Comment

Representation ID: 674

Received: 31/03/2022

Respondent: Mr Christopher Taylor

Agent: Mr Andrew Barton

Para 7.48 This para is broadly supported, but it should also recognise that as the drive to divert the
remaining waste from landfill progresses across the UK, and as the EfW market matures, there
will be a requirement for more centralised EfW facilities serving relatively wide catchments
and several WPA areas. The WLP should not preclude such facilities where appropriately
sited, notwithstanding that quite possibly the majority of waste they may treat may not arise
within the WLP area.
We also note that whilst the WLP itself deals with the proximity principle in, we believe, a fair
and balanced way, para 6.1 of the WNA gets the definition of the principle and, more
significantly, the related self-sufficiency principle (as defined in the WFD), hopelessly wrong.
The self-sufficiency principle does not, as the WNA claims, relate to regionality. As para 152
of Defra’s ‘Energy-from-Waste: A Guide to the debate’ states: “ The proximity principle arises
from Article 16, “Principles of self-sufficiency and proximity”, of the revised Waste Framework
Directive (2008/98/EC), the EU legislation that governs waste management. The principle is
often over-interpreted to mean that all waste has to be managed as close to its source as
possible to the exclusion of other considerations, and that local authorities individually need
the infrastructure required to do so. This is not the case. Indeed the final part of the Article itself states, “The principles of proximity and self-sufficiency shall not mean that each Member
State has to possess the full range of final recovery facilities within that Member State”. Clearly
if not even the entire country needs to have the full range of facilities, a specific local authority
does not have to. While there is an underlying principle of waste being managed close to its
source, there is no implication of local authorities needing to be self-sufficient in handling
waste from their own area”.