Waste Minimisation Supplementary Planning Document Draft For Informal Consultation Sept – Dec 2005 Prepared in partnership with: Draft Gloucestershire County Council Environment Agency Minerals & Waste Planning Policy: Nick Croft nicholas.croft@gloucestershire.gov.uk Tel: 01452 425682 Lower Severn Area Office Riversmeet House Newtown Industrial Estate Northway Lane Tewkesbury GL20 8JG Waste Management Unit: Tel: 01452 426601 Tel: 08708 506506 Fax: 01684 293599 Waste Contractor (Cory Environmental) Helpline: Tel: 01242 680010 Cheltenham Borough Council Cotswold District Council Forward Planning: Holly Jones holly.jones@cheltenham.gov.uk Forward Planning: Chris Vickery chris.vickery@cotswold.gov.uk Planning Reception: Tel: 01242 264328 Development Control: Tel: 01285 623001 planning@cotswold.gov.uk Commercial Waste Collection: Tel: 01242 264385 Commercial Waste Collection: Tel: 01285 868057 Waste enquiries & Recycling: Tel: 01242 264244 or 0800 163134. cleansing@cheltenham.gov.uk Waste management: Tel: 01285 623613 Environmental Health: Tel: 01242 264204 envhealth@cheltenham.gov.uk Environmental Health: Cirencester office Tel: 01285 623000 Moreton-in-Marsh Office Tel: 01608 650881 health@cotswold.gov.uk Gloucester City Council Forest of Dean District Council Forward Planning: Meyrick Brentnal Forward Planning: Nigel Gibbons meyrickb@glos-city.gov.uk Development Control: Tel: 01452 396013 Fax: 01452 396779 Development.Control@gloucester.gov.uk nigel.gibbons@fdean.gov.uk Development Control: Tel: 01594 812340 Waste Helpline: Tel: 01594 812444 Domestic Waste Collection: Tel: 01452 396396 Environmental Health: Tel: 01594 812 442 Fax: 01594 812 500. environmental.health@fdean.gov.uk Commercial/Trade Waste Collection: Tel: 01452 396255 Environmental Health: Tel: 01452 396396 Fax: 01452 396340 enviro@gloucester.gov.uk Stroud District Council Tewkesbury Borough Council Forward Planning: Mark Newcombe mark.newcombe@stroud.gov.uk Forward Planning: Toby Clempson clempsont@tewkesburybc.gov.uk Development Control: Tel: 01453 754518 Fax: 01453 754511 Planning Reception: Tel: 01684 272151 Building Control: buildingcontrol@tewkesbury.gov.uk Household Waste Collection: Tel: 01453 754412 Trade Waste Collection: Tel: 01285 760726 Commercial Waste Collection: Tel: 01684 272192 or 272228 commercialservices@tewkesbury.gov.uk Recycling: Tel: 01453 754424 recycling@stroud.gov.uk Recycling: Tel: 01684 272185 recycling@tewkesbury.gov.uk Environmental Health: Tel: 01453 754478 Environmental Health: Tel: 01684 272191 ehenquiries@tewkesbury.gov.uk 2 Contents Introduction Why minimise waste? Who is this SPD for? What types of development does it apply to? 2 2 2 2 Planning Context Sustainable waste Management National Regional Local Level Supplementary Planning Document Status Community Strategy Linkage Municipal Waste Management Strategy 6 6 6 6 6 7 7 7 Preparing the SPD Sustainability Appraisal & Strategic Environmental Appraisal 8 8 As an applicant/developer, what am I required to do? What if the details of the scheme are undecided? Use of planning conditions and legal agreements 9 10 10 During Design of the Proposal 12 During Demolition and Construction On-site crushing and screening 15 17 During Habitation of Buildings Household Waste Collection Commercial Waste Collection 18 18 19 Checklist for Preparing a Waste Minimisation Statement (WMS) 20 Appendices A Regional Waste Strategy Policy on Waste Minimisation 21 B Gloucestershire Waste Local Plan Policy 36 – Waste Minimisation 22 C Expert Group Composition 24 D Timetable for preparing the SPD 25 E DTI SWMP Nine Step Process 26 F Provision for Waste Recycling/Composting in Developments 27 G Form for Preparing a SWMP 29 H List of Useful Documents 30 I Glossary and Abbreviations 31 J PPS10 Planning for Sustainable Waste Management [excerpt] 33 K Non-Technical Summary of the Interim SEA/SA Results 34 L Minutes of Waste Minimisation Expert Group Discussion 35 Draft Introduction 1.1 The aim of this supplementary planning document (SPD) is to minimise the production of waste during demolition, construction 1 and occupation of buildings. This is to be achieved through developers preparing and submitting a Waste Minimisation Statement (WMS) as part of their planning application, and then committing to implement it through their permission. 1.2 SPDs are planning documents that sit alongside development plans (see section 2). They are an important consideration to take into account when planning applications are decided. This SPD provides additional detail about how Policy 36 ‘Waste Minimisation’2 of the Gloucestershire Waste Local Plan (WLP)3 is to be implemented. The WLP is a statutory land-use document that provides the detailed policy framework for determining planning applications for waste management development in Gloucestershire. It’s aim is to progress the County towards sustainable waste management practices over the next 10 years. To do an SPD, or not to do? 1.3 To date the implementation of WLP policy 36 has been inconsistent. The ‘do nothing’ option in terms of preparing this SPD will serve to perpetuate the lack of action on this important issue. Therefore, although the requirement to submit a WMS is already in place, this SPD seeks to make that requirement more explicit and easier for all concerned to implement. Why Minimise Waste? 1.4 Waste minimisation means not producing waste in the first place. This requires the reduction of waste at source. To do this the waste implications of a proposal need to be considered at the earliest possible stage. In the context of this SPD, waste minimisation also means making the best use of that waste which is produced. Waste should be managed in accordance with the ‘waste hierarchy’ (Prevent, Reduce, Reuse, Recycle, Dispose – see diagram overleaf) unless it can be demonstrated that an alternative approach is more environmentally sound. 1.5 Minimising or re-using waste generated through site development (including demolition waste) will reduce the amount of waste that has to be managed and ultimately disposed of, which in turn will contribute to reducing the production of greenhouse gas emissions. In addition it will reduce the amount of primary construction materials that have to be processed, purchased, and transported. This 1 2 3 For the purposes of this SPD ‘construction’ includes the fitting-out of buildings. Policy 36 is set out in Appendix B of this SPD. Gloucestershire Waste Local Plan adopted October 2004. 2 Draft can result in considerable financial savings 4 for developers by avoiding landfill charges and precluding the need to pay aggregates tax for primary materials. This is over and above the benefits to the environment. However, to be most effective, waste generation needs to be considered at the outset. Reduce the amount produced; Re-use as much as possible; Recycle as much as possible; Recover value from what is left; Dispose as a last resort. Who is this SPD for? 1.6 When preparing, assessing and determining planning applications, this SPD is intended to assist: Applicants and Developers (including planning/technical consultants); Local Planning Authorities; Waste Collection Authorities; Waste Planning Authority; Members of the public; Other interested parties. What types of development does this SPD apply to? 1.7 The principles of waste minimisation apply to all development. This includes newbuild, refurbishment (including demolition), conversion, extensions or change of use (see box overleaf). 4 A Scottish Environment Protection Agency (SEPA) study suggests that the costs of producing and disposing of waste amounts to around 4% of turnover. 3 Draft Waste Minimisation Principles 1.8 To design proposals sustainably; To reduce the amount of waste generated from development; To conserve natural resources through re-using waste arising as a result of construction; To re-use waste materials on-site to reduce transportation. It is generally true that the larger the development the greater its implications for using resources and generating waste. This however does not mean that smaller projects should not apply and abide by the principles of waste minimisation. The implementation of these principles are best undertaken through the planning application process. The majority of applications to which this SPD relates will be determined by District Councils. During 2004 there were over 11,500 planning applications determined in the six Gloucestershire Districts. To require submission of a WMS with each of these would require considerable resources. To make the implementation of this SPD more effective a working threshold for submitting a WMS is intended to be introduced to target ‘major’ development. 1.9 To provide a threshold of planning application size for requiring submission of a WMS a number of cut-off levels can be considered. For example, the Department of Trade and Industry (DTI) guide looks at projects in excess of £200,000. The Demolition Protocol looks at projects over 500m² using more than 1000 tonnes of material in the new build. Neither of these preclude other development likely to produce a significant amount of waste. Wiltshire and Swindon Waste Planning Authorities have prepared a Waste Minimisation SPG using the thresholds below. Case Study 1 - Wiltshire & Swindon Waste Minimisation Thresholds 10+ dwelling units; 500m²+ of retail floor space; 300m²+ of business/industrial floor space; transport, leisure, recreation, tourist or community facilities; car parks, including park and ride facilities; other developments likely to generate significant amounts of waste. 4 1.10 Draft Another option is to use the ODPM's Development Control (DC) Statistics for England definition of 'major' development. For residential developments, a major site is one where 10 or more dwellings are to be constructed or, if this is not known, where the site area is 0.5 hectares or more. For other types of development a major site is one where the floorspace to be built is 1,000 square metres or more, or the site area is 1 hectare or more. As an example of the numbers of applications captured by utilising this threshold, Cheltenham BC determined 66 ‘major’ applications in 2004. The benefit of using this threshold is that monitoring data would be relatively easy to collect and it would be simpler for the individual planning authorities to implement. 1.11 Other options include: developments that require an EIA are potentially of a scale that could generate significant waste. Whilst it is likely that the majority of these would be captured by thresholds such as those used by the ODPM DC definition. It could be of benefit to incorporate the requirement to submit a WMS as part of an environmental statement under the EIA regulations. A further option would be to use a ‘three tier’ approach whereby ‘major’ development and any other application that falls to be determined by planning committee are included. 1.12 Applicants of developments that fall below the chosen threshold would be advised of the financial and environmental benefits of following the principles of waste minimisation. This would take the form of an informative leaflet (to be prepared) in which brief case study examples would highlight potential cost savings and practical solutions. Persuasion for undertakers of these smaller projects (mostly householder extensions) could be the most appropriate way forward. In addition the EA provide guidance on pollution prevention5 to assist developers in undertaking their projects. Question 1 What should the threshold size of planning application be for requiring an applicant to submit a waste minimisation statement? Environment Agency ‘Pollution Prevention Guidance Notes’ can be found at http://www.environmentagency.gov.uk/business/444251/444731/ppg/ 5 5 2 Draft Planning Context Sustainable Waste Management 2.1 Effectively managing waste is a key element of sustainable development, which is the core principle underpinning land-use planning. A key objective is to drive waste management up the waste hierarchy. Where waste is produced it should be seen as a potential resource to be put to good use in place of primary materials. The requirement to minimise the production of waste is supported in land-use planning at national, regional, and local policy level. Waste reduction also contributes to reducing greenhouse gas emissions during the production, use and disposal of these materials. National 2.2 National planning guidance on waste minimisation is primarily contained in Planning Policy Statement 10 ‘Planning for Sustainable Waste Management’ (PPS10) (see Appendix J of this SPD) and the amended National Waste Strategy 'Waste Strategy 2000' (DETR). Regional 2.3 The Regional Waste Strategy (RWS) Policy P10.8 on Waste Minimisation requires new development to be designed to minimise the production of waste (see Appendix A). In determining planning applications the RWS6 states that developers should be encouraged to provide information on how they will minimise the production of waste and maximise the re-use and recycling of that which is produced. Local Level 2.4 WLP Policy 36 requires waste to be minimised when development is undertaken and when buildings are occupied (see Appendix B). The WLP comprises part of the development plan for Gloucestershire. Under the ‘old style’ planning system, the development plan comprises adopted district local plans, the minerals and waste local plans and the structure plan. However, the development plan under the ‘new’ planning system consists of local development frameworks (including minerals and waste development frameworks) and the Regional Spatial Strategy. Planning applications must be determined in accordance with the development plan unless material considerations indicate otherwise. This SPD comprises a material consideration in the determination of planning applications that sets out how Policy 36 is to operate. 6 This is to be translated into the Regional Spatial Strategy (RSS), due to be adopted in 2007. 6 Supplementary Planning Document Status 2.5 Draft Whilst the SPD does not have full development plan status it still comprises an important part (a material consideration) of considering the acceptability of a development proposal. This SPD will largely be implemented through district council development control functions. It has therefore been prepared in consultation and partnership with Gloucestershire’s six Districts. Community Strategy Linkage 2.6 The ‘Community Strategy for Gloucestershire’ states that to ensure a better environment we will minimise the amount of waste produced and increase recycling (P4, page 21). The six District’s community strategies also embrace the notion of minimising waste. District Cheltenham To explicitly seek to reduce waste and increase recycling Cotswolds Aim to minimise waste production and finite natural resource usage Gloucester To ensure that new developments are sustainable Forest of Dean Aim to develop a sustainable environment Stroud Aim to develop a sustainable environment Tewkesbury 2.7 Community Strategy Aims To seek additional recycling schemes This SPD represents a significant step in actioning these aims through the land-use planning system. Municipal Waste Management Strategy 2.8 A revised joint municipal waste management strategy (MWMS) is being developed by the Waste Disposal Authority and consultation on this is due to begin in Autumn 2005. The MWMS sets out future waste management in Gloucestershire reflecting current and future legislation, for example the Landfill Allowance Trading Scheme (LATS). This document may have implications for developers in terms of planning for future waste management practices during the occupation phase of the development. 2.9 The different practices adopted by Waste Collection Authorities in terms of the methods, receptacles and materials segregation is an issue that has been identified as one that may require tailored solutions for each District (see Section 7 and Appendix F). 7 Draft 3 Preparing the SPD 3.1 The community will be actively involved in preparing this waste minimisation SPD in a variety of ways. Public participation will be tailored to the particular stage of preparation. Initially, informal District and County Council Officer input was sought. This was followed by an ‘expert group’ of 21 invitees (listed in Appendix C) to discuss the SPD’s content. The culmination of the group’s deliberations is this draft document, which is currently being subject to an extended period of informal stakeholder consultation (from Sept – Dec 2005). Formal consultation on the SPD will be undertaken in March 2006 for a statutory period of 6 weeks. Approval by elected members will be sought at two key stages (Spring and Summer 2006). It is intended that the final SPD will be adopted in August 2006. 3.2 To make all parties aware of the timetable for preparing this SPD, it is proposed to follow the framework set out in Appendix D. Question 2 Is this document easy for developers, planners and members of the public to understand and use? Sustainability Appraisal (SA) & Strategic Environmental Appraisal (SEA) 3.3 This SPD is required to undergo a Sustainability Appraisal (SA), which incorporates the requirements of the SEA Directive (2001/42/EC). This process provides a framework for assessing the SPD’s sustainability credentials. A copy of the Interim SA Report is also available for people to comment on, with the non-technical summary reproduced in Appendix K. 8 Draft 4 As an applicant/developer, what am I required to do? 4.1 Applicants/developers for ‘major’ development 7 are required to prepare and submit a waste minimisation statement (WMS) to accompany their planning application. The WMS needs to set out how waste arising during the demolition, construction and occupation of the development is to be minimised/managed. The WMS must include: the types and quantities of waste likely to be generated (including hazardous wastes); the range of waste management options to be utilised (paying particular attention to the waste hierarchy and demonstrating how off-site disposal will be minimised); a commitment to re-use and recover materials where possible on-site; a statement setting out how the proposal has been designed to incorporate recycling/composting facilities (where appropriate); and a method for monitoring/recording the amount of waste actually produced & recycled, including corrective actions if non-compliance is detected. 4.2 A checklist is provided on page 18 to assist in preparing a WMS. In addition, further guidance is set out in the DTI voluntary code of practice 8, which encourages the preparation of a Site Waste Management Plan [SWMP] (see Appendix E). This approach is supported by the Environment Agency (EA) 9. To avoid confusion, for the purposes of this SPD the term Waste Minimisation Statement (WMS) is taken to include other derivations such as SWMPs. To be most effective, waste minimisation issues need to be considered during the formative stages of proposal design. 4.3 It is not acceptable for applicants or planning authorities to defer submission of the WMS to a later date through the use of a planning condition. This information must be provided in support of an application from the outset in order for decision makers to take waste issues into account when determining the acceptability of the proposal. Under the ODPM ‘Best Practice Guidance on the validity of planning applications’ (March 2005) consideration is being given to following a practice whereby planning applications for ‘major’ development10 that are not accompanied by a WMS will not be 7 As defined in Section 1 of this SDP. DTI voluntary code of practice for construction contractors and clients (8th July 2004). 9 EA Sustainable Construction: Position Statement (http://www.environmentagency.gov.uk/aboutus/512398/289428/654938/?version=1&lang=_e) 10 As defined in Section 1 of the SPD. 8 9 Draft registered as valid. This though will require the six district councils to adopt such an approach in order to gain consistency across the County. Question 3 Consideration is being given to following a practice whereby planning applications for ‘major’ development11 that are not accompanied by a WMS will not be registered as valid. What are your views on this approach? What if the details of the development are undecided? 4.4 Where the precise details of a development are undecided, for example when an outline planning application is submitted, a broad WMS should be submitted setting down the principles for managing waste on site. This should contain a clear commitment to action and achieving high standards, which will provide the framework for a more detailed WMS setting out tonnages, destinations and timescales to be submitted as part of the reserved matters applications. Both elements of the WMS in such cases need to conform with the requirements set out in this SPD. Use of planning conditions and legal agreements 4.5 The enforceability of planning conditions in respect of requiring submission of a WMS is potentially a concern. However, if this SPD is followed then the WMS will be submitted as part of the application package. Therefore planning conditions can be used to require adherence with the approved WMS. Three standard conditions are set out below, which provide the basis for LPAs to work with in formulating their decision notices. 4.6 In accordance with Waste Local Plan paragraphs 5.130 & 5.131, where particular requirements are made (for example the provision of regular waste audit statements during construction works), it may be that the use of legal agreements provides a better approach. This will be determined on a case by case basis as appropriate. Question 4 Do you consider that the standard conditions below are fit for purpose? What other standard conditions should be included in this SPD? Standard decision notice condition requiring the applicant/developer to adhere to WMS: The development hereby permitted shall be undertaken in accordance with the approved waste minimisation statement (Reference………….). The areas allocated on Plan/Drawing No. …….. for recyclate and/or compostable material storage shall 11 As defined in Section 1 of the SPD. 10 Draft only be used for that purpose. There shall be no deviation from this WMS unless with prior written consent from the local planning authority. Reason: to ensure that dedicate storage areas for waste materials are maintained as such and that the development conforms with waste minimisation requirements. Standard condition for outline applications to set out what needs to be submitted at reserved matters stage: No development shall commence until a Detailed Waste Management Strategy (DWMS) for the treatment, recycling and re-use of waste arising from the construction of the development has been submitted to and approved in writing by the LPA. This DWMS shall be in accordance with the approved Waste Management Strategy (WMS) (ref:....). The DWMS must set out details of volumes and types of waste anticipated to be generated during the construction stage (including anticipated wastage of primary construction materials). The DWMS must also include details of the amount of waste expected to be generated by engineering/landscaping of the site. All such materials must be re-used on-site unless it can be demonstrated to the satisfaction of the LPA that this is not the most sustainable option. In such circumstances details must be provided of where it is to be taken, how much and the timescales for final disposal or recycling. Waste shall thereafter be dealt with in accordance with the WMS and DWMS unless the LPA gives written consent to any variation. Reason: to ensure that the development conforms with waste minimisation requirements. Standard condition to ensure submission of a completion report for monitoring purposes: Prior to occupation of the approved development a statement shall be submitted to the LPA demonstrating how the elements contained in the approved WMS (ref……) have been implemented. The development hereby permitted shall not be occupied until LPA approval for that statement has been given. Reason: to ensure compliance with the WMS and to facilitate monitoring of waste arisings/management from this development. 11 Draft 5 During Design of the Proposal 5.1 Good design and layout in new development can help to secure opportunities for sustainable waste management; for example, storage areas for bins, facilitating kerbside collections, and locations for secure community recycling. This is supported by the Government’s latest Planning Policy Statement on “Planning for Sustainable Waste Management” [PPS10] (see Appendix J). 5.2 The design section of this SPD is intended to provide informative guidance rather than a prescriptive ‘must do’ list. The solution to designing-in recycling facilities (and storage for them) will depend on the type/nature of scheme being developed. This SPD consequently does not seek to impose solutions upon developers, rather it encourages innovation through considering and adapting the ideas from the case studies set out below. The overarching aim is to give people the means and opportunities for recycling at their home, work and during recreation. Further advice can be obtained from the Envirowise Helpline (0800 585794). INSERT case studies from Envirowise when available 12 5.3 Draft Designing-in good waste minimisation practice from the outset can save time and expense later in the process. The design stage encompasses all of the formative work undertaken prior to a planning application being submitted, including how, and with what, the development is intended to be built. For example, consideration should be given to pre-fabricating and pre-treating construction materials at the point of production. This reduces the need to have excess materials on-site. Other options include designing buildings to last multiple generations (build quality), or for ease of disassembly (for example using bolts instead of welds). 5.4 Consideration also needs to be given to reducing hazardous waste generation. By substituting hazardous materials for non-hazardous ones at the design stage, this will make the management of waste easier during both the construction phase and then any future demolition operations. Where materials are used that could cause environmental harm, measures must be put in place to minimise the pollution potential. District Environmental Health Officers should be able to advise on best practice, and the Environment Agency has prepared pollution prevention guidance for developers (contact details are provided at the front of this SPD). 5.5 Planning authorities should ensure that new development makes sufficient provision for waste management. Applicants should consider the following issues: space for recycling boxes (homes/work places); home composting provision; communal/purpose built areas12; deposit points and ‘bring’ facilities. Further examples are given in Appendix F. 5.6 Where internal storage areas for recycling boxes are not practical (for example dwellings with small kitchens) the use of multiple ‘under-sink bins’ for segregating waste could provide the solution (see Case Study 2 below). As a minimum, residential developments should incorporate external provision for storing recycling boxes / wheeled bins. 12 These may require a license from the Environment Agency (contact details are provided at the front of this SPD). 13 Case Study 2 - Segregated Under-Sink Bins Draft Green Lifestyles at BedZED Eco Village Each BedZED home incorporates a colour coded, segregated under-sink bin. The colours relate to the type of waste – green for compostable vegetable waste, two grey sections - for glass, plastics, paper and tins and brown for non-recyclables. This makes separating and transporting the materials to the corresponding outside bins easy. 5.7 It is recognised that the retention of recyclate storage areas, identified to be set-aside as a requirement of planning permission, is not necessarily easy to enforce. However, this should not be used as a reason for not allocating recycling areas. If a space is identified, and put to an alternative use which leads to problems (for example with materials proximate to the public highway), then enforcement action can be taken and the space called upon. If such an area had not been identified at the planning stage then retrospectively finding sufficient space could be difficult. 5.8 A statement should be included in the WMS setting out precisely how the proposal has been designed to incorporate these storage areas. Question 5 Are the requirements set out in Appendix F helpful, overly restrictive or not explicit enough? 14 Draft 6 During Demolition and Construction 6.1 Construction and demolition (C&D) waste accounts for 19% of all UK waste, of which 13 million tonnes comprise materials delivered to sites but never used 13. Not overordering materials is therefore the staring point in minimising waste. 6.2 The recycling of C&D waste has been largely market driven for a number of years. The imposition of the Landfill Tax and Aggregates Tax have made utilising recycled aggregates a commercially attractive option. Consequently many construction firms are likely to be already implementing part of the requirements of this SPD. Nevertheless, the best use of the material should be encouraged, as some recycled aggregates may be suitable for high-grade applications. It is also worth bearing in mind that some recycled aggregates such as recycled planings contain hazardous materials such as tar and will need to be stored as hazardous waste as per the EA’s recommendations until it can be recycled into an appropriate end product. 6.3 To assist in understanding and planning for the wastes that are likely to arise a standard audit form can be used (set out in Appendix G). Key methods for reducing waste are: Avoid over-ordering materials (in terms of quantity and specification); Pre-fabricate off-site to reduce off-cuts and treatment product surplus; Segregate waste materials to avoid cross contamination and facilitate easier recovery; Re-use waste materials on site Re-use off site, as a preference to landfilling. The main contractor should take a lead role in managing the waste arising during construction. 6.3 The EA are seeking the Government to introduce specific targets for recycling construction waste including a requirement to use a fixed percentage of reclaimed materials in construction. This would help make construction and demolition waste more valuable and hence less likely to be purchased or disposed of in a careless way. It would also help to create a ‘level playing field’ for developers across the Country. However, individual site characteristics, difficulties with determining appropriate quantities (not least the expertise required), rapidly changing technologies and subsequently enforcing targets, mean that setting percentages for developers to achieve may not always be applicable or realistic. 13 EA Sustainable Construction: Position Statement (August 2003) 15 Draft Question 6 Do you consider that setting targets for on-site recycling/re-use of C&D waste is the most practical way of implementing waste minimisation principles? If so what should these targets be 6.4 Best practice examples for different developments (below) offer ideas and practical solutions for minimising waste and saving money. It is intended that these will stimulate innovation whilst providing challenging yet realistic guidance. This approach is intended to engender continuous improvement rather than provide a target ceiling for applicants to meet. INSERT best practice examples of recycling/minimising C&D waste when available Question 7 Are you aware of any best practice examples for minimising waste in different developments that could be included in this SPD? 16 6.5 Draft Various documents put forward ideas for good practice and possible methodologies to follow. Examples include: the Demolition Protocol 14; the CEEQUAL Manual15; and the BREEAM16 website. However, the SPD does not delegate responsibility to these documents, it merely identifies them as sources of information that may be of use. 6.6 The sorting of waste at source is deemed to be more appropriate than off site sorting, provided there is sufficient space in which to do so. Managing wastes, in particular material segregation can be improved by staff training and awareness raising. For example, introducing systems and signage to help prevent contamination of one material (e.g. timber sorted in a skip) by another (e.g. paint discarded in that same receptacle). This is also important during the fitting-out of buildings when it is likely that a significant amount of packaging waste will be generated. 6.7 Disposal is the last option. However, if disposal is the only viable option (for example with contaminated soils), the reasons for this must be clearly demonstrated in the WMS, and its final destination justified in respect of proximity to the source of arising. The EA would be able to advise of specific disposal requirements. Question 8 What specific methods for minimising C&D waste should be included in this SPD? On-Site Crushing and Screening 6.8 Mobile plant operation requires a waste management license, though some small scale recovery may be exempt from licensing (they would still require registering). The Mobile Plant Licensing regime is currently in the process of being amended (Environment Agency, July 2005). 6.9 Government guidance (though it is unclear what) cited in the Demolition Protocol suggests that on-site crushing/screening is not appropriate on sites smaller than 0.1ha (1000m²) for environmental/amenity reasons 17. The Environment Agency will be able to advise applicants on the appropriateness of such activities (see inside cover of this SPD for local EA contact details). 14 Demolition Protocol Implementation Document (date unknown) commissioned by London Remade CEEQUAL Manual, Version 3, 30th June 2004 16 BRE’s environmental assessment method for new and existing buildings – www.breeam.org 17 LAPC + LAPPC Risk Method, Revised April 2004 15 17 Draft 7 During Habitation of Buildings 7.1 Once a building is being occupied waste will be generated. This should be managed using the same waste minimisation principles as for its design and construction. Applicants therefore need to address the likely types, quantities and sources of waste generation during the habitation of new or refurbished dwellings. 7.2 People will recycle more if the infrastructure is in place to make it easy for them to do so18. Consequently, applicants will be required to provide (where appropriate): Recycling boxes and appropriate storage areas (for example segregated undersink recycling bins); 7.3 Composting bins and segregated storage areas; Communal facilities; Areas at non-residential development for recycling skips etc. Boxes/bins being provided should be appropriate to the size/nature of the development proposed and the waste collection regime in operation (see section below). To assist in making this provision, Section 106 legal agreements may be sought from developers in accordance with the adopted WLP (paragraph 5.130). Household Waste Collection 7.4 District Councils undertake the collection of waste from homes. They are referred to as Waste Collection Authorities (WCA). Providing the means to facilitate this collection will greatly assist authorities to meet their recycling targets. However, due to historical contracts there are different collection schemes in operation in each of the county’s six districts. Although the Gloucestershire Waste Partnership19 is working towards a more coordinated approach it will take time. It is therefore imperative that applicants/developers discuss the issue of household waste collection with the appropriate District Waste Collection Officer (contact phone numbers are provided on the inside front cover). 7.5 Detailed discussions must be held with the WCA and the Waste Disposal Authority (WDA – the County Council), prior to submission of the WMS to secure the correct type of provision for the scheme being proposed. This will help to: 18 19 reflect existing waste management provision; avoid conflict with waste management systems currently in operation; Regional Waste Strategy for the South West 2004 – 2020 (page 45) The Gloucestershire Waste Partnership consists of representatives from the six Districts and the County Council. 18 Draft determine collection arrangements for the waste; influence transportation methods, distances and routes to waste disposal facilities; take account of the needs of recycling/residual waste collection vehicles in road layouts. Commercial Waste Collection 7.6 The size of waste/recyclate collection vehicles is increasing. The practicalities of waste collection from commercial premises therefore need to be considered as part of the WMS. This includes both materials for recycling as well as residual waste for disposal. 19 Draft 8 Checklist for Preparing a Waste Minimisation Statement (WMS) 8.1 The following criteria provide a checklist for both planning officers and applicants to use to assist in the production of a WMS (also see Appendix E). The WMS’s content is not limited to these issues, which are intended only as a guide: The scheme has been designed to minimise waste production Recycled materials are specified where practicable Tonnage of each type of demolition waste likely to be produced is given On-site re-use of waste materials wherever possible Off-site re-use of waste materials Tonnage of construction waste (including volume of packaging) likely to arise Provision made for waste material segregation Suitable provision for hazardous waste arising on-site Measures for raising on-site awareness of waste minimisation Justification provided for any waste going to landfill WDA / WCA advice obtained on box/bin provision Space provided for recycling boxes Segregated garden space provided for home composting bins Area for communal facilities set aside where appropriate Recycling boxes / composting bins provided by developer Communal ‘bring’ scheme facilities provided Method set out for auditing waste to be managed Monitoring scheme to include corrective measures if failures occur Question 9 Are there any other matters that should be included in this checklist? 20 Draft Appendix A Regional Waste Strategy Policy on Waste Minimisation Policy P10.8 – Design Quality Local and regional authorities and agencies and others should promote sustainable construction and demolition in accordance with the regional sustainable construction charter by: (i) requiring that new development should be designed and planned so as to minimise the production of waste - development plans should encourage development proposals to minimise the use of raw materials and, reuse and recycle waste generated during construction and demolition; (ii) before granting planning permission for major development involving demolition or the production of waste materials, encouraging developers to provide information on the proposed method of dealing with waste so as to minimize its production and maximise reuse and recycling. 21 Draft Appendix B Gloucestershire Waste Local Plan Policy 36 – Waste Minimisation PROPOSALS FOR DEVELOPMENT REQUIRING PLANNING PERMISSION SHALL INCLUDE A SCHEME FOR SUSTAINABLE MANAGEMENT OF THE WASTE GENERATED BY THE DEVELOPMENT DURING CONSTRUCTION AND DURING SUBSEQUENT OCCUPATION. THE SCHEME SHALL INCLUDE MEASURES TO: I. MINIMISE, RE-USE AND RECYCLE WASTE; AND II. MINIMISE THE USE OF RAW MATERIALS; AND III. MINIMISE THE POLLUTION POTENTIAL OF UNAVOIDABLE WASTE; AND IV. DISPOSE OF UNAVOIDABLE WASTE IN AN ENVIRONMENTALLY ACCEPTABLE MANNER; INITIATIVES TO REDUCE WASTE GENERATION WILL BE ENCOURAGED THROUGHOUT THE COUNTY. 5.128 The waste implications of all development should be considered at the earliest possible stage. As local planning authorities, the County and the District Councils have a role to play in ensuring that new development contributes to the objectives of the Waste Strategy for Gloucestershire (June 1997) 20. This policy is not just applicable to development by the County Council but to all development, as indicated in the National Waste Strategy (Waste Strategy 2000). The policy is part of the set of policies that make up the Development Plan as applied through Section 54A of the Town and Country Planning Act 1990 (as amended). Waste is not restricted by administrative boundaries and neither should consideration of it as part of any proposed development. 5.129 Waste generation and disposal implications of new development is a legitimate planning consideration. Planning Applications should contain a statement outlining waste generation and arrangements for minimisation, re-use, recycling, processing and disposal. For development requiring an Environmental Statement, the statement should include a detailed evaluation of the waste generation impact of the proposals. 5.130 This policy should be used in combination with other policies of the Development Plan. Waste minimisation does have a practical land use element to it. In relation to 20 Please note that this document has since been replaced by the Municipal Waste Management Strategy 2002, which in itself is currently in the process of being revised. 22 Draft household waste, it is proposed that through conditions or a section 106 agreement all new housing developments where appropriate should be supplied with home composting bins and booklets on how to use them by the developer. 5.131 In relation to commercial and industrial wastes, developers should provide facilities within: business parks; industrial estates; retail parks; and science and technology parks; that treat and manage the majority of the waste produced internal to the site. This is intended to encourage the use of waste locally, stimulate new businesses, reduce traffic and is in line with the proximity principle. These facilities should be secured through condition or a section 106 agreement with the developer wherever possible, if not included in the original development proposal. 5.132 The Gloucestershire Waste Management Strategy (1997)14 promotes beneficial use of recyclable materials. Without adequate markets for the substantial volumes of recycled materials the strategy would be jeopardised. This partly depends on the private sector creating and marketing new and innovative products and clearly demonstrating that these recyclable materials can meet the standards and specifications achieved by established materials. This is particularly important for the construction industry. It also depends on developing a different attitude to using recycled materials and almost involves an element of ‘positive discrimination’ in favour of recycled products. 5.133 Minimising the volumes of waste we produce is the other half of the waste minimisation equation. It will mean that consumers will have to review issues such as manufacturing processes and purchasing policies. On the face of it this appears to have limited specific land use implications but it may create the need to modify or change the layout and design of existing or new development. In such cases, Local Planning Authorities should take a positive and sympathetic approach to such needs. 14 Please note that this document has since been replaced by the Municipal Waste Management Strategy 2002, which in itself is currently in the process of being revised. 23 Draft Appendix C Expert Discussion Group On the 7th September 2005 an invited group of 21 individuals, representing a wide variety of organisations, convened at Gloucester City Council Offices to discuss the content of this SPD. A roundtable discussion was interspersed with a couple of short presentations to introduce topics. A copy of the minutes of that meeting have been posted on the Gloucestershire County Council website. The attendees were: Martin Chandler Cheltenham Borough Council (Development Control Officer) Meyrick Brentnal Gloucester City Council (Planning) Cat Phelps Gloucester City Council (Recycling) Carlos Novoth Representing Waste Collection Authorities (Stroud District Council) Martin Everett Environment Agency Laura Hackwood Environment Agency Verity Small Smiths Plant Hire Paul Wormald Grundons Simon Ford All Stone Sand & Gravel David Maslen Moreton C Cullimore Ltd David Glenn Huntsmans Quarries Andy Jackson Westbury Homes Ltd Carole Bond Envirowise Frances Robertson Friends of the Earth Peter King Halcrow Kevin Phillips Team Leader, Gloucestershire County Council Nick Croft Principal Planning Officer, Gloucestershire County Council Nigel Overal Highway Operations Manager, Gloucestershire County Council Chris Brown Estate Roads Manager, Gloucestershire County Council Charlotte Weeks Planning Officer, Gloucestershire County Council David Ingleby Planning Officer, Gloucestershire County Council 24 Draft Appendix D Timetable for Preparing the SPD To make all parties aware of the intended timetable for preparing this SPD, it is proposed to follow the framework set out below. Year 2005 Month J Key Milestones (from M&WDS) C Consultation Stages J 2006 A S D L D S J F M A M J J 2 A A P E 1 N O Stakeholder Events Document Preparation O R F 3 4 5 6 7 8 C Commence preparation D Rough draft of initial ideas to be sent to District partners for informal comments L Letters sent inviting selected key members to form an expert group E Convene Expert group to discuss what should be included in the SPD S Wider informal Stakeholder consultation (similar to Reg25) including Newsletter No.3 F Stakeholder Forum to discuss expert group’s suggestions (if enough interest) O Formal 6 week consultation on preferred Options P County and District Council approval of Preferred option R District Council Ratification of final SPD A Adopt SPD 1 initial rough draft prepared based on previous operation of WLP Policy 36 2 amend draft following initial informal District officer comments 3 re-write following expert group discussions/suggestions 4 re-write after wider stakeholder involvement to generate preferred option document 5 amend following County and District Council approval of preferred option document 6 re-write as a result of formal 6 week consultation responses – prepare final version 7 amend if necessary following final County and District Council ratification 8 arrange for printing/publishing of final adopted SPD 25 Draft Appendix E DTI Site Waste Management Plan (SWMP) Nine Step Process The DTI guide sets out a nine step strategy for preparing a SWMP for projects worth in excess of £200,000. Step 1 – Identify who is responsible for producing the SWMP and ensuring that it is followed – and make sure that they know who they are! Different individuals may be responsible during the planning stages and the site-work stages. They must know that they are responsible and what they are responsible for. They must have sufficient authority to ensure that others comply with the SWMP. Step 2 – Identify the types and quantities of waste that will be produced at all stages of the work programme/plan. (See Annex A: Checklist and Annex B: Data Sheet). Step 3 – Identify waste management options including reference to the waste hierarchy, onand off-site options and pay particular attention to arrangements for identifying and managing any hazardous wastes produced. Step 4 – Identify waste management sites and contractors for all wastes that require them and ensure that the contracts are in place, emphasising compliance with legal responsibilities such as the Duty of Care. (See Site Data Form). Step 5 - Carry out any necessary training of in-house and sub-contract staff so that everyone understands the requirements of your Site Waste Management Plan. Step 6 – Plan for efficient materials and waste handling and do this early enough bearing in mind any constraints imposed by the site and it’s location. Based upon steps 2-6 develop indicative percentage targets for each disposal or waste stream and record on datasheet. Step 7 – Measure how much waste and what types of waste are produced and compare these against your SWMP to make sure your are on track to manage all wastes properly and to learn lessons for next time you have to produce an SWMP. These figures should be recorded on the datasheet. Step 8 – Monitor the implementation of the SWMP to make sure that all is going according to plan, be prepared to update your plan if circumstances change or instigate corrective measures if failures are identified. Learn lessons for next time from good practice and benchmarking. Step 9 – Review how the SWMP worked at the end of the project and identify learning points for next time – share these with colleagues who may be involved in preparing or using SWMPs so that they can benefit from your experiences also. You may wish to compare your achieved percentages against your SWMP targets on the datasheet and identify learning points. 26 Draft Appendix F Provision for Waste Recycling/Composting in Developments Housing Specific provision needs to be guided by the number of dwellings provided and location of existing provisions in the surrounding area. Specific percentages for recycling/composting space per dwelling have not been proposed due to the different requirements of occupants, however the following provides a useful guide. Individual Dwellings (houses) • Space for recyclables should take account of standard dimensions of recycling boxes (insert dimensions for each District’s boxes and standard wheelie bins, reflecting also different collection regimes); • Utility rooms, designed-in kitchen space, garages, or adjacent to exterior walls provide the most common solutions; • Home composting bin provision encourages separation and diversion of organic kitchen and garden wastes. Such provision requires discussion between LPA and developer at the preapplication stage to assess viability; Individual Dwellings (flats / apartments) • Where space allows, initiatives such as those listed above could be included, especially where gardens/garages are provided; • Storage areas or a chute system could be provided on each floor or level of blocks of flats / apartments – storage could be lockable / covered and located close to lifts. Chutes would need to meet relevant design standards to ensure health and safety of residents and operatives and to avoid hazard. Regular collection and maintenance would be essential to avoid attracting vermin. Groups of Dwellings (houses, flats and/or apartments) • Provision of a ‘bring’ facility such a recycling banks for glass, paper, cans etc; • Provision of community composting scheme where there is a nearby use for the product; • Where community composting is to be provided, operations must be 250 metres from sensitive land uses and will need to be designed, located, operated and managed to avoid odour and vermin impacts. Consultation with the Environment Agency on location and controls will be essential. Such requirements are likely to impinge on the viability of community schemes; • Any communal storage facilities must be designed to ensure security of storage to avoid vandalism / fly tipping. 27 Draft Commercial, Transport, Leisure, Community, Tourism Development The exact nature of the development in question will influence the type of waste materials to be produced by the premise occupier(s). This can be assessed by the applicant when drawing up details of the development prior to the submission of an application for planning permission. Individual Premises • Provision of purpose built storage areas for both waste materials (for disposal) and recyclables such as packaging materials; • Where appropriate, provision of space for the storage of organic waste, where this is specified as collectable by an identified waste collection / management contractor. Storage for such materials must be designed to minimise odour and vermin (the EA and Environmental Health Officers would need to advise on the appropriateness of particular facilities); • Provision of deposit points within premises for workers/visitors/customers to place recyclables. Groups of premises • Provision of purpose built storage areas for both waste materials and recyclables that can be used and jointly serviced by all occupiers of the development; • Where appropriate, provision of jointly serviced space for the storage of organic waste, where this is specified as collectable by an identified waste collection / management contractor. Storage for such materials must be designed to minimise odour and vermin (the EA and Environmental Health Officers would need to advise on the appropriateness of particular facilities); • Communal storage will need to be designed to ensure security; • Provision of deposit points within premises (inside and outside of buildings) for workers/visitors/customers to place recyclables. Car Parking Facilities • Provision of ‘bring’ facility such as a collection of recycling banks for glass, paper, cans etc where appropriate; • Specific provision needs to be guided by the likely number of users of the car park and its location in terms of transport access for vehicles servicing the facility (e.g. proximity and ease of access). 28 Draft Appendix G Form for preparing a SWMP (Source: DTI voluntary code of practice for construction contractors and clients, 8/7/04) 29 Draft Appendix H List of Useful Documents BREEAM website www.breeam.co.uk CEEQUAL - The Civil Engineering Environmental Quality and Assessment Scheme – Scheme Manual Version 3 (30th June 2004) Wiltshire and Swindon Waste Minimisation SPG (March 2005) ODPM Strategic planning for sustainable waste management (Jan 2004) National Waste Strategy for England and Wales (2002) English Nature Sector Analysis Construction and Development (Jan 2004) Environment Agency Position Statement on Sustainable Construction (Jan 2004) Environment Agency ‘Pollution Prevention Guidance Note 6’ “Working at Construction and Demolition Sites” (undated) DETR Building a better quality of Life (Jan 2004) Welsh Assembly - Waste Minimisation, Good Practice Guide (Jan 2004) Eco-Recycle Victoria Australia Guidelines for Preparing a Waste Reduction Strategy for Construction (date?) CIRA Demonstrating waste minimisation benefits in construction Resource Venture (Seattle, USA) Contractors guide to recycling DTI Site Waste Management Plans Guidance for Construction Contractors and Clients (July 2004) Institute of Civil Engineers (London Remade, Cory Environmental) Demolition Protocol Implementation Document Managing Construction and Demolition Debris (North Carolina) Government of Australia Dept of Environment and Heritage - Waste Reduction Guidelines for the Construction and Demolition Industry (Nov 2002) New South Wales Government - Code of best practice for construction and demolition waste WRAP, The Demolition Protocol: Aggregates Resource Efficiency in Demolition and Construction - Volume 1 for Policy-makers and Planners (undated) 30 Draft Appendix I Glossary & Abbreviations BREEAM BRE’s Environmental Assessment Method This is used to assess the environmental performance of both new and existing buildings. It is regarded by the UK's construction and property sectors as the measure of best practice in environmental design and management. DTI Department of Trade and Industry This is a Government Department with the aim to create the best environment for business success in the UK. EA Environment Agency The body responsible for regulating waste management and pollution control in England. ES Environmental Statement A systematic and comprehensive analysis of the environmental impact of a proposed development presented in non-technical form for public scrutiny. GCC Gloucestershire County Council The Waste Planning Authority for Gloucestershire LATS Landfill Allowance Trading Scheme LAPC Local Air Pollution Control This is Part I of the Environmental Protection Act (EPA) 1990 (The EPA 1990) as the framework for controlling industrial pollution now replaced by the LAPPC. LAPPC Local Authority Pollution Prevention and Control LAPPC is part B of the Pollution Prevention and Control (PPC) Act 1999 and the PPC Regulations 2000 which is the framework for controlling industrial pollution, replacing the LAPC. LAPPC focuses on controlling emissions to air only. MWMS Municipal Waste Management Strategy A statutory document setting out a mainly technical strategy (i.e. future requirements for waste management facilities, the nature of those facilities, favourable locations etc.) for municipal waste management in the County. PPG Planning Policy Guidance Note These set out the Governments policies on different aspects of planning. They range from key objectives, operational principles to guidance and advice on more specific issues. Local planning authorities must take their content into account in preparing structure and local plans. Currently being superseded by PPS’s. PPS Planning Policy Statement PPS’s replace PPG’s and are prepared by the government after public consultation to explain statutory provisions and provide guidance to local authorities and others on planning policy and the operation of the planning system. Local authorities must take their contents into account in preparing their Local Development Frameworks. RSS Regional Spatial Strategy Sets out the region’s policies in relation to the development and use of land and forms part of the development plan for local planning authorities. Planning Policy Statement 11 ‘Regional Spatial Strategies provides detailed guidance on the function and preparation of Regional Spatial Strategies. SA Sustainability Appraisal A tool for appraising policies to ensure they reflect sustainable development objectives (i.e. social, environmental and economic factors) and required in the Act to be undertaken for all local Local authorities are allocated ‘allowances’ for the amount of biodegradable municipal waste they can landfill each year until 2020. They can trade allowances with each other, sell allowances if they have diverted more waste from landfill (e.g. recycling) or buy more if they are likely to exceed their own allocation. 31 Draft development documents. SEA Strategic Environmental Appraisal A process for testing that environmental concerns are integrated into the policy appraisal of development plan preparation. SEPA Scottish Environment Protection Agency The Scottish equivalent of the Environment Agency. SPD Supplementary Planning Document Provide supplementary information in respect of the policies in Development Plan Documents. They do not form part of the Development Plan and are not subject to independent examination. SPG Supplementary Planning Guidance Replaced by SPDs, these were prepared under the previous planning system and fulfilled a similar function to the new style SPDs. SWMP Site Waste Management Plan It is a document that identifies the waste minimisation that all onsite personnel are required to follow. WCA Waste Collection Authority Authority responsible for the collection of household and preparation of Waste Recycling Plans. WDA Waste Disposal Authority Authority responsible for the disposal of local authority collected waste, and the disposal of waste delivered to Civic Amenity Sites or Household Waste Recycling Centres. WLP Gloucestershire Waste Local Plan A statutory land-use plan forming part of the Development Plan for Gloucestershire. Its purpose is to set out detailed land-use policies in relation to waste management development in Gloucestershire. WMS Waste Minimisation Statement A document stating the methods for minimising and managing waste deriving from a development proposal during its design, construction and occupation. 32 Draft Appendix J Planning Policy Statement 10: Planning for Sustainable Management, July 2005 34. Proposed new development should be supported by site waste management plans of the type encouraged by the code of practice published by the DTI14. These do not require formal approval by planning authorities, but are encouraged to identify the volume and type of material to be demolished and/or excavated, opportunities for the reuse and recovery of materials and to demonstrate how off-site disposal of waste will be minimised and managed. Good Design 35. Good Design and layout in new development can help to secure opportunities for sustainable waste management, including for kerbside collection and community recycling as well as for larger waste facilities. Planning authorities should ensure that new development makes sufficient provision for waste management and promote designs and layouts that secure the integration of waste management facilities without adverse impact on the street scene or, in less developed areas, the local landscape. 36. Waste management facilities in themselves should be well designed, so that they contribute positively to the character and quality of the area in which they are located. Poor deign is in itself undesirable, undermines community acceptance of waste facilities and should be rejected. 33 Draft Appendix K Non technical summary of the Interim SEA/SA Results 1.1 Under new planning legislation, Gloucestershire’s Waste Local Plan and Minerals Local Plan are being replaced by the Gloucestershire Minerals and Waste Development Framework (MWDF). The MWDF will contain a suite of documents containing policies relating to minerals and waste development in the county. Work on these documents will continue over a 10-year period. The South West Regional Spatial Strategy (RSS) is due to be adopted in 2007 and the MWDF should be in general conformity with it. There is a requirement to minimise waste in the Regional Waste Management Strategy for the South West 2004 – 2020. 1.2 It is a statutory requirement for the MWDF to undergo a Sustainability Appraisal (SA) whereby potential social, economic and environmental impacts are identified and carefully considered. The SA should inform and influence plans early in the process with the aim of making them more sustainable. This appraisal incorporates the rigorous requirements of European law, (the SEA Directive), which ensures that certain plans and programmes are scrutinised for their potential environmental impact. The initial stages of SA involve gathering evidence and building a framework against which relevant plans within the suite of the MWDF can be tested. Gloucestershire County Council has completed these initial stages with the publication of a Context Report and a Scoping Report. These are available to be viewed on the Council’s website at the following address: http://www.gloucestershire.gov.uk/index.cfm?articleid=1405 1.3 The Supplementary Planning Document (SPD) on Waste Minimisation is required to be tested against this framework. Initially the SPD objectives where tested against the SA framework objectives and judged to be compatible. (See Table 2). The appraisal process required consideration of alternative options i.e.: 1. Without the SPD (Business as usual). 2. An SPD based on best practice examples. 3. An SPD based on targets. Option 2 emerged most favourably with the most positive effects indicated against the SA objectives (See Paragraph 4.4 and Appendix 1) 1.4 Apart from the testing of options, the purpose of the SA process is to test the potential social, economic and environmental effects of the SPD. The SEA Directive requires that a very wide range of possible effects are considered and that recommendations be made as to how these will be addressed and monitored. The detailed appraisal is provided in Appendix 2. The SA report also indicates a proposed approach to monitoring the effects once the SPD is implemented. (See paragraph 5.2) 1.5 This is a draft Interim SA Report for the SPD and is subject to changes. The full SA report on the SPD will be issued for public consultation with the draft SPD in March / April of 2006. 34 Draft Appendix L Minutes of Expert Group Discussions Gloucestershire County Council (in partnership with the Six District Councils) Waste Minimisation Supplementary Planning Document Expert Group Discussion 9:30am – 13:00pm Wednesday 7th September 2005 at Gloucester City Council (Committee Room 1, ground floor of North Warehouse) Agenda 9:30am Coffee and Registration 9:40am Welcome and Introductions 9:45am Agenda Item 1: Presentation (Nick Croft) - Waste Minimisation: The Planning Issue 10:15am Discussion on thresholds for requiring submission of a waste minimisation statement (Draft SPD Section 1) Agenda Item 2: Presentation (Nigel Overall) - Using Recycled Materials in Developments: Gloucestershire County Council Road Maintenance case study 10:30am Agenda Item 3: Discussion on managing C&D waste: What materials can/can’t be used (Draft SPD Section 6) Target percentages for re-used/recycled material in developments (Draft SPD Section 6) Any examples of good practice that could be included in the SPD? 11:30am Coffee Break 11:45am Agenda Item 4: Discussion on incorporating recycling schemes into developments (Draft SPD Sections 5 and 7): 12:50pm Summing up 13:00pm Close Design solutions for storing recycling boxes (internal & external) (Draft SPD Section 5 and Appendix F) Collection requirements (external storage/operatives/vehicles) (Draft SPD Section 7) Use of Section 106 agreements and planning conditions (Draft SPD Section 4) What requirements should the SPD contain (Draft SPD Section 8)? 35 Draft List of Attendees to Expert Group (7th September 2005) to discuss the Waste Minimisation SPD Meyrick Brentnal Gloucester City Council Frances Robertson Friends of the Earth (Gloucestershire) Chris Brown Gloucestershire County Council Martin Chandler Cheltenham Borough Council Verity Small Smiths Plant Hire Martin Everett Environment Agency Laura Hackwood Environment Agency Carole Bond Envirowise Carlos Novoth Representing Gloucestershire’s Waste Collection Authorities Cat Phelps Gloucester City Council Paul Wormald Grundon Waste Management Ltd Andrew Jackson Westbury Plc Simon Ford All Stone Sand & Gravel Aggregates Trading Co Ltd David Maslen Moreton C Cullimore and Son Ltd David Glenn Huntsmans Quarries Peter King Halcrow Nigel Overall Gloucestershire County Council Kevin Phillips Gloucestershire County Council Nick Croft Gloucestershire County Council Charlotte Weeks Gloucestershire County Council David Ingleby Gloucestershire County Council 36 Draft Name Comments Kevin Phillips Welcome and introduction. KP to chair the meeting. Nick Croft Presentation on supplementary planning documents (SPDs), waste minimisation principles & issues. Kevin Phillips Agenda Item 1 on Thresholds for Submitting a Waste Minimisation Statement. Frances Robertson The SPD needs to be applied to every development or else the Districts will not meet their targets. We might want certain aspects to apply to every household. Major applications should have a waste minimisation statement (WMS) and smaller applications could carry out a checklist? Information leaflets would also be useful. If there is an application for development of 9 houses then the threshold of >10 houses for a major application would mean that a 9 house development would fall out of the loop and not have to carry out a waste minimisation statement (WMS) even though this development could be deemed equally major. There is a problem with the whole concept of demolition particularly in Conservation Areas. Developers in Conservation Areas have to have an application to demolish. In these cases you would dismantle a building and re-use the materials, which is therefore more sophisticated protocol for a demolition audit. Paul Wormald Are you talking about sash windows, cornice pieces etc.? Frances Robertson Also old bricks for example. Developers creating new builds could use these old reclaimed materials as these are now becoming more appealing to property buyers. Paul Wormald There is a lot of material out there that can be recovered. Frances Robertson I agree. Dismantling rather than demolition is useful and developers should audit old buildings pre-demolition to evaluate what value in terms of reusable materials could be gained from the building. Nick Croft Good point, but this is a lot of work that is ultimately to be implemented by the Districts. Kevin Phillips Do the Districts have any comments on this? Meyrick Brentnal Development Control (DC) officers will maintain that they are overwhelmed with applications and will be reluctant for extra work. The SPD needs to be clear and not over complicate matters. Although agree with Frances principles, it is not possible for every application to be caught by this SPD. Kevin Phillips For a lot of developments this document will provide enough information for DC officers. It is an important point though as there is a resource issue if WMS’s are required for all developments. Carlos Novoth The whole infrastructure may be too complicated for DC officers to look at? Even the basics of waste storage can be ignored by developers so it may be that just highlighting the need to think about waste issues early on is enough. Frances Robertson Cheltenham Borough Council has a Sustainable Construction SPG. It would be useful if this SPD were linked to it. Paul Wormald The SPD should target the people who produce the waste in the first place such as the site managers. Andrew Jackson We have found that different District Council’s have different requirements for example South Gloucestershire demand a waste minimisation statement regardless of the size of the development. Kevin Phillips We are aware that they use different policies covering this. Draft Nick Croft Is there a development control officer opinion on implementing this SPD? Martin Chandler I think using the ODPM thresholds (cut off points) for large developments is sensible. Developers and DC officers are both aware of them. Imposing further requirements for developers (including small scale) would be very difficult. The issues are less significant for small developments so I would prefer to only make the requirement for WMS on large developments defined by the ODPM threshold. Frances Robertson If you make the threshold black and white some developments may be missed that are important or controversial, but just don’t fit into the threshold. Nick Croft It appears therefore that we agree to use thresholds, but potentially with a caveat that developments likely to produce a lot of waste are proposed that they too are captured. This though would require an element of case officer judgement when an application is submitted. Martin Chandler We need to get consistency around the County so that developers know what is required of them. Meyrick Brentnal This SPD could be a safety net and will create consistency across the County in terms of what is required from developers. DC is overstretched and is a production line. Simon Ford Could conditions be used to state these requirements, as this would seem easier? Nick Croft In the past, a condition was used requiring a waste management stage to be submitted. However, the problem with this method is that the planning decision has already been made. This SPD seeks to make developers think about ways to deal with waste early on from the design stage otherwise waste management becomes an add on and is often too late to make the best design decisions. Kevin Phillips The adopted SPD will be used as part of the planning application stage. The development proposal along with a waste minimisation statement should be submitted together. Simon Ford I have recently been involved in a housing demolition project where I could have burnt all the waste produced on site, as there was no planning condition preventing me from doing so. I did not burn the material but there was nothing to stop me. Nick Croft As part of the negotiations with developers, a discussion around what to do with the waste should be included. Chris Brown Good point, need to make waste important and worthwhile to developers. Paul Wormald Doesn’t the market have the lead in encouraging developers to use waste more efficiently anyway? Nick Croft Yes, it has been found during the evidence gathering stage of the SPD that most developers already optimise the use of waste on site as common practice because it is cost effective and makes financial sense to do so. Paul Wormald In that case do we need to target mid tier developers rather than large developers who do it anyway? Frances Robertson Currently there are no restrictions on burning on site. Could there be a condition applied to the waste during and post development, as the design stage would only affect large developments anyway? Kevin Phillips Due to time restrictions, we should move on to the next presentation. Nigel Overal Agenda Item 2: Presentation on using recycled materials in developments: Gloucestershire County Council Road Maintenance case study. Kevin Phillips In terms of proposals on state roads (private developers), they presumably acquire their own materials from private suppliers and not from the County Council? 38 Draft Nigel Overal Part of the new contract/tender has asked contractors how to open up the market for supplying material to external sources. Currently, we only deal with inhouse waste. Chris Brown For example, a lot of waste generated from GCHQ has gone into state roads e.g. in Tewkesbury and Cheltenham. Kevin Phillips What tonnages per annum are recycled? Nigel Overal These figures can be misleading. Need to be specific when recording & quoting these figures. At present only materials that we produce in house and reuse/recycle in our own works are recorded. Therefore if the material goes out to an external source then it currently isn’t included in the figures. Last year we recycled 40,000 tonnes. This is a significant proportion of all the waste generated. We are looking at new targets for example for imported materials. Kevin Phillips Agenda Item 3: Managing C&D Waste. Firstly, what materials can/can’t be used? Andrew Jackson On contaminated sites (such as an old landfill site) permission may be given to allow material for capping the top of the landfill, but if the landfill needs to be dug into for some reason, such as installing services then the material (waste) extracted is not permitted to be replaced into the ground where it originated. This causes a lot of problems in terms of how to deal with this extra waste generated such as transportation of the waste off site to an appropriate facility. Martin Everett We acknowledge that this is a significant issue. Work is on-going within the EA looking at this. Often there is a serious environmental risk in these cases and so legislation kicks in. These sorts of cases will increase in the future with new legislation encouraging development on brown field sites. The industry should lobby DEFRA on these issues. Kevin Phillips Are there cost issues involved in treating the waste on site? Martin Everett Yes, legislation does not address this problem but work is going on to change this. Frances Robertson Hazardous waste in the County is a big issue – we are still waiting for the relevant chapter in the Regional Waste Strategy. Hazardous waste could be reduced in the design stage. For example some paints that are used may become a hazardous waste source going to landfill when the building is demolished in the future. Paints could be water based reducing hazardous waste in the future. Paul Wormald Another example is aluminium being coated or galvanised being more difficult to recycle in the future due to added energy costs removing the galvanisation or paint etc. Peter King Recycled aggregates are currently judged against primary aggregate specifications. Verity Small Have you had any problems with specifications of recycled aggregates? Peter King Some recycled aggregate products still have tar on them e.g. planings. This creates storage problems as it is classed as hazardous waste even though the tar is usually ingrained and unlikely to come off. It is currently only acceptable to recycle planings back into a bitumen end product such as foam base. Paul Wormald Do you come across any other contaminants? Peter King No not really. In 1985, it was found that actually only a little demolition waste went to landfill, most was re-used as inferior aggregates. In the last 20 years the industry has tried to highlight that recycled aggregates can be used for higher-grade applications and used in the best way that they can. For example, crushed concrete can be re-cycled back into concrete. Ideally we need to make the best use of the material as much as possible not just recycling for the sake of meeting recycling targets. Frances Robertson For individual developments it is not worth taking the material offsite, it may be the best environmental option to re-use the material at the source in a nothing 39 on – nothing off policy. Draft David Glenn The issue of sufficient space may make it difficult to achieve this in every development. Recycling of materials requires a large amount of space in order for materials to be placed in storage piles. The piles may be stored for different periods of time in case there is no current market for that particular product (seasonality). Therefore it may not be practical to store materials where they originated. Peter King Agreed, this is an area of planning that some people are unsure about how to treat, handle and store material. Martin Everett Large-scale industrial operators have far greater capacity but there are issues in identifying sufficient land for large-scale industrial operations that can satisfy the demand. Nigel Overal If we use our own material instead of selling it to external sources then you don’t have to worry about where it came from. Carole Bond Is there a case for a resource (waste) exchange in Gloucestershire? It may be worth investigating the economic opportunities for small operators in using a resource exchange at a forum. Verity Small We do have small operators already selling material to us. David Maslen The Government is pushing for recycling anyway through various taxes e.g. the aggregates tax. Peter King There are very few materials that can’t be recycled. Blacktop (top layer) is a problem, as it needs to have a certain skid resistance and other stringent specifications. We need to get away from selling waste out to external recyclers. David Glenn The County Council may be doing a disservice in not selling waste to recyclers. Nigel Overal In our targets, we have found that it may be cost effective to share recycled materials than only using our own waste. The whole design element is thought through for example using thinner amounts of bitumen. Verity Small Back to the issue of planings, I was under the impression that this was good aggregate, but it is now classed as waste. Peter King We are not allowed to use planings as high quality aggregate as it is difficult to compact in some cases. However, the main problem is in concrete as it is usually visible. Verity Small It can be used on tracks (haul roads) though. Peter King In that case then it’s no problem. Verity Small It is still a grey area though. Martin Everett We need to be pragmatic on where to draw a line on what to allow exemptions on. I don’t want to stop a local farmer mending his track with a couple of tonnes, but it can then get more complex with bigger possibly contaminated loads and potential issues with floodplains etc. Frances Robertson There are other waste arisings other than C & D waste from residential developments, which we have mainly been talking about. Different types of waste arisings are produced in different stages of development. There was a recent study by Cardiff University on the significance of packaging of building materials e.g. single trip pallets. Packaging waste is a large proportion of the waste arisings. In the past people were paid for the pallets used on site, now they are thrown away and not recycled. Simon Ford We work with builders and skips are used for all packaging waste etc. and are sent to us to sort. Frances Robertson But this waste would be better sorted at the source to prevent cross contamination. 40 Draft Simon Ford Why if we do it for them? Verity Small It does happen on sites where it can be done. Frances Robertson Not only could developers reduce over ordering, but they also need to look at the end use of materials. The people around this table know about how to deal with waste but the large majority of small operators may not. Paul Wormald Small operators generally have small amounts of waste and would send the material to waste management sites for sorting as there may not be enough room on site. Simon Ford We took waste from the GCHQ site and we specified that waste should not be mixed but put in separate skips. It turned out that when the skips were brought back the materials were mixed and we had to sort it. Chris Brown Developers need to do it but maybe need to promote the work they are doing? Paul Wormald As devil’s advocate, if developers are already doing it then why do we need an SPD that creates extra paperwork? Simon Ford Because we still need to deal with small developers. Martin Everett There are ways to reduce the amount of packaging that you buy, for example B & Q offer a low rate lower packaging product, so you pay for less packaging and less waste. Meyrick Brentnal The market is driving this anyway. What the SPD needs to do is stimulate the market and should be used as a guide show to the requirements. David Maslen Surely the developers would use the cheapest option available. Meyrick Brentnal If all developers use recycled materials then it would bring the price down. David Glenn It is the smaller developers, which need to think about waste management, but unfortunately it may mean that we end up with more waste minimisation statements and more work. Carole Bond Envirowise is a government programme to provide advice to developers in reducing waste. It has researched the waste horizons for all developers. We have case studies of small and medium developers, which may be useful for the SPD. Research has demonstrated that there is something for everyone to gain. There is a helpline for people needing advice for all developments and local visits can be arranged to provide individual sites advice on how to improve waste management and reduce costs. There is a need to stress to developers that money can be made from recycling. There is an advantage of smaller companies becoming more involved. They could look to the SPD for advice. Frances Robertson A lot of developers are architects and they could be another area targeted by the SPD. Anything that makes the architect think about waste in the design stage is a good thing. Not just developers need to look at reducing waste. Verity Small We must not force too much onto small operators or they will be reluctant to recycle and may be unable to keep up economically. We need to educate them instead. The reason construction packaging is done is to protect the products. If the products are damaged then you could end up with a lot more waste to dispose of. Kevin Phillips Lets go over targets – do we need any and what sort? (Section 6 of the SPD) Meyrick Brentnal An inspector would never have accepted targets in the past. However now targets are more acceptable e.g. renewable energy plans. From a planning 41 Draft viewpoint it is now important to have targets. Frances Robertson How do you tackle where the material was sourced? What percentages would you use? How do you make sure that waste is minimised in the first place and then deal with left over waste? Maybe you could use sliding target? What happens when the targets are not met? I don’t have the answers I’m just asking the questions. There are clear problems with targets e.g. if they are set too low – it may stifle innovation etc. David Glenn What are you going to be measuring? Will it be on tonnage or value of the material? For example how do you measure plastics against builder’s rubble? Martin Chandler DC officers don’t have the expertise to go through the demolition phase. It would be better to have a best practice guide rather than use actual targets. Frances Robertson Could you set a minimum target to achieve? Nick Croft We could use aspirational targets and then you are not stifling progression in the industry. Carlos Novoth There is a significant problem in that the data on waste and tonnages is very poor. We just don’t know the tonnages. Could we use best practice as a starting point until we know and understand what sort of targets are needed. Chris Brown It depends on the development type & what’s being recycled. Bearing this in mind, a lack of targets is better. Kevin Phillips It will vary on a case-by-case basis and there appears to be consensus that the use of targets is not the best way forward. OK, after the coffee break lets move onto how we can incorporate recycling schemes into development, including design and collection requirements. 10 minute coffee break taken Carlos Novoth Gloucestershire Waste Partnership consists of the County and all 6 Districts. All six districts vary in their methods and schemes for collecting waste. Some may use wheelie bins and some may collect garden waste and some may not. There is a large amount of difference between all 6 districts. Gloucestershire waste partnership has been working for 6 months and important decisions are being made on source separation on individual materials or whether to use a mixture of materials. Targets have been given to the County by Central Government in which to meet, but not sure how we don’t have the money to do it. The LATS targets are the main driver in the County but face huge fines if we don’t meet the targets – in the millions of pounds. We are trying to find a level playing field and systems, which all the districts can all fit into. It may take 5 -10 years to achieve. Like householders, developers need to know what methods of collection are being employed in the particular District. In order for the SPD to work we need to get developers to contact the correct district in order to get the proper advice on design and specifics etc. Kevin Phillips The issue of targets are highlighted again. Martin Everett Large sheds are needed to deal with the waste as part of the infrastructure. Kevin Phillips How do we ensure that the right mechanisms are designed in to deal with the waste? Take for example a development of 100 houses. How do we ensure the most effective use of recycling? Paul Wormald Aren’t we required to do this anyway? Martin Chandler This should be dealt with in the pre-application stage. The developers should be told to talk to the correct district waste collection authority. It needs to be flagged up that recycling and collection are important and should be designed in. We need mechanisms in place to make sure that they are included and direct them to the various bodies. Then we don’t need legal agreements and conditions. We could invalidate schemes that don’t have the recycling element. Kevin Phillips This links in to the next topic for discussion. 42 Draft Agenda Item 4: Incorporating Recycling Schemes into Developments Frances Robertson It is recognised that communal buildings are not well serviced in terms of recycling collections/facilities. We don’t want to direct developers to provide understorage bins if the WCA cannot deal with it. Storage for wheelie bins and boxes is a problem for communal buildings. There needs to be something explicit in the SPD and appropriate for a particular area. So far we have concentrated on residential properties, but we should also target commercial developments as they also produce waste and may have more space to allow for waste separation. Paul Wormald Agreed, tonnages are greater from commercial developments than municipal household ones. We need to deal with waste on industrial sites that generally have enough space to do so. Nick Croft In Appendix F, I have tried to encompass these issues, but should it be more explicit or not? Carlos Novoth It gives good guidance as it covers virtually every situation, but there is still the issue of differences between the districts. It is ridiculous how waste collection has been forgotten in urban design. For example, in Stroud town centre where recently bins were being placed on the highway because there was a lack of space for storage. We need to look at the life cycle of buildings. Nick Croft It is an important issue. Do the districts feel confident to give the expertise or point to the relevant people? Carlos Novoth Gloucester City Council have produced a Section 106 agreement which is very comprehensive, but there needs to be consistency across the districts. Meyrick Brentnal In the last presentation training of staff was suggested and this should be an integral part of the process. It may not be for the SPD but it may be useful to start training sessions in each local authority to DC staff in order to make them aware of the SPD and members could also be included. Kevin Phillips Meyrick, have you had any problems with multiple occupancy builds? Meyrick Brentnal Listed building constraints have been an issue. Frances Robertson Need to think about possible future waste collection facilities and requirements with room for expansion. For example, more boxes may be introduced in the future and this needs to be provided for. Can you require that an agreement be made with the developers? Martin Chandler We could make developers aware of future changes and work these things in to the development in order to be flexible enough to change with the times. Kevin Phillips How should we deal with the development of an industrial or commercial site? The advice from a WCA may highlight very different issues. Frances Robertson Need to have stringent conditions. Martin Chandler But how would you enforce it? How would you know if a storage area to the rear of a building was being used in accordance with its planning permission? Frances Robertson The public will be the first to highlight it if things are not done correctly! Paul Wormald Could an area be allocated solely for the use of recycling? Then stop them using the area for anything other than for waste storage. There is a need to educate the commercial sector as well as the household sector. Nigel Overal The problem is you have to make the space available for recycling. Some people have garages, which aren’t used this space should be made available. Soon it will become the culture to recycle and provide space for boxes etc. The important thing is that if you have set aside an area for recycling as part of the permission, and it is subsequently used for other purposes, if there is deemed to be a problem enforcement measures can be taken to return that area to waste/recycling use. If the area is not there then it may be difficult to find sufficient space at a later date. Carlos Novoth Presumably the SPD will be regularly reviewed so that we can change things gradually. So we can learn from our mistakes in the future. 43 Draft Kevin Phillips The Waste Local Plan (WLP) will be replaced with 3 or 4 documents. This is one of the first documents that will be adopted under the new regulations. Once the whole framework is finished then we will have a better idea of how to deal with it. Frances Robertson Have Wiltshire finished their SPD? It would be useful to see what has happened on the ground in terms of planning applications. Nick Croft Yes, it was adopted in March 2005. Appendix F is to some extent lifted from their SPD. It is a culmination of a lot of people’s opinions. They now want to move it on and take on board what they have learnt. Some feedback on the SPD has been that there are problems enforcing it. Frances Robertson It will be useful to see what is proposed and how they coped with it. I’m all for advice and guidance but if it is not used then it is not any good. Kevin Phillips If the SPD is complete then the policy framework is in place. I think I am right in saying that the RTPI gave Wiltshire an award for their SPD. Frances Robertson There are plans to build 30,000 new dwellings in Gloucestershire in the near future in the Joint Study Area (JSA). We need to think about this in terms of waste arisings. It is a case of development mania. The SPD needs to be something that people can use and the planning officers are willing to work with. Nick Croft As with targets, would a few examples of best practice case studies be of use? Frances Robertson Yes, we need good examples of best practice. These would be useful. Carlos Novoth With regard to collection requirements, collection vehicles are getting bigger for example some 21 tonne vehicles are being replaced with 26 tonne vehicles and are also getting longer. Some vehicles are 4 or 5ft longer. Therefore, adequate turning space is required. There is also the issue of providing collections in developments that are part finished and part inhabited. There needs to be a system in place where the developer makes the WCA aware of progress on the development particularly when homes are inhabited and producing waste. Later on, collections have to be shuffled around and it is usually at the last minute. This makes the Council look bad to the public if waste is not collected when expected. Another issue for collection vehicles are areas of adopted or soon to be adopted roads. There is no indication whether a road is adopted or not and if damage is caused to non-adopted roads and potentially the services beneath it such as private driveways, then the WCA is faced with a claim for compensation if damage is caused. Chris Brown In order for developers to recognise the size of collection vehicles they should ask the responsible WCA. It is the developer’s responsibility to make the road up to scratch before it can be adopted. Ask the developers to tell the WCA if any buildings are occupied. The argument to make with the developer should be that if they don’t indemnify the WCA against any damage then the WCA will not collect their waste. Carlos Novoth The customer is the most important person, but they have no connection with the planning stage. Meyrick Brentnal It is equally the WCA’s job to communicate with the planners. Frances Robertson It is also about access to collect waste as well as providing space for it. Martin Chandler You could ask for notices to be put out to the occupants of the half finished development asking them to inform the WCA when their house is occupied. Nick Croft Is section 8 of the document useful for DC officers? Frances Robertson The checklist in the SPD should refer to all those issues dealt with in Policy 36. Martin Chandler The checklist is useful, we use checklists a lot. There is no reason why this wouldn’t work. With experience the DC officers would know what to look for, but initially expert advice is useful. Nick Croft An example of a site waste management plan taken from the DTI guide is in Appendix G of the SPD. 44 Draft Paul Wormald Agree that this is a good practical solution. How complex is the SPD going to be? Anything more than a couple of sides is not going to be useable for the average small operator. Frances Robertson Along with this SPG what would help is if the planning application forms were updated and the amount of space on the forms should be increased in order to provide sufficient detail. Martin Chandler One form for all applications is going to be brought out soon. Martin Everett The fitting out of homes/premises is a significant issue. These can be large sources of waste and fly tipping. This transitional phase between building and occupation is a difficult one. If facilities are in place as early as possible, the occupants get into the habit of using them and then this behaviour gets fixed in. Chris Brown Isn’t this a bit complicated for the SPD? Nick Croft Yes, possibly, but it is still useful to know for background information. Kevin Phillips Thanks to all for coming. If there are any issues that have been raised that need further attention there is a possibility of other meetings in the future. We will incorporate the comments made in this meeting into the revised draft of the SPD, which will go to informal consultation during the Autumn. 45