Municipal Waste Management Strategies and the Land Use ...data.parliament.uk/DepositedPapers/Files/DEP2008-2779/DEP2008-2… · Municipal Waste Management Strategies and the Land

Municipal Waste Management Strategies and the Land Use Planning

System for Waste in England

A Report to Defra and ODPM

September 2004

Integrated Waste Systems

Municipal Waste Management Strategies and the Land Use Planning System for Waste

Eunomia Research & Consulting and The Open University ii


Eunomia Research & Consulting and The Open University i

Contents ACKNOWLEDGEMENTS.........................................................................................................................................2

1.0 EXECUTIVE SUMMARY ............................................................................................................................3

2.0 INTRODUCTION...........................................................................................................................................9 2.1 BACKGROUND TO THE PROJECT ....................................................................................................................9 2.2 PROJECT COMPONENTS ...............................................................................................................................10

2.2.1 Task 1: Assessment of Current Strategies .............................................................................................10 2.2.2 Task 2: Support Gaps Analysis and Advice...........................................................................................10 2.2.3 Task 3: Feedback to Local Authorities..................................................................................................10 2.2.4 Task 4: Advice on New Guidance ..........................................................................................................11 2.2.5 Task 5: Land Use Planning....................................................................................................................11

2.3 STAKEHOLDER DIALOGUE ..........................................................................................................................11 3.0 OUTCOME OF STRATEGIES REVIEW ................................................................................................12

3.1 DESCRIPTION OF ASSESSMENT METHODOLOGY .........................................................................................13 3.1.1 Summary of Criteria...............................................................................................................................13 3.1.2 Limitations of the Methodology .............................................................................................................16 3.1.3 High Level Analysis Results...................................................................................................................16 3.1.4 Groupings of Secondary Criteria ..........................................................................................................20

3.2 CONCLUSIONS ON REVIEW OF CURRENT STRATEGIES................................................................................22 3.2.1 Objectives and Policies..........................................................................................................................22 3.2.2 Consultation and Partnership................................................................................................................23 3.2.3 Analysis of Performance and Strategic Direction.................................................................................23 3.2.4 Economics ..............................................................................................................................................25 3.2.5 Implementation, Monitoring and Risk ...................................................................................................25 3.2.6 Overall Conclusions on Current Strategy Quality ................................................................................26

4.0 DECISION MAKING TECHNIQUES ......................................................................................................27 4.1 DECISION MAKING FOR STRATEGIES ..........................................................................................................27

4.1.1 Community Engagement ........................................................................................................................29 5.0 STRATEGY DEVELOPMENT SUPPORT NEEDS ...............................................................................30

5.1 THE CAPACITY SHORTAGE..........................................................................................................................31 5.2 TECHNICAL SUPPORT AND THE DISSEMINATION OF GOOD PRACTICE........................................................31

5.2.1 Technical Tools and Practice Guidance................................................................................................32 5.2.2 Dissemination of Current Good Practice..............................................................................................33

6.0 STRATEGIES AND THE LAND USE PLANNING SYSTEM..............................................................34 6.1 INTRODUCTION TO THE WASTE PLANNING SYSTEM...................................................................................34 6.2 POLICY ISSUES.............................................................................................................................................35

6.2.1 BPEO......................................................................................................................................................36 6.2.2 The Waste Management Hierarchy .......................................................................................................39 6.2.3 The Proximity Principle .........................................................................................................................40 6.2.4 Regional Self Sufficiency........................................................................................................................40

6.3 INTEGRATING DEVELOPMENT PLANS AND STRATEGIES.............................................................................41 6.4 WIDER INSTITUTIONAL ARRANGEMENTS ...................................................................................................43

7.0 CONCLUSIONS AND RECOMMENDATIONS.....................................................................................46


Eunomia Research & Consulting and The Open University 2

Acknowledgements This report presents the findings of an extensive process of consultation, research, and analysis, conducted by a project team, consisting of:

Joe Papineschi, Eunomia Research and Consulting Dr Christine Thomas, the Open University Integrated Waste Systems Dr Dominic Hogg, Eunomia Research and Consulting Mark Yoxon, the Open University Duncan Wilson, Eunomia Research and Consulting James Fulford, Eunomia Research and Consulting Sarah Gray, Eunomia Research and Consulting Sam Reeve, Network Recycling

We would like to thank the following organisations for their contributions to the project:

Bath and North East Somerset Council Surrey County Council Bolton MBC Warwickshire County Council Cambridgeshire County Council Wigan MBC Doncaster MBC Wolverhampton MBC Durham County Council The Local Government Association Essex County Council LARAC Gloucestershire County Council Friends of the Earth Greater Manchester WDA Greenpeace Halton Borough Council The Composting Association Hampshire County Council The Royal Institution of Chartered Surveyors Kent County Council CI Associates Lancashire County Council TJ Composting Leeds City Council ERM Leicestershire County Council The Environment Agency Lincolnshire County Council Defra London Borough of Bexley ODPM London Borough of Richmond Upon Thames Yorkshire & Humberside Regional Assembly London Borough of Tower Hamlets The University of Birmingham Merseyside WDA Environmental Services Association North Yorkshire County Council Biffa Waste Services Nottingham City Council Brett Waste Management Peterborough City Council Cleanaway Plymouth City Council Cory Environmental Sefton MBC Hampshire Waste Services/Onyx Shropshire County Council SITA UK Somerset County Council Waste Recycling Group

We would also like to take this opportunity to thank the numerous other individuals and organisations that contributed to the project, not least of whom are the 54 Local Authorities who provided us so promptly with their Municipal Waste Management Strategies.



1.0 Executive Summary In March 2001, DETR published Guidance on Municipal Waste Management Strategies, a guidance document on developing non-statutory joint strategies for waste management for all English waste authorities. The passing of the Waste and Emissions Trading Act into law in November 2002 enshrined the duty to produce a Municipal Waste Management Strategy into statute for most two-tier waste authority areas, in line with the Government’s intention expressed in Waste Strategy 2000.

In September 1999, DETR published PPG 10, the first ‘waste specific’ planning policy guidance document. PPG 10 provides a framework for waste management planning and decision making. In May 2001 the Office of the Deputy Prime Minister (ODPM) took over responsibility for planning and within the scope of the current reform of the land use planning system expressed primarily through the Planning and Compulsory Purchase Act 2004, ODPM is currently considering a revision of PPG 10 (which will become Planning Policy Statement 10 or PPS 10), taking account of wider reform of the planning system and developments in waste management since 1999, in particular Waste Strategy 2000.

In November 2002, the Prime Minister’s Strategy Unit published its report Waste Not, Want Not into waste management in England. It highlighted barriers to implementation of sustainable waste management with particular regard to compliance with the Landfill Directive targets for reducing the landfilling of biodegradable municipal waste and made a series of recommendations to Government in terms of action that should be taken. In May 2003, the Government’s response to the report committed resources to implementing its recommendations, in part through the establishment of the Waste Implementation Programme (WIP). It also committed to the joint revision of PPG 10 by ODPM and Defra, in response to the report’s recommendations on overcoming barriers relating to the land use planning system.

These developments led directly to the commissioning of this project. Eunomia Research and Consulting and The Open University’s Integrated Waste Systems were appointed by WIP in October 2003 to carry out a review of English Local Authority Municipal Waste Management Strategies (MWMSs). As initially conceived, the project would entail the evaluation, against an agreed set of criteria, of all existing MWMSs for upper tier waste authority and a number of Unitary Authority areas in England; the consideration of land use planning issues in the context of MWMSs, especially in terms of consistency of Strategies with waste Development Plans; the provision of a ‘support needs analysis’ based on our assessment of Strategies; the provision of feedback to all strategy areas subject to review; and the provision of recommendations for new Guidance on Municipal Waste Management Strategies. Subsequently, in January 2004, the scope of the project was extended, through a joint Defra/ODPM commission, to cover the development of potential options for ensuring greater integration between the municipal waste management and waste planning functions within the various tiers of government.

This report describes the processes undertaken in each of the key project tasks and summarises the key findings, conclusions and recommendations arising from them. A key feature of our approach to the project has been to involve stakeholders throughout. In particular, Local Authority practitioners from both waste management and planning departments were engaged through a series of workshops. Other stakeholders, including representatives of the waste management industry, Regional Planning Bodies, NGOs, Government departments and agencies, academics and consultancies were involved through round table meetings, on-to-one meetings and telephone interviews. A final multi-stakeholder workshop was held in May which brought together representatives of all of these groups to consider the findings of the project. The views of stakeholders, especially where a significant degree of consensus was identified, have substantially influenced our conclusions and stakeholder views are referred to throughout the report. Appendix 1 provides further detail of the specific stakeholder events and consultations undertaken.



A number of broad conclusions can usefully be drawn from the stakeholder dialogue processes undertaken. In particular, broad consensus appears to exist across professions and sectors regarding the following issues:

• That the provision of frameworks for better, more robust, but simpler and speedier decision making are a prerequisite for implementation of facilities and services at the scale required to meet Government aspirations for landfill diversion;

• That such frameworks must be based on and supported by clearer policy principles and practice guidance and that stronger leadership is required at all tiers of Government; and

• That the focus of national and local Government on municipal (and principally household) waste fails to reflect the operational and economic realities of waste management systems and thereby increases the risk of failure to attain objectives for those very waste streams.

Section 3 of the report describes the outcome of our review of existing Municipal Waste Management Strategies (MWMSs). The section considers both the extent to which current Strategies appear to conform to the existing Government Guidance and the ‘quality’ of Strategies when scored against the detailed set of criteria developed by the project team in consultation with Local Authority practitioners (described in Section 3.1). In summary, we found that almost all current Strategies serve an important purpose as high-level strategic documents. However, whilst they are generally strong on establishing the ‘ultimate destination’ of waste management services and gathering some of the tools needed to get there, they often fail to provide a complete route map. It is our view that the next stage in strategy development practice will need to focus on the operationalisation of these high-level plans, both in terms of delivering technically robust route maps based on sound analysis and of providing compelling business cases for investment that are capable of delivering commitment from Members and Chief Financial Officers. In particular, the next generation of Strategies will need to:

• Be based upon more sophisticated technical analysis, with the service development plans of all partner Authorities more fully represented;

• Be founded on assumptions which can be defended, and critical analysis of current performance and the drivers of improved future performance, so that robust, best value plans that can be sold to Members, senior managers and the public;

• Take more account of cost and wider economic issues, and really drive home what will increasingly become undeniable business cases for investment;

• Show appreciation that the strategy process is a living one, and that the dynamics of this process have to be recognised through plans for periodic and ongoing review so as to understand performance against targets and aspirations, and so as to anticipate, and adapt to, new circumstances; and

• Involve the community more, at more stages, to minimise the risks to deliverability associated with, in particular, the development of controversial waste management facilities and lack of public engagement in new services.

In Section 4, decision making techniques, particularly in the context of Municipal Waste Management Strategy development, are considered. Our review of Strategies has revealed that, at the high level, virtually all, whatever the method of evaluation, and whatever the level of detail on implementation, are based around the waste management hierarchy. It is our view that the hierarchy provides a simple yet robust framework for strategy development and tends to result in Strategies that are well aligned with political and community aspirations, provided that its weaknesses are addressed.



Factors such as time dynamics (i.e. the need for strategies to embody flexibility over time) and the sensitivity of conclusions reached to particular fundamental assumptions should also feature in the decision making process. On time dynamics, Section 4.2 offers a conceptual diagram that provides a useful illustration of an approach to ensuring adequate flexibility.

On sensitivity to key variables, Strategies should employ sensitivity analysis combined with Strategy review procedures designed to allow action to be taken before the Strategy is rendered ‘out of date’ by events in the real world. Ideally, contingency planning should be a feature of the Strategy process and we would recommend the use of separate ‘action plans’ along side ‘high level strategies’ that could be updated based on actual performance. Utilising such a structure should allow the ‘high level’ element of Strategies to be retained in all but the most extreme circumstances, preventing the need for frequent large scale revision. Revision of the ‘high level’ element might then only be triggered at the point that the ‘action plan’ has diverged from it to such an extent that it no longer provides a viable framework for it. For those areas subject to the statutory duty under the WET Act, the provision to Government of a new statement of the Strategy might then only be required at the point when the entire Strategy is materially changed.

It is our view that consultation and community engagement at various stages in the Strategy process is essential to supporting decision making processes. Local Authorities should be provided with guidance on what approaches are likely to be effective (based on evidence, which is starting to become available) and that they are supported by policy which facilitates a sense of security in involving members of the public in strategy development. Based on the findings of our research and consultation within this project, it is our view that practice guidance should cover:

• The use of ‘Waste Forums’ which bring together elected Members from across parties and Strategy areas along side representatives of local environmental and community organisations to ‘verify’ and provide a ‘sounding board’ for the Strategy process;

• The use of genuinely representative groups of local citizens at different stages in the process, though various methods potentially including focus groups, citizen’s juries, community advisory groups and consensus conferences or panels. It is through these methods that Members can best be inspired with the confidence to consult with the public at large, especially if results of detailed consultation with genuinely representative samples of the community form part of the material through which mass consultation is facilitated; and

• The involvement of the waste industry at an early stage in the Strategy development process, as the deliverability of Strategies will generally be dependent on the market viability of proposals considered. This should be an essential element of the test for ‘practicability’ and might take the form of a focus group, a soft market test or a ‘sense check’ based on a written summary of a draft Strategy; and

A further issue relating to the role of the waste management industry in Strategy development (raised as a concern by both industry and Local Authority representatives) is the potential for conflict between technically detailed Strategies and increasingly ‘output based’ approaches to procurement. However, it is our view that adequate technical Strategy development, provided industry input is considered, forms an essential part of setting outputs and contract parameters. Local Authority decision makers will need to be well informed of as to what outputs can realistically be delivered within different ranges of cost prior to embarking on output based contracting.

It is our view that although community engagement to this extent has not traditionally formed part of the MWMS process, there is growing evidence that where it has, Strategies have been adopted more quickly, have provided a clearer basis for action and have been better aligned with the realities of implementation through procurement and the planning system.



Section 5 of the report considers support needs that may exist within Local Government if the quality of strategies and their impact on services is to be increased. Perhaps most importantly, it is our view that Government should recognise that, whilst there is widespread practitioner support for better integration of more sophisticated Waste Development Plans and MWMSs, resourcing gaps will need to be filled if such an expectation is to be created. Specifically, we recommend:

• That consideration is given to the resourcing implications of PPS 10, Guidance on Municipal Waste Management Strategies and any accompanying practice guidance and that this consideration includes options for developing increased capacity within both Local Authorities and Regional Planning Bodies to allow these more involved processes to be carried out to timescales that are compatible with Government aspirations for landfill diversion;

• That practice guidance, tools and practical support are provided to assist in improving practise in the areas of performance analysis, waste arisings projection, cost modelling, risk management, residual waste treatment and community engagement thorough the provision of written guidance and by refocusing existing Government funded programmes on the specific needs of Waste Development Plan and MWMS developers;

• That new programmes are developed to assist in the dissemination of best practice in sustainable waste management, covering waste prevention, collection, CA site management and residual waste treatment. A programme of peer review and mentoring, allowing good practice and experience to be shared between Local Authorities should also be initiated, supported by the IDeA, Defra and WRAP; and

• That Defra should dedicate resources to comprehensively collecting and updating information on existing support services and organisations and information sources which should then be provided through a ‘waste information and support signposting portal’ on the WIP Local Authority Support Unit web site.

Section 6 of the report considers issues around the split in functions of waste management and waste planning within Local Government in England. The workshops and wider consultation revealed considerable commitment to, and support for, integrating the Strategy and Waste Development Plan making processes and it is clear that opportunities exist through the provision of updated policy and Guidance from Defra and ODPM in the coming months to encourage such integration. It is our view, therefore, that PPS 10 and Guidance on Municipal Waste Management Strategies should create an expectation that, where possible, the MWMS should form a Supplementary Planning Document within the Local or Waste Development Framework ‘folder’ (which will replace the current Waste Local Plans and their equivalents), but that this approach should not be mandatory. A broad expectation should also be created that spatial and land use issues should be considered within MWMSs and that the needs of MWMSs in terms of land use should be catered for directly in future Waste Development Plans. We have a number of other recommendations in relation to the planning system for waste and links with the MWMS development process:

• On the difference in scope of MWMSs and Waste Development Plans, MWMSs should continue to be primarily focused on municipal waste, in order to maintain focus on the considerable medium term challenges faced by these services. However, they should have regard to other waste streams not necessarily managed by Local Authorities, especially commercial and industrial wastes. This is because, in our view and that of many of the stakeholders we consulted from all sectors, it is impossible to develop a wholly rational strategy for municipal waste in isolation from other wastes. Opportunities to deliver best value in MSW management services will inevitably be compromised where this is not the case.

• Within the scope of the ongoing reform of the land use planning system, policy on institutional arrangements and the roles of different tiers of Government should retain the principle of decisions and responsibilities being discharged at ‘the most appropriate level’. Detailed strategy



development should not be duplicated between tiers and in the case of Waste Development Plan making and MWMS development, the responsibilities that they entail should continue to be discharged by Local Authorities;

• Opportunities offered by the advent of Regional Spatial Strategies (which will have statutory force and replace Regional Planning Guidance) in terms of facilitating clearer leadership and better coordination should be exploited. Whilst freedom to develop detailed strategy must be retained at the local level, it is essential that local decision makers are provided with a better framework for rational decision making. In particular, the extent of ‘need’ for waste management capacity should be established at the regional level. The regions should also assume responsibility for planning directly for capacity that is of genuinely regional significance; and

• Perhaps most importantly, the regions should take a greater role in facilitating and ensuring better coordination of work at the local level. A particular need relates to the increasing potential prevalence of techniques such as MBT, which may result in some cases in residual wastes being treated by perhaps three processes on three separate sites, each producing smaller proportions of residua, all of which will require further treatment or disposal. The regions will have a role in insuring that, beyond the need for the requirements for the Landfill Directive to be complied with at a local level, facilities are planned for for the whole life cycle of new waste management systems.

Section 6.2 considers some of the key policy ‘principles’ which are fundamental to strategic decision making in waste management and are given significant legal force through policy documents including PPG 10 and waste Strategy 2000. In response to a need expressed by practitioners from all sectors, we have made the following recommendations:

• On the role of assessment of the Best Practicable Environmental Option (BPEO); the value added by BPEO in the context of the planning system has been widely questioned, especially since the advent of Strategic Environmental Assessment, Sustainability Appraisal and Environmental Impact Assessment. It was the overwhelming view of stakeholders that decision making methodologies (generally) need to be rationalised and become more transparent and better informed by community engagement. In particular the role of, and approach to, BPEO assessment was seen as a critical issue requiring resolution. It is our view that the Life Cycle Assessment (LCA) based approach to whole-system assessment, particularly in the context of spatial planning, is generally inappropriate. The waste management hierarchy, supported by clearer guidance on the application of the proximity principle and self-sufficiency should, when applied with common sense, provide a reasonable basis for Strategy decision making. Such analyses (when accompanied by adequate cost modelling and sensitivity analysis), in the context of Municipal Waste Management Strategies, would appear to comply with the accepted definition of BPEO and the assessment approach outlined in Part 2 of Waste Strategy 2000. It is our view, therefore, that there should no longer be a direct role for the assessment of the BPEO within the land use planning system for waste. Rather, the principles of the waste management hierarchy, the proximity principle and self sufficiency should be applied with common sense in the context of these other assessment regimes, having regard to any BPEO assessment carried out within the MWMS development process. Appropriate interpretation of BPEO should be clarified through policy, placing greater emphasis on the need for time dynamics to be considered and less emphasis on the need to identify a single ‘best’ solution in both the short and long term. The role of LCA in BPEO assessment should also be revised; rather than being the ‘recommended’ approach to whole system assessment, it should form one of a suite of methodologies, with greater emphasis being placed on the need to base assessment on operational realities and to avoid more abstract analysis;



• On the application of the waste management hierarchy; it is our view that the hierarchy provides a simple yet robust framework for strategy development and tends to result in Strategies that are well aligned with political and community aspirations. Essentially, it is our view that the hierarchy should be used to determine what action should be taken in terms of targeting different waste streams or materials for minimisation, reuse, recycling or further recovery, as opposed to being a mechanistic, inflexible ‘rule’. In other words, it should be assumed that the hierarchy is applied, but that the extent to which waste will be able to be realistically dealt with at each tier should be determined through sound analysis. In principle, residues produced by one tier should be dealt with by the next tier down, and tiers should not be ‘skipped’. Where a particular waste stream or material is not to be managed in accordance with the hierarchy, the onus should be on the strategy to demonstrate through sound analysis why this is the case, through the use of techniques such as cost-benefit analysis or LCA;

• On the application of the proximity principle; It is our view that the proximity principle need only be applied ‘in full’ to operations for waste disposal, as opposed to reuse or recovery. The decision as to whether a particular material should be targeted for recycling or not at any particular point in a strategy timeline would then be the subject of logical cost-benefit analysis, rather than a complex debate related to the proximity of reprocessing facilities relative to other options. This approach is obviously consistent both with the aim of not designing long term plans simply based on the current paradigm (in terms of proximity of recyclate markets) and the fact that recyclate movement is governed by the same global economic forces as primary resources. We also recommend that the position of non-road transportation of waste be clarified in relation to the proximity principle. Waste Strategy 2000 states that alternative modes of transport should be considered and “a longer journey by river or rail may be environmentally preferable to a shorter road journey”. Practice guidance should be provided to assist decision makers in evaluating the relative costs and benefits of non-road transportation methods, in order to facilitate better direct comparison; and

• On regional self sufficiency; We recommend that Government provides clarification as to the relative roles of the proximity principle and regional self sufficiency in decision making, making explicit the primacy of the proximity principle. In other words, regional self sufficiency should become more of a conceptual ‘aspirational’ objective than a specific requirement, but that regional and local decision makers should recognise that it is unacceptable to rely on exporting wastes unless the application of the proximity principle would otherwise be compromised.

Many of the above issues will imply the need for additional resources in the years to come. It is inevitable, however, that new investments are required in order for the UK simply to meet legal obligations, let alone to meet the more encompassing objective of making waste management more sustainable. The resources which are needed are likely to be repaid (albeit not transparently) in improving the value of the investments made, in ensuring that the investment plans proposed are in line with actual requirements for facilities, in improving the value of services procured, in making investment strategies more sensitive to the time profile (improving flexibility to respond to changing circumstances), and in improving the quality of public engagement (so potentially reducing objections to unpopular facilities). There is considerable scope for improving the process of strategy formulation, and opportunities exist to make the development of plans and strategies more rational, and mutually compatible. The prize is a more streamlined and sustainable approach to waste management which has more support from citizens, and which is less burdensome for those seeking to provide facilities and services on the ground.



2.0 Introduction In October 2003 Defra’s Waste Implementation Programme (WIP) Local Government Support Unit appointed Eunomia Research and Consulting and The Open University’s Integrated Waste Systems to carry out a review of English Local Authority Municipal Waste Management Strategies (MWMSs). As initially conceived, the project would entail the evaluation, against an agreed set of criteria, of all existing MWMSs for upper tier waste authority and a number of Unitary Authority areas in England; the consideration of land use planning issues in the context of MWMSs, especially in terms of consistency of Strategies with waste Development Plans; the provision of a ‘support needs analysis’ based on our assessment of Strategies; the provision of feedback to all strategy areas subject to review; and the provision of recommendations for new Guidance on Municipal Waste Management Strategies. Subsequently, in January 2004, further work was added to the project, jointly commissioned by Defra and ODPM, on potential options for ensuring greater integration between the municipal waste management and waste planning functions within the various tiers of government.

2.1 Background to the Project In March 2001, DETR published Guidance on Municipal Waste Management Strategies,1 a guidance document on developing joint strategies for waste management for all English waste authorities. Amongst other things, Annex A of the Guidance published the statutory performance standards for recycling and composting for English waste authorities for the first time. Although the Guidance made clear that preparing Strategies was not a statutory duty, it reiterated Government’s intention, expressed previously in Waste Strategy 2000, to make the preparation of Municipal Waste Management Strategies statutory at some point in the near future. The passing of the Waste and Emissions Trading Act2 (WET Act) into law in November 2003 enshrined this duty into statute, although only for two-tier areas, some of which will be exempted from the duty based on a set of performance criteria. Government has also committed to revising the March 2001 Guidance.

In September 1999, DETR published PPG 10,3 the first ‘waste specific’ planning policy guidance document, following the introduction of the statutory duty to produce separate Waste Local Plans (or equivalents) in 1991. Published months before Waste Strategy 2000, PPG 10 provides a framework for waste management planning and decision making, including guidance on the principle of Best Practicable Environmental Option (BPEO) and the role of Regional Planning Bodies, heralding the development of the Regional Technical Advisory bodies (RTABs). In May 2001 the Office of the Deputy Prime Minister (ODPM) took over responsibility for planning and within the scope of the current reform of the land use planning system expressed primarily through the Planning and Compulsory Purchase Act 2004, ODPM is currently considering a revision of PPG 10 (which will become Planning Policy Statement 10 or PPS 10), taking account of wider reform of the planning system and developments in waste management since 1999, in particular Waste Strategy 2000.

In November 2002, the Prime Minister’s Strategy Unit published its report Waste Not, Want Not4 into waste management in England. It highlighted barriers to implementation of sustainable waste management with particular regard to compliance with the Landfill Directive targets5 for reducing the

1 Guidance on Municipal Waste Management Strategies, DETR March 2001

2 Section 32 of the Waste and Emissions Treading Act 2003

3 Planning Policy Guidance Note 10, DETR September 1999

4 Waste Not, Want Not, Strategy Unit November 2002

5 Particularly those set under Article 5 of the Directive



landfilling of biodegradable municipal waste (BMW) and made a series of recommendations to Government in terms of action that should be taken. In May 2003, the Government’s response to the report committed resources to implementing its recommendations, in part through the establishment of the Waste Implementation Programme (WIP), to be taken forward jointly by Defra and WRAP. It also committed to the joint revision of PPG 10 by ODPM and Defra, in response to the report’s recommendation 32 on barriers within the land use planning system.

These developments led directly to the commissioning of this project. The Local Authority Support Unit, within the Defra arm of WIP, has responsibility for providing direct and indirect support to Local Authorities on municipal waste management and, along with WRAP will provide significant assistance to Authorities as they develop and implement their strategies. As the commissioning body for the project, WIP is primarily interested in gaining a better understanding of the current level of maturity strategic thinking within English waste authorities and this project forms part of their baseline research, as well as providing direct feedback to Authorities on their existing strategies. The project has also informed the joint work of Defra and ODPM officials on the preparation of revised Guidance on Municipal Waste Management Strategies and PPS 10, both of which will be out for consultation later this year.

2.2 Project Components As can be seen from the above, the project has had a wide ranging brief. This section provides a brief summary of the key activities undertaken.

2.2.1 Task 1: Assessment of Current Strategies Task 1 provided the foundation of the project, entailing the assessment of existing MWMSs against a set of criteria developed with Local Authority practitioners and agreed with Defra and ODPM. This work informed the other tasks and provided the basis for our recommendations to Government. The Task entailed the following activities:

• Obtaining MWMSs from all two-tier areas and a sample of Unitary Authorities;

• Initial development of the assessment criteria;

• Holding Local Authority practitioner workshops to refine assessment criteria;

• Conducting a two region pilot of the evaluation methodology;

• Finalising the evaluation methodology; and

• Evaluating the MWMSs from the seven remaining regions.

2.2.2 Task 2: Support Gaps Analysis and Advice Task 2 was concerned with providing WIP with an assessment of the support needs implied by our assessment of Strategies coupled with research into the sources of support currently employed by Local Authorities in developing their MWMSs and entailed:

• Research into and evaluation of the support currently in use and available to Authorities;

• Identifying key strategy process and capacity weakness, based on the findings of Task 1; and

• Conducting a gap analysis based on this work and developing recommendations to Defra.

2.2.3 Task 3: Feedback to Local Authorities Task 3 entailed the supply of feedback to all of the strategy areas subject to assessment in Task 1, with the intention of providing constructive and useful comments to local Authorities based on the findings of their specific assessment. The task involved:



• Developing and agreeing a feedback methodology with Defra, informed by practitioner input;

• Piloting the feedback methodology and amending it as necessary; and

• Providing feedback to the remaining Authorities.

2.2.4 Task 4: Advice on New Guidance Task 4 was concerned with providing the Defra officials responsible for developing the revised Guidance on Municipal Waste Management Strategies with recommendations regarding the content of an approach to new Guidance, informed by the Task 1 assessments. The Task entailed:

• Developing initial recommendations;

• Holding Local Authority practitioner workshops to consider approaches to Guidance; and

• Developing detailed recommendations.

2.2.5 Task 5: Land Use Planning Task 5 included the additional work commissioned in January 2004 on integrating policy and practice in municipal waste management and waste planning and entailed:

• Facilitating interdepartmental Government discussion workshops;

• Carrying out research into barriers to implementation and decision making;

• Holding Local Authority practitioner workshops;

• Holding a waste industry practitioner meeting;

• Consulting with other stakeholders;

• Holding a multi-stakeholder workshop; and

• Analysing and reporting on the findings of research and consultation.

The project was undertaken over several months and the process of providing feedback to Local Authorities on their Strategies is still ongoing. This report constitutes the final report on the findings of the project in the various Tasks outlined above. The following sections describe both the methodologies employed during the project and the key conclusions and recommendations that have emerged from it.

2.3 Stakeholder Dialogue A key feature of the project methodology was the inclusion of stakeholders, in particular Local Authority practitioners (waste management and planning officers) in the formulation of the methodology for assessing Strategies and, perhaps most importantly, in the development of our conclusions and recommendations. A series of workshops were held between December 2003 and May 2004, during which stakeholders were able to inform key stages of the project. Through these events we aimed to ensure maximum practitioner and wider stakeholder ownership of the processes entailed in the project and the conclusions that emerged from them. The main methods of stakeholder engagement were:

• In December 2003, two workshops were held for Local Authority waste management practitioners; one in Manchester and one in Bristol. The primary objective of the workshops was to inform the development of the Strategy assessment criteria and the methodology for providing feedback to Authorities following the assessments;

• In early February 2004, a second round of workshops was held, also in Manchester and Bristol. The Manchester workshop was attended by the same participants as the previous workshop; however, the format was changes slightly for the Bristol workshop, with a roughly equal number of waste managers and waste planners being invited. The broad aim of the second round of



workshops was to help to inform our recommendations to Defra on the revised Guidance on Municipal Waste Management Strategies and to ODPM on integrating the waste planning and waste management service delivery policy frameworks, with, in both cases, a particular emphasis on approaches to decision making.

• In March 2004, a meeting was held in London with senior managers from seven major waste management companies, along with representatives from the Environmental Services Association, the waste industry trade association. The meeting took the form of a round table discussion facilitated by Eunomia and principally considered the issues raised by Local Authority stakeholders at the previous workshops.

• Other Stakeholder Consultation; Between January and June 2004, a range of other stakeholders were consulted on a confidential basis through a combination of face to face meetings and telephone interviews. Consultees included the Environment Agency, the Planning Officer’s Society, NAWDO, LARAC, WRAP, representatives of the RTABs and Regional Planning Bodies, other consultants working in the field and NGOs and campaigning organisations. Evidently, with such a diverse assortment of organisations canvassed, a wide range of views were expressed, all of which have helped to inform the conclusions expressed in this report.

• In May 2004, a final multi-stakeholder workshop was held, bringing together representatives from the stakeholder groups previously consulted to consider the findings, conclusions and recommendations of the project at that time.

Appendix 1 contains a more detailed description of the stakeholder dialogue process and some of the key conclusions of each approach. However, it is useful at this point to highlight that some of the areas which perhaps the clearest consensus emerged across all practitioner sectors were:

• That the provision of frameworks for better, more robust, but simpler and speedier decision making are a prerequisite for implementation of facilities and services at the scale required to meet Government aspirations for landfill diversion;

• That such frameworks must be based on and supported by clearer policy principles and practice guidance and that stronger leadership is required at all tiers of Government; and

• That the focus of national and local Government on municipal (and principally household) waste fails to reflect the operational and economic realities of waste management systems and thereby increases the risk of failure to attain objectives for those very waste streams.

3.0 Outcome of Strategies Review All English upper-tier waste authorities (34 County Councils and six Statutory Joint Waste Disposal Authorities) were contacted between December 2003 and February 2004 with a request to send a copy of their MWMS to Eunomia, along side any supporting documents, appendices, background research/consultancy reports and Waste Local Plans. All but one County Council and two JWDAs provided some sort of strategy, although in some cases this amounted to preliminary research or the report of a BPEO assessment rather than a completed strategy document. The same information was sought from a sample of 26 Unitary Authorities, of whom 18 responded; making a grand total of 55 strategies available for analysis. Strategies ranged in vintage from early 2000 to late 2003, although the vast majority were produced following both Waste Strategy 2000 and the current Guidance on Municipal Waste Management Strategies (published March 2001), as well as PPG10.



3.1 Description of Assessment Methodology The methodology of analysis was developed in consultation with Local Authority waste management practitioners through two stakeholder dialogue workshops held in Bristol and Manchester in December 2003. As a result of these workshops, it was decided that supporting documentation, as well as published strategies, should be taken into account in the analysis, as it became clear that different authorities had aimed their strategy documents at different broad audiences (e.g. some were detailed technical documents intended for primarily internal use, whilst others were much less detailed documents intended for general public consumption). As a primary objective of the project was to assess the technical maturity of strategy processes it was therefore considered essential that all work undertaken in developing strategies should be considered; this approach has had obvious implications in terms of the scale of the task undertaken by the project team in evaluating strategies, with several thousand pages of work eventually being digested and assessed. However, not all Authorities provided ‘full’ documentation and as a result a somewhat incomplete picture has inevitably resulted.

The strategy documentation was assessed against two sets of criteria; ‘positivist’ criteria, which were developed to allow the extent to which strategies followed the guidelines within the 2001 Guidance to be evaluated; and ‘normative’ criteria, which were developed to compare strategies against the project team’s interpretation of the ‘ideal’ MWMS, based on practitioner consultation.

3.1.1 Summary of Criteria

The positivist criteria were split between 24 Primary and 66 Secondary criteria. These criteria were based entirely on the existing Guidance, and as a result, may have effectively included some factors which are (arguably) of limited importance in producing a ‘quality’ strategy, whilst at the same time excluding factors which may be critical to strategy success. It has been widely acknowledged that the current Guidance is far from comprehensive in terms of practice guidance, but it was felt by stakeholders and the project team that measuring the extent to which strategies appeared to follow current Guidance would be of interest in the context of the wider analysis of ‘quality’. The scoring system used is effectively unweighted; in other words, the relative importance of different criteria is not represented in the scoring system. Rather, the system simply allows the extent to which different factors have been considered and included in strategy processes to be understood. Assessors were provided with guidance as to how to interpret strategies with respect to the scoring system. A comparison is made below of the relative ranges of scores against the two sets of criteria, but since the primary aim of the project was to assess the quality of strategies (i.e. using the normative criteria) further detail on the the positivist criteria analysis is consigned to Appendix 3.

The normative criteria are much more complex, as they are intended to allow evaluation of the extent to which different factors affecting strategy quality have been taken into account. 15 Primary, 52 secondary and 359 tertiary criteria were developed which were designed to account for as many as possible of the key factors which an ‘ideal’ MWMS should consider. The primary and secondary criteria are shown in Table 1 below; tertiary criteria are considered later in this report and a detailed analysis against them is presented in Appendix 2.



Table 1 - Normative Criteria

Primary Criteria Secondary Criteria Number of Tertiary Criteria

Performance monitoring 5BACKGROUND Depth of consultation 18Depth of analysis 15Projection methodology 5WASTE ARISINGS PROJECTION Realism of approach 3Data quality 7Quality of analysis 3WASTE COMPOSITION

ASSUMPTIONS Stream coverage 8Refuse collection 5Dry recyclables kerbside 7Biowaste kerbside 8Bring sites 5CA sites 7Bulky waste 5Street cleansing 6Commercial collection 7Composting 5Residual waste treatment and disposal 5

EXISTING SERVICE DESCRIPTIONS

Other streams 5Facility types 9EXISTING AND PLANNED

INFRASTRUCTURE General and key issues 4Existing service costs 6ECONOMICS Future budget pressures 5Capture rates 5Participation rate analysis 7Gap analysis 7

CRITICAL ANALYSIS OF PERFORMANCE OF EXISTING SERVICES

Overall analysis 4LA Partnerships 9PARTNERSHIPS External partnerships 8Objectives 5OBJECTIVES AND CONSTRAINTS Short term issues and constraints 8Analysis of direction 7Understanding of drivers 6BASIC ANALYSIS OF STRATEGIC

DIRECTION Basis for targets and direction 7Minimisation and prevention 5Enforcement 7Collection 7CA Sites 12Awareness and participation 9Markets and materials processing 5

PLANNED INITIATIVES

Treatment and disposal 6Cost and performance 8QUALITY OF ANALYSIS

UNDERPINNING DIRECTION Analysis and realism 10Policies and targets 8Monitoring and Review 9Joint working 4Governance 5Implementation 9

BUILDING BLOCKS FOR IMPLEMENTATION

Commitment 4Facilities 6Planning and permitting 10RISK MANAGEMENT Risk assessment 9

As with the positivist criteria, the normative criteria were unweighted; it was considered to be impossible to determine with objectivity the relative importance of quite incomparable factors in determining the quality of a strategy. The approach has therefore been to attempt to break down the criteria into as comprehensive a list as possible in terms of detailed tertiary criteria, thereby allowing a quantitative analysis of qualitative factors. The approach has essentially been to determine whether a



factor contributing to the quality of analysis of a particular strategically important issue has been considered. Therefore, where possible, tertiary criteria were scored in a range from 0 – 1 points (with 0 meaning that the factor appeared to be absent from the strategy author’s analysis and 1 meaning that it was present).

Table 2 below provides an example of the 15 tertiary criteria for the secondary criterion ‘Projection of future waste arisings - Analysis includes:’ Through this approach, we have attempted to analyse all of the factors which should reasonably be considered in making a projection of future waste arisings, to allow the quality of analysis employed by a strategy author to be assessed quantitative terms.

Table 2 - Example of Tertiary Criteria for Projection of Waste Arisings

Secondary Criteria Tertiary Criteria Score Range

Arisings broken down by WCA? 0-1 Arisings broken down by collection categories? 0-1 Historic data over several years? 0-1 Comments on relationships between categories? 0-1 Attempts to explain large variances? 0-1 Population and household number trends? 0-2 Recognition of trade waste entering HH streams? 0-1 Appreciation of data quality issues? 0-1 Appreciation of limitations of projection? 0-1 Analysis of sources of growth? 0-1 Elaboration on differences between WCAs? 0-1 Cross-border issues at HWRCs? 0-1 Incorporation of waste minimisation assumptions? 0-3 Incorporation of collection system effects assumptions? 0-2

Projection of future waste arisings - A

nalysis includes:

Overall sound basis for projections? 0-2

As can been seen from the example above, it has not always been realistic to design the scoring system to be based exclusively on an analysis of whether a factor is ‘present’ or ‘absent’ (i.e. the 0 – 1 score range outlined above), primarily because this would have resulted in an excessive number of tertiary criteria. So, for example, under the tertiary criterion ‘Incorporation of waste minimisation assumptions’, which has a score range of 0 – 3, a score of 0 means that no waste minimisation assumptions have been incorporated, 1 means that effects have been assumed but specific initiatives not considered, 2 means simple specific initiatives have been considered a maximum score of 3 means that specific initiatives including those based on enforcement (e.g. CA trade waste abuse) and prevention have been considered. Overall, the 359 tertiary normative criteria were therefore attributed a total of 501 points in the full two-tier area analysis (which included criteria of no relevance to Unitary Authorities; e.g. those concerned with the involvement or otherwise of constituent WCAs). Unitary Authorities were scored on 336 tertiary normative criteria with a total of 478 points, and results presented below have been adjusted accordingly.

Detailed guidance and training was provided to the strategy assessors (of which there were six) to ensure that the scoring system has been applied consistently across all strategy evaluations and all evaluations have been verified centrally.

As can been seen from the above, the evaluation of strategies has been a complex and time-consuming process. In order to facilitate feedback to Local Authorities, assessors have also made specific comments against criteria and percentage scores at the secondary criteria level have been calculated to provide a simple basis for quantitative feedback.



3.1.2 Limitations of the Methodology The development of a meaningful methodology for evaluating MWMSs has presented significant challenges and it is important to note a number of limitations inherent in our analysis. Some of these are related to the methodology adopted, whilst others are the result of the wide variation in approach taken to Strategy development and publication by waste authorities. It is particularly important to note the following:

It is an obvious fact that we have only been able to assess available information. It is our firm belief, supported by our findings within this project that the process underpinning the development of a strategy is often of greater importance than the documents which may have been produced as a result of that process. As we have only been able to take into account written material, our ability to evaluate that process has been limited, especially given the fact (discussed above) that published material is often targeted at a specific (perhaps non-technical) audience. Whilst we have tried to take account of the wider process by including supporting information in our analysis, this approach has been imperfect for a number of reasons, not least of which has been probable variation in the extent to which authorities have furnished us with all relevant documentation.

Also, it is clearly the case that not every strategy will require ‘something’ relating to every one of our criteria. For example, a criterion may relate to describing current in-vessel composting arrangements, but where these do not exist (as is the case in most Authorities), it would not be expected that Local Authorities would describe these. This factor has therefore distorted overall scores downward.

The scoring system has attempted to provide an objective method for evaluating factors effecting strategy quality. However, our approach has resulted in our assessing strategies against a very large number of criteria. This has inevitably resulted in strategies generally receiving relatively low total ‘scores’. Whilst it has been important for us to set a high standard for the ‘ideal’ strategy, it should be recognised that this was done with the prior knowledge that very few (if any) existing strategies would perform well against our relatively exhaustive list of tertiary criteria. Having said that, it should be noted that even our 359 criteria are limited in that we had to restrict ourselves to assessing strategies against a ‘realistic’ methodology relative to the resources available to the project.

Perhaps most importantly, the fact that our scoring system is unweighted means that one’s ability to compare strategies against one another at anything above the tertiary criteria level (e.g. at the ‘total score’ level) is limited. This is because the scoring system cannot satisfactorily differentiate between a strategy which has done a lot of less important things well, but may have overlooked a small number of fundamentally important considerations (but may have therefore scored relatively well overall), and another which may have considered the most important factors in some detail without exploring less important ones (and therefore may have scored poorly overall). Also, the nature of measuring whether a factor was addressed or present in a strategy cannot judge the quality of its inclusion. Whilst the scoring system could be adapted through weighting to provide a better basis for comparison of Strategies against one another, this was explicitly not an aim of the project and we would therefore strongly guard against making direct comparisons between total or even secondary criteria level scores of individual Strategies. A primary objective of the approach was to provide feedback on the Strategies rather than to inform Local Authorities that their strategies were good, bad or indifferent. The intention was to provide constructive feedback rather than to criticise, so the lack of weighting was not deemed to be critical.

3.1.3 High Level Analysis Results Whilst it has been noted above that the extent to which individual strategies can be directly compared with one another in terms of total score is limited, there is value in understanding the range of total scores which have been achieved across the sample. This section therefore considers four factors which



are of interest; firstly, the extent to which a correlation exists between positivist and normative scores; secondly, the total range of scores achieved against the normative criteria; thirdly, the extent to which strategy quality (in terms of total normative criteria scores) varies between two-tier and Unitary areas; and finally, the extent of strategy score correlation with actual performance in terms of recycling rate. For simplicity of presentation, scores have been converted to percentage of total available points. Figure 1 below considers the first of these factors.

Figure 1 - Positivist and Normative Scores (pink = Positivist, blue = Normative, black = Normative trend)

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As can be seen above, there is a broad correlation6 between the extent to which strategies conform with the current Guidance (the pink line) and strategy quality according to our normative criteria (the blue line). The black normative trend line shows that there is slightly less variation in normative scores against positivist scores, which may be partly explained by the larger number of normative criteria. Two noteworthy observations can be made from Figure 1; firstly that the average positivist score (43%) is significantly higher than the average normative (26%), implying that conformity with current Guidance might not be sufficient to ensure a high quality MWMS; and secondly, that there are a number of exceptions to the correlation between positivist and normative scores, suggesting that if the normative criteria are well-described, adherence to current guidance was not a pre-requisite for a strategy to have high quality. Anecdotal evidence from the practitioner workshops undertaken within the project7 showed that, although most strategy authors had read the Guidance, it had not been a significant influence on the strategy development process.

6 The coefficient of correlation between the positivist and normative scores was calculated as 0.862, revealing a fairly strong but imperfect correlation between the two data sets.

7 Workshop participants were asked whether they had read the guidance, and how useful they felt it had been.



Figure 2 - Total Range of Normative Scores (blue = Normative scores, black = Normative trend)

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This figure shows the total range of normative scores for all of the verified strategy assessments. Whilst recognising the limitations inherent in drawing conclusions from total scores (see above), it is clear that the quality range of existing MWMSs is wide. With the exception of the two highest total scorers, the range closely follows the trend line. Even with those relative outliers removed, there is almost a 400% difference between the highest and lowest overall score. Whilst it is likely that the detail of this figure would look quite different if the criteria were weighted, it is also likely that a similar range of scores would be revealed across the sample. It is undeniable that strategy quality does vary widely between Authorities and this suggests that practice guidance and support may be able to reap considerable dividends in terms of improving the maturity of strategic thinking in a typical English waste authority simply by drawing upon existing good practice.

The scatter chart shown in Figure 3 below illustrates the range of total scores for two-tier and Unitary areas. The normative criteria for two-tier and Unitary areas are slightly different, in that tertiary criteria relating to, for example, joint working between constituent WCAs have been discounted. The chart shows that, when scores are adjusted to account for the expected variation in scope of two-tier and Unitary strategies, there is relatively little variation in performance against the normative criteria between the two area types, with the Unitary curve dropping off slightly more steeply at the lower end. In some ways, this is surprising given the ‘advantage’ that Unitaries have in terms of service integration between the waste collection and disposal functions. It might be expected that the task of developing a good strategy would be significantly less complex for the single Unitary authority, and that they should therefore be expected to score more highly. The fact that this is not reflected in our analysis may be related to a possible relative lack of development resources in smaller Unitary authorities, or may be explained by the lack of criteria weighting; it may be that Unitaries have in fact scored well against different criteria compared to the two-tier areas, a possibility which cannot be evaluated in an analysis of total scores alone.



Figure 3 - Two-tier/Unitary Comparison of Normative Scores (blue = Two-tier, Yellow = Unitary)

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Comparison of the BVPI recycling and composting rates for 2002/3 for each authority with the normative score for its strategy assessment, as shown in Figure 4, indicates there is not a strong correlation between how well Authorities are performing in terms of recycling achievement and the quality of their strategy documentation.

Figure 4 – Comparison of Normative Scores and 2002/3 BVPI Recycling Rates

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normative criteria average score 02/03 recycling rate

However the situation is considerably more complex than this indicates, because of the wide variation in the type of strategy documents reviewed and the range of dates when they were written. Qualitative assessment drawn from the evaluation process suggests that an authority does not need to have a good



strategy to have good recycling performance but that poor performing authorities are more likely also to have poorly rated strategies, although with some exceptions. The average normative score for the third of the authorities with the lowest recycling rates was 20% compared to an average of 29% for the third with the highest recycling rates, indicating some link exists between recycling rate and strategy quality.

In conclusion, although the explanatory power of analysis of total scores is somewhat limited, one key fact does seem to have emerged; that the quality of Municipal Waste Management Strategies varies significantly between Authorities. This raises both a concern (that some areas appear to have much less developed strategies than others) and a potential opportunity; the possibility that, assuming strategies have an impact on service quality, performance across the country could be improved significantly by facilitating the development of strategies according to existing best practice. However, as will be shown below, it is also clear that an examination of scores against specific secondary and tertiary criteria shows that even most of the higher-scoring current strategies do not address critical issues adequately. This gives some credence to low scores achieved against the normative criteria.

3.1.4 Groupings of Secondary Criteria Even at the secondary level there are too many individual criteria to be able to assess whether there are broad differences between Authorities in the types of issues most thoroughly addressed in their Strategies. For this reason the secondary criteria were grouped into seven groups, each addressing a particular aspect of strategy planning. These secondary criteria groups and the criteria included in each are detailed here:

Objectives and policies Objectives; Policies and targets

Consultation and partnership Depth of consultation; LA Partnerships; External partnerships

Analysis of performance and strategic direction

Depth of analysis; Projection methodology; Realism of approach; Data quality; Quality of analysis; Stream coverage; Capture rates; Participation rate analysis; Gap analysis; Overall analysis; Analysis of direction; Understanding of drivers; Basis for targets and direction; Cost and performance; Analysis and realism

Economics Existing service costs; Future budget pressures

Existing and planned services Refuse collection; Dry recyclables kerbside; Biowaste kerbside; Bring sites; CA sites; Bulky waste; Street cleansing; Commercial collection; Composting; Residual waste treatment and disposal; Other streams; Facility types; General and key issues

Future initiatives Minimisation and prevention; Enforcement; Collection; CA Sites; Awareness and participation; Markets and materials processing; Treatment and disposal

Implementation, monitoring and risk Performance monitoring; Short term issues and constraints; Monitoring and Review; Joint working; Governance; Implementation; Commitment; Facilities; Planning and permitting; Risk assessment

Figure 5 gives the range of scores found for each group, and shows that all groups display a very wide range, as did the overall normative average scores. ‘Objectives and policies’ overall score higher than any other group with an average of 50%, that most strategies have a good basis in this important area. However both ‘analysis of performance and strategic direction’ and ‘economics’ score poorly with averages of 27% and 23% showing a worrying lack of analysis to support the delivery of stated objectives.



Figure 5 – Range of Normative Scores for Different Groups of Criteria

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objectives and policies consultation and partnership analysis of performance and strategic directioneconomics existing and planned services planned initiativesimplementation, monitoring and risk

Individual authorities displayed considerable variation in their scores for each group of criteria, with similar overall average scores being achieved by attention to different elements of a strategy. This is illustrated in Figure 6 which shows the scores for each group of criteria from six authorities; three with high average normative scores of around 40% (shown in green) and three with low scores averaging only 10% (shown in blue). It highlights that although the high scoring strategies score higher in most groups, there are some criteria where the low scoring strategies score higher even though their performance in other areas ensures a low overall score.

Figure 6 – Range of Normative Scores for Different Groups of Criteria

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Although the differences between these high and low scoring strategies are large for all groups of criteria it is greatest for ‘analysis of performance and strategic direction’ and ‘planned initiatives’, probably because these groups contained a large number of criteria and hence ‘points available’, presenting a larger possible range of scores.

3.2 Conclusions on Review of Current Strategies As discussed above, it is only through an analysis of tertiary level criteria that it is really possible to draw conclusions as to the overall strengths and weaknesses of existing Strategies. A detailed analysis of average scores against each of the tertiary criteria in included in Appendix 2. Rather than going in to that level of detail in the body of the report, this section summarises the findings from our detailed analysis of tertiary criteria scores and presents a number of interesting conclusions. Our findings are arranged in accordance with the criteria groupings outlined above, with overall conclusions offered at the end of the section.

3.2.1 Objectives and Policies In terms of scores achieved, this is the area in which current Strategies do best. 93% of strategies set out clear objectives and 78% clearly set out targets against which future performance will be measured. 70% of Strategies establish a range of policies that directly support the delivery of stated targets. Overall, Strategies are clear as to what they are trying to achieve and the fact that objectives are established should mean that Strategies generally offer a sound foundation upon which services can be developed.

However, it is generally the case that target setting is primarily driven by national policy and European legislation. This in no way reduces the importance or validity of those targets, but the fact that clear targets are generally set largely reflects the fact that waste management services are increasingly ‘target driven’; having said that, in 50% of cases, local aspirations clearly influenced the setting of targets. The key issue, as will be discussed below, appears to be the extent to which target setting is supported by in-depth analysis of how they will be met.

With regard to policies, it is clearly important that principles which will guide the implementation of the strategy are established within them. Whilst specific initiatives might be adapted or re-prioritised in the context of periodic reviews of the strategy, underlying policies ought to be more robust over time and ought to give those charged with delivering the strategy a sound basis and mandate from which to move forward into the delivery phase.

Whilst, in the large majority of cases, clear policies exist, the direct influence that they are likely to have on implementation is often questionable. One notable exception to this is the fact that 70% of Strategies establish a clear policy on the role of thermal treatment technologies, a surprisingly high figure given the oft-stated criticism that Local Authorities lack clear leadership on such controversial issues. Of some concern here is the apparently growing trend for Authorities basing their residual treatment strategies on ‘MBT with RDF to power plants or cement kilns’. Whilst offering a role for combustion based thermal treatment, we do have some concern that the extent to which such an RDF market will emerge is still somewhat uncertain.

Another noteworthy observation on policies is that only 2% of Strategies include policies falling within the realm of ‘enforcement’. Whilst some enforcement (in terms of Streetscene) will tend to fall to WCAs, and enforcement may, in general, not be viewed as being within the territory of the MWMS, the potential role of enforcement in preventing waste and minimising the management of illicit commercial waste arising as household waste, would suggest to us that there may be value in considering these issues jointly and strategically to a greater extent in the future.



3.2.2 Consultation and Partnership Here again, high scores were achieved against a number of important criteria. 76% of strategies were exposed to formal public consultation and in 50% of cases there was some evidence that strategies had been influenced by the community. However, more ‘innovative’ approaches to community engagement were much rarer. In only 24% of cases did some form of public meeting or workshop appear to have taken place and, as an interesting example only 7% had utilised Citizen’s Juries.

Given the problems that some strategies have faced in terms of public opposition in implementation, there are good arguments and a growing body of evidence for the efficacy of such in-depth approaches to community engagement becoming more widespread. Whilst most strategies make much of the need to engage the public in the context of participation in new services, by and large, they fail to engage them fully in the strategy development phase. The evidence suggests that Local Authorities may be too parsimonious in their efforts to engage the public at this stage, with the possibility that this stores up problems for the future.

On partnership between Authorities, in 94% of cases, all constituent WCAs in two-tier areas had been involved in the Strategy development process. In 48%, this partnership working was supported by some form of formalisation such as a Memorandum of Understanding. 45% of strategies had considered joint procurement and perhaps surprisingly, as many as 27% had considered single-client approaches to service delivery across the tiers, although a much smaller proportion had arrived at a clear conclusion on the issue. Given the varying vintage of Strategies and the probability that Strategies were, until relatively recently, considered to be primarily concerned with planning for waste disposal capacity, these statistics are perhaps surprisingly high. However, it may be that the inclusion of WCAs in the strategy development process is not as smooth a process as final documents suggest.

Furthermore, as will be discussed below, few strategies consider collection systems in any great depth. The fact that basic economic instruments such as enhanced recycling credits or joint investment strategies were only considered in 12% of cases is perhaps of concern in the post-LATS world, where alignment of economic priorities between the tiers will be increasingly important. It is obviously the case that the large majority of strategies evaluated predate the first publication of the Waste and Emissions Trading Act, but equally, the substance of the WET Act was relatively well known in advance of the publication of the Act.

3.2.3 Analysis of Performance and Strategic Direction Within this large criteria group, scores varied significantly between criteria and individual Strategies. However, in some key areas Strategies generally performed poorly against the criteria. On setting sound baseline assumptions (an area of the strategy process that, in our view is critical in protecting the Strategy from challenge in implementation) current practice typically falls some way short of the ideal.

Perhaps most importantly, when examined against the 23 criteria we developed for assessing methodologies for projecting future waste arisings, the average score across all Strategies was only 12%. At the detailed level, whilst 58% of Authorities appear to have considered variation between WCAs in their analysis, only 6% have attempted to explain this variation. Only 29% have considered what is known to be often the most significant cause of underlying change in arisings (changes in population and household numbers) and only 9% have attempted to explain large variances between years in the historic data.

Most projections were based upon either national data (e.g. the much publicised 3% growth rate, itself based on relatively few years’ data) or local historic trends, which tend to be extrapolated forward twenty years or so. The statistical basis for doing so is almost entirely absent simply because of the limited number of historic data points available, not to mention any questions concerning their accuracy or consistency across time. Five strategies incorporated assumptions relating to projected demographic changes and none considered the interrelationships between different WCAs or waste streams. 20



strategies were based on static projections (which showed no variation in future years in terms of rate of change), 15 were based on relatively arbitrary changes (e.g. spontaneous reductions in the rate of growth at certain points in the timeline, with no explanation offered), whilst in only seven cases were changes in the rate of growth explained by initiatives (e.g. home composting schemes etc.)

Most of these approaches suggest that waste minimisation and prevention is not well integrated within strategies in anything more than an abstract sense. This is of real concern given the scale of the medium to long term challenge that waste growth, as projected, appears to pose. Whilst this is undoubtedly a difficult area and ‘accurate’ projections as such are unlikely to be possible, however sophisticated the methodology, it does seem important that better practice in this area becomes more wide spread; it is our view that sound projection of waste arisings is important both in a technical sense, and as a means to ensure credibility with an increasingly sophisticated public during implementation that will inevitably result in the development of often controversial facilities.

Similar problems appear to exist in current Strategies with regard to consideration of waste composition; the other critical baseline assumption upon which technically sound strategy development ought to be based. Perhaps of greatest concern is that 39% of strategies did not consider waste composition at all. Only six (13%) used ‘multi-season’ data based on local composition surveys. In only 15% of cases did Authorities avoid applying waste composition data from one waste stream to another that was not represented in the sample analysed.

Perhaps not surprisingly, given the importance of waste composition assumptions in conducting such analyses, only 2% of strategies assessed their current performance on recycling and composting in terms of material capture rates. This is the first of several areas which appear to reveal a general lack of detailed consideration of collection system issues. Whilst it must obviously be recognised that strategy development in two-tier areas is, by definition, more complex, and analysis of capture rates might best be left to constituent WCAs, it is nevertheless important that collection system issues are properly considered in Strategies and that this can only be done if current performance is analysed. The fact that our sample included a significant proportion of Unitary Authorities implies that the analysis of capture rates is generally uncommon.

Other key indicators of collection system efficiency were also rarely considered. For example, analysis of participation rates based on operational surveys were only presented in 7% of Strategies and no Strategies considered material recognition rate (i.e. the efficiency with which participants set out targeted materials). The overall view of assessors was that collection issues were generally considered in somewhat abstract ways, raising the concern that whilst targets are set, how they are going to be reached is rarely demonstrated by strategies. This appears to have had a widespread knock-on effect on option selection when considering approaches to service development; only 26% of Strategies select ‘operationally based’ options for appraisal, with the large majority tending to consider more abstract ‘high, medium and low recycling’ scenarios. Whichever option is ultimately selected, such approaches are not likely to result in the most realistic systems, limiting the ability for strategies to be implemented in the real world, potentially opening them to criticism from the public.

It is our view, based both on this analysis and on work undertaken with Authorities, that there is a strong argument for creating a best practice model for strategy development in two-tier areas that involves WCAs working within a collectively agreed framework to develop individual ‘collection strategies’ that would then form the collection and source separation elements of the joint strategy, allowing the Authorities jointly, but led by the WDA, to develop a ‘central treatment and disposal strategy’ that is well aligned with the operational plans of WCAs and based upon sound analysis of the realistic role that recycling and composting can play in the overall Strategy. This framework has also to consider how the quantity of waste collected is likely to change over time, and critically, it must consider how to deal with uncertainties in such projections (through, for example, periodic review, and through careful consideration of capacity requirements for specific treatments).



3.2.4 Economics Economic issues are obviously of growing importance in the municipal waste management sector as the costs of providing services that comply with legislative and regulatory drivers begins to increase. The key budget pressures facing Authorities were generally well represented in Strategies, with the extent of recognition of specific pressures being naturally dictated by their publication date relative to the timings of the various announcements (i.e. Landfill Tax and LATS) by Government. Not surprisingly, since most of the Strategies evaluated predate the WET Act, budget pressures associated with LATS are only analysed in 17% of cases. Whilst this is obviously understandable, it does render the large majority of Strategies somewhat out of date. Indeed, most Strategies are predicated on the assumption that the long-mooted trading scheme would not be introduced until the first Landfill Directive target in 2010. Hence, some strategies which have planned in what might be considered an exemplary manner based on that assumption would likely be showing a large deficit on their landfill allowances in the years just prior to 2010.

However, in general terms, most strategies deal with cost issues in a relatively superficial way, if at all. Cost modelling is generally somewhat simplistic and although it is recognised that such exercises probably qualify as ‘more art that science’, there is a clear need for a number of improvements to be made to the approaches that have generally been taken to date. Only 33% of strategies analyse future costs in a holistic manner, considering the whole (collection and disposal) system. Only a tiny minority use measures such a Net Present Value in comparing relative the lifetime value of system options. In terms of demonstrating an understanding of the current cost base, only 22% include an analysis of relative spend on collection and disposal. In modelling future costs, only 9% of two-tier strategies model collection systems at the WCA level and only 11% consider avoided costs (and how these might change over time) within their analysis. Given the lack of clear analysis of collection systems, this poor level of analysis is perhaps to be expected.

Given the pressures and, in particular, the likely time dynamics of the LATS market, considering investment strategies in more sophisticated ways is now essential. Local Authority practitioners who participated in our workshops clearly aspired to having strategies that provided a basis for investment and there was recognition amongst officers that the current generation of Strategies rarely achieves this.

It is our view that Strategies will increasingly have to serve as ‘strategic business plans’ for services that must successfully justify significant levels of investment in order to avoid much more significant costs in the medium to long term. Whilst ‘investment to save’ is wholly logical, the competing priorities and increasing budget pressures within Local Government generally presents a challenge to waste managers. In our view, this can only be addressed though the development of Strategies that bring together the technical and economic aspects with sufficient credibility to present a sound business case for investment in a highly competitive environment. Waste managers have long been used to having to face the challenges of sceptical members of the public in attempting to develop new services and facilities; in the new, post LATS paradigm, the greatest challenge may be convincing sceptical Chief Financial Officers of the need to invest, and that will be achieved in part through more robust long term Strategies.

3.2.5 Implementation, Monitoring and Risk On the criteria within this group, current strategy performance is mixed. 70% of Strategies provide for a regular review and 41% include an assessment of the short term drivers that may trigger a requirement for an earlier review. However, only 9% link drivers that may bring about a need for a review to a timeline through the setting of milestones. This suggests that key uncertainties and dependencies have often been identified, but systems are generally not in place to ensure that monitoring of performance and key indicators is aligned to plans for implementing reviews.

In terms of governance, 64% of strategies will be steered by some form of joint board, but Member involvement is only envisaged in 20% of cases and senior management in 13% of cases. In 33% the



impression is given that officers are empowered to ‘get on with’ implementation, but in only half of these cases (17%) does the strategy itself equate to a financial commitment.

In general, risk issues are not considered in depth, if at all. Overall, the nine risk management criteria scored an average of 10% and in only 17% of cases are planning risks identified as a key potential cause of slippage in implementation. A risk assessment is only included in 7% of Strategies. In general, the depth of analysis of sensitivity to key variables or risks is limited.

It is our view that Strategies should contain more in the way of risk assessment, sensitivity analysis and contingency plans if the risk of their becoming ‘overtaken by events’ is to be minimised. This also has implications for the development of the type of ‘strategic business plan’ mentioned above.

3.2.6 Overall Conclusions on Current Strategy Quality Whilst the sections above may come across as overly critical, in fact it is only when Strategies are set against such an exacting set of criteria that they appear to perform badly. The large majority of Strategies examined within the project constitute the first generation of integrated joint Strategies and there are obviously several important positives that can be taken from the review. Authorities in two-tier areas, despite the imperfections in the institutional framework, are increasingly working together and aligning their objectives both vertically between the tiers and horizontally within them. Some very big and fluid issues are being grappled with, and in many cases ‘performance on the ground’ is outstripping the performance of Strategies.

A key question that we have attempted to answer through this project is ‘what is the role of the MWMS’. Service development through the imperatives of short term targets and procurement cycles is evidently progressing despite (to some extent) the limitations of existing Strategies. So, are sophisticated strategies actually necessary? It is our view that the answer to that question has to be ‘yes’, more so now than when many of the current generation of Strategies were conceived; and this conclusion is supported both by general consensus on the question within the participants of the project stakeholder dialogue exercises and the fact that Authorities are, in many cases, seeking to address the issues raised in the sections above at the present time.

In summary, almost all current Strategies serve a purpose as high-level strategic documents. However, whilst they are generally strong on establishing the destination and gathering some of the tools needed to get there, they often fail to provide a complete route map. The next stage in strategy development practice will be about operationalising those high-level plans, both in terms of delivering technically robust route maps based on sound analysis, and by providing compelling business cases for investment that are capable of delivering commitment from Members and Chief Financial Officers. In particular, Strategies will need to:

• Be based upon more sophisticated technical analysis, with the service development plans of all partner Authorities more fully represented;

• Be founded on assumptions which can be defended, and critical analysis of current performance and the drivers of improved future performance, so that robust, best value plans can be sold to Members, senior managers and the public;

• Take more account of cost and wider economic issues and really hit home what will increasingly become undeniable business cases for investment;

• Show appreciation that the strategy process is a living one, and that the dynamics of this process have to be recognised through plans for periodic and ongoing review so as to understand performance against targets and aspirations, and so as to anticipate, and adapt to, new circumstances; and



• Involve the community more fully, and at more stages, both to minimise the risks to deliverability associated with, in particular, the development of controversial waste management facilities (of almost all kinds), and to kick-start the process of public engagement required to ensure full and efficient use of new services.

4.0 Decision Making Techniques It was the overwhelming view of stakeholders that decision making methodologies need to be rationalised and become more transparent and better informed by community engagement. In particular the role of, and approach to, BPEO assessment was seen as a critical issue requiring resolution. It is our view, as will be discussed in detail in section 6.2.1 below, that the Life Cycle Assessment (LCA) based approach to whole-system assessment, particularly in the context of spatial planning, is generally inappropriate. The waste management hierarchy, supported by clearer guidance on the application of the proximity principle and self-sufficiency should, when applied with common sense, provide a reasonable basis for Strategy decision making. It is our view that such analyses (when accompanied by adequate cost modelling and sensitivity analysis), in the context of Municipal Waste Management Strategies, would comply with the accepted definition of BPEO and the assessment approach outlined in Part 2 of Waste Strategy 2000.

The advent of the requirements for Strategic Environmental Assessment (SEA) and Sustainability Appraisal (SA) in Development Plan making and Environmental Impact Assessment (EIA) at the site application level provide an adequate framework for decision making within the land use planning system and we would therefore recommend that PPS 10 make clear that, whilst Plans should have regard to BPEO assessments carried out as part of the MWMS, development process, their responsibilities in terms of assessment and sound decision making should be discharged through SEA and SA at the Plan making stage, and evaluation of SEAs in the determination of planning applications at the site level. This is not so say that there should not be a role for LCA in decision making; rather that it is one of many tools that can inform decision making at all stages. The following section presents our views on approaches to decision making in specific regard of Municipal Waste Management Strategies.

4.1 Decision Making for Strategies Our review of Strategies has revealed that, at the high level, virtually all, whatever the method of evaluation, and whatever the level of detail on implementation, are based around the waste management hierarchy. As discussed above, it is our view that this provides a simple yet robust framework for strategy development and tends to result in Strategies that are well aligned with political and community aspirations. We have examined the strengths and weaknesses of the hierarchy as a decision making tool (see section 6.2.2 below) and it is our view that its application should be supported by practice guidance from Government in order to avoid its being used inappropriately.

Essentially, it is our view that the hierarchy should be used to determine what action should be taken in terms of targeting different waste streams or materials for minimisation, reuse, recycling or further recovery, as opposed to being a mechanistic, inflexible ‘rule’. In other words, it should be assumed that the hierarchy is applied, but that the extent to which waste will be able to be realistically dealt with at each tier should be determined through sound analysis. In principle, residues produced by one tier should be dealt with by the next tier down, and tiers should not be ‘skipped’. Where a particular waste stream or material is not to be managed in accordance with the hierarchy, the onus should be on the Strategy to demonstrate through sound analysis why this is the case, through the use of techniques such as cost-benefit analysis or LCA.

Factors such as time dynamics (i.e. the need for strategies to embody flexibility over time) and the sensitivity of conclusions reached to particular fundamental assumptions should also feature in the decision making process. On time dynamics, the conceptual diagram shown below provides a useful illustration of an approach to ensuring adequate flexibility:



Figure 4 - The ‘Three Segments’ Concept

Quick Win Long TermResidualSlow Down

All Municipal Waste

'Easy to recycle/compost'material, available in largequantities and captured atrelatively easily achieved

rates

Post-plateau material -quick win materials athigh capture rates and

materials only available insmaller quantities

Material which isdifficult to recycle &

uncaptured quick win/slow down material

Recycling/composting facilities

Long term fixedthroughput facilities

Flexible throughputfacilities

The ‘quick win’ segment includes all of the ‘main’ materials within the waste stream being examined that are well suited to source separation; i.e. glass, paper, cans, green garden waste, kitchen waste etc. The size of the segment would be based on assuming that they were captured at moderately high but realistic capture rates, perhaps based on the performance of mature recycling schemes in the UK. These are materials which ought to be amenable to capture through source separation rather quickly, the materials being either recycled or composted. The ‘slow down’ segment represents the material that can be captured in the longer term, through maximising capture rates of the main recyclables, and targeting ‘more difficult to capture’ materials which arise as smaller proportions of the waste stream; i.e. some plastics, more obscure paper grades etc. The ‘long term residual’ segment represents the portion of the waste stream which it is difficult to envisage being recycled other than in the longer term, even with well developed recycling schemes supported by incentives to encourage participation; i.e. materials for which no markets are likely to exist in the longer term (some composite materials e.g. sanitary products etc.) and the difference between high capture rates and 100% recycling of the materials targeted in the first two segments. Strategy authors would consider different techniques and facilities to treat each segment; recycling/composting facilities for the first segment, a mixture of ‘flexible throughput’ technologies for the second (probably a combination of modular, adaptable treatments and untreated landfill); and potentially (though not necessarily) fixed throughput, capital intensive technologies for the ‘long term residual’ segment.

On sensitivity to key variables, Strategies should employ sensitivity analysis combined with Strategy review procedures designed to allow action to be taken before the strategy is rendered ‘out of date’ by events in the real world. Ideally, contingency planning should be a feature of the Strategy process and we would recommend the use of separate ‘action plans’ along side ‘high level strategies’ that could be updated based on actual performance. Utilising such a structure should allow the ‘high level’ element of Strategies to be retained in all but the most extreme circumstances, preventing the need for frequent large scale revision. Revision of the ‘high level’ element might then only be triggered at the point that the ‘action plan’ has diverged from it to such an extent that it no longer provides a viable framework for it. For those areas subject to the statutory duty under the WET act, the provision to Government of a new statement of the Strategy might then only be required at the point when the entire Strategy is materially changed.



4.1.1 Community Engagement It is our view that consultation and community engagement at various stages in the Strategy process is essential to supporting decision making processes. One of the weaknesses of current approaches is that consultation often only takes place once a draft strategy has been produced. We would recommend that, as a component of the options assessment process, appropriate methods for community engagement are employed. One of the classic delaying factors in strategy development has been the ‘throwing out’ of strategies by elected Members after significant amounts of work have been completed by officers and consultants, because they do not feel confident that they are managing their political risks by adopting a strategy containing controversial features. Officers may then go away and develop an alternative strategy which is either unrealistic or so ‘high level’ as to be of little practical value. Only when that Strategy has failed to deliver will a third version be produced; by which time the members concerned may be adequately appraised of the issues to make a more objective judgement. Whilst this description of events is obviously something of a caricature, it is by no means unheard of in the real world and reflects the anecdotes presented by stakeholders during the course of this project.

In our view, it is essential that Local Authorities are provided with guidance on what approaches are likely to be effective (based on evidence, which is starting to become available) and that they are supported by policy which facilitates a sense of security in involving members of the public in strategy development. We have a number of views as to the types of approaches to community engagement that may prove effective, based on the findings of our research and consultation within this project:

• Firstly, we would suggest that partnerships of Authorities form what could be termed a ‘waste forum’, made up of officers involved in the strategy development process, elected members for across the partnership and political spectrum and representatives from local community and environmental organisations. The forum might meet regularly throughout the strategy process and would act as a ‘project reference group’. They might be particularly involved in the initial ‘scoping’ stages, option development for prevention, recycling/composting and residual waste treatment and preferred option selection. A not uncommon barrier to Strategy adoption and implementation has been the potential for objectors to challenge the process or assumptions used and this type of approach may allow these forms of challenge to be minimised.

• In addition to the waste forum, we would recommend the use of genuinely representative groups of local citizens at different stages in the process. There are various methods which might be appropriate, including using focus groups, citizen’s juries, community advisory groups and consensus conferences or panels. The key here is to ensure that groups are adequately informed to consider the issue at hand. WCA level focus groups may be appropriate for considering changes to collection systems, whereas longer term ‘community advisory groups’ citizen’s juries or ‘consensus panels’ might be more appropriate in considering the complex issues surrounding residual waste treatment options. The outcomes of these consultations could then be fed to the ‘waste forum’ and into the Strategy development process. It is through these methods that Members can best be inspired with the confidence to consult with the public at large, especially if results of detailed consultation with genuinely representative samples of the community form part of the material through which mass consultation is facilitated.

• Another aspect of consideration concerning consultation is the role of the waste management industry. There is a growing concern within the industry that Local Authorities are (deliberately or not) seeking to ‘privatise’ consultation by effectively leaving it largely to the planning application stage. Not only is this approach not consistent with emerging best practice in terms of on-going community engagement, it is also a problematic function to transfer to the party with the most obvious commercial interest in the outcome. Whilst the industry clearly does have a role here, the extent to which companies feel they are being relied upon is unlikely to be a recipe for success. Ideally, at the planning application stage the applicant would simply be responsible for consulting communities on the specific aspects of its proposal, assuming it was in conformity with the more general requirements of the Strategy and Development Plan.



However, the involvement of the waste industry is crucial at an early stage in the Strategy development process, as the deliverability of Strategies will generally be dependent on the market viability of proposals considered. This should be an essential element of the test for ‘practicability’ and might take the form of a focus group, a soft market test or a ‘sense check’ based on a written summary of a draft Strategy.

• A further issue relating to the role of the waste management industry in Strategy development (raised as a concern by both industry and Local Authority representatives) is the potential for conflict between technically detailed Strategies and increasingly ‘output based’ approaches to procurement. As a prominent feature of PFI and other PPP approaches to procurement, output specifications at first seem incompatible with detailed technical analyses at the Strategy development stage (which should clearly ideally precede procurement). However, it is our view that adequate technical Strategy development, provided industry input is considered, forms an essential part of setting outputs and contract parameters. Local Authority decision makers will need to be well informed of as to what outputs can realistically be delivered within different ranges of cost prior to embarking on output based contracting.

It is our view that although community engagement to this extent has not traditionally formed part of the MWMS process, there is growing evidence that where it has, Strategies have been adopted more quickly, have provided a clearer basis for action and have been better aligned with the realities of implementation through procurement and the planning system. Provided that processes are well planned and adequately resourced, much of what is envisaged above could be carried out concurrent with the technical work that will be required in any case, and should not necessarily cause Strategy processes to become too protracted. Indeed, where ideal sequencing is a possibility, the majority of this work could be combined with the consultation required by the Plan making process and SEA. Furthermore, it seems inconsistent for Local Authorities to exhort citizens to participate in recycling schemes when they have not been consulted adequately on waste strategy development. The latter ought to be seen as central in raising the level of waste-consciousness of citizens in the UK.

5.0 Strategy Development Support Needs The review of existing strategies has revealed a number of apparent weaknesses which seem to be common across most strategies. However, it must be recognised that these weaknesses do not, in reality, reflect entirely on Local Authorities themselves. The existing Guidance places emphasis on a number of important strategy considerations, but also overlooks a number of others. Perhaps more fundamentally, our review has considered existing strategies against criteria based on our interpretation of the ‘ideal’ MWMS. In doing this, we were well aware that most existing strategies would appear to perform badly against such a comprehensive list of criteria. However, our criteria were developed to reflect what we believe to be necessary to produce a really effective MWMS. No strategy would be able to score 100% against our criteria, as some refer to services which will not be universally provided; but if strategies are to have a real and direct impact on service performance and are to lead into action which will have financial implications, we are of the view that they would need to be scoring much higher than they do against all of the secondary level criteria discussed above.

The question is, how can this improvement in strategy development practice be achieved? This section considers the role that the provision of support, in its many possible forms, may have on achieving that objective and makes a number of recommendations. It draws upon our research of existing support employed by local authorities in the development of the current generation of strategies and considers our recommendations above on decision making techniques.



5.1 The Capacity Shortage It is our view, supported by our wider experience as consultants in this field as well as the stakeholder dialogue carried out within this project, and leaving aside any discussion of skills gaps, that a fundamental shortage of capacity exists within the organisations that currently bear the brunt of the Strategy development process.

Firstly, within Local Authorities, senior waste managers are often preoccupied with the day-to-day realities of service delivery in what is clearly a ‘front-line’ service. In our experience working with, and speaking to, Local Authority practitioners, even Heads of Service can spend large parts of their day dealing with specific, detailed queries from members of the public or elected Members and often have very little time available to devote to strategic thinking. It is hardly surprising, then, that MWMSs that these individuals are generally charged with developing seem to suffer from a lack of thorough analysis. The quality of MWMS we envisage in our idealised vision will never be delivered on a wide scale whilst this remains the case.

Additionally, we are confident of the need for the MWMS development process to become better integrated with the waste Development Plan making process. Again, strategic planners with experience of waste planning are generally already over committed and this situation is unlikely to be improved in the short term by the requirements of the planning system reforms and the SEA Directive.

Finally, whilst waste authorities remain dependant on external consultants to facilitate strategy development processes, the current shortage of well qualified specialist waste management consultants will continue to result in either a compromise in terms of strategy quality or delivery timescales, or perhaps worse still a ‘brain drain’ from Local Authorities to consultancies that is not compatible with the need for Authorities to have full ownership of the Strategy development process.

It is our view that there is little point in Government creating an expectation that MWMSs should be developed to a much higher standard unless, at the very least, the first of these issues can be addressed quite directly. We envisage an ideal scenario being that, for each strategy (i.e. probably WDA) area, a number of Service Manager level officers from across the constituent Authorities in the area being devoted, either full time for a smaller team, or part time for one which represented all constituent authorities, to work as a Strategy Development Unit on a ‘secondment’ basis. This work would entail the coordination and much of the direct work of the Strategy development process, but would also allow time for those officers to engage in training, and to receive other direct forms of support suggested below.

It is our view that this approach, or one which is its equivalent, should be considered a prerequisite to the creation of expectations for a high quality strategy, or to the investment of resources in other support initiatives. How such intensive work on Strategy development should be resourced is a question that cannot be answered within the scope of this project, but it is our view that Government should consider options for facilitating such resourcing, including the possibility of some funding being provided directly by Government for this purpose through the Waste Implementation Programme.

5.2 Technical Support and the Dissemination of Good Practice Here we consider a range of other potential support initiatives which, in our view, are necessary for Strategy development to improve to the extent we envisage.



5.2.1 Technical Tools and Practice Guidance Practice guidance notes of some kind, or potentially, technical tools, are required in a number of areas where significant inconsistencies in terms of quality of approach appear to exist at the present time. Topic areas should include:

Evaluation of current performance; in terms of collection systems, WRAP has made some headway here, especially with regard to operational data analysis, though their recycling officer’s training programme and accompanying course literature. However, this should be adapted specifically for the needs of collection strategy development within the context of MWMS development;

Projection of future waste arisings; in this case, Defra should consider developing a tool, which could be at least partly IT based, which Authorities could use to develop more sophisticated arisings projections, talking account of all of the known drivers affecting arisings and allowing waste prevention initiatives to be modelled as realistically as possible. Some serious strategic research into this issue is long overdue, and should be commissioned by Defra so that key variables can be considered with an eye to better informed ‘futurology’;

Consultation and community engagement; practice guidance should be provided, ideally in conjunction with practice guidance that may be produced by ODPM to accompany PPS 10, on the ‘how’s’ and ‘when’s’ of community engagement in the waste management field. A growing body of evidence and verified good practice is becoming available in this area and this could be drawn upon to provide officers with practical examples of what works;

Cost modelling; again, a tool may be appropriate here. We understand that WRAP are funding the continued development of the CAT model recently published by Waste Watch. Whilst this tool is comprehensive in some aspects of collection cost modelling, it would need to be adapted further to cover all of the needs of MWMS developers. As WRAP will be promoting and supporting its use in any case, it should perhaps become something of a ‘standard’ tool in Strategy development. CAT does not address residual waste options. Some information on this is being collected through the New Technologies Data Centre, but the suggested costs for some conventional technologies vary significantly across various consultants’ reports and strategies. Some clear information is needed concerning cost ranges which could be expected in contractual situations. Other issues which need to be considered would be the approach to contracting of services within the whole system, and the timing of re-letting of these contracts so as to optimise the value obtained in the procurement process, consistent with meeting statutory targets and other objectives

Option selection; It will be necessary to provide some high-quality practice guidance covering issues such as option selection (i.e. not option evaluation, but the choice of which options to consider in the first place). For collection systems, this need arises for those not choosing to use the WRAP model and in part to facilitate the integration of approaches to the modelling of collection (which the WRAP model will cover) and treatment/disposal (which it will not). Hence, some clear information about option selection for residual waste will be required. Some of this may come forward through the New Technologies Supporter Programme. This would have to address operational issues such as flexibility to input streams, suitable materials for co-treatment, etc; and

Risk management; some specific guidance on risk assessment and management is essential. Firstly, risk issues are clearly not being considered adequately within current strategies, given the financial risks which currently exist for waste authorities. Secondly, it will only be when issues such as Strategy risk are being discussed that, in many cases, senior corporate management will tend to engage with MWMS development.



5.2.2 Dissemination of Current Good Practice Good practice clearly does exist within English waste authorities. An increasingly large number of authorities are developing approaches to service delivery which are likely to exceed the requirements of current and forthcoming legislative and regulatory requirements, in some cases by a significant margin. Increasingly innovative methods are being employed with regard to financing, procuring and delivering services through partnership based approaches. It simply seems to be the case that this positive development is occurring on a somewhat piecemeal basis, and that the most ground-breaking work in the field at the moment is not being driven by well worked-up Strategies but by opportunities presented in the course of day-to-day service delivery or procurement imperatives.

So, if Strategies are to take on part of the role of leading service development there is a need for existing good practice to be disseminated in a more structured way, as well as for new skills and approaches to be taught. We therefore recommend consideration of the following:

Waste prevention, collection and CA sites; WRAP should be clearly designated the role, delivered through its existing programmes, of providing ‘bench mark’ support in developing strategic local authority thinking in these areas. Whilst it is unrealistic to imagine WRAP providing all of the ‘on the ground’ support that will be required, it should have something of a ‘quality control’ function, by providing a range of standard methodologies, approaches, tools and guidance notes. If the CAT model is to have a major role in strategy development, its use will need to be directly supported. It is our view that the new WRAP programmes will be covering a large part of this territory in any case, and that duplication and potential inconsistency are best avoided by clearly designating a role around Strategy support to them;

Peer review and mentoring; as resources devoted to strategy development increase over time, it will be necessary for dissemination of good practice to involve increased coordination and face-to-face exchange. We would therefore recommend that a programme of funding be established to facilitate access, by those needing to develop new skills or approaches, to our most experienced officers. Under this scheme, peer reviewers and mentors would be selected to work with a number of less experienced officers form other authorities. Peer reviewers might provide a ‘sounding board’ for strategy developers, primarily through email and telephone contact, whilst mentors would take a more hands-on role in supporting strategy processes through face-to-face meetings and on-the-job training. The employers of mentors and peer reviewers would have to be compensated financially for their time and expenses and they could be supported in terms of training and ‘quality control’ by the IDeA, WRAP, and Defra. This type of approach appears to be the only realistic way of increasing experienced support capacity without removing some of our best officers from their front-line role;

Residual waste; it will be necessary for a coordinated programme of support on residual waste treatment and disposal to be developed through the various WIP and Environment Agency initiatives in this area. We would envisage the Local Authority Support Unit taking a similar role to WRAP here, providing guidance, tools and a ‘quality control’ function; and

Signposting; our analysis of support currently available to Local Authorities has shown that few authorities take advantage of more than one or two such opportunities, and virtually none, for example, utilise the CIWM research library during development of MWMSs. An increasing range of web based resources exist and we recommend that Defra dedicates resources to comprehensively collecting and updating information on existing support services and organisations and information sources which should then be provided through a ‘waste information and support portal’ on the Defra web site. At the very least, this should distil all the relevant information regarding UK and EU legislation for local authorities in a ‘Local Authority friendly way’. Almost every strategy includes such a section, which absorbs a considerable number of pages in each document. Defra should (as a sort of local-authority equivalent to the Environment Agency’s NetRegs) provide a regularly updated picture of what existing and proposed National and European legislation implies, now and in future, for Local Authorities.



6.0 Strategies and the Land Use Planning System The aspirations of Government for Local Authority waste management services will only be delivered through service change and investment, in general terms executed through the procurement process. However, as has been seen in a number of high profile cases in recent years, successful procurement remains wholly dependent on the land use planning system ensuring delivery of sites upon which facilities can be developed.

It is being increasingly recognised by central and local Government that greater integration of Waste Development Planning and Municipal Waste Management Strategy development makes good sense. One of the objectives of this project, in the context of advising Defra on the revision of Guidance on Municipal Waste Management Strategies, has been to consider possible approaches to facilitating the integration of waste strategy development and the relevant land-use planning issues. A particular opportunity presents itself this year with the almost simultaneous revision of the Defra Guidance and PPG 10, which will become Planning Policy Statement (PPS) 10 following consultation later this year. Defra and ODPM have worked closely on these parallel documents and this project has been able to inform both processes.

As described above, the stakeholder dialogue undertaken within this project identified cross-sectoral consensus (and indeed unanimity) on the issue of improved integration and, despite the need to overcome a number of challenging issues, it is our view that such a move is essential. Before we discuss our findings and conclusions on how this might be done, the following section provides a summary introduction to the waste planning system, in the context of the wider reform of land use planning heralded by the Planning and Compulsory Purchase Act 2004.

6.1 Introduction to the Waste Planning System The waste planning system as such has only existed since 1991, when the statutory duty to produce a separate Waste Development Plan (at the current time, in the form of a Waste Local Plan or within a Unitary Development Plan) was introduced. The ‘plan led’ system that is at the heart of town and country planning legislation (and remains so following the passing of the Act into law) applies to waste as it does to most other forms of development and essentially requires that planning applications are determined ‘in line with’ the relevant Development Plan unless a material consideration suggests otherwise. The simplified diagram overleaf summarises the system and the changes that will be brought about by the Planning and Compulsory Purchase Act.

The wider reform of the planning system, along side the creation of PPS 10 presents opportunities to increase the level of focus on ‘delivery’ within the waste planning system, to clarify policies and to align policy on planning with policy on municipal and wider waste management. Whilst the planning system is often blamed for failures to deliver waste management facilities, it is our view that the perception that the planning system its self is ‘the problem’ results primarily from the fact that it is by definition often only at the planning application stage that negative decisions and hence barriers to implementation come about. The plan led system is heavily dependant on good plans and strategies being in place and these in turn are predicated on policy within the waste management, rather than the planning realm. The following section considers some possible approaches to clarifying policy which is of relevance to both Development Plan making and MWMS development.



Figure 5 - Changes to the Land Use Planning System

6.2 Policy Issues Four policy and decision making concepts are outlined in Waste Strategy 2000 and PPG 10; the Best Practicable Environmental Option (BPEO), the waste management hierarchy, the proximity principle and regional self sufficiency. Clarification of the roles and relationships of these principles has been identified by stakeholders from all sectors as being essential to providing a more robust decision making

Planning PolicyStatements

Regional SpatialStrategy

DevelopmentFrameworks

DevelopmentControl

Town and Country Planning legislationAims to secure the most efficient and effective use of land in the public interest and attempts

to reconcile the competing needs of development and conservation

Public Enquiry

PlanningAppealsProcess

The PlanningInspectorate isresponsible for

holding examinationsin public of local

development plansand processing

planning appeals

RSS will replace existing RegionalPlanning Guidance, which has beencriticised for being unfocused and

passive; RSS will be more spatial innature, will have statutory force, will

become part of the DevelopmentPlan that the local level and

Development Plans will be requiredto be in line with RSS

Planning Policy Guidance Notes (PPGs) willbe replaced by new Planning Policy

Statements (PPSs) which will be morefocused statements of national policy. PPS 10

will deal specifically with waste planning

Waste Development Frameworkswill replace the current Waste Local

Plans and will be a folder ofdocuments designed to be more

flexible and responsive. These willhave to be 'in line' with RSS and will

contain both Development PlanDocuments and Supplementary

Planning Documents

Development control is the point at which individual planningpermissions are granted or rejected. This is a democraticprocess, with decisions being made by elected member

committee. Within the plan led system, decisions will be inline with the development plan unless a material

consideration contradicts the plan. Precisely what does anddoes not constitute a material consideration is not clearly

laid down and is informed by case law. The courts (asopposed to the appeals process) generally only becomeinvolved where an allegation of misadministration by theplanning authority is made, often concerning inadequate

regard having been given to material considerations



framework. This section considers these concepts in turn, providing some analysis based on our research and stakeholder dialogue, followed by our conclusions and recommendations.

6.2.1 BPEO In practical terms, waste strategy and planning processes make decisions as to how much waste will need to be managed by different means at different points in time. They must do this is a in a robust way that facilitates implementation on the ground both operationally (the results have to be technically realistic) and politically (the outcomes have to inspire local political, and wider community confidence). One of the weaknesses of BPEO assessment highlighted by stakeholders is that both the result and process often fail to deliver against these fundamental criteria.

The concept of BPEO was originally formulated in 1976 by the Royal Commission on Environmental Pollution in the 5th Report8 Air Pollution Control: An Integrated Approach. It was proposed as a development of the regulatory requirement to use ‘Best Practicable Means’ (‘BPM’) which can be traced back to the 19th century and possibly earlier. BPM was formalised in legislation as a requirement of the Smoke Nuisance Abatement (Metropolis) Act of 1853, the Alkali Act in 1874, and then in most subsequent pollution control legislation up to the late 20th Century. The Royal Commission expressed discontent with the way that BPM had been used as a criterion and recommended that the pollution inspectorate should:

“ seek the optimum environmental improvement within the concept of ‘best practicable means’, employing the knowledge of industrial processes and many of the present techniques of the Alkali inspectorate to reduce or modify the wastes produced whether solid, liquid or gaseous. In effect, we have in mind an expansion of the concept of ‘Best Practicable Means’ into an overall ‘Best Practicable Environmental Option’.”

BPEO, as originally envisaged, was therefore intended to focus primarily on industrial practices, with the objective of improving environmental performance by waste and emissions reduction, and modification (reduction in hazard) of wastes and other emissions. In their Eleventh Report9, published in December 1985 the Royal Commission examined the application of BPEO to the disposal of certain types of waste. Concerned that “the indiscriminate use of the term to describe almost any course of action which takes some account of environmental factors can only undermine the underlying principles on which BPEO is based” the Royal Commission dedicated the Twelfth Report to the concept of Best Practicable Environmental Option. It is this Report which provided the basic and still used, definition10:

“the outcome of a systematic, consultative and decision-making procedure which emphasises the protection and conservation of the environment across land, air and water. The BPEO procedure establishes, for a given set of objectives, the option that provides the most benefits or the least damage to the environment as a whole, at acceptable cost, in the long-term as well as the short-term.”

BPEO was incorporated into the Environmental Protection Act 1990, which introduced legislation on Integrated Pollution Control (IPC). It required that determination of applications for permits under IPC be made on the basis that the Best Available Techniques Not Entailing Excessive Costs (‘BATNEEC’), having regard to BPEO. An element of cost versus environmental benefit/risk was thus brought into play

8 Air Pollution Control: An Integrated Approach. Fifth Report of the Royal Commission on Environmental Pollution, Cmnd.6371, January 1976. Paragraph 14, page 3; paragraph 271, page 76; and paragraph 275, page 77.

9 Managing Waste: The Duty of Care. Eleventh Report of the Royal Commission on Environmental Pollution, Cmnd 9675, December 1985, HMSO London

10 Best Practicable Environmental Option. Twelfth Report, Cmnd 310, February 1988. Paragraph 2.1, page 5.



in deciding which process option constitutes the BPEO and the Environment Agency later developed a set of guidance to help establish the appropriate level at which the costs of additional environmental protection exceeded the benefits.

The first indications of the widening of BPEO from a process industries-related pollution control concept into the field of waste planning came with the publication of Making Waste Work (MWW) in December 199511. MWW made several references to BPEO but never put it clearly into context. PPG 10 made reference to BPEO as a decision making ‘principle’, alongside the proximity principle and regional self sufficiency. For example, it states with regard to Waste Development Plans that ‘the selected policies [must] represent the best balance of social, environmental and economic costs and benefits, after full consideration of the BPEO and the principles of sustainable development.’ Waste Strategy 2000 states that decisions on waste management should be based on a local assessment of BPEO, which may be different for different waste streams in different locations at different points in time. Part 2 of Waste Strategy 2000 also provides the main source of guidance on practical application of BPEO in England and Wales, though this is somewhat rudimentary.

The concept of BPEO assessment clearly enshrines an element of comparison of the environmental performance of different configurations of waste management systems. The approach which has been generally recommended thus far (for example, in Part 2 of Waste Strategy 2000), is based upon life cycle assessment (LCA), using assessment tools such as WISARD.

LCA has two inherent weaknesses which have directly compromised its ability to deliver on the criteria outlined above. Firstly, LCA struggles to address ‘real world’ operational realities, in particular because it is close to impossible to consider collection logistics and therefore whole system cost, and to make a credible assessment of the optimal role of recycling and composting. These are critical considerations in both operational and political terms and can only be considered by LCA in relatively abstract ways. Secondly, the modelling of full life cycles for systems as complex as those required to manage whole waste streams is practically impossible and diverges substantially from the original scope of LCA as a process assessment methodology. A valiant attempt can be made, but the process itself inevitably resembles a ‘black box’, the box being dependent upon the quality of what becomes an incredibly large amount of data, much of which is frequently out of date by the time the assessment is carried out. More importantly, the black box is somewhat impenetrable for stakeholders seeking to assess the validity of the process and of the outcomes, at least for all but the most technically knowledgeable. The results are inevitably susceptible to challenge by specialists, due to the fundamental impossibility of representing all possible impacts of all options in the analysis; resulting in the general perception that ‘it is much easier to criticise a BPEO assessment than it is to do a good one’.

A key feature of the BPEO approach was that decision-making should be transparent and that an audit trail should be created so that all stages in the choice of the BPEO could be scrutinised12. In its First Report the Royal Commission pointed out that there is no completely scientific and objective means of striking a balance between environmental and other considerations. For this reason, they wrote in their Twelfth Report:

“Openness and accountability are central to BPEO. The reasons for a decision, and the value judgements which necessarily underlie it, should be clearly identified and there should be the widest possible opportunity for others who may be affected to contribute to the decision. If the grounds for a particular decision are clearly understood, it can be more readily reviewed when assumptions or value judgements change”.

11 Making Waste Work – A Strategy for Sustainable Waste Management in England and Wales Cm 3040

12 DETR Guidelines for Environmental Risk Assessment and Management Revised Departmental Guidance



The need for effective public engagement in the determination of BPEO is seen as vital if the outcomes are to be accepted and if conflict in the planning process is to be reduced. Furthermore developments such as the Aarhus Convention13 and the emerging Directive on Public Participation in Environmental Decision Making will require full and open engagement. BPEO assessments which are primarily LCA based are rarely compatible with this key requirement.

Whilst stakeholders from all sectors appeared to agree that the Royal Commission’s definition had validity in waste management decision making today, it was generally agreed that it contained a fundamental conceptual weakness, in that it presumes that a single ‘preferred option’ will have validity over both the short and long term. To summarise the views of stakeholders consulted within the project, it was felt that this facet of the definition was fundamentally at odds with the reality of the pace of change within waste management (both political and technical); and that the definition, especially given the complexity of the ‘assessment process’ which an attempt to identify what is ‘best’ would logically demand, effectively creates a situation where ‘the best is the enemy of the good’, and where in any case, what the process defines as ‘the best’ may simply be undeliverable. Stakeholders expressed the view that, especially in the current environment, in which policies are changing quickly and where there is (as discussed earlier) some uncertainty about rates of waste growth, flexibility within strategies is paramount. We therefore recommend that Government provides a framework within which the BPEO concept can be interpreted in such a way as to allow time dynamics and flexibility to be incorporated into the concept. Life-cycle assessments are based upon comparative static analysis and whatever role they may have in selecting from alternative industrial processes, they do not deal particularly well with the dynamics of complex strategies which are often written for a period of twenty years or more.

Since PPG 10 and Waste Strategy 2000, BPEO has arguably become an increasingly problematic concept in its application within waste management and planning. This situation recently came to a head with a High Court judgement (R v Derbyshire County Council ex parte Blewett) that appeared to suggest that BPEO is ‘more than’ a material consideration in any application for planning permission for a waste management facility. An implication of the judgement might be that all but the smallest waste management proposals may, in future, need to be supported by a tailor-made, area specific BPEO assessment. Waste Planning Authorities who grant permission without such assessments being considered will run the risk of judicial review. Even if this judgement is overturned in the appeal courts, it represents the current end point in a trend of case law regarding BPEO which, in the view of the overwhelming majority of stakeholders consulted, renders the application of the BPEO concept in its current form unsustainable. In particular, we share the view of many of the stakeholders (from all sectors) that the expectation that is currently being created for all significant waste planning applications to be supported by a BPEO assessment as currently conceived must be reversed if facilities of all kinds are to be developed to a timescale in line with the implications of Government targets and policy. The proliferation of such assessments could simply paralyse the development of waste facilities rather than streamlining the process, which almost all stakeholders recognise as being necessary.

Given the new requirements for Waste Development Plans to be supported by a Strategic Environmental Assessment (SEA) as outlined in the SEA Directive (2001/42/EC) and a Sustainability Appraisal, it is our view that the implicit requirement for them to be supported additionally by a BPEO assessment is unnecessary, and over burdensome to the extent of risking non-delivery of Plans to a timescale compatible with the Landfill Directive targets. Our interpretation of the SEA requirement suggests that it is likely to be impossible to fully integrate BPEO assessment as required by Waste Strategy 2000 with SEA and it is therefore our view that the remit of BPEO assessment should be limited to one which focuses on technical waste management system issues to inform the overall SEA rather than attempting to be the SEA. We therefore recommend assessment of the BPEO should fall within the remit of the

13 Convention on access to information, public participation in decision making and access to justice in environmental matters, Aarhus 25th June 1998.



MWMS as opposed to the Waste Development Plan and that PPS 10 should make this position clear. The approach to application of BPEO concept within the MWMS process has been considered above.

6.2.2 The Waste Management Hierarchy All stakeholders generally agreed that a simpler method for prioritising environmental considerations is required in decision making, provided that the quality of decisions is not compromised. It is our view that, notwithstanding some exceptions, the hierarchy provides a foundation for such a method. A growing number of extended cost-benefit analyses which have been carried out across Europe suggest that the hierarchy is at least a reasonable guide as to what might be the Best Environmental Option. The primary advantage that the hierarchy has over other methods for ranking the environmental performance of options is its obvious simplicity, and given its consistency with much European and indeed national policy, as well as much public sentiment, there seems little reason why it could not be practically applied, provided that guidance takes account of its weaknesses.

Most of these relate to the relative rigidity and linearity of the hierarchy, which is probably the source of the most obvious difficulties that people have had with applying it practically. However, this apparent shortcoming should be relatively straightforward to overcome. Applying the hierarchy should obviously not imply that it should be assumed, for example, that all recyclable materials will be captured at a rate of 100%; rather that they should be targeted for recycling; and even then, not necessarily immediately. Strategies will obviously have to be dynamic, and recognise that the capture rates of recyclables will vary during the strategy period (hopefully upwardly) and that few, if any, materials will be captured with 100% efficiency in the foreseeable future. The object of a strategy therefore should be to prioritise initiatives to maximise prevention and recovery at different points on the timeline, taking account of the relative scale of availability of different materials in the waste stream (i.e. there is more paper than glass in household waste), their bulk density (from the point of view of designing and costing collection and transport logistics), their value as commodities, their relevance in the context of key drivers (for example, whether they are biodegradable), the proximity of reprocessing facilities and the potential for emerging markets, technologies or treatments to reprocess, to capture or recover value from them more effectively at a later date.

The approach would therefore be for Strategies or Plans to be designed on the basis that proper consideration should first be given to waste prevention (in terms of policies and initiatives), following which materials should be targeted for recycling and composting/digestion in accordance with a logical analysis of priorities and projected capture efficiencies. After this, residual waste should be treated in such a way as to maximise further recovery of value and minimise the environmental impacts of its disposal. This seems consistent with the general and specific direction of Government policy, but perhaps most importantly represents a simplified methodology for arriving at the conclusions that Strategy and Plan making processes invariably tend to arrive at in any case. In fact, almost without exception, the Strategies that we reviewed could be summarised as saying (even where they did not always include much by of operational details as to ‘how?’) ‘we will prevent waste from arising where we can, then recycle / compost as much of it as we can, and finally recover value from material that we cannot wither prevent from becoming waste or recycled.’ It should be noted that a presumption in favour of the hierarchy would not prevent an analysis from suggesting that specific materials should not be targeted for recycling; rather that such decisions would have to be well justified in the analysis. So, that rather than an elaborate BPEO analysis being used to justify – often controversially – one from a range of a small number of system options, with not much by way of evolution over time, the presumption would be in favour of the hierarchy, except where good arguments could be presented to the contrary, and with the movement up the hierarchy increasing over time.



6.2.3 The Proximity Principle We have given considerable thought to issues surrounding the application of the proximity principle and regional self sufficiency, from the point of view of simplifying the relationship between these concepts and clarifying their application in Strategy and Plan development.

It is our view that the proximity principle need only be applied ‘in full’ to operations for waste disposal, as opposed to reuse or recovery. In our interpretation, this would be consistent with the Waste Framework Directive and broadly consistent with Waste Strategy 2000 (although there are a small number of instances where the terms ‘managed’ or ‘dealt with’, as opposed to ‘disposed of’ are used).

In our opinion, the decision making process would benefit from clarification along these lines, leaving debates regarding the application of the proximity principle to discussion of appropriate scale of residual waste treatment or disposal facilities, thus avoiding potential for direct conflict with the hierarchy. The decision as to whether a particular material should be targeted for recycling or not at any particular point in a strategy timeline would then be the subject of logical cost-benefit analysis, rather than a complex debate related to the proximity of reprocessing facilities relative to other options. This approach is obviously consistent both with the aim of not designing long term plans simply based on the current paradigm (in terms of proximity of recyclate markets), as well as with the fact that the movement of materials collected for recycling is governed by the same global economic forces as are primary resources. Within the UK, the movement of materials is already subject to one of the highest rates of fuel duty in the world, internalising much of the environmental impact of transport.

We also recommend that the position of non-road transportation of waste be clarified in relation to the proximity principle. Waste Strategy 2000 states that alternative modes of transport should be considered and ‘a longer journey by river or rail may be environmentally preferable to a shorter road journey’. Practice guidance should be provided to assist decision makers in evaluating the relative costs and benefits of non-road transportation methods, in order to facilitate better direct comparison.

6.2.4 Regional Self Sufficiency It was the generally accepted view of stakeholders that it is not sensible for regional self sufficiency to restrict cross border transfer of wastes where the adjoining region can offer more proximate disposal facilities. The proximity principle ought, therefore, to be the prior consideration and it is not clear what the concept of ‘Regional Self Sufficiency’ really adds to the decision making process. Indeed, it is probably not sensible or practical for all regions to be self sufficient in all waste management capabilities (this is particularly obviously the case for materials reprocessing facilities). Even so, the work of waste strategists (especially the RTABs, who have to deal with the longest ‘frontiers’) is often complicated by complex waste flow modelling of imports and exports. Whilst some of this is of value and needs to be understood, it rarely captures ‘real world’ dynamics and can be an example of a conceptual principle being ‘excessively applied’, as resources, time and energy are expended with independent regions trying to devise abstract ‘optimal’ cross boundary strategies. The concept of self sufficiency is obviously of merit and, we assume, is intended to place emphasis on the need implicit within the objective of the proximity principle to:

“…avoid passing the environmental costs of waste management to communities which are not responsible for its generation” (Waste Strategy 2000)

We would therefore recommend that Government provides clarification as to the relative roles of the proximity principle and regional self sufficiency in decision making, preferably, in our view, making explicit the primacy of the proximity principle. In other words, regional self sufficiency is more of a conceptual ‘aspirational’ objective than a specific requirement, but that regional and local decision makers should recognise that it is unacceptable to rely on exporting wastes (especially for extended periods of time) unless the application of the proximity principle would otherwise be compromised.



6.3 Integrating Development Plans and Strategies As discussed above, it was almost unanimously the view of stakeholders that MWMSs and Waste Development Plans should be better integrated in future than is generally the case now, and that this should be facilitated by better integration of waste management and planning policy. However, views differed (in particular between Local Authority planners and waste managers) as to how this could best be achieved. The most commonly raised issue was the fact that MWMS and Waste Development Plans differ in scope, with Strategies being concerned with MSW and Plans dealing with all wastes. Other issues concerned the fact that Plans are statutory for all areas, whilst MWMSs will only be statutory for some; that in some cases (e.g. some Unitary areas that have a joint Plan but their own Strategy) the geographical scope can also vary; and that sequencing of Plan and Strategy development might not fit with an ‘ideal’ policy and would be dictated by the prevailing situation in individual areas.

The imminent replacement of Development Plans in their current form with Development Frameworks presents some practical opportunities to facilitate better integration with MWMSs. Local14 and Waste Development Frameworks will comprise a ‘folder’ of documents, including Development Plan Documents (DPDs, which have full Development Plan status) and Supplementary Planning Documents (SPDs, which will not have Development Plan status, but will be material considerations in the determination of planning applications). Not only should the ‘new’ documents and process be more flexible and responsive (in part due to their ‘modular’ nature), but the new structure allows for the possibility for the Municipal Waste Management Strategy to become a SPD within the folder. This concept was generally well received by stakeholders, with no objections to the principle being expressed, although some expressed reservations as to extent of its practical applicability. It is therefore our view that, through PPS 10 and Guidance on Municipal Waste Management Strategies, Government should set an expectation that MWMSs should be adopted as SPDs, without making such an approach mandatory.

Perhaps more importantly, it is our view that the processes through which each is developed should become more integrated. Waste managers should be considering land use and to some extent spatial issues in the development of Strategies and planners should equally be considering strategies for both waste collection and disposal service development in the preparation of their Development Plans. It is perhaps over simplistic (and to some extent at odds with the scope and sequencing issues raised above) to say that Strategies should be determining how waste is to be managed with Plans determining where, but this type of logic should ideally feature in the process as much as possible. On the issue of scope our views are as follows:

• MWMSs should continue to be primarily focused on MSW; municipal waste management services are becoming rapidly more challenging to provide cost effectively, and a strong focus on these challenges is essential.

• However, they should have regard to other waste streams not necessarily managed by Local Authorities, especially commercial and industrial wastes. This is because, in our view and that of many of the stakeholders we consulted from all sectors, it is impossible to develop a wholly rational strategy for municipal waste in isolation from other wastes. In reality, wastes with similar properties are generally treated in similar or the same facilities and it is neither logical nor viable to imagine, faced with their proliferation in the medium term, facilities being duplicated in a given catchment area for wastes from different sources.

14 Unitary Authorities will not have a duty to produce a separate Waste Development Framework, in the same way that they can discharge their plan making duties for waste through their Unitary Development Plans at the moment. However, they will have the option to produce a WDF if they wish, either unilaterally or in partnership with neighbouring Waste Planning Authorities.



• This is obviously not to say that Local Authorities should be responsible for providing facilities for other wastes. Whilst in the planning system they are effectively responsible for planning for them, in the case of waste managers, it should rather be a case of best practice, or indeed best value. Increases in the Landfill Tax and measures within the Landfill Directive, as well as the Animal By-products Regulation, will directly impact on private sector waste producers, incentivising landfill diversion. Coupled with this, developments of major waste facilities are, and are likely to remain for some time, predicated on a guaranteed tonnage of MSW in order to make them bankable. For these reasons, even before the land use planning system is considered directly, Local Authority waste management strategies are likely to be key to delivering sustainable management of wider wastes. Authorities wishing to deliver cost effective services will need to ‘partner’ MSW with wastes from other sources, particularly in treatment, and should be able to benefit financially by doing so. These financial benefits may relate to collection as well as treatment, since the logistics of municipal waste collection may be significantly improved through including non-household wastes in collection rounds.

• This approach to strategy thinking is not simply about economies of scale. Local Government is actually in something of a strong position in having the key to unlock finance for waste treatment facilities that will increasingly be required for all wastes. This advantage is likely to evaporate if it is not exploited, as the private sector will be forced to find alternative ways of financing investment in facilities for treating commercial and industrial wastes. Before it does so, given the scale of increased cost that Local Authority waste management services are facing, it is essential that ‘partnership’ with the waste management industry becomes exactly that. The industry will have to expand dramatically, often based on infrastructure investment supported by Local Authority wastes. The opportunity to offset increased cost by sharing in the wealth that will be generated by sustainable management of waste as a whole, through joint venturing and true partnership with the private sector, must be taken if we are to avoid the result of an irrational, over priced waste management system.

• So, in modelling the costs and performance of systems for managing MSW, setting policies or agreeing procurement strategies, Local Authority waste managers should be incorporating wider wastes into their thinking. They should know what types of waste are generated in their area. They should be consulting with the private sector, particularly those companies with a strong presence in their areas, so that local market conditions for wider wastes can be factored in. In the longer term, it is not impossible that MWMSs with the same scope as Waste Development Plans will become the norm. Until then, it is essential that Local Authority waste managers begin to make steps towards incorporating wider wastes into their Strategies.

In practice, better integration of Plans and Strategies will occur as a result of planners and waste managers working more closely together. The deliverability of Strategies will depend on the planning system, and land use issues will only be factored into them if planners are involved in their development. Similarly, it will not be possible for planners working in relative isolation from waste managers to develop policies and specify sites capable of delivering the Strategy without the expert input of waste managers. Although this joint working does happen in most Authorities to some degree, the overwhelming majority view of stakeholders was that the more that this is done, the better the result; and that almost all Authorities could be doing more. The approaches that work best in terms of current practice seem to be variations on the concept of the ‘Virtual Authority’, established as a vehicle for joint working between Authorities. The simplified Venn diagram below illustrates the concept in the context of MWMS and Waste Development Framework development in a two-tier area with Unitary Authority partners.



Figure 6 – Virtual Authority Concept

WDF MWMS

'Virtual' Authority- WDAs - WCAs - Unitaries

Waste ManagersPlanners

Plus Finance Officers, Lawyers,Strategic Procurement Officers,

Marketing and Senior Management

Where circumstances allow, it should be possible for the MWMS and Plan making processes to be combined, ideally with a single project plan being developed for both processes, allowing optimum sequencing (and some iterative logic) to be achieved. In particular, it is most important that duplication of effort is minimised and that the work on each process that directly affects or informs the other is carried out in the ‘right’ order. Given the new requirements for SEA and SA to be carried out (indeed, it is not inconceivable that MWMSs will also fall under the SEA regime), that will necessitate, in particular, community engagement at several stages. It will be important to try to integrate aspects of both processes in order to avoid duplication or conflict and minimise the potential for ‘consultation fatigue’ amongst the public.

More work is required to establish precisely how these emerging processes can best be configured and Government should give consideration to the practical implications of better integration of Plan making and Strategy development in the practice guidance that will support PPS 10 and Guidance on Municipal Waste Management Strategies. Whilst the issues involved are, without doubt, complex, the practitioners involved in this project unanimously expressed a desire and commitment to bring these processes together, and it is our view that the benefits of better integration substantially outweigh the challenges.

6.4 Wider Institutional Arrangements Whilst it is generally accepted that better integration of Plans and Strategies at the local level makes sense, it is not possible to begin to draw conclusions as to how such new ways of working would be executed in practice without considering the local level in the context of wider Government functions in waste management. In particular, the role of Regional Government in the current system, and its potential role in future, were raised as key issues at all of our stakeholder events. Views expressed varied enormously. The observation was made that the current generation of Regional Waste Strategies has been resource intensive, but that due to their lacking a sufficiently well-defined role, they have little prospect of having a real impact. On the other hand, the view was expressed that strategy and even Plan making should effectively be carried out at the regional level, for a number of reasons. These included the perception that local Plan making is currently too ‘political’ and that more objective decisions would be made if local decision makers were more ‘insulated’ from local controversy; that local Plans and Strategies can sometimes come into conflict with one another within regions and should be better coordinated; and that duplication of effort within already-stretched planning and waste management departments within Local Authorities is inevitable in the current system.



The reform currently underway within the planning system presents a particular opportunity here. The Regional Waste Strategies, effectively authored by the RTABs, were intended to inform Regional Planning Guidance (RPG), which is produced in each region by the Regional Planning Bodies (RPBs). However, RPG does not have statutory force and is rather intended to provide a framework of guidance for development within regions. This will change with the replacement of RPG by Regional Spatial Strategies (RSS), which will not only have statutory force in their own right (local Development Plans will have to be ‘in line’ with RSS), but will also become part of all Development Plans in their region; effectively meaning that they will form part of the Plan in the plan-led system in determining individual planning applications. Whilst Guidance will make clear that strategic decisions should be made ‘at the most appropriate level’, this change will undoubtedly allow planning at the regional level to have a greater impact upon local decision making.

Our views on these issues developed during the project, informed by the stakeholder meetings conducted at various stages. In particular, we presented a number of options covering the roles and responsibilities of different levels of government at the final multi-stakeholder workshop held in May 2004 with the intention of provoking discussion between representatives of all of the sectors with whom we had previously consulted. Within the context of an overall discussion of ‘who should do what, how and when?’ we considered the following questions:

i. What is the right balance to strike between a ‘command and control’ and a ‘market based’ policy on facilitating the development of the facilities required to meet our Article 5 obligations, given the current direction of wider policy?

ii. What is the right level for different responsibilities to be discharged?

iii. Given past experience, is greater ‘insulation’ of local decision makers an essential prerequisite to the delivery of facilities required by Government aspirations for landfill diversion?

iv. Is it possible to envisage less emphasis being placed on local strategy, given the responsibilities of local authorities to deliver through procurement?

v. What degree of political and technical responsibility can Regional Government realistically be expected to discharge, given the relative immaturity of institutions?

Our conclusions here, although somewhat broad, are of value in considering what the ‘right’ balance of roles and responsibilities might be:

• Local Government has responsibility for delivering (and paying for) municipal waste management services and for making decisions on specific development proposals. Whilst there are attractive arguments for devolving Strategy- and Plan- making responsibilities up to the regional level, this is unlikely to be viewed as compatible with local democratic accountability and past experience has shown that where community buy-in is absent from the decision making process, proposals for developing controversial facilities are likely to face stern opposition. Local Government is still best placed to deliver that buy-in and the alternative would be likely to result in fragmentation and conflict between tiers of Government in some cases. In considering the implications of such devolution to the regions in detail, stakeholders expressed little in terms of real appetite for such a fundamental change;

• Furthermore, current Government policy for ensuring compliance with the Article 5 Landfill Directive targets (in particular the advent of LATS) is based on the assumption that the market based solutions will be most the cost-effective route to delivering compliance. The mechanism to be employed, whilst predicated on the widespread development of real facilities on the ground, explicitly leaves strategic decision making to WDAs. Devolution to the regions would be incompatible with this policy;



• However, it is our view that the opportunities offered by the advent of RSS in terms of facilitating clearer leadership and better coordination should be exploited. Whilst freedom to develop detailed strategy must be retained at the local level, it is essential that local decision makers are provided with a better framework for rational decision making. In particular, the extent of ‘need’ for waste management capacity should be established at the regional level. The regions should also assume responsibility for planning directly for capacity that is of genuinely regional significance; for example, hazardous waste treatment and disposal capacity, and, increasingly (as facilities become fewer, but potentially larger), landfill;

• Perhaps most importantly, the regions (perhaps through re-constituted and better resourced RTABs) should take a greater role in facilitating and ensuring better coordination of work at the local level. In particular, as techniques for treating all wastes become more sophisticated, it is likely that the typical ‘mass balance’ of waste management systems at the local level will change, resulting in a need for management capacity to equal significantly more than the total of wastes that arise. Technologies such as MBT will result in large throughput facilities that produce outputs of perhaps up to 75% of input material and in some cases residual wastes may be treated by perhaps three processes on three separate sites, each producing smaller proportions of residua, all of which will require further treatment or disposal. The regions will have a role in insuring that, beyond the need for the requirements for the Landfill Directive to be complied with at a local level, facilities are planned for the whole life cycle of new waste management systems; and

• It is our view that there is also a key role for central Government here. Our review of MWMSs has revealed that approaches to determining how much waste will need to be managed (in terms of projecting waste arisings) and evaluating the capacity that may be required in future relative to existing and planned capacity varies significantly across the country. It would be helpful to those planning for waste management at the regional and local level if some indication of the medium to long term level of waste management capacity need could be provided centrally, either through the provision of a national assessment or of a nationally adopted protocol for projecting arisings. It is also our view that it is essential that Government, perhaps through the Environment Agency, provides better information on existing and planned capacity and actual throughputs at the regional or ideally WPA level. This could be achieved through the current reform of the waste permitting system, by requiring waste facility operators to provide data on capacity, throughput and output to the Agency. The waste management industry has expressed a commitment to provide such data on their activities as is required and, in particular, such information is likely to form key the ‘market intelligence’ that Local Authorities will require of the LATS market is to be effective.

In conclusion, it is our view that responsibility for detailed Strategy development and Plan making should be made at the local level, but that the regions, through high level RSS, should provide a simple framework within which these processes can take place, focused on management capacity need rather than specific technologies or sites, apart from in cases of genuine regional significance. This approach would limit the potential for duplication and conflict, but would be reliant upon a coordinating and facilitating function being developed at the regional level, supported by better data and clearer indication of need from central Government.



7.0 Conclusions and Recommendations This project has been wide ranging and the report as a whole covers a not inconsiderable territory and range of issues. This section provides a summary of the conclusions and recommendations presented throughout this report.

1. Stakeholder dialogue has been an essential feature of this project and it is our view that significant value can be added to future WIP and other Government projects in this field by adopting such approaches.

2. Stakeholder dialogue has revealed that broad consensus exists across professions and sectors regarding the issues covered by the project. In particular:

a. That the provision of frameworks for better, more robust, but simpler and speedier decision making are a prerequisite for implementation of facilities and services at the scale required to meet Government aspirations for landfill diversion;

b. That such frameworks must be based on and supported by clearer policy principles and practice guidance and that stronger leadership is required at all tiers of Government; and

c. That the focus of national and local Government on municipal (and principally household) waste fails to reflect the operational and economic realities of waste management systems and thereby increases the risk of failure to attain objectives for those very waste streams.

3. Almost all current Strategies serve a purpose as high-level strategic documents. However, whilst they are generally strong on establishing the destination and gathering some of the tools needed to get there, they often fail to provide a complete route map. The next stage in strategy development practice will be about operationalising those high-level plans, both in terms of delivering technically robust route maps based on sound analysis and of providing compelling business cases for investment that are capable of delivering commitment from Members and Chief Financial Officers. In particular, Strategies will need to:

a. Be based upon more sophisticated technical analysis, with the service development plans of all partner Authorities more fully represented;

b. Be founded on assumptions which can be defended, and critical analysis of current performance and the drivers of improved future performance, so that robust, best value plans that can be sold to Members, senior managers and the public;

c. Take more account of cost and wider economic issues, and really drive home what will increasingly become undeniable business cases for investment;

d. Show appreciation that the strategy process is a living one, and that the dynamics of this process have to be recognised through plans for periodic and ongoing review so as to understand performance against targets and aspirations, and so as to anticipate, and adapt to, new circumstances; and

e. Involve the community more, at more stages, to minimise the risks to deliverability associated with, in particular, the development of controversial waste management facilities and lack of public engagement in new services.

4. Considerable commitment to, and support for, integrating the Strategy and Waste Development Plan making processes exists, but such integration will only be achieved through better integration of Defra and ODPM policy and Guidance. PPS 10 and Guidance on Municipal Waste Management Strategies should therefore create an expectation that, where possible, the MWMS should form a



Supplementary Planning Document within the Local or Waste Development Framework ‘folder’, but that this approach should not be mandatory. A broad expectation should also be created that spatial and land use issues should be considered within MWMSs and that the needs of MWMSs should be catered for directly in Waste Development Plans;

5. On the difference in scope of MWMSs and Waste Development Plans, MWMSs should continue to be primarily focused on MSW; municipal waste management services are becoming rapidly more challenging to provide cost effectively and a strong focus on these challenges is essential;

6. However, they should have regard to other waste streams not necessarily managed by Local Authorities, especially commercial and industrial wastes. This is because, in our view and that of many of the stakeholders we consulted from all sectors, it is impossible to develop a wholly rational strategy for municipal waste in isolation from other wastes. Opportunities to deliver best value in MSW management services will inevitably be compromised where this is not the case;

7. The advent of the ongoing reform of the land use planning system, in particular the replacement of Regional Planning Guidance with Regional Spatial Strategies offers a number of opportunities to improve the configuration of institutional arrangements between the various tiers of Government. However, policy should retain the principle of decisions and responsibilities being discharged at ‘the most appropriate level’ and detailed strategy development should not be duplicated between tiers; in the case of Waste Development Plan making and MWMS development, the responsibilities that they entail should continue to be discharged by Local Authorities;

8. Having said this, opportunities offered by the advent of RSS in terms of facilitating clearer leadership and better coordination should be exploited. Whilst freedom to develop detailed strategy must be retained at the local level, it is essential that local decision makers are provided with a better framework for rational decision making. In particular, the extent of ‘need’ for waste management capacity should be established at the regional level. The regions should also assume responsibility for planning directly for capacity that is of genuinely regional significance;

9. Perhaps most importantly, the regions (perhaps through re-formed and better resourced RTABs) should take a greater role in facilitating and ensuring better coordination of work at the local level. In particular, as techniques for treating all wastes become more sophisticated it is likely that the typical ‘mass balance’ of waste management systems at the local level will change, resulting in a need for management capacity to equal significantly more than the total of wastes that arise. Technologies such as MBT will result in large throughput facilities that produce residues of perhaps up to 75% of input material and in some cases residual wastes may be treated by perhaps three processes on three separate sites, each producing smaller proportions of residua, all of which will require further treatment or disposal. The regions will have a role in insuring that, beyond the need for the requirements for the Landfill Directive to be complied with at a local level, facilities are planned for for the whole life cycle of new waste management systems;

10. It is our view that there is also a key role for central Government here. It would be helpful to those planning for waste management at the regional and local level if some indication of the medium to long term level of waste management capacity need could be provided centrally, either through the provision of a national assessment or of a nationally adopted protocol for projecting arisings. It is also our view that it is essential that Government, perhaps through the Environment Agency, provides better information on existing and planned capacity and actual throughputs at the regional or ideally WPA level. This could be achieved through the current reform of the waste permitting system, by requiring waste facility operators to provide data on capacity, throughput and output to the Agency. The waste management industry has expressed a commitment to provide such data on their activities as is required and, in particular, such information is likely to form key the ‘market intelligence’ that Local Authorities will require of the LATS market is to be effective.



11. On decision making, there is a need for the policy framework and principles currently offered to be clarified and in some cases simplified; we would recommend the following:

a. On the role of assessment of the BPEO; it is our view, reflected broadly by the opinions of practitioners from all sectors, that current policy and practice is unsatisfactory. With the advent of other assessment methodologies such as SEA and SA at the Plan making stage and EIA in development control, there should no longer be a direct role for the assessment of the BPEO within the land use planning system for waste. Rather, the principles of the waste management hierarchy, the proximity principle and self sufficiency should be applied with common sense in the context of these other assessment regimes, having regard to BPEO assessment carried out within the MWMS development process. Appropriate interpretation of BPEO should be clarified through policy, placing greater emphasis on the need for time dynamics to be considered and less emphasis on the need to identify a single ‘best’ solution in both the short and long term. The role of LCA in BPEO assessment should also be revised; rather than being the ‘recommended’ approach to whole system assessment, it should form one of a suite of methodologies, with greater emphasis being placed on the need to base assessment on operational realities and to avoid more abstract analysis;

b. On the application of the waste management hierarchy; it is our view that the hierarchy provides a simple yet robust framework for strategy development and tends to result in Strategies that are well aligned with political and community aspirations. Essentially, it is our view that the hierarchy should be used to determine what action should be taken in terms of targeting different waste streams or materials for minimisation, reuse, recycling or further recovery, as opposed to being a mechanistic, inflexible ‘rule’. In other words, it should be assumed that the hierarchy is applied, but that the extent to which waste will be able to be realistically dealt with at each tier should be determined through sound analysis. In principle, residues produced by one tier should be dealt with by the next tier down, and tiers should not be ‘skipped’. Where a particular waste stream or material is not to be managed in accordance with the hierarchy, the onus should be on the strategy to demonstrate through sound analysis why this is the case, through the use of techniques such as cost-benefit analysis or LCA.

c. On the application of the proximity principle; It is our view that the proximity principle need only be applied ‘in full’ to operations for waste disposal, as opposed to reuse or recovery. This approach would be consistent with the Waste Framework Directive and broadly consistent with Waste Strategy 2000 and in our opinion, the decision making process would benefit from clarification along these lines, leaving debates regarding the application of the proximity principle to discussion of appropriate scale of residual waste treatment or disposal facilities, thus avoiding potential for direct conflict with the hierarchy. The decision as to whether a particular material should be targeted for recycling or not at any particular point in a strategy timeline would then be the subject of logical cost-benefit analysis, rather than a complex debate related to the proximity of reprocessing facilities relative to other options. This approach is obviously consistent both with the aim of not designing long term plans simply based on the current paradigm (in terms of proximity of recyclate markets) and the fact that recyclate movement is governed by the same global economic forces as primary resources (and indeed generally displaces transport of primary resources to the benefit of the environment). We also recommend that the position of non-road transportation of waste be clarified in relation to the proximity principle. Waste Strategy 2000 states that alternative modes of transport should be considered and “a longer journey by river or rail may be environmentally preferable to a shorter road journey”. Practice guidance should be provided to assist decision makers in evaluating the relative costs and benefits of non-road transportation methods, in order to facilitate better direct comparison.

d. On regional self sufficiency; We recommend that Government provides clarification as to the relative roles of the proximity principle and regional self sufficiency in decision making, making explicit the primacy of the proximity principle. In other words, regional self



sufficiency should become more of a conceptual ‘aspirational’ objective than a specific requirement, but that regional and local decision makers should recognise that it is unacceptable to rely on exporting wastes unless the application of the proximity principle would otherwise be compromised.

12. With regard to support needs, Government should recognise that, whilst there is widespread practitioner support for better integration of more sophisticated Waste Development Plans and MWMSs, skills gaps and, perhaps more importantly, resourcing gaps will need to be filled if such an expectation is to be created. Specifically, we recommend:

a. That consideration is given to the resourcing implications of PPS 10, Guidance on Municipal Waste Management Strategies and any accompanying practice guidance and that this consideration includes options for funding capacity within both local Authorities and regional Planning bodies to allow these more involved processes to be carried out to timescales that are compatible with Government aspirations for landfill diversion;

b. That practice guidance, tools and practical support are provided to assist in improving practise in the areas of performance analysis, waste arisings projection, cost modelling, risk management, residual waste treatment and community engagement thorough the provision of written guidance and by refocusing existing Government funded programmes on the specific needs of Waste Development Plan and MWMS developers;

c. That new programmes are developed to assist in the dissemination of best practice in sustainable waste management, covering waste prevention, collection, CA site management and residual waste treatment. A programme of peer review and mentoring, allowing good practice and experience to be shared between Local Authorities should also be initiated, supported by the IDeA, Defra, and WRAP; and

d. Defra should dedicates resources to comprehensively collecting and updating information on existing support services and organisations and information sources which should then be provided through a ‘waste information and support signposting portal’ on the WIP Local Authority Support Unit web site.

Many of the above issues will imply the need for additional resources in the years to come. It is inevitable, however, that new investments are required in order for the UK simply to meet legal obligations, let alone to meet the more encompassing objective of making waste management more sustainable. The resources which are needed are likely to be repaid (albeit not transparently) in improving the value of the investments made, in ensuring that the investment plans proposed are in line with actual requirements for facilities, in improving the value of services procured, in making investment strategies more sensitive to the time profile (improving flexibility to respond to changing circumstances), and in improving the quality of public engagement (so potentially reducing objections to unpopular facilities). There is considerable scope for improving the process of strategy formulation, and opportunities exist to make the development of plans and strategies more rational, and mutually compatible. The prize is a more streamlined and sustainable approach to waste management which has more support from citizens, and which is less burdensome for those seeking to provide facilities and services on the ground.