Further supplementary memorandum submitted
by the Environmental Services Association (Waste 39b)
FURTHER REQUESTED
INFORMATION
1. A copy of the report commissioned by the
ESA from Ernst and Young in 2002 relating to incentives and charging
for household waste
Please find relevant document attached: "Analysis
of the Application of the Producer Pays Principle to Producers
of Household Waste as a Driver Towards Sustainability" Ernst
and Young, July 2002 (Funded by ESTET)[1]
2. A note of key points on the problems the
planning system presents for the development of waste infrastructure
We have five recommendations:
Our first suggestion relates to timely and adequate
delivery of waste development frameworks:
— Timely delivery of new waste management
facilities depends on local authorities having in place up to
date development plans with provision for the allocation of waste
sites. Otherwise, the submission of development proposals are
likely to run contrary to a development plan, increasing the chances
of proposals being referred to committee or planning inspectorate
upon appeal.
— The introduction of the Planning and
Compulsory Purchase Act required all county councils to replace
waste local plans with new waste development frameworks. In England,
34 County councils and even more unitary authorities are responsible
for waste development frameworks but as of last month the Planning
Inspectorate had approved as sound only five local authorities'
waste development plans.
— HMG should indicate what action it
proposes to take against local authorities taking longer than
the law allows to complete a development plan document and should
offer more guidance on how waste development frameworks should
be prepared and specify the waste issues that must be included
in the core strategy.
— ESA suggests that core strategies
and site proposals should be considered simultaneously to increase
wider understanding of waste management issues and speed up the
overall delivery of Waste Development Frameworks. Waste development
documents must outline the number, capacity and type of facilities
that will be required to meet the needs for the management of
the broad equivalent of waste generated within the boundaries
of each local authority.
Our second recommendation is to extend Permitted
Development Rights to our sector:
— We believe our sector should be treated
like other utilities and that permitted development rights should
be extended to minor, uncontroversial development on existing
waste management sites. This is not a panacea but would release
resources to focus on more substantial applications. This requires
an amendment to the Town and Country Planning (General Permitted
Development Order) 1995.
— The change would, for example, help
existing facilities quickly to respond to regulators. For example,
the installation of spray masts may be required on an existing
facility in response to changes to the Environment Agency's permitting
regime, or HM Revenue and Customs may request the installation
of a weighbridge to ensure better data reporting for landfill
tax purposes.
Our third recommendation follows the Environment
Agency's evidence on dual tracking, the simultaneous processing
of applications for planning and permits:
— Provided this a choice for the applicant,
in principle we welcome parallel tracking of planning and permit
applications. However, this could be made to work better with
the following changes: most, but not all waste management planning
applications need planning approval before a permit can be granted.
Other industrial processes within the PPC regime do not have a
requirement for prior planning permission and neither should we:
developers should be able to submit an application for permit
prior to application for planning consent where local circumstances
dictate.
— While planning authorities adhere
to a standard administrative and consultation process, the Agency's
approach to such processes is inconsistent. ESA would welcome
a public statement of the Agency's consultation procedures and
timeframes. Also, the same specialist case workers (ie hydrologists,
ecologists) assigned to assess a planning application should work
on the permit.
— PPS10 noted that perceived and real
health impacts are the responsibility of the environmental regulator
and are addressed fully through the PPC regime. Planning authorities
should rely on the Agency's permitting approach in dealing with
health issues.
— The Environment Agency's standard
response to planning authorities as a statutory consultee should
not be "no objection" but a statement as to whether
an application for development conforms with the Government's
strategic waste objectives. The Agency should also desist from
lodging planning objections on matters which are clearly permitting
issues.
Our fourth recommendation is that PPS10 should
be better reflected in waste development plans:
— ESA welcomed the Government's introduction
of PPS10 in July 2005 which sets out the Government's national
policies for planning for waste management. The policies of PPS10
should be taken into account by planning authorities in preparing
development plans, and form a material consideration in determination
of individual planning applications.
— ESA's Members have expressed concern
that PPS10's policies have not adequately implemented through
waste development plans. Robust interpretation of PPS10 has been
broadly limited to decisions made by the Planning Inspectorate
upon appeal.
— ESA suggests development plans should
be assessed, in the context of PPS10, for evidence of: apportionment;
allocation of sites for waste management development; interpretation
of the proximity principle as "nearest appropriate facility";
planning for residual waste; planning for shortfall in landfill
capacity; and correct interpretation of self sufficiency.
Our final recommendation relates to the proposed
National Policy Statement:
— ESA supports the Government's proposals
to devise a National Policy Statement for waste management development
to highlight the Government's priority and to update PPS10 in
the context of WS 2007. The Government's proposed focus of the
National Policy Statement should be widened beyond very large
facilities because smaller, strategically located facilities could
equally help the UK to comply with EU law and improve sustainability.
3. In addition, the Committee would be grateful
for your response to a supplementary question: What proportion
of materials collected in England are exported for reprocessing?
Is the industry working to fill the gap in specific reprocessing
capacity in England, eg for plastics
— As we move away from landfill towards
recycling and recovery, the only options are to build infrastructure
or export material for recycling. — According to the
Confederation of Paper Industries (CPI), in 2007 the UK exported
most (54%) of the paper collected for recycling. Also in 2007
(as reported by WRAP) 70% of plastics collected for recycling
were exported, and 20% of glass.
— If the UK wants to increase domestic
reprocessing capacity, then local authorities must make greater
provision such facilities in their local development plans.
— Even with a renewed planning system
delivering new infrastructure, England will be for the foreseeable
future be dependent on exports of materials for reprocessing as
there is simply insufficient reprocessing capacity in the UK.
Lower energy, property and labour costs abroad and the strength
of overseas markets abroad will continue to make exporting a viable
option.
— Announcements such as the granting
of planning permission for a new newsprint mill in Kings Lynn
in November 2007 increase British capacity but, in a context of
increased collections, most material will continue to be exported.
— In response to growing interest in
the fate of material collected for recycling, the Recycling Registration
Scheme was launched by ESA in April 2007.
Environmental Services Association
November 2008
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