URGENT REQUEST FOR ACTION
Deadline: Friday 7 June 2013
You will recall that we have been supporting the Pinkham Way Alliance in their successful campaign to protect the Pinkham Way nature conservation site from waste development. Work has now begun on the new North London Waste Plan. The Pinkham Way site was included in the last (failed) plan which we objected to. The seven North London Councils, who are developing the new waste plan between them, have asked for our views on what should be in the new plan. We would like to let them know that we do not consider it is appropriate to develop a waste facility on the Pinkham Way site. There is no document that we are being asked to consider at this time. That will not appear until summer 2014, when there will be a formal consultation.
It is important we all comment to Archie Onslow at email@example.com or by post to Archie Onslow North London Waste Plan Camden Town Hall Argyle Street London WC1H 8EQ. See draft sample letter below to assist you to respond. Links to more information can be found at the end of the draft letter.
Dear Mr Onslow,
I do not agree that the information generated through the preparation of the previous NLWP is a useful starting point from which to develop the new plan. What is needed now is a completely fresh approach. My comments are set out below under the headings you have identified.
Content of the local waste plan: The plan should provide for an incremental strategy of smaller plants eg building as and when needed, instead of the previous proposal which was to build three large plants up front. The weakness of that plan was evidenced by the announcement in December last year that there was no longer a need for one of the planned MBTs. The Plan must allow for the fast changing and improving technological advances in dealing with waste. An incremental strategy would allow for that and would avoid the risk of wasted public funds.
Attitudes to waste have changed radically. Waste is now regarded as a store of resources for re-use. Although the waste hierarchy was mentioned in the previous Plan, it did not appear to be central to it. The waste hierarchy should be the main driver of the plan, ie reduce (Prevention), reuse (repairing, refurbishing, etc for reuse), recycle (turning waste into new a substance eg composting), recovery (eg anaerobic digestion, incineration/energy recovery, gasification and pyrolysis which produce energy) and only as a last resort, disposal.
All waste management should aim at moving further up ‘the hierarchy’. If properly implemented this should reduce residual waste and therefore the need for new residual waste disposal sites. Current indicators are that recycling targets will rise from 50% to 70%. Rigorous reassessment of the waste projections should therefore be undertaken and critically reviewed throughout the development of the plan.
The plan period should be realistic and clear. It is unrealistic to forecast too far into the future and certainly not for a period of 30 – 40 years. The plan should not reach conclusions about anything beyond the end of the plan period. While it is necessary to take into account the North London Waste Authority’s (NLWA) needs, these should not have the over riding influence that was all too obvious in the previous plan. It is for the seven North London Councils to decide how they wish to manage all of their waste, (including residual waste, which they are obliged to send to the NLWA for onward disposal). It is for them to decide what waste policies they wish to adopt (including policies on location of waste sites). The Councils’ waste plan should drive the NLWA’s arrangements for waste disposal and identification of sites, not the other way around.
The need for new waste facilities.
Existing designated waste sites and waste transfer sites should be protected, and every effort made to reorientate or intensify their use. The plan should identify which of the existing sites are suitable for reorienting or intensification. Residents would welcome improvements and upgrades to badly managed, and unsightly existing sites and the Plan should encourage that.
Consideration should be given to the potential use of spare MBT capacity in the UK , Germany and Holland , before developing new sites in London . Eunomia’s ‘Residual Waste Infrastructure Review’ published in 2012 found that overall in the UK there is existing spare capacity (not including sites with planning consent waiting to be constructed). Some London waste companies have already begun to send waste to plants in Holland (using water and rail transport to do so).
New un-designated waste sites should only be considered for inclusion in the plan as a last resort and should be required to have direct access to suitable rail and/or water connections, ie, adjacent to the site itself. New undesignated sites should only be included if the relevant borough has decided, at Cabinet level that it is potentially suitable for waste use, after consideration of a report setting out all relevant information about the proposed site, its surrounds and the impact of doing so on the borough’s other planning policies. This should be done in a transparent way, with proper local consultation, so that concerns and objections can be dealt with at an early stage in the plan process.
The ‘sequential test’ for sites should be expanded to include an additional test ie that it can be demonstrated that there is no spare capacity within a radius of xx miles from the proposed new site. The policy should be clear that the sequential test will be strictly applied.
The characteristics of a site suitable for waste use
Green sites, eg open spaces and sites with ecological value should not be included in the Plan. These should be considered “showstoppers”. For example, Pinkham Way is totally unsuitable for waste use. This site has regenerated into a valuable site of importance for nature conservation over the past 50 years (SINC No 1 Borough Importance). It shares a boundary with Hollickwood Park – another valuable SINC and with Muswell Hill Golf course which is designated Metropolitan Open Land – a suite of three valuable open spaces in the borough of Haringey. It would be hard to think of a more unsuitable site in North London . The London Plan definition of brownfield land or previously developed land (PDL) excludes land like Pinkham Way . The policy makers positively excluded it because they recognised not only the rare biodiversity value of such sites, but that these sites could only be transformed by nature doing its job over a long period.
It is unacceptable to carry over the previous scoring system given the significant number of objectors who identified major defects and inconsistencies in that scoring system. There needs to be a radical review of the scoring. The criteria for a particular score must be clear and scoring must be transparent, consistent, and with no double counting, no ‘marking up’. Negative scores should not be marked as positives. All scores given, and all changes to scores, should be justified and formally recorded and a proper audit trail should be kept so that it is possible to quickly identify the origin and reason for any particular score on any site. Most importantly, scoring should NOT be a desk exercise. All potential new sites must be subjected to a personal, on site physical assessment of the site itself by the evaluating officer/consultant, including of all the surrounding environs and full notes should be recorded for later reference.
Proposals for waste sites
The London Plan identifies existing waste management sites and designated Preferred Industrial Locations as being particularly suitable for waste management and recycling. It envisages that land in strategic industrial locations will provide the major opportunities for locating waste treatment facilities but recognizes that some boroughs may have to look at locally significant industrial sites as well. Annex 3 of The London Plan lists nine strategic industrial locations within the seven North London boroughs. Is it not possible to find a space within one of those for any new waste sites that might be needed?
Policy NLWP 1 is about safeguarding and protecting existing sites. It should not include the new sites identified in Schedule C.
Schedule C sites should have a separate policy. The Policy should be clear that before sites in Schedule C can be developed, a strong case must be put showing it is absolutely necessary. Schedule C should be considered “the Schedule of last resort”. Perhaps Policy NLWP 2 could be used as a basis for an additional policy for new sites.
Any policy for new sites should require a developer to demonstrate that a) there is a demonstrable need for a new site, and b) no suitable sites are available in Schedules A and B. This new policy should also have an additional test, eg that there is no existing spare waste capacity within xx radius of the proposed new site. This would give a clear message that new sites should be taken as a very last resort.
Policy NLWP 4 should include some reference to health conditions and impacts
I hope this is helpful