Warrington Clinical Waste Treatment Centre Appeal Proposed Outline Evidence of Alan Watson

13.The Need for residual MSW Treatment Capacity:

1. 
   The need for residual MSW treatment capacity is essentially a function of the total MSW arisings and the maximum recycling/composting rates together with the waste growth (or reduction) over the relevant period.
   
2. 
   There is quite good data on the historic MSW arisings, recycling, recovery and disposal. This has the advantage of having data available for the tonnage collected and the tonnage treated/ disposed thus allowing some validation. In general the disposal figures are probably more useful and reliable as they are part of a taxation regime and so tend to be better audited and appropriate allowances is made, for example, for evaporation of moisture during processing (heavier rain, for example, increases the tonnage of MSW collected but is a confounder for the real and useful data).
   

14.Most Recent Residual MSW Data

153. 
     The latest data currently available from the DEFRA WasteDataFlow database is upto December 2012. This allows annual data for the calendar year to be collected:
     

154. 
     It is important to recognise that much of this waste is recyclable as demonstrated by the waste composition data (see Annex 2). Furthermore not all of this waste is suitable for incineration in any case. The collected non-household construction and demolition waste is largely rubble and is unsuitable for incineration as it the asbestos, much of the bulky waste, some of the fly tipped materials and some of the CA site wastes.
     
155. 
     The data has been further interrogated to show that the majority of the MSW is currently being landfilled at the Cory site:
     

156. 
     WasteDataFlow Data for the full financial year 2012/2013 should then be available in November. GCC has already published some data for this period:
     

1. 
   This shows that the MSW for the financial year 2012/13 included over 17,000 tonnes of commercial waste. The total annual MSW landfill requirement for the financial year, at 150,224 tonnes, is also lower than for the annual year 2012. When rubble and other wastes unsuitable for incineration are deducted, together with inevitable bypass where waste has to be taken directly to landfill without incineration⁵⁷, the maximum tonnage available for incineration would be less than 140,000 tonnes.
   
2. 
   Allowing for recycling to reach even just 60% would reduce the maximum tonnage of residual waste available for incineration to less than 100,000 tonnes.
   
3. 
   It can also be seen that there is significant monthly variability in the waste arisings with May, the peak landfill month, generating 14,246 tonnes of waste for landfill. This is 27% more waste than December. High variability in arisings can cause operational problems and increased bypass for incinerators, particularly when they have only one line as with Javelin Park. This is because of the operational constraints outlined in relation to the Stoker capacity diagram in Part 2 of my evidence.
   

15.Recycling Rates:

160. 
     The 2004 Regional Waste Strategy ‘From Rubbish to Resource’ published by the SW Regional Assembly included a regional aim of recycling over 45% of waste by 2020. A rate which has already been achieved and which showing how rapidly policy drivers can become out of date and lag far behind practical implementation.
     
161. 
     The WCS also sets a target for recycling and composting "at least 60%" of household waste by 2020 as the minimum target and it is expected that higher recycling levels would be achieved – Strategic objective 2 includes “an aspiration for 70%(recycling) by 2030”.
     
162. 
     The statutory recycling target in neighbouring Monmothshire is 70% - a level to be achieved by 2025 for the whole of Wales.
     
163. 
     Cllr Stan Waddington, GCC's Cabinet champion for waste, has publically stated⁵⁸: “The Javelin Park facility is based on Gloucestershire achieving 70 per cent recycling”.
     
164. 
     The Kier Group, contracted with GCC to run household recycling centres (HRCs) in 2006, say that by 2012 they had increased the recycling rate at the HRCs from 56% to 74% which clearly makes an important contribution to the total recycling rate which was about 48% for 2012/13.
     
165. 
     Other authorities have already achieved significantly higher levels than GCC and 60% should be comfortably achieved well before 2020 if GCC is serious about achieving higher recycling levels Examples of the highest Household Recycling and Composting Rates for 2011/12 are:
     

Authority	Region	Type	Rate
Vale of White Horse District Council	South East	Collection	68.71%
South Oxfordshire District Council	South East	Collection	67.92%
Rochford District Council	Eastern	Collection	67.35%
Surrey Heath Borough Council	South East	Collection	64.99%
Stockport MBC	North West	Collection	62.62%
Harborough District Council	East Midlands	Collection	61.56%
Rutland County Council	East Midlands	Unitary	61.29%
West Oxfordshire District Council	South East	Collection	61.21%
Three Rivers District Council	Eastern	Collection	60.47%
West Devon Borough Council	South West	Collection	59.90%

166. 
     Comparisons with other County authorities using recent WasteDataFlow data⁵⁹ for 2012 shows that neighbouring Oxfordshire was already recycling and compositing about 60% MSW:
     

County	82a	82b	Total
Oxfordshire County Council	32.80%	26.84%	59.64%
Leicestershire County Council	25.66%	29.65%	55.31%
Devon County Council	28.47%	26.14%	54.61%
Staffordshire County Council	27.13%	26.46%	53.59%
Cambridgeshire County Council	27.43%	25.84%	53.27%
Warwickshire County Council	26.21%	26.22%	52.43%
Suffolk County Council	28.88%	23.33%	52.21%
Surrey County Council	29.31%	22.75%	52.06%
Essex County Council	28.27%	23.71%	51.98%
Lincolnshire County Council	27.70%	23.58%	51.28%
Somerset County Council	25.98%	24.12%	50.10%
Lancashire County Council	27.64%	21.15%	48.79%
Gloucestershire County Council	26.44%	21.46%	47.90%
Buckinghamshire County Council	27.59%	19.90%	47.49%
Northamptonshire County Council	22.88%	23.15%	46.03%
Cumbria County Council	27.50%	17.99%	45.49%
North Yorkshire County Council	24.00%	21.39%	45.39%
Hertfordshire County Council	21.18%	24.11%	45.29%
Derbyshire County Council	24.39%	20.85%	45.24%
Norfolk County Council	25.74%	18.11%	43.85%
Worcestershire County Council	29.54%	13.81%	43.35%
Nottinghamshire County Council	27.25%	15.44%	42.69%
West Sussex County Council	25.72%	16.70%	42.42%
Kent County Council	24.77%	16.27%	41.04%
East Sussex County Council	19.94%	18.72%	38.66%
Hampshire County Council	23.66%	14.21%	37.87%

167. 
     The European Commission goes further and states⁶⁰: “In some Member States more than 80% of waste is recycled, indicating the possibilities of using waste as one of the EU’s key resources”.
     
168. 
     Recycling is, in any case, becoming increasingly cost effective – not least because of pressures on virgin raw materials. WRAP states, for example⁶¹: “MRF gate fees continue to fall and overall are substantially lower than our previous surveys, many local authorities are receiving revenue rather than paying gate fees for their recovered materials”. The median price for contracts starting in 2011 or later is now -£26 with some contracts paying as much as £55/tonne for recyclate. This can be compared with the cost of incineration with a median cost of £90/tonne for incinerators under 200,000 tonnes per annum. Although the gate fee in Gloucestershire is a closely guarded secret there are indications that it may be as much as 50% greater than this at c.£135 per tonne
     
169. 
     The appellant has essentially adopted the projections for ‘need’ from the Waste Disposal Authority (‘WDA’). There was some scrutiny of these projections during the WCS EIP and there is no doubt that the process leading to the adoption of the WCS has been a challenging one for the WDA.
     
170. 
     Their residual waste assessments, in particular, have been found to be based on pessimistic assessments of future recycling along with high waste growth assumptions. Whilst the WDA was assuming that waste growth was growing in Gloucestershire they were unable to distinguish the county from the rest of the country where waste levels have been consistently falling. The Inspector concluded:
     

24. In the light of this conclusion and the current economic outlook for the national economy, the WDA’s view that growth of 1.6% per annum will occur from as early as 2012/13 appears optimistic (or pessimistic from the representors’ standpoint). For example, no evidence was produced to indicate why the performance of the local economy should differ from that of the national economy.

171. 
     The Inspector recommended significant changes to the range for which residual waste capacity was needed and has reduced this to a lower level of just 108,000 compared with the WDA’s original, and largely ‘evidence free’, claim that “around 150,000 tonnes” would be needed.
     
172. 
     The proposed changes by the Inspector suggested that there was less need than had previously been argued by the WDA but the response of the Authority was to raise their estimate of an upper limit of 170,000 tonnes of residual waste capacity per annum. The WDA provided no logical basis for this increase but said that this amount is required “to allow for sufficient flexibility and an effective policy framework during the plan period and beyond”⁶².
     
173. 
     It should be noted that the WDA assessment of a need of 170,000 tonne is for 2040 – well beyond the WCS period and at a time during which even the best informed predictions are unlikely to be accurate. The WDAs crystal ball has been demonstrated to be inaccurate even over timescales of 3 – 4 years and there is no evidence that it would fare better over 20-30 year timescales.
     
174. 
     It seems more likely that this increase was required to cover the WDA’s tracks in relation to the previous inaccurate assessments of waste arisings associated with their Waste Contract - and ultimately the desire to justify the need for this incinerator which was based on their previous estimates but, by that stage, was in an advanced stage of planning.
     
175. 
     It was clearly anomalous that the response of the WDA – guiding the strategic planners - to reductions in waste arisings should be to increase the future provision! It appears that it is not coincidental that the financial modelling for the reference project/incinerator had earlier increased the capacity from 130,000 tonnes pa to 175,000 tpa⁶³ and the approach to capacity by GCC seems to be more of an exercise in justifying those decisions than achieving the best planning outcome.
     
176. 
     It is appreciated that this is set as a maximum provision and that a wide range is already set in Table 3 of the WCS. The WCS says it: ”will only make provision for a maximum of 145,000 for the recovery of MSW during the WCS period”. The figure of 145,000 tpa for MSW was provided at the request of the WCS Inspector by GCC “since it is not possible to derive it from any of the documents produced during the examination”⁶⁴. This figure is based on “a 'medium' recycling figure for 2028 … which is based… on 60% recycling from 2019/2020 and 70% by 2029/30” ⁶⁵ and the reason given for using this approach was “to align more closely with the strategic objectives of the CS”.
     
177. 
     The methodology used in the course of the preparation of the WCS for establishing the recovery of a maximum of 145,000 tonnes of MSW during the WCS period is therefore clear and replicable.
     
178. 
     It is not part of my evidence to re-run the WCS or to challenge the process. Accepting the approach used it is, however, now a relatively straightforward matter to now update the calculation to reflect the real data for arisings and growth rates which have become available since it was prepared.
     
179. 
     The original response is pasted below and is changed only by adding a final column showing the calculated recycling rate which has been placed where the LATs were in the original version:
     

180. 
     The recycling rate was calculated simply by adding the composting and recycling tonnages and calculating this as a percentage of the total waste arisings.
     
181. 
     It is a matter of concern that this table does not provide what was asked for by the Inspector. The Inspector specifically requested that the reworked table should be based on “60% recycling from 2019/2020 and 70% by 2029/30” yet the table shows that the simple recycling rate never rises above 57%. I can understand that the c3% shortfall from 60% could be explained by the MSW figure containing about 3% rubble - 8,687 tonnes out of 279,370 in 2012/13, for example. This is inactive waste which does not burn and will be used as hardcore or landfilled in an inactive landfill site. It does, however, mean that it carries directly through to the residual treatment column where it informed the need for MSW treatment.
     
182. 
     If this is the correct explanation for the recycling not reaching 60% then it means that the WCS calculation includes between 8,500 and 10,000 tonnes of rubble. This is obviously unsuitable for incineration and the maximum provision for residual treatment appropriate for this site should be reduced from 145,000 to about 136,000 tonnes.
     
183. 
     I cannot understand, however, why the WDA/GCC appears to have ignored the Inspector’s clear request to provide a model output based on 70% recycling by 2030. This would be a serious omission.
     
184. 
     A series of tables have therefore been prepared using a spreadsheet with the same approach to the calculation used by the WDA. The first sheet includes the original data presented to the Inspector in response to his request to the WDA as above but is simply updated with the three years of real arisings data which have since become available:
     

Year	Arisings	Growth %	Recycling Rate	Residual Treatment
2000/01	268,504	12.17%
2001/02	268,320	-0.07%
2002/03	283,493	5.65%
2003/04	291,978	2.99%
2004/05	309,486	6.00%
2005/06	312,118	0.85%
2006/07	324,143	3.85%
2007/08	322,796	-0.42%
2008/09	307,269	-4.81%
2009/10	293,815	-4.38%
2010/11	288,884	-1.68%
2011/12	280,205	-3.00%
2012/13	279,370	-0.30%	47%	149,316
2013/14	278,537	1.60%	48%	145,327
2014/15	282,994	1.60%	48%	146,225
2015/16	287,522	1.60%	51%	140,287
2016/17	292,122	1.60%	52%	139,767
2017/18	296,796	1.60%	53%	138,651
2018/19	301,545	1.60%	54%	137,232
2019/20	306,370	0.80%	57%	132,721
2020/21	308,821	0.80%	57%	133,446
2021/22	311,291	0.80%	57%	134,996
2022/23	313,782	0.80%	57%	135,445
2023/24	316,292	0.80%	57%	136,605
2024/25	318,822	0.80%	57%	137,812
2025/26	321,373	0.80%	57%	138,878
2026/27	323,944	0.80%	57%	139,713
2027/28	326,535	0.80%	57%	140,486
2028/29	329,148	0.80%	57%	142,109
2029/30	331,781	0.80%	57%	143,233

185. 
     It will still be necessary to reduce the total of residual waste which could be treated by an incinerator by about 9,000 tonnes to allow for the rubble, as above.
     
186. 
     The revised growth rates based on real arisings data are highlighted in the table. The WDA had assumed that waste arisings would grow by 3.1% between 2010 and 2013. In fact they reduced by 4.92%, albeit with a smaller reduction last year than previously with a 0.3% reduction, thus introducing a total error of 8% into the WCS within the first six months after adoption.
     
187. 
     I note the WCS Inspector said: “the WDA’s view that growth of 1.6% per annum will occur from as early as 2012/13 appears optimistic (or pessimistic from the representors’ standpoint). For example, no evidence was produced to indicate why the performance of the local economy should differ from that of the national economy”. ⁶⁶
     
188. 
     The evidence suggests that the WDAs forecasting error will grow. As can be seen in the section on growth the most recent DEFRA predictions for the national economy are for a small fall in total MSW waste arisings over the period to 2020 - yet the WDA’s figures suggest that it will grow by nearly 10%.
     
189. 
     To better reflect the DEFRA position this version of the table includes the updated arisings and sets the growth rate to zero whilst keeping the WDAs maximum recycling of 57% (meaning that the rubble needs to be deducted from these totals).
     

Year	Arisings	Growth %	Recycling Rate	Residual Treatment
2000/01	268,504	12.17%
2001/02	268,320	-0.07%
2002/03	283,493	5.65%
2003/04	291,978	2.99%
2004/05	309,486	6.00%
2005/06	312,118	0.85%
2006/07	324,143	3.85%
2007/08	322,796	-0.42%
2008/09	307,269	-4.81%
2009/10	293,815	-4.38%
2010/11	288,884	-1.68%
2011/12	280,205	-3.00%
2012/13	279,370	-0.30%	47%	149,316
2013/14	278,537	0.00%	48%	145,327
2014/15	278,537	0.00%	48%	143,922
2015/16	278,537	0.00%	51%	135,903
2016/17	278,537	0.00%	52%	133,267
2017/18	278,537	0.00%	53%	130,121
2018/19	278,537	0.00%	54%	126,761
2019/20	278,537	0.00%	57%	120,663
2020/21	278,537	0.00%	57%	120,360
2021/22	278,537	0.00%	57%	120,792
2022/23	278,537	0.00%	57%	120,232
2023/24	278,537	0.00%	57%	120,299
2024/25	278,537	0.00%	57%	120,399
2025/26	278,537	0.00%	57%	120,367
2026/27	278,537	0.00%	57%	120,129
2027/28	278,537	0.00%	57%	119,836
2028/29	278,537	0.00%	57%	120,258
2029/30	278,537	0.00%	57%	120,247

190. 
     The maximum MSW capacity requirement would therefore be around 111,000 tonnes pa after allowing for rubble being counted.
     
191. 
     Finally a scenario has been run which addresses the Inspectors original request to include 70% recycling by 2030 along with stable waste arisings:
     

Year	Arisings	Growth %	Recycling Rate	Residual Treatment
2000/01	268,504	12.17%
2001/02	268,320	-0.07%
2002/03	283,493	5.65%
2003/04	291,978	2.99%
2004/05	309,486	6.00%
2005/06	312,118	0.85%
2006/07	324,143	3.85%
2007/08	322,796	-0.42%
2008/09	307,269	-4.81%
2009/10	293,815	-4.38%
2010/11	288,884	-1.68%
2011/12	280,205	-3.00%
2012/13	279,370	-0.30%	48%	145,272
2013/14	278,537	0.00%	50%	139,269
2014/15	278,537	0.00%	52%	133,698
2015/16	278,537	0.00%	54%	128,127
2016/17	278,537	0.00%	56%	122,556
2017/18	278,537	0.00%	58%	116,986
2018/19	278,537	0.00%	59%	114,200
2019/20	278,537	0.00%	60%	111,415
2020/21	278,537	0.00%	61%	108,630
2021/22	278,537	0.00%	62%	105,844
2022/23	278,537	0.00%	63%	103,059
2023/24	278,537	0.00%	64%	100,273
2024/25	278,537	0.00%	65%	97,488
2025/26	278,537	0.00%	66%	94,703
2026/27	278,537	0.00%	67%	91,917
2027/28	278,537	0.00%	68%	89,132
2028/29	278,537	0.00%	69%	86,347
2029/30	278,537	0.00%	70%	83,561

1. 
   In this scenario the recycling rates have been applied to the whole of the arisings so no correction for rubble is required. It is clear that if the aspirations of the WCS are met then well under 100,000 tonnes of residual MSW capacity is needed.
   
2. 
   I conclude that it is not appropriate to use the 145,000 tonne limit for residual MSW capacity derived from the WDA data in the determination of this application because 1) the assumptions were demonstrably wrong in relation to waste growth and is inconsistent with the latest projections from DEFRA; 2) the recycling rate was reduced to 57% by the WDA, presumably to make allowance for rubble, and it was not the made clear that the 145,000 tonnes would include c.9,000 tonnes of rubble; 3) the scenarios did not include 70% recycling by 2030 as unambiguously requested by the Inspector. Correcting these errors and omissions shows that the maximum residual MSW provision should be less than 90,000 tonnes.
   
3. 
   On the basis of the actual MSW waste arisings rather then the inflated WDA claims it would also would not be correct to claim that “the significant majority” of the waste burned would be municipal waste unless it was to be imported from out of the County or waste that would otherwise be recycled was being burned.