National Planning Policy Framework

Written evidence from the Chartered Institution of Wastes Management (CIWM)

The Chartered Institution of Wastes Management (CIWM) is the professional body which represents around 7,000 waste management professionals, predominantly in the UK but also overseas. The CIWM sets the professional standards for individuals working in the waste management industry and has various grades of membership determined by education, qualification and experience.

House of Commons Communities and Local Government Committee examination of draft National Planning Policy Framework (NPPF)

1 The waste and resource management sector has the potential to make a significant contribution to the green economy, supporting economic development, resource efficiency and the energy and climate change agendas. Estimates suggest that between £10 and £20 billion of new waste infrastructure will be needed across the UK by 2020. However, planning issues remain a key barrier to delivery. The draft NPPF is therefore highly relevant to CIWM.

2 Summary:

· CIWM is disappointed that waste has been left out of the draft NPPF.

· CIWM remains to be convinced that the NPPF properly implements its own definition of sustainable development.

· If waste is dealt with outside of the NPPF, it will be vital to ensure that the interface between specific waste and resource planning policy and the general planning principles embodied in the NPPF (much of which could be supportive of our industry) is effectively managed.

· CIWM does not think that the NPPF, on its own, will deal with the challenges of larger-than-local planning issues. This is extremely relevant to our sector, which cannot be planned effectively on an entirely local basis.

· CIWM is looking for an urgent resolution of these issues. Large amounts of new waste infrastructure need to be built over the next decade if the UK is to meet its ambitious environmental ambitions. We cannot afford a lengthy transitional period while the new planning framework replaces the old.

Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?

3 For the resource and waste management sector there is a vacuum. It is disappointing that waste has been orphaned out of the NPPF (see paragraph 7 of the draft NPPF); this undermines the principle of unified planning policy. PPS 10 contains important and necessary detail that could be transferred, without waiting for the Waste Management Plan (WMP). If there is to be no equivalent governmental guidance, this could leave planning professionals with insufficient information on which to base important and complex decisions on waste planning cases. CIWM thinks a significant piece of work would then need to be done by professional institutions in planning and relevant environmental professions to make sure information, skills and relevant guidance can be made available in sufficient time. CIWM is happy to commit to this but would always prefer to see guidance offered the proper status by being Government derived.

4 CIWM feels it is crucial that the NPPF should stress the importance of local planning authorities developing and publishing their local Plan, as this will allow them to interpret the NPPF properly in the context of their local circumstances, and will empower local people. However, local waste plans also need the right emphasis and attention, as these will help locally elected members to have the confidence to support waste infrastructure projects when they accord with the local waste plan.

Is the definition of ‘sustainable development’ contained in the document appropriate; and is the presumption in favour of sustainable a balanced and workable approach?

5 Having waste taken out of the draft NPPF makes it particularly difficult to answer this question as the resource and waste management sector is left waiting for further elements of planning policy/strategy. For example the Waste Management Plan (WMP) is still awaited and CIWM is unsure of the relationship of the NPPF and the WMP.

6 However, in broad terms, CIWM feels that although the definition of sustainable development proposed in paragraph 9 of the draft NPPF is fine, the interpretation of that definition, as set out in the following paragraphs, is more problematic. For example, paragraph 13 moves from supporting ‘sustainable development’ to ‘sustainable economic growth’. However, the two are not synonymous. Paragraph 14 suggests that ‘Local planning authorities should plan positively for new development, and approve all individual proposals wherever possible.’ This does not appear to implement the trade-off between economic, social and environmental goals that is at the heart of sustainable development.

Are the ‘core planning principles’ clearly and appropriately expressed?

7 The Institution is unclear as to whether the general principles contained in the NPPF apply to the resource and waste industry, as they apply to other sectors; waste is not included in the Framework. It is therefore difficult for us to comment on this issue directly.

Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear? Does the NPPF serve to integrate national planning policy across Government Departments?

8 Since the Framework explicitly excludes the resource and waste sector, which is to be dealt with later, it is difficult at this stage to comment on the first issue. Perhaps the best way to overcome this would be to incorporate resource and waste into the NPPF. CIWM is seeking advice from Government as to why resources and waste have been left out of the NPPF. If resource and waste issues are not re-incorporated back into the NPPF, CIWM would welcome some assurances about the way that the interface between the NPPF, Waste Management Plan and other elements of the waste planning regime will be managed.

Does the NPPF, together with the ‘duty to cooperate’, provide a sufficient basis for larger-than-local strategic planning?

9 The larger-than-local scale is very important for the resource and waste sector; there are links to economic development when using resources and waste, and economies of scale as well as of investment, favouring facilities that draw feedstocks and serve markets that are not bound by artificial local boundaries.

10 The NPPF does not appear to deal sufficiently with this scale of planning, CIWM needs to see much more detail regarding the operation, resourcing and support of the ‘duty to cooperate’ before we will be able to have confidence in its ability to deliver greater than local thinking and action on resources. Previously set-up regional collaboration frameworks (RTABs) have now been variously disbanded. This means there is a need for a National Planning Statement (NPS) for resources and waste to fill the gap between the scale of project that will be dealt with by the major infrastructure planning unit and entirely local planning.

11 The waste and resource management sector needs a planning system that is capable both of delivering the waste infrastructure that is needed for a greener economy and of protecting natural resources and the natural environment. This needs to happen at multiple scales; it is not clear to CIWM that the draft NPPF can deliver this without further thought.

Are the policies contained in the NPPF sufficiently evidence-based?

12 CIWM believes that the UK is going to need significant changes to waste and resource management infrastructure– collection systems, treatment and distribution of outputs, etc – if it is to make a proper contribution to sustainable living. The existing planning system has proven to be slow and expensive, as well as vulnerable to overturn and appeal – for example, the CBI recently reported that it takes seven years on average for a waste management company to get a plant up and running, of which four years are spent in the planning process. Therefore, whilst the existing system is capable of developing strategies and approving individual applications, as an industry we have long been calling for improvements to the system. Whilst high level concepts contained in the NPPF may lead to streamlining planning and delivery, for our sector it is unclear what relationship we are likely to have with the final NPPF, given our exclusion from it. The resource and waste industry will therefore find this particular question hard to answer, until further policy/strategy has been issued.

September 2011