Written evidence from Grundon Waste Management
Limited (ARSS 96)
1.0 SUMMARY OF
KEY POINTS
RELATING TO
ABOLITION OF
REGIONAL SPATIAL
STRATEGIES
Need for some formal arrangement to ensure that regional
and sub-regional requirements are taken into account when local
planning authorities consider proposals for waste management facilities
or mineral extraction which serve a catchment area larger than
a local.
Need for some formal arrangement for continuation
of research previously carried out by the South East Partnership
Board and data incorporated into the South East Plan with respect
to waste management and mineral requirements.
2.0 GRUNDON WASTE
MANAGEMENT LIMITED
2.1 Grundon is the UK's largest privately owned
waste management company, having been established in 1929 as a
family business in the west of London. It provides a wide range
of collection, treatment and disposal options including:
Recycling.
General (non-recyclable) waste collection.
Hazardous waste treatment.
Hazardous and non-hazardous waste landfill.
Clinical/medical waste incineration and treatment.
Tankers (Bulk liquids and APC ash residues).
Energy from Waste.
2.2 There are waste collection depots in Banbury,
Cheltenham, Leatherhead, Oxford, Reading and Slough, with material
recovery facilities at Leatherhead, Reading, Slough, and Oxford.
2.3 The company manages hazardous and non-hazardous
landfill sites in Cheltenham, and a non-hazardous landfill between
Maidenhead and Reading. Clinical/medical waste is managed via
the clinical waste incinerator in Slough, and a high temperature
steam sterilisation facility between Maidenhead and Reading. Hazardous
waste treatment is provided at the Oxford site.
2.4 The Lakeside Energy from Waste plant in Slough,
which has a capacity of over 400,000 tonnes per annum, is a joint
venture between Grundon Waste Management and Viridor.
2.5 Grundon has established a reputation as a
competent and professional waste operator and its clients include
a number of local authorities, as well as numerous commercial
companies and other organisations. It provides waste collection
and recycling for special events such as Wimbledon, British Grand
Prix at Silverstone and Cheltenham Gold Cup.
2.6 In addition to waste management services,
Grundon Sand & Gravel Ltd operates a number of quarries producing
aggregates for the building, construction, decorative, landscaping
and leisure markets. Products include a wide range of sands, gravels,
shingles and decorative stone. Quarries are located at Chieveley,
Frithend, Henham, Thatcham and Faringdon.
3.0 GWML'S COMMENTS
ON ABOLITION
OF REGIONAL
SPATIAL STRATEGIES
Need for some formal arrangement to ensure that
regional and sub-regional requirements are taken into account
when local planning authorities consider proposals for waste management
facilities which serve a catchment area larger than a very local
one
3.1 Grundon Waste Management Ltd considers that
it is well placed to comment on the abolition of regional spatial
strategies given its experience in dealing with a number of local
planning authorities in terms of both submission of planning applications
and consideration of mineral and waste local development documents.
Similarly, it has taken a close interest in the modelling which
forms the basis of the waste capacity requirements in the RSS
for the South East.
3.2 To date there have been no proposals for
how "appropriate cooperation between local planning authorities"
can realistically be achieved. For "unneighbourly" developments
such as waste management facilities, local planning authorities,
whose members have an eye on their electorate, are going to pay
lip service to any "appropriate cooperation" with adjoining
authorities. There needs to be a more formal arrangement to provide
the necessary waste management capacity required to implement
the national waste strategy and meet our obligations under European
legislation.
3.3 There is also the issue that to date local
planning authorities have focused on the management of MSW arisings,
ignoring commercial and industrial and construction and demolition
wastes. However, these wastes comprise over 50% of total waste
arisings in England, compared to MSW which comprises only 9% of
total arisings. (Figures from Waste Strategy 2007). C&I and
C&D wastes tend not to be regarded as 'local' waste requiring
management facilities despite the fact that we all use schools,
hospitals, shops, and work in offices and factories etc. There
is therefore a reluctance on the part of local residents to accept
the need for waste management facilities to handle C&I and
C&D wastes, and a lack of understanding of the C&I and
C&D waste streams on the part of local planning authorities.
3.4 The "appropriate cooperation" reflects
the Government's Open Source Planning Green Paper which suggests
that local planning authorities be given a "Duty to Co-operate
so that there is a sensible conversation between all those involved
in shaping neighbourhoods…" More than sensible conversation
is needed in order to determine how much waste management capacity
will be required and where the capacity should be most sustainably
located.
3.5 The proposal that local plans be developed
through collaborative democracy and grass roots engagement may
work for some types of development which are generally regarded
to be desirable or positive by local residents. However, for waste
developments, it is hard to conceive of neighbourhoods expressing
an aspiration for waste management developments and vying each
other to accommodate such developments within their area.
3.6 The problem is further compounded under the
Green Paper proposal that proposed developments would need to
conform to the local plan. If that local plan were to be built
"bottom up", it has already been stated that there is
little likelihood of neighbourhoods embracing a major waste development
facility within their area. It is difficult to see how developers
of waste management facilities could realistically engage with
the local community and effectively overcome concerns regarding
matters such as perceived health risks and emissions. The likelihood
of comprehensive consultation exercises with local neighbourhoods
in relation, for example, to a major waste management proposal
leading to absence of local opposition is unrealistic.
3.7 It is suggested in the Green Paper that developers
of "unneighbourly" developments could offer compensation
to immediate neighbours for any loss of amenity. However, it is
necessary to determine what benefits would be required to make
a proposed development acceptable in planning terms; anything
over and above could be seen as trying to buy a planning permission.
3.8 As stated above, any major waste development
proposal would be likely to be in contravention of a local plan,
in which case, the Green Paper proposal to limit the grounds for
appeal would mean that a company proposing a major waste management
facility or mineral extraction site would have the right of appeal
only if correct procedures had not been followed.
3.9 There needs to be a formal arrangement, preferably
on the regional level, whereby future requirements for waste management
capacity are established. It is considered naïve to believe
that local planning authorities have the propensity to work with
each other to plan waste management requirements which will meet
the future needs of the country as a whole.
3.10 This is a particular issue in areas such
as Berkshire where there are six unitary authorities which have
the responsibility for preparing or reviewing waste policies in
Berkshire, through the Joint Strategic Planning Unit. The Joint
Unit is responsible to a Joint Strategic Planning Committee, made
up of elected councillors from all six authorities. Not only would
there be the problem of the six authorities cooperating, but furthermore,
there is the issue that waste policies would need to be consistent
with the local plan adopted for each unitary authority.
Need for some formal arrangement for continuation
of research previously carried out by the South East Partnership
Board and data incorporated into the South East Plan with respect
to waste management
3.11 It is not clear how research carried out
previously by the South East Partnership Board and data incorporated
into the South East Plan with respect to waste management could
be carried forward independently by individual local planning
authorities. Some local planning authorities have no staff with
any experience in mineral and waste planning, and few authorities
have the staff with the experience required to carry out specialised
research. It is difficult to see how a "realistic and responsible
approach to future waste management" compromising all waste
streams will be achieved without some form of a regional strategy
for waste management.
3.12 The waste data in the South East Plan is
based on the output of a model developed by ERM and thus the capacity
requirements for the various authorities within the South East
have all been determined on the same basis (though this is not
to say that the model is without flaws.) If each authority were
to develop its own model, there would be no consistency across
a sub-region, much less a region. It would also make it extremely
difficult for the waste industry to engage in the preparation
of local plans if there were no commonality amongst plans.
3.13 The problem is compounded by the fact that
there is a lack of data on waste arisings, other than MSW. Commercial
and industrial wastes compromise almost a quarter of total waste
arisings, but the last survey of C&I waste arisings in the
South East was in 2002-03. With the lack of up-date information
on arisings, future capacity requirements are uncertain.
September 2010
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