Updated national waste planning
policy: Planning for sustainable waste
management
Consultation questions response form
Consultation Questions
Question 1: Existing national waste planning policy in Planning Policy
Statement 10 has been well-supported, so the Government has focussed on
streamlining the policy in line with National Planning Policy Framework
principles rather than introduce radically new proposals. Do you agree with
this approach? Do you think there is anything fundamentally missing
from the updated policy that must be included?
Yes
Comments
We agree with this approach, and have set out where we believe the policy should better
support the development of anaerobic digestion facilities in questions 3, 6 and the “other
comments” section.
Question 2: The updated policy states that local planning authorities should
ensure that the planned provision of new capacity and its spatial distribution is
based on robust analysis of available data and information. Do you think that
sufficient data and information exists to allow waste planning
authorities to adequately plan for provision of new capacity? What
changes to the updated policy, if any, do you consider are necessary to
achieve this?
No
Comments
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No, there is a lack of up-to-date robust data on national waste infrastructure. Many within the
waste management sector have also pointed to the fact that data on municipal waste is widely
considered to be more reliable than that for commercial & industrial waste.
Question 3: The policy sets out the requirements for identifying sites for new
development, including the proximity principle and assessment criteria. Do
you agree with the requirements set out for identifying sites, including
the policy additions on the potential for utilising heat and the siting
alongside waste sewage treatment works in respect of energy from
waste schemes?
Yes
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Comments
ADBA welcomes the policy addition recognising the benefits that can be realised from making
use of heat from energy from waste schemes, which should mean that anaerobic digestion
(AD) projects are supported more strongly in the planning process.
Wastes including household food waste, farm slurries, and waste from food processing plants
and supermarkets, react with bacteria in the AD process to produce a biogas, which is
approximately 60% methane and 40% carbon dioxide, and digestate, which can be applied to
farmland to reduce the need for damaging artificial fertilisers.
Biogas can be combusted in a combined heat and power (CHP) engine to generate heat and
power or it can be upgraded to a renewable natural gas equivalent (biomethane) and injected
directly into the gas grid.
AD technology has helped businesses in a range of sectors reduce their energy bills, as well as
enhancing their sustainability credentials. Farmers, food and drink processers and water
companies are particular leaders in the field, as they can recycle organic wastes to generate the
power and heat their businesses need.
As well as using the biogas to meet their on-site energy needs, operators can also supply heat
to nearby buildings or businesses, for example farmers can use the heat to dry grains.
It is also important to note that an increasing number of AD plants will be able to make use of
the heat they generate through CHP engines next year. At present, the Renewable Heat
Incentive (RHI) only supports heat generation from AD plants with a thermal capacity up to
200kW. This is set to change in the next year however, with a far greater proportion of existing
and new installations potentially able to make us of heat generated, when the RHI is expected
to be extended to AD installations of all sizes in spring 2014. Planning policy should therefore
reflect the importance of this to wider government policy in terms of delivering renewable
heat.
We also welcome the encouragement for recycling projects sited alongside sewage treatment
works. AD has been used in the water industry for decades as a sewage treatment process,
while also providing heat and power for on-site operations. There may be opportunities to colocate AD plants treating sewage sludge with those treating other organic waste such as food
waste, although there should be no restriction on these being sited in other areas appropriate
to the local need.
Question 6 Guidance: Alongside this consultation exercise, the Government
will be preparing guidance to support the policy in line with the principles set
out by Lord Taylor of Goss Moor. Are there any specific parts of the
existing Planning Policy Statement 10 Companion Guide or Guidance to
local authorities on implementing the EU Waste Framework Directive
that you wish to see carried forward? Are there any other areas where
guidance is required?
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Comments
Article 22 of the Waste Framework Directive requires member states to ‘take measures...to
encourage the separate collection of bio-waste with a view to the composting and digestion of
bio-waste’. Accompanied by Defra’s 2011 Review of Waste Policy in England which states that
AD offers ‘the greatest environmental benefit’ of any treatment for food waste, we believe that
government must take a more proactive approach to encouraging local authorities to
separately collect their food waste to enable this waste stream to be treated through AD, in
line with European and national objectives.
Northern Ireland, Scotland and Wales have all taken strong action in this area to ensure
progress. For example, the Scottish Government has provided the legislative framework to
support rolling out food waste collections across all local authorities and businesses by 2015
and for banning organic waste to landfill by 2020, under their Zero Waste Plan. Zero Waste
Scotland provided £9m funding to councils and businesses in 2012, helping to fund food
caddies, communications to local residents, as well as supporting the development of AD and
composting infrastructure to treat the greater quantity of available food waste.
ADBA believes that current UK government action has not been enough to encourage separate
food waste collections, for subsequent treatment through AD. In February 2012, the
Department for Communities and Local Government launched the £250m Weekly Collection
Support Scheme to enable councils to introduce weekly waste collections. Although support
was extended to weekly food waste collections, much of the messaging around the policy
concentrated on supporting weekly residual collections, and this undoubtedly sent mixed
messages to councils and the public about collection policy.
Government must offer clear guidance to local authorities that where feasible, separate food
waste collections should be encouraged, with support given to AD facilities which are then able
to process the food waste which is collected.
Other comments:
There are significant environmental and economic benefits that can be delivered by AD
facilities, which should be recognised by planning authorities. AD was acknowledged in Defra’s
2011 Review of Waste Policy as delivering the ‘greatest environmental benefit’ of any food
waste treatment, diverting food waste from landfill.
As set out in question three, through the generation of a flexible renewable gas, “biogas”, the
UK’s energy security can be boosted. Biogas reduces the need for volatile imported gas
supplies, with biogas capable of being used for on-site heat and power, exported to the grid, or
upgraded to biomethane and injected directly into the gas grid.
The AD sector can also offer specific benefits for farmers. AD technology integrates easily into
existing farm operations, acting as a treatment for slurry while providing a biofertiliser which
reduces reliance on expensive environmentally damaging artificial fertiliser. The use of crops as
an AD feedstock can also boost the sustainability of farming operations, acting as a break crop
to help improve soil quality and yields, reduce chemical inputs to control persistent weeds and
pests, and bring marginal farmland into use. Planning policy should recognise AD as an
important part of farming operations.
Businesses in the food and drink sector are also particularly well placed to benefit from AD,
using organic waste treated on-site, as well as taking in other waste, for example from local
authorities or other businesses. This should also therefore be supported in the planning
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process.
Government has been explicit in giving its backing to the AD industry, committing in the 2010
Coalition Agreement to delivering a ‘huge increase in energy from waste through anaerobic
digestion’. 2011 also saw the publication of their ‘AD Strategy and Action Plan’, outlining how
this ‘huge increase’ would be delivered. Given the firm backing that central government has
given to the growth of the AD industry, in the context of the environmental and economic
benefits that the industry will bring, local planning authorities should be willing to provide a
supportive attitude when considering AD planning applications.
Thank you for your comments.
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