Taken from Recycling & Waste World published 18.08.11
Smoothing the way for contentious facilities
As the Government publishes its draft national policy statement (NPS) for hazardous waste Rebecca Eatwell, Head of Waste & Resources at communications consultancy PPS Group investigates the opportunities and challenges for the waste sector in delivering a new generation of hazardous waste facilities.
What is hazardous waste?
There are few development proposals that will attract the attention of local communities and stakeholders in the same way as a hazardous waste facility. Non-hazardous waste facilities have the potential to be controversial at the best of times, but couple ‘waste’ with ‘hazardous’ and the communication challenge is tenfold.
But what is hazardous waste? The definition of hazardous waste is ‘waste that contains one or more hazardous properties that may cause harm to human health or the environment’. In fact, this can include everyday items such as TVs and fridges coming to the end of their lives. Whilst the majority of hazardous waste is produced by the chemical and oil industries and by construction and demolition work, the types of waste this can include cover everything from asbestos to old tins of paint.
Hazardous waste accounts for only a small percentage of total waste arisings, however the volumes produced are significant with around 4.8 million tonnes produced in England and Wales in 2008. This figure is also likely to increase, despite efforts to minimise hazardous waste arisings, as new European Union (EU) measures see more waste classified as hazardous.
Nationally significant hazardous waste infrastructure
The draft National Policy Statement (NPS) on Hazardous Waste is one of a series of NPSs published by the Government to establish a framework for nationally significant infrastructure projects. This means that planning applications for hazardous waste facilities over a certain size will be dealt with by the Infrastructure Planning Commission (IPC) – which is due to be replaced through the Localism Bill by the Major Infrastructure Unit – rather than by the local waste planning authority.
Whereas non-hazardous waste facilities must generate over 50MW of electricity in order to be considered as nationally significant (which could equate to treating over 450,000 tonnes of waste a year), the Hazardous Waste NPS covers facilities which will treat just 30,000 tonnes per year (or 100,000 tonnes per year for landfill or deep storage).
This reflects the desire in Defra’s 2010 Hazardous Waste Strategy to ‘facilitate the provision of infrastructure for the management of hazardous waste’. New infrastructure is needed to move hazardous waste up the hierarchy by providing facilities which enable more reuse, recycling and recovery.
Rather than prescribing where and what should be built the government is looking to the industry to use its expertise to determine what is required. By providing certainty about government intentions for hazardous waste it is hoped that the NPS will encourage the private sector to bring forward proposals. Given the potentially highly controversial nature of hazardous waste facilities coupled with the pressing need for new infrastructure, it could be said that providing a strategic route for these facilities is vital.
The IPC process
Many within the waste industry have argued that the threshold for IPC applications should be lowered for non-hazardous waste projects, given the difficulties faced in navigating the local planning system for Energy from Waste (EfW) facilities. However, experience shows that taking a planning application down the IPC route is not an ‘easy option’.
PPS Group is working for EDF Energy on its proposals for a new nuclear facility at Hinkley Point, which is currently going through the IPC process. Whilst the IPC is being replaced by the Major Infrastructure Unit, it is expected that the consultation requirements for such applications will remain broadly similar. There are different types of consultation which a developer is required to undertake for an IPC application, each with different requirements, including consultation with:
- statutory consultees and those with an interest in the land
- local community and those living in the vicinity of the land
- the wider general public
For an application going through the IPC process the local authority is essentially a statutory consultee. However, this does not mean that their role and influence should be underestimated. The local authority will review and approve the consultation process, which must be set out formally through a Statement of Community Consultation (SOCC), and therefore effective joint working will make for a smoother process.
The SOCC is a formal document which steers the whole consultation process. Keeping this high level and flexible will enable you to adapt the consultation programme as you progress. Furthermore, as it currently needs to be published, in full, in a locally circulating newspaper, it is important not to get bogged down in the detail.
Multi-stage consultations will be essential for large-scale projects such as a hazardous waste facility. It is likely that an initial stage of consultation would be needed to introduce the project and options, followed by a consultation on preferred proposals. Subsequent consultations on material changes then may be required before the submission of a development consent order to the IPC.
A variety of consultation techniques will be essential in order to demonstrate that the consultation is accessible to all those living in the area. In addition to traditional consultation methods such as newsletters, public exhibitions, website, focus groups and workshops, consideration should also be given to ensuring that hard to reach groups are able to participate.
Careful recording of all the different elements of the consultation process is imperative. Utilising consultation software can be a useful way of recording and analysing the variety of responses and feedback received through the process. It will also be important to decide at the start of the consultation process how the final consultation report will be structured and how responses will be classified and responded to from the outset.
Whilst applications to the IPC will take a strategic route, developers will still need to engage with local communities and politicians to address their concerns. The NPS highlights the potential impacts of hazardous waste facilities, including visual, biodiversity, noise, air emissions, dust, odour and traffic. It is important to explain in simple terms how these potential impacts will be mitigated against to protect local people and the environment.
An opportunity?
Despite the obvious challenges in developing hazardous waste facilities, the draft NPS will help to move another waste stream up the hierarchy and divert it from landfill. The need for new hazardous waste infrastructure presents a new growth area for the industry at a time when the municipal waste PFI programme is coming to an end. Whilst the NPS will provide a strong policy framework for new hazardous waste infrastructure, which should help to underpin investment, the development of these facilities will be highly scrutinised. The fact that the Environment, Food and Rural Affairs (EFRA) Committee has launched an inquiry into the proposed hazardous waste NPS indicates the level of attention this type of facility will attract.
Whilst the government is providing a framework for the hazardous waste debate it is the developers of infrastructure that will be at the coalface, engaging directly with local communities. The challenges that hazardous waste projects present can be overcome with a comprehensive and carefully planned communications programme which is tailored to the local situation. The major players in the waste management sector are well placed to take on the local and national debate and work with local communities to deliver this essential infrastructure.
Rebecca Eatwell is Head of Waste & Resources at communications consultancy PPS Group, rebecca.eatwell@ppsgroup.co.uk , 0207 529 1700
Tags: "PPS PR" "Waste & Resources" "PPS Group"
Written by reatwell