ldf evidence base report waste apportionment investigation ... · dpd should identify sufficient...

LDF Evidence Base Report Waste Apportionment Investigation of the potential for working with other boroughs Nov 2010 Contact: [email protected]

H:\devplan\Core Strategy Submission\Final Evidence for Inspector\Key context docs\Environmental sustainability\CS17 Waste\141-143 Joint Working\143 Potential for Joint Working on Waste Apportionment Nov 10 new layout.doc 1 11/05/10

Contents 1 Executive Summary ............................................................................................ 3 2 Aims .................................................................................................................... 4 3 Background: ........................................................................................................ 4 4 Other boroughs general position: ........................................................................ 5 5 Detailed position of other boroughs..................................................................... 7 6 Conclusion ........................................................................................................ 25 7 Appendix 1: ....................................................................................................... 26 Evidence of joint working discussions with the North London Waste Partnership in 2010. ........................................................................................................................ 26 8 Appendix 2: ....................................................................................................... 30 Evidence of the City’s joint working discussions with Bexley 2010 .......................... 30


1 Executive Summary The London Plan sets a target for the City Corporation to identify 100,000 tonnes of waste management capacity within the City’s boundaries or work collaboratively with other boroughs to identify capacity elsewhere in London. Other evidence shows that there is no deliverable waste management capacity in the City. Therefore, collaborative working will be necessary. This report explores the potential for joint working with other London boroughs to meet the City’s London Plan waste apportionment of 100,000 tonnes. The report summarises other boroughs’ waste planning arrangements, capacity positions and progress towards meeting their apportionments. The potential for the City to work collaboratively with each borough or group of boroughs is assessed, and evidence is presented of possible joint working opportunities. The report concludes that the London Borough of Bexley is the most suitable partner for the City, and evidence is presented of collaborative working between the City and Bexley. However, joint working with Bexley is dependant on the adoption of the Draft Replacement London Plan targets for waste apportionment, which will not be finalised until autumn 2011.


2 Aims

2.1 To establish the potential for the City of London to enter into a joint working agreement with other boroughs to satisfy the London Plan’s waste apportionment target

2.2 To record progress on joint working arrangements with other London boroughs

3 Background:

3.1 European, national and regional guidance on waste emphasises the principle that waste should be managed at one of the nearest appropriate installations. This limits the environmental impact associated with the transport of waste and encourages communities to take more responsibility for the management of their own waste. In order to ensure that a range of waste management facilities are provided, which enable disposal close to the site of waste production, national and regional guidance introduced the concept of waste apportionment. Waste apportionment allocates tonnages of waste at local authority level. Waste planning authorities should identify sites with the capacity to manage this level of waste within their area.

3.2 PPS 10 Planning for Sustainable Waste Management – PPS 10 requires regional planning authorities to identify the tonnages of waste requiring management and apportion this by waste planning authority area. This is aimed at ensuring that sufficient capacity is available in each region so that waste can be managed close to where it is produced.

3.3 London Plan Apportionment – in accordance with PPS10 the London Plan (chapter 4A) contains waste projections for both municipal and commercial and industrial waste at borough level up to 2020. Table 4A.6 apportions these tonnages of waste by borough and Policy 4A.25 requires that “boroughs in their DPD should identify sufficient land to provide capacity to manage the apportioned tonnages of waste set out in Table 4A.6” and further suggests that “Boroughs preparing joint waste DPDs may wish to collaborate by pooling their apportionment requirements”

3.4 The London Plan consolidated with changes since 2004 (published Feb 2008) sets the apportionment for the City of London at 100,000 tonnes per annum.

3.5 The draft Replacement London Plan was issued for consultation in Oct 2009 and minor alterations on waste were issued for consultation in Dec 2009. The London Plan Examination in Public (EIP) will consider both documents and make recommendations in Feb 2011 prior to adoption later in 2011. The City of London’s waste apportionment remains at 100,000 tonnes per annum whereas all other London boroughs’ apportionments have been reduced by approximately 25% (comparing LP 2015 figures with MALP 2016 figures)

3.6 New commercial and industrial waste figures are due to be published late in 2010 and are likely to show a reduction in this waste stream. Adjustments to


borough’s waste apportionments may be made to reflect these revised figures. This could result in a reduction in the City’s apportionment target.

3.7 Research carried out by AEA has identified that there is no deliverable waste management capacity in the City since the only suitable site at Walbrook Wharf would be subject to major engineering and financial viability issues. Therefore the City is unable to meet the apportionment target by identifying sites within the City boundary.

3.8 This report investigates the possibility of joint working with other boroughs to meet a pooled apportionment target. This could be through the preparation of a Joint Waste Development Plan Document with one or more other London boroughs, or through the production of joint research which identifies capacity across a group of boroughs. In both cases formal agreement at Member level would be required to give integrity to the process.

4 Other boroughs general position:

4.1 Waste planning alliances exist for several groups of London boroughs and are generally based on long standing collaboration for waste disposal purposes, through Waste Authorities. These Waste Authorities are, in general adopting responsibility for joint waste planning and specifically for collaboration to satisfy the London Plan’s waste apportionment, through the development of joint waste DPDs. The City has operated independently rather than as a member of a waste authority for waste related activities in the past and therefore does not have an obvious partner or grouping for waste joint working to meet the waste apportionment targets.

4.2 Several South East London boroughs are planning to collaborate on a joint approach to meeting the waste apportionment targets through joint research to demonstrate that collectively they meet their pooled apportionments.

4.3 The central London boroughs are generally working independently and covering waste in their Core Strategies which are at different stages of production.

4.4 Figure 1 shows how London boroughs are collaborating for waste planning and apportionment purposes


Fig 1 Waste Partnerships 2007


5 Detailed position of other boroughs

5.1 Progress on the North London Joint Waste Plan (NLWP) is shown in fig 2 Fig 2: North London Waste Plan (NLWP) Contact: Archie Onslow Tel: 020 7974 5916 Email: [email protected] Boroughs Historic

working Proposed Planning Document

Timetable Capacity position Joint working mechanism

Barnet Camden Enfield Hackney Haringey Islington Waltham Forest

Have been working together since 1985

Joint Waste DPD

Issues & Option stage complete Jan 2008 Preferred Options consultation complete Oct /Nov 2009 Further possible consultation on additional sites Sept 2010 – this could delay subsequent dates by 3 months Submission version consultation scheduled for Nov/Dec 2010 Examination in Public scheduled for June 2011

The north London group aims to meet the joint apportionment for the seven boroughs Preferred Options consultation document identifies sites with sufficient flexibility to meet joint apportionment through Schedule A - Existing waste management sites Schedule B – Existing waste transfer sites with reorientation potential Schedule C - Potential new waste management sites

Seven boroughs are working together as planning authorities on a joint waste plan. There is a memorandum of understanding signed by Members with responsibility for waste at each of the seven boroughs.

5.2 If the draft replacement London Plan apportionments were adopted, the North London group’s apportionment would drop by 184,000 tonnes in 2010/11, 490,000 tonnes in 2015/2016 and by 642,000 tonnes in 2020/2021. This could present opportunities for joining this group if they have already identified sufficient sites to meet the adopted London Plan apportionment. Fig 3 shows the impact of the draft replacement London Plan on apportionment targets for this group.


Fig 3 North London Waste Plan – impact of Draft Replacement London Plan Adopted

London Plan 2008 apportionment (‘000 tonnes)

Draft replacement London Plan 2009 apportionment (‘000 tonnes)

Reduction (‘000 tonnes)

% reduction

2010 to 2011 1,504 1,320 184 12% 2015 to 2016 1,994 1,504 490 25% 2020 to 2021 2,341 1,699 642 27%

Potential for Joint Working with the North London Waste Plan.

5.3 The City informally approached NLWP in 2008 and concluded that there was little prospect of collaboration with this group since the NLWP were unlikely to have spare capacity above that required to meet the London Plan 2008 joint waste apportionments for the seven boroughs. Further informal discussions in 2010 indicated that opportunities might exist if the apportionments proposed in the draft replacement London Plan were adopted. A formal approach was made via the NLWP co-ordinator in April 2010 for discussion by the NLWP officer group in June 2010 and Members group in July 2010. After due consideration the NLWP responded in Sept 2010 concluding that partnership working is unlikely at this late stage in the process. (see appendix 1 – copies of these letters)

5.4 Risks and opportunities – North London Waste Plan • Further evidence of 100k tonnes surplus capacity would be needed, since the

deliverability of sites in NLWP schedules B and C is not guaranteed and the draft replacement London Plan apportionments will not be confirmed until Oct 2011.

• Members from seven boroughs would need to agree to joint working with the City

• The NLWP are working to a tight timetable and would need assurances that this timetable would not be affected by the City joining the group

• There would be a need to satisfy the NLWP that procedurally the joint waste DPD would not be deemed unsound due to lack of consultation regarding the City joining this group

• This group may be reluctant to accommodate an additional authority given their history of joint working on waste – it may be necessary to identify a mutually beneficial issue to which the City could contribute.


5.5 Progress on the East London Joint Waste Development Plan Document (JWDPD) is shown in fig 4

Fig 4: East London Joint Waste DPD Contact: Irene Lu Tel: 020 3373 9613 Email: [email protected] Boroughs Historic working Proposed

Planning Document


Barking & Dagenham Havering Newham Redbridge

East London Group have been working together as a waste disposal authority for approximately 15 years and therefore agreed to adopt a joint approach to waste planning for this area

Joint Waste DPD

Preferred Options consultation complete April 2008 The pre-submission version of the joint waste DPD was published for consultation Aug/Sept ‘09 Alterations to this pre-submission version were issued for consultation in Sept 2010 Submission late 2010 or early 2011

The East London group are aiming to meet the waste apportionments for the four boroughs but not exceed the apportionment since they do not want to become the “dumping ground” for central London’s waste The submission document schedules identify capacity in Schedule 1- existing waste management sites Schedule 2- locations for future waste sites

Each of the four boroughs has Member agreement for its Local Development Scheme which includes preparation of a Joint Waste DPD. Each borough has signed up to Terms of Reference for joint waste planning at Senior Officer/Planning Manager level.

5.6 If the draft replacement London Plan apportionments were adopted, the East London group’s apportionment would drop by 170,000 tonnes in 2010/11, 454,000 tonnes in 2015/2016 and by 597,000 tonnes in 2020/2021. This could present opportunities for joining this group if they have already identified sufficient sites to meet the adopted London Plan apportionment.

Fig 5 East London Joint Waste DPD – Impact of Draft Replacement London Plan Adopted




% reduction

2010 to 2011 1,394 1,224 170 12% 2015 to 2016 1,847 1,393 454 25% 2020 to 2021 2,171 1,574 597 27%


Potential for joint working with the East London Waste Partnership

5.7 The City informally approached ELWP in 2008 and concluded that there was little prospect of collaboration with this group since one of the stated objectives of the East London Joint Waste DPD is to “Reverse the historic trend of the ELWA being the dumping ground for London’s waste” ref Joint Waste DPD for East London Waste Authority Boroughs - Preferred Options report April 2008.

5.8 If adopted, the draft replacement London Plan waste apportionments would reduce the ELWP targets significantly, which could provide opportunities for the City to join this group. However the objective to avoid being London’s dumping ground for waste remains in place in the Joint waste DPD for East London Waste Authority Boroughs Proposed Submission Draft Aug 2009, therefore it is unlikely that this group would consider partnership working with central London boroughs. Informal discussion with the coordinator for the East London Waste Planning Group in June 2010 confirmed that this is still the group’s general position.

5.9 Risks and opportunities – East London Waste Partnership • The East London group are unlikely to welcome additional members from

central London with low capacity – this group has stated that they want to reverse the historical trend of the ELWA being the dumping ground for London’s waste.

• Deliverability of sites in schedule 2 not guaranteed • This group has produced a draft submission version of their joint waste DPD.

The soundness of the plan would be in jeopardy if an additional borough joined this group at this late stage, without further public consultation.


5.10 Progress on the South East London Group’s waste planning is shown in fig 6

Fig 6: South East London Group Contact: Clare Loops Tel: 020 8308 7782 Email: [email protected] Boroughs Historic



Bexley Bromley Greenwich Lewisham Southwark

Working together since 2006 on waste planning

Joint technical paper as part of the evidence base to inform each borough’s Core Strategies

Joint Waste Apportionment Technical Paper published March 2010 as part of the evidence base for Lewisham and Southwark’s submission version Core Strategies Revised joint waste technical paper published in Oct/Nov 2010 for Bexley’s proposed submission version Core Strategy Core Strategy proposed adoption dates: Bexley 2012 Bromley 2012 Greenwich 2012 Lewisham 2011 Southwark 2011

Technical paper Oct 2010 shows potential surplus capacity of 2011:837K tonnes 2016:686K tonnes 2021:505K tonnes 2026:312K tonnes 2031:104K tonnes Over 2009 draft replacement London Plan targets

Formal agreement at Member level – signed by the Cabinet Member responsible for waste

5.11 If the draft replacement London Plan apportionments were adopted, the South East London group’s apportionment would drop by 187,000 tonnes in 2010/11, 488,000 tonnes in 2015/2016 and by 639,000 tonnes in 2020/2021. This could present opportunities for joining this group if they have already identified sufficient sites to meet the adopted London Plan apportionment. Fig 7 shows the impact of the draft replacement London plan on waste apportionment targets for the southeast London group.


Fig 7 Southeast London waste group – impact of Draft Replacement London Plan Adopted




% reduction

2010 to 2011 1,485 1,298 187 13% 2015 to 2016 1,967 1,479 488 25% 2020 to 2021 2,310 1,671 639 28%

5.12 Fig 8 shows the impact of the DRLP on Bexley’s individual waste apportionment and demonstrates that in 2010-11 the reduction awarded to Bexley is 56K tonnes which would not be sufficient to cover the city’s !00K tonne apportionment therefore some phasing of the City’s apportionment could be beneficial in negotiations with Bexley.

Fig 8 Bexley – impact of Draft Replacement London Plan Adopted




% reduction

2010 to 2011 454 398 56 12% 2015 to 2016 602 453 149 25% 2020 to 2021 707 512 195 28% Potential for joint working with the Southeast London Group / Bexley

5.13 The City informally approached the Southeast London group through the group co-ordinator at Bexley in 2008 and identified that there may be potential for joint working but this was dependant on the group identifying surplus deliverable capacity above the joint waste apportionments of the five boroughs which make up this group. Ongoing informal dialogue continued while the south east London group worked on their joint evidence paper. Formal agreement for the City to join this group was not sought at this stage since their willingness to accommodate additional waste apportionment was dependant on the identification of surplus capacity through the evidence base studies.

5.14 Evidence published in January 2010 (updated March 2010) to support Southwark’s draft Submission Core Strategy indicated that although this group should have surplus capacity of 200-400K tonnes during the earlier periods of the plan this diminished to around 50K tonnes in 2021 and 2K tonnes in 2026, compared with the Adopted London Plan Apportionment targets. Informal discussions indicated that under these circumstances it would be unlikely that the group would agree to an additional member joining.

5.15 This evidence also highlighted that, should the draft replacement London Plan figures be adopted, the group would have a considerable surplus throughout the plan period to 2031. Bexley would contribute significantly to this surplus due in part to the presence of the 616K tonne Riverside energy from waste facility under construction in Belvedere.

5.16 In March 2010 the City’s Town Clerk and Planning Policy Director met with Bexley’s CEO and Director of Environmental Services to discuss the potential


for joint working. A general approach to bilateral working with Bexley was agreed via an exchange of letters between the City’s Town Clerk and Bexley’s CEO in August 2010. Detailed arrangements are currently being progressed (see appendix 2 - copies of correspondence).

5.17 The City’s intention to pursue this approach was approved by the City of London Policy and Resources Committee on 23rd Sept 2010 (see appendix 2 - Committee Report)

5.18 The Bexley Core Strategy proposed submission document was published in Nov 2010. Policy CS20 Sustainable waste management commits Bexley to “meeting its waste apportionments and other requirements including collaboration with other London boroughs as appropriate” This would enable collaborative working between the City and Bexley to make best use of their surplus capacity.

5.19 Evidence published to support Bexley’s waste policy demonstrates that waste sites in Bexley contribute significantly to the overall surplus capacity identified for the South East London Group. Appendix A of the South East London boroughs’ joint waste apportionment technical paper Oct 2010 shows a surplus capacity of just over 100K tonnes in 2031, with significant additional surplus prior to this date, compared with the Draft Replacement London Plan targets (see appendix 2 Evidence of Bexley’s surplus capacity).

5.20 The South East London Group may also be in a position to assist other boroughs in satisfying their waste apportionment targets. Westminster’s Cabinet member for City Management has approached Members from Lewisham and Southwark with a view to joint working (ref Westminster Core Strategy technical paper for Submission draft Core Strategy March 2010)

5.21 Risks and opportunities – Southeast London Group/Bexley • Opportunities for joint working with Bexley depend on the adoption of the draft

replacement London Plan waste apportionment targets which will not be finalised until Oct 2011.

• The members of this group are each covering waste in their Core Strategies and are collaborating to produce a joint waste technical paper as a “living draft”, rather than producing a joint waste DPD. The question of soundness if another borough joins the group or comes to a unilateral agreement with one borough should not therefore be an issue.

• The GLA has proposed further alterations to the DRLP allowing for a range of mechanisms for joint working including bilateral agreements therefore bilateral working should be in conformity with the London Plan’s approach.

• Bilateral agreement with Bexley is the preferred approach given their significant surplus as an individual borough (as a result of the proposed minor alterations) within the South East London group.


5.22 Progress on the South London Waste Plan is shown in fig 9

Fig 9: South London Waste Group Contact: Emma Smyth Tel: 020 8547 5375 Email: [email protected] Boroughs Historic



Croydon Kingston Merton Sutton

Partnership formed in April 07

Joint Waste DPD

Issues and options consultation Autumn 08 Stage 2 consultation July-Oct 09 Stage 2a Additional Sites consultation Feb-Mar 2010 Publication of draft South London Waste Plan due Jan-Feb 2011 Adoption: Winter 2011

The stage 2 consultation identifies sites with sufficient capacity to satisfy the target of 20 hectares of land to meet the joint waste apportionments: Table 2.2 –Existing waste sites (19.97 hectares) Table 2.3 Existing waste site with delivery constraints (2.02 hectares) Table 2.4 Potential new sites for waste management (12 sites) The Stage 2a consultation identifies a further 8 potential sites which are undergoing evaluation

Member Working Group made up of 2 Members from each of the four local authorities Memorandum of Understanding signed in Nov 07

5.23 If the draft replacement London Plan apportionments were adopted, the South London group’s apportionment would drop by 124,000 tonnes in 2010/11, 300,000 tonnes in 2015/2016 and by 391,000 tonnes in 2020/2021. This could present opportunities for joining this group if they have already identified sufficient sites to meet the adopted London Plan apportionment. Fig 10 shows the impact of the draft replacement London Plan on apportionment targets for the south London group

Fig 10 South London Waste Plan – Impact of Draft Replacement London Plan Adopted




% reduction

2010 to 2011 855 731 124 15% 2015 to 2016 1,133 833 300 26% 2020 to 2021 1,332 941 391 29%


Potential for joint working with the South London group

5.24 Informal discussions in 2008 indicated that this group were not in a position to confirm whether they would have surplus capacity to meet their joint waste apportionments. Preparations for consultation were underway and may need to be repeated if the City joined the group therefore there was little potential for joining this group.

5.25 Evidence of this group’s capacity position was published alongside the Stage 2 consultation in July- Oct 09 and identified that 20 hectares would be needed to meet the group’s apportionment. Existing waste sites totalling 19.97 hectares were identified along with an existing waste site of 2.02 hectares with deliverability constraints (table 2.3). Twelve additional sites with opportunity for development as waste sites were also identified (table 2.4).An additional 8 sites were put forward at Stage 2a consultation for consideration.

5.26 This published capacity data indicates that existing waste sites will only just meet the 2008 London Plan apportionments. Deliverability of sites in Stage 2 tables 2.3 and 2.4 and Stage 2a is not guaranteed. In these circumstances it is unlikely that this group would admit an additional authority.

5.27 Any further capacity evidence which is published by this group, particularly in the light of draft replacement London Plan targets, will be evaluated with a view to approaching the South London group if surplus deliverable capacity is identified.

5.28 Risks and opportunities • No surplus deliverable capacity has been identified through existing published

evidence. • There would be a need to satisfy the South London Waste Group that

procedurally their joint waste DPD would not be deemed unsound due to lack of consultation if the City joined this group

• If the draft replacement London Plan targets are adopted (Oct 2011) this group may have surplus capacity on existing waste sites.


5.29 Progress on the West London Waste Plan is shown in fig 11 Fig 11 West London Waste Plan Contact: Janet Rangeley Tel: 01895 250553 Email: [email protected] Boroughs Historic working Proposed

Planning Document


Brent Ealing Harrow Hillingdon Hounslow Richmond

West London Waste Authority have >10 years history of joint working on waste disposal. The Joint waste planning group have been working together for approximately 4 years

Joint Waste DPD 2011- 25

Issues & Options consultation completed April 09 Consultation on proposed sites and policies due after Autumn 2010 Adoption By Dec 2011

Issues & Options report Feb 2009 para 7.2 identifies a shortfall of 1,493k tonnes of capacity to meet the 2020 apportionment target. Details of potential sites to meet this shortfall have not yet been published

Memorandum of understanding signed by Members Officer level steering group deals with progress of the project Hillingdon provide coordination role and project management – other boroughs provide funding

5.30 If the draft replacement London Plan apportionments were adopted, the West London group’s apportionment would drop by 222,000 tonnes in 2010/11, 552,000 tonnes in 2015/2016 and by 723,000 tonnes in 2020/2021. This could present opportunities for joining this group if they have already identified sufficient sites to meet the adopted London Plan apportionment. Fig 12 shows the impact of the draft replacement London plan targets on the west London waste group.

Fig 12: West London Waste group – Impact of Draft Replacement London Plan Adopted

London Plan apportionment 2008 (‘000 tonnes)

Draft replacement London Plan 2009 (‘000 tonnes)


% reduction

2010 to 2011 1,621 1,399 222 14% 2015 to 2016 2,147 1,595 552 26% 2020 to 2021 2,521 1,798 723 29% Potential for joint working with the West London Waste Group

5.31 This group’s waste management capacity on existing sites falls short of the joint waste apportionments for this group. Potential sites to meet this apportionment have not been identified therefore it is unlikely that there will be potential for joint working with this group.

5.32 GLA officers advised the City at our meeting with them on 09/03/10 that the West London group is unlikely to be a suitable partner therefore no further approaches have been made to this group

5.33 Westminster’s Cabinet Member for City Management has approached Members from Brent, Ealing, Harrow, Hounslow, Hillingdon and Richmond to


explore potential for joint working ref Westminster Core Strategy technical paper March 2010

5.34 Risks and Opportunities • This group may be reluctant to accommodate an additional authority given their

history of joint working on waste and lack of identified waste management capacity.

• The GLA advised at our meeting on 09/03/10 that the West London group are unlikely to be a suitable partner for the City


5.35 Boroughs Working Independently

City of London Contact: Janet Laban email: [email protected] Historic working

Proposed Planning Document


Independent Core Strategy CS Preferred Options consultation Summer 07 Additional PO consultation Nov 09 Publication consultation Sept/Oct 10 Proposed submission date Dec 2010

No deliverable waste management capacity has been identified in the City therefore joint working will be necessary.

To be confirmed

City of London – Impact of draft replacement London Plan figures Adopted




% reduction

2010 to 2011 100 100 0 0% 2015 to 2016 100 100 0 0% 2020 to 2021 100 100 0 0%


Hammersmith & Fulham Contact: Trevor Harvey Historic working



Independent Core Strategy

CS Preferred options consultation Summer 07 Additional options consultation June 09 Publication consultation Oct 2010 Proposed submission 2011

H&F have two existing waste sites which should satisfy the borough’s waste apportionment – see waste background paper May 2009

N/A

Hammersmith & Fulham – Impact of the draft replacement London Plan figures Adopted




% reduction

2010 to 2011 247 216 31 13% 2015 to 2016 327 246 81 25% 2020 to 2021 385 278 107 28% Potential for joint working with Hammersmith and Fulham

5.36 The draft replacement London Plan could result in surplus waste management capacity in Hammersmith and Fulham since they have already identified two existing waste sites with capacity to manage the adopted London Plan apportionments. However this additional capacity would not be sufficient to cover the City’s apportionment in the early parts of the plan period. Kensington and Chelsea would be a more likely partner for Hammersmith and Fulham since they are neighbouring boroughs and Kensington and Chelsea have a deficit in waste capacity.


Kensington & Chelsea Contact: Patricia Cuervo email: [email protected] Historic working


Timetable Capacity position

Joint working mechanism

Independent Core Strategy and Waste DPD

Core Strategy Submission March 2010 Examination July 2010 Adoption Dec 2010 Waste DPD Submission Sept 2011 Adoption June 2012

Core Strategy commits to the preparation of a Waste DPD which will identify sites and partners to satisfy waste apportionment.

May work with Hammersmith & Fulham

Kensington & Chelsea - Impact of draft replacement London plan figures Adopted




% reduction

2010 to 2011 201 176 25 12% 2015 to 2016 266 201 65 24% 2020 to 2021 313 227 86 27% Potential for joint working with Kensington and Chelsea

5.37 Informal correspondence with Kensington and Chelsea (RBKC) indicates that they have not identified sites with capacity to manage their adopted London Plan waste apportionment. Therefore although the draft replacement London plan reduces their apportionment figures by up to 86K tonnes compared with the adopted figures this will not represent surplus capacity on the ground. RBKC have a deficit in waste capacity therefore is not a potential partner for the City.


Lambeth Contact: Tammy Riordan email: [email protected] Historic working



Independent Core Strategy Draft Core Strategy Submission March 2010 Examination Sept 2010 Adoption 2011

Draft Core Strategy safeguards sites to meet waste apportionment: 1)sites in waste management use 2) waste sites not currently in waste management use 3) operational waste sites

N/A

Lambeth – Impact of draft replacement London Plan figures Adopted




% reduction

2010 to 2011 222 195 27 12% 2015 to 2016 294 222 72 24% 2020 to 2021 346 250 96 28% Potential for joint working with Lambeth

5.38 Lambeth’s draft Core Strategy indicates that a proportion of their safeguarded sites are sites that are not currently in waste management use. Since these sites would need to be developed, it is likely that any reduction in the London Plan waste apportionments would result in fewer sites being developed rather than that sites would be developed to accommodate the City’s apportionment targets. Therefore Lambeth is unlikely to be a suitable partner for the City.


Tower Hamlets Contact: Peter Farnham email: peter.farnham:towerhamlets.gov.uk Historic working



Independent Core Strategy – identifies “areas of search” Site allocations DPD will identify sites

Core Strategy submission Dec 09 Examination March 2010 Adoption Sept 10

Waste research paper identifies potential to exceed apportionment in specific areas of search -some new sites will need to be developed to meet apportionment

N/A

Tower Hamlets – Impact of draft replacement London Plan figures Adopted




% reduction

2010 to 2011 311 273 38 12% 2015 to 2016 412 311 101 25% 2020 to 2021 484 351 133 27% Potential for joint working with Tower Hamlets

5.39 Discussions took place with Tower Hamlets’ Planning Officers and Waste Management Officers during 2009 with a view to joint working to meet our combined waste apportionments. Tower Hamlets have identified surplus potential capacity for waste management facilities within the borough in specific “areas of search”. In 2009 they were seeking partnerships, involving substantial commercial investment, to assist with the delivery of sites. The level of investment being sought and a lack of detail available indicated that agreement would not be reached within the timescales needed to satisfy the Core Strategy timetable deadlines. Negotiations did not continue into 2010, therefore it is unlikely that Tower Hamlets will be a suitable partner for the City at this stage.


Wandsworth Contact: Adam Hutchings email:[email protected] Historic working



Independent Core Strategy Submission consultation Mar 09 Examination Feb 2010 Adoption Sept 2010

Wandsworth expect to narrowly exceed their apportionment figure through the safeguarding of 1)existing waste management sites 2) reorientation of other waste sites 3) new “windfall” waste sites in Strategic Industrial Locations

Considered joint working with other Western Riverside authorities but differing timetables made this impractical

Wandsworth – Impact of draft replacement London Plan figures Adopted




% reduction

2010 to 2011 314 275 39 12% 2015 to 2016 417 313 104 25% 2020 to 2021 489 354 135 28% Potential for joint working with Wandsworth

5.40 Wandsworth have identified sufficient potential capacity to meet their adopted London Plan waste apportionments but this includes some sites which are not currently in waste management use. Although the draft replacement London Plan proposes a reduction in Wandsworth’s apportionment targets by up to 135K tonnes, it is unlikely that this will materialise as surplus capacity. It is more likely that some of the potential sites will be developed for non waste uses rather than being developed to satisfy the apportionments of deficit boroughs like the City. Therefore Wandsworth is unlikely to be a suitable partner for the City.


Westminster Contact: Tom Kimber email:[email protected] Historic working



Independent Core Strategy Preferred options consultation Sept 2008 Submission April 2010 Examination July 2010 Further consultation on post submission amendments Sept 2010 Adoption 2011

Plan to meet apportionment by 1) safeguarding existing waste sites 2) identifying new sites 3) in vessel composting programme 4) onsite waste management in new development Post submission amendment adds partnership working with other boroughs to the policy

N/A

Westminster – Impact of draft replacement London Plan figures Adopted




% reduction

2010 to 2011 125 111 14 11% 2015 to 2016 166 126 40 24% 2020 to 2021 195 142 53 27% Potential for joint working with Westminster

5.41 Westminster has not identified sufficient waste management capacity to meet its apportionment within the borough and are seeking a partner borough to assist in meeting the targets. Westminster is not a potential partner for the City


6 Conclusion

6.1 This report identifies Bexley as the most suitable partner for joint working with the City to satisfy the London Plan waste apportionment targets. However this partnership opportunity is dependant on the adoption of the draft replacement London Plan waste apportionment targets, which reduce Bexley’s waste apportionment figures significantly.

6.2 The potential for joint working with other boroughs has been thoroughly explored, but is limited since:

6.2.1 Joint working is generally based on historic alliances for waste disposal through Waste Authorities and the City has historically worked independently on waste disposal.

6.2.2 The waste management capacity identified in most other boroughs or groupings relies on the development of some new waste management facilities. If London Plan waste apportionment targets are reduced, boroughs are more likely to remove sites from their lists of potential waste sites, rather than progress these sites in order to accommodate the City’s apportionment.

6.2.3 Each authority or group of authorities are working to different timetables in preparing the relevant Development Plan Documents therefore collaborative working risks problems with the alignment of public consultation and soundness issues for these DPDs.


7 Appendix 1:

Evidence of joint working discussions with the North London Waste Partnership in 2010. A formal approach was made to the North London Waste Partnership in April 2010 for discussion at their Officer and Members group meetings in summer 2010. The response received in Sept 2010 indicates that partnership working with the North London Waste Partnership is unlikely at this stage.( see attached copies of letters )


Department of Planning & Transportation Peter Wynne Rees BSc, BArch, BTP, RIBA, FRTPI, FRSA The City Planning Officer

Mr Archie Onslow Programme Manager North London Waste Plan Camden Town Hall Argyle Street, London WC1H 8EQ

Telephone 020 7332 1970 Email paul.beckett @cityoflondon.gov.uk Date 30 April 2010

Dear Archie

Partnership Working on Waste Apportionment Further to your telephone conversation with my colleague Janet Laban I am writing to explore the potential for the City Corporation to enter into joint working with the North London Waste Planning group (NLWP) on waste apportionment.

The City informally approached NLWP in 2008 to discuss the possibility of joint working on waste apportionment. We concluded at that time that there was little prospect of collaboration, since NLWP were unlikely to have spare capacity above that required to meet the joint waste apportionments for the seven north London boroughs which make up the group. Since then waste apportionments for all boroughs have been reviewed and, in December 2009, revised apportionments were proposed by the Mayor as minor alterations to the draft replacement London Plan. If these revised apportionments are adopted, after consideration at the London Plan examination in public, the NLWP joint apportionment would fall from 1,994,000 to 1,504,000 tonnes in 2015/16 with even greater reductions beyond this date. This could open up the potential for identification of excess waste management capacity in the NLWP area, and the potential for partnership working with the City.

The 2008 London Plan set the City’s waste apportionment at 100,000 tonnes pa and the apportionment review does not propose any alteration to this figure, although the City will be challenging this figure at the London Plan EIP. The City of London Waste Management Capacity Study, prepared by AEA in 2009, concluded that there is no viable waste management capacity within the City boundary, and the City’s only waste site at Walbrook Wharf is unsuitable for reorientation to accommodate waste management alongside its important river-based waste transfer function.

The City Corporation is currently exploring the potential for joint working with various partners within London and as part of this process wishes to explore the potential for joint working with NLWP to identify sites suitable for management of 100,000 tonnes pa in addition to the NLWP’s existing apportionment for North London.


We understand from informal discussions that any joint working agreement would need to:

• Be dependant on the identification of 100,000 tonnes of surplus capacity in the NLWP area in excess of the NLWP’s joint apportionments as defined in the London Plan 2008 or its replacement when adopted.

• Guarantee that the NLWP’s revised joint waste DPD timetable would not be affected. • Satisfy the NLWP that procedurally the joint waste DPD would not be deemed unsound

due to lack of consultation regarding the City joining the group. • Be approved by Members of the seven boroughs in the NLWP. • Involve future collaboration on a mutually beneficial issue.

The City Corporation wishes to explore further the potential for joint working and would be grateful if you could advise whether collaboration on this issue merits further exploration. Should you decide that joint working is not practicable in this instance, it would be helpful if you could confirm this, so that the potential for joint working with other partners can be pursued. Yours sincerely

Mr Paul Beckett Policy & Performance Director


Camden Town Hall

Argyle Street London WC1H 8EQ

Email: [email protected] Tel: 020 7974 5916 Fax: 020 7974 1930 Web: www.nlwp.net

21st September 2010 Dear Paul,

Mr Paul Beckett Policy & Performance Director Department of Planning & Transportation City of London PO Box 270 Guildhall London EC2P 2EJ [email protected]

Partnership Working on Waste Apportionment Thank you for your letter of 30th April about the potential for the City Corporation to enter into joint working with the North London Waste Plan on waste apportionment. I took the matter to the Planning Officers Group and to the Heads of Planning Group. As far as formally becoming part of the joint waste plan, I think this is unlikely at this late stage of the process. You will know that we have produced our preferred options and we are moving towards producing our submission version by December with an examination in 2011. The arrival of a significant new player in the Plan would require amendments to our evidence base and might require additional public consultation. In addition while our apportionment is reduced in the emerging London Plan, we have not identified significant spare capacity that we are able to offer up. I am sorry I cannot be more helpful at this stage. Yours sincerely

Archie Onslow Programme Manager


8 Appendix 2:

Evidence of the City’s joint working discussions with Bexley 2010 A series of meetings were held with Bexley during spring and early summer 2010 to discuss the possibility of joint working on waste apportionment. Bexley confirmed that

• Bexley will have significant surplus waste management capacity throughout the period of the Core Strategy if the draft replacement London Plan waste apportionment figures are adopted.

• Bexley’s surplus is on sites which are already in waste management use and have been identified in the South East London Group’s joint technical paper.

• Bexley is in a position to act independently from the other boroughs in the South East London Group since the majority of the group’s surplus is within Bexley.

• Bexley is willing to use a proportion of this surplus to accommodate the City’s waste apportionment targets.

The principle of joint working was confirmed in an exchange of letters between Chris Duffield Town Clerk City of London and Will Tuckley Chief Executive Officer Bexley in August 2010. (copies of letters attached) The principle of partnership working was approved by the City of London’s Policy and Resources Committee on 23rd Sept 2010 (Committee report attached) Evidence of Bexley’s surplus capacity compared with the draft replacement London Plan targets is presented (Tables taken from joint waste technical paper attached)


Committee(s): Date(s): Item no. Policy and Resources Committee

23rd September 2010

Subject: City Corporation’s Partnership Working with the London Borough of Bexley Regarding London Plan Waste Apportionment: Request for Funding Report of: Town Clerk and City Planning Officer

Public For Decision

Summary

The purpose of this report is to agree in principle the City Corporation’s partnership working with the London Borough of Bexley on waste apportionment and other matters and to authorise a grant of £16,500 to Bexley as part of the partnership commitment.

• The London Plan requires the City Corporation to identify land in the City with the potential to manage 100,000 tonnes of waste annually or to enter into a joint working arrangement with a partner to identify such land or waste facilities elsewhere in London.

• There is no suitable land in the City and so the City Corporation needs to work with a partner to meet the London Plan requirement. Without such an agreement the City’s Local Development Framework Core Strategy may be considered by the Mayor of London to be not in general conformity with his London Plan.

• Following discussions with officers from the GLA and various boroughs, Bexley has been identified as the most suitable partner to meet the whole 100,000 tonnes annual City waste apportionment during 2011-31.

• There are close and growing links between the City and Bexley regarding waste management matters. The City’s municipal waste will soon be transported sustainably from Walbrook Wharf by river barge to the new energy-from-waste riverside facility at Belvedere in Bexley. In addition the City Corporation currently manages London’s hazardous waste service on behalf of all London Boroughs including Bexley.

• The hazardous waste service attracts an annual fee and it is intended that as part of the partnership agreement the City will grant Bexley £16,500 as a commuted sum equivalent to the annual fee for 5 years (with Bexley still continuing to pay each year’s actual fee).

• The report is seeking an allocation of £16,500 from the Committee’s 2010/11 City’s Cash contingency to grant to Bexley as part of the partnership agreement.


Recommendations

Members are recommended:

• To agree that the City Corporation should work jointly with Bexley on waste apportionment and other matters.

• To authorise from the Committee’s 2010/11 City’s Cash contingency the grant of £16,500 to Bexley subject to Bexley confirming a partnership working agreement on waste apportionment and other matters on the terms set out in this report.

Main Report

Background 1. The London Plan 2008 includes policy 4A.25 requiring boroughs to identify

sufficient land to provide capacity to manage the apportioned tonnages of waste set out in London Plan Table 4A.6. This table gives the City of London a ‘waste management apportionment’ of 100,000 tonnes annually. This policy is intended to ensure that all local planning authorities make some provision for waste management as a contribution to the Mayor’s aim that more of the waste generated in London should be managed in London. Mayor Johnson’s recently prepared Draft Replacement London Plan continues with this policy approach and retains the 100,000 tonnes annual apportionment for the City.

2. The City’s waste apportionment figure of 100,000 tonnes was set after taking

some account of the waste that is generated in the City and the very limited capacity for that waste to be managed in the City. The City does not have any industrial sites that might typically be suitable for a new waste management facility and the existing Walbrook Wharf site operates as a waste transfer station, moving waste sustainably by river barge. Walbrook Wharf’s waste transfer activities do not count as waste management and there is little scope to add waste management activities to the site without compromising its existing waste transfer role and its safeguarded river wharf status. Therefore the City has strong evidence that the 100,000 tonne waste apportionment figure in the London Plan is not deliverable in the City.

3. Officers have presented the City’s evidence for a reduction in the City’s

waste apportionment to the Mayor’s staff and to the planning inspectors at the Draft Replacement London Plan examination in public. These discussions have not been successful so far and the Mayor has not been minded to change the figure. Therefore the City Corporation needs to take


steps now to address its 100,000 tonnes annual waste apportionment responsibility rather than rely on the possibility that it might be reduced in the future.

4. The London Plan policy allows local authorities to satisfy their waste

apportionment requirement by collaborative working when a single authority is unable to meet its apportionment requirement. Partnership working with another borough has therefore been investigated as the best way of satisfying the London Plan policy. Without such a partnership the City’s Local Development Framework Core Strategy may be considered by the Mayor of London to be not in general conformity with his London Plan. Therefore some partnership working is needed to enable the City’s LDF Core Strategy to progress towards adoption.

Scope for Partnership Working with Bexley on Waste and Other Matters 5. Following officer discussions with various boroughs Bexley has been

identified as the most suitable partner for joint working on waste apportionment matters. Bexley has surplus waste management capacity that could be used to meet the whole 100,000 tonnes annual City waste apportionment during 2011-31. There are close and growing links between the City and Bexley regarding waste management matters. The City’s municipal waste will soon be transported sustainably from Walbrook Wharf by river barge to the new energy-from-waste riverside facility at Belvedere in Bexley. In addition the City Corporation currently manages London’s hazardous waste service on behalf of all London Boroughs including Bexley.

6. Officer discussions with Bexley have identified several areas of closer

cooperation that could be pursued in parallel with partnership working on waste apportionment. Closer cooperation on economic development matters could lead to stronger economic links between the City and Bexley as part of a complementary working relationship and a greater appreciation of the strategic importance of regeneration in the Thames Gateway area for the wellbeing of London as a whole. Bexley has also been advised of the potential for local charitable organisations to apply to the City Bridge Trust for financial assistance for appropriate local enhancement projects.

Need for Funding 7. As part of the commitment to partnership working Bexley is seeking some

assistance with the cost to Bexley of London’s hazardous waste service managed by the City Corporation. This service is operated by the City Corporation as part of a London-wide agreement. Therefore the City cannot reduce or waive the annual fee payable by Bexley without upsetting existing


London-wide arrangements. The solution suggested is that as part of the partnership agreement the City will grant Bexley £16,500 as a commuted sum equivalent to the annual fee for 5 years. Authority is needed to allocate £16,500 from the Committee’s 2010/11 City’s Cash contingency for this purpose.

Options 8. The City Corporation needs to meet the London Plan’s waste apportionment

requirement in order for the City’s LDF Core Strategy to be in general conformity with the London Plan on waste matters. As there is no scope for this apportionment to be met within the City itself the City Corporation needs to meet its London Plan responsibility through partnership working. Bexley has been identified as the most suitable partner to meet the whole 100,000 tonnes annual City waste apportionment during 2011-31. Not agreeing terms with Bexley or another borough would jeopardise progress of the City’s LDF Core Strategy.

9. There is the possibility that the planning inspectors report into the Draft Replacement London Plan, due in Spring 2011, will recommend that the City’s London Plan annual waste apportionment figure should be reduced from its current 100,000 tonnes figure. However a recommendation for a significant reduction seems unlikely because of its consequences for other authorities. The Mayor would not be bound to accept such a recommendation anyway and has consistently opposed such a reduction. Therefore it is considered that it is a better option to agree arrangements now with Bexley based on the current waste apportionment figure rather than jeopardise progress on the LDF Core Strategy by waiting for an uncertain future reduction in the waste apportionment figure.

Proposals 10. The report proposes partnership working with Bexley on waste

apportionment matters and the authorisation of a £16,500 grant to Bexley as part of the partnership agreement.

Financial and Risk Implications 11. The proposed grant to Bexley will be conditional on satisfactory partnership

working being agreed on waste apportionment matters on the terms set out in this report. It is considered appropriate to allocate the required funding from the Committee’s 2010/11 City’s Cash contingency which currently has an uncommitted balance available of £164,000.

Legal Implications H:\devplan\Core Strategy Submission\Final Evidence for Inspector\Key context docs\Environmental sustainability\CS17 Waste\141-143 Joint Working\143 Potential for Joint Working on Waste Apportionment Nov 10 new layout.doc 37 11/05/10

12. The commitment to partnership working on waste apportionment matters will be achieved by an exchange of letters recognising the need to include appropriate arrangements regarding any necessary updates to reflect the commitment in both the City and Bexley LDF Core Strategies (subject to relevant consultation and any necessary authority for such updates). The City’s Core Strategy already allows for partnership working and can be amended to name Bexley as the partner (subject to consultation and authority). The commitment to partnership working will then be examined by the Planning Inspectorate during 2011 when the Core Strategies are examined for soundness.

Strategic Implications 13. The Mayor’s London Plan requires all local authorities to contribute to the

management of more of London’s waste within London. This requirement is enforced through the need for all local authorities to identify waste management capacity within London to meet their individual waste management apportionments. Meeting the City’s apportionment through partnership working with Bexley will satisfy London Plan policy and will ensure that the City is playing its part in the more sustainable management of London’s waste.

Consultees 14. A draft of this report has been the subject of consultation with the

Chamberlain, the Comptroller and City Solicitor, the Director of Environmental Services, the City Surveyor and the Director of Economic Development and their comments have been incorporated.

Conclusion 15. Approval of the report will enable the City Corporation to progress its

proposed partnership working with Bexley, thereby enabling the City’s LDF Core Strategy to satisfy the Mayor’s London Plan waste apportionment requirements. It will also enable the City Corporation to play its part in the more sustainable management of London’s waste.

Background Papers: Waste Arisings in the City of London. Consultant’s Report by AEA Energy & Environment. August 2008. Waste Management Capacity in the City of London. Consultant’s Report by AEA Energy & Environment. December 2009. Contact: Paul Beckett 020 7332 1970 [email protected] H:\devplan\Core Strategy Submission\Final Evidence for Inspector\Key context docs\Environmental sustainability\CS17 Waste\141-143 Joint Working\143 Potential for Joint Working on Waste Apportionment Nov 10 new layout.doc 38 11/05/10

Evidence of Bexley’s surplus capacity – extract from Appendix A of the Southeast London Boroughs’ joint waste apportionment technical paper Oct 2010.
