Contact: Tony Cook, ext 6730

1. Summary

1.1 The following decisions are sought:

(i) That the South East England Regional Assembly be informed that the County Council's views on the consultation draft of the Regional Waste Management Strategy are, with regard to the vision, land use planning issues and waste management matters, that:

Vision

(a) the Strategy be reconsidered as a resource management strategy with the planning and delivery ultimately reflecting this radical approach; and

(b) support be given to the option involving exceeding Government targets, as this would reflect the philosophy of the approach adopted in Hampshire, subject to clarifying the roles to be undertaken by the various parties to achieve the targets, and the Government accepting the resource implications of this option;

Land Use Planning Issues

(c) the Regional Assembly assure itself that all aspects of the preferred option are justified by the sustainability appraisal, and conform to the waste hierarchy and Best Practicable Environmental Option appraisal and how waste management could be integrated and achieved for all the waste streams;

(d) the Strategy does not give sufficient guidance on how the approach to regional self-sufficiency will be effective in practice and how London's waste should be apportioned;

(e) the Strategy should give more guidance on the approach to be adopted at the sub-regional level;

(f) the Strategy should contain more explicit criteria on-site identification and suitability for new waste management facilities; and

(g) the Strategy should clarify in Policy W23 that the relaxation of Green Belt constraints in the location of new waste management facilities also applies to the general countryside, subject to the need being justified and that the overall benefit outweighs any adverse environmental impact. The Policy should clarify that this distinction does not apply in the same way to the two proposed National Parks and Areas of Outstanding Natural Beauty;

Waste Management Matters

the policy:

(h) on energy from waste be supported, subject to re-wording the policy to indicate that the recycling, composting and recovery of materials does not necessarily have to be undertaken on site, and that there are constraints on the effective use of the heat generated;

(i) on providing for declining landfill capacity and the policies on providing capacities for certain waste streams should provide more sub-regional details; and

(j) on waste transfer stations should include reference to transport by water.

(ii) That the detailed comments on the Regional Waste Management Strategy made in section 3 of the report be considered by the Regional Assembly.

(iii) That the South East England Development Agency be informed of the County Council's response.

2. Reason

2.1 The Regional Assembly is seeking views on the draft Regional Waste Management Strategy as part of the review of Regional Planning Guidance for the South East (RPG9). The County Council should submit views in order that revisions to the Strategy can be considered by the Regional Assembly prior to its submission to the Government Office for the South East (GOSE) in late 2003.

3. Other Options Considered and Rejected

3.1 Not to offer any comments to the Regional Assembly.

3.2 To support the option of meeting but not exceeding Government targets.

4. Conflicts of Interest Declared by the Decision Maker or a Member or Officer consulted - None.

5. Dispensation granted by the Standards Committee - Not applicable.

6. Reason(s) for the Matter being dealt with if Urgent - Not applicable.

Approved by: ..................................... Date: ..................................

Councillor T K Thornber

Contact: Tony Cook, ext 6730

1. Summary

1.1 The South East England Regional Assembly (SEERA) has published a consultation draft of the Regional Waste Management Strategy. Comments are required by 23 June 2003.

1.2 The County Council's response proposes that the Regional Assembly considers adopting a resource management approach, not only to the vision of the future but also ultimately in the planning and delivery of the Strategy. The County Council should support the option that reflects this philosophy, subject to a clarification of roles and a recognition of the resource implications. The County Council supports sub-regional net self-sufficiency but proposes that more guidance should be given on the provision and achievement of facilities. It is also proposed that the detailed comments included within the report should be forwarded to the Regional Assembly, and that the South East England Development Agency (SEEDA) should be informed of the County Council's response.

2. Background

2.1 In March 2003 the Regional Assembly published the consultation draft of the Regional Waste Management Strategy "No Time to Waste". Appendix 1 contains a summary of the document, together with the proposed policies.

2.2 Regional Planning Guidance for the South East (RPG9) indicates that an early review should be undertaken of certain policies, including waste and minerals. The Regional Waste Management Strategy is part of this review and SEERA is seeking views by 23 June 2003.

2.3 The Strategy covers in detail the period up to 2016 and includes a longer term view. The vision is for a region in which natural resources are used and managed efficiently such that the amount of waste will be minimised, the overwhelming majority of materials be reused, recycled or have value recovered, and the environment be protected and enhanced. A waste hierarchy is adopted: prevent, reuse, recycle, recover, dispose.

2.4 The document sets out the main policy drivers which will shape future waste management arrangements in the south-east. The Strategy covers three principal waste streams - municipal solid waste (which accounts for about 16% by weight of the Region's waste), commercial and industrial waste (32%) and construction and demolition waste (52%). The document also summarises current waste generation, management and disposal in the region. The Strategy examines forecasts of waste growth, current and future waste management infrastructure and the capacity gap that will exist. This is mainly based on the Regional Waste Management Statement, a report by consultants for the South East Regional Technical Advisory Body for Waste (SERTAB) which assesses waste generation, facilities, and future requirements at county and regional level. The Strategy also draws on the Statement for a Sustainability and Best Practicable Environmental Option (BPEO) appraisal of scenarios.

2.5 Two strategy options are invited for comment. The preferred option involves attempting to exceed Government and European Union targets for recycling and recovery as part of an overall approach where these targets are adapted for other waste streams. The preferred option also adopts a mixture of management methods and infrastructure, and incorporates a mixture of sizes of facilities. The alternative option would be set to meet but not exceed those targets. A third possible approach is included for comment which is a hybrid of the two options.

2.6 Supporting policies are put forward in the draft Strategy, which it is felt will be much the same whichever option is chosen, with some targets needing to be altered to reflect the particular option. The main policy themes are:

(i) Waste Minimisation - a set of policies to address this issue.

(ii) Recycling and Composting - specific targets and policies including the development of new markets and a large number of small relatively local facilities.

(iii) Other Recovery - draft policies encouraging the development of advanced techniques and the selective use of energy from waste plants as part of an integrated approach to waste management.

(iv) Landfill - some additional landfill sites required, safeguarding of major sites and the demand for further increases in landfill tax.

(v) Self-Sufficiency - waste authorities should plan for net self-sufficiency with a degree of flexibility to cater for cross border movements, including reduced waste from London.

(vi) Marketing and Advocacy - policies to influence attitudes and change markets.

(vii) Inter-Regional Links - policies for inter-regional cooperation.

(viii) Location of Facilities - A policy on safeguarding transport links and advocating that Green Belt policy should not be a constraint.

3. The County Council's Response

3.1 The Regional Planning Guidance on waste policy must be taken into account in the preparation of development plans and will be fundamental to the production of the Hampshire Minerals and Waste Development Framework. The Regional Waste Management Strategy and the accompanying Regional Waste Management Statement will be material planning considerations when applications for new waste management facilities are determined by the County Council. The content of the draft Strategy therefore has crucial long term implications for the development of waste management policy in Hampshire and the future shape of waste management infrastructure that will be permitted. The County Council's response should cover the vision adopted in the Strategy, the land use planning issues raised and waste management matters.

VISION

General Approach

3.2 The Strategy substantially focuses on `waste' rather than `resource utilisation'. Although the document refers to the Strategy taking more efficient management of natural resources as its guiding principle, the process and resulting conclusions still reflect to an extent the current thinking on waste management. A step change is required. It could be considered that an approach based on "predict and provide" is likely to reinforce existing trends and solutions.

3.3 The Hampshire Natural Resources Initiative is examining ways that might bring about a shift in thinking. A key aspect is examining how this more radical approach could be linked to conventional thinking to deliver real change at the local level. A resource management approach blurs the distinction between the municipal, commercial and industrial and construction and demolition waste streams. It requires the resource streams to be integrated and categorised according to the different processing requirements. It involves engaging all sectors involved in the production cycle and goes beyond the traditional waste management remit and requires new skills in business development and social science. There are a number of examples across Europe of regions utilising a resource management approach and further details are given in Appendix 2.

3.4 The key steps in a resource management strategy are:

(i) an integrated "top down and bottom up" approach linking Government policy with local action on a sector-by-sector basis;

(ii) addressing all levels of the product process chain from natural resource production through to retailing as well as post-consumer waste;

(iii) an integrated waste handling/processing infrastructure serving key resource streams regardless of whether they arise from the municipal, commercial or construction sectors; and

(iv) creation and delivery of resource parks for resource management use and other suitable infrastructure.

3.5 The Hampshire Natural Resources Initiative approach will take time to achieve. Such an approach will need lifestyle changes, new fiscal measures, Government support and a shift in public opinion. In the long term the new thinking on the process chain will require a recalculation of the type and number of master category waste handling/process infrastructure serving the municipal, commercial and construction sectors.

3.6 In the short term a twin-track approach may be needed while these changes are being brought about. In the light of this, the rest of the Strategy is still relevant and the County Council should comment on the direction and emphasis of the proposed options and policies.

Waste Minimisation

3.7 Policies W1 to W4 of the Strategy promote measures to slow the rate of growth in waste. Raising awareness has a role to play but the relationship between economic growth and waste production is strong, with limited evidence on how to de-couple the actions. There is, though, a lack of detail in the Strategy as to how the general policies W1 to W4 will be implemented. A more robust approach might be to set a consensus seeking agenda, fostering the active engagement of stakeholders and planning for different resource utilisation infrastructure. There is a need to clarify who should do what to achieve waste minimisation. The Strategy could be enhanced by indicating the broad roles that each of the key drivers for resource management should play.

3.8 The achievement of waste minimisation will need changes in consumer behaviour and production processes, as well as action within waste management and land-use planning. An integrated holistic approach is needed to coordinate action. There is perhaps insufficient emphasis on an integrated approach in the Strategy. The Regional Assembly should take positive steps to promote this different approach.

LAND USE PLANNING ISSUES

Options and Targets

3.9 Current statutory targets relate only to the municipal waste stream except for the need to reduce the amount of industrial and commercial waste sent to landfill. The Strategy proposes regional recovery targets for all the waste streams based on and adapting these targets. The two main options put forward in the Strategy involve a choice between the preferred option (which is based on in some cases exceeding the statutory targets for recovery and treatment of waste and reductions in landfill), or the alternative option (which is based around meeting the statutory targets). The biggest difference between the options as shown in Policy W6 is in the targets for the commercial and industrial and construction and demolition waste streams. Potentially, some regional stakeholders may wish to support the alternative option on the basis of current low levels of recovery and the costs involved. The assumptions made about waste growth are critical to the forecasts. Certainly a rigorous approach is needed for decisions to be appropriate in the long term.

3.10 The preferred option in the Strategy requires that the targets in the Government's Waste Strategy 2000 will be exceeded in that, for municipal solid waste, the final target for diversion of biodegradable waste will be achieved by 2016 rather than 2020; for commercial and industrial waste, the continuation of the diversion from landfill required in Waste Strategy 2000 beyond 2005 and decreasing at a similar rate; and for construction and demolition waste, the use of the same target as for commercial and industrial waste. These targets are identified in Policies W6 and W7 of the Strategy. The County Council should support in principle the preferred option on the basis that this puts faith in achieving effective recovery of waste. It should be noted, though, that there are already problems in meeting short term recovery/recycling targets. It will require concerted action by waste authorities, Government, public bodies and communities. It also needs to be recognised by SEERA that there will be substantial costs involved in achieving the higher targets and the nature of these costs is not really examined in the Strategy.

3.11 More up-to-date information is available for construction and demolition waste and this indicates higher rates of recycling and recovery being achieved. SEERA should review the Strategy in the light of this new data.

3.12 The Strategy prioritises recycling and composting in advance of other recovery methods. Whilst this helps focus action, there will be practical limits to recycling and composting, and the Strategy should still have adequate reference to the waste hierarchy, based on the European Waste Framework Directive which indicates that where re-use cannot be achieved, value should be recovered by either recycling, composting or energy recovery.

3.13 In addition, Waste Strategy 2000 indicates that the Government expects future waste management decisions to be based on the consideration of the Best Practicable Environmental Option. In determining the BPEO, consideration needs to be given to the waste hierarchy as well as the principle of self-sufficiency, and the proximity principle. PPG11 states that regional planning guidance should specify the number and capacity of different types of waste management facility in line with BPEO. The Regional Assembly should therefore assure itself that the preferred option in all its facets conforms to the BPEO.

3.14 In a similar fashion, the Regional Assembly should consider whether all aspects of the preferred option perform well in the sustainability appraisal.

Self-Sufficiency

3.15 Policy W9 proposes that management capacity is provided sufficient to deal with the region's waste plus a declining amount from London. Provision for London's exports is limited to landfill in accordance with the Landfill Directive targets up to 2016 and thereafter only for residual waste from recovery processes. The principle of regional self-sufficiency is well established and current RPG9 reflects this. The County Council has previously expressed its concern that inadequate recovery provision within London will lead to the continued export of waste from London for treatment and disposal in surrounding counties, including the pressure for additional incineration capacity outside London as landfill availability declines. The Strategy does not provide sufficient guidance on how the approach will be effective in practice or how the waste should be apportioned between the individual planning authorities.

Planning for Facilities

3.16 Policy W10 of the Strategy identifies that waste planning authorities should plan for net self-sufficiency, subject to a degree of flexibility, through the provision of management capacity to meet requirements. No specific sub-regional capacity targets are set in the Strategy but it does provide a table showing the illustrative cumulative number of new facilities required for future waste management in the region as a whole in respect of the three scenarios which make up the preferred option.

3.17 PPG11 indicates that regional planning guidance should specify the number and capacity of the different types of waste management facilities required, identify their broad locations in the region supported by a criteria-based approach.

3.18 The Strategy indicates that several hundred new facilities will be required in the region over the next 20 years and gives illustrative cumulative figures. However, the Regional Waste Management Statement does give a breakdown on a sub-regional basis for 2016/17. The table below shows the estimated number of new facilities envisaged to cater for all the waste streams for Hampshire, Portsmouth and Southampton in total:

2016/17	Scenario 5b (large facilities)	Scenario 6a (small facilities)	Scenario 6b (large facilities)
Thermal Treatment (EfW)	0	7	3
Materials Recovery Facility (MRF)	25	46	17
Composting	6	0	0
Landfill	4	18	4

Scenario 5 exceeds targets with additional recovery through enhanced levels of recycling and composting. Scenario 6 exceeds targets with additional recovery through a mixture of enhanced levels of recycling and composting, and energy from waste. Capacities assumed for the appraisal are Thermal Treatment 100,000 tonnes pre annum (small), 250,000 tonnes per annum (large); MRF 25,000 tonnes per annum (small), 70,000 tonnes per annum (large); Composting 5,000 tonnes per annum (small), 50,000 tonnes per annum (large); and Landfill 50,000 tonnes per annum (small), 250,000 tonnes per annum (large).

3.19 SEERA has chosen not to be prescriptive at sub-regional level. Whilst this gives some flexibility, the setting of targets does provide the necessary direction and stimulus for action. It should also be noted that varying the assumptions about waste growth does lead to differing figures for the number and type of facilities required. As referred to in paragraph 3.5, the resource management approach may also require different types of facility to handle materials. There is also a danger that different approaches across the region will be confusing to commercial activities that do not recognise administrative boundaries. In addition, it will be more difficult to monitor the Strategy without a sub-regional dimension to the figures.

3.20 Policy W11 states that development plans should identify suitable sites for development of a range of types and scales of facilities to provide for all forms of recovery for all the waste streams. Policy W12 also refers to expansion of and co-location with existing waste management facilities and the development of resource parks, subject to meeting environmental, technical and operational objectives. Policy W23 proposes priority to safeguarding and expanding suitable sites with existing waste management use and good transport connections. The policy then states that the Green Belt should not preclude the location of new facilities. Policy W24 lists criteria to guide the siting of waste management facilities.

3.21 The safeguarding of sites with an existing waste management use is a sensible starting point, although the impact of some new uses (eg incinerators) may not be compatible with the particular circumstances of the existing facility. The co-location of activities as a resource park should also be supported as this has considerable advantages in promoting the resource management approach.

3.22 The Strategy proposes the relaxation of Green Belt constraints in providing new waste management facilities where this is consistent with the proximity principle. The County Council should respond that such a relaxation should also apply to the general countryside, subject in all cases to the need being justified, the appropriateness of any built form in the countryside, and the overall benefit to be gained from the facility outweighing the adverse environmental impact that it would have on the area concerned. It can be argued that the relaxation covered by this should not apply to the two proposed National Parks, or Areas of Outstanding Natural Beauty.

3.23 PPG11 states that in regional planning guidance the identification of the broad locations of different types of waste management facilities should, where appropriate, be supported by a criteria-based approach. The Strategy's proposed criteria for site identification in Policy W24 is neither comprehensive in covering necessary appraisals nor robust in giving guidance to the standards that should be achieved in locating new waste management facilities. The criteria should contain more guidance on the environmental constraints to be considered. The site criteria could also be varied according to the type of waste management facility proposed. Criteria similar to that adopted in the Hampshire, Portsmouth and Southampton Minerals and Waste Local Plan would assist guiding new proposals.

3.24 Policy W17 states that development plans should provide for continuing but declining landfill capacity. The Strategy identifies that there is sufficient capacity at the regional scale to manage the region's waste plus a declining amount from London up to about 2013/14. However, this relies on large void space in three particular counties and skews the real view of local landfill needs. In view of the proximity principle new facilities will be needed at a sub-regional level. As indicated in paragraph 3.19 above, the policy is not effective without specific sub-regional details. Policy W25, seeking high quality restoration of waste management sites, should be supported.

3.25 In addition, the resource management approach proposed by the County Council would ultimately require different storage and reprocessing facilities compared to those considered in the Strategy. For example, commercial and industrial processes might require on-site materials handling, facilities management and materials brokerage. The Strategy should include policies which ultimately allow for this different infrastructure.

Design

3.26 Policy W5 indicates that development plans should encourage design which minimises waste. Specific guidelines could be brought forward for new development which required the integral design of recycling facilities. A good practice guide would help to promote this action. The bigger challenge is how to provide the same facilities within existing housing and commercial development.

WASTE MANAGEMENT MATTERS

Delivery of Facilities

3.27 The delivery of a large number of new waste management facilities will be a daunting task. There are examples of strong public opposition to the siting of facilities with little consensus on what are appropriate locations.

3.28 Policy W10 encourages cooperation between county councils and unitary authorities at sub-regional level. The approach in Hampshire through Project Integra should be put forward as a template of best practice in collaboration.

3.29 In addition, the Waste and Emissions Trading Bill will introduce statutory landfill "allowances" which can be traded between local authorities, and this may affect approaches to disposal across the region.

3.30 The Strategy gives insufficient attention as to how the new infrastructure will be funded. The Regional Assembly should include a policy to lobby the Government to seek additional funding/fiscal measures to assist the implementation of the Strategy.

Specific Waste Management Facilities

3.31 Policy W15 encourages the separation of biomass waste and its use in energy plants. Policy W16 supports the development of anaerobic digestion and advanced recovery techniques and states that development plans should only include energy from waste as part of an integrated approach to management. The policy also identifies that such facilities should incorporate measures to recover materials and include combined generation and distribution of heat and power.

3.32 Waste Strategy 2000 identifies that the Government believes that recovery of energy from waste, through using it as a fuel, has an important role to play alongside recycling and composting in a system of sustainable waste management. PPG10 also states that waste planning authorities should not seek to prohibit particular types of waste facility unless adequate alternative facilities will be available. The Project Integra strategy is based on an integrated approach to waste management in which the range of available options is harnessed to provide an overall solution. The proposed infrastructure includes three energy recovery incinerators. The County Council should therefore support Policy W16 in principle, subject to the re-wording of the policy to indicate that the recycling, composting and recovery of materials does not necessarily have to be undertaken on-site, and that there are constraints on the effective use of the heat generated. The further encouragement to anaerobic digestion should also be supported.

3.33 Policies W20 and W21 cover the need to provide for capacity for hazardous waste, paper and card, plastic, glass, tyres, waste electrical and electronic equipment and end-of-life vehicles. Whilst supporting the need for capacity for these waste product streams, the policies similarly do not give any guidance on how they may be applied in practice at the sub-regional level.

3.34 Policy W22 covers identifying suitable sites for waste transfer stations and encourages the use of rail transport. Project Integra is investigating the transport of waste and recyclables by water. Similar encouragement should given to this form of transport in Policy W22.

3.35 The Strategy should include further consideration of the implications of the future management of agricultural waste.

4. Conclusions

4.1 The Strategy raises many issues in relation to the waste production and disposal crisis. The Strategy will be fundamental in influencing the shape and style of waste management infrastructure in the region. It will provide a benchmark which waste planning authorities would be expected to follow.

4.2 The Strategy incorporates resource management as part of the longer term vision but the planning and delivery of the aims still utilises conventional thinking in process and infrastructure. The County Council's philosophy in the Natural Resources Initiative would point to a fundamental, comprehensive approach involving different responses to achieve sustainable consumption. SEERA should be recommended to consider twin-tracking the Strategy to ultimately achieve a resource management approach.

4.3 The County Council should support the adoption of the option which incorporates ambitious targets as this would reflect the vision of the Hampshire Natural Resource Initiative, subject to clarity of the roles to be undertaken to achieve these standards, and an acceptance of the resource implications that will arise to provide the facilities required. The Strategy should also identify the minimum provision of facilities required in regional terms to meet the options.

4.4 The County Council should support the principle of net self-sufficiency at the sub-regional level. The Strategy would be enhanced by clearer guidance on the likely provision of necessary facilities at a sub-regional level. The delivery of new facilities will be difficult and the Strategy could be expanded to give much clearer direction to achieve additional waste management infrastructure.

4.5 The report also identifies many detailed comments on the proposed policies and these should be forwarded to SEERA. SEEDA should also be informed of the County Council's response.

Recommendations

1. That the South East England Regional Assembly be informed that the County Council's views on the consultation draft of the Regional Waste Management Strategy are with regard to the vision, land use planning issues and waste management matters, that:

Vision

(i) the Strategy be reconsidered as a resource management strategy with the planning and delivery ultimately reflecting this radical approach; and

(ii) support be given to the option involving exceeding Government targets, as this would reflect the philosophy of the approach adopted in Hampshire, subject to clarifying the roles to be undertaken by the various parties to achieve the targets, and the Government accepting the resource implications of this option;

Land Use Planning Issues

(iii) the Regional Assembly assure itself that all aspects of the preferred option are justified by the sustainability appraisal, and conform to the waste hierarchy and Best Practical Environmental Option appraisal, and how waste management could be integrated and achieved for all the waste streams;

(iv) the Strategy does not give sufficient guidance on how the approach to regional self-sufficiency will be effective in practice and how London's waste should be apportioned;

(v) the Strategy should give more guidance on the approach to be adopted at the sub-regional level;

(vi) the Strategy should contain more explicit criteria on site identification and suitability for new waste management facilities; and

(vii) the Strategy should clarify in Policy W23 that the relaxation of Green Belt constraints in the location of new waste management facilities also applies to the general countryside, subject to the need being justified and that the overall benefit outweighs any adverse environmental impact. The Policy should clarify that this distinction does not apply in the same way to the two proposed National Parks and Areas of Outstanding Natural Beauty;

Waste Management Matters

the policy:

(viii) on energy from waste be supported, subject to re-wording the policy to indicate that the recycling, composting and recovery of materials does not necessarily have to be undertaken on site, and that there are constraints on the effective use of the heat generated;

(ix) on providing for declining landfill capacity and the policies on providing capacities for certain waste streams should provide more sub-regional details; and

(x) on waste transfer stations should include reference to transport by water.

2. That the detailed comments on the Regional Waste Management Strategy made in section 3 of the report be considered by the Regional Assembly.

3. That the South East England Development Agency be informed of the County Council's response.

8033/TC