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Draft SPP10 was published in August 2006 and comments on this draft were invited by 6 November 2006. The purpose of the SPP is to provide guidance to planning authorities on their role in helping to further the National Waste Plan's objectives in relation to sustainable waste management; to help achieve compliance with environmental legislation on waste management and to ensure compliance with EC Directives. In December 2006 the Scottish Executive commissioned Halliday Fraser Munro Planning to undertake an analysis of the consultation responses received on Draft SPP10.

Main Findings

• The review of SPP10 was broadly supported and the draft SPP10 was seen as timeous;
• One of the main factors arising from the review of SPP10 was the lack of reference and guidance to non-municipal waste throughout the SPP;
• In considering the policy context there needs to be a greater focus on inter-authority working and further guidance on the planning policy hierarchy;
• More emphasis is required to take account of local circumstances and context rather than focussing on set distances, this particularly refers to buffer zones, the proximity principle and proximity to settlements;
• The principle of a model policy was welcomed by many respondents however, it was suggested that the inclusion of Class 4 business land needs to be considered in greater depth and in general the policy requires to have greater flexibility;
• Further emphasis is required on the benefits of energy from waste facilities;
• There is perhaps a greater role for SEPA in relation to the provision of advice and in helping with resourcing constraints.

Background

Draft SPP10: Planning for Waste Management was published in August 2006 with responses sought by 6 November 2006. The consultation exercise attracted 55 responses from a range of groups, individuals and organisations.

Draft SPP10 sets out and updates policy on waste management and provides guidance to planning authorities.

The aim of this research was to carry out a review and analysis of the responses received in relation to the consultation exercise.

Method

Halliday Fraser Munro Planning developed Response Analysis Pro-formas to review in-depth the responses received, identify comments on specific elements, issues of key concern and any themes emerging from particular sectors.

These pro-formas were used to distil and sort wide-ranging comments into particular topics. Once sorted the comments were then reviewed to generate the report's findings.

Research Findings

Policy Context

This section of the SPP sets out the policy context within the Planning White Paper and the Planning Bill for SPP10 in relation to EC Directives and targets and standards set out in the National Waste Plan.

The findings suggested that further information is required on the relationships between the different levels of planning and integration with relevant national and area waste plans.

The business responses welcomed the recognition of waste within the planning policy context but also suggested that the SPP set measures and actions against those councils that fail to meet targets.

A general theme emerging from the responses was that there was widespread support for distinction of the role of the planning authority from those with more technical input such as SEPA, however that this should be simplified and set out more clearly.

A contradiction emerged regarding working with communities versus national or major projects determined centrally.

Waste Infrastructure

This section sets out some of the types of waste infrastructure required. Further advice was sought on the balance, type and scale depending on the local, regional and national requirement. The findings also outlined that the SPP should encourage greater promotion of joint working between authorities in general. Local authorities felt that development plans should seek to safeguard all sustainable waste management facilities and not just landfill.

Sustainable Waste Management

The relationship of waste management and health was outlined in the draft SPP10. Respondents overall welcomed this reference, however concern was expressed amongst all sectors over the role of planning authorities in health issues, ability to judge health impacts and the potential duplication of the roles for other parties.

The proximity principle and proximity to settlements attracted a wide variety of responses from the consultees. These responses varied somewhat amongst the sectors with some sectors expressing support for small scale facilities located within the community and others outlining a preference for larger facilities out of town. Overall however, there was general agreement over the impact that each of these options might have.

The issue of buffer zones also attracted a wide variety and number of responses. Support for buffer zones emerged through the responses, however concern was expressed over the reference to a standard distance and suggested that such zones required to take greater account of local circumstances and be flexible to the local context.

The analysis indicated strong support for enhanced working with communities. In particular, the business view was supportive of enhanced community involvement but that there was an onus on communities to engage and this should be reflected in the planning process.

Concern was expressed amongst community groups regarding the use of Good Neighbour Agreements, preferring concerns to be addressed by local officers and members. On the other hand local authorities supported them. This would suggest that these require further thought.

Development Plans and Waste Management

In relation to need, SEPA was identified as a source of further information when determining need.

This section of the SPP provided guidance on areas of search and site assessment. The findings outlined that local authorities sought greater flexibility in development plans and where a criteria based or site specific approach is more appropriate. In general the responses suggested that further clarification is required on the process of identifying sites and areas of search.

Specific comment was sought from consultees on a model policy. Respondents in general welcomed the introduction of a model policy, however many questioned the policy principles of this. Strong objection came through many of the responses to the use of Class 4 business land for waste management infrastructure and many planning authorities sought greater flexibility in the policy.

The findings support supplementary planning guidance as a useful tool to ensure integrated waste management in new development.

Assessing Development Proposals

This area in particular received a number of specific comments from various sectors. The findings suggested that consultees were largely in agreement with these sections with some further consideration of the finer detail required.

On the issue of thermal treatment plants there was general support for the approach, particularly amongst the business sector who support the co-location of industry and thermal treatment plants.

Coming through the findings was a clear message that there needed to be further recognition that energy from waste is a business opportunity. It creates economic growth and jobs, as well as processing waste.

Development Management

There were strong views amongst the responses for a greater role for enforcement. Communities were concerned about enforcement and the ability for this to be able to operate 24 hours a day because of an associated lack of resources. This was also reflected in the responses received from local authorities.

Design

The section on design was welcomed across all respondents, with a suggestion that it may be useful to cite some European examples of good design within the SPP.

Monitoring and Implementation

The findings suggested that there is support for a partnership approach to monitoring and implementation, however more focus is required on inter-authority co-operation.

Policy Framework Annex

A policy framework annex was included in the Draft SPP10 to set out the purpose and role of the various policies. Whilst there were few comments received in relation to this, those that responded felt that this was a clear and simple way of setting out the relevant policies and providing information on their role.

Issues Raised Outwith the Structure of the Draft SPP10

As outlined in the main findings a key theme running through the responses was the lack of reference to non-municipal waste throughout the SPP. Respondents suggested that this is a key issue that should be considered in the SPP particularly in relation to the different volumes and waste streams and its overall economic importance.

"Draft Scottish Planning Policy 10: Planning for Waste Management Analysis of Consultation Responses" the research report which is summarised in this research finding, is available at: www.scotland.gov.uk/Topics/Planning/Consultations

or from

Tel: 08457 741741

August 2007

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