Meeting documents

APPENDIX C

Response of the West of England Joint Scrutiny Committee to the Pre-Consultation Draft of the Waste Core Strategy DPD Preferred Options Document

JOINT SCRUTINY OF THE WEST of ENGLAND PARTNERSHIP

BATH AND NORTH EAST SOMERSET COUNCIL, BRISTOL CITY COUNCIL, NORTH SOMERSET COUNCIL AND SOUTH GLOUCESTERSHIRE COUNCIL

Joint Waste Core Strategy: A Response to the invitation of the West of England Waste Strategy Member's Project Board for views on the draft Pre-Consultation Preferred Options Document and Consultation Plan.

The Joint Scrutiny Committee welcomes the opportunity to comment on the draft pre-Consultation Preferred Options Document and Consultation Plan.

Joint Waste Core Strategy

It needs to be clearly set out what the status of the strategy is and the relationship with other core strategies

Regional Spatial Strategy Proposals

It is acknowledged that the Pre-Consultation Document is prepared in the context of the emerging Regional Spatial Strategy (RSS) and that it is required to be in general conformity with the RSS. Although representations have been made to the Examination in Public Panel that the indicative waste capacity apportionments should be based on the latest data available, it was concluded that the delay and cost involved in providing up-dated apportionments could not be justified given the urgent requirements for new treatment facilities other than landfill. The Committee does not find this acceptable.

The baseline data used to inform the sub-regional apportionments for recovery capacity set out in the draft Regional Spatial Strategy is out of date and not sufficiently robust to justify the proposals in Policy W1.

The Joint Scrutiny Committee recommends that in responding to the Proposed Changes to the draft Regional Spatial Strategy, the West of England Unitary Authorities should request that RSS Policy W1 be amended to require more up-to-date data to be taken into account by waste planning authorities when making proposals for strategic waste management facilities.

With improvements in recycling and re-use, it should be recognised that there will be less need for the indicative waste capacity apportionment proposed by the draft Regional Spatial Strategy.

Less Waste, more Resource

Less waste involves a more efficient use of resources, and requires less waste collection and treatment. Continued improvements in waste minimisation are imperative if we are to achieve a more sustainable approach to the management of waste. More needs to be done to promote a reduction in Commercial and Industrial waste, although it is recognised that this is outside of the remit of the Joint Waste Core Strategy. Whilst it is noted that, other than landfill facilities, there are limited commercial and industrial facilities located in the West of England there may in the future be more scope for the joint use of treatment facilities by municipal and commercial and industrial waste.

More efficient re-use and recycling that meets or exceeds national waste strategy targets will also promote the better use of resources, and the Joint Scrutiny Committee recognises that the Joint Waste Core Strategy does have a role to play in enabling a strategic network of recycling and composting sites within the West of England also taking into account developments in those authorities outside the West of England boundaries.

Cross Boundary Issues - Proposals for Strategic Waste Management Facilities

While it is recognised that there is a continuing need for landfill / landraise in the West of England, reliance must be kept to an absolute minimum. The Committee is keen to see dialogue taking place with other authorities on cross-boundary issues. There may be waste management facilities, including landfill, available in adjoining authorities with spare capacity. There may also be scope for Commercial and Industrial facilities either within or outside of the area to be used to manage Municipal waste.

Proposed Strategic Waste Sites

It is noted that the proposal is that the Joint Waste Core Strategy should be technology neutral and that proposed sites have been chosen because they are suitable for a range of waste treatment technologies, thus increasing the flexibility to allow new technologies to come forward at a later date.

However, because of the status of the strategy equal to a planning policy document and material to the consideration of planning applications concerning strategic waste management facilities and to create greater clarity for stakeholders and the public, the consultation document should contain some description of the type of waste facility and scale of operations suitable for the site.

Whilst it is acknowledged that the list of sites was drawn up 18 months previously and circumstances will change every effort should be made to ensure the accuracy of the sites listed. The Committee agreed that the table in the consultation document relating to `general areas' should be deleted to avoid confusion. Also it should be made clear that strategic waste sites refer to `recovery' sites.

Urban Extensions/ Opportunities for Combined Heat and Power Schemes powered by waste

As a planning document, the Joint Waste Core Strategy also has significant role to play in promoting better use of waste in new development, both during the construction stage and during the operational life of the development. It is recognised that the additional houses and employment proposed in the draft Regional Spatial Strategy will have implications for the future management of waste. This will present opportunities to enhance the network of waste management facilities and this opportunity must be taken.

The document should strongly support the opportunities in relation to Urban Extensions in providing local waste disposal options, for example, recycling, composting, combined heat and power facilities. In planning terms it should be necessary to include these in development proposals unless there is proven reason not to. The opportunity to install such facilities from the outset should be tested during the early planning/master planning stages.

The opportunities for waste, either directly or indirectly (through the production of "Refuse Derived Fuel") to contribute to Combined Heat and Power (CHP) schemes as part of the proposed urban extensions should be investigated as a matter of urgency.

Hazardous Waste

The Joint Scrutiny Committee accepts that due to the specialist nature of its treatment, hazardous waste should continue to be exported.

Emerging Technologies

The Joint Waste Core Preferred Options Document needs to make reference to emerging technologies, in particular in relation to merchant facilities that may appear.

Consultation

The Joint Scrutiny Committee supports the proposal to engage with the public and stakeholders on the spatial options and possible sites suitable for delivering the much-needed waste management infrastructure within the West of England in order to divert residual waste away from landfill.

Whilst the Committee acknowledges that the proposed consultation includes more that the `drop in' events in each constituent authority there needs to be a clear and detailed public consultation and awareness plan in order to be able to effectively engage the public and stakeholders in different ways. The consultation proposals should also be seen as an opportunity to raise awareness with the public on these issues and there need to be `awareness raising', media and communications plans.

The consultation document must be clear and explanatory in it use of terminology - for example what is recovery, recycling, Energy from Waste. The document itself should make better use of photographs in order to help people visualise what is being proposed.