MEMORANDUM BY REIGATE AND BANSTEAD BOROUGH
COUNCIL (DSW 118)
I refer to the memoranda which have been submitted
to the Environment Sub-committee on the subject of "Delivering
Sustainable Waste Management".
I appreciate that the time has passed for submission
of formal written evidence. However, following the recent submissions
of oral evidence, I felt I must write in my capacity as Chairman
of the Borough Council's Environmental Services Committee and
support the submissions of the Capel Action Group and the Planning
Reigate and Banstead Borough Council and our
neighbour in Mole Valley have been consulted by the Surrey County
Council on two proposed energy from waste plants in our areas.
In addition, we have been consulted by the County Council on their
latest Waste Local Plan. As a result the Borough Council has gone
on record on waste management issues in the following terms:
This Council strongly supports the
concept of geographical equity, whereby the responsibility
for dealing with waste must rest with the local level, in order
for the waste hierarchy to work. There is no incentive for households
to minimise their waste creation and, reuse, recycle or compost,
if waste is transported outside the locality for unseen disposal,
and where the real impacts of that disposal are imposed on residents
of other locations.
The residents of Reigate & Banstead
have already demonstrated their commitment to meeting the Government's
recycling targets, currently achieving a rate of some 23 per cent
of domestic waste and a participation rate of 65 per cent of households
in the Council's door to door scheme. The Council would, therefore,
support the inclusion of targets for recycling, recovering and
composting within any waste management plan, but these targets
must be progressively more challenging and be based on some form
The Council would strongly support
the inclusion in a waste management strategy of the concept of
environmental capacity and the imposition of limits to further
waste disposal facilities in areas already subject to our current
activities. However, the concept would need careful definition,
in particular in relation to traffic movements, and the Plan would
need to address how the County would ensure that capacity limits
are not breached.
Recent Government Guidance suggests
that waste disposal cannot be considered solely on a county by
county basis and Local Planning Authorities will need to give
consideration to the regional dimension. There are currently two
proposals for EfW plants (one with planning consent), adjacent
to Surrey's county boundaries, which may well affect disposal
patterns within Surrey. Regional agreements must first be addressed,
to avoid either unnecessary provision of facilities or locations
which perpetuate or increase waste transportation.
The Council supports the application
of Best Practical Environmental Option (BPEO). However, this will
mean that many more alternative disposal options and locations
will need to be tested, particularly including facilities higher
up the waste hierarchy. BPEO will need to be applied, both for
proposals within Waste Local Plans and for subsequent planning
applications as circumstances will change over the life of those
This Council does not support the
use of Green Belt land for major new waste disposal facilities.
This Council supports the identification
of specific sites within Waste Local Plans which would allow proper
consideration of alternatives against the application of the proximity
principle, BPEO and the waste hierarchy. From experience, the
private sector will select sites mainly on commercial grounds.
Reliance on a planning application-led approach is unlikely to
lead to an optimum strategic fit for major proposals.
The Council supports the inclusion
of challenging targets for inclusion in Waste Local Plans and
specific policy guidance on the application of the BPEO. Such
applications must ensure that preference is given to recycling
facilities, both in terms of capacity and earlier implementation
to ensure that less environmentally friendly methods of disposal
are restricted to the minimum amount necessary at any one period
of time. This may well require some phasing to be included within
the policy guidance.
This Council supports the application
of the proximity principle, and sees merit in a sequential approach
as a policy tool to assist in its implementation, together with
specific site identification.
Traffic congestion and its impacts
of delay and pollution are among the most serious problems affecting
the quality of life in Surrey. The addition of even one more HGV
is unacceptable, and policies and proposals need to be created
which actually reduce movement. The use of rail needs to be given
much greater prominence. Routing strategies for HGV movement also
need to be incorporated. However, the most important aspect will
involve the optimum location of sites for new facilities.
The Council supports a more flexible
approach to the restoration of former mineral workings, with the
creation of differing forms of landscape and habitat areas. However,
the question of environmental quality must be addressed from the
outset. Applications must be supported by appropriate schemes,
and robust conditions and legal agreements applied to any consents.
Councillor M H C Buttery
Chairman of the Environmental Services