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Policy SI8 Waste capacity and net waste self sufficiency


  1. In order to manage London’s waste sustainably:
    1. the equivalent of 100 per cent of London’s waste should be managed within London (i.e. net self-sufficiency) by 2026
    2. existing waste management sites should be safeguarded (see Policy SI9 Safeguarded waste sites)
    3. the waste management capacity of existing sites should be optimised
    4. new waste management sites should be provided where required
    5. environmental, social and economic benefits from waste and secondary materials management should be created.
  2. Development Plans should:
    1. identify how waste will be reduced, in line with the principles of the Circular Economy and how remaining quantums of waste will be managed
    2. allocate sufficient land and identify waste management facilities to provide the capacity to manage the apportioned tonnages of waste, as set out in Table 9.2 - boroughs are encouraged to collaborate by pooling their apportionment requirements
    3. identify the following as suitable locations to manage borough waste apportionments:
      1. existing waste and secondary material sites/land, particularly waste transfer facilities, with a view to maximising their capacity
      2. Strategic Industrial Locations and Locally Significant Employment Sites / land
      3. safeguarded wharves with an existing or future potential for waste and secondary material management.
  3. The following are particularly encouraged – development proposals which:
    1. deliver a range of complementary waste management and secondary material processing facilities on a single site
    2. support prolonged product life and production of secondary materials including repair, refurbishment and remanufacture
    3. contribute towards renewable energy generation, especially renewable gas technologies from organic/biomass waste
    4. provide combined heat and power and/or combined cooling heat and power
    5. contain proposals to effectively deal with CD&E waste on site and minimise export to landfill.
  4. Developments proposals for new waste sites or to increase the capacity of existing sites should be evaluated against the following criteria:
    1. the nature of the activity, its scale and location
    2. job creation and social value benefits including skills, training and apprenticeship opportunities
    3. achieving a positive carbon outcome (i.e. re-using and recycling high carbon content materials) resulting in significant greenhouse gas savings - facilities generating energy from waste will need to meet, or demonstrate that steps are in place to meet, a minimum performance of 400g of CO2 equivalent per kilowatt hour of electricity produced
    4. the impact on amenity in surrounding areas (including but not limited to noise, odours, air quality and visual impact) - where a site is likely to produce significant air quality, dust or noise impacts, it should be fully enclosed
    5. the transport and environmental impacts of all vehicle movements related to the proposal - the use of renewable fuels from waste sources and the use of rail and waterway networks to transport waste should be supported.

Table 9.1 - Forecast arisings of Household and Commercial & Industrial waste by borough 2021-2041 (000’s tonnes)

Barking & Dagenham214230
City of London230238
Hammersmith & Fulham 183190
Kensington & Chelsea202211
Tower Hamlets260273
Waltham Forest202180
City of Westminster722750
London total8,2168,726

Table 9.2 - Borough-level apportionments of Household and Commercial & Industrial waste 2021-2041 (000’s tonnes)

Barking & Dagenham6.1505537
City of London1.08489
Hammersmith & Fulham 2.6210222
Kensington & Chelsea1.4116123
Tower Hamlets2.4195207
Waltham Forest2.4199211
City of Westminster2.3188199
London total100.08,2168,726

* Apportionment is per cent share of London’s total waste to be managed by borough

Table 9.3 - Projected exports of Household and Commercial & Industrial waste from London (000’s tonnes)

London’s arisings8,1008,2168,2998,726
London’s exports3,4491,72500

Note: 2015 is an actual figure (SLR May 2017), data for 2021, 2026 and 2041 are projections

In 2015, London managed 7.5mt of its own waste and exported 11.4mt of waste. London also imported 3.6mt of waste. This gives London a current waste net self-sufficiency figure of approximately 60 per cent. Around 5mt (49 per cent) of waste exported from London went to the East of England and 4.2mt (42 per cent) to the South East. The bulk of this waste is CD&E waste. Approximately 1.3mt of waste was exported overseas.

In 2015, 2.9mt of the waste sent to the East of England went to landfill and 2.2mt went to landfill in the South East. Some 32 per cent of London’s waste that was biodegradable or recyclable was sent to landfill. The Mayor is committed to sending zero biodegradable or recyclable waste to landfill by 2026 (see Table 9.3).

Waste contracts do not recognise administrative boundaries and waste flows across borders. Therefore, sufficient sites should be identified within London to deal with the equivalent of 100 per cent of the waste apportioned to the boroughs as set out in Table 9.2. The Mayor will work with boroughs, the London Waste and Recycling Board, and the London and neighbouring Regional Technical Advisory Bodies to address cross-boundary waste flow issues.

Waste is deemed to be managed in London if any of the following activities take place within London:

  • waste is used for energy recovery
  • it relates to production of solid recovered fuel (SRF), or it is high-quality refuse-derived fuel (RDF) meeting the Defra RDF definition as a minimum[131]
  • it is sorted or bulked for re-use (including repair and re-manufacture) reprocessing or recycling (including anaerobic digestion)
  • It is reused, recycled or reprocessed.

[131] for an explanation of the differences between SRF and RDF

Supporting the production of SRF and high quality RDF feedstock will promote local energy generation and benefit Londoners, improving London’s energy security, helping to achieve regional self-sufficiency and possibly reducing leakage of SRF and RDF overseas. London facilities should produce high-quality waste feedstock with very little recyclable content (i.e. plastics), supporting renewable energy generation.

Table 9.1 shows projected arisings for Household and Commercial & Industrial waste for each borough. National policy guidance requires boroughs to have regard to the waste apportionments set out in the London Plan. The Plan’s waste apportionment model defines the proportion of London’s total Household and Commercial & Industrial waste that each borough should plan for, and these apportionments are set out in Table 9.2. Part B.2 of Policy SI8 Waste capacity and net waste self-sufficiency requires boroughs to allocate sufficient land (sites and/or areas) and identify waste management facilities to provide the capacity to manage their apportioned tonnages of waste. Boroughs are encouraged to collaborate by pooling their apportionment requirements.

Boroughs should examine in detail how capacity can be delivered at the local level through site allocations in Development Plans to meet their apportionments, and should aim to meet their waste apportionment as a minimum. However, this may not always be possible and boroughs will need to agree the transfer of apportioned waste. Boroughs should identify suitable additional sites for waste including waste transfer sites where practicable. Where apportionments are pooled, boroughs must demonstrate how their joint apportionment targets will be met, for example through joint waste Development Plan Documents, joint evidence papers or bilateral agreements. Mayoral Development Corporations should cooperate with boroughs to ensure that the boroughs’ apportionment requirements are met. This could be widened to cover boroughs in the relevant waste disposal authority. Plans or agreements safeguarding waste sites should take a flexible approach. They should be regularly reviewed and updated to take account of development that may lead to the integration of waste sites or appropriate relocation of lost waste sites. Waste plans should be responsive to strategic opportunities across borough and joint waste planning boundaries for optimising capacity on existing waste sites, or that help to unlock investment in developing new waste sites.

Land in Strategic Industrial Locations will provide the main opportunities for locating waste treatment facilities. Existing waste management sites should be clearly identified and safeguarded for waste use. Boroughs should also look to Locally Significant Industrial Sites and existing waste management sites. Large-scale redevelopment opportunities and redevelopment proposals should incorporate waste management facilities within them. The London Waste Map[132] shows the locations of London’s permitted waste facilities and sites that may be suitable for waste facility location.


As noted above waste flows across boundaries and London exported 3.4mt of Household and Commercial & Industrial waste in 2015. To meet the Mayor’s policy commitment of net self-sufficiency by 2026 there needs to be a reduction in exports over the decade to 2026. Table 9.3 is included to help neighbouring authorities plan for London’s waste exports.

Tables 9.1, 9.2 and 9.3 only refer to Household and Commercial and Industrial Waste, not Construction, Demolition and Excavation (CD&E) Waste. As the reliability of CD&E waste data is low, apportionments for this waste stream are not set out. For a fuller discussion of the issues around CD&E data see the SLR consulting report (task 2) (May 2017).

To support the shift towards a low-carbon circular economy, all facilities generating energy from waste should meet, or demonstrate that they can meet in future, a measure of minimum greenhouse gas performance known as the carbon intensity floor (CIF). The CIF is set at 400g of CO2 equivalent generated per kilowatt hour (kwh) of electricity generated. The GLA’s free on-line ready reckoner tool can assist boroughs and applicants in measuring and determining performance against the CIF[133]. Achieving the CIF effectively rules out traditional mass burn incineration techniques generating electricity only. Instead, it supports techniques where both heat and power generated are used, and technologies are able to achieve high efficiencies, such as when linked with gas engines and hydrogen fuel cells. More information on how the CIF has been developed and how to meet it can be found in the London Environment Strategy.


Waste to energy facilities should be equipped with a heat off-take from the outset such that a future heat demand can be supplied without the need to modify the heat producing plant in any way or entail its unplanned shut-down. It should be demonstrated that capacity of the heat off-take meets the CIF at 100 per cent heat supply. In order to ensure it remains relevant, the CIF level will be kept under review.

Examples of the ‘demonstrable steps’ required under part D3 of Policy SI8 Waste capacity and net waste self-sufficiency are:

  • A commitment to source truly residual waste – waste with as little recyclable material as possible.
  • A commitment (via a Section 106 obligation) to deliver the necessary means for infrastructure to meet the minimum CO2 standard, for example investment in the development of a heat distribution network to the site boundary, or technology modifications that improve plant efficiency.
  • An agreed timeframe (via a Section 106 agreement) as to when proposed measures will be delivered.
  • The establishment of a working group to progress the agreed steps and monitor and report performance to the consenting authority.

To assist in the delivery of ‘demonstrable steps’ the GLA can help to advise on heat take-off opportunities for waste to energy projects, particularly where these are linked to GLA supported energy masterplans.

In 2015 around 324,000 tonnes of hazardous waste was produced in London. London sends small amounts of hazardous waste to landfill outside of London, approximately three per cent of the national total. The amount of such waste produced has continued to grow in the short and medium term. Without sustained action, there remains the risk of a major shortfall in our capacity to treat and dispose of hazardous waste safely. This could lead to storage problems, illegal disposal (including fly tipping) and rising public concern about health and environmental impacts. There is therefore a need to continue to identify hazardous waste capacity for London. The main requirement is for sites for regional facilities to be identified. Boroughs will need to work with neighbouring authorities to consider the necessary facilities when planning for their hazardous waste.

Waste processing facilities should be well designed. They should respect context, not be visually overbearing and should contribute to the local economy as a source of new products and new jobs. They should be developed and designed in consultation with local communities, taking account of health and safety within the facility, the site and adjoining neighbourhoods. Developments supporting circular economy outcomes such as re-use, repair and re-manufacture, will be encouraged. Where movement of waste is required, priority should be given to facilities for movement by river or rail. Opportunities for combined heat, power and cooling should be taken wherever possible. Although no further landfill proposals in London are identified or anticipated within the Plan period, if proposals do come forward for new or extended landfill capacity or for land-raising, boroughs should ensure that the resultant void-space has regard to the London Environment Strategy.

Following the Agent of Change principle, developments adjacent to waste management sites should be designed to minimise the potential for disturbance and conflicts of use. Developers should refer to the London Waste and Recycling Board’s design guide for ensuring adequate and easily accessible storage space for high-rise developments, see part G of Policy D4 Housing quality and standards.