This month the Government published six draft National Policy Statements (NPS), which will underpin the deliberations of the newly constituted Infrastructure Planning Commission. Of immediate interest to the waste management sector is the NPS on renewable energy.
Relating as it does to EFW plants generating more than 50 MW of electricity, as such it would only catch large facilities in the order of 500,000 to 600,000 tonnes per year of waste input. There aren't many of those around. The vast majority of facilities will have to run the gauntlet of the conventional planning system, with its attendant delays.
Recycling and waste expert, Gev Eduljee, is director of external affairs at SITA UK Magnitude
Government appears not to have fully appreciated the magnitude of the infrastructure challenge facing the UK. In round numbers, if 65% of both the 30 million tonnes of municipal waste (the landfill diversion target) and 70 million tonnes of commercial-industrial waste is to be diverted from landfill by 2020, treatment capacity in the order of 50 million tonnes will need to be built – or 500-1000 facilities of nominal 50,000 – 100,000 tonnes capacity.
Spreading this over 10 years, we will need to grant planning permission to an average of one to two new treatment facilities per week. Admittedly some of this infrastructure has already been delivered (we recycle and recover 45% of municipal and C&I waste) but much remains to be done to reach the Government's landfill diversion aspirations, especially for C&I wastes. The longer delivery of this infrastructure is delayed, the greater the pressure on costs, as landfill tax escalates to £72 and beyond.
It was hoped that the IPC (or at least, the concept of a body taking planning decisions away from the vagaries of local authority decision-making) might be applied more generally to the waste management sector in order to speed up planning decisions and prevent vexatious rejections. This has proved not to be the case.
The reason for this can be found in the explanation for what an NPS contains – objectives “for the development of nationally significant infrastructure in a particular sector”. Clearly, “nationally significant infrastructure” is taken to mean infrastructure that is significant on a UK scale – hence the 50 MW threshold applied to EFW plants.
Scale
However, it can be argued that each sector needs to be assessed on its own merits. Waste plans are designed by regional planning bodies to meet regional needs, and therefore in a plan-led system the basis for estimating significant size in our industry is not at national, but at regional scale. A 20 MW EFW plant might well be strategically significant at this scale.
The first option could therefore be to reflect the regional structure of waste planning in the functioning of the IPC by lowering the size threshold for EFW planning permissions determined by the IPC, plus including other key technologies, with their respective size thresholds, within the IPC's remit.
If there was a danger of the increased workflow creating a bottleneck at the IPC, other options could also be explored. For example, delegated IPC-style bodies could operate at regional or local authority level to consider planning applications for smaller facilities.
Above all, regional waste plans, waste local plans and waste development plans can be made binding on all parties through a covenant of sorts, committing parish, borough and county-level public authorities to honour a process that takes years of analysis and consultation to set down. The quid pro quo would be a more inclusive plan-making process through which communities feel more connected with the decisions taken on their behalf, and moreover experience tangible benefits from hosting waste facilities in their area, say by tapping into cheaper, locally-generated energy.
Our industry has estimated that by 2020 the UK needs an injection of £10 billion of investment in treatment facilities for municipal waste diverted from landfill. Add a further £10-15 billion if C&I waste currently going to landfill is also to be diverted and treated. Significant investment and job creation opportunities hang in the balance if we accept the status quo and limp along with a planning system that is hindering the delivery of infrastructure.
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