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The Statement of Common Ground between UBB and GCC states: “The WCS derives its MSW residual treatment requirements from Core Document (of the WCS inquiry) CD14.12 Appendix 2. The forecast annual average growth rates are included in column 3”. Whilst GCC agreed with UBB that these figures were suitable for the forecasting of waste arising for the purposes of this appeal GlosVAIN did not.
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GlosVAIN does not agree with UBB because:
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the evidence from the actual arisings shows that these growth rates are not appropriate and in the case of last three years are simply wrong. As I noted above the WDA assumed that waste arisings would grow by 3.1% between 2010 and 2013 but they actually reduced by 4.92% introducing a total error of 8% - equivalent to close to 24,000 tonnes. This also means that the calculations upon which the WCS conclusions of the need for 145,000 tpa of residual MSW capacity are already out of date and unreliable as discussed above.
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the growth rates included in Table 3 of CD14.12 are 1.5% for 2011/12 followed by 7 years steady growth at 1.6%. The assumption is then the primary strategic objective of the WCS which is to reduce the amount of waste produced and to achieve zero-growth across all waste streams by 2020 fails to deliver and a steady annual waste growth of 0.8% is assumed from 2019/20 until 2039/40. These waste growth rates are not only badly aligned with the WCS objectives but are not supported by the Government’s recent projections. There is no good reason to assume that growth trends in Gloucestershire are significantly different from the rest of England.
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The proposed incinerator requires a steady supply of waste over a very long operating period67 and is essentially predicated on waste growth. Yet the continuing fall in waste arisings has, yet again, undermined the WDAs projections. If approved most of the incentives to reduce waste arisings would be removed and the incinerator does nothing to further the primary strategic objective of the WCS which is to reduce the amount of waste produced and to achieve zero-growth across all waste streams by 2020.
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DEFRA data68 shows that household waste arisings grew at a steady rate of just over 1% pa from the mid-1980s to the mid-1990s. There was a short period of higher growth with the introduction of the landfill tax. This was followed by a steep fall in the growth rate with an average growth reduction since about 3002/3.
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ERM and other consultants claimed for many years that the average growth rate was 3% - and made long-term projections on that basis. The Gloucestershire County Council Outline Business Case69 stated: “growth in MSW arisings has risen by about 3% per year”. Later that year GCC in November 2008 told the public: “Waste growth on average 3% past years”.
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In fact there have actually only been two years in the past 30 years when household growth has exceeded 3% and only 4 years at or exceeding 2.5%. These higher growth years were all when the landfill tax was starting to bite and are probably largely due to the diversion of easily re-directed C&I waste to the domestic waste stream – examples include carpet fitters remnants and builders offcuts which would previously have been taken away were increasingly left behind after jobs to avoid the new charges and the increased restrictions on the trade use of civic amenity sites whilst old furniture which would previously have been taken by suppliers of replacements in exchange schemes was left to be disposed of by homeowners. This was also the time when there were the first major increases in home working which would have resulted in increased commercial waste being generated at home rather than in the office.
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The WDA’s high projections for growth were included in the 2008 Outline Business Case70 :
(note: The X axis is not clear on this graph (even in the original) but I understand the scale runs from 2008 to 2040 with the residual waste treatment starting in 2015.)
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The OBC included growth rates reducing from about 2%/year in 2011 to 1.2% in 2020 and 0.68% by 204071giving a 30% increase in total arisings between 2013 and 2040. This is not the whole story however. Because of the much higher rates in the early years arisings were predicted to reach 371,390 tonnes by 2013. The actual total MSW arisings for 2012/13 were 279,370 so the WDA overestimated waste growth by 100,000 tonnes in just five years!
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It is particularly notable that there has been a strong downward trend recently in spite of the major increase in the collection of green waste by authorities in Gloucestershire keen to boost their recycling rates (at the expense of total waste arisings) and by the collection of rubble at HRC sites. The underlying reduction trend in household waste is therefore almost certainly stronger than the headline rates indicate and there is great potential to reduce waste significantly by the introduction of green waste charges.
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I understand that Cllr Lunnon has addressed some of these issues in her evidence and in an effort to avoid duplication I will not address these matters in detail here.
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Extending this to include the most recent data shows the trends in the fall of waste continue:
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And plotting this data clearly shows the fall even with a full range y-axis:
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Zooming in to the totals allows the trend to be illustrated more clearly:
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Furthermore the falls are reflected in reductions in household waste per household:
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And in household waste per capita:
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Furthermore if less waste is available than had been claimed and more waste has to be sourced from further away from the site than has been assumed during the preparation of the Environmental Statement. This would inevitably increase the overall environmental impacts of the proposal beyond those assessed in the Environmental Statement.
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The proposal is intended to divert waste which would otherwise be landfilled and so the total tonnage of waste generated in Gloucestershire and landfilled as well as the trends in the quantities of waste being landfilled are also important.
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Nationally there has been an enormous reduction in the quantity of waste being landfilled since the introduction of the landfill tax in 1996:
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Based on landfill tax returns to HMRC the fall has been from 51,796,000 tonnes in 1997 to 18,987,000 tonnes in 2012. This is a reduction of more than 63%.
17.Decoupling? -
The Companion Guide to PPS10 states72: “In making forecasts, account should be taken where possible of the impacts of commercial and legislative drivers of waste production, recognising that these are not certain”. The landfill tax has been a powerful driver which has helped to reduce the disposal of waste to landfill dramatically as outlined above. Another important commercial issue which bears upon long term predictions for waste arisings is the question of decoupling.
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The WCS Inspector considered the WDA to be correct in it’s view that73: “success locally in de-coupling growth in MSW from economic growth will be an important influence on the total arisings during the plan period”.
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There is already strong evidence of decoupling at a national level over the past decade and this can be seen by plotting MSW arisings against GDP:
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The divergence of the plots becomes more clear when viewed in close up:
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The WDA has currently made allowance for and that the likely outturn of residual MSW by 2027 will certainly be at the lower end of the scale in the WCS – and almost certainly leaving less than 100,000 tonnes of residual waste for treatment.
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The European Commission states74: “Overall waste generation is stable in the EU”.
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The Government has changed it’s own position on growth rates from predicting 3% annual growth in Waste Strategy 2000 to it’s current position that household waste arisings are likely to fall slightly over the period to 2020:
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The assumption of continued waste growth made in the WCS lacks any evidence base and, if relied upon, would lead to over-provision of capital intensive capacity low in the waste hierarchy. This is particularly relevant in this case because the incinerator would probably operate until at least 2040. This would be damaging to long-term recycling because once investment has been made then operators would seek to maximise throughput of that capacity. The consequence of over-provision in these circumstances would be a reduction in gate fees for commercial and industrial waste if waste was not otherwise available75. This would increase the prospects of longer distance shipments to the facilities and would compete with recycling locally by undermining prices. Both outcomes would be contrary to the sustainability requirements of the NPPF.
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