There are many positive and encouraging signs that the circular economy is gaining traction at relevant levels of public policy and beginning to embed itself within business strategies. However, one aspect which is perhaps overlooked is the critical role of the planning system in helping the UK to realise fully the environmental and economic benefits that flow from the circular economy (CE).
A new report from the Environmental Services Association (ESA), Planning for a Circular Economy, suggests a number of improvements to the planning system to ensure that it is more closely aligned with the strategic objectives of the CE. Despite some positive signs at the local level towards adoption of waste plans, the reality is that many new facilities are still bogged down by lengthy and costly planning delays.
As the industry seeks to position itself as resource provider for the wider economy, it needs a planning system which is not only more efficient, but one which is also capable of allowing the industry to optimally manage material flows and source sustainable end markets for society’s materials.
Arguably, the crux of the matter is not the system itself but a somewhat outdated planning culture which continues to prevail in one form or another within some planning authorities: a culture which is,, in many respects a legacy of the bygone landfill era.
The waste and recycling industry has changed beyond recognition since those ‘throwaway society’ days
It wasn’t that long ago that most of society’s waste was simply disposed of in landfill, with planning authorities regulating the supply of landfill capacity and controlling the daily operations of such sites. This was often done through detailed and prescriptive planning conditions.
However, the waste and recycling industry has changed beyond recognition since those ‘throwaway society’ days, and has instead aligned itself with greater levels of resource efficiency. This means more waste material is reused and recycled, and low-carbon energy is generated from any residual, non-recyclable wastes. While the transition has been a real success, the sheer pace of change has perhaps caught many planning authorities offguard, and left local plans and planning practices in many respects lagging behind.
The tendency of some planning authorities to impose restrictions on the movement of waste and recyclable materials (so called ‘catchment boundaries’) illustrates this point well. Catchment boundaries (where an authority aims to prevent a consented waste facility from receiving waste materials from neighbouring authorities or areas beyond its administrative boundaries) is an example of this strict control culture in action and points to a poor understanding of the dynamic commercial market that the recycling industry now operates in.
It is entirely reasonable to expect the sub-regional movement of waste and the movement of waste across local administrative boundaries, when collected waste may be bulked or recycled in one location, recyclables processed at another or residues treated or disposed of elsewhere. The planning system should therefore seek to promote the recycling and recovery of waste which enables movement of materials to areas where they can cost-effectively input into manufacturing processes.
Quite simply, the commercial landscape in which the waste and recycling industry now operates has changed considerably in recent years. In many respects the industry now resembles that of any other logistics enterprise: handling, processing and transporting materials as customers and commodity markets dictate.
Few other industries face the same planning or political obsession about the origin of material or commodities and where these should be transported to. To hamstring the waste and recycling industry unfairly compared with other businesses risks hampering investment in the CE rather than promoting it.
Planning authorities should refrain from duplicating the work of the Environment Agency by seeking to regulate pollution control issues through planning consent conditions
Of course, in no way should this be misconstrued as a call for deregulation. Instead the industry merely seeks greater flexibility around some aspects of planning consents which puts it on a level pegging with other, similar industries. Rigid, inflexible operating times, for example, fail to recognise the commercial market and the ever-changing demands of the industry’s customer base, many of which expect collections outwith the regular ‘nine to five’ time slot – for example, collection of waste from schools.
Similarly, attempts to control waste inputs through planning consent merely duplicates the environmental permitting regime, and is perhaps just one example of ’planning creep’ whereby planning authorities are seemingly reluctant to relinquish regulation of pollution control issues, despite such matters best left to the environmental regulator. This can lead to duplication in time and costs in the provision of information to competent authorities.
Planning authorities should therefore refrain from duplicating the work of the Environment Agency by seeking to regulate pollution control issues through planning consent conditions, and should instead work on the assumption that the relevant pollution and control regime will be properly applied and enforced when consented development seeks an application for an environmental permit.
The adoption of the CE, with much higher rates of resource efficiency and an emphasis on reuse and recycling, should not, of course, be at the expense of planning for continued provision of those tiers lower down the waste hierarchy. Energy from waste and landfill not only offer flexibility and, in the case of the former, low-carbon energy but, for the foreseeable future, will provide the safest and most viable option for the handling of wastes which for technical or environmental reasons cannot be managed further up the waste hierarchy.
Investments should not be stymied by something as simple as an unwillingness to shed preconceived notions of the sector
Few are likely to associate a continued need for landfill provision with a move towards a CE and the fact is that, in the dash to recycle, landfill seems to have fallen from grace. But it is worth bearing in mind that landfill is the only waste management option which is consumed as it is used and so some degree of replacement capacity is going to be required. Remaining capacity is increasingly under pressure, with planning for new landfill provision having largely ground to a halt and reduced rates of landfilling forcing the closure of many sites (a trend likely to continue in years to come).
For the future, capacity will likely be limited to a few, strategically located landfill sites and further demands will be placed on this remaining capacity as waste travels further afield for disposal. Without a more strategic, joined-up approach to planning for (and safeguarding) this resource, there is a risk that the resource efficiency models of the CE will not be fully realised. Higher rates of recycling, for example, are likely to be compromised without a disposal option for residues from the recycling and treatment process.
For those closed landfill sites, with no further operational use, a more flexible planning system should enable innovative use of the land in line with wider CE goals – for example, installation of solar parks or cultivation of energy crops.
The waste and recycling industry is well placed and eager to deliver the UK’s ambitions for a CE and looks to the planning system to help facilitate the delivery of much-needed waste management infrastructure. Investments should not be stymied by something as simple as an unwillingness to shed preconceived notions of the sector or to foster a greater understanding of new business models deployed by the waste and recycling industry.
Stephen Freeland, policy adviser, Environmental Services Association