Is England’s planning system able to cope with the demands of the new Resource and Waste Strategy?

6th June 2019 Posted by

Posted by Dr Adam Read.Dr Adam Read, External Affairs Director, SUEZ reccyling and recovery UK

The last 20 years has seen the UK switch from being landfill dominated, to one which has a healthy mix of recycling and energy recovery.

But this transition hasn’t been easy, and in many respects the transition has been delivered despite a significant degree of misalignment between national policies and targets and local decision making, both in terms of collection systems and more significantly in terms of strategic siting and infrastructure planning.

After all, we can all name a locally contentious site, a problematic planning application or an infamous campaign group stunt, and in some respects that is to be expected in a democratic society like ours, where local decisions are taken by locally elected representatives.

But as someone who has been involved in strategic site identification, local planning development, site delivery and infrastructure build (as a local authority officer, consultant and now operator) this level of local democracy is often at the expense of delivery necessary strategic or at least regional (and sub-regional) infrastructure.

Although very local interests might be upheld, the interests of wider society may be marginalised, resulting in significant planning delays, contract disputes and ultimately rising costs to the public purse. So if the last 20 years have seen huge tensions when it comes to local infrastructure sites and decision-making, what should we expect in the coming decade as we move even further away from landfill.

And so the debate begins

SUEZ has been considering the likely infrastructure needs of the government’s Resources and Waste Strategy sites, new technologies and processing facilities that match the demands of the evolving policy agenda.

At SUEZ, we have been considering the likely infrastructure needs of the government’s new Strategy for the last 18 months or so, identifying the next wave of investments we want to make in terms of regional sites, new technologies and processing facilities that match the demands of the evolving policy agenda. And since Christmas, and given the increasing clarity provided in the recent consultations concerning EPR, DRS, consistent recycling collections and the plastic tax, the direction of travel now appears more certain than ever.

This has enabled us to pull together our third 10-year investment plan, the last of which resulted in over a £billion in new infrastructure build in the UK, supporting the drive away from landfill (primarily SRF, EfW and recycling facilities).

So, the discussions aren’t that new, but a workshop I spoke at least week, hosted by the CIWM London & Southern Counties New Members Network brought the issues of new infrastructure delivery right into focus.

A few quick calculations, plus a closer look at any number of the publications and reports issued in recent months suggest we are going to need something in the order of:

  • 4-5 Mtpa of new residual waste capacity (replacing closing landfill)
  • 2-4 Mtpa of additional RDF treatment capacity (if we reduce exports)
  • 1-1.5 Mtpa of new packaging & materials processing capacity
  • 1.5-2 Mtpa of increased food waste treatment capacity
  • Plus 1 Mtpa of new green waste capacity.

That works out as a lot of new sites, even with the current pipeline of planned facilities and recent announcements about UK-based reprocessing. Most of them will be much smaller than the closing landfill sites, and ideally in different locations (for example closer to end markets or industrial zones ), ensuring there will be lots of future siting, planning and community engagement activities needed to get this essential infrastructure off the ground in the next 10 years.

Plus, the need for new depots and transfer stations to move these materials out of the city centres (and ever more dense suburbs), and the redevelopment of the UK’s HWRCs into reuse and repair centres. Just how optimistic are we that it will all get delivered in time?

Change is needed

How aligned right now are the national policy and local planning agendas? The consensus at a number of recent roundtables and the aforementioned CIWM workshop is not nearly enough.

We have new national policy in terms of the Strategy, a somewhat dated National Waste Management Plan, and the existing Planning Practice Guidance, but do they align? Unfortunately not. Overlay this with Local Waste Plans, all of which were developed sometime before the new national policy change, and you can see we are on the verge of a complete rift in terms of national policy and local decision-making. This is a worry for anyone looking to invest in new infrastructure and should be of equal concern to those who are responsible for delivering on the new targets.

Unfortunately, much of the new infrastructure required will not meet the guidelines for what is a Nationally Significant Infrastructure Project (projects considered by government to be so large and important that permission to build them needs to be given by a Secretary of State), as most won’t be of the scale of the North London Heat & Power Plant or the new Cory proposal at Belvedere.

This leaves all of the needed AD plants, the upgraded transfer stations, the planned RDF processing sites, the new breed of MRFs, the essential refining and reprocessing plants, the proposed chemical recycling sites, and many new advanced conversion technologies needing to engage in local politics and decision-making.

And that just doesn’t seem right when we need a portfolio of solutions, new sites, and supporting infrastructure to help meet Defra’s targets in both the Strategy and its 25 Year Environmental Plan, and more importantly to make a significant contribution to mitigating climate change. This sounds like a recipe for even more tension, yet the country really can’t afford the delays, the costs or the pain.

So what am I asking for? Well apart from an overhaul of local government in England (a recurring theme in my blogs over the years), to create larger administrative areas that are more appropriate in terms of sub-regional infrastructure decision-making.

We need open recognition from government and all of its departments that resource infrastructure is critical to green growth, post-Brexit prosperity and environmental protection, and that decisions on key sites and facilities should not be held up by local decision-making processes and procedures.

The targets are there for all to see, the solutions are on the whole well understood, but what we need is the hundreds of new sites, in the right locations, to make the targets a reality. If government really wants to reduce our reliance on global markets for some recyclables, and with Brexit concerns making many look at repatriating RDF exports, the need for new sites and facilities is even more critical than first outlined.

As such, government must finally align its policies and decision-making powers (from national to local) to enable the private sector investment that is so desperately needed now to deliver the infrastructure of tomorrow.


This blog was originally published on on 05 June 2019.

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