal waste produced.
More effort needs to be applied to reduce the quantities of municipal waste produced
building upon the initiative of many of the major retailers who have so far signed up to the
Courtauld Commitment to reduce packaging and food waste.
xv)Review of definitions of waste as part of the review of the Waste Strategy.
We will review whether in Wales we are working to definitions consistent with the rest of
Europe in terms of what counts towards recycling targets.
CONCLUSIONS AND PROPOSALS
Conclusions
It is clear that Welsh authorities now have very little option other than to substantially
increase recycling and composting rates in order to meet the 2009/10 and 2012/13 Landfill
Directive targets. High rates of recycling appear, in the long term, to be the most cost
effective way of managing municipal waste. Also, the higher the recycling rate in
comparison to the rate of energy from waste, the greater the greenhouse gas savings.
26
However, the major constraint is the willingness and ability of householders to segregate
their wastes for recycling. If very high recycling rates are to be achieved, persuasion of the
public is likely to have to go beyond education and awareness raising. It is most likely to
require some form of obligation or financial penalty for not recycling (eg through charging
for waste not separated for recycling).
There are no conclusive arguments for setting different targets for different types of
authorities. There is also no reason why the current system of Landfill Allowance
allocations should be amended.
Proposals
Based on the evidence gathered and appraisals carried out, the following are the
proposed municipal waste management targets to 2025 to form the basis for discussion
(proposed supporting actions are set out on pages 24-26):
Targets
i)
statutory minimum targets for recycling4 and composting as follows
•
•
•
•
•
2009/10 - 40% (of which 15% is composting, not food specific)
2012/13 - 52% (of which 15% is a food specific target)
2015/16 - 58% (of which 15% is a food specific target)
2019/20 - 64% (of which 15% is a food specific target)
2024/25 - 70% (of which 15% is a food specific target)
ii) consider whether the target of 70% for 2024/25 should be statutory at this stage
iii) a maximum target of 30% for 2009/10 to 2019/20 for energy from municipal waste for
each local authority to provide certainty for investment (further consideration will be
given on a potential minimum efficiency target)
iv) maximum municipal waste landfill targets (as a % of total municipal waste) for each
local authority of
•
•
10% for 2019/20
5% for 2024/25 and thereafter
v) a maximum residual household waste target for each local authority of
•
150kg per inhabitant per annum by 2024/25
vi) A potential ban on landspreading non-source separated treated municipal waste from
1 April 2016 (using new legislative powers).
4
Potentially to include the recycling of incinerator bottom ash
27
Table 6 – Summary of preferred new targets
TARGET FOR:
Minimum levels of recycling / composting (or
AD)
Minimum levels of composting (or AD) of
source separated food waste from kitchens
as part of the combined recycling/
composting target above
Maximum level of energy from waste
Maximum level of landfill
Maximum level of residual household waste
per inhabitant per annum
TARGETS FOR EACH TARGET YEAR
09/10
12/13
15/16
19/20
24/25
40%
52%
58%
64%
70%
-
15.0%
15.0%
15.0%
15.0%
-
-
-
30%
10%
-
30%
5%
150 kg
Note – specific composting targets for green waste have been dropped as they have the potential to
encourage the collection of green waste that would not normally have been put out for collection by
householders. Food waste composting/AD targets increase non-linerarly in order to help make a substantial
contribution towards meeting the 2012/13 and 2019/20 Landfill Directive targets.
28
ANNEX 1
OPTIONS FOR TARGETS
The following options for targets have been appraised:
1. Recycling target options:
Table 2 Five recycling target options for municipal waste (recycling/composting)
OPTION
A - No change- 40%
B – 50%
C – 60%
D – 70%
Hybrid D1 - 70% LAS
compliant
E – 80%
TARGET YEAR AND MINIMUM % TARGETS FOR TOTAL
RECYCLING & COMPOSTING / FOOD WASTE COMPOSTING
or AD
09/10
12/13
15/16
19/20
24/25
40/
40/
40/
40/
40/
40 /
43 / 10.0
46 / 10.0
50 / 10.0
50 / 10.0
40 /
44 / 10.0
48 / 12.0
53 / 12.0
60 / 12.0
40 /
46 / 10.0
52 / 12.0
60 / 14.0
70 / 15.0
40/
52 / 15.0
58 / 15.0
64 / 15.0
70 / 15.0
40 /
48 / 10.0
56 / 12.0
67 / 14.0
80 / 15
Note – specific composting targets for green waste have been dropped as they have the potential to
encourage the collection of green waste that would not normally have been put out for collection by
householders. Food waste composting/AD targets increase non-linerarly in order to help make a substantial
contribution towards meeting the 2012/13 and 2019/20 Landfill Directive targets.
2. Potential energy from waste target options
Table 3 – Five energy from waste target options for municipal waste
OPTION
TARGET YEAR AND MAXIMUM % TARGETS FOR ENERGY FROM
WASTE
09/10
12/13
15/16
19/20
24/25
60
60
60
60
60
A. No
change
B
50
50
50
50
50
C
40
40
40
40
40
D
30
30
30
30
30
Hybrid
40
38
34
30
30
D2
E
20
20
20
20
20
Note: The “Hybrid D2” option is to explore the advantages and disadvantages of allowing
individual local authorities (or groups thereof) to enter into contracts that have a built in
reduction in tonnage of municipal waste sent to EfW.
29
3. Potential residual household waste target options:
Table 4 – Four residual waste options for household waste
OPTION
A
B
C
D
E
TARGET YEAR AND TARGETS FOR TOTAL RESIDUAL HOUSEHOLD
WASTE (kg per person per year)
09/10
12/13
15/16
19/20
24/25
300
300
300
300
300
300
290
280
267
250
300
280
260
233
200
300
270
240
200
150
300
260
220
167
100
Note: “Residual” means household waste not reused, recycled or separately composted or separately
anaerobically digested – it covers non-source separated household waste subjected to energy from waste,
landfill or biological treatment. [NEEDS TO BE MORE TIGHTLY DEFINED TO ENSURE ABSOLUTE
CLARITY]
30
ANNEX 2
RECYCLABLE MATERIALS IN MUNICIPAL WASTE (FROM EUNOMIA)
Waste fraction
Newspapers and
magazines
Recyclable paper
Cardboard
boxes/containers
Other paper and
card
Refuse sacks and
carrier bags
Packaging film
Other plastic film
Dense plastic
bottles
Other packaging
Other dense
plastic
Textiles
Shoes
Disposable
nappies
Wood
Carpet and
underlay
Furniture
Other misc.
combustible
Packaging glass
Non-packaging
glass
Garden waste
Food and kitchen
waste
Other organics
Ferrous food and
beverage cans
Other ferrous
metal
Non-ferrous food
and beverage
cans
EUNOMIA
Composition
%
2024/25
7.2%
Capture
rate for
40%
recycling
80.1%
Capture
rate for
50%
recycling
82.2%
Capture
rate for
60%
recycling
83.2%
Capture
rate for
70%
recycling
83.8%
Capture
rate for
80%
recycling
95.0%
1.9%
5.3%
58.8%
69.7%
64.7%
74.3%
76.2%
80.4%
81.4%
83.9%
94.8%
94.8%
5.2%
24.4%
43.3%
67.6%
81.6%
90.6%
1.4%
12.0%
14.1%
29.0%
50.9%
78.1%
1.5%
0.2%
1.8%
8.5%
7.8%
60.2%
8.5%
7.8%
63.5%
16.2%
14.5%
73.2%
36.4%
34.4%
80.9%
74.5%
68.8%
86.5%
1.7%
1.5%
0.0%
13.4%
0.0%
14.9%
18.8%
32.8%
44.9%
55.0%
72.4%
85.9%
2.1%
0.4%
2.5%
30.2%
21.5%
0.0%
33.2%
23.4%
0.0%
52.3%
48.9%
0.0%
69.3%
68.9%
0.0%
86.7%
78.5%
0.0%
3.6%
1.7%
76.5%
0.0%
78.0%
0.0%
85.7%
31.1%
90.8%
54.6%
93.7%
86.7%
1.5%
2.1%
61.7%
0.0%
69.9%
0.0%
82.7%
0.0%
89.3%
0.0%
92.5%
0.0%
5.3%
0.5%
85.0%
0.0%
84.2%
0.0%
88.4%
0.0%
89.6%
19.2%
94.6%
64.4%
10.5%
17.6%
77.0%
13.1%
77.5%
52.7%
82.2%
68.0%
92.3%
80.4%
96.8%
89.6%
2.3%
1.9%
0.0%
57.4%
0.0%
59.8%
27.1%
75.6%
56.2%
83.0%
81.5%
85.8%
2.2%
62.8%
64.8%
73.7%
84.6%
89.3%
0.4%
58.0%
60.4%
76.4%
83.9%
87.6%
31
Other non ferrous
metal
White goods
Large electronic
goods
TVs and monitors
Other WEEE
Lead/acid
batteries
Oil
Identifiable
clinical waste
Other potentially
hazardous
Construction and
demolition waste5
Other MNC
Fines
Mixed waste
Total
0.6%
20.9%
26.3%
49.6%
71.3%
77.6%
0.9%
0.2%
78.9%
62.0%
82.7%
63.4%
85.5%
66.2%
89.6%
76.4%
93.9%
92.9%
0.3%
0.7%
0.2%
82.0%
39.1%
60.1%
84.7%
43.3%
63.0%
87.2%
52.6%
65.9%
90.1%
66.7%
73.7%
93.4%
84.8%
85.0%
0.1%
0.2%
48.9%
0.0%
50.0%
0.0%
53.5%
0.0%
59.9%
0.0%
78.3%
0.0%
0.3%
7.5%
10.2%
15.0%
28.8%
50.5%
5.2%
74.1%
74.5%
75.6%
81.5%
90.0%
1.2%
5.7%
2.0%
100.0%
25.7%
7.9%
0.0%
40.0%
25.7%
14.9%
0.0%
50.0%
25.7%
17.6%
0.0%
60.0%
25.7%
33.1%
0.0%
70.0%
25.7%
41.9%
0.0%
80.0%
5
N.B. capture rates are listed for rubble, however the tonnages do not count towards the denominator or
numerator in the calculation of the overall recycling rate
32
Alan Watson
By e.mail alanwatson@p-i-c.org
Reply to
Telephone
Minicom
Fax
Email
Our Ref
Your Ref
Date
Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT A (3) 7
Statement regarding Outline Business Case to DEFRA from Councillor Steve Comer
(Lib Dem - Eastville)
There has been much discussion over recent months on the future waste disposal strategy
for the West of England, and rightly so. This is an important issue, it affects every citizen
in the sub-region and will have a major impact on our environment and on public finances
for many years to come.
The decision to use mass burn incineration as a 'reference technology' is controversial. To
use an old fashioned and dirty technology will be hugely damaging to our environment. It
has become clear that there are far better solutions available for dealing with residual
waste, and the technology is developing all the time. Given the pace of change we should
not be saddling ourselves with on old fashioned technology on the spurious defence that
however bad it is, it is 'tried and tested'. We should look at all possible solutions for waste
disposal, and not be restricted to those which the Private Finance Initiative is prepared to
fund.
An incinerator has to be fed to keep working at maximise efficiency, and that in itself
detracts from what we should be doing as a priority, reducing what we consume in the first
place and recycling more. The statements before Cabinet today from Alan Watson and
from Ethos clearly show there are better ways of dealing with waste than going down the
road to mass burn incineration.
Already Bath & NE Somerset Council has withdrawn from the PFI procurement, and many
other Councillors outside Bristol share the misgivings of a majority of Bristol Councillors
who have already expressed their opposition to incinerations at full Council.
The great Economist John Maynard Keynes said in a famous quote "When the facts
change, I change my mind. What do you do, sir?"
The evidence before Cabinet today clearly shows that the facts have indeed changed
since the outline business case was initially worked up. The assumptions on which there
report is predicated are open to question, especially in terms of the projected volume of
waste. We need locally based small and medium scale solutions for residual waste, not
large numbers of lorry movements to a huge incinerator to be inflicted on our citizens in
north west Bristol.
The proposal that has gone to DEFRA will be costly for the citizens of Bristol in both its
economic and financial impact for generations to come. We are on a slippery slope
towards mass burn incineration in Bristol, but have an opportunity tonight to halt this slide,
to change course, and to avoid large penalty costs for the people of Bristol when a future
administration in Bristol has to cancel this white elephant. Lets scrap the bid today, and
say 'no' to mass burn incineration in Bristol.
Steve Comer
Liberal Democrat City Councillor for Eastville
Cllr S Comer
C/o The Council House
Reply to
Telephone
Minicom
Fax
Email
Our Ref
Your Ref
Date
Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT A (3) 8
Statement from Cllr Brown to the 8th January Cabinet meeting in
connection with Agenda Item 3
When Full Council considered waste disposal and incineration last year, I
raised concerns, following the efforts of the Select Committee on Climate
Change to promote minimisation of carbon dioxide emissions, about the CO2
emissions that could result from the operation of a waste incineration plant of
the type being considered.
I note in the current report the statement that modelling has shown that “this
technology results in no net greenhouse gas emissions – the emissions of
CO2 are offset by savings in greenhouse gas emissions from conventional
energy generation displaced by the energy produced from the plant”. This
statement is too cryptic to be able to assess:•
•
•
•
•
what type of modelling parameters were used,
whether the model only deals with the action of the plant itself and not
the carbon dioxide generated by transporting waste from three widely
dispersed local authorities to a single central operation,
whether the efficiency of all “EfW with CHP” systems are identical to
“conventional energy generation” processes designed specifically for
this purpose,
what demand for CHP (necessary to achieve this carbon dioxide
balance) exists in the immediate area,
why the Council assumes that all future CHP generation will generate
identical carbon emissions to current equipment.
It is vague statements of this kind that continue to undermine the credibility of
the OBC and is precisely why it is vital to establish immediately an effective
all-party working arrangement to ensure that proposals are fully scrutinised in
advance, so as to minimise the risk of working towards solutions that may fail
to achieve the greatest efficiency of waste disposal, using all relevant
parameters.
Cllr D Brown
C/o The Council House
Reply to
Telephone
Minicom
Fax
Email
Our Ref
Your Ref
Date
Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATENEBT A(3) 9
10–12 Picton Street
Montpelier
Bristol
BS6 5QA
info@bristolfoe.org.uk
7 January 2009
Statement to Cabinet Meeting 8/1/09
on behalf of Bristol Friends of the Earth
In the light of the current economic downturn, the West of England Partnership needs to reassess
all of the financial assumptions made in the Joint Municipal Residual Waste Strategy and Phase 3
Outline Business Case. The waste volume projections are based on assumptions about the
development of urban extensions, on population growth and increasing prosperity. While these
may have seemed reasonable assumptions 6 months ago, work has now stopped on most housing
developments and people are buying less, with volumes of waste going down.
The speed of change in our economic circumstances serves to remind us how quickly circumstances
can also change in the waste industry. The very last thing we should be doing is tying in to the
longest-term, most inflexible contract imaginable. If the WoE goes ahead with pursuing
incineration – and incineration is what we will end up with if the WoE keeps an incinerator as the
reference project in its OBC, and does not actively rule out incineration as an acceptable option –
then we will not be able to adapt advantageously to future changes in the waste stream.
The Call-in panel identified a number of areas for further discussion:
2 (a) Making the tendering process open to a range of technologies
• The application, if approved in its current form, could be seen as undermining the work of the
newly formed Department of Energy and Climate Change (DECC) in that the proposal does not
contribute to ensuring energy is affordable (the waste is to cost some £100–£120 per tonne to
process, whereas the financial costs associated with composting and AD are considerably less).
Indeed the emerging worm MBT technology can actually yield a profit rather than representing a
net cost.
• An opportunity cost of granting approval for this application is to close the door on alternative
treatments, including AD and/or worm MBT (increasingly used as a less expensive and more
environmentally-friendly alternative to incineration in other European countries, e.g. Portugal).
• Additionally, waste incineration does not make a positive contribution to the DECC’s intention to
ensure energy security, as incinerators have been known to break down in the winter months,
resulting in hardship for householders and great expense for local authorities (e.g. problems with
Nottingham’s Eastcroft incinerator led to the failure of their district heating scheme and
expensive alternative measures were required).
2 (b) Carbon dioxide emissions targets
• The latest WoE WRATE assessment only compares incineration with/without CHP against landfill,
rather than comparing incineration against technologies that would have reduced climate change
impacts. This is not a reasonable comparison, as no one is suggesting that we stick with the status
quo. Studies by Eunomia have shown that MBT with stabilised residue sent to landfill offers the
best option in terms of climate change impacts.
• Insufficient weight is given to Planning Policy Statement 1 (PPS1) Supplement on climate change.
One is left with the incorrect impression that the Environment Agency will take primary
responsibility for ensuring compliance with climate change reduction commitments. This is
technically incorrect. PPS1 Supplement on Climate Change is a guide to material planning
considerations. Page 8, para 3 of PPS 1 states: “Addressing climate change is therefore the
Government’s principal concern for sustainable development”.
• Also from PPS1: “… applicants for planning permission should consider how well their proposals for
development contribute to the Government’s ambition of a low-carbon economy and how well adapted they
are for the expected effects of climate change. Applicants and planning authorities should bear in mind that
the policies in this PPS are capable of being material to decisions on planning applications… climate
change considerations should be integrated into all spatial planning concerns”.
• It will be for the Planning Authority (and ultimately the Secretary of State) to determine if the site
selection process maximised potential for heat usage (raising the obvious question – How will the
applicant identify suitable potential users for the heat when there is no suitable infrastructure in
place, and little demand for all-year-round heat?).
• It is incorrect to define energy from waste as renewable energy for planning purposes or when
interpreting the PPS on climate change.
2 (c) Recycling rates
• The Waste Framework directive establishes a new Waste Hierarchy that differentiates between
efficient and inefficient waste incinerators. Inefficient incinerators, i.e. those below 65% relative
efficiency (relative to convention energy generation) are classed as ‘disposal’ facilities, and are
positioned below landfill, as a worse option due to relatively high financial and social costs when
compared with landfill.
• See, for example, OECD 2007: OECD Working Group on Waste Prevention and Recycling,
ENV/EPOC/WGWPR (2005)4/FINAL, 2007. www.oecd.org/env/waste: “…environmental harm caused
by a modern landfill and a modern incineration plant are of a similar magnitude, while the costs of
building and operating an incinerator are much higher than the similar costs for a landfill. Hence, the total
costs to society as a whole of a modern incinerator seem significantly higher than for landfilling”.
• The May 2007 National Waste Strategy encourages Local Authorities to use anaerobic digestion
(AD) for biodegradable waste. This is based on recent research demonstrating “that anaerobic
digestion has significant environmental benefits over other options [including incineration]…” The
digestate produced by anaerobic digestion has a range of potential uses on land, including as a
fertiliser or soil improver. The building of a waste incinerator is bound to have a detrimental
impact on recycling and composting rates.
Health issues that have not been adequately taken into consideration
• The Environment Agency has confirmed that they are currently “still working to an enforcement
position that IBA [Incinerator Bottom Ash] is ‘non-hazardous’”. The Agency also confirms that there
“could be situations where the ecotoxic component in the IBA would lead to a HW [Hazardous Waste]
classification”. Whether IBA should be classed as non-hazardous or hazardous waste is currently
being debated between the Environment Agency and the Environmental Services Association and a
protocol is being developed by ESA members “to determine whether batches of IBA test as HW and,
where this occurs, what effect this will have on disposal arrangements”.
• The scientific literature has been reviewed for the evidence that IBA is likely to be eco-toxic. The
conclusions were that some, and perhaps most or all, bottom ash is likely to exceed the threshold
for the classification as Hazardous Waste under either the ‘H14-Ecotoxicity’ or the ‘H4-Irritant’
requirements. The data supplied by Veolia as part of their Environmental Permit application in
Nottinghamshire, for example, confirms that the expected bottom ash contamination exceeds the
threshold for hazardous waste.
• The difference between the bottom ash being either ‘non-hazardous’ or ‘hazardous’ is not a trivial
one. If the ash is, in whole or part, hazardous then it is doubtful whether the proposed treatment
facility would be permitted to receive it and the market as a secondary product is likely to be
dramatically reduced in any case. The chemical composition and the regulatory classification of
the ash produced by the proposed incinerator is fundamental to the possibility of re-use.
• The Environmental Protection Agency cites health studies indicating that particles smaller than
2.5 micrometers (PM2.5) are “the major contributor to serious health problems like respiratory
illness and premature mortality”.
• Whatever the technical details, everyone agrees that waste incinerators emit dangerous substances
– the debate is around how much is emitted, and how dangerous these emissions are. The fact that
research into incinerator emissions is still being conducted demonstrates that the scientific
knowledge is far from complete, and that uncertainties remain over safety. A recent study (Aboh,
et al. 2007) that looked into a medium sized city in southwestern Sweden, clearly identified their
new modern incinerator as the single most significant source of PM2.5’s.
• Another recent study (Mao, et al. 2007) found that the concentrations of PM2.5 and PM10 in the
study area located downwind of the incinerator were significantly higher (between 220% and
700% higher) than the study area upwind of the incinerator. The study indicated that the air had
“significant contamination by air pollutants emitted” from a waste incinerator, representing a public
health problem for nearby residents, despite the facility being equipped with a modern air
pollution control system.
• Many studies, old and new, show that communities all around the world, living close to
incinerators, even modern facilities, suffer higher rates of cancer and respiratory problems
(e.g. http://tinyurl.com/y7dteo). The recently released Paris Appeal Memorandum, supported by
the European Standing Committee of Doctors (representing 2 million doctors), urged a
moratorium on building any new incinerators
(www.artac.info/static.php?op=MemorandumParisAppeal.txt&npds=1).
• The Environment Select Committee notes: “concern about impacts of emissions from incinerators upon
human health” cannot be assuaged or dismissed while “emissions standards are based on what can be
measured and what is technologically achievable, rather than what is safe… Health effects which result
from an incinerator’s emissions are not yet fully known… Regulation of incineration to date has been
rather poor and that this has resulted in poor practices developing in some incinerators…” [House of
Commons (2001) Delivering Sustainable Waste Management].
• It is misleading to suggest “If LATS permits cost £60/tonne, the difference for Bristol is estimated at
£3.8m pa. This illustrates the need to reduce dependence on landfill.” as it does not reflect the current
collapse of the LATS market (where LATS Credits currently trade for less than £3 per tonne).
Jane Stevenson
Bristol Friends of the Earth
Jane Stevenson
By e.mail Janestevenson@madasafish.com
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Councillor Mark Bradshaw
0117 92 22879
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10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT A (3) 10
Please find below a statement that I wish to make to council on Thursday in respect of the
choice of phase 3 technology to realise the West of England Partnerships waste strategy.
The climate change bill became law in November 2008. The UK government committed all
large organisations to an overall reduction in carbon emissions of 80 % by 2050. This is a
very serious commitment and the choice of technology used to meet the needs of the
West of England partnerships waste should reflect this need. In is critical that any
technology selected for handling residual waste in phase 3 and 4 does not damage the
partnerships ability to achieve this cut in emissions.
A suitable technology needs to minimise the amount of carbon emission, be flexible
enough to cope with the potentially large changes this policy will cause in the waste
stream composition and volume and be efficient.
Long contract of say 28 years, starting in 2015 and end around 2043 are not likely to
associated with sufficient flexibility to deal with changes in either the waste stream or the
development of new technologies. Large contracts for 150,000 tpa are unlikely to be
flexible. Energy from Waste using incineration is a very inefficient energy production
process that releases carbon from plastics and wood which would otherwise be fixed
carbon, consequently the contribution to the UK energy budget in terms of carbon
intensity is utterly inadequate and likely to be rejected as a contribution by a future
government. This makes a large project of this nature a very risky option.
The proposal to make a CHP plant has failed to identify any serious users of heat in the
locality of the proposed EfW plant so it seems very unlikely that this aspect of the proposal
can be realised.
There are numerous objections to the proposed choice for phase 3 and I urge the council
to reappraise the options making a very careful risk analysis of all phase 3 proposals and
their relationship with future requirements imposed by the commitment embodied in the
climate change bill.
Dr A. Tubb
Dr A Tubb
By e.mail andy.tubb@uwe.ac.uk
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Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT A (3) 11
Submission to Bristol City Council Cabinet 8th January 2009 from Charlotte Leslie,
Prospective MP for Bristol North West
In reference to the call-in of the Cabinet decision I wish to formally record my continuing
concern about the Waste Strategy being pursued by Bristol City Council. Despite the
majority of Council members, including the Conservative Group, voting to register their
opposition to mass-burn incineration as the solution to Bristol’s waste issues this remains
in the Outline Business Case as the Reference Project. I believe that the City Council
should have been far more proactive and open to alternative solutions rather than
continuing to appear wedded to the concept of an incinerator as the solution.
I am also concerned that Avonmouth continues to appear to have already been chosen as
the site for such an incinerator, without any meaningful consultation with the local
community. . Labour does not have a mandate to progress the building of an incinerator,
or anything else, at Avonmouth. I believe that the Labour minority administration in
Bristol should not proceed with the development of an incinerator at Avonmouth. The
decision about which technology is chosen as the solution to Bristol’s waste will have
such an impact on the whole City for years to come that it should be informed by the
Council as a whole, after full and meaningful consultation with residents. I am deeply
concerned that the City Council, whether deliberately or not, is giving a clear impression
that it has decided upon an incinerator at Avonmouth and is merely going through the
pretence of an open process when in reality it has already made up its mind. The
comments in the report that there will be a, “stakeholder engagement day on 12th January
2009, regular Joint Scrutiny Committee meetings and local scrutiny arrangements” will
not be sufficient to allay local concerns. What the residents of Bristol North West expect
and deserve is for the City Council to clearly state how residents will be able to influence
the decision on which technology is adopted and crucially which location is chosen. This
must go beyond “scrutiny” within the Council to be a full a proper debate in which the
residents of Bristol are listened to and where an incinerator, or anything else, is not
imposed upon them against their wishes.
Charlotte Leslie
By e.mail charlotte@charlotteleslie.com
Reply to
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Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT A (3) 12
The Bristol Green Parties
Statement to the Bristol City Council Cabinet Meeting on Thursday 8th January 2009
Joint Waste Strategy Phase 3 - OBC
In the last couple of years The Green Party in Bristol has followed (and done its best to
influence) the development of the West of England's waste strategy. We have watched
while you gradually abandoned every 'green' objection to mass burn incineration, instead
adopting it as your reference project because your officers believe it is the most likely to
attract funding from the banks.
Now we're asking you to adopt the modest suggestions of the Call In Panel of the
Overview & Scrutiny Management Committee.
We, and others, have already put forward many reasons why mass burn incineration is
unacceptable. They include especially the inflexibility of the contract, the increasingly
probable impacts on recycling levels, the very dubious PFI financing, and the heightened
impact of incineration on greenhouse gas emissions. On all these things, mass burn
incineration compares badly with the alternatives. Not only that, but it appears
increasingly likely that the sole redeeming factor of the chosen reference project - the
provision of surplus heat to neighbouring customers - will not be realised. As Mr
Bradshaw is well aware ( Cabinet Q&A, November)1 this would seriously undermine the
financial viability of the plant, and leave any environmental credibility in tatters, as the West
of England gets stuck with the obligation to provide bulk waste to an outdated plant that
can't deal with efficiently.
Since all these arguments were put forward, and ignored in favour of the perceived good
judgement of the banking system (!), there have been more developments which really
should make you review your ideas. The farcical situation with the Hull and Newhaven
incinerators is mentioned in the reports.
At Wolverhampton2, they're desperately trying to find 30,000 tonnes of waste to import to
satisfy the appetitite of their incinerator; because if they fail, they'll be stuck with a bill of
£2.25 million for the shortfall.
Does our would-be 'Green capital' want to risk the same kind of embarrassment, because
it failed to anticipate the trend toward reduced residual household waste levels?
The report before you doesn't mention the 'penalty payments' risk that Wolverhampton is
experiencing - instead it talks of sky high LATS prices, presenting an intolerable risk that
must drive you toward incineration. That argument is doubly flawed; if the figures were
true, it might be a case AGAINST landfill, but that is not a case FOR incineration - and
anyway, if you've taken a look at recent LATS prices, you'll know that the figures are
nothing like those predicted by your officers - indeed many local authorities are writing off 3
their LATS "assets" as valueless.
Above all, though, you should remember that the majority of Council Members are
"opposed to a “feed the beast” mass burn incinerator". Those words were added, with
unopposed cross party support, to your decision4 at the Council's September meeting.
In conclusion, it is vitally important that you should, at this late stage,
* make sure that every alternative option remains open, none are excluded
* that the choice of technology gives proper weight to the importance of limiting CO2
emissions (as per PPS1 "Addressing climate change is therefore the Government's
principal concern for sustainable development") and weighs this against any factors it can
find that suggest incineration somehow adds to sustainable development.
* Make sure that there is representation from all parties (and that includes the Green Party)
when bids are evaluated
Peter Goodwin
on behalf of the Bristol Green Parties.
Sources:
1. Cabinet 27/11/2008, Public Forum Questions, pp40-41
http://www.bristol.gov.uk/committee/2008/ua/ua000/1127_1a.pdf
2. Report to Wolverhampton City Council, Cabinet, 3/6/2008 Para.4.2
http://decisionmaking.wolverhampton.gov.uk/CMISWebPublic/Binary.ashx?Document=119488
3. 'Letsrecyle' report, 28/7/2008
http://www.letsrecycle.com/do/ecco.py/view_item?listid=37&listcatid=326&listitemid=10241
4. Full Council, 9/9/2008, Minutes, p45
http://www.bristol.gov.uk/committee/2008/ta/ta000/0909_mins.pdf
Contact:
Peter Goodwin, 11 Lanesborough Rise, Stockwood, Bristol BS14 8AJ, Tel 01275
543280
Peter Goodwin
By e.mail greenpanda@blueyonder.co.uk
Reply to
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Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT A (3) 13
EPi Energy Statement for Bristol City Council Cabinet Meeting Thursday January 8th
January 7th 2009
This statement is an addendum to that provided in December for the Call-in Panel
Introduction to Environmental Power International ( UK ) Ltd
EPi is an energy technology company based in Wiltshire. EPi have developed a market leading pyrolysis
technology which will be operational on two sites in the south of England early in 2009. EPi are aiming for a
rapid roll out of plants across the UK from mid 2009 onwards.
Description of EPi Technology
The unique fast pyrolysis system developed by EPi produces two main outputs… Biogas and Biochar. The
process itself is entirely emission free. The Biogas is used to create substantial amounts of renewable
electricity whilst creating equal amounts of useable heat. The Biochar can be used for further energy
production or soil improvement / carbon sequestration.
A standard module processes 1 tonne of waste per hour or 8,000 tonnes per annum. A system comprising 5
modules capable of processing 40,000 tonnes per annum probably represents the highest level of financial
efficiency, but the technology is very scaleable. The company is currently investigating the development of
micro plants which could handle circa 300kg per hour. Even a five module plant can fit within an industrial
building of c 12,000 sq ft.
Further Comments over the West of England Waste Strategy
Our previous statement set out our general concerns over the strategy. Below we set out some specific
comments relating to the Call-in Panel’s points and the Officer responses thereto;
We are concerned about the costs and complexity of the PFI process, both from the point of view of the
public sector and the private sector bidders. In our view PFI is entirely justified for long term, capital intensive
projects, but our technology is more flexible and fundable entirely by EPi and our partners and can be up and
running within 6 months.
Flexibility and the potential to further enhance sustainability performance over the period of any contract
should also be valued appropriately.
We agree that it is very important that any process ensures that both large and small scale technologies are
given full and equal opportunities. Smaller companies that have developed scaleable technologies can of
course combine with larger companies to enhance credibility and financial security, but there is a danger that
this will add cost for the public sector, some of which may be unnecessary. We are not convinced that the
process envisaged will enable the Council to take advantage of scaleable solutions by trialing them in
advance of entering into larger, longer term commitments. We believe that this should be happening as part
of Phase 2 or even earlier.
The use of scaleable technologies provides the potential for selection of more than one technology enabling
later decisions about concentration towards the better performing solutions. A phased introduction of
technologies will greatly reduce risk to the public sector.
The potential benefits of EfW with CHP as compared to EfW without CHP are likely to be greatly reduced
with large centralized facilities. Heat is difficult to distribute and therefore lots of heat in one place is far less
valuable than heat in a range of locations.
We reiterate that EPi believe that waste should be considered as a very valuable resource and the
performance target must be way beyond carbon neutral. Such ambition is justified by technologies available
now-significant advances can be expected over the period covered by the four phases.
It is impossible to judge what changes there may be the gross amount of waste produced in the first instance
or its reduction through recycling over the period in question. The Councils should be seeking to avoid
commitment to provide unnecessarily high volumes of waste to a contractor; reward should be provided to
those who can work with reducing quantum over the period of contract.
In summary, we remain concerned that the Council could be progressing down a route which is inflexible,
sets a course for 25-30 years and which does not allow the state of the art, emerging technologies to be
utilised. This would put the Council at a significant disadvantage in respect of meeting climate change
commitments and achieving the desired status of Green Capital.
We would like to make a public statement at Thursday’s meeting and will be happy to provide any further
information that may be helpful to the Council.
Mike Roberts
Mike Roberts
By e.mail mike@vertigosdc.com
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Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT A (3) 14
Statement to Cabinet 8th Jan 09 from Cllr Gary Hopkins
For many years Bristol’s record on waste was a shameful one. Since the
forced closure of the Avonmouth incinerator because of pollution standards
nothing had been done to clean up the mess.
In May 2005 we inherited an authority sending 88% of its waste to distant
landfill and a rusting hulk that you couldn’t even be bothered to clean up.
We passed back to you in May 2007 one of the most improved councils in the
country in waste and recycling and one working closely with its 3 neighbours
towards an effective modern solution to our residual waste disposal issues.
In 18 months we have seen:
- An expensive Citizens’ Jury that had the good sense to reject your plans and
endorse our solutions and plans. The report has been buried.
- Zero further progress on recycling.
- The partial break up of the West of England waste partnership due to the
incinerator/PFI.
- The wasting of millions of pounds on lawyers and consultants fees with zero
results.
- The attempted misleading of Cllrs and public about the outcome of your
policies. The layers of the onion of failure have been gradually peeled away
and the final collapse is at hand.
- You stated that you were doing everything you could to progress the Ethos
plant at Avonmouth so that a fair choice could be made.
The reality is that you told them and the public one thing and did another.
DEFRA funding was lost and this council will now face the serious possibility
of a major compensation claim. Even if this is successfully defended you have
passed up a golden opportunity to have our waste treated locally, cheaply and
in an environmentally friendly manner with zero public investment because
you preferred to go on landfilling.
- You stated that there was no bias in this system but several submissions
show this to be untrue.
- You stated that the PFI route was cheaper but only did comparisons with
landfill.
In fact the technology that your consultation was based on has been shown to
be so questionable from an environmental point of view that the Environment
Agency was forced by the High Court to withdraw operating licenses.
Although the Pyrolysis technology is capable of operating efficiently at smaller
scale which incineration is not it can be scaled up. In their statement Ethos
refer to a 160,000 ton facility that they have just quoted £40m to supply. How
does this compare with your incinerator PFI.
You have arrogantly carried on over the last 18 months digging an ever bigger
hole, refusing to work with others, wasting millions of pounds of taxpayers
money and looking resolutely to the past for your solutions.
- You stated that the PFI transferred the risk the private sector. This is
entirely untrue as the excellent work of Norman Baker shows.
In addition with new and more efficient systems coming in gate fees projected
to reduce just as you want to tie Bristol taxpayers into a high cost 25 year
deal. Paying by the ton gives the maximum flexibility and allows us to benefit
from progress.
- You said that Mass Burn incineration was reliable and that ATT was not.
The Allington experience should be enough but within the next few weeks a
case starts in Bristol courts of a Welsh local authority suing the advisors who
led them into an incinerator fiasco. ATT is being delivered without public
subsidy in this country now. Incinerators demand huge public subsidy.
- The written response to the parts made by the call in would be laughable if
they did not, as they do, encourage you to go on wasting taxpayers money.
It is very clear that after the change in administration in May 2007 objective
analysis was thrown completely out of the window and instead paper thin
justification for a predetermined course of building a huge incinerator have
been trotted out. Quite a number of people were fooled at first but that
number is decreasing rapidly and as the short but forensic dissection by Alan
Watson shows THE EMPEROR HAS NO CLOTHES.
- The inheritance that you will leave us when you are thrown out of office in
June this year is immeasurably worse than it should and could have been.
You even refused pro-bono consultancy advice from Eunomia who are Bristol
based are one of the countries leading waste advisors. The incinerator will
not be built and it is vanishingly unlikely that anything can be rescued from
this PFI shambles that would produce anything useful for Bristol taxpayers. I
would urge you therefore to stop digging and refrain from trying to tie the
hands of a future administration with contracts that you know will not and
should not be delivered.
enc:
Appendix 1: R (HOTI) v Environment Agency (Hull Incinerator)
Appendix 2: Biogenic Carbon
Appendix 3: Newark & Sherwood District Council Planning Officer's report on
proposed incinerator
Appendix 4: Letter from DEFRA dated 17 September 2008
Appendix 5: Letter from DEFRA dated 30 May 2008
Appendix 6: A salutary lesson from Sussex
Appendix 7: Email from Patrick McConville of Energos
Note on Appendices 2 and 3. These expert documents have not been
customised for Bristol because the administration has refused the small
amount of funding required for this process but the lessons are important and
wideranging.
COMMERCIAL LAW - COMMON LAW - ENVIRONMENTAL & PLANNING - PUBLIC LAW - CASE ARCHIVE HOME > CASES > ENVIRONMENTAL & PLANNING >
Richard Wilmot-Smith QC
Matthew Horton QC
Nigel Pleming QC
William Norris QC
Robert Jay QC
Richard Clayton QC
Neil Block QC
Alison Foster QC
Stuart Catchpole QC
Colin McCaul QC
Jeremy Morgan QC
Adrian Hughes QC
John Pugh-Smith
Martin Edwards
Stephen Tromans
Gordon Nardell
Charles Manzoni
Richard Harwood
Justine Thornton
Christiaan Zwart
Richard Wald
Vikram Sachdeva
Nicola Greaney
Colin Thomann
Karim Ghaly
James Burton
Alexander Ruck Keene
Rory Dunlop
Christopher Staker
Caroline Allen
Victoria Butler-Cole
R (HOTI) v Environment Agency (Hull incinerator)
Date: 11 Jul 2008
Chambers Members Involved:
Richard Harwood
In February 2008 the Environment Agency revoked the Pollution Prevention and
Control permit (“PPC permit) of a proposed 240,000 tonnes Energy from Waste facility
at Saltend in Hull on climate change grounds.
The Agency decided to revoke the PPC permit ‘in its entirety’ following a judicial
review pre-action protocol letter on behalf of Hull and Holderness Opposing the
Incinerator (“HOTI”). As the operator had not said whether it intended to appeal
before the three month judicial review period expired, judicial review proceedings
were commenced on 30th January to quash the permit.
The Agency’s reasons for revocation are:
“The Agency has reviewed the determination process which led to the grant of the
Permit and is of the opinion that it should revoke the Permit under regulation 21,
because the conclusion that a moving grate type of furnace represented the Best
Available Technique for burning wastes involved was not adequately supported by the
evidence, particularly in relation to emissions of carbon dioxide and global warming
potential, in breach of regulations 11(2) and 12(2) and (8) of the PPC Regulations.
In light of a legal challenge by a third party to the grant of the Permit, the Agency has
determined that revocation of the permit and the fresh determination of an application
made under regulation 10 of the PPC Regulations is the appropriate course of action.”
The decision follows the quashing of a PPC permit for the proposed municipal waste
incinerator at Newhaven by the High Court on 5th December 2007 in
R (Day) v
Environment Agency on similar grounds.
The operator decided not to appeal. As the permit no longer existed it was agreed that
the judicial review claim would be withdrawn and written submissions made to
determine costs.
On 11th July Mr Justice Bean ordered the Environment Agency to pay HOTI’s costs. He
observed on the principle of costs:
“The Claimant is entitled to an order for costs. By mid-December 2007, if not before,
it was (or should have been) clear to the Defendant that the Saltend permit could not
stand. The Christmas period does create difficulties for litigators but it does not stop
time running for the purpose of the 3 month time limit.
When on 25 January 2008 the Defendant finally agreed to revoke the permit the
Claimant was nevertheless justified in issuing proceedings just before the 3 month
time limit expired since otherwise WRG might appeal against the decision to revoke,
leaving the Claimant at a significant disadvantage.”
Richard Harwood acted for HOTI and appeared for Mrs Day in the Newhaven case. Phil
Michaels of the Friends of the Earth Justice & Rights Centre is instructing on Hull and
John Dunkley of Earthrights was the instructing solicitor on the Newhaven case.
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Biogenic Carbon
1. Whether or not special consideration should be given to biogenic carbon
there is another basic error in the assessment has been made. This is that
the basis of the waste analysis is for total waste arisings before any
recycling or other treatments rather than on the residual waste which
would be fed into the incinerator. This makes a very significant difference
as much of the paper and card will (or should) have been removed for
recycling.
2. The XXX assessment in the application therefore dramatically over states
the level of biogenic carbon the waste that would be incinerated.
3. XXX then uses a rather obscure methodology, presented in Table 1, to
establish the proportion of “Dissimilable Degradable Organic Carbon” 1 in the
waste. The report does not, however, present any readily comparable
output against which the assumptions on he biogenic proportion of the
waste can be assessed.
4. To resolve this concern we have considered the assessment in the light of
the 2007 consultation (Department of Trade and Industry 2007) on the
review of the Renewables obligation. The Government response to the
submissions to the consultation was published in January 2008 (BERR
2008) and said :
Deeming the biomass fraction of waste: we will proceed with the
introduction of deeming, but will begin with a lower deemed level of 50%
fossil fuel energy content that will increase over time to 65% following a
trajectory in line with the Government’s waste policy 2 .
And warns:
5.9 Ofgem will be given powers to withhold ROCs for mixed waste streams
where there is reasonable doubt that the biomass energy content reaches the
deemed level. This is consistent with the approach currently used under the
scheme for issuing Climate Change Levy Exemption Certificates. It should be
noted that lowering the deemed level of fossil-fuel energy from 65% to 50% is
likely to increase the risk for some stations that a test of reasonable doubt will
be met.
5. This consultation and response provide a more robust approach than that
proposed by XXX because it considers the carbon levels in the waste that
This is the fraction of the Degradable organic carbon content ‘DOC’ that dissimilates (i.e.
mineralises) to CO2 and/or CH4. DOC is the fraction of the waste made up of biodegradable
carbon;
1
There is the possibility of producing evidence of different waste analysis but this must be
well founded and evidence based: We will allow operators the opportunity to present Ofgem with
evidence that the fossil fuel content is lower than the deemed level and look to make the fuel
measurement system more flexible.
2
would be burned after the removal of the recyclables that the Government
clearly considers should be taken out. Thus at least 50%, rising to 65%, of
the waste that would be burned in this incinerator would be as classed
fossil based in any case.
6. To test the assumptions that have been made in the application the
Governments assumptions about calorific values have been used with the
waste analysis presented in the Xxxxxx ES 3 :
Although even the basic waste analysis data is not locally derived – it is sourced from the
WRATE model and the default data is understood to be a Welsh waste dataset.
3
7. As not all categories precisely match between the tables minor alterations
have been made to the calorific value to address any differences (an
average of the biodegradable and green waste has been used in this table;
and similarly for the high levels of ‘other or ‘miscellaneous’ combustibles
assumed by XXX).
8. This shows that the XXX assumptions are similar to those in the original
consultation for the whole waste stream with c 63% of the energy from
biogenic material. In order to reflect the reduction of the biogenic element
to between 30 and 38% of the post recycling waste stream the carbon
dioxide emissions in the XXX assessment attributed to fossil carbon need
to be approximately doubled.
Failure to properly take into account the Biogenic Emissions
9. XXX say, “ biogenic emissions are considered to be from biomass sources and are
therefore treated, like biomass renewables, as having a zero carbon emissions
factor”. I will return to the incorrect claim that biomass renewables are
treated as having a zero emission factor below. The explanation to justify
ignoring the biogenic emissions is given at Para 2.27 as being “consistent
with international guidelines”. The basis for this claim is seen in Box 1
where XXX claim “Intergovernmental Panel on Climate Change guidelines on
greenhouse gas assessment and reporting stipulate that biogenic emissions of
carbon should not be included in the assessment of emissions from waste”.
10. Whilst this statement is strictly true it is incomplete and, in this context is
seriously misleading. A more comprehensive and relevant version of the
IPCC approach can be seen in their 2006 review on waste (IPCC 2006),
says:
“…if incineration of waste is used for energy purposes both fossil and
biogenic CO2 emissions should be estimated. Only fossil CO2 should be
included in national emissions under Energy Sector while biogenic CO2
should be reported as an information item also in the Energy Sector.”
11. The Rufford incinerator is clearly proposed to be used for energy purposes
and so the inference that the IPCC approach justifies ignoring emissions
from biogenic carbon is misguided. IPCC instead requires that they
should be allocated to another sector to assist with the rational integration
of the national inventories. If there was no energy recovery but the
biogenic material was undergoing a net decline then it should be reported
to the Agriculture, Forestry and Other Land Use sectors as the guidance
continues 4 :
“Moreover, if combustion, or any other factor, is causing long term decline in the
total carbon embodied in living biomass (e.g., forests), this net release of carbon
should be evident in the calculation of CO2 emissions described in the
Agriculture, Forestry and Other Land Use (AFOLU) Volume of the 2006
Guidelines.”
12. Emissions from biogenic carbon are claimed (Para 2.27) to be “estimated but
not reported”. These estimates should, as a minimum, have been included
in the submissions for checking and consideration by others as part of the
Environmental Assessment process. The appropriateness of this approach
has recently been confirmed in a strongly worded editorial by Ari Rabl in
the International Journal of Life Cycle Assessment (Rabl, Benoist et al.
2007):
“In a part of the LCA community, a special convention has been established
according to which CO2 emissions need not be counted if emitted by biomass. For
4
See also [1] http://www.ipcc-nggip.iges.or.jp/faq/faq.html
Q54. How should we treat CO2 emissions from waste incineration, where the waste is of
mixed biogenic and non-biogenic material?
A: Distinctions between carbon of biogenic and non-biogenic origins have to be made,
because any net changes in carbon stock of biogenic origin is already covered in the AFOLU
Sector. The method to estimate the non-biogenic carbon fraction is described in Sections 2.3
and 5.4.1.2. of the Waste Volume of the 2006 Guidelines.
In the absence of energy recovery by the incineration of waste, CO2 emissions from the
incineration of non-biogenic carbon in the waste are considered as net emissions and reported
under the Waste Sector while those of biogenic carbon in the waste should not be included in
national total.
Where the incineration of waste is used for obtaining energy, CO2 emissions from nonbiogenic carbon need to be reported under the Energy Sector. Emissions from biogenic carbon
should be reported as information items under the Energy Sector, hence, not included in the
national total.
example, many studies on waste incineration do not take into account CO2 from
biomass within the incinerated waste, arguing that the creation of biomass has
removed as much CO2 as is emitted during its combustion”.
13. “The logic of such a practice “ he continues:
“would imply absurd conclusions, e.g. that the CO2 emitted by burning a
tropical forest, if not counted, would equalize the climate impact of burning a
forest and preserving it, which is obviously wrong. Likewise, the benefit of adding
carbon capture and sequestration (CCS) to a biomass fuelled power plant would
not be evaluated because that CO2 is totally omitted from the analysis. ”
14. Amongst the advantages of including biogenic carbon emissions, Rabl
says, are that:
“By explicitly counting CO2 at each stage, the analysis is consistent with the
'polluter pays' principle and the Kyoto rules which imply that each greenhouse
gas contribution (positive or negative) should be allocated to the causing agent”.
15. The further claim by XXX that biogenic emissions “like biomass renewables,
as having a zero carbon emissions factor” is also not valid. It would not be
enough to show that any material being burned was biogenic for this to be
true. Paper, for example, requires far more energy to process than pure
bio-mass and the savings in recycling materials are thus often far greater
than can be recovered from them as energy. This can be seen in table A38
of Waste Strategy 2007 (DEFRA 2007):
16. This shows that in almost every case the savings from recycling are far
higher than from energy from waste. The embodied energy is higher still
showing the importance of waste reduction and demonstrating that even
recycling is only a partial solution, albeit much better than energy from
waste.
17. It is also clear from the current debates about the climate change impacts
of bio-fuels that simply growing material to be used for combustion is not
a climate neutral option. Fertilisers used for plant growth release N2O
(Crutzen, Mosier et al. 2007) and the climate balance of some bio-fuels is
strongly negative (i.e. it is actually worse to burn them than fossil fuels)
(Fargione, Hill et al. 2008).
18. The National Assembly for Wales consultation on Renewable Energy
(Welsh Assembly Government 2008) says:
6.6 Levels of energy from waste above 30-35% begin to have a negative carbon
balance as they involve combustion of energy-intensive materials that are better
recycled.
Unreasonable comparisons with alternative technologies designed
to favour this proposal
19. The majority of the assumptions made in the report tend to favour
incineration on the proposed site rather than the alternative technologies
which may be available.
20. AEAT work for the EU (AEA Technology, Smith et al. 2001) concluded
that:
“The issue of the source of displaced energy is critical to the performance of
incineration in terms of net greenhouse gas flux…..The greater the CO2 emission
factor of the replaced generation source, the greater the emission saved due to its
replacement by incineration.”
21. Displaced electricity is assumed to be the average UK mix with a claimed
carbon emission of 520 g/kWh. This is a high assumption factor which
favours incineration. Other recent studies (Eunomia Research &
Consulting and EnviroCentre 2008) have used a displaced emission factor
of 447 g/kWh with assumptions that future displaced electricity will be
lower carbon:
22. Similar results were reported in the AEA study for the EC (AEA
Technology, Smith et al. 2001):
23. The reason that XXX have so much higher carbon intensity is because they
have calculated the emissions based on coal, oil and gas but have simply
ignored the low/zero carbon contribution made by nuclear and
renewables in their calculations. They say:
“the total CO2 was divided by the total electricity supplied (including Nuclear
and renewables) to provide the composite emissions factor”
24. This is not what they have done, however, and the 520 g/kWh is based on
339,350 GWh electrical output which is just 78% of the UK electricity
production. They have, however, used the total output of 176,542,193
tonnes of carbon dioxide to calculate the average emission factor
(176,542,193/339,350,000 = 520 g/kWh). The correct factor for the average
for the total emissions is the total electrical output which for 2006 was
394,971 5 . This the corrected calculation would be:
176,542,193/339,350,000 = 447 g/kWh
25. This is the same as the carbon intensities cited by other authors cited
above.
26. As a sensitivity test “the long-term projected emissions factor of 0.43
kgCO2/kWh was also applied” claims the review. Not only is this figure too
high for the same reasons as explained above but no results are reported
with the lower long term emission factor in any case. A more appropriate
sensitivity test would be on the basis of an average emission factor of 0.38
kg/kWh for 2020.
27. Even this may still be too high. Recent literature has suggested that zero
(or close to zero) carbon displacement should be assumed in the light of
the carbon cap on European emissions (Finnveden 2008). These
assumptions would have a dramatic effect in reducing the apparent
benefits associated with incineration.
28. All waste management processes require energy to operate (a “parasitic
load”). It is not clear that this has been taken into account as, unlike in
some of the other work by XXX, it is not specified.
29. The capture rate for methane of 50%, attributed to IPCC, may be valid as a
global average but it is rather low for a modern landfill in the UK which is
the likely landfill alternative in this case. Spokas (Spokas, Bogner et al.
2006) reviewed this issue recently for the French Government. Total CH4
recovery for the sites with active gas recovery ranged from 41% to 94% of
the theoretical modelled CH4 production. Thus a 50% capture rate is at the
lower end of the range.
30. Furthermore as a result of those studies guidelines by the French
environment agency (ADEME) for default values for percent recovery
have been set at: 35% for an operating cell with an active landfill gas (LFG)
recovery system, 65% for a temporary covered cell with an active LFG
recovery system, 85% for a cell with clay final cover and active LFG
recovery, and 90% for a cell with a geomembrane final cover and active
LFG recovery. UK performance after the initial landfilling is likely to be
similar to the higher capture rates in cells with geomembranes and active
LFG recovery.
31. It is also assumed that all carbon for landfill and alternatives is released
instantly. This assumption is incorrect and strongly favours incineration.
The timing of releases is actually very important as a climate change
abatement measure and whilst incineration obviously releases carbon
dioxide and other greenhouse gases immediately this is not normally the
case for other technologies which generally have a slower release with a
DUKES Table 5.2 2006
http://www.berr.gov.uk/whatwedo/energy/statistics/source/electricity/page18527.html
5
subsequently softer impact on climate change. Favoino (Favoino and
Hogg 2008) examined this in relation to compost and wrote:
“Typically, life-cycle analyses (LCAs) exhibit limitations related to assessing the
effects of ‘time-limited’ carbon sequestration in soils. This has tended to obscure
the potentially important effect of composting, in which biogenic carbon is held in
soils for a period of time before the carbon is released”.
32. The assumptions made in this report are different in some important
regards to the similar report prepared by XXX for Viridor in Exeter. These
differences invariably favour incineration over alternatives
Rufford Carbon Analysis Report
Para 2.19 “CH4 oxidation to CO2
by microbes is not assumed in this
assessment” (Einola, Sormunen et
al. 2008; Huber-Humer, Gebert et
al. 2008) 6
Exeter Carbon Analysis
Para 2.19 “CH4 oxidation to CO2
by microbes is 10%”
2.30 It is also possible to avoid
emissions through the sale of the
combustion residues to the construction
industry, again avoiding the need to
consume resources in the
production of virgin materials. For this
assessment it has been assumed that all
suitable residues will be transported
and utilised at a facility approximately
30 km from the site.
2.29 It is also possible to avoid
emissions through the sale of the
combustion residues to the construction
industry, again avoiding the need to
consume resources in the production of
virgin materials. In practice, however,
markets for such materials are difficult
to secure and are piecemeal. For this
assessment it has been assumed that all
residues will be transported and
disposed of at the landfill site.
No non-ferrous metal recovery
assumed.
2.29 It is assumed that …. non-ferrous
metals are recovered at an efficiency of
35% of the input.
33. It is notable that no explanation is given for these changes but they all
favour an incineration based option compared with landfill or MBT.
Costs and Contracts:
34. The most recent information published by WRAP comparing the costs of
waste treatment options (Waste Resources Action Program (WRAP) 2008)
Einola et al. show that MBT stabilate can play a particularly useful role in reducing
landfill emissions of methane by providing an oxidizing medium when used as landfill
cover – thus undermining the arguments presented by XXX in relation to the difficulties
of MBT stabilate disposal. Spokas reports, “Total methane oxidation rates ranged from 4% to
50% of the methane flux through the cover at sites with positive emissions. Oxidation of
atmospheric methane was occurring in vegetated soils above a geomembrane”.
6
indicates that the costs of the environmentally preferable options are
actually lower than for incineration.
35. Mechanical Biological Treatment (‘MBT’) is assessed with a median cost of
£ 53/tonne whilst incineration has a median cost of £ 80/tonne with a
range from £ 65 to £ 136.
36. Waste Strategy 2007 emphasises that recycling should be maximised
before consideration of the alternatives lower down the hierarchy. This
was the approach emphasised it the evidence given by Neil Thornton,
Director, Environment Quality and Waste, Department for Environment,
Food and Rural Affairs to the Public Accounts Committee (House of
Commons Committee of Public Accounts 2007):
“We are equally clear and positively clear that we want recycling done first;
maximum recycling, maximum reduction and composting and then considering
recovering energy from waste”.
37. Recycling, he said, would be favoured over incineration “because it would
be cheaper”. The danger, of course, if that large incinerators such as this
one result in contractual ‘lock-in’ where waste must be supplied to the
incinerator or penalties paid. This results in significant market distortion
due to the waste contracts. In this case the contract, which has a major
influence on many aspects of this proposal, including the requirements for
minimum waste quantities, and the areas from which waste would be
sourced, is not in the public domain. It is important that this contract,
which has never been subject to public scrutiny or consultation, does not
usurp the more open and democratic land-use planning regime. It is
therefore recommended that in the event of planning permission being
recommended strict conditions should be attached requiring that wastes
incinerated should be as described in the application and environmental
statement. A condition should also be attached requiring that only
proximate waste should be incinerated in accordance with the Waste
Framework Directive requirement to dispose of waste at the “nearest
appropriate installation".
38. Much higher levels of recycling than are currently proposed as part of this
scheme (70% + rather than the current long-term goal of c 50%) will also
be cost effective and have a much higher environmental benefit than
incineration. Both the higher environmental benefits and the lower costs
have been demonstrated in the recent publications of the National
Assembly for Wales (National Assembly for Wales 2007). This shows that
recycling 80% of municipal waste will actually be more cost effective than
recycling just 60%.
39. The proposed option is likely to be significantly more expensive (a higher
“private cost”) than both recycling and MBT alternatives. Cost cannot
therefore reasonably be argued to be a barrier to the implementation of the
environmentally preferable options.
Recovery or Disposal?:
40. The primary purpose of this incinerator is waste disposal and not the
generation of electricity.
41. In the 2002 decision of the European Court of Justice on the case C-458/00,
the Commission of the European Communities versus the Grand Duchy of
Luxemburg (European Court of Justice 2002). Advocate General Jacobs
determined that the primary objective of incineration in a dedicated
municipal waste incinerator is waste disposal. The Court added that even
if, as a secondary effect of the process, energy is generated and used, this
classification as a disposal operation remains the same. The generation of
electricity, whether purported to be renewable or otherwise, is therefore a
secondary function.
42. This is, in any case, supported by the economic position. The capital cost
of an EfW plant is very much greater than that of a conventional electricity
generating station of the same capacity (AEA for DTI 2005) and this is due
to two main factors;
•
•
the low energy density of MSW compared with other renewable fuels (and
even more so compared with conventional fossil hydrocarbon fuels)
necessitating physically much larger plant,
the need for advanced pollution control equipment fitted to the plant and the
costs of safe disposal of ash and other residues.
43. Although the recent revisions 7 , just approved by the European Council, of
the Waste Framework Directive, so make provision for incinerators to be
classified as recovery operations rather than as disposal technologies there
is little evidence that that will make much impact in practice in the UK.
ENDs reports (ENDS 2006), for example:
“But in the UK only one plant would meet the criteria, according to a DEFRA
official. This is assumed to be Xxxxxx’s Sheffield incinerator which, thanks to a
district heating scheme, would score a 61% efficiency rating, although ENDS
could find no-one in the industry prepared to confirm this, nor would the
Environment Agency”.
44. Even 61% would be too low for a new incinerator to be classed as recovery
(which requires 65%). To match that level would require that the Rufford
proposal have an efficiency approximately equal to Scenario 4 (“this option
provides a combined efficiency similar to that achieved at the Sheffield CHP”).
This is completely unrealistic given the lack of a suitable heat load at the
proposed location.
45. It should be noted that the efficiencies quoted in the revised Directive are
not thermal efficiencies but relate to factors based on equivalence with
other generation plant.
7
http://register.consilium.europa.eu/pdf/en/08/st03/st03646.en08.pdf
Generating Efficiency:
46. Incinerators are particularly inefficient generators of electricity. This can
be improved by operation combined heat and power (“CHP”) plants but,
if this is to be meaningful and effective, this requires a large heat load.
Only in those circumstances, as can be seen below, is incineration likely to
move up the waste hierarchy above landfill.
47. Following the 2006 Energy Review, the Government announced a number
of proposals for changes to the Renewables Obligation (RO). These
changes would provide differentiated support levels to different
renewables technologies and give additional certainty on long-term
Renewable Obligation Certificate prices. These changes to the RO will
require new primary legislation and so will not be introduced until
towards the end of this decade at the earliest.
48. The proposal is clearly not advanced thermal technology nor can it be
expected to meet the criteria for ‘good quality’ CHP. Xxxxxx have
demonstrated that they are prepared to promote incinerators in the UK
with exaggerated claims about intentions to deliver CHP at the planning
stage which have not subsequently been delivered in practice. Their
incorrectly named SELCHP (‘South East London Combined Heat and
Power’) which is not a CHP plant, and looks increasingly unlikely to ever
become one, is a case in point.
Combined Heat and Power (‘CHP’):
49. It has long been recognised in assessments of waste management and
climate change that CHP is vital to even moderate performance by energy
from waste plants. Work by AEA Technology for the European
Commission (Smith, Brown et al. 2001) emphasised the importance of
CHP to even ‘tip the balance’ in making incineration beneficial in climate
change terms:
For a tonne of whole waste, it is clear that landfill is the worst option, followed by
incineration without energy recovery. Incineration with energy recovery provides
net benefits due to the displacement of fossil fuels in the energy system. With
energy recovery as electricity only, the benefits of energy recovery only just cancel
out the direct greenhouse gas emissions from waste combustion, but with CHP
there is a significant net benefit.
50. The recent BERR Consultation on Heat (BERR 2008) Para 80, page 37 says:
“Where there is no environmental or economic case for recycling, recovering
energy from waste can make an important contribution to a well balanced energy
policy. The fraction of the waste fuel that is bio-degradable is classed as a
renewable fuel. By 2020 it is estimated that 25% of England’s municipal waste
and around 6% of commercial and industrial waste will need to be dealt with
through energy recovery”
51. In this case it has been demonstrated that there is both an economic and
environmental case for recycling more of the material that is proposed to
be burned.
52. If, however, it was accepted that some waste was to be incinerated as part of an
energy policy, then energy would obviously have to be recovered as efficiently as
possible.
53. The Waste Incineration Directive (European Commission 2000) says:
Article 4 (2)(b):
(b) the heat generated during the incineration and co-incineration process is
recovered as far as practicable e.g. through combined heat and power, the
generating of process steam or district heating;
Article 6 (6):
6. Any heat generated by the incineration or the co-incineration process shall
be recovered as far as practicable.
54. Whilst the Environment Agency is the body normally responsible for the
implementing the “Waste Incineration (England and Wales) Regulations 2002”
(HMSO 2002) the locational requirements for CHP can only be secured at the
planning stage and should be addressed as part of this decision.
55. We note also that DEFRA's Outline Business Case template for PFIs (Department
for Environment Food and Rural Affairs (DEFRA) 2008) says:
Combined Heat and Power (CHP) solutions are typically the most efficient
outcomes giving a significant climate change benefit.
56. WS 2007 delivers a similar message:
116. The Government, while not generally expressing a preference for one
type of technology over another for EfW, does believe that any given
technology is (where applicable) more beneficial if both heat and electricity
can be recovered. The strategy therefore states that particular attention
should be given to the siting of plant to maximise opportunities for CHP.
Greenhouse gas emissions should be an important criterion for stakeholders
developing EfW plant. Some indications of typical emissions patterns are
given in the summary guidance, but these will, of course, vary from location to
location according to local transport links ,etc.
57. In a 2005 report for DEFRA on extending the Renewable Obligation to
include energy from waste with CHP ILEX consulting wrote:
We estimate that EfW with CHP will produce a net environmental gain, producing
additional carbon savings beyond that from electricity-only EfW plant – of
between 120 kgCO2 and 380kgCO2 for each MWhth of heat produced.
58. They thus estimated that:
“ a 400kt/yr EfW with CHP facility would create additional carbon savings of
between 0.7 and 1.0 million tonne 8 s of carbon dioxide (CO2) in total over a 20year lifetime, over and above those achieved by a conventional EfW facility
without CHP.”
59. Without CHP the benefits are substantially reduced. The graph below,
from research by Eunomia (Hogg and Eunomia Research & Consulting
Ltd 2006) for Friends of the Earth shows how electricity only incinerators
produce about twice as much carbon dioxide per kWh as coal fired power
stations.
60. For completeness it should be noted that this graph includes biogenic
carbon. This is the appropriate approach to adopt when accounting for
incinerator emissions as described above. The applicants and ERM have
ignored this element of the emissions claiming that it is ‘climate neutral’
but that would only be valid in an incineration life cycle assessment if the
climate change impacts of a biogenic carbon dioxide molecule was
different from any other carbon dioxide molecule.
61. Even if biogenic carbon is excluded most incinerators still produce more
carbon dioxide per unit of electricity than gas fired power stations:
Additional net carbon savings assumed for the upper bound a plant operating at 20MWth
capacity producing 125GWhth per annum, at a net saving of 380kgCO2/MWhth. For the
lower bound ILEX assumed a plant operating at 45MWth capacity producing 280GWhth per
annum at a net carbon saving of 120kgCO2/MWhth.
8
62. Incinerators that utilise the heat effectively for district heating or CHP can
be marginally more efficient in carbon dioxide terms than combined cycle
gas turbines power generation.
63. The location chosen for the proposal is, however, fundamentally
unsuitable for good quality CHP. The carbon Analysis says:
“An ERF with CHP requires either a residential or industrial outlet for the heat
and this is difficult to deliver unless local infrastructure is in place”.
64. Emphasising the importance of appropriate site selection for facilities with
large quantities of waste heat. The weighting given to proximity to an
adequate heat load was clearly not rated high enough to reflect the
environmental and legislative requirements for efficient use of energy and
minimisation of carbon footprint in the selection criteria.
65. Even with good quality CHP the current configuration would be one of
the worst solution to residual waste treatment in climate change terms.
(Hogg and Eunomia Research & Consulting Ltd 2006; ENDS 2008):
66. This shows the higher carbon costs associated with thermal treatment
when compared with the options of MBT with stabilised output to landfill.
The best solution assessed in this study has not even been considered in
the application as alternative options for this site.
67. Additional recycling – which is shown above to be practical for at least
30% more of the waste stream than has been assumed in the application is
a far more effective way of addressing the challenges of climate change.
68. A recent report by the UK Government sponsored Waste Resources
Action Programme ‘WRAP’ (Wenzel 2006) concluded:
“Further analysis by WRAP of the research findings has provided an assessment
of the relative greenhouse gas savings associated with current UK levels of
recycling for paper/cardboard, glass, plastics, aluminium and steel.
Again, the results are clear and positive. The UK’s current recycling of those
materials saves between 10-15 million tonnes of CO2 equivalents per year
compared to applying the current mix of landfill and incineration with energy
recovery to the same materials. This is equivalent to about 10% of the annual
CO2 emissions from the transport sector, and equates to taking 3.5 million cars
off UK roads.”
69. It is shown above in the carbon dioxide modelling for the National
Assembly for Wales that this additional recovery has a strong positive
climate change benefit whilst the incineration element always produces a
net carbon emission if appropriate assumption are made about displaced
fuels.
Environmental Damage Compared with Landfill:
70. The European Commission’s thematic strategy on waste prevention and
recycling notes that "at low energy efficiencies incineration might not be more
favourable than landfill" (ENDS 2007).
71. This conclusion is supported by a large body of literature showing that the
external costs of thermal treatment are actually very similar to those for
landfill. Studies finding similar results include, but are not limited to:
1. Eunomia, A Changing Climate for Energy from Waste?, Final report for
Friends of the Earth, 03/05/2006. (Hogg and Eunomia Research &
Consulting Ltd 2006).
2. Rabl, A., J. V. Spadaro, et al. (2008). "Environmental Impacts and Costs
of Solid Waste: A Comparison of Landfill and Incineration." Waste
Management & Research 26(2): 147-162. (Rabl, Spadaro et al. 2008).
3. Holmgren, K. and S. Amiri (2007). "Internalising external costs of
electricity and heat production in a municipal energy system." Energy
Policy 35(10): 5242-5253. (Holmgren and Amiri 2007)
4. Eshet, T., O. Ayalon, et al. (2006). "Valuation of externalities of selected
waste management alternatives: A comparative review and analysis."
Resources, Conservation and Recycling 46(4): 335-364. (Eshet, Ayalon et
al. 2006)
5. HM Customs & Excise (2004). "Combining the Government’s Two Health
and Environment Studies to Calculate Estimates for the External Costs of
Landfill and Incineration, December 2004." (HM Customs & Excise 2004)
6. Turner, G., (Enviros Consulting), D. Handley, (Enviros Consulting), et al.
(2004). Valuation of the external costs and benefits to health and
environment of waste management options Final report for DEFRA by
Enviros Consulting Limited in association with EFTEC, DEFRA. (Turner,
Handley et al. 2004)
72. An independent study by Dijkgraaf (Dijkgraaf and Vollebergh 2004)
concluded:
“The net private cost of WTE (waste-to-energy) plants is so much higher than
for landfilling that it is hard to understand the rational behind the current
hierarchical approach towards final waste disposal methods in the EU
(European Union). Landfilling with energy recovery is much cheaper, even
though its energy efficiency is considerable lower than that of a WTE plant.”
73. This conclusion is similar to that reached by the OECD (Organisation for
Economic Co-operation and Development (OECD) 2007) this year
following their review of waste Management in the UK and the
Netherlands:
“In both countries, there is currently a strong preference given to
incineration compared to landfilling of waste – as reflected e.g. in the landfill
taxes they apply. A similar preference underlies the Landfill Directive of the
European Union, which fixes upper limits for the amounts of biodegradable
waste member states are allowed to landfill.
However, estimates in both countries indicate that the environmental harm
caused by a modern landfill and a modern incineration plant are of a similar
magnitude, while the costs of building and operating an incinerator are much
higher than the similar costs for a landfill. Hence, the total costs to society as
a whole of a modern incinerator seem significantly higher than for landfilling
- which indicates that some reconsideration of the current preference being
given to incineration could be useful.”
74. And:
“Analyses of the negative environmental impacts of landfilling and
incineration in both countries suggest, however, that the foundation for the
present preference for incineration is questionable from the point of view of
total social costs”.
75. It should be noted that the “social costs” of waste management include the
respective private costs i.e. the costs to society of building and operating the
various management options together with the external environmental
costs.
ENDNOTES:
AEA for DTI (2005). Renewable Heat and Heat from Combined Heat and Power
Plants - Study and Analysis Report April 2005.
AEA Technology, A. Smith, et al. (2001). Waste Management Options and Climate
Change Final report to the European Commission,. Brussels, DG
Environment.
Baddeley, A., Eunomia Research & Consulting, (2008). "‘Biostabilisation’ of Wastes:
Making the Case for a Differential Rate of Landfill Tax January 2008."
BERR (2008). Heat Call for Evidence http://www.berr.gov.uk/files/file43609.pdf.
BERR (2008). RENEWABLES OBLIGATION CONSULTATION Government
Response January 2008.
Communities and Local Government (2007). "Planning Policy Statement: Planning
and Climate Change Supplement to Planning Policy Statement 1 (PPS1) December 2007."
Crutzen, P., A. Mosier, et al. (2007). "N2O release from fertilizer use in biofuel
production." Atmos. Chem. Phys. Discuss 7: 11191–11205.
DEFRA (2007). Waste Strategy for England 2007, May 2007, Cm 7086.
Department for Environment Food and Rural Affairs (2007). "How to use the Shadow
Price of Carbon in policy appraisal."
Department for Environment Food and Rural Affairs (2007). The Social Cost Of
Carbon And The Shadow Price Of Carbon: What They Are, And How To Use
Them In Economic Appraisal In The UK - Economics Group, DEFRA
December 2007
Department for Environment Food and Rural Affairs (DEFRA) (2008). Waste
Infrastructure Delivery Programme: outline business case template for
applications for Private Finance Initiative credits Version 3.1 – January 2008.
Department of Trade and Industry (2007). "Renewable Energy - Reform of the
Renewable Obligation May 2007."
Dijkgraaf, E. and H. R. J. Vollebergh (2004). "Burn or bury? A social cost
comparison of final waste disposal methods." Ecological Economics 50(3-4):
233-247.
Einola, J. K. M., K. M. Sormunen, et al. (2008). "Methane oxidation in a boreal
climate in an experimental landfill cover composed from mechanicallybiologically treated waste." Science of The Total Environment In Press,
Corrected Proof.
ENDS (2006). "UK incinerators set to fall under ‘disposal’ label." Environmental
Data Services(381): 16.
ENDS (2007). "Mass burn begins its big breakthrough." Environmental Data Services
394: 28-31
ENDS (2008). "Carbon analysis favours MBT waste treatment using anaerobic
digestion." Environmental Data Services (ENDS) Ltd.(397): 19.
ENDS (2008). "Xxxxxx wins Southwark private finance deal " Environmental Data
Services(397): 17.
Eshet, T., O. Ayalon, et al. (2006). "Valuation of externalities of selected waste
management alternatives: A comparative review and analysis." Resources,
Conservation and Recycling 46(4): 335-364.
Eunomia Research & Consulting, Dr Dominic Hogg, et al. (2006). "Modelling the
Impact of Household Charging for Waste in England Final Report to Defra
20/12/2006."
Eunomia Research & Consulting and EnviroCentre (2008). Greenhouse Gas Balances
of Waste Management Scenarios - Report for the Greater London Authority
January 2008.
Eunomia Research & Consulting and TOBIN Consulting Engineers (2008). Meeting
Ireland's Waste Targets - the Role of MBT Final report for Greenstar
http://www.greenstar.ie/docs/Eunomia_MBT.pdf.
European Commission (2000). "DIRECTIVE 2000/76/EC OF THE EUROPEAN
PARLIAMENT AND OF THE COUNCIL of 4 December 2000 on the
incineration of waste." Official Journal of the European Communities L 332.
European Court of Justice (2002). OPINION OF ADVOCATE GENERAL JACOBS
delivered on 26 September 2002 (1) Case C-458/00 Commission of the
European Communities v Grand Duchy of Luxembourg.
Fargione, J., J. Hill, et al. (2008). "Land Clearing and the Biofuel Carbon Debt."
Science 319(5867): 1235-1238.
Favoino, E. and D. Hogg (2008). "The potential role of compost in reducing
greenhouse gases." Waste Management Research 26(1): 61-69.
Finnveden, G. (2008). "A world with CO2 caps." The International Journal of Life
Cycle Assessment 13(5): 365-367.
HM Customs & Excise (2004). "Combining the Government’s Two Health and
Environment Studies to Calculate Estimates for the External Costs of Landfill
and Incineration, December 2004."
HMSO (2002). Statutory Instrument 2002 No. 2980 The Waste Incineration (England
and Wales) Regulations 2002.
Hogg, D. and Eunomia Research & Consulting Ltd (2006). A changing climate for
energy from waste - Final Report for Friends of the Earth.
Holmgren, K. and S. Amiri (2007). "Internalising external costs of electricity and heat
production in a municipal energy system." Energy Policy 35(10): 5242-5253.
House of Commons Committee of Public Accounts (2007). HC 212 Department for
Environment, Food and Rural Affairs: Reducing the reliance on Landfill in
England Fifty–seventh Report of Session 2006–07 Report, together with
formal minutes, oral and written evidence 18 July 2007 Published on 30
October 2007
Huber-Humer, M., J. Gebert, et al. (2008). "Biotic systems to mitigate landfill
methane emissions." Waste Management Research 26(1): 33-46.
IPCC (2006). "2006 IPCC Guidelines for National Greenhouse Gas Inventories Volume 5 Waste."
National Assembly for Wales (2007). Future Directions For Municipal Waste
Management In Wales - A Paper For Discussion. NAW.
Organisation for Economic Co-operation and Development (OECD) (2007).
Instrument Mixes Addressing Household Waste, Working Group on Waste
Prevention and Recycling, ENV/EPOC/WGWPR(2005)4/FINAL 02-Feb2007 Environment Directorate Environment Policy Committee.
Rabl, A., A. Benoist, et al. (2007). "Editorial - How to Account for CO2 Emissions
from Biomass in an LCA." International Journal of Life Cycle Assessment
12(5): 281.
Rabl, A., J. V. Spadaro, et al. (2008). "Environmental Impacts and Costs of Solid
Waste: A Comparison of Landfill and Incineration." Waste Management &
Research 26(2): 147-162.
XXX (2008). Carbon Analysis Final Report RUFFORD ENERGY RECOVERY
FACILITY Nottinghamshire on behalf of Xxxxxx Environmental Services,
July 2008.
XXX, S. Critten, et al. (2007). Exeter Energy from Waste Facility Carbon Analysis
Final <http://www.devon.gov.uk/graceroad-carbonanalysis.pdf>.
XXX Consultants for Viridor Waste Management Ltd (2007). Heat Plan Energy from
Waste with Combined Heat and Power Facility, Oxwellmains.
Smith, A., K. Brown, et al. (2001). Waste Management Options and Climate Change
Final report to the European Commission, DG Environment, AEA
Technology.
Smyth, D. (2008). Carbon Analysis –anecessary part of waste management decisions
19-20 February 2008
<http://www.XXXplc.co.uk/news_html/latest/pdf/carbon-analysis.pdf>.
Energy from Waste 2008 Chelsea Old Town Hall, London, .
Spokas, K., J. Bogner, et al. (2006). "Methane mass balance at three landfill sites:
What is the efficiency of capture by gas collection systems?" Waste
Management 26(5): 516-525.
TBU and Eunomia Research & Consulting (2003). Cool Waste Management - MBT A State-of-the-Art Alternative to Incineration
for Residual Municipal Waste. London, Greenpeace.
Turner, G., (Enviros Consulting), D. Handley, (Enviros Consulting), et al. (2004).
Valuation of the external costs and benefits to health and environment of
waste management options Final report for Defra by Enviros Consulting
Limited in association with EFTEC, DEFRA.
Waste Resources Action Program (WRAP) (2008). "WRAP Gate Fees Report, 2008 Comparing the cost of alternative waste treatment options
<http://www.wrap.org.uk/document.rm?id=5755>."
Welsh Assembly Government (2008). "A Guide to the New Renewable Energy Route
Map for Wales Consultation on the way forward to a leaner, greener and
cleaner Wales."
Wenzel, H., Technical University of Denmark for WRAP. (2006). Environmental
Benefits from Recycling - An International Review of Life Cycle
Comparisons for Key Materials in the UK Recycling Sector. Banbury,
England, Waste Resources Action Programme.
Appendix 3
Entire Newark & Sherwood District Council Planning Officer's report - along with a recently
created PowerPoint Presentation, available by request
Excerpt below:
RECOMMENDATION
That Nottinghamshire County Council be advised that Newark and Sherwood District Council
currently object to the proposals on the grounds set out in the above report.
In view of the conclusion from the carbon assessments by the applicant and the EA, that
there are other options that produce a better impact on carbon emissions (including ERF with
combined heat and power), it is not considered that the applicants have justified the suitability
of the scheme on Greenfield land in the open countryside.
By virtue of the restoration conditions attached to the site, however, it is technically classed as
a Greenfield site and indeed is required to be restored to natural heathland and woodland.
It is also located within the open countryside.
For both these reasons, the proposals would be contrary to a number of development plan
policies and, in particular, it would be a departure from Local Plan Policy NE1 and JSP Policy
2/10.
The proposals have been submitted in isolation from the rest of the former colliery site and, at
present, there are no planning approvals (or indeed, planning applications) in place for
employment development and nor is it allocated for such a use in the Local Plan or the
emerging LDF.
The proposals that have been submitted, do not demonstrate that the benefits of the scheme
would justify the visual impact on the landscape of the area and on Greenfield land in the
open countryside.
Such a justification might exist if the scheme were part of a comprehensive redevelopment of
the former colliery site that included the provision for a waste management facility comprising
incineration with combined heat and power.
Currently, however, this is not the case.
Indeed, the site selection process is unduly influenced by the emphasis placed on what may
or may not occur on the adjoining land in the future.
The rejection of alternative sites within urban areas has not been adequately justified and I
consider that there is insufficient certainty over the future of the adjoining land to agree with
the degree of emphasis being placed on this aspect by the applicant.
In summary, to date, insufficient material planning considerations have been advanced to the
extent that would warrant a departure to the strong policy considerations which presume
against development in the countryside.
Source:
http://www.newark-sherwooddc.gov.uk/pp/gold/viewgold.asp?idtype=page&id=17795
Waste Implementation Programme
6F, Ergon House
Horseferry Road
London SW1P 2AL
Telephone 020 7238 4310 GTN 238 4310
Email john.f.burns@defra.gsi.gov.uk
Website www.defra.gov.uk
Steve Evans
Project Sponsor
Director of Community Services
South Gloucestershire Council
Broad Lane Offices
Engine Common Lane
Yate
BS37 7PN
John Burns
Director
Waste Implementation Programme
6F Ergon House
Horseferry Road
London
SW1P 2AL
30 May 2008
Dear Mr Evans
Expression of Interest (EoI) for Private Finance Initiative (PFI) funding – Round 4
Thank you for your submission of an EoI on behalf of the West of England Waste
Management and Planning Partnership. I am writing to notify you of the results of the
evaluation process.
The EoI was evaluated by colleagues in the Waste Infrastructure Delivery Programme
(WIDP) Scrutiny team taking into account comments from Government Office South
West, WRAP and the Environment Agency. The recommendation of the Scrutiny team
was considered and approved by the WIDP Programme Board.
The primary aims of this stage of the application process are to provide an opportunity
for:
a) a review of the compatibility of the Authorities’ procurement strategy with
Defra’s programme objectives including compliance with the Departmental PFI
criteria; and
b) an assessment of the Authorities’ state of readiness in relation to the
preparation of the Outline Business Case (OBC) required to secure PFI funding
as according to the stated WIDP timeframes.
Accordingly we provide feedback under two separate headings.
Compatibility with Defra’s Programme Objectives
I am pleased to confirm that, subject to the comments below, in the opinion of the WIDP
Board, the Authorities’ procurement strategy appears likely to lead to the development of
a project that is compatible with Defra’s Programme Objectives and compliant with the
Departmental PFI criteria.
As is clear in the waste PFI criteria, Authorities should be aware of the Waste Strategy
for England 2007 (WSE 2007) http://www.defra.gov.uk/environment/waste/strategy/. In
line with WSE 2007, Defra is now strongly encouraging Authorities to give a high
weighting to the relative carbon efficiency of different technological solutions - especially
where they involve energy recovery. Combined heat and power (CHP) solutions are
typically the most efficient outcomes giving the maximum climate change benefit. Your
OBC will therefore be strengthened significantly if you can show that your procurement
approach, evaluation and site selection criteria are developed in a manner that
encourages the delivery of solutions that include CHP.
In considering your CHP options, please cast the net widely. CHP can be achieved in a
number of different ways and potential heat use opportunities may not always be
available adjacent to a heat source. (Please be aware of the information available
regarding heat users in your area at
http://www.defra.gov.uk/environment/climatechange/uk/energy/chp/ ).
To facilitate the matching of heat production and heat usage you may wish to consider a
“fuel production / fuel use” approach, whereby the Authorities’ selected waste
management solution produces a fuel which can be used to fire a CHP application in
existing industrial plants. This is likely to involve converting CHP applications from gas
to solid fuel firing with attendant energy cost, security of supply and energy efficiency
benefits for the user and the Authorities. An essential first step when considering this
approach is to research potential industrial energy users in your region. The information
available at the following website is a useful starting point although additional project
specific studies are likely to be needed:
http://www.industrialheatmap.com/download.php
I would also draw your attention to the following issues relating to compliance with the
Defra PFI criteria:
a) Criterion 1 – this criterion encourages applicants to explore the opportunities
for joint working with neighbouring Authorities. As a joint procurement your
application can potentially score highly in relation to this criterion. We would
therefore stress that the joint working proposal must be maintained as an
essential element of the Business Case and we would expect the OBC to include
a full evidence base to justify the decision taken as to the right degree of joint
working.
b) Criterion 2 - this criterion refers to “longer term national targets for recycling
and composting.” WSE 2007 incorporates three explicit targets for Municipal
Solid Waste management which Defra wishes to see reflected in all applications
for PFI credits i.e.:
Recycling and composting of household waste – at least 40% by 2010, 45%
by 2015 and 50% by 2020;
Household waste not re-used, recycled or composted - reduce to 310 kg per
person in 2010, 270 kg in 2015 and 225 kg in 2020; and
Recovery of municipal waste – 53% by 2010, 67% by 2015 and 75% by 2020.
Since Round 2 it has been mandatory for plans to meet or exceed these targets
to be incorporated in OBCs for all projects. Any OBCs which do not incorporate
these targets are liable to be rejected by Defra. In this context, please note that
the WSE 2007 highlights Anaerobic Digestion for food waste collections as a
means of combining a recycling process with energy recovery and we expect to
see Anaerobic Digestion considered as a means of achieving the above targets.
WSE 2007 also highlights the case for extracting energy from waste wood that
cannot be readily re-used or recycled. The waste wood collected at your Civic
Amenity sites has high biomass content. The OBC needs to consider how waste
wood can be diverted from landfill and used to recover energy. The Authorities
should explore whether they can offer medium/long term contracts for both Solid
Recovered Fuel and waste wood that could help energy users secure finance for
the construction of combustion capacity. Please see WIDP’s “Waste Wood
Information Report”:Report - http://www.defra.gov.uk/environment/waste/topics/woodwaste.htm
Press notice - http://www.defra.gov.uk/news/2008/080409b.htm
c) Criterion No 8 - Authorities applying for PFI credits must commit to follow
extant guidance for PFI procurement including Defra-issued specific guidance.
Please note that this will include WIDP'
s new guidance on the development of
the Payment Mechanism and Output Specification schedules to the PFI project
agreement. These contractual documents determine how the Authority'
s payment
will vary with variations in residual waste. Hence they are critical in determining
whether the Authority'
s contractual commitments in respect of residual waste are
consistent with its plans in relation to waste minimisation and recycling. This will
be a key issue for Defra in evaluating the OBC and Authorities are requested to
give early consideration to the guidance and set out how they intend to
implement the guidance when completing the OBC.
d) Criterion 15 – this criterion states that Authorities are expected to take
proactive action to acquire sites. For the avoidance of doubt the OBC will need
to provide confirmation that sites have been acquired or that steps have been
taken that provide a high degree of confidence that sites will be acquired before
the procurement process commences. If the latter course is adopted, Project
Review Group approval is likely to be conditional on completion of the site
acquisition.
Please note that these are provisional conclusions based on the information provided to
WIDP to date. There is no commitment from Defra at this stage in relation to the
allocation of PFI credits. The allocation of credits will be based on the approval of an
OBC.
State of Readiness
The WIDP Board considers that your project has a reasonable prospect of being able to
submit a compliant OBC before 31 October. Areas we would highlight as in need of
further consideration include:
•
•
•
•
•
•
•
The robustness of the partnership to ultimately deliver the Residual Project;
The effectiveness of decision making and the governance arrangement;
The real potential for a CHP solution which needs to be rigorously explored;
The key interim solutions and the wider Reference Project infrastructure;
The identification of sites and the development of the Waste Development Plan
Document matched with the procurement timeline. As planning is a key issue for the
project we would highlight the need to keep the issues raised in WIDP’s Planning
Guidance under constant review and to liaise closely with your WIDP Transactor
regarding the strategy for managing this risk;
Establishment of waste minimisation targets (kg/head) in line with the national
strategy and the development of solutions to achieve this; and
Further evidence on how recycling projections will be achieved.
The Process Going Forward
In developing the OBC over the course of the next few months we would be grateful if
you would adopt the template WIDP has prepared to help ensure all OBCs cover all
relevant points. A copy of the template (v 4.0) is attached. Your WIDP Transactor, Mike
Williams, will be available to assist you.
As you firm up your plans regarding the timing of and capacity of new residual waste
treatment facilities, we would like to reflect your plans in WIDP’s Interim Reporting Tool
(IRT). The IRT model aggregates the existing and planned new facilities across all
Waste Disposal Authorities in England to allow a comparison of the forecast residual
waste capacity with that needed to comply with EU landfill targets. The data for the IRT
model is collected monthly from Authorities and we would now like to include the West of
England project in the data gathering exercise. Your Transactor will liaise with you to
initiate the submission of the monthly return. We would also encourage your continued
engagement with the WRAP programme.
PFI Credit Allocations
Finally, please note that Defra’s PFI credit allocation policy has been revised to bring it
into line with other Government Departments. From Round 2 onwards the PFI credit
awarded to an individual project will be a set percentage of the relevant capital
expenditure in the OBC.
The relevant capital expenditure should be calculated in accordance with Section D of
Communities and Local Government’s Local Government PFI Project Support Guide
(2007-08) (http://www.local.odpm.gov.uk/pfi/sg0708.pdf ). Supplementary guidance on
how to interpret this guidance in the waste context is offered in Appendix E of the
enclosed OBC template.
The minimum percentage applicable will be equal to 50% of the relevant capital
expenditure. We will not reduce that percentage for any project, subject to WIDP
satisfying itself that the capital expenditure figures are based on appropriate
assumptions in line with market prices. We are currently reviewing the potential for
higher awards for individual projects that make exceptional contributions to the
objectives set out in WSE 2007. This requires Ministerial clearance and there is no
commitment yet to such a process. We will contact you again shortly as soon as a
decision has been taken.
A number of Authorities in Rounds 2, 3 and 4 are currently going through the PFI credit
application process and it is possible that the credits allocated to Defra under the 2007
Comprehensive Spending Review (CSR07) will not be sufficient to fund all projects in
those rounds.
In addition, as this current allocation of credits may have to be used by the end of the
spending round, Defra is not currently in a position to allocate credits to projects that are
scheduled to reach financial close after 31 March 2011. We believe that the end of
October 2008 is the latest OBC submission date that is consistent with a reasonable
level of confidence that the project can reach financial close by 31 March 2011.
Therefore we have to inform all applicant Authorities that:
a) Although we will aim to allocate funding to those Authorities which can provide
a compliant OBC by the Round 4 submission date i.e. 31 October 2008, oversubscription will inevitably introduce a competitive nature to the process and not
all Authorities will necessarily secure funding. PFI credit allocations will be
dependent on the requirement for residual treatment to deliver on UK Landfill
Directive targets and other policy objectives, and on the availability of credits;
b) Authorities that submit OBCs (that are judged compliant) on or before 31
October 2008 will be given priority over those that need longer to complete and
submit a compliant OBC;
c) Authorities that cannot submit compliant Round 4 OBCs until after 31 October
2008 may still be able to apply for PFI credits. However, PFI Credits will only be
available if and when WIDP (i) determines there are valid policy reasons to
allocate further PFI credits; and (ii) that unused PFI credits from the CSR07
period (if any) can be carried forward to 2011/12, or additional credits are
allocated to Defra for 2011/12.
If you require any further information regarding the contents of this letter please do not
hesitate to contact John Enright, Head of Project Development and Scrutiny for WIDP
(020 7238 4313 or john.enright@defra.gsi.gov.uk).
Yours sincerely
John Burns
Programme Director
Direct Line: 020 7238 4310
http://www.defra.gov.uk/environment/waste/wip/index.htm>
cc
– Mike Williams WIDP Transactor
- Jeremy Seldon WIDP Regional Co-ordinator
- Graham Turner Chief Executive of Bristol City Council
- Jan Ormondroyd, Chief Executive of South Gloucestershire Council
- Amanda Deeks, Chief Executive of North Somerset Council
APPENDIX 6 – A salutary lesson from Sussex
[Veolia] Incinerator's cost doubles -- Friday 28th September 2007
www.theargus.co.uk/mostpopular.var.1720827.mostviewed.incinerators_cost_doubles
.php Exclusive by Jess Bauldry and Lawrence Marzouk
The construction costs of a controversial incinerator project have more than doubled
from original estimates. A total of £145.7 million will now have to be paid by waste
contractor Veolia just to prepare the site in Newhaven and to build the incinerator.
Last night Brighton and Hove City Council agreed to help Veolia meet its financial
burden by extending the life of the contract from 25 to 30 years. East Sussex County
Council gave its backing to the deal on Tuesday. Both councils took the decisions at
secret meetings. All councillors have refused to discuss the details of the arrangement
although opinion was divided over whether details of such largescale spending should
be released into the public domain. A copy of the papers, leaked to Lewes MP
Norman Baker, suggests that Veolia claimed that the waste contract, agreed four
years ago, was no longer profitable and would have to be extended by five years.
Under the contract Veolia is liable for all increased costs to the project but
councillors feared that without help the contractor would go bankrupt causing
the project to collapse.
Veolia faces a rise in construction costs from £71.7 million to £145.7 million. The
longer contract will give Veolia an extra £35 million in income. Councillors feared
that if they refused to extend the contract Veolia would walk away. The project
would then have to be put back out to tender and be likely to cost even more…The
project is already two years behind schedule because of delays in submitting
planning applications.
Both councils are so keen to see it completed they have also promised a blank
cheque to Veolia for any legal costs that arise if opponents of the scheme challenge
it in the courts. The deadline for a "judicial review" is next January. Veolia is also
thought to have been granted an indemnity against costs if the incinerator
project falls through, meaning it will get back at least some of the money it has
spent so far. It is understood that councillors were told that the costs of not accepting
Veolia's demands would have been significantly more than agreeing to the revised
contract. In 2003, a 25year contract was signed between East Sussex, Brighton and
Hove and Veolia, the world's second biggest waste management operator. The
contract was dubbed a "25-year monopoly" by opponents and has attracted sustained
opposition for plans to build a waste sorting centre in Hollingdean, Brighton, and the
incinerator in Newhaven…even though the project has a £1 billion price tag
almost nothing is known about the financing or the costs of the buildings or
services.
...Liberal Democrat councillor Paul Elgood said: "Residents should be extremely
concerned about what they're not being told by the council. We call on Brighton and
East Sussex to make a full disclosure in the public interest." Lewes MP Norman
Baker plans to complain to the Audit Commission and the European Union. He said:
"This is a criminal waste of taxpayers' money and represents the Arthur Daley school
of economics. "The councils appear to be determined to throw good money after bad
in their blinkered determination to bulldoze through this incinerator. They are
recklessly gambling with our money."
APPENDIX 7 - Email from Patrick McConville of Energos
>>> "Patrick McConville" <patrick.mcconville@energ.co.uk> 06/01/2009 16:26 >>>
Gary
Thank you for sending me the documents which I have read with interest.
I think that the case for small-scale plants can be made simply by
looking at the volumes of non-recyclable residual waste available in an
area and comparing it directly with local opportunities (present and
future) to supply heat. In this way we can displace the use of fossil
fuels and offer a stimulus for economic regeneration, offering low-cost
heat to industry/district heating systems and renewable power. As an
Advanced Conversation Technology the Energos technology would benefit
from ROCs. As we have discussed previously, the Energos technology's
emissions are well below the EU WID limits. Also, because the plants
are small-scale there may be a larger number of suitable sites compared
to large scale plants and more opportunities to offer heat to major
energy users.
Regards
Patrick
Patrick McConville
Business Development Manager
ENERGOS Limited
11b Olympic Park
Woolston Grange Avenue
Birchwood
Warrington
WA2 0YL
United Kingdom
m: +44 (0) 7920 188654
t: +44 (0) 845 683 7012
t: +44 (0) 1642 760992
patrick.mcconville@energ.co.uk
www.energ.co.uk
ENERGY FROM WASTE - RENEWABLE ENERGY - ENERGY MANAGEMENT - COGENERATION
Disclaimer: The information contained in this e-mail is confidential and
is intended for the exclusive use of the individual(s) or organisation
specified above. Any unauthorised dissemination or copying of this
e-mail, or mis-use or wrongful disclosure of information contained in
it, is strictly prohibited and may be illegal. Please notify the sender
by phone or fax immediately should you have received this e-mail in
error.
Cllr Gary Hopkins
C/o The Council House
Reply to
Telephone
Minicom
Fax
Email
Our Ref
Your Ref
Date
Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT A (3) 15
Statement to Cabinet 8th January 2009
Leader
The Liberal Democrat opposition to a mass burn incinerator in Avonmouth is well know.
We have explored every avenue to encourage your administration to consider alternative
options.
We are concerned that insufficient efforts have been made to improvement in recycling as
an alternative to incineration or landfill.
We are concerned about the inadequate attention paid to climate change impact.
We are concerned that small-scale technologies would be excluded by the high cost of the
bidding process.
We all want to support and encourage the people of Bristol to be environmentally aware
but shackling the city to a dirty incinerator, which has to be paid for over 25 or 30 years,
does not help anyone.
Cllr Dr Jon Rogers
Ashley Ward Lib Dem Councillor
0117 914 2558
Cllr Jon Rogers
C/o The Council House
Reply to
Telephone
Minicom
Fax
Email
Our Ref
Your Ref
Date
Councillor Mark Bradshaw
0117 92 22879
0117 92 22090
mark.bradshaw@bristol.gov.uk
10th February 2009
Public Forum Business– Cabinet 8.1.09
It has been reported elsewhere on many occasions the reasons why it has been
necessary to submit an Outline Business case to Defra and fully costed financial
model based on a deliverable technology at the scale required to meet our collective
LATS allowances to 2020, namely 160,000 tonnes per year. This has enabled each
authority to have confidence in meeting its statutory obligations and to enable them
to confirm their ability to meet future costs. These are reflected within the
Affordability Envelope identified in the recommendations which were placed before
Cabinets/Executives in October. Failure to act, or the introduction of further delay
would have led to greatly increased financial risk for council tax payers.
Having identified the 'Reference Technology' as Energy from Waste by incineration
with Combined Heat and Power, and a 'Reference Site', the Authorities wish to
encourage other competing value for money solutions to come forward provided
they are capable of delivering the key objectives set out in the Joint Waste Strategy
and the Outline Business Case, at an affordable cost. Contractors can offer
alternative locations if they wish to.
The key objective is to secure a technology which is proven in terms of dealing with
municipal waste and which provides the appropriate level of confidence both for the
Authorities and Government so that PFI funding support is forthcoming. Without PFI
funding, the Authorities would have to carry a significant increase in risk by the very
nature of the alternative, more expensive, funding arrangements which would be
required.
Whatever solution is finally adopted it will be required to contribute to resource and
energy recovery at all stages, reduce overall transport impacts, and be flexible in
dealing with changes in waste arisings, waste composition and legislation over the
contract period, whilst maximising opportunities to recycle and reuse as supported in
Phase 1 of the Joint municipal residual waste strategy for the West of England. All
the participating authorities remain fully committed to an ambitions, and necessary
programme of improved, reduction, reuse and recycling performance.
It will be necessary during the procurement process to set minimum thresholds of
financial standing and technical capacity. The resources, range and depth of skills
needed to provide the requisite service are such that some companies may wish to
collaborate to form a consortium approach, or form a single organisation offering the
full service. The Authorities will welcome all expressions of interest at the Pretender Qualification Stage and have no pre-determined views on the technology or
combination of technologies taking part in this procurement process.
Yours sincerely
Cllr Mark Bradshaw
Executive Member for Sustainable Development
STATEMENT C 1
GMB Submission to Cabinet – 8th January 2009
Housing Caretaking Review –Tied Accommodation –
The GMB have put forward our proposals in relation to the recommendations put
forward by Housing Services. We have submitted a statement to Cabinet because we
would urge you to reconsider the recommendation to delegate this decision affecting
120 caretaking staff across the whole of the City.
We have taken the unusual step of actually putting forward an alternative structure as
we would like you to consider another option that we believe will deliver the
increased quality of service and ensure the caretaking service is recognised as a
professional service. These proposals are attached to this statement.
The GMB and it’s members are not challenging constructive change – we are
challenging negative management change!
The GMB do not consider the existing management’s proposal reflects those wishes
and we would therefore urge Cabinet to reconsider delegating this decision. We are
not asking for ‘favours’ but just a chance to properly look at this service and consider
how to take it forward to the future ‘fit for purpose’.
The GMB wants to find a mutually agreeable solution which increases service
delivery; ensures our members feel valued and recognised and the caretaking service
is seen as an example of good practice!
Rowena Hayward
Organisation Officer
GMB Response
supported by Unite
The GMB's paper sets out the proposals for the future Caretaking Service, highlighting
staffing and HR issues.
It uses the Managements ‘Caretaking Service Review Proposal’ as its basis.
The proposals will seek to:
present a sound business case
propose new operational arrangements
to satisfy Tenants’ concerns and meet their needs
lead to improved levels of satisfaction
minimise the impact on staff
deliver savings to the Service
establish a service that will be a blueprint to other authorities
Review drivers
The management document focuses on the following drivers
Improve the quality of the service and customer satisfaction with it.
Deal with the inconsistencies of the present arrangements.
Improve the equality of treatment of customers
Ensure customers receive a cost efficient service
Improve the quality of the service and customer satisfaction with it. It is important to
remember when referring to the ‘Customer satisfaction survey’ that it was undertaken soon
after the service as centralised. It would therefore be safe to say that the results are more
of a reflection on the previous service rather than the new one.
Deal with the inconsistencies of the present arrangements. There is no logic in the
way the service is organised at the moment. It has developed over many years in an ad
hoc way, must likely because the service was for sometime was run by the individual area
offices. Also the level of service varies considerably between sites due to inconsistent
levels of resources.
Improve the equality of treatment of customers. Each group of tenants, Multistorey
(enclosed), Multistorey (open). Walk ups, should expect the same standard of service. The
specifications and frequency may alter between Multistories (all) and walk ups, but the
same standard of cleanliness and the same level of service should be received by all.
Ensure customers receive a cost efficient service
It is important that an equitable charging system should be introduced, where service
charges meet those costs which are attributable to the service charge.
However it is important to remember that the service charge has never covered the cost of
the service, as it was not initially set at the right level. The GMB agree that a balance has
to be achieved between charges that can be applied to the HRA, and those that are
covered by the service charge. However the GMB does not agree that management have
been given a mandate to return money to tenants
Consultation
The key areas of consultation for the proposals were:
The Managements ‘Caretaking Service Review Proposal’
Meetings and ongoing discussions with staff and tenants
Views of Caretaking Service Users Group
Discussions with all four Political parties
Leader of the Council Helen Holland's statement
Considerations
The following were carefully considered and the pros and cons balanced before we put
forward our recommendations
The desires and needs of the tenants
The ability to meet required standards of cleanliness, safety and tenant satisfaction
The views of the Political Parties
The need for a cost effective service
The need for a robust service that can meet the demands of ever changing
customer base
The need to set up a joint mechanism that will review the service every three years
The need for an agreed, cohesive strategy that i.e. not open to ad hoc tinkering
The needs and aspirations of the staff
Staff Numbers
There are currently 108 permanent site based staff equating to 104.32 full time equivalent
posts, 17 temporary staff with 13.5 FTE's and 12 permanent office based staff equating
to 10.5 full time equivalent, broken down as follows:Site based posts
Mobile Caretakers
Non Resident Site Team Leaders
Resident Site Team Leaders
Non Resi Community Caretakers
Resident Community Caretakers
Assistant Community Caretakers
Temporary ACC's
Total
No.posts
11
3
12
6
37
39
19
127
No.FTE
11
3
11.54
6
37
35.78
15.5
119.82
Management proposal
Site based posts
Site Co ordinator
Senior Community Caretaker
Community Caretaker
Total
No. posts - FTE
15
14
75
104
Office posts
Service Manager
Area Managers
Staff development /training post
Housing Advisors
Total
1
4
1
Subject to separate review
6 plus Housing Advisors
GMB OPTION
Site based posts
Site Co ordinator
Senior Community Caretaker
Community Caretaker
Total
Office posts
Service Manager
Area Managers
Housing Advisors
Total
No. posts - FTE
10
14
86
110
1
3
Subject to separate review
4 plus Housing Advisors
Grading
The management propose 28 residents and suggest the following grades
Site Co ordinator BG 7
Senior
BG 5
Caretakers
BG4
These grades and the drop ion the number of residents will mean that the majority of staff
will take a pay cut. Some STL's, Mobiles and RCC's who lose their residency, will face a
substantial pay cut and may be made redundant,
The GMB proposes 37 residents and suggests the following grades
Site Co ordinator BG 7
Senior
BG 6
Caretakers
BG5
We appreciate that there is still a drop in the number of residents but with some STL's
becoming Site Coordinators and with some perceived retirements, we feel that this figure
is realistic.
Raising Senior and caretakers grades will not only minimise the financial impact on staff
but will vastly reduce the number of possible redundancies.
Ring Fencing
Under Management proposals the ring fencing will be as follows:STL's and mobiles for the BG7 Site Coordinators role (26 staff 15 jobs)
Existing BG5's for the BG5 Senior role (44 Staff 14 jobs)
RCCs for the residents positions (37 staff 28 positions)
Those unsuccessful at getting a new role will be placed in the 'job pool'. Any one in the job
pool will only be eligible to be considered for a position in Caretaking once the job
selection has taken place. However due to the pay difference for STL's, Mobiles and
RCC's there is a chance that people will be made redundant as the offer of a job as non
resident BG4 will not be suitable as it will only attract 3 years pay protection.
Under the GMB proposals the ring fencing will be as follows:STL's and mobiles for the BG7 Site Coordinators role and senior roles (26 staff 24 jobs)
Resident STL's and RCCs for the residents positions (47 staff 38 positions*)
Existing BG5's and BG4's will automatically be slotted into the BG5 caretakers role
*STL's who become Coordinators will be non resident.
It is anticipated that due to retirement/natural wastage the effects on staff regarding job
losses will be minimal.
Methodology
Using the Management proposals as a base we will structure the city into 10 sites. The
Henbury. Shire and Blaise sites will be restored to two sites. Withywood and hartcliffe will
become one site, the two dispersed teams will be joined together and the positions of
Sheltered sire coordinators will be deleted.
The sheltered sites will be distributed equitably looking at area size and density between
the 10 remaining coordinators.
There will be 14 seniors will be split between the 11 sites with 1 additional senior in
bedminster/clifton. Kingsdown/St. Pauls and the dispersed team.
There will be an additional community caretaker for each site which will provide a balance
for sickness and holidays.
The role of the Community Caretaker will be enhanced. As the first point of contact for
many tenants we foresee that their level of knowledge of Council services and procedures
need to be increased to a level equal to that of a of an advisor in the CSC. This along with
other suggestions would more than likely result in this position being graded at BG5.
Rationale
At present there are approximately 120 staff in 'hands on' positions across the City.
In the new service the 12 site coordinators will not undertake cleaning or will the 12
mobiles team members directly.
The 14 senior Caretakers and 86 Community caretakers will undertake the 'hands on' role.
We feel that a reduction from 120 to 100, still a loss of a sixth of the workforce would be a
far more sustainable option that the loss of 31 or a quarter of the work force as proposed
by management.
Community caretakers will have a greater knowledge of council services and be able to
Signpost tenants to the right department/agency, hand out leaflets or forms where
required. This in turn will lead to a reduction of work for other areas of the council allowing
them to concentrate on more important activities.
This would tie in with the Estate Management review.
Site coordinators would have a close relationship with the SHA's and ASB officers who
cover their areas. This would lead to a greater flow of information and lead to a quicker
resolution of any problems. With greater involvement some cases may be dealt with before
they need to go to a case conference.
Caretaking staff would have full control of the laundries. At present caretakers look after
laundry rotas and deal with any 'squabbles' that occur. However it is Estate Management
who would take ultimate responsibility for laundry. It makes more sense for one service to
deal with all aspects of the running of the laundry and as the caretaking service is site
based, it is the obvious choice.
The same argument would hold true for community rooms. As caretakers would be
responsible for the opening and closing of these rooms it would be sensible for them to
handle the bookings as well. This responsibility would pass from T.A.s as well as EM, to
ensure a unified approach.
There should be no exceptions from the above points regarding laundries and community
rooms.
Financial considerations
It is important to remember the following points
tenants are happy with the charge that they pay. In the survey they ranked the
charge they pay 10th out of 12 in importance. There has never been a move from
tenants for banded charging or a rebate.
Councillors have never given an undertaking to refund any money to tenants.
Although the draft review was agreed by the QOL committee, the focus of the debate was
around the number of resident caretakers. The body of the review was not and should not
be deemed as agreed by default.
The service charge should only cover additional services NOT those the tenant may
be deemed as having paid for through their Council tax or their rent. It should be possible
for additional funding to come from the HRA and the General fund.
Funding the Service
Management states that
Depending on the outcome of the Job Evaluation process these proposals will achieve a
saving to the Housing Revenue Account of approximately £475,000 and a surplus of
income over expenditure of £360,000 making a total reduction in the cost of the service of
£835,000. This saving will be realised at the end of year 3 after implementation of this
review.
The surplus of £360,000 would be returned to tenants.....
Part of this £360,000 will fund the additional 11 community caretakers we have proposed
Additional funding is available as followsHRA funding (£120k) for deleted Area Manager and site coordinators posts will
be used to fund the increase in grades
CONCLUSION
We feel that these proposals will :●
modernise the service
●
increase productivity
●
address customer concerns
●
increase customer satisfaction
●
resolve most potential HR issues
●
deliver savings to the service
Mobile Team Review
GMB response
Objectives
This paper sets out the proposals for the future Caretaking Service. It uses the
Managements ‘Caretaking Service Review Proposal’ as its basis.
The proposals will seek to:
present a sound business case
propose new operational arrangements
to satisfy Tenants’ concerns and meet their needs
lead to improved levels of satisfaction
minimise the impact on staff
deliver savings to the Service
establish a service that will be a blueprint to other authorities
Background
This document is in response to the proposals outlined in Managements ‘Caretaking
Service Review Proposal’. It is recognized that the service as a whole needs to be
modernized and that working practices need to be changed to meet the challenge of
changing demographics.
The GMB believe that rather than looking at what other authorities are doing now, it is
important to develop a plan for the future. This review has to be bold, so that we do not
end up reviewing the service gain in a few years time.
The Mobile team 11 staff and provides cover at various levels for 7,700 properties,
including out of hours and are also responsible for locking laundries around the City.
Staff work in teams on a shift system.
Review drivers
The management document focuses on the following drivers
●
●
●
●
Improve the quality of the service and customer satisfaction with it.
Deal with the inconsistencies of the present arrangements.
Improve the equality of treatment of customers
Ensure customers receive a cost efficient service
Improve the quality of the service and customer satisfaction with it. It is important to
remember when referring to the ‘Customer satisfaction survey’ that it was undertaken soon
after the service as centralized. It would therefore be safe to say that the results are more
of a reflection on the previous service rather than the new one.
Deal with the inconsistencies of the present arrangements. There is no logic in the
way the service is organised at the moment. It has developed over many years in an ad
hoc way, must likely because the service was for sometime was run by the individual area
offices. Service levels vary - as mentioned above. Also the level of service varies
considerably between sites due to inconsistent levels of resources. There are some flats
receive no service at all
Improve the equality of treatment of customers. group of tenants, Multistorey
(enclosed), Multistorey (open). Walk ups, should expect the same standard of
service. The specifications and frequency may alter between Multistories (all) and
walk ups, but the same standard of cleanliness and the same level of service should
be received by all.
Ensure customers receive a cost efficient service.In respect of those costs that are
recovered through service charges and the level of those charges. The cost of the service
was not a major concern to the
vast majority of tenants. It is important that an equitable charging system should be
introduced, where service charges meet those costs which are attributable to the service
charge.
It is important to remember that the service charge has never covered the cost of the
service, as it was not initially set at the right level. The GMB agree that a balance has to be
achieved between charges that can be applied to the HRA, and those that are covered by
the service charge. However the GMB does not agree that management have been given
a mandate to return money to tenants
Human Resources Implications - The service currently employs 11 permanent staff, all
of whose jobs are being deleted.
Work currently undertaken
The 11 members of the Mobile team cover staff shortages or undertake remedial or 'blitz'
cleaning during the day.
An out of hours and emergency service is currently provided by a mobile caretaking team
who respond to caretaking related emergencies any time outside normal working hours.
Instances of caretaking emergencies are low, as most calls are directed to contractors
rather than the 'in house' service.
The Mobile team also lock the communal laundries around the city from 8pm onwards to
prevent misuse of them.
The cost of the standby payments and shift allowances to provide these out of hours
services costs over £34,000 a year (2008/09).
The other costs associated with this 24 hour service are transport and accommodation.
Consultation
The key areas of consultation for the proposals were:
The Managements ‘Caretaking Service Review Proposal’
● Meetings and ongoing discussions with staff and tenants
● Views of CSUG
● Discussions with all four Political parties
●
Views of Caretaking service user group
Salient points
The service from the mobile team needs to be improved
Consider expanding the role of the caretaker to include minor repairs
Weekend cover needed on some sites
Area teams must have built in capacity to cover absences e.g. holidays, sickness
Considerations
The following were carefully considered and the pros and cons balanced before we put
forward our recommendations
● The desires and needs of the tenants
● The ability to meet required standards of cleanliness, safety and tenant
satisfaction
● The views of the Political Parties
● The need for a cost effective service
● The need for a robust service that can meet the demands of ever changing
customer base
● The need to set up a joint mechanism that will review the service every three
years
● The need for an agreed, cohesive strategy that i.e. not open to ad hoc tinkering
● The needs and aspirations of the staff
The New Mobile Service
OUT OF HOURS
An out of hours and emergency service will still be provided by a mobile caretaking team
who will respond to caretaking related emergencies any time outside normal working
hours.
Recently instances of caretaking emergencies are low, at between five and eight call outs
a month. It is envisaged that with the correct routing of emergencies, an 15% increase n
the number of tenancies covered and responsibility being taken for a large number of
sheltered schemes this service will become viable once the correct charging is in place.
It has bee calculated that the cost of the standby payments and shift
allowances to provide these out of hours services costs over £34,000 a year
(2008/09).
However to replace this team a figure of £39,000 to just lock 36 laundries has been quoted
plus contractors will have to be employed to cover emergencies. As we have said with the
correct charging this team will be more than viable and still have the capacity to undertake
other work.
There will be four teams of three mobiles who will work nights on a four
weekly rota.
When working days the following options could be considered
• each members works for a specific area as a member of that site based team
• each team of three works on specific projects e.g. restorative cleaning
• members cover for holidays and sickness as required and remainder of team
undertake restorative work
However our preferred option would be :• the work of the Mobile Team is enhanced
• restore the bulky waste collection and increase to include new premises to be
covered by the service
• undertake flat clearances
• internal window cleaning
• change communal light bulbs
• undertake tasks to ensure that sheltered schemes reach H & S standards
(these will be identified by site coordinators)
• weed spraying/removal
Out of hours service
As mentioned above, with an increase in the number of sites managed the
number of out of hours emergencies that the Caretaking service deal with
would increase. Also better understanding by EC staff should result in work
being correctly placed with the Mobile team.
There will be no need for the out of hours service to be provided by an external contractor.
Other work may be transferred from external contractors to this 'in house' team enhancing
it's cost effectiveness. With correct charging and work being kept 'in house' the Mobile
team could become revenue producing rather than being subsidised by the HRA.
Staff numbers
12 in 4 teams of 3.
Financial considerations
It is important to remember the following points
●
tenants are happy with the charge that they pay. In the survey they ranked the
charge they pay 10th out of 12 in importance. There has never been a move from
tenants for banded charging or a rebate.
●
Councillors have never given an undertaking to refund any money to tenants.
Although the draft review was agreed by the QOL committee, the focus of the
debate was around the number of resident caretakers. The body of the review was
not and should not be deemed as agreed by default.
●
The service charge should only cover additional services NOT those the tenant may
be deemed as having paid for through their Council tax or their rent. It should be
possible for additional funding to come from the HRA and the General fund.
Funding the Service
1. The Service charge should be banded as mention previously. With no
reduction in this charge in line with our Banded Charging proposals and the
addition of an extra 1000 properties charges raised should increase be
approximately 12% initially and then by a further 6% above that through our
proposed Banded Charging.
2. Management states that
Depending on the outcome of the Job Evaluation process these proposals will achieve a
saving to the Housing Revenue Account of approximately £475,000 and a surplus of
income over expenditure of £360,000 making a total reduction in the cost of the service of
£835,000. This saving will be realised at the end of year 3 after implementation of this
review.
The surplus of £360,000 would be returned to tenants.....
There will be no surplus over expenditure as this will be used to pay for additional staff but
still a saving to the HRA of £475,000.
This £360,000 will fund the additional 11 community caretakers we have proposed and go
in some way to support the Mobile Team.
Additional funding is available as follows●
additional funding should be negotiated for this work from the HRA and General
fund to cover the additional duties taken on by the mobile team
●
charge for clearing empty flats for EM
●
resuming the Bulky waste collection would attract back the £100k+ paid to Sita,
plus increased funding to cover additional sites
●
locking the laundries would free up the approximate £39k that would be need to
pay a private contractor
●
the window cleaning contract is valued at £50k
●
charge for light bulb replacement, weed killing/spraying, flat clearances
CONCLUSION
We feel that these proposals will :●
modernise the service
●
increase productivity
●
address customer concerns
●
increase customer satisfaction
●
resolve most potential HR issues
●
deliver savings to the service
STATEMENT C 2
Caretaking Review
You should be aware that a joint Union proposal for the future of the Caretaking service
has been submitted to Management and it has been included in todays HR committee
paperwork.
We can't help but feel snubbed that, although our proposal has been included in all
relevant documentation, we have never had a formal response and more to the point not
been given the chance to discuss or explain it.
This document was not put up as a distraction but as a solution to, not only our members
concerns but to the problems facing the service as a whole.
These proposals also addresses the aspirations for the service expressed by Helen
Holland last summer, which was supported by the Cabinet and the Council as a whole.
We would ask you to consider our proposals and feel that you will agree that they are a
viable solution to the resolution of the Caretaking review.
As I said we do feel slighted as we have not been given the opportunity to discuss our own
proposals with the Management Team, to explore it's merits, cost implications, impact on
tenants and how it will enhance the service.
As with any proposal we would have been happy to negotiate with the Management team
to try and come to an agreement that would provide the best service possible and an
equitable outcome for staff and tenants.
It is very interesting to note that during the current climate when management is being
restructured and reduced that in the Caretaking Service the opposite is happening. We
currently have 120 staff and 8 supervisors/managers, we will have 89 staff and 21 site
coordinators/managers. In effect moving from a ratio of 15 :1 to 4.5:1.
The 'declining' point seems to be that our proposals would cost £400k and mean that the
tenants service charges could not be reduced is a red herring.
Firstly our proposals would eventually lead greater savings and an increase in income.
Secondly should we be looking at ways of reducing income? Rather we need to look at
redistributing costs and maintaining our current level of income.
I hope you feel that we have given you some valid point to consider and also that as a
Cabinet you would agree that the Executive member for Neighbourhoods, Cllr Price,
supports formal discussion around our proposals
Jeff Sutton
GMB
Pay Comparison Sept 2008
Residential Site Team Leaders
Salary
Current
£16,536
Residential
£2,973
Total
£19,509
Diff
Loss
Tied review
£1,112
additional
loss***
£1,500
BH
£418.00
weekend
£1,117
x f3+g3
total
£23,656
£22,156
Potential OT
Max
Weekends
Min
Site Co-ordinator
£18,430
£18,430
-£1,079
-£1,112
-£1,500
-£418
-£1,117
-£5,226
£0
£0
Snr Comm Caretaker
£15,470
£15,470
-£4,039
-£1,112
-£1,500
-£418
-£1,117
-£8,186
£3,762
£627
Res Snr Comm Ctkr
£15,470
£18,443
-£1,066
-£1,112
-£1,500
-£418
-£1,117
-£5,213
£3,762
£627
Community Caretaker
£14,197
£14,197
-£5,312
-£1,112
-£1,500
_£418
-£1,117
-£9,041
res Comm Ctkr
£14,197
£17,170
-£2,339
-£1,112
-£1,500
-£418
-£1,117
-£6,486
Total
£16,536
Diff
£418
weekend
£1,117
total
£18,071
£2,973
£2,973
Non Residential Site Team Leader
Salary
Current
£16,536
Site Co-ordinator
£16,536
£16,536
£0
-£1,117
-£1,117
£0
£0
Snr Comm Caretaker
£15,470
£15,470
-£1,066
-£1,117
-£2,183
£3,762
£627
Community Caretaker
£14,197
£14,197
-£2,339
-£1,117
-£3,456
Total
£18,443
Diff
Tied Review
£1,112
BH
£418
weekend
£1,045
total
£21,018
£15,470
-£2,973
-£1,112
-£1,500
-£394
-£1,045
-£6,957
£3,762
£627
£18,443
£0
-£1,112
-£1,500
-£394
-£1,045
-£4,051
£3,762
£627
£14,197
-£4,246
-£1,112
-£1,500
-£394
-£1,045
-£8,297
£3,452
£575
£17,170
-£1,273
-£1,112
-£1,500
-£394
-£1,045
-£5,324
£3,452
£575
Non Residential Community Caretaker
Salary
Residential
Current
£15,470
Total
£15,470
Diff
weekend
£1,045
total
Snr Comm Caretaker
£15,470
£15,470
£0
-£1,045
-£1,045
£3,762
£627
Community Caretaker
£14,197
£14,197
-£1,273
-£1,045
-£2,318
£3,452
£575
Standby
£1,864
Total
£19,557
Diff
weekend
£0
total
£0
£0
Residential Community Caretaker
Salary
Current
£15,470
Snr Comm Caretaker
£15,470
Res Snr Comm Ctkr
£15,470
Community Caretaker
£14,197
Res Comm Ctkr
£14,197
Residential
£2,973
£2,973
£2,973
Mobile Caretaker
Current
Salary
£16,536
Shift
£1,157
Site Co-ordinator
£18,430
£18,430
-£1,127
£0
-£1,127
Snr Comm Caretaker
£15,470
£15,470
£4,087
0
£4,087
Community Caretaker
£14,197
£14,197
£5,360
£5,360
Page 1
Future Weekend proposals
*Max = every weekend
*Min = 1 in 6 weekends
*Level will be dependant on number of volu
*Minimum staffing = 15 working 3 hours on
*Weekend working paid as Contractual ove
and above any protected salary
Pay Comparison Sept 2008
***based on actual
cost as
opposed to
pension
figure of
£3,990
Page 2
Pay Comparison Sept 2008
nteers
sat & sun
ertime over
Page 3