Written evidence from Steve Tremlett (ARSS
06)
This submission is an edited extract from my recent
MA Urban & Regional Planning dissertation titled "The
Institutional Structures of Waste Planning." Part of the
dissertation considered the effectiveness of regional planning
under the Labour Government and the impact of the Coalition's
abolition of Regional Planning Bodies and RPBs on the planning
for waste management facilities. Key findings were as follows:
There is a need for a strategic level to effectively
plan for waste management. Abolition of RSSs has created a large
policy vacuum.
The elevation of RSSs as part of the development
plan had a positive effect in increasing the speed of delivery
of waste facilities
The focus on localism and local decision making may
be problematic when applied to such an inherently controversial
form of development as waste management. Political pressures are
likely to restrict the delivery of new waste infrastructure.
Abolition of RSSs has removed the strategic targets
and level of policy which could be used locally and by industry
to demonstrate the need for new facilities
Waste streams have become increasingly specialised
in order to maximise the recycling and recovery of materials,
and an increasing number of facilities are consequently only required
at a regional level. Planning for these facilities is most effectively
carried out at regional level.
European countries which achieve high diversion from
landfill have a strong emphasis on an influential regional tier
that provides clear and unambiguous forward capacity planning.
EXTRACT FROM
DISSERTATION
All those questioned for the research agreed there
is a need for a strategic level to effectively plan for waste
management. It generates administrative economies of scale, and
allows for a better understanding of the wider picture of waste
management amongst the counties, rather than just what is occurring
within their borders (interview with former CLG officer). It also
provides a context for each Waste Planning Authority (WPA) to
work in, and a better understanding of the interrelationships
between WPAs' areas, and indeed adjacent regions (interview with
regional planner).
The elevation of RSSs as part of the development
plan had a positive effect in increasing the speed of delivery
of waste facilities (Bell, in "Waste Planning", August
2010). The RSS also enabled local members to see the broader picture
and the need for certain policies even where these policies may
have been unpalatable locally. Without the regional tier, unpopular
but necessary policies may become harder for local authorities
to accept (interview with regional planner). This is a key comment
given that one of the reasons given for the removal of the RSSs
is that they contain unpopular policies.
Waste streams have become increasingly specialised
in order to maximise the recycling and recovery of materials,
and an increasing number of facilities are consequently only required
at a regional level, for example waste paper and glass reprocessing
(interview with Strategic Waste Policy officer). Indeed, even
some types of facility that previously attracted a sufficiently
large quantity of waste to enable their provision at a County
level, for example landfill, are now moving towards regional or
sub-regional facilities. This is because the declining amounts
of waste being sent to landfill combined with the economies of
scale required to make a site viable mean that they will serve
larger and larger areas, in effect becoming regionally significant
facilities (interview with County Council Waste Planning Policy
Manager). The waste management company Biffa (2010) state that
their business model is already based on the regional scale for
reprocessing and recovery facilities, and believe that will be
the case for landfill provision in the future, especially given
the increasing impact of policy drivers such as landfill tax.
If facilities are serving a regional area, it makes sense to plan
for them at the same spatial scale.
SLR Consulting (2005) examined the institutional
architecture in nine other European countries which currently
vary significantly in how sustainably they manage their waste.
They concluded that countries with success in achieving more sustainable
waste management regimes generally have a clear, consistent policy
statements from central government that provide certainty through
the planning system. Partnership working between national, regional
and local government is promoted with a strong emphasis on an
influential regional tier that provides clear and unambiguous
forward capacity planning. This is contrasted in the report with
the situation in the UK which is characterised by a lack of direction
and leadership from central Government, with a reliance on market
based policy tools such as LATS.
Regional planning of future capacity needs can also
facilitate cooperation at the lower tier towards sharing the burden
of new infrastructure, and the study recommended giving a clear
mandate for Regional Planning Authorities in the UK, noting that
a further benefit of this is to distance local politicians from
unpopular decisions (SLR Consulting, 2005:64).
The Coalition Government is criticised for the speed
of removal of the regional tier, with Chalmers (contribution to
forum at www.pas.gov.uk, 8.6.10) arguing that "removing it
asap without recognising how it forms a critical part of the whole
planning process is at best naïve", and suggesting that
the new Government may be too focussed on housing numbers. It
was also suggested that the previous structure of waste planning
"has been hampered by the broader political hostility to
regional planning in many areas, perhaps driven principally by
dislike of the regional housing allocations" (interview with
former CLG officer).
The abolition of RSSs before any alternative systems
have been implemented is also criticised, with an anonymous forum
contributor stating that "the real problem here is…
the complete lack of any strategic level alternative." (contribution
to forum at www.pas.gov.uk, 8.6.10). The "Open Source Planning"
Green Paper (Conservative Party, 2009) which does not make any
reference to waste planning which increases suspicion that it
has been broadly overlooked.
EFFECTIVENESS OF
RTABS
There was a broad consensus that RTABs have played
a beneficial role in facilitating effective waste planning, however
a number of issues were identified which restricted their effectiveness.
It has been difficult to create a truly technocratic
group with a politically neutral environment has failed as political
influences have come to the fore when controversial issues have
been discussed. It was argued that any collection of local authorities
will inevitably be political to some extent.
The original concept of collaborative governance
has not been successfully achieved with little interest from industry
for ongoing engagement and consequently local authority officers
dominating groupings. For example, the effectiveness of the South
East RTAB (SERTAB) has been restricted by the dominance of local
authority planning officers in the group. The government's intention
in creating RTABs was for a broad range of stakeholders to be
represented, however in the South East representatives from the
waste industry have tended only to get involved when it suits
them. It was questioned whether industry is able to lead a planning
process rather than respond to it, hence the limited involvement
(interview with County Council Planning Policy Manager).
The process of agreeing on a way forward for difficult
strategic decisions was problematic as officers are at times wary
of offering views that "may not be well received back at
the ranch". The principal of what is trying to be achieved
is understood but difficulties can arise when detailed discussions
occur. The example was given of the apportionment of residual
waste from London for landfilling in surrounding counties. In
this instance there was agreement that apportioning waste in this
manner is appropriate, however the consensus unravelled once discussions
reached the stage of allocating figures for individual WPAs' apportionments
(interview with County Council Planning Policy Manager). However
an alternative view from the West Midlands RTAB was that members'
engagement has been motivated by self-interest on occasions, "but
the ethos of the group has prevailed and they have quickly taken
the broader view or moved on quickly and been replaced",
suggesting different experiences in the different RTABs across
the country.
Despite these issues RTABs have performed a valuable
role in developing effective waste planning policy, as they have
proved to be an effective forum for the technical work, especially
data collection and analysis, which is essential to planning effectively.
A Regional Planner argued that "what it did do was enable
evidence to be collated and policy discussed and developed collectively,
without one authority dominating or influencing due to certain
political views, for example being anti-incineration. The democratic
accountability came through the Assembly as all policy decisions
were made by members through Regional Planning Committee, Executive
Committee and full Assembly".
At this stage it remains unclear exactly what future
holds for RTABs. One local authority SERTAB member believed that
as much the groups work had been led by the South East England
Partnership Board, the fact that that organisation has been abolished
means there is now a need for the RTAB to take stock and consider
its future role. It was felt that there remains a useful role
to play, however to continue there must be a reassessment of the
scope and purpose of the group.
A West Midlands RTAB member was also of the opinion
that RTABs have been a success and should continue. In terms of
their future role, the view was not whether they are able to work
with the new Government, as RTABs have thus far worked effectively
in all regions regardless of political composition, but will they
be allowed and continue and work with them. The inference here
is that a decision to abolish RTABs would be political and not
a reflection of the effectiveness of the groups.
It was argued that the continuation of RTABs will
be essential under the new administration if agreed data and analysis
to be available to WPAs, as good quality data is an essential
requirement of assessing the need for, and therefore adequately
planning for, waste management facilities (interview with former
CLG officer). The West Midlands RTAB member felt that there had
been some success so far in the aim of producing good quality
data, as bringing together a wide range of stakeholders "has
been effective in brokering sensible estimates of demand unlike
the RAWP[9]
which has been industry dominated and had a reputation for always
overestimating need".
FUTURE OF
STRATEGIC WASTE
PLANNING
There is agreement that there will be a need for
discussions on waste planning to continue at a strategic level
at a scale between the counties and national government. The revocation
of the RSSs has created "a massive vacuum in [waste planning]
policy" (interview with Strategic Waste Policy officer),
with the limited interim guidance issued by the Government being
described as "hopelessly vague… no-one knows what the
national planning policy is now". (Webb, 2010)
Without a regional tier of policy making, planning
for regionally significant facilities will be difficult, as although
decisions could be made locally at officer level, the local democratic
process can override recommendations for political reasons. Given
the inherent unpopularity of waste facilities, this situation
is likely to lead to inadequate planning for the required capacity
(interview with County Council Planning Policy Manager).
There is evidence that the motivation for the rapid
removal of RSSs is to alleviate the burden of the housing targets
they contained, as discussed above, and has involved little consideration
of the effect of this action on other aspects of strategic planning.
The focus on localism and local decision making may be problematic
when applied to such an inherently controversial form of development
as waste management which has an increasing requirement for regionally
significant facilities.
In addition the abolition of RSSs will remove the
strategic targets and level of policy which could be used locally
and by industry to demonstrate the need for new facilities, particularly
those serving a catchment regional or sub-regional catchment area
(interview with Regional Planner). Without regional policy, planning
applications for regionally significant facilities will be easier
for authorities to reject (interview with County Council Head
of Planning), jeopardising the delivery of new waste management
capacity which is needed to achieve Landfill Directive targets.
RTABs could see their role enhanced as the abolition
of RPBs would leave them as the only remaining regional level
institution (interview with County Council Head of Planning).
However, RTABs are solely a technical body with no policy making
responsibilities, and as discussed above, will be reliant on decisions
being implemented through local policies. However, the indication
from CLG that the role of RTABs will, in due course, be transferred
to local authorities casts doubt on whether this is possible without
some form of structural reorganisation. As one of the reasons
for the establishment of RTABs in the first place was that individual
authorities were unlikely to have the resources to carry out the
required data collection and analysis individually they are likely
to have to form voluntary groupings along the lines of the RTABs
in order to continue this essential work. This could be argued
as a reversion to the situation in the mid-1990s until establishment
of statutory RSSs in the 2004 Act, where regional groupings of
officers, through RTABs, "offered a view on agreed common
assessments of waste arisings, future need and capacity arrangements
to their constituent WPAs, together with a view on the spatial
pattern required to deliver it" (interview with former CLG
officer).
Whilst there are clear benefits in groupings such
as this, the lack of regional policy to support the technical
work performed by RTABs or their replacements will be a hindrance.
There are already tensions in reaching consensus on controversial
strategic issues, and without statutory regional policy to deliver
these objectives local authorities may not have the discipline
to carry them out. In other words, without support from policies
that form part of the statutory development plan the difficult
decisions recommended at officer level may fail to be implemented
when considered by elected representatives. In addition, "voluntary
collaboration can be hard to achieve and can disintegrate following
a change of political leadership" (TCPA, 2010:7), which casts
doubt on the stability of any new sub-regional groupings.
A collective refusal by authorities to deal suitably
with site allocations would expose the UK to EU penalties under
the Waste Framework Directive. There is therefore a requirement
for an effective conflict resolution system as any new grouping
would be relying on a number of WPAs to implement their recommendations
without clear policy support. Clear government guidance to ensure
that WPAs engage with each other effectively in order to deliver
the strategic facilities that are necessary would be desirable.
The lack of a single regional point of contact may
also be a problem as there will be no regional voice to respond
or input to policy in other areas. In addition industry may find
it harder to effectively engage with the planning process on a
strategic level as operators would have to communicate directly
with each WPA instead of having a single regional body to liaise
with (interview with Regional Planner).
RECOMMENDATIONS
The Coalition Government needs to acts swiftly to
provide a strategic level replacement for RPBs at a level above
counties. It is clear that adequately planning for waste management
increasingly requires coordination at this level. The removal
of RPBs and revocation of RSSs with no clear indication of what
will replace them is damaging to the aim of moving towards sustainable
waste management.
The policy vacuum has caused uncertainty and the
removal of strategic level waste polices from the statutory development
plan will result in more decisions being subject to political
forces at county level. Several possible scenarios for a strategic
replacement appear possible based on the research carried out
for this report. Table two identifies these together with potential
risks and opportunities:
Table 3
POSSIBLE SCENARIOS FOR NEW STRATEGIC WASTE
PLANNING ARRANGEMENTS
| Scenario | Opportunities
| Risks |
| Voluntary groupings of WPAs at a sub-regional level to continue technical work performed by RTABs.
| More spatially coherent groupings which better reflect the nature of waste movements and interdependencies between areas, allowing more effective spatial planning. Essential data collection work would continue.
| Reliance on individual WPAs to devise policies at the local level to implement group decisions may be problematic. Lack of regional policy to support need for new facilities.
|
| Groups of WPAs produce statutory development plans and policies covering sub-regional areas
| More spatially coherent groupings which better reflect the nature of waste movements and interdependencies between areas Regional technical work is backed up by policy to deliver the required capacity and distribution of new facilities
| Vulnerable to changes in political administration in constituent authorities. Difficulties in agreeing distribution of facilities amongst WPAs. Difficulties in coordinating work between a number of groups of officers. Need for effective conflict resolution.
|
| RTABs continue in their present form to provide strategic technical support to WPAs
| Existing established working relationships at regional level between officers can continue. WPAs benefit from strategic level data to help preparation of DPDs
| Lack of regional policy support for RTABs recommendations may hinder their implementation
|
In the absence of a formal regional planning tier the Coalition
Government must quickly engage with WPAs to develop an effective
strategic coordinating system for waste planning, together with
clear instructions to local authorities on the need for cooperation
on difficult issues.
REFERENCES
SLR Consulting (2005), "Delivering Key Waste Management Infrastructure:
Lessons Learned from Europe", CIWM;
Webb, S (2010) cited in Planning Daily, 16.7.10 www.planningresource.co.uk/bulletins/Planning-Resource-Daily-Bulletin/News/1016027/Regions-defence-steps/?DCMP=EMC-DailyBulletin
August 2010
9
Regional Aggregate Working Party, the equivalent grouping in minerals
planning. Back
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