Surrey Waste Local Plan

Issues & Options Consultation

Background

Surrey County Council is the Waste Planning Authority [WPA] for all local authorities in Surrey. The Surrey Waste Local Plan is being reviewed for the first time in 10 years and is proposed to set domestic and commercial waste disposal policy for 15 years, beginning 2018.

The county council sought responses to this first round of consultation "Issues & Options" over a period of 6 weeks ending 25 November 2016.

The Surrey Waste Plan includes proposals for waste site location and selection criteria, including greenfield sites and potential use of the Green Belt. 

Responses were invited by completion of a structured questionnaire, either on-line or in paper version. Guildford Greenbelt Group submitted our response to engage, at this stage, with proposed policies and options that appear to threaten the Green Belt in Surrey and put forward recommendations on the addition and/or removal of proposed policy options to attenuate the potential impact of future growth in waste sites in Surrey's Green Belt.

The following pages show the questionnaire and the GGG responses. Where questions involved non-Green Belt issues we responded "Neither".


Introduction

The Issues & Options stage is the first formal consultation in the process of preparing the Surrey Waste Local Plan (SWLP) that will cover the period 2018 to 2033. The Plan will include policies which set out how and where waste management can take place in Surrey in the future. Among other things, these policies will identify sites which are suitable for hosting waste management facilities.

This stage sets out the context for the new SWLP and identifies issues affecting the future management of waste which the Plan needs to address and options for addressing these issues. The Issues & Options Consultation Report proposes a draft vision and draft objectives and describes options for planning for waste management in Surrey to 2033.

All documents associated with the Issues and Options Consultation are available on the Surrey CC Planning Policy website (http://www.surreycc.gov.uk/environment-housing-and-planning/minerals-and-wastepolicies-and-plans). These documents are as follows:

This document is intended to help stakeholders respond to the consultation by setting out the specific questions we would like stakeholders to consider.


Section 1 Introduction (pp. 7 – 10 of Issues and Options Consultation Report)

Surrey County Council as the Waste Planning Authority (WPA) has to comply with specific requirements in the Town and Country Planning (Local Planning) (England) Regulations.

1a). Do you feel that the process that we are proposing to prepare the Plan (as set out in the Surrey Local Development Scheme) will meet these requirements? Yes 
No  

 

1b). If not, why not?
 No comment submitted

Section 2 Context (pp. 11 – 14 of Issues and Options Consultation Report)

2). Do you have any comments on the context we have set out for the preparation of a new SWLP?

 GGG appreciate the comprehensive documentation outlining the protected landscapes and biodiversity at large in the county of Surrey. We welcome the assertion in the Draft Vision that “Surrey County Council seeks to enhance and protect these features” i.e. landscape, heritage and biodiversity assets. The role of planning legislation and guidance for waste management is both restrictive but enabling and this is made clear in the supporting documentation.

However, the evidence of the waste volumes data Table at 2.1.6 page 12 suggests there is a major problem for the Surrey CC with C&I and CD&E waste volumes in general and untreatable waste in particular, with 26% going to landfill but more importantly 34.4% being transferred out of the Surrey area to other WDAs. In all, this represents 60% of all Surrey's waste.

GGG does not believe Surrey CC has the financial resource base neither now nor into the foreseeable future to address the capacity needs within the county this implies for this volume of waste to be either reused, recycled or composted or used in energy recovery facilities.

In addition, Background Paper 4 Capacity, illustrates the uncertainty surrounding these figures as waste data recording and consolidation is a best incomplete and at worst incoherent. There is also the question of continuing imports of waste from adjacent WDAs and the continuing need to maintain relationships with the multiple recipient local authorities of Surrey's exported waste.


Section 3 Issues (pp. 15 – 17 of Issues and Options Consultation Report)

3a). Do you agree that we have identified the key issues affecting the way in which waste is managed in the future in Surrey which we should consider as part of the preparation of a new SWLP?
Issue (section no.)

Strongly
disagree

Slightly
disagree
Neither Slightly
agree
Strongly
agree
Future growth of homes and businesses (3.2)
Transport infrastructure (3.3)
Environmental Protection (3.4)
Institutional and responsibility issues (3.5)
Resource value of waste and closing the loop (3.6)

 

3b). Do you have any comments on the issues?

Future Growth of Homes & Businesses

Surrey CC is the recipient of information from emerging or approved Local Plans from its constituent local authorities and has included them unquestioning into its Surrey Infrastructure Study. Also the report repeats without question the mantra of growth, presenting numerical estimates as if they are immutable. This is not an appropriate approach to policy formation and too rigid a presentation in which GGG to express confidence.

In the case of Guildford Borough Council, the draft Guildford Local Plan Regulation 19 consultation has received 32,000 comments. In the light of this public response, the council has announced a further Regulation 19 consultation in 2017 and the council leader has suggested some strategic sites may be removed, thus reducing the infrastructure burden. Surrey CC is beholden to take account of any changes in developing the SWLP.

GGG would like to see a better analysis and presentation of the uncertainties in Section 3.2 that makes allowance for a "maximum", "most likely" and "minimum" estimate of new homes and businesses across the county that is then used as the basis for a spread of estimates of waste growth and how this will be translated into a flexible waste plan with an associated site selection and location hierarchy.

 

3c). What other issues which might affect the future management of waste in Surrey do you think are important for Surrey County Council to consider in preparing the new SWLP?
 No comments submitted

Section 4 Vision, Objectives (pp. 18 – 19 of Issues and Options Consultation Report)

4a). Do you agree the draft vision for the SWLP 2018 – 2033 is:
  Strongly disagree Slightly disagree Neither Slightly agree Strongly agree
Positive
Ambitious
Achievable

 

4b). Do you have any comments about the draft vision?
GGG doubts that the aspiration to have no landfill waste within Surrey will be achieved. Surrey is an affluent county that, as the evidence of the Surrey Nature Partnership presents so dramatically, consumes resources at a rate equivalent to 3 Earth planets. Unless there is major economic recession in the plan period 2018-2033 that impacts the affluent residents of the county significantly, their consumption patterns are unlikely to change. The Vision totally ignores the potential influence of alternative negative economic futures, trying to present the best of all possible outcomes in the best of all possible worlds.

 

5a). Do you think the proposed draft objectives will help Surrey County Council implement the draft vision? Yes 
No  

 

5b). Do you have any comments about the draft objectives proposed in the SWLP (also set out in Section 5 below)?
 No comments submitted

 

6a). Do you agree with the proposed 15 year plan period for the SWLP 2018 – 2033? Yes 
No   

 

6b). If not, what period you think the plan should cover?
GGG is concerned at the mismatch between the SWLP time period 2018-2033 and the Local Plan periods of its constituent local authorities. Also the fact that local authorities will be encouraged to review their Local Plans at least every 5 years in order to bring forward more land in the 5-year rolling site availability requirement plus its associated housing will inject stresses into the SWLP that cannot be anticipated. Therefore, as a minimum GGG would suggest breaking the current 15 year plan period into three sub plans 2018-2023, 2023-2028 and 2028-2033, each with annual reviews, to provide a more flexible planning vehicle, rather than a one-time straight jacket that will be out of date 6 months after publication (see 2008 Surrey Waste Plan as example of a time-expired document).

Section 5 Options (pp. 20 – 23 of Issues and Options Consultation Report)

Question 7: Do you agree with any of the proposed options for the delivery of the draft objectives?

7a). Objective 1: To increase the sustainable management of waste through waste prevention, re-use, recycling and recovery.
  Strongly disagree Slightly disagree Neither Slightly agree Strongly agree
1A: Work with our stakeholders to support initiatives that help meet local targets for prevention, re-use, recycling and recovery.
1B: Prioritise development of facilities which allow management of waste further up the waste hierarchy e.g. recycling preferred over recovery.
1C: Reduce the waste we send to landfill by encouraging other types of facilities, but recognising that landfill is a last resort and one which we will still need to plan for.
1D: Eliminate landfill entirely from Surrey over the plan period.

 

7b). Objective 2: To encourage communities and businesses to take responsibility for their own waste.
  Strongly disagree Slightly disagree Neither Slightly agree Strongly agree
2A: Work with our stakeholders to support initiatives that help meet local targets for prevention, re-use recycling and recovery. (N.B. This is the same as option 1A)
2B: Promote the management of waste in locations near to communities and businesses.

 

7c). Objective 3: To ensure new waste management facilities are developed in suitable locations.
  Strongly disagree Slightly disagree Neither Slightly agree Strongly agree
3A: Generally identify suitable specific sites to meet the predicted need for new waste management facilities.
3B: Generally identify ‘preferred areas’ to meet the predicted need for new waste management facilities.
3C: Identify sites or preferred areas alongside, or within, sites identified for other forms of development in district or borough local plans, to ensure a joined-up approach.
3D: Enable waste to be managed at one of the nearest appropriate locations by locating facilities as close as possible to key population centres and identified opportunities for growth, such as new settlements or major urban extensions.
3E: Mitigate impacts to communities by identifying site allocations which promote sustainable methods of transport and minimise travel distances on road networks.

 

7d). Objective 4: To make best use of land when managing waste.
  Strongly disagree Slightly disagree Neither Slightly agree Strongly agree
4A: Provide enough waste management facilities to deal with the equivalent amount of waste generated in the county.
4B: Provide additional facilities needed to deal only with waste produced in Surrey.
4C: Give priority to previously developed land (PDL) including sites identified for employment uses, and redundant agricultural and forestry buildings and their environs when looking for sites and area.
4D: Allow development on Greenfield sites.
4E: In recognition of the shortage of development opportunities identify sites or preferred areas which are within the Greenbelt.
4F: Promote the co-location of waste facilities within areas of non-waste development where appropriate e.g. industrial estates.
4G: Identify opportunities to improve and enhance existing waste management facilities.
4H: Safeguard all existing waste management facilities.
4I: Safeguard only those waste management facilities in locations which are consistent with the vision and objectives of the Plan.

 

7e). Objective 5: To maximise the economic benefits of waste management.
  Strongly disagree Slightly disagree Neither Slightly agree Strongly agree
5A: Support the development of sites which capture economic benefits from waste by creating new jobs and/or contributing to local Gross Value Added.
5B: Encourage new development to reuse and recycle the waste generated from construction and demolition activities.
5C: Encourage the use of materials made from recycled waste in new development.

 

7f). Objective 6: To encourage innovation and new technologies which provide opportunities to minimise the impact of waste development on communities and businesses.
  Strongly disagree Slightly disagree Neither Slightly agree Strongly agree
6A: Ensure new waste facilities are well designed, well constructed and well operated to reduce potential adverse effects on human health and the environment.

 

7g). Objective 7: To support the reduction of greenhouse gas emissions through sustainable management of waste.
  Strongly disagree Slightly disagree Neither Slightly agree Strongly agree
7A: Minimise the need for waste transport by locating new waste facilities in proximity to population centres.
7B: Minimise the need for waste transport by identifying and/or safeguarding sites for facilities which are needed to allow transport of waste by means other than road i.e. rail and water.
7C: Encourage the generation of energy whereby waste is used as a fuel.

 

7h). Do you have any comments about the options for achieving the draft objectives? (Including views on whether they are realistic). Do you have any additional options you would like Surrey County Council to consider?

Objective 3

Option 3B states “preferred areas” for new waste management facilities without defining what that means. What areas and where? GGG would recommend a map that makes clear where such areas would be to better inform public response to the consultation.

We propose that the term "preferred areas" be better defined and a set of criteria developed to enable more precise site selection rather than be left to the whim of a planning officer or by an applicant when putting forward a planning application at a specific location.

We propose that should it be the intention to establish zoning within constituent local authorities for waste management facilities then “preferred areas” should be explored under the Duty to Co-operate and laid out in the Regulation 18 draft SWLP for consultation in table and map form to provide consultees with a firm spatial recognition of preferred waste locations.

We are aware of the conflict between planning permission for a site and the approval of vehicle Operator Licences of site operators by the Traffic Commissioners.

We are aware of waste sites in Guildford Borough where the operator main business location is at a different remote location and who’s O Licences may be allocated to a further different location.

We propose a new Option 3F as follows;

“Enable communities where waste site allocations are made as having been judged a “suitable location” to access a central set of records for each new and existing site to be maintained by Surrey CC Waste management team that bring together the records for each site’s planning permission (both SCC record and local authority record), Environment Agency waste licence (where appropriate), Surrey CC waste licence, site operator O Licences”

Objective 4

We are disappointed that in spite of the large amount of environmental information provided as background to prove the extent of Surrey’s environmental status and the large extent of protected landscapes, that Options 4D and 4E respectively contain a bald reference to identifying and developing waste sites either on “Greenfield sites” (4D) or “within the Green Belt” (4E). This appears to be in contradiction to the Draft Vision 5.1.2 that asserts “Surrey County Council seeks to enhance and protect these features” i.e. landscape, heritage and biodiversity assets.

We propose the removal of Option 4D and Option 4E as waste sites represent best use of neither agricultural land nor Green Belt land.

NPPF Para 87 requires any development in the Green Belt to prove “very special circumstances”. This objective provides no explanation in the Options as to the SCC criteria and process required to define an objective definition of such “very special circumstances” that would lead to a site’s acceptance or rejection in the selection process in advance of being proposed in a formal planning application.

NPPF Para 116 also requires any allocation of land for development within the Green Belt that would cause a re-drawing of the Green Belt boundary requires “exceptional circumstances” to be brought forward. This objective provides no explanation in the Options as to the SCC criteria and process required to define an objective definition of such “exceptional circumstances” that would lead to a site’s acceptance or rejection in the selection process in advance of being proposed in a formal planning application.

We propose that this objective contains criteria that define the “very special circumstances” and “exceptional circumstances” required in planning law that would lead to a site’s acceptance or rejection in the selection process are developed in order to give certainty to the site selection procedure.

Objective 4C proposes the use of redundant agricultural and/or forestry buildings and their environs. We believe this to be a ‘Trojan Horse’ that would permit development of waste sites not only in the Green Belt but also in protected landscapes such as AGLV and Surrey Hills AONB. The background evidence presented asserts at its beginning that Surrey is the most wooded county in the country and while understanding what this might imply, any objective that seeks to develop waste sites in such protected landscapes should be clearly stated and not hidden.

We propose that the additional words “excluding protected landscapes such as AGLV and Surrey Hills AONB” should be added to Objective 4C to make this clear.

We oppose any “safeguarding” of land (NPPF Para 85) in advance as it leads to ‘blight’ and deterioration. Any “Greenfield” site should be available for its current economic use up until such time as a planning application is submitted.

We propose the removal of Option 4I

Objective 5

Waste sites inevitably generate Large Goods Vehicle movements. Many waste sites are located remote from urban areas in the countryside, sometimes in the vicinity of small villages, and consequentially generate LGV traffic movements in unsuitable minor roads, leading to a physical deterioration of the road surface and verges, presenting traffic hazards where previously there were none, endangering local residents who walk or cycle on the roads where there are no footpaths or cycle lanes.

The associated costs of road infrastructure and subterranean services damage are unallocated to the costs of running the site and would attenuate the economic benefits of waste management; they are not borne by the operator but by the SCC Highways budget and are therefore not taken into account in any gross GVA justification and become a ‘hidden cost’ borne by Surrey’s council tax payers.

We propose that Option 5A should specifically recognise SCC Highways total road maintenance and repair costs generated in the vicinity of existing and new waste site location due to the associated LGV traffic movements, allocating them proportionately on a site tonnage handled basis, in order to produce a more realistic appraisal of GVA by including the cost to the community of local infrastructure damage.

Objective 6

Experience tells us that in practice this aspirational Option 6A is rarely achieved. We are aware of examples of licensed waste sites in Guildford Borough whose approach to planning regulations is cavalier. We are also aware that due to cut-backs in the waste planning team, temporary planning permissions that expire are not dealt with in a timely manner, leading to breaches of planning permissions.

We propose that a new Option 6B is added to include a requirement as follows:

“Ensure new waste facilities conform to appropriate waste planning regulations and planning law and preclude the implementation of novel technologies that might pose a hazard to human health and the environment.”

 

8a). Do you agree with the approach set out in the Assessment of Suitable Land Scoping Statement for identifying suitable sites? Yes 
No  

 

8b). If not, why not? What alternative approach would you like Surrey County Council to consider?

GGG have considerable reservations regarding the Draft Site Selection Criteria set out in Backgound Paper 2, Land Suitability, Appendix 2 (2016-08-17). Our comments are as follows:

c) Landscape & Visual Impacts

We are disappointed that neither areas identified as “National Parks & Areas of Outstanding Natural Beauty (AONB)” nor areas defined as “Area of Great Landscape Value” are given a Primary Criterion.

We propose that, as AONB has equivalent status to National Parks, new locations (not just extensions to existing locations) within the Surrey Hills AONB should be “not considered” is allocated as a Primary Criterion. In addition, due to the stress given in the supporting documentation to AGLV being an important buffer zone around AONB that they too should be ”not considered” for new locations as a Primary Criterion. Their importance to Surrey’s leisure industry and its claimed GVA as a “go to” visitor destination within the South East and further afield for walking, cycling and beautiful countryside, that any new waste location inserted into such a protected landscape is to the county’s economic detriment.

d) Nature Conservation

It is disingenuous to not allocate a Primary Criterion to “Protected Species” and “Local Non-Statutory Nature Conservation Designations”. The evidence in the presented supporting documentation recognises SPA and Ramsar sites that in Surrey’s case host endangered Nightjar and Dartford Warbler populations; SNCI is a UK-wide conservation designation recognised by Natural England.

We propose that in both cases the Secondary Criterion is promoted to become the Primary Criterion in order to provide maximum protection for wildlife corridors so important to bird and other protected species.

g) Air Emissions, including Dust

We observe that simply evaluating sites on a case by case basis where within or located adjacent to an AQMA is not good enough. It is currently estimated using the Birkett Index that Surrey deaths attributable to human made air pollution stands at 5.2% of the county population, above the average for the whole of England.

The same index shows Surrey air pollution at 11.4ug/m3 total PM2.5, a level greater than for the whole of England (11.1) and other surrounding local authorities.

Currently, Guildford Borough Council is failing to measure air pollution appropriately and has yet to make a decision as to whether to implement an AQMA at any locations in the borough. Therefore it seems appropriate based on experience in GBC to include a parameter that is not dependent upon an AQMA being present.

There are new technologies and remote monitoring devices and services (e.g. CleanSpace) that could be implemented easily at each waste site by the Surrey Waste Management team to track air pollution.

We propose an additional third Selection Criteria for Air Emissions as “CleanSpace air quality monitoring”

l) Potential Land Use Conflict

GGG is astonished that there is no Primary Criterion for Green Belt land.

We propose that the Secondary Criterion "Sites outside of the Greenbelt will be preferred" is promoted to be the Primary Criterion.

 

9a). Do you have a site that you would like to be considered for inclusion in the SWLP 2018 – 2033? Yes 
No  

 

9b). If so, have you completed a site nomination form? Available at: http://www.surreycc.gov.uk/__data/assets/pdf_file/0018/98010/2016-08-11-Land-Nomination-Form.pdf

Yes 
No  

 

10a). Do you have any comments regarding the Duty to Cooperate (DtC) Scoping Statement?
 No comments submitted

 

10b). Do you consider that the DtC Scoping Statement will help Surrey County Council demonstrate that it has met the DtC? Yes 
No  

 

10c). If not, why not?
 No comments submitted

 


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