I was recently asked by a colleague if I thought that innovation within the waste sector was sufficient by itself, to reduce Scotland’s extensive waste capacity shortfalls. Having thought about this, I think it’s clear that advances in technological capabilities can provide substantial improvements to waste processing opportunities and efficiencies. However, the critical factor to the delivery of such facilities across Scotland is, as you can imagine, their ability to negotiate the planning system.
Whilst environmental permits and licenses can address pollution prevention control matters, the expedient delivery of a waste management facility hinges upon the principle of development being established through planning approval.
Clearly the Scottish Government is advocating a strong approach to promote sustainable resource recovery and deliver its ‘zero waste’ ambitions. Specifically, in recent years there have been numerous measures that build on Scotland’s Zero Waste Plan including: The Government’s Online Planning and Waste Management Advice and the Planning for Zero Waste requirements within Scottish Planning Policy. Scottish Environment Protection Agency (SEPA) is also assisting by preparing a raft of helpful guidance notes and creating waste capacity tables that can be interrogated to ascertain underlying demand for such facilities. However, perhaps there is scope to summarise the overall waste capacity shortfall within these tables to re-emphasise the undersupply of these facilities across Scotland. I think that these approaches move the policy argument in the right direction and that decision makers have a range of positive policy objectives through which to support such facilities.
Similarly, the removal of the proximity principle and areas of search approach has ensured that there is no longer a requirement to consider the location of waste sources when determining the suitability of new facilities. Rather, a development’s ability to address nationwide capacity requirements is a critical consideration - helping to create the potential for what Zero Waste Scotland see as a ‘Zero Waste Society’. This is a game-changer and a real positive outcome to support waste facilities across Scotland.
This follows the renowned Carnbroe waste case which digressed both the Inner and Outer Houses of the courts to substantiate that waste could be transferred beyond local authority boundaries. In essence, what I used to call a ‘Scottish-wide’ approach to addressing waste capacity during my time as Zero Waste Planning Officer at SEPA.
Importantly, the Scottish Government’s Online Waste guidance makes reference to this, stating that waste infrastructure capacities should not be treated as limits. This, in turn, moves the argument towards the creation of waste need rather than the proximity of individual waste sources themselves. It therefore provides an opportunity to cater for waste demand throughout Scotland by developing a variety of waste management facilities to accommodate nationwide demand for respective waste streams rather than (confined) local demand.
In principle, if the demand is there, the policy can support it. Whilst the legislative and regulatory framework for waste management in Scotland is changing, there is scope to provide new facilities that will enable the realisation of waste hierarchy principles. Specifically, for the provision of greater opportunities to prevent, reuse, recycle and recover waste prior to its disposal into landfill (which, itself, should only form 5% of all waste by 2025 if the Government’s targets are to be achieved).
So, coming back to my original question, it would seem that there is strong policy support for such facilities and innovation in the waste sector can certainly help, in part, address waste capacity shortfalls. However, I think there’s perhaps an opportunity to let the decision makers know that this is the case. I believe that a general fear from local communities may be at the forefront of decision maker’s minds, particularly when such applications are determined at Committee. Strong, mobile and opinionated community groups will always have a strong message to convey, particularly when words like incineration, gasification or anaerobic digestion are used. Additionally, the complex nature of such technology can often be misunderstood or potential amenity impacts grossly overestimated. Ultimately, if we are to avoid the longevity and timescales associated with ‘approval by appeal’, it is vital for decision makers to be able to objectively understand that these technological innovations can ultimately help realise sustainable resources management objectives and deliver strategic Government objectives for waste minimisation.
It is therefore important that the industry continues to push ahead with the provision of efficient waste management facilities that can realise national ambitions for sustainable resource recovery. Now we just need to persuade the politicians and decision makers…..and find ways to educate the NIMBYs…
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