APPENDIX 7
Letter to the Clerk of the Committee from
Andrew Price, Chairman, Planning Officers Society Minerals and
Waste Topic Group
Thank you very much for consulting the Society
on the Government's response to the Environmental Audit Committee's
report. We note that many of the views and concerns raised by
the Committee have drawn a helpful response, and would make only
a few brief comments. We set these out below in relation to the
numbered key comments made in the Environmental Audit Committee's
report.
6. Missing Targets
— We would question the adequacy of
resources made available under the Waste Minimisation and Recycling
Fund and point to the need for more generous resourcing of the
successor Performance Reward Fund. We have several reservations
as well about the competitive nature of this process, with costly
time and effort spent on preparing bids and then providing quarterly
accounting returns on a recurring basis for those that are successful.
— In relation to the Waste and Emissions
Trading Bill we are unclear as to what is meant by the intention
"to provide more strategic waste planning at a local level
in two tier authorities". This should be clarified.
9. Definition of Waste (see also paragraph
19 under comment 5)
— We have a major concern that waste
is dealt with under different categories when the real problem
is that we should be managing all wastes better. The UK
interprets municipal waste as being predominantly household waste,
whilst in Europe this definition more appropriately includes a
wider range of wastes, including industrial and commercial.
12. Environmental and Health Effects of Waste
Management Options
— We welcome the commissioning of this
review, but must record our concerns that the Environmental Audit
Committee has sought a moratorium on "all larger scale municipal
incinerators". Our fear is that this may result in further
delay in progressing towards meeting targets, given the very long
lead times needed to bring forward major new infrastructure and
our belief that incineration must play a part on achieving targets
within the integrated portfolio of waste management practices.
We are not convinced there is a proven case on health risks and
believe that other options also carry health and environmental
risks.
15. Waste Strategy
— Introduction of tradable landfill
allowances demonstrates an intention to move towards landfill
diversion, by pressurising local authorities through financial
means. Whilst there is a crucial need to limit landfill, the key
requirement is for clarity on the means by which waste that cannot
be avoided, recycled or composted should in future be managed.
There is a clear need for Government policy statements and leadership
on what alternatives should be pursued to replace landfills.
18. Planning Uncertainty and Delay
— The Government's intentions to speed
up the planning system and review PPG10 are noted, but the fundamental
need is for clear and unambiguous guidance from Government on
waste management policy which will allow long term planning to
be undertaken with confidence. Development of regional and more
particularly local waste plans need to be well-founded in clear
statements of Government waste strategy policy.
We trust these points may be of some assistance
to the Committee, and thank you once again for the opportunity
to be further involved in their important work.
September 2003
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