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front of pipe home > Stop this PFI (2005)

Cambridgeshire's PFI process is ineligible to proceed

The following evidence was prepared by James Greyson and provided to DEFRA on 1st November 2005. Despite follow-ups by James and David Howarth MP, DEFRA have yet to investigate or make a substantive reply. This amounts to a government cover-up of an unsustainable PFI which has proceeded without adequate democratic scrutiny either locally or nationally.

The PFI plans of all local authorities must meet the same non-negotiable criteria set by government ministers, as written on DEFRA's site.
http://www.defra.gov.uk/environment/waste/localauth/funding/pfi/criteria.htm
In September 2005 Cambridgeshire's plans became ineligible under three of the criteria, quoted in brown. The criteria must all be met for a PFI project to proceed so Cambridgeshire's PFI process should now be immediately and completely suspended. This move will provide Cambridgeshire County Council a much needed opportunity to revise its waste strategy and its plans for residual waste.

Proposals should make clear how schemes would cut waste as required under Best Value.

Cambridgeshire's waste strategy 2002 has no Best Value target for cutting waste generation levels, no waste prevention strategy, no waste prevention policy, no prevention analysis of waste streams, no prevention targets for key streams, no hazardous-waste prevention policy or initiatives, no public dialogue about waste prevention, no dedicated staff to coordinate waste prevention, no forum for discussing waste prevention opportunities, no mechanism for improvement in waste prevention policy or initiatives and no known plans for improving waste prevention. Despite commencing some small-scale initiatives it is clear that Cambridgeshire County are institutionally impervious to waste prevention and their preparedness to cut waste generation is negligible.

County planning and public awareness work implements the waste heirarchy in reverse, with recycling consistently prioritised above prevention. End-of-pipe disposal is being planned with 25 years of funding whilst a token prevention effort such as the nappy scheme, has just one year of funding. The County has never asked the public what it could do to promote prevention. The 2005 County 'waste strategy consultation' assumed that all non-recycled rubbish is non-recyclable which ignores the potential for improved recycling/composting. Non-technical residual waste solutions such as prevention of residual wastes were excluded from the County's strategy, and from both forms of consultation (meetings and leaflets). The consultation leaflet claims that the County is already 'maximising waste reduction' despite the above institutional failures. County predictions for MSW generation at 2020 have been raised by 22% since 2002 (note 1), in effect planning to fail to cut waste. This starkly conflicts with the regional waste strategy which provides for no increases at all in waste generation from 2010 (note 1).

The use of residual waste treatment options involving recovery should be considered and their use justified in line with the waste hierarchy and should demonstrate that there is no future barrier to reduction, reuse and recycling efforts

Spending on MBT will systematically undermine reduction, reuse and recycling efforts since funds lost to MBT investment will no longer be available to manage the same waste by prevention initiatives, by direct recycling of metals (with higher quality and value) and by local or municipal composting (since the organic fraction will be dried and converted into greenhouse gases by burning). The County are also likely to be locked into contracts which guarantee minimum waste volumes and/or minimum calorific value, which will further undermine the potential for waste prevention, composting and recycling of burnable materials such as paper, cardboard, fabrics, organic matter and plastics. Large investments in end of pipe technologies and waste burning send the wrong message to the public ("we are ready for all your mixed unrecycled waste") undermining all future efforts at public engagement on waste issues. Dependence on burning of wastes is deeply unpopular with the public and will seriously compromise the high levels of public engagement and participation which are needed.

The County's estimation of maximum recycling levels has been miscalculated by an error in addition. The table in section 2.2.5 of the 2002 waste strategy shows that a total of 83% of current waste was theoretically recyclable: 54% organic and 29% inorganic, which are mistakenly added together to give a potential recycling rate of 60%, 23% less than the correct total. This error has not been corrected since 2002 and in the 2005 consultations the County interchange the terms recycled and recyclable, which misleadingly suggests that anything which is not recycled is not recyclable. This serious error underpins the ludicrously low long-term recycling target of 50%. Although Cambridgeshire is already recycling over 45% of household waste, this is planned to increase to just 50% by 2032, with no improvement at all planned between 2010 and 2032. Over the coming decades it is highly likely that recyclability, awareness, participation and economic incentives will be vastly improved, allowing recycling rates above 83%. Since up to 83% is already technically achievable planning for a long-term maximum of 50% recycling is not valid or acceptable. The 50% limit exists only in the minds of County waste managers, not in reality. (2007 note: the Council mistakenly presented the 50% limit at a consultation event in 200. The PFI proposes a maximum recycling target of 60% which is expected to be achieved before the PFi starts handling waste in 2009/10, leaving the PFI with nothing to do towards recycling for 25 years.)

Using the County's own figures for recyclable and recoverable proportions of household waste (given in 2.2.5 of their 2002 strategy) it is clear that the viability of RDF production depends upon burning recyclable and compostable wastes. If the county recycle 50% of household waste, there is still 33% recyclable materials in the remaining 50%. Thus two thirds of the MBT input would be recyclable and only 16% is combustible but not recyclable. 78% of the recyclable materials entering MBT are combustible, so these would form the bulk of the RDF, under the County's plans. However if all recyclable materials were source separated and removed from MBT then the residual wastes would be only 47% combustible. Such low calorific value would be practically unusable as a fuel and would leave approximately two thirds of its weight as ash to be disposed to land. Hence the County's PFI bid is underpinned by needlessly restraining long-term recycling levels to 50%.

Consideration by the County of future barriers and future risks is entirely absent from both their 2005 waste strategy and from the 2005 waste strategy consultation. Major risk factors which have not been assessed include:
1. Reliance on an obsolete end-of pipe strategy, in which the waste heirarchy is interpreted as a slow creep away from landfill. Effort, ambition, staff time and funding are all allocated with the waste heirarchy in reverse. Waste reduction receives the least attention and least funding, being expected to make the least contribution. This is in conflict with regional, national, EU, OECD and UN requirements and guidance to prioritise prevention.
2. The relative speed of prevention and MBT/burning as tactics for residual waste. There are massive untapped opportunities for local preventive work, which can be implemented immediately with widespread public support. MBT/burning is very slow to implement and will be further delayed by strong public opposition, risking years of avoidable heavy fines for the County.
3. Burning wastes assumes that the growing national response to climate change will not bring higher costs and tougher controls on emissions from burning preventable, recyclable and compostable wastes. The County's energy-intensive and high-emissions plans are incompatible with Objective 3 of Cambridgeshire’s Climate Change Strategy which aims to reduce greenhouse gas emissions through better waste management. All the emissions now planned from waste burning are avoidable. All the resources which are burnt need to be replaced with new resources with an additional burden of energy and emissions which eliminates the small energy gain from burning waste. Even if the rules for Renewable Obligation Certificates are bent to allow subsidy of waste burning it is almost certain that as the response to climate instability grows the subsidy will be revoked.
5. The County's increasingly pessimistic estimates of future waste volumes do not account for the effects of known European producer responsibility, nor the benefits of future waste prevention directives and waste-related economic instruments. The County do not appear to have studied the generally available successes and best practice in waste prevention.
6. There is no provision for prevention or collection of household hazardous wastes, which is unlikely to survive future European directives and national requirements. Future obligatory separation of hazardous wastes from MBT inputs and incinerator outputs will massively increase operating costs and undercut viability of waste burning. Disposal to land of the hazardous ash from waste burning is already expensive and will become extortionate as government applies economic incentives to hazardous waste management, as required under EU directives.
7. The growing trend towards including end-of-life costs within product prices is not considered. This will stimulate prevention and provide new external funding for reuse/recycling. There is no equivalent trend to support disposal of wastes to the air.
8. Forthcoming improvements in national waste strategy, with greater emphasis, guidance and support on waste prevention. National waste PFI criteria may soon read, "The use of residual waste treatment options involving waste prevention should be considered...".
9. The possibility of a breakthrough in public attitudes and participation in waste/sustainable development, allowing reduced waste generation and more recycling. Every few years a replacement national programme is started; eventually one of these will take note of the first principle in waste management, the waste hierarchy.
10. Cambridgeshire have not properly considered the option of actually following their own strategy to pursue either of the strategy's preferred options of anaerobic digestion or gasification/pyrolysis. The latter option is particularly important since it already qualifies for Renewables Obligation Certificate support and is compatible with a future sustainable resource-generating economy, unlike waste burning. More local authorities made PFI bids for gasification/pyrolysis than for MBT.
11. The complete absense of any plausible vision for waste and resources in County waste management. Is it a sufficient ambition just to meet current rules and regulations (though this evidence shows the County are not doing even this) or could it help to develop thinking beyond business-as-usual and the throw-away society?
 

Proposals should demonstrate that other relevant authorities, the public, and interested parties have been consulted.

The County ran a public consultation in 2001 for their 2002 waste strategy. This strategy made specific undertakings to the public:
1. A waste forum would be set up. Three years later this appears not to have happened, effectively blocking a route for relevant authorities, the public and interested parties to bring in new ideas. (The County network for reuse and recycling does not serve this purpose since it excludes work on waste policy, research or prevention.)
2. A "small group of officers" would examine the area of waste minimisation and alternatives to the "end of pipe solutions" contained in the strategy (2.1.3). This work, if it was attempted at all, appears not to have borne fruit since the County have massively raised their expectations for waste generation (note 1).
3. Future decisions on residual waste would be led by the County Council, in line with a list of agreed preferences, which considered anaerobic digestion and "technically feasible" gasification/pyrolysis first and MBT/burning as a "last resort". In 2005 the County's leaflet consultation offers a wide range of technical options for residual waste. However the County's consultation meetings presented just the one option of MBT and senior County waste managers explained that only one option was available since contractors were offering just MBT. This indicates that the County have given away control of residual waste choices to contractors and that decisions have been taken well in advance of consultation. The consultation is thus merely a marketing exercise.

The 2005 Cambridgeshire 'waste strategy consultation' should have been run as part of the decision-making process for a review of the strategy and for choices on residual wastes. The 'consultation' consists of leaflets being delivered to 10 to 15% of the population and a series of meetings inviting selected people. The meeting I attended had only 10 participants, which may be due to the lack of any publicity or press releases to encourage attendance. Cambridge Friends of the Earth were not invited but local authority staff were invited, in their capacity as citizens. No press releases have been issued to invite public comment and the County website does not allow public input to this consultation. The leaflets and meetings for this 'strategy consultation' did not include any question about strategy; all questions were about delivery of services.

Consultees were not given the basic information on which a judgement about residual waste could be formed; the County has withheld crucial facts:
¥ The PFI process is well advanced, with tender invitations already issued.
¥ The PFI bid 'assumes' burning waste for energy (note 2) nor that this option was the 'last resort' option in the 2002 strategy (2.6).
¥ Estimates of waste volumes at 2020 have been boosted by 22% since the 2002 strategy, which makes expensive technical solutions appear more necessary.
¥ Better prevention, recycling and composting could manage most or all residual waste. The County consistently acts to disregard and suppress this option. It is worth noting that the chair of the consultation meeting chose to argue against the practice of waste prevention, rather than permit discussion to explore its scope. We were told that if we preferred other options besides MBT we could object when the facilities reached planning application.

In summary there was no valid public consultation about either waste strategy or residual waste choices in 2005. Opportunities for regular input of ideas to the County, via a public waste forum, waste policy networks or an electronic waste forum have been entirely missed. Critical changes to residual waste preferences and waste generation predictions have never been made public, which also invalidates Cambridgeshire's 2001 public consultation and the 2002 strategy.

Notes

1. County waste strategy 2002 (http://www.recap.co.uk/recapdocuments/thestrategy.html) Para 2.2.4. gives MSW at 2020 as 529426 tonnes. The County waste strategy 'consultation' 2005 used a handout prepared for Cambs County by Chris Brown which gives MSW at 2020 as 650000 tonnes. This 'shifting of goal-posts' was not discussed with consultees. The East of England Regional Waste Strategy http://www.eera.gov.uk/Text.asp?cat=128&id=SX11AE-A77F8F87 provides for no increases at all in municipal waste generation from 2010 (page 52). This makes Cambridgeshire's planning incompatible with regional planning.

2. The County do not admit that their planned MBT process will produce Refuse Derived Fuel (RDF) and have so far refused to disclose any documentation regarding their actual plans. However DEFRA's website discloses that Cambridgeshire's PFI bid "Assumes a central MBT-type facility which will extract recyclates and compostable organics and generate RDF for use in an appropriate third party energy recovery plant." http://www.defra.gov.uk/environment/waste/localauth/funding/pfi/pdf/cambridgeshire.pdf

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