By Neil Carrett, Technical Manager, London CRN (25 October 2005)

London CRN welcomes comments from members to the draft response on the Proposed Single Waste Authority for London. Closing date for comments to London CRN is 8th November 2005

London CRN is broadly supportive of the principle of a single waste authority for London. In this regard it sees the following arguments as particularly persuasive:

• Better capacity to develop an appropriate mix of facilities (both in scale and type) in accordance with the principles of sub-regional self-sufficiency.
• The ability to better scale and phase capacity to meet need.
• Cost savings on procurement and ability to absorb risk, rather than outsourcing it.
• Pooling of expertise. We are particularly keen to see the amount of money spent on consultants in relation to PFI contracts reduced.

We do not expect the cost savings to be as great as projected. We agree with the North London Waste Disposal Authority’s point that LATS allowances are clearly likely have a value of less than £150 per tonne (unless central government increases the tonnage penalty back to £200 or beyond). However, we do anticipate the savings to be significant.

We are concerned with a potential loss of local democratic accountability in waste management decisions but accept that this may sometimes need to be offset against other considerations. We would also argue that local democratic accountability and community involvement in waste management decisions is not particularly good as things currently stand. The Joint Waste Disposal Authorities are, in particular, not very accountable to local populations and do not have a good record in involving the public in their decision making.

However, our concerns lie less in who runs and plans waste disposal in London and more with how they do it. Whilst we have a number of concerns regarding aspects of the Mayor's Municipal Waste Strategy, the relevant proposed amendments to the Mayor’s Spatial Strategy and associated technical papers, we recognise that the Mayor has taken a more enlightened and strategic approach than many others with a more narrow perspective would have preferred. For example the Mayor has not simply plumped for very large collocated facilities in the ‘areas of least resistance’ in his proposed amendments to the spatial strategy.

Our overriding concern is that waste management in London is undertaken in accordance with the principles of the waste hierarchy, sustainable development and the proximity principle wherever practicable. We are particularly concerned that the proposed treatment and disposal facilities do not drive the collection systems based upon spuriously precise waste arisings projections and very basic assumptions at the front end.

The Mayor’s Municipal Waste Management Strategy should be reviewed to accommodate a thorough technical study to identify the most appropriate household waste collection systems based upon the above principles (potentially significantly reducing the projected municipal waste arisings projections and ending the patchwork of systems currently used). This should be within a presumption of separate food waste collections from suitable properties, support for home composting and greater acknowledgement of the role that reuse can play. Any disposal authority should then work forwards to develop facilities based upon the pattern of waste collected, rather than backwards.

We are also concerned about any strategy that the GLA may take in relation to procurement. In particular we are concerned that any waste authority relies upon inappropriate economies of scale and clustering of contracts, the potential benefits of which could be dissipated by a lack of supplier diversity. We would also clearly be concerned if the projected facilities are driven by a scramble for PFI credits after which millions of pounds will be spent on bloated procurement processes to deliver the ‘right answer’, rather than Best Value.