In November 2011 the Chancellor announced the Government’s intention to reform PFI, followed by a call for evidence in December 2011. UKWIN has responded to the Treasury’s PFI Reform Call for Evidence, and our consultation response is available here.
In summary, our submission sets out UKWIN’s position that:
- There is no need for new incineration infrastructure and that it would be inappropriate for incineration infrastructure to be subsidised by the Government.
- Municipal waste incineration has no place in a zero waste economy. True zero waste can only be achieved without incineration, as burning discarded material goes against the principle of zero waste.
- UKWIN hopes that any financing mechanism that is to replace Waste PFI will help fund the weekly separate collection of food waste, and will not be used to fund any scheme that does not include separate collection of food waste.
- Public money should not be used to encourage increased incineration, as subsidising incineration perversely discourages waste minimisation and incentivises burning material that should be reused, recycled, composted or anaerobically digested.
- To help avoid exacerbating the over-capacity of incinerators in the UK, projections of likely future waste arisings and associated treatment capacity requirements should be based on an expectation of successful waste minimisation, the maximising of reuse and recycling, and the anticipated growth in the use of anaerobic digestion, all as part of a trajectory towards zero waste.
- UKWIN believes that greater transparency often results in better scrutiny, reducing the likelihood of project failure. UKWIN hopes that the replacement for PFI will fully address the need for greater transparency and greater community involvement to bring about improved decision-making, and to engender a greater sense of community ownership.
- Community involvement should not be limited to deciding the waste strategy and whether or not to enter into a contract, but should also extend to such decisions relating to extending, altering or terminating long-term waste contracts.
- As waste is a rapidly changing sector it is important that there is careful monitoring of expectations versus reality. Predictions can soon become out of date, targets can easily become un-ambitious, and circumstances can alter which solution would be the best economically and environmentally to pursue. Contracts not only need to be flexible, but that flexibility must be utilised as appropriate.
- A more critical approach is needed in the evaluation of Business Cases presented to Treasury/Defra for approval. This should include critical examination of the various assumptions in the Business Case and the evaluation of realistic alternative assumptions. The justification offered for incinerators in existing/proposed Waste PFI contracts should also be reviewed, with particular scrutiny where separate collection of food waste is not part of the PFI.
- Getting private companies to borrow money at a higher rate than the public sector to buy infrastructure which the public sector then needs to pay a further premium on might not be the best way to achieve value for money.
Other UKWIN consultation responses are available from our Consultation Submission Archive.