In October 2010 York and North Yorkshire Waste PFI issued a Questions and Answers update which purported to answer popular questions and “misconceptions”. Below we compare NYCC claims with reality.
Why can’t we recycle more?
The Claim: NYCC say that they can and will recycle more and that the proposed Allerton Waste Recovery Park would help them do so by recovering as much recyclable material from our waste as it is cost effective to do so.
Reality: North Yorkshire’s recycling rate is approximately 45% and with use of the proposed MBT plant this figure is likely to reach nearly 55%. However NYCC cannot be seriously considering that recycling rates should remain below 60% for the next 25 years while the Governments of Scotland and Wales have already committed themselves to reaching 60% by 2020 and England is likely to go the same way.
The Claim: The proposal would complement the work being done by the York and North Yorkshire Waste Partnership on waste reduction and recycling activities. North Yorkshire already has a good recycling performance – currently at over 45%.
Reality: NYCC’s achievements on recycling are actually quite modest and compare badly with best practice. In the UK, South Oxfordshire has already achieved 70% while San Francisco has reached 75%, and many smaller communities in Europe have reached or exceeded 70%. The proposed incinerator plans will undermine the Waste Partnership’s commitments to reduction, re-use and recycling because of the need to continuously feed it with large amounts of waste to burn. If we want recycling above 60% then the proposed incinerator is not a suitable solution to diverting waste from landfill.
Why not make more use of the anaerobic digestion plant?
The Claim: The proposed Anaerobic Digestion (AD) plant can handle 40,000 tonnes of organic waste a year recovered through the mechanical sorting process. The residue from the AD will be used to power the Energy from Waste (EFW) unit because the input is mixed waste, so the material produced cannot be used by farmers or the public as compost or top soil.
Reality: The proposed AD plant is simply not of the design to produce useful product, though doing so is perfectly feasible. Indeed, this is done in other AD treatment processes in the UK, where the output can be used as a valuable soil conditioner ideally suited to land reclamation projects. There is a government protocol PAS 110 that allows AD residual to be used for such a purpose. Why is the proposed plan not allowing this to happen?
Will the facility handle commercial waste and charge for it? Are there financial penalties if the councils do not provide enough waste?
The Claim: As a waste disposal authority NYCC has a statutory duty to manage locally generated commercial and industrial waste collected by the Waste Collection Authorities. It is claimed that Council Tax will not be being used to subsidise commercial waste disposal – in fact it is the other way round. Any shortfall in waste delivery will be offset by commercial waste and Council is confident that there will be a sufficient amount available.
Reality: Simply, the incinerator is oversized and the council tax payer could face a bill for this error. There are commercial risks in trying to source commercial waste as it will be becoming a very competitive market as other incinerators are already competing for the limited resource i.e. Sheffield. NYCC seem not to have factored these risks into their simplistic economic case, nor acknowledged the possibility of penalties being paid if the incinerator does not get its regular ‘feed’ as Stoke-on-Trent found and face a £625,000 fine for just this year. Much depends on the terms of the contract which are shrouded in mystery under the blanket of commercial confidentiality.
What are the total costs of the proposed Waste PFI?
The Claim: The total estimated waste management bill which City of York Council and North Yorkshire County Council will face if they continue to rely on landfill is approximately £1.8billion for the period up to 2039/40. NYCC claim that the contract will give North Yorkshire and York residents a saving on future disposal costs, cutting their combined waste management bill by over £320 million over 25 years, based on the financial detail in the final tenders they received in October 2009.
Reality: The ‘saving’ (£320m or £12.8m per year on average) is in comparison to a ‘Do Minimum’ scenario. This means don’t manage, change or influence the current situation for 25 years and just assume all trends continue. No sensible commercial organization would be foolish enough to use this as their only baseline for comparison and to then use this theoretical ‘saving‘ as the major plank in their marketing.
Thus NYCC’s case rests on one analysis which uses some very risky, outdated and poorly researched assumptions, which when proven wrong, will cancel out most of the so called ‘savings’. Using more relevant and realistic data regarding future landfill tax, population growth and waste volumes, Marton- cum-Grafton’s report to the Scrutiny Committee concludes that ‘the PFI contract would be more costly than the Do Nothing option”.
There is likely to be a number of changes in national policies and technology over the next 25 years and we are not confident that the proposed plans allow enough flexibility to respond appropriately, resulting in further costs to NYCC. To our knowledge only the MT and AD plant is modular based and can be changed, leaving a majority of the plant inflexible to adapt to any significant future changes, like the possibility of food waste collection that is currently being considered by Harrogate Borough Council. We also believe there are a number of hidden costs not included, for example the cost of decommissioning the site, the impact of likely reduced subsidies, likely increase in transport costs and the cost of developing existing, and at least two new, waste transfer sites.
What happens to the ash produced?
The Claim: The waste treatment processes proposed for the Allerton Waste Recovery Park have two types of by-products: Incinerator Bottom Ash and APC residues. NYCC define IBA as the material which comes out of the grate at the end of the Energy from Waste (EfW) process. It is mostly a mix of ceramics, slag and glass although there might be small amounts of low value metals such as iron, steel, aluminium, copper and brass which can be extracted for recycling.
Reality: Ash is more complex than just two components. More importantly, NYCC fail to mention that it also contains some dioxins and heavy metals and there are concerns over its ecotoxity. These arise from October 2005 when the Health and Safety Executive reclassified zinc oxide (a potential compound in ash) as ecotoxic, joining zinc chloride and all lead compounds. We do not know what storage procedures will be used. However, leaching of hazardous and/or toxic materials could take place either from waste prior to it going into the incinerator or from any IBA left out for weathering. Leaching could include hazardous and/or toxic materials present in the rubbish and leachate could enter the local land and groundwater and hence affect people, crops and animals
What about impacts on the environment?
The Claim: AmeyCespa’s proposal will divert waste from landfill, which generates up to 40% of the UK’s methane emissions. Methane is more harmful to the environment than carbon dioxide and represents about 3% of the UK’s total greenhouse gas emissions.
Reality: This is an example of half-truths intended to give a misleading impression. The incinerator does divert waste from landfill, but only at the expense of dumping waste into the atmosphere in the form of various emissions. Many of these will eventually return to earth, affecting the land for many miles around the incinerator and have an impact on the environment. Incineration is the worst choice for climate change (Greenhouse gases, GHGs). Choosing it runs contrary to national policy on GHG emissions. While landfill emits methane (24 times more powerful as a GHG) it can be captured and burnt to produce energy. This means that implementing the proposed technology runs counter to the UK’s international commitments on climate change. The more accurate model used by Greater London clearly shows that there are many other alternatives than an EfW (as proposed for NYCC) that are better for the environment.
What about health impacts?
The Claim: AmeyCespa will have to submit a Permitting Application to the Environment Agency. Energy from Waste is a tried and tested technology and the emissions from Energy from Waste plants are subject to strict monitoring by the EA and if the plant failed to meet their criteria it would not get a permit to operate, or could have the permit withdrawn.
Reality: Monitoring of emissions of waste incinerators is not continuous but conducted via spot checks and often with the operator given advance notice and therefore able to ensure acceptable standards. Such sporadic monitoring means that the operator and the public might never find out about unintended periods of high emissions. So while the emissions from incinerators are subject to regulatory controls, this is not a guarantee that the standards set are adequate.
The Claim: Independently reviewed evidence shows no adverse health effects to people from living near incinerators (source DEFRA Waste Strategy for England 2007) and in its most recent report, The Health Protection Agency supported that view, saying that it did not recommend doing any more studies of public health around modern, well managed municipal waste incinerators “as the effects are probably not measurable”.
Reality: While UK bodies such as the Environment Agency and the Health Protection Agency say that “Modern, well managed waste incinerators will only make a very small contribution background levels of air pollution” and “provided they comply with modern regulatory requirements, such as the Waste Incineration Directive, they should contribute little to the contribution of monitored pollutants in ambient air”, there is a lot of evidence from overseas (and some in the UK) that identifies health risks and the extent of excess deaths and morbidity. It has recently been estimated by the United States Environmental Protection Agency that they are 10 times more likely to cause cancer than was previously thought hence no incinerator has been built in the USA since 1995.
Why are you proposing a 25 year PFI deal and what happens at the end of the contract?
The Claim: By using PFI we have been able to attract £65million of PFI credits from government. This is revenue funding which will be used to keep Council Tax down. This will actually equate to approx £125m as payments are spread over the life of the contract.
Reality: All the PFI would achieve is a modest up-front support for an uneconomic scheme and it would have the effect of locking NYCC and York into a high-cost solution. Since the claimed savings are illusory and predicated on a number of unsupportable assumptions, this scheme would actually cost the council money over the 25 year period.
The Claim: Unlike PFI contracts which provide a maintained building, for example for hospitals and schools, waste PFI contracts buy a long term waste management solution at a predetermined cost which gives us financial security. At the end of the contract AmeyCespa will hand the plant over to the councils in fully operational condition. The councils can then choose to operate it or decommission it, subject to planning conditions.
Reality: NYCC have failed to realise that there are cheaper alternatives. We think that any strategy should be cost-effective and place strong emphasis on waste reduction, re-use and recycling and that it should be as environmentally friendly as possible. This approach points to a strategy that combines maximal waste reduction, re-use and recycling with technologies such as Mechanical Biological Separation/Anaerobic Digestion (MBT/AD) and avoids incineration.
What if AmeyCespa don’t get the contract?
The Claim: It is up to councillors to decide whether or not to award the contract to AmeyCespa in December. If the council decides against contract award we will then have to start the tender process again, continue with landfill and incur the financial penalties in the meantime while we determine whether to start the procurement process again and/or review our waste strategy.
Reality: It is our belief that restarting the tendering process would be the best possible outcome for York and North Yorkshire council tax payers as it will identify cheaper options that create a greater number of jobs and have less health and environmental concerns. Other County Councils like Lancashire who have restarted the tendering processes for large PFI projects have managed to regain ground within 18 months.