Submission on the proposed disposal of Enfield Crematorium, and Tottenham and Wood Green Cemeteries.
- Sustainable Haringey is very concerned that the Bereavement Services Disposal report (Cabinet 4th October) recommends that the contract for Enfield Crematorium and Tottenham and Wood Green Cemeteries is awarded to the company which scored lowest in both quality and proposed approach to the management of biodiversity and conservation, with a score of less than 20% on biodiversity and conservation (see para 5.9).
- We are also very concerned at the proposals in the current report for the Final Heads of Terms to be delegated to the Director of Place and Sustainability (para 3.6), without any public scrutiny or involvement and without even Cabinet scrutiny and we urge the Cabinet to reject this course outright.
- We requested that we be provided with copies of all the appendices and draft Heads of Terms, if necessary with company names and financial information redacted, so that residents could see for themselves the basis for these proposals and have the opportunity to engage meaningfully with the decisions being taken. However our requests have so far been refused.
- We also requested copies of other background documents, in particular the details of how each of the companies intends to deal with sustainability and biodiversity issues relating to the running of the 3 sites. This was also refused without any real explanation.
- The decision to transfer the Crematorium and Cemeteries to the private sector for 50 years will last beyond most of our lifetimes, yet there has been no public consultation or even public awareness of the final proposal, with the limited report released without public notice just 7 days before the Cabinet meeting. For such a far reaching decision there should be proper opportunity for scrutiny and comment on the proposals. Sustainable Haringey made extensive submissions at the time of the original Cabinet meeting in November 2010 (see attached), yet were not notified or invited to comment in any way before this Cabinet meeting.
- We request that the Cabinet defer the decision on the report until adequate information has been provided and consultation has taken place. The proposed lease is for 50 years, not just 5 or 10, and therefore deserves proper consideration and scrutiny to ensure the interests of residents and local sustainability are being best served. A month or so for proper consultation is not long when compared to 50 years. We also ask how meaningful consultation can take place (para 7.6) with staff or with residents, if the final decision to outsource the service has already taken place.
- During our earlier discussions with the lead Cabinet member and officers it was said there would be opportunity to address some of our concerns and consult more widely at a later stage, yet we are not even allowed to see documents relating to how these sites, including Tottenham Cemetery, a designated Ecologically Valuable Site of Borough Grade 2 Importance, which has significant nature conservation value and which is also a historical asset to Tottenham, will be maintained and protected and what environmental practices will be in place. There can be no good reason for such secrecy, and we do not believe this secrecy is in the interests of Haringey residents.
- There are also huge doubts over whether the proposed course of action represents the best solution financially. The supposed costs of keeping the service in house are said to be £13.4 million investment (para 4.1.1), but this is based on including costs of a new car park and massive concrete burial chambers.
- According to the Council's own figures, the cost of 3 new cremators & abatement equipment is in the region of £1.2m (email from Tim Baker to Sustainable Haringey 20 Dec 2010). Company A is proposing to replace the four existing cremators with two abated cremators (para 10.8). So if this option was pursued in house by the Council the total cost of becoming mercury compliant would be less than £1M. According to the response by Tim Baker to Sustainable Haringey's submission, "'Invest to Save' prudential borrowing schemes are usually only approved by the Council if the payback is no more than three years". As the Bereavement Service has an annual surplus of well over half a million pounds, the payback period would easily fall within this. Whilst undoubtedly some improvements were needed to the facilities, no real evidence has been demonstrated for the level of investment suggested. Some of the improvements could be part funded by the money raised from the sale of Grenville Cottages, which raised £400,000 (para 5.2).
- The expensive proposals for extensive car parking, rather than promoting public or shared transport options, were not compatible with the Environmental Considerations section of the Options Appraisal (S12) "it is noted that opportunities should be explored for improving public transport links to the site, and reducing the need to access the site by car". Environmental sustainability would be best served by improved public transport access to the Crematorium, not increased car parking.
- As to the huge cost for development of burial facilities, in para 5.12 of the report it is stated that 'the tendering process did not demonstrate that the site value would be greater with planning permission for a new burial facility', so the planning application was not progressed. The report is silent on whether or not the private operator will in fact develop additional burial facilities at the site, who will profit from this, and what controls will be in place to protect residents interests. It also leads to a situation where the in house option costs of £13.4m (of which burial facilities were £5.4m) are not being compared like with like with the private operator option.
- The proposed course of action also gives Tottenham and Wood Green cemeteries away at a peppercorn rent (para 7.3), when over £450k was spent last year on Wood Green Cemetery to create 132 new burial plots which were expected to last for 2-4 years. According to the report for the Cabinet meeting last year, plots are sold for £3600 - £4700, so this appears to be a substantial gift of income to the private operator from Haringey's reserves. [see burial charges at p 5 and Wood Green expansion at p3 & 5 of
- The report is also silent on re-use of graves, which could be a potential huge source of income for the private operator, and a huge loss and source of controversy to the Council. In the response to Sustainable Haringey's submission last year, Tim Baker (consultant employed to facilitate the disposal of the service) stated: "Public resistance could be a big factor when determining whether grave re-use should occur and it is likely that this would apply regardless of whether the Council or someone else proposed its use. Therefore, the Council isn’t necessarily losing out on this as a potential income source. Because the current situation regarding the re-use of graves is not entirely clear, we have not attempted to factor in any financial implications or benefits that may accrue either to us or a private operator."
- So if the private operator decides to re-use graves on any of the 3 sites, they have the potential for a massive source of income, while the Council and residents will be left to deal with the controversy (as has occurred with other privatised cemeteries in the past).
- The section on sustainability issues in the report (paras 10.2 - 10.8) refers to addressing some of the concerns Sustainable Haringey raised previously. However the whole section is lacking in detail and does not provide any real re-assurance that sustainability issues will be taken seriously by the private operator, particularly in light of the fact that Company A scored just 1.6% out of a possible 6.7% on their proposed approach to the management of biodiversity and conservation (para 5.9), the lowest score of the 3 companies, yet was still selected as the preferred bidder.
- For example under the draft Heads of Terms the clause 'Manage the property in accordance with the principles of good estate management'could be interpreted in any number of ways, there would be a vast difference in opinion between operators trying to manage in a sustainable way, and those who might seek to minimise staffing costs by extensive use of chemicals, yet argue that the estate was tidy and therefore well managed.
- There is reference to maintaining biodiversity in accordance with conservation management plans and biodiversity report recommendations, but these are not set out. Then in para 10.6 we are told that Company A has proposed to formulate it's own action and ongoing management plan, according to 4 listed principles, which are so vague as to be virtually meaningless. Such self regulation by a private operator cannot be relied on to protect the interests of Haringey residents and the environment.
- The break clause only refers to terminating the lease because 'certain covenants' have not been complied with. Those covenants are not specified, nor are the consequences of the termination set out - would there be financial costs or penalties involved?
- Additionally, while the clauses set out in para 10.4 are included in the draft Heads of Terms, we have no way of knowing or ensuring that they will be included in the final Heads of Terms.
- The report to Cabinet makes little reference to reduction of carbon emissions or 40:20 objectives, with no detail on what reductions will be made (para 10.8) and it is unclear to what extent these were considered during the decision making process.
- Without the provision of the information requested we can have no confidence that sustainability, biodiversity and conservation issues will be taken seriously by the proposed operator or that the interests of Haringey residents will be protected by the lease and disposal of the sites for 50 years.
4th October 2011