Cardiff Officers are pushing their Council to incineration

• – and taking Newport, Monmouth, Vale of Glamorgan and Caerphilly with them. The report to the Env Scrutiny Cttee of 10 July shows dubious methods www.cardiff.gov.uk/content.asp?nav=2872,3250&parent_directory_id=2865&id=1509
  
  Recall the background
• Phil Sherratt as Chief Waste Officer in mid-2004 promised to get to grips with Cardiff’s low recycling record and increasing waste (4-6% per yr he said); he would end black-bag collection via wheelie bins plus a green bag for recyclables (but collected only once a month); he’d go for new landfill capacity, seeing Lamby Way filling up.
  
• Sherratt in 2005 advised Cardiff to go for refuse-derived fuel, with outlets at Lafarge Cement works, Tower Colliery incinerator, Torfaen’s ReChem site incinerator, etc.
• This would fit with the 2004 SE Region Waste Plan (www.sewaleswasteplan.org/) for maximising recycling/composting and MBT on the remnants, because RDF would be the product of MBT
• Sherratt advised dropping RDF as none of the outlets available. Switched attention to replacement landfill capacity, with Lamby Way fast filling up with high income from commercial waste [1]. Said takes 5 yrs to commission a new landfill, so they need emergency options.
• Consultants commissioned to report on landfill options, which (as expected) raised public opposition
• Sherratt having failed to meet recycling targets, dropped RDF plans and failed on replacement landfill gets promoted to chief Transportation etc. officer.
  
  Now Cardiff find they will have to pay £11 M landfill costs and forgo £3M commercial waste income per year. The report says the landfill TAX element is refunded by WAG. But as this is not guaranteed, the big costs are retained to make a costly incinerator look good.
• Abandon plans for a new landfill, despite admitting any strategy needs landfill [1]. The need is for 25% landfill post-treatment (eg. diversion from incineration and ashes produced in incineration), yet no mention made of this large quantity, nor the high costs of transport and dumping elsewhere, nor the proximity principle requiring landfill.
• Plan for 3 to 5 times the incineration capacity “needed”, 300-400 000 tonnes per year. This compares with 300 000 t/yr from the four (plus maybe 50 000 Caerphilly) half or more of which should be recycled, 20% food waste that should go for AD (Cardiff is buying in-vessel composting) so residual waste even on rough figures would be ~100 000 t/yr (unattractive for commercial incineration – the Viridor scheme talks of 500 000 t/yr [2]). Their models apparently include waste increasing by 1.5% per yr, on the basis that increases have been “in the recent past by as much as 1.5% in the past”! The “current requirements of the wider region” (para.49) tacitly admits they intend to import waste to their giant incinerator.
• claim that all the authorities are “delivering and proposing new options for high recycling and composting figures” (when Cardiff was bottom at ~10% [3]). WAG’s Capital Access Fund is conditional on good performance in recycling etc., hence this claim. The document claims not to understand what WAG’s 25% limit on incineration means (para. 35) – clearly means no more than 25% of the 350 000t plus growth.
  
• invite proposals to build a ‘facility’, but make MBT plus landfill impossible (or impossibly costly), by dropping plans for a new landfill on the excuse that it would take 5 to 10 yrs (yet the ‘facility’ is timed for 2013). In fact, the fall-back tipping option appears to be an “overtip” on Lamby Way, to which there were “no fundamental objections”.
  
• the impudent name “Prosiect Gwyrdd” is chosen on the basis that greenfields are not ‘consumed’ or methane produced (para. 26), with no mention of air pollutants and toxic ashes.
• the figures imply the VoG would have immense tonnages of untreated biol degradable waste (BMW) of 26 500 t (10 000t over limit) by 2013 – I suspect inflated or worst case by the Vale’s pro-incineration officer.
• no “maximum recycling” option has been considered, just a “do minimum” and pay fines at £200/t, yet clearly recycling is much cheaper (Newport WasteSavers are at ~£50 /t)
• with the biased options, incineration comes out “cheaper”, though still with a £20M /yr “affordability gap” (£3M from VoG). That “MBT” is a further ~£15M /yr is curious, as in other places (eg. Oxford) MBT came cheaper. It may be that the procurement outline was oriented to Hampshire’s (the infamous ‘Integra’) which has huge incinerators; or maybe that the bidder was required to transport MBT-product way out of S-E Wales.
  
  [1] the mid 2005 assessment (Env. Scrutiny Cttee 14 June) said “Cardiff will continue to require landfill capacity indefinitely for some proportion of its waste, regardless of what action is taken to process residual waste. … A replacement landfill facility will need to be in place and operational by the time Lamby Way is full.” “Regardless of which of the available technologies (for waste treatment) are adopted, it is likely that a residue of approximately 25% of current waste arisings will still require disposal at landfill.” Treatment options were: Incineration; Gas Pyrolysis; Anaerobic Digestion; MBT or BMT; Autoclaving; Composting.
  
  [2] On the previous Ocean Technical Glass site in Cardiff Bay. An industrial site with ‘clean’ business would now go for the dirtiest type. Battle lines drawn over £150m Cardiff incinerator LetsRecycle 15-06-2007
  www.letsrecycle.com/do/ecco.py/view_item?listid=37&listcatid=217&listitemid=8850
  [3] Cardiff’s policy agreement with WAG adopted the minimum targets in the SE Regional Plan with “at least 25% recycling/composting by 2006/7. In mid-2005, Cardiff projected 12% recycling and 8 % composting, so planned to fall short of the WAG-agreed target. They now talk of 30% in 2007/8, but not the 40% WAG-agreed target for 2009/10. The Council Leader Rodney Berman gives 50% by 2013 in his defence against the rush to incinerate (http://cardiffincinerator.blogspot.com/). Cardiff have made two bad choices – wheelie bins that are known to generate high amounts of waste, and collection plus machine separation of mixed recyclables, which is known to give high levels of contamination and discards.
  
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  Information via WAG/Andy Rees 3 Sept 07
  The Capital Access Fund applications are being assessed this month (September) by his unit (ANNEX)
  The Minister is keen on increasing recycling to the maximum
• they are looking at the achievement in Flanders and may choose 70% recycling
• they say it’s essential not to create surplus incineration capacity and are looking closely at Cardiff’s 400 000 t/yr claim
• Cardiff could claim they intend to recycle incinerator bottom ash, if they limited toxic metals etc. (though this is inflexible as bottom ash may be reclassified as hazardous waste)
  
  Priority items for the Capital Access Fund are # AD plus collection system # auto-sorting of plastics
  
  Andy Rees is unsure about requiring a coherent plan that includes sufficient landfill capacity (for 10 or 20 yrs). Newport has ~15 yrs capacity at Docks Way for its own waste
  
  The Regional Waste Plan 1st Review
  A document for consultation will be published in 2007-08.In March 2006 the Members Steering Group agreed a document scoping the RWP 1st Review entitled ‘The Regional Waste Plan 1st Review – Content & Approach (777k)’, proposing two principal elements:• A Regional Waste Strategy which sets out a preferred mix of waste management / resource recovery technologies and capacities for managing the forecast arisings of all controlled waste streams.• A spatial element that guides the location of new facilities.
  
  The Regional Waste Strategy will be formulated by generating a number of alternative strategic waste management ‘Options’. The Options will then be assessed for their performance against various environmental, social and economic criteria using a Lifecycle Assessment tool that will feed into a wider Sustainability Assessment, a Strategic Environmental Assessment (SEA), a Health Impact Assessment (HIA)
  
  ANNEX – details of the Capital Access Fund, evaluation criteria and guidelines.
  
  RCAF/07/C
  ASSESSMENT AND EVALUATION CRITERIA
  
  The following are the assessment and evaluation criteria against which applications will be scored.
  
  1 The proposal meets the aims of Wise about Waste, including its promotion of sustainable development (maximum 10%)
  
  2 The proposal meets one of the requirements below (maximum 25%).
  
  a. a plastics autosorter to sort plastic bottles, including plastic bottles from the municipal waste stream in Wales;
  b. vehicles, plant and equipment for the collection and treatment of food wastes, including municipal food wastes in Wales;
  c. capital work preparatory to the development of facilities that derive energy from waste – including support for procurement of capital assets up to a limit of £200k in any one case. Local authorities should clearly identify the revenue element that they are committing in support of procurement.
  
  3 For energy from waste facilities, estimated quantity of MSW the proposal will divert from landfill (as % of total municipal waste arising in the areas of all the collaborating LAs) (Maximum 20%).
  
  > 60% of total MSW (10%)
  40 to 60% of total MSW (15%)
  < 40% of total MSW (20%)
  
  4 For a plastic bottles autosorter/washing plant and for an anaerobic digestion plant, estimated quantity of each specific, relevant, waste stream to be diverted (as % of total of that waste stream arising in the areas of all the collaborating LAs). There must be a minimum of two collaborating LAs. (Maximum 20%).
  
  30 to 40% of the specific waste stream (10%)
  41 to 50% of the specific waste stream (15%)
  > 51% of the specific waste stream (20%)
  
  5 The proposal contains evidence that markets have been identified for the energy, recyclate or compost from the proposed facility. (Maximum 20%).
  
  Potential markets have been identified and quantified (maximum 10%)
  
  Markets have been identified and quantified and there is evidence of support for the application from potential customers (15%)
  Markets have been identified and quantified and there is evidence of commitment to contracts from potential customers (20%)
  
  6 The proposal includes all the funding required to develop the proposed facility. (Maximum 20%).
  
  A business case identifying potential funding sources, including eligible grants, loans and assets/finance held by the applicant (10%)
  
  A business case identifying confirmed funding sources, including eligible grants, loans and assets/finance held by the applicant (20%)
  
  7 Does the proposal include the co-management of municipal, industrial and commercial waste (in a State Aid compliant manner)? (If yes, 5%)
  
  8 Proposals must be State aid compliant and fit with a current scheme or block exemption. If a proposal does not, consideration will be given to notifying the proposal to the European Commission and a case needs to be made for the State aid proposed.
  
  CAF/07/D
  GUIDELINES FOR THE REGIONAL CAPITAL ACCESS FUND (RCAF)
  
  Purpose The Welsh Assembly Government will establish a Regional Capital Access Fund (RCAF) to support the procurement of waste management infrastructure by local authorities. This paper sets out the outcomes the Welsh Assembly Government wishes to achieve and the guiding principles for the fund.
  
  The provision of capital grant funding will help:
  · secure private sector investment
  · stimulate interest from private sector waste management companies including the community sector
  · lower the level of private finance borrowing and hence reduce interest payments (which are usually factored into gate fees)
  
  Objectives
  The Assembly Government’s objectives in relation to the RCAF are:
  · to ensure that the waste infrastructure necessary is provided to meet EC Directives and Assembly Government Waste Strategy targets
  · to ensure that the most sustainable solutions are delivered for the management of waste in Wales particularly in respect of municipal waste
  · to ensure that the most cost effective solutions are delivered at least overall cost to the public purse particularly in respect of municipal waste
  · to encourage and support collaborative working by local authorities in order to provide economies of scale and reduce costs for the management of municipal waste
  · to ensure as far as possible the co-management of municipal, industrial and commercial wastes in order to provide economies of scale and reduce costs for the management of municipal waste and provide sustainable and cost effective solutions for the recycling, recovery and disposal of industrial and commercial wastes
  · to operate a capital grant system to support and incentivise the further development of an efficient and effective waste management infrastructure in Wales, in line with EC State aid rules
  
  General guidelines for the Regional Capital Access Fund
  The following principles will guide the RCAF:
  · the development and operation of high technology waste management plants is a complex and highly skilled operation that is best performed by organisations with a long track record of developing and managing that particular technology
  · such experience and expertise is only provided by the private sector
  · funding under the RCAF will be available i) to private sector organisations or ii) to consortia of local authorities to award to private sector organisations for projects procured by the consortia by competitive tender
  · bids by local authorities for funding for projects should be made by a consortium (or designated lead authority on behalf of a consortium)
  · bids should be accompanied by a detailed implementation plan including outputs, contribution to landfill diversion targets, details of costs, funding arrangements, amount of grant required and reasons for the amount and details of the grant profile
  · grant paid via a local authority will drawn down by the consortium (or designated lead local authority) to be paid to the successful tenderer against agreed project milestones
  · Welsh Assembly Government will confirm in principle whether or not it can make grant available including confirming it is within the scope of the relevant State aid approvals (see below)
  · payments will be made quarterly in arrears by means of a standard invoice
  · grants will not be paid in advance of need
  · if grant is not drawn down in line with the profile in one year the grant for that year will be reduced. It is not usually possible to carry sums of grant over from one financial year to the next and grant not drawn down in any one year may be lost to the RCAF and to the project. It is at the discretion of the Welsh Assembly Government whether to increase the grant for the following year to compensate
  · grant will only be offered for projects which help to deliver local authority targets for municipal waste and meet the policies and priorities of the Wales Waste Strategy including EU landfill diversion targets
  · grant will only be awarded for projects which involve collaborative partnerships or joint solutions for groups of local authorities or serve more than one local authority area
  · in order to meet landfill diversion targets for 2010 priority will be given to projects for recycling and composting/AD of the source separated fraction
  · in order to accelerate landfill diversion of residual non-recyclable waste, and given that given that public funds will always be constrained, priority for grant will also be given to plant which addresses residual waste disposal including energy from waste
  · priority will also be given to projects with the potential capacity to deal with industrial and commercial waste
  · in addition to energy from waste plants some further example of projects which could attract capital grant support are set out in appendix A
  · the Welsh Assembly Government will enter into discussions with private organizations and local authority consortia about the availability of grant from the RCAF with immediate effect
  · standard Welsh Assembly Government grant terms and conditions including claw-back will also apply
  · the RCAF will be administered by the Waste Management & LEQ Unit, Department for Environment, Planning and Countryside, Welsh Assembly Government
  
  State Aids
  The Welsh Assembly Government must ensure that financial and other assistance it provides to organisations involved in economic activity is state aid compliant. Most direct capital support grant schemes for undertakings operating in the waste management market are likely to constitute State aid and will require the necessary Commission approval before the aid is granted, either by ensuring that it complies fully with an existing approved scheme or a block exemption or by notifying the aid separately to the Commission.
  
  Many of the existing European State aid rules are based on allowing (limited) aid to undertakings, in recognition of the failure of the market to deliver optimal solutions in specific activity areas. There may also be distinct market failures affecting the delivery of waste management activity in Wales that are not covered under the existing State aid regulations. Where such a market failure can be identified and evidenced, and it is considered appropriate to provide support to address that market failure, there is scope to notify such aid schemes to the Commission for direct assessment of compatibility under the Treaty.
  
  As a general principle, for aid to be deemed to compatible it must aim to induce an undertaking to do something they would not otherwise do under normal market conditions. The aid must be necessary to offset some economic, regional or structural handicap and must therefore be justified in relation to specific Community objectives. State aid should only be used when it is an appropriate instrument for meeting a well defined objective, when it creates the right incentives, is proportionate and when it distorts competition to the least possible extent.
  
  The capital grants will aim to:
  · provide direct investment in undertakings in support of developing the internal market for the provision of waste management activity
  · provide investment and incentives in support of specific market failures for example, where there is an uncertainty in the return of a specific type of new investment; the risks and costs associated with obtaining and using appropriate waste materials or the negative prejudgements with consumers of products made from recycled materials
  
  There is potential scope to provide support for a capital grant scheme for the development of waste management infrastructure and market in line with the following State aid cover
  · SME Block exemption, which allows aid to be given to small and medium sized enterprises towards investment in tangible assets
  · Regional Aid Block Exemption, which provides cover for transparent investment aid schemes to support new productive investments in Assisted areas
  · Extension of State aid N412/2005 (subject to WRAP, DTI and Commission agreement), a notified scheme established by WRAP, which provides cover for a capital grant scheme established to increase the recycling of waste by subsidising investments by private companies in recycling facilities where there is an identified market failure
  · Direct notification of a scheme or individual award of aid to the Commission for assessment and approval either under the Regional Aid Guidelines or directly under the Treaty as appropriate
  
  Further consideration will be given to the appropriate State aid cover and the administrative requirements necessary once the detailed delivery mechanisms for the grant support scheme are identified and confirmed. It will be essential for local authority consortia to discuss proposals at the earliest opportunity with Welsh Assembly Government.
  
  Funding for the Regional Capital Access Fund
  
  Funding for the RCAF was identified in the Sustainable Waste Management Grant (SWMG) letter for 2006-07 sent to all local authorities in July 2006. The fund is £7 million in 2007/08 and £9 million in 2008/09. In addition £1 million will be made available each year as part of the scheme to support local authority procurement work.
  
  Other Welsh Assembly Government Grant Schemes
  Other Welsh Assembly Government capital grant schemes to support the development of municipal waste management infrastructure (not including RSA/AIG) are:
  · the Waste Strategy budget – there are funds available for capital projects such as the Regional Compost R&D and Demonstration plants
  · Sustainable Waste Management Grant (SWMG) - paid annually to local authorities to support additional activity on recycling and composting (largely used for revenue support, but can be used for capital funding of facilities such as household waste recycling centres, composting plants or material recovery facilities)
  
  In respect of industrial and commercial waste, grants are available from the Materials Action Programme (MAP) for Wales. The MAP grant programme is run in Wales by WRAP under the terms of previously notified State Aid schemes.
  
  European Funding
  The draft Strategic Framework for Waste under the Convergence Fund 2007-2013 contains a key fund to provide capital funding. It is also proposed that the Competitiveness Fund will also be used to support waste management.
  
  Department for Environment, Planning and Countryside
  March 2007
  
  
  APPENDIX A
  PRIORITY PROJECTS FOR CAPITAL GRANTS
  The following projects are priorities for capital grant to reflect policy priorities within Wise About Waste.
  
  A plastics auto-sorter: a plastics auto-sorter is an essential strategic facility. A single auto-sorter can serve the whole of Wales, since the reprocessors are located in different parts of Wales, from which feedstock may be collected from clusters of local authorities. In addition to an auto-sorter, some washing is required to prepare the plastic for sale into the market.
  The strategic advantage of this is the creation of secure and stable markets for separated plastic polymers, which will encourage Welsh local authorities to recycle this material. It is the recycling of plastic bottles that will reduce the volume of waste collected from households more significantly than any other recycling (for the majority of households). This will greatly assist in helping the move to fortnightly collection of municipal wastes, since the issue of volume capacity will have been largely addressed.
  
  Anaerobic Digestion plants: two strategically located anaerobic digestion plants would be able to treat separately collected food wastes from the majority of Welsh local authorities. Evidence from, amongst others, the Waste and Resources Action Programme (WRAP) is that the most cost effective way of meeting composting targets is to separately collect food wastes (weekly) and to treat them in an AD plant, to recover energy. The digestate produced can be used for lower specification applications, eg silviculture.
  
  Providing treatment plants with a gate fee less than landfill gate fees is a key to encouraging this aspect of the waste strategy. AD is well placed in this respect because of the revenues from the sale of energy.
  
  Vehicles/receptacles for separate collection of food wastes: the treatment of food wastes is dependent upon a system of collection that can provide the food waste feedstock to the AD (and other) plants. Food waste collections can take place as part of weekly dry recyclable collection, as separate collection or co-collection with other wastes. To optimise the collection of food waste, new vehicles will be necessary to facilitate extensive weekly collections.
  
  Consultancy and preparation of thermal treatment facilities: it is very unlikely that any local authority will be able to spend money on thermal treatment or disposal facilities in the short term. However, consortia of local authorities are likely to be engaged in procurement, land acquisition, Environmental Impact Assessments, planning applications and other activities for such facilities. Provided that these activities, which are essential to progressing thermal treatment facilities, are capable of being classed as capital activities, then they will be an important aspect of the RCAF.