Overview and context
This guidance seeks to complement Policy 4 (Sustainable Construction and Waste Management in New Development) of the Surrey Waste Local Plan 2020 by providing context for the importance of and need for sustainable waste management as part of new development in the county. It also provides advice about Site Waste Management Plans to be submitted in support of planning applications for major development.
Section 336 of the Town and Country Planning Act 1990 and Article 3(1) of Directive 2008/98/EC of The European Parliament and of The Council say that 'waste' is any substance or object which the holder discards or intends or is required to discard.
All development generates waste. It arises from differing sources including land clearance and engineering operations, ground excavations, demolition of structures, construction activities, and occupation and use of land and buildings.
The volume or amount of waste generated by any development will depend on a range of variables including its scale, and whether it is permanent or temporary, or domestic, commercial, or industrial in nature.
There are a range of waste types, and different types of waste can be mixed. For the purposes of this note, the types of waste generated by development generally falls within three categories:
- Construction, Demolition and Excavation Waste (CD&E waste).
- Commercial and Industrial Waste (C&I waste).
- Local Authority Collected Waste (LACW).
CD&E waste generally comprises material resulting from the construction or demolition of buildings, ground excavations, or engineering operations. C&I waste arises from the use of land and buildings for commercial and/or industrial purposes including restaurants, hotels, cafes, trade businesses, and offices. The collection and management of CD&E and C&I waste occurs within the private sector and is facilitated through commercial contracts and by different types of waste management organisations.
LACW comprises material arising from households and collected by District and Borough Councils (Waste Collection Authorities) including food waste, plastic and metal, and black bag waste. It also includes a range of material which residents and businesses take to their local community recycling centres (CRC) such as domestic CD&E waste, garden waste, mattresses, old furniture and appliances, paint tins, and pieces of metal. Surrey County Council, as the Waste Disposal Authority, is responsible for managing LACW from Surrey's households and CRCs.
In England, the waste hierarchy is both a guide to sustainable waste management and a legal requirement enshrined in law through the Waste (England and Wales) Regulations 2011.
Figure 1. The Waste Hierarchy ranks differing ways of managing waste according to what is best for environmental outcomes.
Prevention is the best and most efficient way of managing waste. It means using less material in design and manufacture, keeping products in use for as long as possible, and using less hazardous material or substances.
Second order of preference is checking, cleaning, repairing, refurbishing, and reusing whole items or parts of items in other ways.
This is followed by recycling waste to turn it into a new substance or product for example turning food and garden waste into compost or soil-type products for horticulture, or waste from building or demolition operations into recycled aggregate for making concrete.
Next is other recovery, where waste is used for beneficial purposes instead of recycling it. This could be using discarded soil and earth from ground excavations to facilitate engineering operations or incinerating black bag waste which cannot be recycled to generate energy for heat or electricity.
The last and least preferred way of managing waste is through disposal. However, disposal of some waste continues to be necessary if it cannot be managed in any other way including by recycling or recovery for beneficial purposes. This type of waste is commonly referred to as 'residual waste' i.e., waste left over from other treatment processes.
Climate change and resource efficiency
The Intergovernmental Panel on Climate Change, in 2023, set out in their Climate Change Synthesis Report that there is clear scientific consensus that human activity is increasing the atmospheric concentration of greenhouse gases which is resulting in climate change and that this is causing widespread adverse impacts and related losses and damages to nature and people.
In the United Kingdom (UK), the Climate Change Act 2008 (2050 Target Amendment) contains a statutory target of securing a reduction in carbon dioxide levels of 100% below 1990 levels by 2050. It also requires the UK Government to set legally binding carbon budgets for each five-year period to 2050, of which those legislated to date run until 2037 through the sixth carbon budget.
The Climate Change Committee sets out in their Sixth Carbon Budget Advice, Methodology and Policy Report that the UK's sixth carbon budget, the legal limit for UK net emissions of greenhouse gases over the years 2033-37, requires a reduction in UK emissions of 78% by 2035 relative to 1990, a 63% reduction from 2019.
It also explains that although waste sector emissions in the UK have fallen 46% over the period 2008-2018 (and by 61% against 1990 levels), progress has stalled. It goes on to set out that total waste sector emissions increased by 3.7% from 2017 to 32.9 metric tonnes of carbon dioxide-equivalent in 2018 and explains that his is primarily due to the volumes of residual waste that end up in landfills or energy from waste facilities, and emissions associated with wastewater treatment. As of 2018, waste sector emissions accounted for 6% of total UK greenhouse gas emissions.
In this context, Section 182 of the Planning Act 2008 places a duty on planning authorities to include policies that contribute to climate change mitigation and adaptation in their local plans.
According to UKGBC's Net Zero Whole Life Carbon Roadmap, the built environment is responsible for some 25% of UK carbon emissions, of which about 25% is embodied emissions of buildings and other infrastructure. Moreover, UKGBC also reports on their web page that construction, demolition, and excavation account for 60% of material use and waste generation in the UK.
Consequently, developers must also address their responsibility for a changing climate and work with planning authorities to accelerate decarbonisation in the design, construction, demolition, and operation of development.
Fundamental to mitigating and adapting to a changing climate is moving towards a circular economy. A circular economy is an alternative to a traditional linear economy (make, use, and dispose) and an economic model where we keep resources in use for as long as possible extracting the maximum value from them whilst in use before they are recovered and regenerated at the end of their service life.
Unlike a linear economy, the basis of a circular economy is zero-waste, where everything that we produce and consume can return safely to nature or society. A zero-waste circular economy requires transformation of our production and consumption patterns to achieve high resource efficiency and a move towards zero waste.
Figure 2. Circular Economy - an economic model where we keep resources in use for as long as possible extracting the maximum value from them whilst in use before they are recovered and regenerated at the end of their service life.
By designing out waste and pollution, keeping products and materials in use for as long as possible, and regenerating rather than degrading natural systems, the circular economy represents a powerful contribution to combating climate change. Further, with increasing prices of construction material and waste disposal, embracing a circular economy would also increase business competitiveness, stimulate innovation, create jobs, and ultimately boost economic growth.
WRAP's 2021 Resource efficiency Scenarios for the UK: A technical report explains how changing the way we use materials and energy could deliver an additional 100 million tonnes (mt) reduction in territorial carbon dioxide emissions between 2023 and 2032, boosting savings from the UK Government's Ten Point Plan for a green industrial revolution by over 50%. It could also contribute over 10% of the reductions required from the fifth to the sixth recommended carbon budgets.
The Centre for Research into Energy Demand Solutions and WRAP's Net Zero: Why Resource Efficiency Holds the Answers report suggests, amongst other measures, that:
- By sharing a product with several people (changing use patterns), the resource productivity of the product will be increased and the consumption of natural resources in production will be reduced.
- Product lifetimes can be extended through simply making more use of the products we already have or passing them on to others to use.
- By increasing the amount of waste that is recycled and increasing the proportion of these recycled in the UK, will lead to greater carbon reductions.
- Across furniture, vehicles, construction, and packaging, it is possible to substitute high carbon intensity materials with lower carbon intensity alternatives that can perform the same role.
The Resources and Waste Strategy for England (2018) is particularly concerned with ensuring that society's approach to waste aligns with circular economy principles. The strategy has several strategic ambitions including the doubling of resource productivity and eliminating avoidable waste of all kinds by 2050.
Additionally, the Waste Management Plan for England (2021) and the Waste Prevention Programme for England: Maximising Resources, Minimising Waste (2023) both seek to facilitate a circular economy by encouraging people and businesses to use products for longer, repair broken items, and enable reuse of items by others.
The National Planning Policy Framework 2023 (NPPF) explains, at paragraphs 8 and 9, that planning policies and decisions in England should play an active role in guiding development towards sustainable solutions to:
- Help build a strong, responsive, and competitive economy.
- Support strong, vibrant, and healthy communities.
- Protect and enhance our natural, built, and historic environment.
More broadly, chapter 14 of the NPPF sets out how the land-use planning system should support the transition to a low carbon future through encouraging the reuse of existing resources, and chapter 17 supports the use of secondary or recycled materials. So that sustainable development in pursued in a positive way, paragraphs 10 and 11 explain that at the heart of the NPPF is a presumption in favour of sustainable development.
The National Planning Policy for Waste 2014 sets out, at paragraph 8, that in determining planning applications for non-waste development LPAs should ensure, amongst other things, that:
- New development makes sufficient provision for waste management and promotes good design to secure the integration of waste management facilities with the rest of the development and, in less developed areas, with the local landscape. This includes providing adequate storage facilities at residential premises, for example by ensuring that there is sufficient and discrete provision for bins, to facilitate a high quality, comprehensive and frequent household collection service.
- The handling of waste arising from the construction and operation of development maximises reuse/recovery opportunities and minimises off-site disposal.
In this regard, Policy 4 (Sustainable Construction and Waste Management in New Development) of the Surrey Waste Local Plan 2020 (SWLP) seeks to ensure that planning permission for new development is only granted where:
- CD&E waste is limited to the minimum quantity necessary.
- Opportunities for re-use and for the recycling of CD&E waste on the application site are maximised.
- On-site facilities to manage waste arising during the operation of the development are of an appropriate type and scale.
- Integrated storage to facilitate reuse and recycling of waste is incorporated in the development.
Sustainable management of CD&E waste can play a significant role in minimising the demand for primary aggregates and for other minerals used in construction; and careful design of development can reduce the amount of primary and recycled aggregate used in construction and ensure buildings can be adapted for different uses in the future.
In addition, Policy MC4 (Efficient Use of Mineral Resources) of the Surrey Minerals Plan Core Strategy 2011 (SMPCS) seeks to support and promote sustainable design and construction that provides for efficient use of minerals and enables the use of recycled and secondary aggregates in new development. Similarly, Policy MC5 (Recycled and Secondary Aggregates) of the SMPCS encourages the reuse of CD&E waste at source or its separation and collection for recycling off-site.
The SWLP and SMPCS form part of the Development Plan for Surrey and planning applications for new development should be determined in accordance with Policy 4, Policy MC4, and Policy MC5 unless material considerations (strongly) indicate otherwise. Section 70(2) of the Town and Country Planning Act 1990, Section 38(6) of the Planning and Compulsory Purchase Act 2004, and Section 92(5) of the Levelling Up and Regeneration Act 2023 are clear about this requirement.
Determining planning applications for most types of development in the county is the responsibility of Surrey's eleven LPAs. In this regard most local plans and associated guidance prepared by District and Borough Councils also seek to address the issues of sustainable design and construction including storage and collection of LACW and C&I waste. In addition to the SWLP and SMPCS, regard should also be given to local plans and relevant guidance in designing development and preparing planning applications.
The CD&E waste challenge
In 2021 some 3.3 million tonnes of waste was generated in Surrey. This included some 2,218,500 million tonnes (mt) of CD&E waste (about 68% of total waste arisings) of which about 1,666,000 mt comprised inert CD&E waste. From 2026 inert CD&E waste generated in the county is forecast to equal or exceed some 1,775,000 mt per annum.
The SWLP sets targets to increase recycling rates and decrease how much waste is disposed. Waste not managed by recycling or disposal is assumed to be managed through its recovery for beneficial purposes (including for energy). In this regard SWLP targets for CD&E waste management are shown in Table 1.
Table 1. CD&E Waste Management Targets
| Milestone target
| Milestone target
|Milestone target 2030
|Milestone target 2035
Once generated, the inert component of CD&E waste should be managed in two principal ways depending on its nature and composition. The first and preferred method is by way of recycling to produce recycled aggregate or soil type products. The second is by depositing it on land for beneficial purposes (recovery of waste) e.g., to facilitate engineering operations or restoration of mineral workings or non-inert landfills. For these reasons, the disposal of inert CD&E waste is not acceptable and should not be supported by LPAs.
Surrey has several recycling facilities (temporary and permanent) and recovery to land sites which can be used to manage inert CD&E waste arising in the county. However, because arisings continue to increase and some temporary facilities are set to close, from 2027 it is anticipated that Surrey will face a growing shortfall in inert CD&E waste management capacity:
Table 2. Inert CD&E Waste Management Capacity
| Capacity gap (mt) at milestone
| Capacity gap (mt) at milestone
| Capacity gap (mt) at milestones
| Capacity gap (mt) at milestones
|Aggregate recycling/recovery to land
There are three ways in which the shortfall in CD&E waste management capacity can be addressed. More management capacity can be provided by way of new or existing waste management facilities, or the amount of waste generated each year can be reduced, or the shortfall can be met through a combination of providing more capacity and producing less waste.
However, in the interests of promoting a circular economy, mitigating and adapting to climate change, and securing the best available outcomes for our natural environment the prevention and reuse of CD&E waste (as close to its source as possible) should be prioritised over recycling and recovery.
Further information about Surrey's future waste management needs can be found on Surrey County Council's monitoring web page.
Site waste management plans
Site Waste Management Plans (SWMP) can be an effective tool in ensuring that development proposals are sustainable in a waste management context. SWMPs help developers demonstrate how good waste management practices have been integrated into the design of development and, in turn, how development meets the requirements of SWLP Policy 4.
To ensure that waste management is considered as an integral part of the design of development SWMPs should be prepared at the earliest opportunity and include the following considerations:
- Integrating local waste management opportunities in new development particularly for large scale developments where there is scope for the recovery and use of energy for heat.
- Integrating appropriate facilities for storage, segregation, and regular collection and transfer of LACW and C&I waste such as bin stores, recycling bin sites, and composting facilities.
- Maximising opportunities to prevent, minimise, and reuse CD&E waste on or as close as possible to the development site.
- Maximising opportunities to recycle CD&E waste on or off the development site.
- Maximising sustainable construction practices including the use of recycled and recovered materials over primary resources and products.
Prior to the commencement of the development SWMPs should be augmented by:
- Identifying each type of waste expected to arise because of the development.
- Estimating the amount of each waste type that will arise because of the development.
- Identifying how each waste type will be managed on or off the application site.
Once SWMPs have been finalised or otherwise approved by LPAs, developers should:
- Ensure that the requirements of SWMPs are included in sub-contracts.
- Arrange suitable site induction, information, and training of personnel to raise awareness and ensure implementation of SWMPs.
- Take all reasonable steps to prevent unauthorised disposal of waste by others.
- Update SWMPs as the development progresses to reflect actual waste management details against planned details.
- At the end of the development (within 3 months) reconcile the planned management of waste against what happened and provide an explanation for any differences.
When should a site waste management plan be required?
Supporting information accompanying planning applications should be proportionate to the nature and scale of the relevant development including the type and amount of waste likely to be generated by that development.
Policy 4 of the SWLP relates to all new development. Regardless of its nature or scale, new development should have regard to sustainable waste management. However, the preparation and submission of SWMPs to demonstrate compliance with Policy 4 should only be required for planning applications seeking consent for major development which is defined in Annex 2: Glossary of the NPPF as:
- Development involving the construction of 10 or more dwellings.
- Development involving the construction of new floorspace of 1,000 square metres or more.
- Development of a site with an area of 1 hectare or greater.
- Or as otherwise provided in the Town and Country Planning (Development Management Procedure) (England) Order 2015.
A SWMP can be prepared as a stand-alone document or incorporated into another supporting document such as a Construction Environmental Management Plan or a Waste Strategy for LACW. Either way, the same information should be provided.
Suggested structure and content of site waste management plans
Section 1 – Introduction
Site Description and Development Overview
This should include a description of the application site and proposed development. It should also include details of who prepared the SWMP and when it was finalised for planning purposes.
Involved Parties and Contractors
This should include details of the client, principal contractor, and person(s) responsible for managing waste arising from the development. It should also include details of the person(s) or organisation(s) responsible for removing or otherwise transferring waste from the development site, where waste is taken to, and who receives waste:
|Name and address of person(s) or organisation(s) transferring waste
|Waste carriers registration number
| Waste management permit reference
(for receiving site)
|Address of receiving site
|Name and address of persons or organisation(s) receiving waste
|Mr J Smith
|1 Street Lane
|Mr A Smith
|Mrs J Smith
|2 Street Lane
|Mrs A Smith
Note: this is example data
Section 2 – Waste Management
Waste Management and Minimisation
This should include:
- A description of the waste type(s) expected to be produced during each phase of the development (using separate tables for each phase).
- An estimation of the volume (metres cubed) and quantity (in tonnes) of each waste type expected to be produced during each phase of the development.
- Information about how the volume (metres cubed) and quantity (in tonnes) of each waste type to be produced during each phase of the development will be measured.
- The waste management action proposed for each waste type, including reuse, recycling, recovery, transfer off-site, and disposal.
- The measures taken to reduce the amount of waste generated throughout the development.
|On-site waste reduction measures
|Concrete from demolition (demolition phase)
|Crushing to segregate reinforcement bar from concrete.
|Metal will be removed and taken for recycling as scrap where appropriate.
Separate storage for crushed concrete.
|Arrangements with skip hire firm to collect and re-recycle 2600 tonnes of metal and crushed concrete.
|On-site waste reduction measures
|Soil from excavation (excavation phase)
|Separate storage areas for screened material
|Screening of excavated material and re-use for landscaping purposes.
|Arrangements with soil recycling contractor to take residual material.
|On-site waste reduction measures
|Canteen waste once occupied (operational phase)
|< 2 tonnes per week
|Information campaign to inform staff about making use of reusable cups and cutlery etc.
|Providing separate bins for recyclable waste, and waste for disposal.
|Arrangements with private contractor to collect and treat recyclable waste.
Note: this is example data
Duty of Care
This should outline all reasonable measures to ensure:
- All waste arising on the application site is managed in accordance with the waste duty of care in section 34 of the Environmental Protection Act 1990 and the Environmental Protection (Duty of Care) regulations 1991.
- Materials will be handled efficiently, and waste managed appropriately.
Section 3 - Monitoring
This should set out the measures that will be taken to monitor waste generation and fate throughout all stages of the project. The waste management and minimisation measures identified before commencement of development should be updated as the project progresses. The data can be used to monitor performance in minimising waste and compare the actual amount of waste arisings and costs with predicted values.
Further sources of information
Should you require any further information or guidance please see the resources and references signposted throughout this document or the publications below. Alternatively, you can contact your Local Planning Authority.
- The Circular Economy wiki web page for designing buildings
- Department for Environment, Food and Rural Affairs non-statutory guidance for site waste management plans
- Environment Agency's advice for business waste and environmental impact
- The Environmental Services Association homepage
- The building research establishment environmental assessment methodology homepage
- UK Green Building Council web page on system enablers for a circular economy