We've now submitted our response to the North London Waste Plan consultation, which closed on 30th September 2015. Thanks for your comments.
We support many of the objectives of the plan, especially:
- Net self-sufficiency in waste for the NLWP area.
- Virtually eliminating landfilling of household waste.
We think the plan is flawed for the following reasons:
- It misses the opportunity to provide land for prevention and re-use, options that are at the top of the waste hierarchy.
- We don't think the plan lives up to the objective of net self-sufficiency as it envisages increasing amounts of excavation waste continuing to be landfilled outside the NLWP area.
- It proposes as "most suitable" a number of sites and areas for waste use that it's own analysis shows are "possibly suitable with significant mitigation issues to address". We don't agree that these site are the "most suitable".
- We think the plan should include a strategy for reducing imports and exports of waste as well as net self-sufficiency.
- No evidence is presented to support the assumption of future growth in waste arisings, indeed household waste arisings have been flat since 2008 despite a rising population.
- The forecast for waste arisings (used to identify capacity gaps) is flawed and inconsistent.
- Some of the capacity gaps disappear if Edmonton would accept commercial and industrial waste. No rationale has been presented why this is not possible.
- No analysis is presented to show that the 16ha of additional land could not be provided within existing waste sites or those which are most suitable for waste use.
- The allocation of 354ha of land for waste use, much of which is only marginally suitable, in response to a need of 16ha is grossly disproportionate and not justified.