Consultation Draft of the Surrey Waste Plan : Executive on 06/12/2005

Waverley Borough Council Committee System - Committee Document

Meeting of the Executive held on 06/12/2005
Consultation Draft of the Surrey Waste Plan

Summary & Purpose

The report sets out the objectives, and the main issues of the “Surrey Waste Plan-Preferred Plan 2005” and explains the implications of the Plan for Waverley.

The Plan is currently undergoing a period of consultation, and it is recommended that Waverley respond with comments suggested in this report. Whilst the Borough is not affected significantly by proposals such as the identification of possible thermal treatment plants, the Plan nevertheless highlights major challenges in waste management that will have major implications for Waverley and the whole of Surrey.

This report has been prepared for consideration by a specially convened meeting of the Environment and Leisure Overview and Scrutiny Committee. The meeting is due to have been preceded on the same day by a Development Control Forum to which all Waverley Members have been invited. Whilst this report makes a series of recommendations for representations to be made to Surrey County Council, Members may wish these to be modified as a result of the presentations and discussions at that earlier Forum.

APPENDIX L

Waverley Borough Council

EXECUTIVE - 6TH DECEMBER 2005

eNVIRONMENT and LEISURE OVERVIEW AND SCRUTINY COMMITTEE –
1ST December 2005

Title:

CONSULTATION DRAFT OF THE SURREY WASTE PLAN

[Wards Affected: All]

___________________________________________________________________

Summary and Purpose:

The report sets out the objectives, and the main issues of the “Surrey Waste Plan-Preferred Plan 2005” and explains the implications of the Plan for Waverley.

The Plan is currently undergoing a period of consultation, and it is recommended that Waverley respond with comments suggested in this report. Whilst the Borough is not affected significantly by proposals such as the identification of possible thermal treatment plants, the Plan nevertheless highlights major challenges in waste management that will have major implications for Waverley and the whole of Surrey.

This report has been prepared for consideration by a specially convened meeting of the Environment and Leisure Overview and Scrutiny Committee. The meeting is due to have been preceded on the same day by a Development Control Forum to which all Waverley Members have been invited. Whilst this report makes a series of recommendations for representations to be made to Surrey County Council, Members may wish these to be modified as a result of the presentations and discussions at that earlier Forum.

Environmental implications:

The Surrey Waste Plan, if sustainably implemented, would achieve a considerable improvement in the control and disposal of waste, meeting the need to reduce the waste stream and finding ways for Surrey to become self sufficient in the disposal of its own waste.

Social / community implications:

The community will be encouraged to make lifestyle changes including making waste-conscious purchasing decisions, recycling additional materials, composting at home and reducing the waste stream.

E-Government implications:

There are no direct implications for E-government associated with this report.

Resource and legal implications:

Surrey County Council is required to produce a Waste Plan in a form required by the Planning and Compulsory Purchase Act 2004. Whilst there are no direct legal implications for this Council, Waverley is a statutory consultee in the process and could become variously affected by policies set out in the Waste Plan.

Similarly, there could be financial implications resulting from the location of, and facilities available at waste management and waste disposal sites across the County.

Background

1. “The Surrey Waste Plan – The Preferred Plan 2005”, was approved for consultation by the Surrey County Council Executive on 27th September 2005. A period of six weeks of consultation began on 31st October. All Members have been sent a copy of the document as background to the Development Control Forum being held before this meeting.

2. The Plan sets out policies and proposals for the development of waste management facilities in Surrey up to 2016. The following documents comprise the legal framework of the Plan:

a) The Core Strategy; setting out the spatial vision with key spatial objectives and strategic objectives and policies;

b) Waste Development; containing site-specific proposals;

c) Waste Development Control Policies; and

d) The Proposals Map.

3. The amount of waste produced in Surrey and how it is managed is set out in Annexe 1 to this report. It may be noted that municipal solid waste accounted for a relatively small percentage of the total Surrey waste stream, at 18.5% of total arisings in 2004/05.

The Objectives of the Plan in the Core Strategy

4. The strategic objectives of the Waste Development documents are:

a) To provide for sustainable management of Surrey’s waste;

b) To address waste as a resource and look for disposal as the last option;

c) To provide treatment and disposal facilities so that Surrey will be net self-sufficient in accordance with the South East Plan;

d) To permit local installations in accord with the proximity principle;

e) To protect the Green Belt, but recognise it may have to be used for some facilities;

f) To reflect the concerns and interests of communities and the needs of business, and waste collection and disposal authorities;

g) To protect the environment and heritage; and

h) To enable the provision of a range of waste technologies including Energy from Waste.

The Locational Strategy

5. The main elements of the Locational Strategy are:

a) There should be waste minimisation and more recycling;

b) Surrey must provide enough facilities to meet its own needs.;

c) New facilities will be considered for a sequence of identified locations, reflecting the makeup of the County and the general
locational strategy of the Surrey Local Structure Plan;

d) Industrial sites and urban areas are the prime locations;

e) Previously developed land and redundant farm buildings may also be suitable;

f) Only In very special circumstances can sites be in the Green Belt; and

g) Sites should be on the strategic road network.

Thermal Treatment of Waste

6. One of the issues for the Plan is that of thermal treatment facilities. This follows the National Waste Hierarchy, originally set out in the Government’s “Waste Strategy 2000” as the preferred environmental approach to waste management. This places energy recovery from waste below waste reduction, reuse, recycling and composting, but above disposal by landfill, in the following descending order of importance:

i. Reduce

ii. Reuse

iii. Recycle

iv. Compost

v. Disposal with energy recovery

vi. Disposal to landfill

7. The Plan proposes that planning permission for development involving the thermal treatment of waste will be granted provided:

a) the waste to be treated cannot practically and reasonably be reused, recycled or processed to recover materials;

b) provision is made for energy recovery;

c) the proposed development is at the following preferred site, as shown on the proposals map:

· Clockhouse Brickworks, Capel:

d) and, where very special circumstances can be demonstrated in accordance with Policy CS6, the following safeguarded sites will be considered:

· Charlton Lane, Shepperton

· Martyrs Lane, Woking

· Randalls Road, Leatherhead

· Land adjacent to Trumps Farm, Longcross

· Land at Wisley Airfield

8. The appearance of a preferred site, and other possible sites is likely to prove to be controversial in their proximity.

Sites for Recycling, Storage, Transfer, Materials Recovery and Processing (Excluding Thermal Treatment).

9. The Plan considers the need for the bringing together of waste collected from a number of sources, either on a large scale or a small scale:

“C8 Recycling, recovery and processing facilities cover a wide range of technology types that might include a materials recovery facility, mechanical biological treatment plant, or autoclave plant. This list is not exhaustive of the current technologies available and the policy is not technology specific so that the Waste Development document is able to react to new technologies that are developed. In essence, these facilities are expected to enable and to encourage waste to be used as a resource, and to recover materials that will be put to beneficial use

Policy WD2

does not include those technologies that involve the thermal treatment of waste.

C9 The recycling and processing of waste is increasingly being carried out within modern, purpose-designed buildings that can be located in urban areas and industrial estates. In terms of supporting sustainable communities, the location of waste facilities within the urban fabric is preferred. An Area Action Plan is being prepared jointly with Guildford Borough Council for Slyfield, where land for waste development will be allocated. A list of 29 industrial estates, which may be able to accommodate waste development, [

is shown below, in Table 3.1,

] although this list is not exhaustive.”

10. Of these 29 “Potential Urban Sites/Industrial Estates for Accommodating Waste Development” have been identified in the Plan, 4 of which are in Waverley:

a) Farnham Trading Estate, Water Lane, Farnham;

b) Bourne Mill Trading Estate, Farnham;

c) Hewitts Trading Estate, Cranleigh;

d) Coxbridge Sandpit, Farnham.

11. Provided policies in the Waverley Borough Local Development Framework Core Strategy, and the Waverley Borough Local Plan 2002 are met, the use of any “Potential Sites” that do come forward in Waverley would need to be considered very carefully depending on their use and environmental impact.

12. However, the Waste Plan recognises that urban locations within Surrey are not readily available, and therefore other discrete sites have also been named as either 2 “Preferred Sites” or 11 sites “Safeguarded” for waste development. None of these Preferred or Safeguarded sites are in Waverley.

Further Officer Comment

A- Location of facilities in the Green Belt

13. The location of facilities in the Green Belt is likely be a major issue where it arises. PPS10 states the Waste Planning Authority should:

a) “protect Green Belts but recognise the particular locational needs of some types of waste management and that the wider environmental and economic benefits of sustainable waste management are material considerations that should be given significant weight in determining whether proposals should be given planning permission” (paragraph 3).

b) A number of the sites safeguarded for waste facilities in the Plan are in the Green Belt, (though not in Waverley). Policy CS6 of the Surrey Waste Plan states “there will be a presumption against inappropriate waste related development in the Green Belt”, but it also states that there are considerations where there may be “very special circumstances” for the locational needs of some types of management facilities and there may be wider environmental and economic benefits of sustainable waste management. This approach is likely to be controversial where it occurs, but it does comply with PPS10.

B- The locational strategy

14. The strategy in the Government document Planning Policy Guidance 10 (1999) was referred to as the “proximity principle”, which stated that “waste should generally be managed as near as possible to its place of production, because transporting waste itself has an environment impact.” This guidance has been amended in PPS10 (2005), and the proximity principle has been downgraded. European Directives have come to the fore instead, requiring that waste be sent to the nearest appropriate installation. The sequence of search for sites in PPS10 (2005) is:

a) Look first to on-site management of the waste where it occurs;

b) Industrial sites looking for opportunities to co-locate facilities together and with complementary activities;

c) Give priority to the reuse of previously developed land, and also in rural areas; to redundant farm buildings and their curtilages before green field sites.

15. The proposal to use industrial estates for waste management facilities included in the Plan does comply with PPS10 (2005), but it is likely that traffic movement will be an issue. PPS10 provides criteria for considering sites and states; ”the capacity of existing and potential transport infrastructure to support the sustainable movement of waste, and products arising from resource recovery whenever practicable should be by modes other than road transport”. This approach does not appear to be feasible for the 4 “Potential” sites identified in Waverley.

C- Surrey Joint Municipal Waste Management Strategy

16. It is widely accepted that sustainable waste management can only be delivered through joint strategic action. Waverley is therefore working with other Surrey Districts (as Waste Collection Authorities) and Surrey County Council (as Waste Disposal Authority) towards the adoption of a Surrey Joint Municipal Waste Management Strategy. Whilst the joint strategy is being developed under a separate legal regime there is virtually no linkage between them with only a single simple reference at Paragraph A31:

“Surrey County Council is preparing a joint municipal waste management strategy with District and Borough Councils to cover municipal waste, under new Government guidelines.”

17. This is a potentially important omission as an indicator of lack of connectivity of strategic processing within SCC.

D- Waste Disposal Contract

18. Surrey County Council as Waste Disposal Authority is delivering a number of its principal disposal functions through the mechanism of a comprehensive 25-year private-sector contract. This includes the provision of disposal services and disposal infrastructure. The Draft Waste Plan does not reference the performance of this contract as a key driver in the provision and location of waste disposal facilities in Surrey for the life of the Plan and beyond.

E- Minerals and Waste

19. It would have been beneficial to link this Waste Plan with the emerging Surrey County Council Minerals Plan. Notification has been received that the Statement of Community Involvement for the SCC Minerals and Waste Plans has been submitted to the Secretary of State, although the Draft Minerals Plan, referred to as the “Preferred Options” is not expected to be ready for public consultation until Spring 2006.

20. Many waste disposal facilities, and landfill sites in particular, are located at previous minerals extraction sites. There are many of these in Waverley associated with geological deposits in the areas of Farnham and Cranleigh that are linked with earlier and possibly future extraction.

21. Whilst it is clear from EU and domestic Government policy that landfill capacity is being restricted into the future, and that this is also a clear driver for the Surrey Waste Plan, it would be reassuring for Waverley’s local communities to see the inclusion of an unambiguous strategic statement that such existing and future mineral extraction sites will not be used for landfill purposes.

F- Compatibility and Connectivity with Waste and Minerals Plans in Surrounding Areas

22. Since Surrey shares boundaries with other waste and minerals planning authorities it is important that facilities are located in such places, and following such consultation, that neighbouring authorities and any impact on their communities are taken into account. This is especially the case where facilities are to be located close to common boundaries and may therefore adversely affect communities of more than one responsible authority.

G- Fiscal Measures

23. Whilst difficult to model, the future effects of important fiscal measures should be included in the Surrey Waste Plan as they will undoubtedly impact on the demand for and location of waste management infrastructure. The most important of these are:

a) Landfill Tax

b) Aggregates Levy

c) Landfill Allowance Trading Scheme

24. In particular it will be important to avoid these impacting disproportionately across Surrey.

H- Sustainable Development

25. It is suggested that the Surrey Waste Plan should make clear connections with the need for sustainable development. Surrey County Council are therefore encouraged to use this opportunity to further the challenge of decoupling waste generation from economic growth. This is essential if economic growth in Surrey is not to equate to greater environmental damage into the future.

I- Recycling Targets

26. Whilst there is no detailed discussion of the effects of recycling targets, they have had and will continue to have a primary effect on demand for waste disposal and recycling infrastructure in Surrey. It is suggested that the County Council consider the effects of materials-based recycling targets. Whilst not legally binding in the current statutory regime, these could help to capture difficult to collect material such as plastic, which would have a corresponding reduction in predicted need for disposal facilities. In the first instance such targets could be implemented by Surrey on its own function as Waste Disposal Authority and possibly through its own disposal contract.

J- Prescriptive Instruments

27. Surrey could consider excluding certain types of substance from disposal streams as a way of controlling future demand for certain types of disposal or treatment facility in the County. Examples might include excluding cadmium-based batteries from landfill or incineration or unsegregated waste from any form of disposal. Again, such measures could not be made legally binding at this time but could nevertheless be made to have impact in relation to its own activities.

K - Research & Development

28. Reference could usefully be made in the Surrey Waste Plan to priorities for research and development. In particular, these could include:

a) New waste management systems, especially cheaper and cleaner technologies.

b) Information systems;

c) Tackling difficult wastes, such as plastics;

d) Scenario planning, and the identification of unforeseen consequences of policy options; and

e) Identification of the drivers for change in consumer and producer behaviour, including product-life, upgradability and obsolescence.

L- Education & Training

29. The importance of education and training is referred to in the document, but any resources are only likely to have limited effect unless made an integral part of an overall strategy. Making information available in itself is unlikely to raise awareness and even less likely to lead to changes in behaviour unless linked to other policy instruments. For example education and training could more effectively be used to support the introduction of a new or revised service.

M- Contaminated Land Waste

30. Waste generated by the remediation of contaminated land sites could result in unmet demand for appropriate specialist disposal facilities in Surrey. Consideration should therefore be given to allow for this type of disposal where all other options such as on-site treatment have been exhausted.

Conclusion

31. The Waste Plan is to be welcomed as it seeks to contribute towards tackling the major problem of the disposal of waste in Surrey. However, the complexity of the challenge facing Surrey County Council should not be underestimated. It is therefore important that the Surrey Waste Plan is placed in its proper context alongside other strategies in the wider perspective of sustainable development. If Surrey is to maintain a coherent approach and establish clear linkages the comments suggested in this report should be taken seriously as part of the iterative process on waste in moving from the consultation version of the plan to the adopted version.

Recommendations

It is recommended that the Environment & Leisure Overview and Scrutiny Committee advise the Executive to make the comments suggested in this report to Surrey County Council about the “Surrey Waste Plan: The Preferred Plan 2005”.

________________________________________________________________________

Background Papers ( D of P&D / D of E&L)

“Surrey Waste Plan: The Preferred Plan 2005 – For Consultation.” [Available directly at www.surreycc.gov. uk/wasteplan]

Letter from David Munro, Surrey CC Portfolio Holder for the Environment, to Christine Pointer; 31st October 2005.

________________________________________________________________________

Contact Officers:

Names: Geraldine Molony Telephone: 01483 523296

E-mail: gmolony@waverley.gov.uk

Martin Shorten

Telephone:

01483 523434

E-mail: mshorten@waverley.gov.uk

Comms/.exec/2005-06/198