What we are doing
We wrote to every member of the North London Waste Authority (NLWA), prior to their meeting on 25 September 2012, reminding them of the failure of their plans so far, and warning them of the imprudence of continuing with their proposed procurement. We urged them to consult the public properly, and to produce a new and more acceptable North London Waste Plan, capable of passing its Examination in Public as “sound”. Only then should a procurement be devised, to achieve the new plan.
Why are we campaigning against the present procurement?
The NLWA claims that its proposed procurement, committing over £4bn now to construct and run waste treatment facilities for the next 30 to 40 years, benefits from “economies of scale” and represents value for money. However, we point out that scale can produce economy only if that scale is known with reasonable certainty. If you build large scale capacity but fail to utilise the whole of that capacity, then the hope of economy of scale turns into the folly of over-investment. So is the proposed procurement just a NLWA vanity project, funded by the Council Tax payer?
North London’s waste procurement and other public procurement mistakes
There are worrying similarities between recent mistaken forecasts fed into the West Coast mainline railway franchise procedure, and the proposed waste plant procurement of the seven councils comprising the NLWA. In both cases, unrealistic forecasts, over too long a contract period, have led to unsound contract proposals. By coincidence (or not?) a cluster of recent news reports relate to further faulty forecasting: delegates at a recent road transport conference laughed at the Department of Transport’s latest traffic forecasts; Holland and Germany have overscaled their waste treatment capacity and are importing waste to pay for their misjudged investment.
Risky contracts based on unsound assumptions
Until recently, about half of North London’s residual waste was buried in the countryside (“landfill”), and the other half was incinerated in the elderly Energy from Waste plant at Edmonton. In the coming decades, North London must gradually reduce the amount going to landfill, so new provision must be made, and the Edmonton plant must be renewed in some form. When Holland and Germany faced similar challenges to modernise, they overbuilt new facilities. Today they both import waste to fill their unused capacity. We must learn from this: Eunomia consultancy reported in May 2012 that the UK as a whole has already commissioned over-capacity. Panicky building of overcapacity for 30 to 40 years hence is not the answer.
The authorities were warned about their unsound assumptions
The Sustainability Appraisal for the submitted North London Waste Plan (NLWP) was beset with warnings or caveats about the unreliability of the evidence on which the Plan was based. Just a few examples of the warnings inserted by the consultants who wrote it are:
Para 4.60 p 48 “The data reported here has relied to a large extent on subjective opinions … there are areas of the appraisal where the evidence base has a high degree of uncertainty.”
Para 4.61 p 49 “There are significant uncertainties in the existing baseline for waste management in the North London area”
Para 5.16 p 70 “There are substantial inconsistencies in the waste data available for the North London area. The data that are available vary in their origin, reliability and recentness.”
Our submission to the NLWP’s Examination in Public (EiP) in June 2012 highlighted, amongst other errors, the plan’s unrealistic forecast that residual waste would rise every year throughout its over-long contract period (30 to 40 years compared to the 15 years of the recently discredited railway franchise), its underestimate of waste site efficiency (only 62% of the recommended London throughput) , and its consequent reliance on three over-sized plants to manage North London’s waste .
At a time when waste management technology is rapidly changing, and the public and businesses are learning to prevent waste, reuse, and recycle, it is not possible to forecast far ahead. The forecasts made by the North London Authorities were so poor that for every iteration of their evolving plan, every couple of years or so, the authorities were forced to revise the starting point of their forecast substantially, and downwards. Yet they dogmatically continue to project residual waste as rising, claiming that growth in household or population will cause this.
What do we know now?
The most recent figures on population and waste trends for the years 2000-2010 are as follows:
Households in the North London Waste Authority area (census to census) rose by 10%.
Population in the NLWA area (census to census) rose by 15.9%.
For waste, we have been waiting for some time for figures for the decade from the NLWA, so meanwhile we are using the London figures.
Waste in London fell by 14.3%.
Think again before dragging us into a costly, harmful mistake!
We are not so naïve as to pronounce that this is now the trend. However, all existing policy is bearing down on waste creating and encouraging reuse and recycling. The North London Authorities have not modeled the cost or effects of this more probable variant.
The proposed procurement, relying on dubious claims of economy based on the questionable presumption of rising levels of waste for the next 30 to 40 years, would be risky, in conflict with waste reduction policy, and wasteful of scarce land, including the feckless despoliation of Pinkham Wood, designated a Site of Importance for Nature Conservation of Number 1 Borough Importance. This is a valuable open green space of 13 acres for the adjacent communities in Bounds Green, New Southgate, Friern Barnet and Colney Hatch Lane who all lack open space, according to official figures.
Our alternative plan for waste versus the “Guaranteed Minimum Tonnage”
We advocate building more local, smaller scale plant, nearer to where the waste is collected.
The bidders insist that the Councils must contract to pay for a “Guaranteed Minimum Tonnage” (GMT) of 70% of the forecast amount of waste. If the hard-headed waste contractors place no reliance on the forecast growth and, indeed, protect themselves against a reduction, is it not imprudent for the Councils to build plant for imagined additional residual waste 30 years in advance?
We say a rolling, incremental programme of local provision, scaled to the actual amount of waste that arises over the years, including the gradual reduction of reliance on landfill, is simpler, free of significant risk, and is a cost that can be justified to the public. It also minimises costly, traffic-congesting, polluting vehicle movements across North London, and ensures that every tonne of waste prevention saves us the cost of equivalent disposal. More than 40 waste-licensed sites already exist across North London, of sufficient total area, that can be reoriented to the task. Moreover there are existing merchant and municipal waste plants in London with spare capacity which ought to be taken up before any new land is taken for waste.
The Councils argue that the 70% GMT gives enough flexibility to ensure that we pay only for the waste that actually arises. We dispute that, because if waste continues to fall, as it has over the past decade, there will be less than this 70%, but we will be obliged to pay as if the contractors were processing the whole 70%.
Furthermore, the Councils, have not counted the amenity cost of the completely unnecessary destruction of the valuable, irreplaceable open space that is Pinkham Wood. They want to obliterate this nature conservation site with a waste facility sized at 300,000 tonnes per year. It so happens that this is the size of the unconvincing forecast increase or gap on which the contractors’ viability calculations place no reliance! And it’s entirely unnecessary.
NO WASTE PROCUREMENT WITHOUT A SOUND WASTE PLAN!
We have also produced a critique of the Outline Business Case of the NLWA, upon which their current procurement proposal relies, which you can download. You can also download our letter to NLWA directors regarding the procurement, sent in September 2012.