Main Points of the PWA Submission
This consultation is the ‘pre-submission’ consultation, and it’s the last one before the the North London Waste Plan (NLWP) is examined in public in front of an independent Planning Inspector. This is scheduled for the autumn.
The consultation asks certain questions about the plan’s fitness to be examined. Is it legal? Is it sound? Has it followed due process?
The planning officers tell us that it’ll be examined under the new London Plan, due for adoption in 2020, which is undergoing its own long public examination at present.
It must be ‘in general conformity’ with the London Plan:
•A waste plan (usually 15 years) must first assess how much waste it will need to deal with.
•It must look at existing waste processing capacity within its area, and how capable that is to deal with forecast waste ‘arisings’ as they are known.
•Before assessing if it needs any new land, it must investigate possibilities of expansion or intensification of operations at existing waste use sites. This may be through improved technology, increased capacity or expanding the range of waste treated.
•The London Plan has looked at available evidence and assessed how much waste London as a whole will produce over the next 15 years. It has then ‘apportioned’ that waste among the 32 boroughs, depending on a borough’s ability to treat waste. The boroughs must plan for that amount at a minimum
•The seven member councils of the NLWP have chosen to pool their apportionments, hence the plan we are now discussing.
Waste forecasting is a notoriously inaccurate business. One only has to look at the original proposal of a 300,000 tons per year plant on Pinkham Way, abandoned as unnecessary within 18 months of its being announced, to realise that.
•The NLWP has disregarded the apportionments in the London Plan, and instead is choosing the North London Waste Authority’s (NLWA) independent forecasts. These are nearly 40% higher than the waste apportionment for the 7 member councils set out in the LP.
•The forecasts are based on a model prepared in 2014 for the NLWA’s application for the new Edmonton plant. The study was peppered with caveats on the difficulty of long term waste forecasting. This is what the consultants Eunomia stated:
‘… we have at most 15 years’ worth of observations on which to base our projections ... we would not normally advise forecasting for more than a very small number of years into the future on this basis’.
•In the very few years since Eunomia prepared its study, actual waste is already 10% under its forecast. The caveats were absolutely justified..
•The NLWP asserts that waste will grow as population increases. Uptodate evidence simply doesn’t support this assertion – since 2006 total population in the NLWA area has risen by over 25%, whilst total waste arisings have fallen significantly.
•Assuming that the London Plan has based its estimates on the available evidence and proper objective analysis, it follows that it is impossible for the NLWP, a subset of the London Plan, to assess the same evidence and come to a conclusion so different, whilst claiming that its strategy is sound and the most appropriate.
•With forecasting so intrinsically problematic, it’s anomalous that the NLWP has chosen to go out on such a statistical limb.
•In our view there are other factors at work. One is the need to justify the scale of the proposed new plant at Edmonton, and the other is to support the need for new land for waste treatment.
•After so many years, no prizes for guessing what particular land that might mean!
Existing waste treatment capacity:
Even given the fact that the councils are planning to deal with waste arisings far above their apportionments, N London still has more than enough treatment capacity – over 50% more - to deal with it.
•No mention of intensification ie increasing capacity / efficiency of existing sites.
•The NLWP actually aggravates the inaccuracy of long term forecasting by slicing various main 'waste streams’ (eg household, commercial etc) into over 30 smaller specialist segments, and then
•... calculates its need for land on any lack of existing micro-capacity for these precise micro-segments.
•When these are all added up the need for land naturally increases, reinforcing the picture of the NLWP as a mechanism for over-providing land, incidentally aiming to justify the inclusion of the Pinkham Way Nature Conservation Site - an open green space.
The London Plan states clearly that boroughs must site new waste facilities on Industrial Land – designated as Strategic Industrial Locations or Locally Significant Industrial Land:
•As you’ll remember, the 2012 Inspector rejected Haringey’s attempt to redesignate PW as industrial land.
•Haringey has continued to insist that Pinkham Way is suitable for waste use, but has never produced supporting evidence. Neither can we find any justification in the London Plan, or in any of the other London borough’s Local plans.
•As it’s a protected nature conservation site there should be special reasons to justify its inclusion – we have seen none.
•The NLWP has identified 98 ha from which to find 9 ha of extra land that they say is needed - and which we say is an overestimate. All land included is designated Industrial, apart from PW (removing the 4 ha plus area of PW would still leave plenty of industrial land to choose from).
•For NLWP purposes, the effective size of the site is just over 4 ha, which is the NLWA-owned portion of the site. Barnet has its own plans for the remainder. A good 80% of the NLWA portion is covered in trees, and c 20% is in the Flood Zone of the highest risk.
The inclusion of Pinkham Way SINC in the NLWP:
•PW’s inclusion is based on a site assessment that is designed to identify sites suitable for inclusion in the NLWP after they have been put forward by the boroughs - the assumption being that before putting land forward boroughswould have assessed it against the NPPF, the LP and policies in its own Strategic Plan and would have considered its current value to the borough.
•The consultant that reviewed the site for Haringey in 2015 advised the council that Pinkham Way was of high ecological value and a rare asset for the borough. We have seen no evidence that Haringey carried out a proper - or any - assessment of PW and its value to the borough as a whole before agreeing to its inclusion in this plan.
•The site’s inclusion is against National and London Plan policies on Open Space and Nature Conservation Sites and does not fall within the Industrial land category identified in the LP.
•It is against Local Plan biodiversity policies of all member councils. These all emphasise protection of Open Space, SINCs and particularly of priority habitats and species.
•Priority habitats and species‘… are conservation priorities in London’ - London Environmental Strategy (LES), part of the London Plan.
•Natural England considers the site as of Metropolitan, ie London-wide, Importance.
•LES states;‘Sites of Met Importance are of the highest priority for protection …they include habitats typical of urban areas, e.g. various types of abandoned land colonised by nature (‘wasteland’ or ‘brownfield’).
•Pinkham Way identified as Green Space in Council maps. London Plan defines ‘Green Space’ as: ‘All vegetated open space of public value … which offer opportunitiesfor …wildlife conservation and other benefits such as storing flood water’
•Pinkham Way is part of London’s ‘Green Cover’:‘The total area covered by vegetation and water across London. It … includes publicly accessible and vegetated land (i.e. green space) and waterways, but also non-accessible green spaces …‘
•In terms of its capacity to absorb water, NLWP consultants regard the site as greenfield, and highlight the increased risk to surrounding areas were the site to be substantially covered in hard surfacing, the consequences of which would of course be exacrebaated by the removal of hectares of tree cover.
•Any development plan must assess the risk 'downstream' of any increased Flood Risk on Pinkham Way, first on to the A406, which is the old valley of the Bounds Green Brook, and further on into the Pymmes Brook catchment, which extends all the way to the River Lea, and is of moderate to severe risk most of the way. This is a most serious omission.
THE NORTH LONDON WASTE PLAN
REGULATION 19 CONSULTATION (March - April 2019)