Written evidence from Covanta Energy (ARSS
82)
SUMMARY
US-based Covanta Energy Corporation (Covanta) is
the world leader in developing and operating Energy from Waste
(EfW) power stations to generate renewable and low carbon energy
from residual waste.
Typically, projects of interest to Covanta will be
scaled to meet the needs of more than one waste disposal authority
(WDA) or to cater for joint municipal/merchant requirements. Consequently,
they tend to be of at least sub-regional or regional significance.
EfW is recognised within EU and UK legislation and
policy as having a valuable part to play in meeting cost-effectively
important objectives in driving the move towards a low-carbon
economy and towards a more resource-based approach to waste management.
Historically, the biggest single barrier to the development
of new EfW facilities has been planning.
In recognition of the difficulties that the waste
management sector in general (and EfW developers in particular)
have faced in the planning system, government has in recent years
worked to put in place a comprehensive and cohesive policy framework
to guide planning decisions.
Regional Spatial Strategies (RSS) were conceived,
at least in part, to provide a mechanism for giving spatial expression
to the development parameters of these national strategies and
policies, especially for projects of greater than local significance.
It is clear from the announcements made by the new
government in the lead up to RSS abolition that their main focus
was on the housing aspects. At no time, ahead of their abolition,
was any statement made either to show that the government appreciated
the wider role of RSSs, especially in relation to wider infrastructure
provision.
The abolition of RSSs leaves a potentially serious
gap between broad statements of policy and approach at the national
level and the detailed land-use frameworks that will be set out
at a local level by LPAs. It is essential that LPAs are obliged
in their plans to take into account wastes streams arsing outside
their area.
A duty to co-operate on its own will not be enough
to ensure that realistic co-operation takes place.
It will be incumbent upon government to put in place
strong powers and guidance to ensure co-operation. It will also
need to be willing to intervene to secure co-operation and solutions
where it becomes apparent that the imperatives of local decision-makers
will lead them to fail to deliver on wider regional and national
priorities.
We are very sceptical that the proposed Local Enterprise
Partnerships (LEP) will be able to play significant role. It will
be some time before LEPs are up and running, and possibly as long
as four years before any would be in a position to exercise any
meaningful planning role.
INTRODUCTION
US-based Covanta Energy Corporation (Covanta) is
the world leader in developing and operating Energy from Waste
(EfW) power stations to generate renewable and low carbon energy
from residual waste.
The company operates 44 EfW plants internationally,
handling around 18 million tonnes of residual waste every year—equivalent
to around two thirds total UK municipal waste arisings. Most of
these plants have been built to meet the needs of local authorities,
enabling them to divert from landfill waste that cannot be recycled,
generating beneficial renewable electricity and, where practicable,
heat and reducing harmful carbon emissions.
Covanta has been active in the UK waste market since
2005, pursuing a combination of local authority and merchant development
opportunities. The company's current plans envisage inward investment
to the UK in excess of £2 billion to renew the UK's waste
management infrastructure and create significant renewable and
low carbon generating capacity.
Typically, projects of interest to Covanta will be
scaled to meet the needs of more than one waste disposal authority
(WDA) or to cater for joint municipal/merchant requirements. Consequently,
they tend to be of at least sub-regional or regional significance.
EFW AND
PLANNING
EfW is recognised within EU and UK legislation and
policy as having a valuable part to play in cost-effectively meeting
important objectives in driving the move towards a low-carbon
economy and towards a more resource-based approach to waste management.
Such policies recognise that EfW is a means of securing renewable
and low-carbon energy production form residual waste streams that
cannot viably be recycled, contributing significantly towards
the reduction of greenhouse gas emissions. The new UK government
has confirmed its commitment to securing future EfW development.
For example, the terms of reference of the Department of the Environment,
Food and Rural Affairs (DEFRA) review of waste policy sets an
objective to "maximise the cost effective generation of renewable
energy from residual waste."[121]
Historically, the biggest single barrier to the development
of new EfW facilities has been planning. In part this has been
a consequence of public opposition resulting in concerted 'NIMBY'
pressure on planning committees to refuse planning consent, even
where the material considerations in support of such a decision
have been flimsy. Such decisions mean that applicants face the
additional burden and delay associated with making an appeal to
the Secretary of State.
A significant problem that has compounded this has
been a long-standing inadequacy in the regional and local development
plan system which has meant that most Local Planning Authorities
(LPA) have not had in place an effective policy framework to provide
guidance on the appropriate level and location of new waste infrastructure.
In the absence of this kind of policy framework, it is more difficult
for LPAs to resist well-orchestrated and vocal local opposition
to proposals.
One result of this is that the planning lead-times
for EfW projects typically lie in the range of three to seven
years. New plants take around three years to build and commission
once planning consent is obtained.
However, the UK faces a number of immensely challenging
legal obligations, including:
Reducing by 2020 the proportion of biodegradable
municipal waste sent to landfill to just 35% of the level in 1995;
and
Increasing the proportion of electricity generated
from renewable sources from around 6.5% in 2009 to 30% by 2020.
EfW has a vital contribution to make to meeting these
obligations, but will only be able to do so if decisions on future
planning consents are made in a timely manner that attaches significant
weight to the wider regional and national policy priorities.
RSS AND AN
EFFECTIVE PLANNING
FRAMEWORK
In recognition of the difficulties that the waste
management sector in general (and EfW developers in particular)
have faced in the planning system, government has in recent years
worked to put in place a comprehensive and cohesive policy framework
to guide planning decisions.
At a national level, this has included:
Waste Strategy 2007.
Low Carbon Transition Plan 2009.
Renewable Energy Strategy 2009.
Planning Policy Statement 10, planning for sustainable
waste management.
These documents have established the broad need case
for the different waste management and renewable and low-carbon
energy technologies and considerations that should govern site
selection and the determination of planning applications for them.
Regional Spatial Strategies (RSS) were conceived,
at least in part, to provide a mechanism for giving spatial expression
to the development parameters of these national strategies and
policies, especially for projects of greater than local significance.
This is a vital consideration for EfW projects where larger scale
facilities can deliver substantial economic and environmental
benefits over smaller ones. For example, the cost to customers
of using a 600,000 tonne facility could be as much as 50% lower
than for 200,000 tonne one, while its energy efficiency will be
significantly higher, delivering important carbon benefits.
Such projects often will be of a size that exceeds
the municipal waste arisings of a single LPA. They may also be
conceived to cater for both the municipal and commercial and industrial
(C&I) markets. The key benefit of the RSSs was that they provided
a reasonably robust assessment of the long-term arisings across
both of these sectors, typically over a 20 year horizon. This
statistical base had the potential to provide a sound rationale
for large-scale projects which individual LPAs otherwise would
be highly likely to resist, if only on the grounds that they were
not necessary to meet purely local needs.
IMPACT OF
RSS ABOLITION
The critical role of the RSS in informing the scale
and nature of provision for future waste infrastructure to be
made by LPAs in their waste plans is set out in paragraph 17 of
PPS10 which states that:
"Waste planning authorities should identify
in development plan documents sites and areas suitable for new
or enhanced waste management facilities for the waste management
needs of their areas. Waste planning authorities should in particular:
allocate sites to support the pattern of waste management
facilities set out in the RSS in accordance with the broad locations
identified in the RSS; and
allocate sites and areas suitable for new or enhanced
waste management facilities to support the apportionment set out
in the RSS."[122]
It is clear from the announcements made by the new
government in the lead up to RSS abolition that their main focus
was on the housing aspects. At no time, ahead of their abolition,
was any statement made either to show that the government appreciated
the wider role of RSSs, especially in relation to wider infrastructure
provision.
The 6 July letter from DCLG's Chief Planner providing
guidance to LPAs on the way forward following abolition of RSSs
sought to address this gap. With regard to waste management it
calls upon them to press ahead with preparation of waste plans
and "provide enough land for waste management facilities
to support the sustainable management of waste (including the
move away from disposal of waste by landfill."[123]
It notes that data collected by the authority, industry and other
partners through the Regional Waste Technical Advisory Bodies
will continue to be available to inform plan preparation. In future,
it says, that the function of collecting this data will be transferred
to the local authorities themselves. This inevitably means that
the focus of future waste planning will become more narrowly focussed
on the immediate needs of local planning authority areas, rather
than on the wider regional and even national priorities and requirements.
RESPONSES TO
COMMITTEE QUESTIONS
We provide below short responses to the specific
issues raised by the Committee and relevant to our future development
interests.
The arrangements which should be put in place
to ensure appropriate cooperation between local planning authorities
on matters formerly covered by regional spatial strategies (eg
waste, minerals, flooding, the natural environment, renewable
energy, &c.)
As noted above, the abolition of RSSs leaves a potentially
serious gap between broad statements of policy and approach at
the national level and the detailed land-use frameworks that will
be set out at a local level by LPAs. It is essential that LPAs
are obliged in their plans to take into account wastes streams
arsing outside their area. The regional areas covered by the RSSs
provide a reasonable proxy for the kind of geographical area that
should be considered in order to maximise opportunities for economically
and environmentally beneficial handling of wastes, especially
residual wastes.
Going forward, in the absence of RSSs government
will need to ensure that this wider view is taken by:
Enshrining within the Localism legislation a duty
for local waste plans to assess waste arisings across the relevant
region and indicate broadly where they can best be accommodated.
Where an authority proposes to adopt a policy that would preclude
bringing waste into its area for treatment, it should be obliged
to provide a robust justification for that.
Providing within a revised PPS10 strong and specific
guidance on local waste plan preparation to ensure that this obligation
is required and intervention where necessary through the Examination
in Public (EiP) process to secure compliance. In addition, PPS10
should include guidance on how LPAs within a region should work
together to develop an agreed approach that will ensure that sufficient
capacity is identified in plans to meet regional needs.
Placing an obligation upon a suitable competent authority—probably
the Environment Agency—to make periodic regional assessments
and forecasts of waste arisings across all waste streams to be
drawn upon by LPAs in preparing their plans.
The adequacy of proposals already put forward
by the Government, including a proposed duty to co-operate and
the suggestion that Local Enterprise Partnerships may fulfil a
planning function
A duty to co-operate on its own will not be enough
to ensure that realistic co-operation takes place. Under existing
arrangements a duty of co-operation exists between, for example,
the Greater London Authority and the surrounding regions in respect
of the apportionment of waste that may need to cross regional
boundaries for treatment and disposal. At each plan iteration
and revision there is conflict between these bodies that is left
to government-appointed experts to resolve at EiP.
Given that the planning process in future will be
much more fragmented, such conflict is likely to become more,
not less, endemic. It will be incumbent upon government to put
in place strong powers and guidance to ensure co-operation (see
response to question above). It will also need to be willing to
intervene to secure co-operation and solutions where it becomes
apparent that the imperatives of local decision-makers will lead
them to fail to deliver on wider regional and national priorities.
We are very sceptical that the proposed Local Enterprise
Partnerships (LEP) will be able to play significant role. At the
time of writing, the deadline for submission of proposals has
just passed and some 56 LEP proposals have been submitted. It
is clear that they vary enormously in the geographic coverage
and the nature of the partnership underpinning them and in their
aspirations. Not all of the country is covered by the proposals.
It will be some time before LEPs are up and running,
and possibly as long as four years before any would be in a position
to exercise any meaningful planning role. In the meantime, there
will be a critical gap in regional planning policy coverage that
could significantly impede development needed to meet key landfill
diversion targets in 2013 and 2016 and 2020.
September 2010
121 http://www.defra.gov.uk/corporate/consult/waste-review/index.htm
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122
http://www.communities.gov.uk/publications/planningandbuilding/planningpolicystatement10
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123
http://www.communities.gov.uk/publications/planningandbuilding/letterregionalstrategies
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