The Cardiff report smacks of desperation and looks like an attempt to steamroller a dodgy proposal through as quickly as possible before anybody checks their maths. It may be easy for them to blame the assembly but wasn’t their original timeline to complete the Outline Business Plan by December 2007 and to put the advert in the OJEU by March 2008 [1] but they still say it isn’t finished yet and now won’t go into the OJEU until Mar 09. In which case isn’t it really the project team and their (£ 250,000 + to date) consultants who are to blame for the full year slippage to date? And if the project can slip a full year between the July 2007 Cardiff Council Executive meeting and now what are the realistic prospects for it being delivered on time and to budget in the longer term?
Obviously the final draft OBC raises a lot of questions. Why, for example, have they placed so much emphasis on landfill penalties (at £ 200/tonne [2]) in the letter to Jane D, and in the OBC, when all the authorities will meet the Landfill Directive Diversion targets through complying with the National recycling targets?
The growth rates are unrealistically high – and a quick check shows the total MSW has fallen again in each of the authorities. The argument they use (in Appendix 4b and not 2a as they incorrectly reference in para 2.3.2) is a silly one:
“there is concern with basing projections on the high negative growth seen over the last few years, at is not completely understood how this reduction has come about. It would be more prudent to base projections on a higher growth rate in early years”The ‘prudence’ together with the reduction of the recycling target by 5% means they are pitching for 35% of 575,000 tonnes - which they then add another 10% to, presumably for ‘prudence’ to justify 220,000 tpa.
Prosiect llwyd is not necessary to comply with European targets and adds only 1.2% [3] to recycling – and that is low grade post incineration steel which could be recovered with higher quality at a landfill with a magnet. It is therefore difficult to understand why it is considered so important to concentrate on this residual waste project at this stage as it seems to requires a rather perverse mentality to prioritise this rather than the the main event of meeting the recycling targets,
A more realistic assessment of the residual waste need would, in any case, be 30% of 500,000 tonnes ie 150,000 tonnes. The proposal is therefore probably 50% too big with profound impacts on the costs assessments. This is a shoddy way to play with £ 1 billion of our money.
Even the proposed option with ash recycling would still need landfill for 36,500 tonnes of rejects; 6,300 tonnes of hazardous APCD residues (table 4.4). They should also add the requirement for at least half the bottom ash to be landfilled as this is the level being achieved in Hampshire. If we can demonstrate that the bottom ash is hazardous then even more would be landfilled. Thus the total landfill requirement of the Project would be 42,800 + 16,650 = 59,450 tonnes. The reduction in landfill compared with do nothing thus reduces to c. 90,000 tonnes. These corrections would make a large difference to the cost assessments.
The WRATE assessment is typically awful, but as expected given the fundamental flaws and limitations of the model.
The report has far too much redacted information
[1] Cardiff Council (2007). EXECUTIVE BUSINESS MEETING: 5 JULY 2007 MUNICIPAL RESIDUAL WASTE TREATMENT REPORT OF CORPORATE DIRECTOR AGENDA ITEM: 8 PORTFOLIO: ENVIRONMENT & TRANSPORT Prosiect Gwyrdd procurement.
[2] I think it will be difficult in any case for Wales to maintain the threat of a £ 200 penalty given that the English financial penalty was reduced to £ 150 by Environment Minister Elliot Morley on 9 December 2004 “as part of a package of measures designed to ensure that local authorities have the flexibility to meet challenging targets for the diversion of biodegradable municipal waste from landfill without increasing pressure on council tax”. It follows that landfill will never reach £ 200/tonne when LATS penalties are set at £ 150 in England – authorities would simply pay the penalty or export the waste to English landfills where the LATS can be traded and the market price for landfill would be below £ 150.
[3] The 1.2% is for metal recovery. More worrying is the comment at: 4.4.16 “It has recently (although unofficially) been suggested by the Assembly Government that bottom ash recycling may count towards future recycling targets”. This could add another 5.2% they claim – this is wrong because only half the ash is likely to be recycled and it is, in any case, an approach that has recently been rejected in England.
Report to Cdf Exec on Thursday 4th
Municipal Residual Waste Treatment (Prosiect Gwyrdd) - Report (169k)
Municipal Residual Waste Treatment (Prosiect Gwyrdd) - Appendix 1 (2.87M)
�h Municipal Residual Waste Treatment (Prosiect Gwyrdd) - Appendix 2-5 (350k)
Note they have reduced the 70% recycling target to 65% and say the Eunomia report is still contested.
Will abandon Prosiect Gwyrdd if WAG does not guarantee funding by March.
Regional Waste Plans held up.
Extracts from the Report
． The review of 2002 National Waste Strategy has been delayed;
． The “Eunomia report” (September 2007) outlining the economic and
achievability assumptions was challenged and a further review of this
work has not produced a clear way forward;
． A review of Regional Waste Plans was completed; but a further
review is apparently planned to include relevant Planning Policies
under TAN 21;
Stakeholder Consultation
33. The principal focus of the Partnership thus far has been internal -
although the Project and individual authorities have engaged with
external stakeholders to an extent e.g. Friends of the Earth. The need for
comprehensive stakeholder/community group engagement is recognised
and similar considerations apply to neighbouring local authorities and other public bodies through established consultative mechanisms. A communications strategy will be the main vehicle for doing this and early outputs will include the establishment of a Prosiect Gwyrdd website which members are asked to approve as part of this report.
Procurement & Timetable
36. For the reasons explained above, this report does not seek authority for procurement to commence;
RECOMMENDATIONS
The Executive is recommended to:
(1) Approve the Final Draft Outline Business Case for submission to WAG based upon the affordability gap described in this report for a Residual Waste Treatment Solution predicated upon a technology neutral assumption.
(2) Agree that the Approved Outline Business Case will remain subject to three conditions:
(i) The Procurement being premised upon a) a publicly owned site
being made available to bidders and as such maintaining
discussions with the Welsh Assembly Government is necessary
until a public authority contractually commits to securing an option in the Project’s control and to note that this does not preclude a private owned site being brought forward by a bidder or b) the
Partnership and WAG become satisfied that adequate private sector competition is available;
(ii) The Welsh Assembly Government providing the Authorities
sufficient comfort that they will fund the Project to at least a
minimum level of funding over the life of the Project as per the Outline Base Case; and
(iii) The partner authorities also approving the Outline Business Case with the same conditions applying.
(3) Agree that if the three conditions in recommendation 2 above are not all
met by 31 March 2009, the approval of the OBC automatically lapses
and the Council will reconsider matters including alternative options
outside of the scope of Project Gwyrdd.
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