Comments on the reference project for Procurement of Long Term Waste Management Treatment Facilities.

 

 

Friends of the Earth are extremely worried by the selection of a mass burn waste incinerator as the reference project for Leicestershire residual waste procurement PFI. I have outlined some areas of concern requiring further scrutiny.

 

Executive summary

 

 

 

 

 

 

 

 

Options evaluation & deliverability

 

The selection process gave each option a score based on a supposed large number of criteria. Unfortunately the process required a large number of subjective judgements to be made by waste officers or consultants who only seem interested in building as big an incinerator as possible.

 

We have finally obtained the scoring used for the 19 original options and assume the same bias is used in studying the final 9 options in detail.

 

Each of the 19 options had a score out of a possible 128. Between 1 and 4 points are given to the recycling rate. Inexplicably, only between 2 and 8 points are given for Environmental impact - carbon footprint given that reducing the County’s carbon footprint is the main aim of diverting waste from landfill.

 

The rating for deliverability is allocated a massive 24 points. This has been very narrowly defined in terms of the technology being mature in the UK. This rating ignores real world deliverability issues. A Mechanical and Biological Treatment (MBT) facility is currently operating in Leicester demonstrating how MTA facilities showing that they can be built relatively quickly and cheaply. In contrast many of the large mass burn incinerators have failed to get as far as construction. A good example was the proposed incinerator in Norwich, which got as far as preferred bidder for the PFI, before being dropped altogether .

 

The planning risk of building an incinerator was also down played. Extremely vocal protest groups are formed where incinerators are planned. These are now networking Nationally to share expertise. It is likely that an incinerator, which does not meet the EU efficiency targets for use of heat would not secure planning permission. It will be extremely hard to find a suitable place in Leicestershire to make use of so much heat in one location that would also meet the other restrictions on locating an incineration facility (e.g. well away from residential neighbourhoods, away from regeneration areas, etc.).   .  

 

Extracts from the East Midlands Waste Strategy (whole document available from http://www.emra.gov.uk/waste/Documents/RWSfinal_Jan06.pdf)

 

Although the technical report favoured an approach based on high levels of incineration, after further consideration – particularly on the issue of the realworld deliverability of such an approach - it was agreed that the RSS should be based on a revised scenario: to reduce waste arisings working towards zero growth in waste from 2016, to exceed government targets for recycling and composting and take a flexible approach to other forms of waste recovery..

 

Principles of the Regional Waste Strategy (Policy 38, RSS)
Working towards zero growth in waste at the regional level by 2016
Reducing the amount of waste sent to landfill in accordance with the EU landfill Directive Exceeding Government targets for recycling and composting, with the objective to bring all parts of the Region up to the levels of current best practice. Taking a flexible approach to other forms of waste recovery, on the basis that technology in this area is developing very quickly and is difficult to predict over a 20 year period.
 
Policy RWS 5
All local authorities in the East Midlands, working with Regional and local partners will:
a) Adopt waste prevention as a first priority in Municipal Waste Management Strategies
b) Seek to exceed statutory, nonstatutory and best value performance targets for the re-use, recycling or composting of municipal solid wastes, embracing opportunities for crossboundary
regional and sub-regional working to ensure economies of scale are achieved
c) Ensure that residual MSW that cannot be recycled or composted is managed in a sustainable manner in accordance with the waste hierarchy.
 
Policy RWS 13
Regional and local partners should promote the research, development, trial and long-term adoption of alternative, novel and emerging waste reduction and treatment technologies in the East Midlands, where improved valorisation of waste and reduced environmental impact can be clearly evidenced in accordance with the waste hierarchy.

 

Waste growth

 

Waste growth projections seem exaggerated by waste management consultants who have an obvious investment in making the problem appear as big as possible.

 

Leicestershire councils currently have a generally good recycling and composting rate. At 41.29%, the combined rate for the county council is 5th best out of the 34 county councils in England. It is also clear that the rapid increase in the total amount of waste is now over. In total municipal solid waste (MSW) in county has barely risen in the last 4 years.

 

Analysis of MSW in a shire counties shows that a sizeable fraction (25%-35%) is garden waste. The tonnage of garden waste varies greatly over the year and between years. Some councils have introduced separate collections for garden waste which has lead to some extra waste being collected. This can be seen as the jump it waste per head in 2004/5 as new services came online. The amount of waste per head of population in the county was 530Kg in 2001/2, peaking at 568Kg in 2004/5 and felling back to 536Kg in 2006/7.

 

The Leicestershire Municipal Waste Strategy projected a  rate of waste growth over the next few decades that are already wildly inaccurate. The procurement process has scaled this back but expects growth for the next years to decline slowly from 2.2% to a long-term growth rate of 0.8% per year.

 

The original LMWMS is based on excessive waste growth forecasts, in part due to the waste spike from starting garden waste collections. The reference project still forecasts a step rise in waste that slows.   Taking the last 5 years waste has grown with the rise in population. Taking the last 3 years waste is falling. It is probable that the total MSW will remain between 350,000 and 400,000 over the period of the LATS targets i.e. up to 2020.

 

Worst practical environmental option

 

The County Council has been unable to provide a detailed report of 9 more closely studied options or to provide the risk analysis. We can only guess most of the details of what was studied. It seems that the proposal is for a single 186,000 tonne per year mass burn waste incinerator. This was modelled that the MBT options would take 7 years and an incinerator option 8 years to come on line. Due to its lower funding requirement an MBT type of solution could come on line more quickly. If use was made of around 90,000 tonnes of excess capacity at the Leicester city MBT some of the waste could be diverted from landfill in less than 2 years.

 

The consultants, Entec claim to have done a study using the WRATE computer model developed to compare the impact of different waste treatment options. The MBT options have far better scores than the mass burn waste incinerator, especially when the incinerator is used for food waste. Presumably, that this study assumed that the incinerator would be able to make full use of its waste heat. It is also an unrealistic assumption that the inflated size of the proposed incinerator would be the correct size. The other options can be easily expanded or scaled back to adjust to waste growth/decline. An incinerator will perform very poorly if too little waste is available.

 

The incinerator will produce more CO2 than all the other options. It will be claimed that much of that is from a non-fossil source. The other solutions will fix part of the overall carbon so having a CO2 benefit. It is probable that the incinerator will have a thermal efficiency of only 21%. That means only 21% of the energy liberated will be exported to the grid. The other solutions also extract more materials for reuse so reduce the energy used in extracting and producing new items from raw materials.  Aluminium is especially important in this regard as 27 tonnes of CO2 are saved for each tonne recycled.

 

Most costly option

 

Financing, biding, designing, planning approval, construction and commissioning of a mass burn incinerator is an extremely risky process. While it may be theoretically possible to do it in 8 years, most similar projects have suffered at least one major set back not accounted for in this over-optomistic forecast

 

We notice that extremely long timescales have been used for the studies. The waste growth has been projected out to 2035. The solutions are then compared on the basis of processing the inflated waste over the lengthy period. No analysis has been reported as to the cost of the waste growth being wrong (as will certainly be the case) for each option. This equates to projecting that the M1 will need 7 lanes each way in 28 years time and signing a contract to provide that capacity in 8 years time.

 

We cannot predict how much waste will exist in just 5 years time let alone 28 years. The cheapest outcome is achieved by building the correct capacity. Unless we have a time machine that cannot be done by building one monolithic incinerator. The Landfill Allowance and Trading System (LATS) does not require a one hit fix but a progressive reduction in biodegradable waste going to landfill. Leicestershire did have a strategy of adding residual treatment in several stages. That would allow the size of the second facility to be fine-tuned the capacity required by actual waste growth/reduction. If we assume we will be 20% out with our projections in either direction then building one oversized plant would represent poor value for money.

 

It is often reported that an incinerator around this size costs £100 million. In reality paying for it via PFI adds vast amounts of additional costs. On top of that the inflation rate in construction is high due to rocketing material costs and increased demand linked to the upcoming Olympics. The ability to obtain £50m must also be treated with caution. The DEFRA programme only has a few hundred million to spend nationally on the programme each year. Many bigger waste PFIs are planned that cost £1-3 billion each. Last year Nottinghamshire signed an £850m (27 year) PFI and obtained only around £38 million in PFI credit.  It should be assumed that the actual project cost will end up around £200m and that the level of PFI credit would be between £10-30million.

 

Obtaining PFI money to build an incinerator in the County looks very doubtful. It will give poor value for money as far as DEFRA goes. It is also likely to attract very few bidders due to its relatively small scale and to Leicestershire’s good recycling record. The big incinerator firms can only progress a few projects at any time. The mega contracts like Leeds and Manchester may mean that the County will have few credible bidders. Bidders are also keen to monitor the likely level of public protest. It has been estimated that public protest adds £12/tonne to the costs of incinerator projects. That would be £67 million over 30 years.

 

Conclusion

 

The County Council is being badly advised into making exactly the same mistakes make by Norfolk when it tried to procure an incinerator in Norwich. This is not surprising as the same consultants are being used. In the long-term going for something environmentally better than a mass burn incinerator will be the less risky and cheaper option. The existing MBT in Leicester could be the basis for a far cheaper distributed solution with a phased rollout.

 

It is very important that major £200 million projects are properly studied for their environmental impact by people outside the waste department.

 

 

Keith Kondakor

Waste Campaigner

Friends of the Earth – Midlands waste network.