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Official Official
Regulation 18
Draft Updated West London
Waste Plan
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October 2025
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Appendix C
Project: West London Waste Plan
Document: Regulation 18 Draft Plan
Version: LPA Member Sign Off 07.10.2025
Official Official
Contents
1. Executive Summary ..............................................................................................................1
2. Introduction and background ................................................................................................3
What is the West London Waste Plan? .............................................................................3
The need to replace the current waste plan .......................................................................4
The process of preparing the West London Waste Plan ....................................................5
Key elements of the West London Waste Plan .................................................................6
This stage of preparing the WLWP ....................................................................................6
Supporting documents .......................................................................................................7
How to comment on the Regulation 18 Draft WLWP .........................................................7
3. The Plan Context ..................................................................................................................8
Spatial Portrait ...................................................................................................................8
Local Planning Authority-Level Summaries .......................................................................8
Common Themes ............................................................................................................ 11
Proposed Planning Strategy ............................................................................................ 11
4. Waste Management in West London .................................................................................. 13
Scope of the new WLWP ................................................................................................ 13
Local Authority Collected Waste (mainly household waste) (LACW) .............................. 13
Commercial & Industrial Waste (from businesses & industry) (C&I waste) ...................... 13
Construction, Demolition and Excavation Waste (C, D & E waste) .................................. 14
Hazardous Waste. ........................................................................................................... 14
Existing Management Arrangements for West London's waste ...................................... 15
Management Profiles ...................................................................................................... 15
Flows to and from West London ...................................................................................... 18
Existing Waste Management Sites in West London ........................................................ 20
5. The Policy Context .............................................................................................................. 21
National Policy ................................................................................................................. 22
Climate change ............................................................................................................... 27
The Proximity Principle and Net Self Sufficiency ............................................................. 29
Regional Policy – The London Plan ................................................................................. 30
London Environment Strategy (May 2018) ...................................................................... 33
London-wide Climate Emergency .................................................................................... 34
Local Policy ..................................................................................................................... 35
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LPA Local Plans and Related Plans and Guidance ......................................................... 35
West London Waste Authority ......................................................................................... 37
6. Vision and Objectives .......................................................................................................... 38
The Vision ....................................................................................................................... 38
Strategic Objectives ........................................................................................................ 39
West London Waste Plan Strategic Objectives ............................................................... 39
7. Future Requirements for Waste Management Capacity ...................................................... 40
Management Capacity for Apportioned HIC Waste ......................................................... 40
Management Capacity for C, D & E Waste ...................................................................... 40
Management Capacity for Hazardous Waste ................................................................... 41
Requirements for landfill .................................................................................................. 41
Providing for Unmet Needs for Waste Capacity from Elsewhere within London ............. 41
8. Future Waste Management Capacity in West London ........................................................ 43
9. Proposed Policies ............................................................................................................... 44
10. Policies Map ........................................................................................................................ 69
11. Glossary ............................................................................................................................. 70
Appendices
Appendix 1 – Monitoring Framework ....................................................................................... 81
Appendix 2 – List of Safeguarded Sites ................................................................................... 89
Appendix 3 – Maps of Safeguarded Sites (see Separate Document) ..................................... 101
Appendix 4 – Replacement of Policies in the West London Waste Plan ................................ 102
All map data from OpenStreetMap contains Ordnance Survey data © Crown copyright and
database right 2010 to 2023. Contains national statistics data © Crown copyright and database
right 2024
Project: West London Waste Plan
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Table of Tables
Table 1: Anticipated Timetable for Preparation of the West London Waste Plan ..........................8
Table 2: London Plan Forecast Waste Arisings for the West London Boroughs ........................ 24
Table 3: Non-hazardous C, D & E Waste arisings from West London 2020-2023 Mean ............ 26
Table 4: Non-hazardous C, D & E Waste in West London - Waste Management Profile 2023 .. 27
Table 5: Principal Hazardous Waste Component Arisings in West London 2023 ...................... 29
Table 6: Adjusted Tonnages of West London waste managed in permitted facilities within West
London and outside West London, and tonnage of imported waste to West London
facilities: ...................................................................................................................... 30
Table 7: London Plan Forecast HIC Waste Arisings & Apportionments for the West London
Boroughs ..................................................................................................................... 47
Table 8: Combined apportionment for West London Boroughs compared to Estimated
Apportionment Capacity in West London (after release of sites)................................. 57
Table 9: Existing Waste Sites Proposed for Release from Safeguarding .................................... 60
Table of Figures
Figure 1: Area Covered by the updated West London Waste Plan and wider context .................4
Figure 2: Flows of Waste for Management at Permitted Facilities ............................................. 19
Figure 3: Map of West London Existing Waste Sites Proposed to be Safeguarded ................... 20
Figure 4: The Policy Context for the new WLWP ........................................................................ 21
Figure 5: The Waste Hierarchy ................................................................................................... 23
Figure 6: Circular Economy ........................................................................................................ 24
Figure 7: Residual Waste ............................................................................................................ 54
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Abbreviations
AMR Authority Monitoring Report
BAP
CCC
CCS
Biodiversity Action Plans
Climate Change Committee
Carbon Capture and Storage
CE Circular Economy
C, D & E Construction, Demolition and Excavation
C&I Commercial and Industrial
HRA Habitats Regulation Assessment
LACW Local Authority Collected Waste
LNR Local Nature Reserve
Mtpa Million tonnes per annum
MBT Mechanical Biological Treatment
NPPF National Planning Policy Framework
OPDC Old Oak & Park Royal Development Corporation
OS
RBMP
RDF
RWS
SIL
Ordnance Survey
River Basin Management Plan
Refuse Derived Fuel
Resources and Waste Strategy
Strategic Industrial Location
SA Sustainability Appraisal
SEA Strategic Environmental Assessment
SPA Special Protection Area
tpa Tonnes per annum
WDI Waste Data Interrogator
WLLPAs
WLWA
West London Local Planning Authorities
West London Waste Authority
WLWP West London Waste Plan
WLWP 2015 West London Waste Plan 2015
WPA Waste Planning Authority
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1 Executive Summary
1.1 Managing waste is a key part of a well-functioning modern society. If waste is not
handled in the right facilities or locations, it can harm both the environment and
local communities. The National Planning Policy for Waste (NPPW) requires all
waste plans to follow the waste hierarchy, which prioritises prevention, reuse,
recycling, and then recovery over disposal. It also encourages managing waste
close to where it is produced. Because of this, the future management of waste
needs to be carefully planned for, and it is a statutory requirement for each waste
planning authority to have a ‘waste local plan’ that sets out how and where waste is
to be managed.
1.2 In west London, the adopted waste local plan, known as the ‘West London Waste
Plan 2015’ (WLWP 2015), was adopted in 2015. It plans for the management of
waste through to 2031 within the following London boroughs: Brent, Ealing,
Harrow, Hillingdon, Hounslow and Richmond upon Thames. Those parts of the
boroughs of Brent and Ealing that fall under the planning jurisdiction of the Old Oak
& Park Royal Development Corporation (OPDC) are also included. Together these
seven local planning authorities are referred to as the West London Local Planning
Authorities (WLLPAs).
1.3 Since 2015, both planning policy and the national waste management policy has
changed. New waste management technologies, collection methods and
understanding of the impacts of different approaches have also improved. Because
of this, the WLLPAs decided to update the WLWP.
1.4 The updated version of the WLWP will cover all types of waste expected to be
produced within west London during the Plan period. It will focus especially on the
management of Household, Industrial, Commercial (HIC) waste, Construction,
Demolition and Excavation (C, D & E) waste and Hazardous waste. In doing so the
updated WLWP will take account of the requirements of the London Plan and the
West London Waste Authority’s strategy for managing Local Authority Collected
Waste (LACW).
1.5 This document is the draft version of the updated WLWP published for public
consultation. Once adopted, the WLWP will replace the WLWP 2015 and form part
of each authority’s wider development plan. It will sit alongside their adopted Local
Plans, the London Plan and any relevant neighbourhood plan(s). The updated
WLWP is designed to support existing planning policies rather than repeat them.
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1.6 This draft emerging updated WLWP includes a Vision and five Strategic
Objectives, along with six policies that will guide decisions about waste related
planning applications, or applications for planning permission which would impact
on safeguarded waste sites as follows:
• Policy WLWP 1 – Safeguarding and Optimising Waste Site Network
• Policy WLWP 2 – Provision of additional Waste Management Capacity
• Policy WLWP 3 – Residual Waste Management & Energy Recovery
• Policy WLWP 4 – Ensuring High Quality and Resilient Waste Facilities
• Policy WLWP 5 – Recovery and Disposal of Waste to Land.
• Policy WLWP 6 – Circular Economy & Resource Efficiency
1.7 These policies aim to ensure that waste related development, such as new or
expanded waste management facilities, is well located and does not cause harm to
local communities or the environment. They provide a clear framework to support
waste management development to meet targets, protect existing capacity and
allow for the release of land from waste use where appropriate.
1.8 A recent assessment shows that west London has more than enough capacity for
the management of current and forecast future waste arisings, other than for
landfill. This includes the amounts of HIC waste apportioned for management by
each London Borough through the 2021 London Plan. Therefore, there is no
immediate need for more waste management requirements within the Plan area.
1.9 The London Plan is under review. Once the new version is adopted, this updated
WLWP may also need to be reviewed to ensure it aligns with it. For now, this draft
version is considered to be in general conformity with the requirements of the
2021 London Plan.
1.10 The updated WLWP proposes to protect most existing waste sites in west London.
It also supports additional waste development where such development will help
achieve the Plan's goals. However, it does not identify specific areas of land for the
development of additional waste management capacity.
2 Introduction and background
What is the West London Waste Plan?
2.1 The efficient and effective management of waste is an important aspect of a well-functioning
society. While essential, waste management has the potential to cause impacts on the
environment and communities if it is not undertaken in the right facilities located in the right
place.
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2.2 It is a statutory requirement for each area to have a ‘waste local plan’ that sets out how and
where waste expected to be produced within the area is to be managed. Policies in waste
local plans are used by the responsible decision maker, usually the Local Planning Authority
(LPA) alongside policies contained in other development plan documents, to determine
applications for planning permission relating to waste management development.
2.3 In West London, the current waste local plan, known as the ‘West London Waste Plan’
(WLWP 2015), was adopted in 2015 and plans for the management of waste over the period
until 2031 within the following LPA areas located in west London (‘the WLLPAs’):
a. London Borough of Brent
b. London Borough of Ealing
c. London Borough of Harrow
d. London Borough of Hillingdon
e. London Borough of Hounslow
f. London Borough of Richmond upon Thames
g. plus those parts of Brent and Ealing that fall under the jurisdiction of the Old Oak &
Park Royal Development Corporation.
2.4 Once adopted the updated joint West London Waste Plan (WLWP or ‘the Plan’), will replace
the adopted 2015 West London Waste Plan taking account of changes in policy and taking the
planning horizon forward for another 15 years. The new West London Waste Plan will form
part of each authority’s Development Plan.
2.5 A map of the area covered by the Plan (‘the Plan area’) is presented in Figure 1. The other
areas of London have either prepared, or are in the process of preparing, their own waste
plans and planning policies so the requirements of the London Plan are met.
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Figure 1: Area Covered by the updated West London Waste Plan (‘The Plan Area’) and
wider context
The need to replace the current waste plan
2.6 Waste management is a rapidly evolving sector, shaped by new initiatives
aimed at reducing waste generation and ongoing innovation in the way it is
managed.
2.7 Since the current plan was adopted in 2015, a number of changes have
occurred which include:
a. Changes in the planning policy landscape including:
i. a new London Plan published in 2021;
ii. several updates to national planning policy;
iii. new Local Plans adopted by WLLPAs; and,
b. Changes in the national waste management policy landscape including the
introduction of Simpler Recycling requirements and a target to halve
residual waste produced in England by 2042.
c. Evolution of waste management technologies, collection
methods and better understanding of the impacts of different
approaches.
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d. Current and emerging local conditions including pressure to release
existing waste sites to alternative development, in particular that relating to
alleviating the pressures in London for more housing.
e. Changes in patterns of waste production.
f. Emergence of the ‘Circular Economy’ as a concept to be
embedded into planning policy to promote the management of
waste in accordance with the waste hierarchy in priority order
and thereby driving it up the hierarchy.
2.8 The WLLPAs will use the policies in this draft emerging WLWP when
determining planning applications relating to waste management
development, so it is essential that the Plan provides an up-to-date policy
framework that reflects these changes to support the more sustainable
management of waste that is produced.
2.9 Through safeguarding existing capacity and ensuring that additional waste
management capacity provided within the Plan area is of the right type and in
the right locations and contributes towards more sustainable management of
waste when it is needed, this draft emerging WLWP will ensure that there
continues to be sufficient capacity to manage waste in west London over the
Plan period.
The process of preparing the West London Waste Plan
2.10 The process by which a Local Plan is prepared is prescribed in legislation1 and
policy2 and Table 1 shows the related various stages with regard to the
preparation of the new WLWP. The different stages provide opportunities for
residents, businesses and other key stakeholders to comment and be involved
in determining the content of the Plan. A ‘Consultation Protocol’ has been
prepared that sets out in more detail how the WLLPAs are seeking to engage
with communities and stakeholders during the preparation of the Plan.
1 Planning and Compulsory Purchase Act 2004 and the Town and Country
(Local Planning) (England) Regulations 2012
2 National Planning Policy Framework, December 2024
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Table 1: Anticipated Timetable for Preparation of the West London Waste Plan
Key Stage Timeline
Draft emerging WLWP – 6/8-week public
consultation (‘Regulation 18’)
End 2025
‘Final’ Submission WLWP published for
representations (‘Regulation 19’)
Mid 2026
WLWP submitted for independent examination Late 2026
Examination hearings (if needed) Early/Mid 2027
Main modifications (if needed) published for
representations
Mid 2027
Inspector’s Report Late 2027
Adoption Late 2027/Early 2028
Key elements of the West London Waste Plan
2.11 The key elements of the emerging updated West London Waste Plan are:
i. Vision
ii. Strategic Objectives
iii. Policies
iv. Policies Map
v. Monitoring Framework
2.12 Together, these elements will set out how and where the WLLPAs intend the
management of waste to take place in West London
2.13 The Vision and Strategic Objectives set out how it is proposed that waste be
managed to ensure it benefits, protects and enhances communities and the
environment of west London. The Policies and Policies Map are intended to
ensure the Vision is realised and the Strategic Objectives are achieved. To
ensure the objectives of the Plan are being met and the Policies are working
effectively, certain indicators will be monitored on a regular basis as set out in
Appendix 1.
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This stage of preparing the WLWP
2.14 Regulation 18 of the Town and Country Planning (Local Planning) (England)
Regulations 2012 requires the Waste Planning Authority (WPA) to notify and
invite representations from key stakeholders and communities on the content
of the plan.
2.15 This draft emerging updated WLWP is the first formal opportunity for
stakeholders to contribute to the draft emerging updated WLWP. The Topic
Papers published alongside this draft emerging Plan explore the issues that
affect the delivery of waste management capacity in West London.
2.16 The consultation, on this first draft of the emerging Plan, will run for a
minimum period of eight weeks during December 2025 and January 2026. A
‘Consultation Protocol’ has been prepared that sets out how the WLLPAs are
seeking to engage with communities and stakeholders during the preparation
of the Plan.3 Following closure of the consultation period, the WLLPAs will
publish a statement summarising the comments received and how each, if
necessary, will be addressed in changes to the content of the emerging
WLWP.
Supporting documents
2.17 This draft emerging updated WLWP is underpinned by supporting evidence
including:
a. Waste Capacity Assessment and Arisings Estimates
b. Strategic Waste Flows Report
c. Existing Safeguarded Sites for Release – Assessment Report
d. Integrated Impact Assessment comprising:
e. Sustainability Appraisal
f. Habitats Regulation Assessment
g. Climate Change Topic Paper
h. Circular Economy Topic Paper
i. Waste Management in West London Topic Paper
j. Strategic Flood Risk Assessment
2.18 The draft emerging WLWP and all evidence base documents can be found on
the following website: http://www.wlwp.net/.
3 See Consultation Protocol October 2025. This is based on a distillation of each LPAs' own
Statements of Community Involvement.
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How to comment on the Regulation 18 Draft WLWP
2.19 A questionnaire has been prepared to help all stakeholders in West London
respond to this consultation. The questionnaire is available online and at the
Borough’s main offices (and certain libraries in some LPA areas). There is
also the potential for respondents to raise other issues that they consider the
emerging Plan needs to take account of, which may need to be reflected in
revisions to this draft emerging updated Plan. This includes inviting
stakeholders to nominate sites for waste management facilities, either new or
expansion to existing.
2.20 You can respond during the consultation period between December 2025 and
January 2026 via the following email address: info@wlwp.net
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3 The Plan Context
Spatial Portrait
3.1 This section sets out the key spatial characteristics and constraints affecting
development involving the management of waste in West London, providing
the context for the updated West London Waste Plan (WLWP).
3.2 West London is a diverse sub-region comprising dense urban centres,
established industrial hubs, strategic transport corridors, and extensive green
spaces. Waste management development in this area is shaped by a
combination of opportunities and challenges. Strategic industrial areas
provide essential locations for waste management facilities, while major
regeneration areas are delivering new homes and employment space that will
increase waste generation but also create opportunities for innovative and
sustainable management solutions.
3.3 Waste management development is constrained by the presence of
residential areas and other sensitive land uses particularly, Green Belt,
Metropolitan Open Land (MOL), heritage and conservation designations,
ecological protections, and widespread Air Quality Management Areas
(AQMAs).
3.4 Transport infrastructure, including road, rail, and waterborne freight networks,
also plays a critical role in determining where waste produced in West London
ends up being managed.
3.5 These unique spatial characteristics determine the location of existing waste
management facilities within each local planning authority area, and
availability of land to support expansion of the network where needed.
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Local Planning Authority-Level Summaries
London Borough of Brent
3.6 In Brent, Strategic Industrial Locations (SIL) and Locally Significant Industrial
Sites (LSIS) in Wembley, Neasden and Alperton currently host waste
management facilities. Growth and regeneration across the borough are
driving high-density development, which requires integrated waste solutions.
Road transport is supported by the A406, A5, and M1 corridors, though
congestion is a major challenge. Railheads for materials transportation exist in
Wembley and Neasden. Environmental and land-use constraints include
AQMA coverage, flood risk along the River Brent, and the protected Welsh
Harp Reservoir (SSSI). Brent currently accommodates 13 existing waste
facilities adjudged to be lawful (excluding those located in OPDC), and its
overarching strategy is to protect and modernise them while promoting low-
carbon transport solutions. Three existing waste sites identified within the
adopted Brent Local Plan for comprehensive, residential-led redevelopment
are put forward in this Waste Plan to be considered for release from
safeguarding, as their continued safeguarding and use for waste is likely to
conflict with wider planning and regeneration objectives of the Local Plan.
London Borough of Ealing
10.1 Ealing’s strategic industrial areas — including Greenford, Perivale, Northolt,
and Southall — host several waste management facilities. The Southall
Opportunity Area is expected to generate significant additional waste,
highlighting the need to embed circular economy principles into development.
The A40, A406, and Uxbridge Road provide vital transport routes, with further
potential for rail-based waste movement. Future development is constrained
by AQMA coverage, Green Belt land, and flood risk in Southall and Acton.
With 14 existing waste management facilities in operation adjudged to be
lawful (excluding those located in OPDC), Ealing’s strategy is to safeguard
existing suitable sites, establish circular economy hubs, and expand rail-
based freight transport.
London Borough of Harrow
3.7 Harrow has limited industrial land, with only Wealdstone and Honeypot Lane
designated as SIL or LSIS. Regeneration in Wealdstone and Harrow Town
Centre will increase waste production, but space for new waste management
facilities is scarce. The borough lacks major highways or rail freight links,
making it reliant on local road transport. Additional constraints include AQMA
coverage and significant areas of Green Belt. Harrow currently hosts only two
existing waste management facilities adjudged to be lawful, and its strategy is
to protect and intensify their use where needed, while integrating waste
infrastructure into any major non-waste developments and supporting
localised recycling facilities.
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London Borough of Hillingdon
3.8 Hillingdon benefits from industrial and transport hubs, including Heathrow
Airport, Stockley Park, and the Hayes and West Drayton Corridor, which
generate substantial commercial and industrial waste. Existing infrastructure
includes the West Drayton Waste Transfer Station, the South Hillingdon
Recycling Centre, and former mineral sites such as Harmondsworth Quarry.
Transport strengths include access to the M4, A40, M25, and West Drayton
Rail Freight Terminal, as well as the Grand Union Canal, which offers
potential for non-road waste movement. However, Green Belt, AQMA
coverage, and flood risk from the River Colne and canal present constraints.
With around 23 existing waste facilities adjudged to be lawful, Hillingdon’s
strategy is to modernise and intensify existing sites where needed, expand
sustainable transport use, and safeguard key facilities from displacement by
redevelopment.
London Borough of Hounslow
3.9 Hounslow’s Strategic Industrial Locations (SIL), including in Brentford along
the Great West Road, and the North Feltham Trading Estate, and other local
sites (LSIS), accommodate a number of existing waste management facilities.
Growth pressures from the Great West Corridor and Heathrow Opportunity
Areas are expected to increase demand for waste management capacity. The
M4 provides a strategic road link, supplemented by rail freight at Transport
Avenue and potential river transport via the Thames. Constraints include high
air pollution along the A4/M4, flood risk in Brentford and Feltham, and
extensive Green Belt. With 11 existing waste management facilities adjudged
to be lawful, the borough aims to expand low-carbon waste management,
modernise and intensify existing sites where needed, and increase
sustainable waste movements through utilising river and rail-based waste
transport options. One existing waste site identified within the adopted
Hounslow Local Plan for comprehensive, residential-led redevelopment is put
forward in this Waste Plan to be considered for release from safeguarding, as
its continued safeguarding and use for waste is likely to conflict with wider
planning and regeneration objectives of the Local Plan.
Old Oak & Park Royal Development Corporation (OPDC)
3.10 The OPDC area includes London’s largest Strategic Industrial Location,
accommodating around 2,000 businesses in sectors such as logistics, food
production, and creative industries. It is also one of the UK’s largest
regeneration projects, supporting the delivery of tens of thousands of new
homes and jobs. Existing waste management facilities are located within Park
Royal SIL as well as in areas planned for new mixed-use neighbourhoods.
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Transport links are strong, with the A40, A406, multiple rail connections, and
the Grand Union Canal offering multimodal opportunities. However,
constraints include AQMA coverage, the proximity of Wormwood Scrubs
MOL, High Speed 2 (HS2) construction impacts, and flood risk from the canal.
With five existing waste facilities adjudged to be lawful, the OPDC’s strategy
is to safeguard existing waste infrastructure when it doesn’t conflict with wider
development aspirations, embed waste solutions into regeneration, and
promote rail and canal-based waste transport.
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London Borough of Richmond upon Thames
3.11 Richmond upon Thames has the smallest industrial base in West London,
with just four existing waste management facilities adjudged to be lawful, most
notably the Townmead Road Council Depot, a Household Waste & Recycling
Centre, a composting site in Kew Gardens and a dormant waste oil treatment
site at Arlington Works. Regeneration in Mortlake, Twickenham, and
Richmond will increase waste generation, but opportunities for developing
additional capacity are extremely limited. The borough’s constraints include
extensive protected land, such as Richmond Park and Kew Gardens,
alongside Green Belt, MOL, and flood-prone riverfront areas. The Borough is
rich in built heritage and has a number of protected vistas/views. Transport
capacity is constrained, though there may be limited scope for river-based
waste movement on the Thames. Richmond’s strategy is to safeguard
existing facilities, integrate waste solutions into redevelopment where
possible, and develop Circular Economy hubs.
Common Themes
3.12 Several themes emerge from the above Plan area analysis.
3.13 First, competition for land and conflicting uses highlight the need to safeguard
existing waste management facilities, particularly where they are located on
industrial sites. Waste management facilities are often under residential and
commercial redevelopment pressure, while other brownfield land is productively
used and designations such as Green Belt and MOL apply to greenfield areas
and limit opportunities for expansion. This means intensification and
modernisation of existing waste sites should be prioritised.
3.14 Second, regeneration projects and circular economy initiatives present
opportunities for integration of waste management. Growth areas will
generate significant additional amounts of waste, but could also create
opportunities for circular economy hubs, facilitating reuse and recycling of
materials, and possible co-location of compatible industries.
3.15 Third, environmental challenges such as climate change require resilient
infrastructure and low-emission technologies to protect air and soil quality,
mitigate flood risk, and deliver biodiversity net gain.
3.16 Finally, transport and logistics remain a central concern. Congestion on key
routes, including the A40, A406, A316, M4, and the North Circular hampers
efficiency, while opportunities for rail and river freight at locations such as
West Drayton, Brentford, the Grand Union Canal, and the River Thames
should be fully exploited.
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Proposed Planning Strategy
3.17 To address these issues, the planning strategy for waste management in west
London focuses on two key areas:
a. First, maintaining sufficient suitable management capacity by
safeguarding key existing waste sites and allowing for the use of such
sites to be intensified to meet emerging requirements where appropriate.
b. Second, high standards of environmental protections in line with best
practice be applied to all facilities whether new or expanded, including
robust emissions controls, enclosed operations, sustainable drainage
systems, and climate resilience measures, ensuring that waste
management safeguards health, enhances local amenity, and supports
wider environmental goals. Finally, encouraging the increased use of low-
carbon transport, with greater use of rail and river freight supported by
electric and low-emission vehicles for road-based transport.
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4 Waste Management in West London
4.1 The legal definition of waste, set out in section 75(2) of the Environmental
Protection Act 19904, is “..any substance or object which the holder discards,
or intends or is required to, discard”. The key concept relates to the producer
or holder's intention regardless of whether the waste may have a value to the
recipient.
Scope of the emerging updated WLWP
4.2 The emerging updated WLWP will focus on providing for the principal types of
waste produced within West London, which are as follows:
Local Authority Collected Waste (mainly household waste) (LACW)
4.3 Local Authority Collected Waste (LACW) consists of waste which comes into
the possession of, or under the control of, the local authority including waste
collected from households (household waste). LACW collected by or on behalf
of the Boroughs can include household waste (residual, dry mixed recycling
and food waste), street sweepings, green waste from maintenance of open
spaces, and a small quantity of clinical waste5. Depending upon the local
arrangements, LACW can include commercial waste collected by trade waste
operations.
Commercial & Industrial Waste (from businesses & industry) (C&I
waste)
4.4 Waste produced by businesses. A significant proportion of commercial waste
(c60%) is also classed as 'municipal waste' and is therefore subject to
statutory management targets that also affect LACW set out in a subsequent
section of this draft Plan.
4.5 These first two categories (of LACW and C&I) are combined into a single
category of 'household, industrial and commercial' waste in the London Plan
(‘HIC waste’ for short). The London Plan apportions quantities of HIC waste
arisings to each Borough within London for provision of management capacity
through to 2041. It is this categorisation that is used throughout this Plan to
reflect the influence of the London Plan on its approach/trajectory.
4 Transposing the Waste Framework Directive as amended 2008/98/EC.
5 Household clinical waste is not deemed hazardous unless a particular risk has been identified (based
on medical diagnosis).
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Construction, Demolition and Excavation Waste (C, D & E waste)
4.6 Construction, Demolition & Excavation (C, D & E) waste comprises waste
arising from construction and demolition activity, including excavation during
construction activities, and is made up of mainly inert6 materials such as soils,
stone, concrete, brick and tile. However, non-inert elements such as wood,
metals, plastics, cardboard, and offcuts of plasterboard may also be present
in this waste stream. Due to their weight, the inert elements make up the
majority (c.80%) of the total tonnage.
4.7 The London Plan deals with Construction and Demolition waste separately to
excavation waste, as excavation waste is not normally suited to recycling, and
this distinction is recognised in the waste evidence reports produced to support
production of this Plan. The London Plan does not apportion quantities of C, D
& E waste for management, but LPAs are still required to plan for this waste
stream to meet national planning policy.
Hazardous Waste
4.8 Hazardous wastes are categorised as those that are harmful to human health,
or the environment, either immediately or over an extended period of time. In
West London, hazardous waste arises mainly from: construction and
demolition activity, vehicle maintenance and/or dismantling activity and
healthcare. Hazardous waste may also be present in C,D & E waste
particularly when development takes place on brownfield sites that have been
affected by historical contamination
4.9 The London Plan states that hazardous waste arising in the HIC waste stream
(to which apportionments relate) includes hazardous waste, and therefore
does not distinguish its management needs from the non-hazardous
component of HIC waste. However, for the purposes of this Plan, all
hazardous waste has been considered and planned for separately. Therefore,
to some degree there will be an element of double counting between the
London Plan apportionment values and the hazardous waste management
capacity needs identified.
6 Inert waste is defined as “waste that does not undergo any significant physical, chemical or
biological transformations”.
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Existing Management Arrangements for West London's waste
4.10 This section sets out how the main waste streams relevant to the draft
emerging WLWP are currently managed.
Management Profiles
Local Authority Collected Waste
4.11 In 2023/24 0.65 million tonnes of LACW was generated in West London, of
which 0.43 million tonnes is managed through incineration with Energy from
Waste (EfW) (at facilities outside of West London), 0.2 million tonnes recycled
or composted, and only 101 tonnes managed through disposal to landfill.
Commercial & Industrial Waste
4.12 Data for the amount of C&I waste produced is not readily available as
businesses are not currently required to report on waste produced. The
London Plan 2021 estimates that this waste stream represented 28% of total
waste arisings in London in 2015. This compares with household waste at
17% and C,D & E waste at 54%. If that % is applied to the LACW arisings for
West London above, it indicates that arisings in the Plan area may be in the
region of 1 million tonnes per annum.
4.13 The London Plan provides Borough level forecasts for arisings of HIC waste
combined and these are presented in Table 2 below:
Table 2: London Plan Forecast Waste Arisings for the West London
Boroughs
Borough Waste Arising
(tonnes per annum)
2021 2041
Brent 259,000 274,000
Ealing 291,000 306,000
Harrow 188,000 205,000
Hillingdon 347,000 365,000
Hounslow 260,000 275,000
Richmond upon Thames 179,000 190,000
Total 1,524,000 1,615,000
Given the known amount of LACW in 2023/24 was 0.65 million tonnes, that
confirms the estimate for C&I waste arisings in West London to be c1 million
tonnes. However, the management profile of this waste stream is not fully
understood because it is not reported on separately.
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Construction, Demolition and Excavation Waste
4.14 The production of C, D & E waste is influenced by large-scale infrastructure
projects, as well as commercial and residential developments, which means
that peaks and troughs in its production are often observed with arisings not
following a regular pattern. Given it is a bulky and heavy waste type it does not
tend to travel significant distances from source for management unless moved
by rail or water.
Table 3: Non-hazardous C, D & E Waste arisings from West London 2020-2023 Mean
(tonnes)
Category Type Tonnes
C&D waste Inert 538,506 1,134,622 Non-inert 596,116
Excavation waste Inert 2,128,422 2,132,006 Non-inert 3,584
Total Non hazardous C, D & E waste: 3,266,628
4.15 Different types of C, D & E waste require different forms of management. For
example, hard inert materials (such as concrete, brick and road planings
arising from demolition and road maintenance) can be recycled for use as an
aggregate, while soft materials such as soils and sub-soils can be used for
beneficial purposes such as the restoration of minerals workings and in other
engineering projects. The non-inert component includes timber, plasterboard
and plastics which may be recycled if separated. Ultimately there is very little
C, D & E waste that cannot be recycled or recovered in some way.
4.16 Excavation waste will mainly be managed through the deposit on land for
beneficial purposes. This may in certain cases be consented as non-waste
development and, either be subject to an Environmental Permit as a recovery
to land operation, or managed as non-waste under the CL:AIRE definition of
waste protocol.
4.17 The management profile for Non-hazardous C, D & E waste (including inert
waste) arising in West London in 20237 is set out in Table 4 below.
7 At the time of writing 2023 Waste Data Interrogator (WDI) was the most current dataset available.
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Table 4: Non-hazardous C, D & E Waste in West London - Waste
Management Profile 2023 (% of Total Arisings)
Category Waste Type Recycling Recovery Landfill Transfer Mobile
Plant
C&D Waste
Inert 25% <1% 7% 7% 0%
Non-inert 25% <1% <1% 35% 0%
Subtotal
C&D 50% 1% 7% 42% 0%
Excavation
Waste
Inert 14% 65% 0% 21% <1%
Non-inert <1% 0% <1% 0% 0%
Subtotal
Excavation 14% 65% <1% 21% <1%
4.18 To summarise the management profile for non-hazardous C&D waste
managed at permitted facilities is as set out below:
• At least 51% was managed through recycling or recovery;
• With 7% disposed at permitted landfills; and
• 42% transferred on for recovery or disposal.
4.19 Waste going for re-use may not be managed through permitted sites, plus a
substantial proportion of C&D waste that constitutes hardcore may be
converted into recycled aggregate and either used on site or sold offsite8.
Hence the recycled/recovery value of 51% should be taken to be a minimum.
4.20 The management profile for non-hazardous excavation waste is as below:
• Just less than 80% was managed through recycling or recovery;
• With <1% disposed at permitted landfills; and
• c.21% transferred on for recovery or disposal.
Given that disposal would only be to landfill, and backfilling of mineral workings
and other uses would be classed as recovery, it is considered highly unlikely
that the inert fraction of this stream would end up being disposed of.
4.21 This compares with the targets for C, D & E waste management in Policy SI7
of the London Plan, Reducing waste and supporting the circular economy:
meet or exceed the targets for each of the following waste and
material streams:
• construction and demolition – 95 per cent reuse/recycling/recovered;
8 Data provided by the National Federation of Demolition Contractors.
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• excavation – 95 per cent beneficial use overall and 100% of inert
excavation beneficial used.9
Hazardous Waste
4.22 It has been estimated that around 52,500 tonnes of hazardous waste was
produced in West London in 2023. The term 'hazardous waste' covers a wide
range of waste types which each may require management at specialist
facilities, and given they generally arise in relatively small amounts, such
facilities are usually developed to manage quantities greater than that which
would arise in a single Plan area.
4.23 The principal types of hazardous waste arising in West London making up
90% of the total arisings in 2023 are presented in Table 5 below. The five
principal hazardous waste streams arose from construction activity, oil/ water
separator cleaning, vehicle maintenance/ELV depollution, infectious clinical
waste and Waste Electrical and Electronic Equipment (WEEE).
Table 5: Principal Hazardous Waste Component Arisings in West London 2023
Source: HWI 2023 (Environment Agency)
Hazardous Waste Type/Source 2023
C, D & E Waste 22,721
Oil/Water Separator Waste 7,159
Infectious Clinical Waste 6,323
WEEE 5,499
Vehicle Maintenance & ELV depollution 4,018
Total 45,72010
Flows to and from West London
4.24 Analysis of the best available data shows that significant quantities of waste
are routinely transported between West London and other Waste Planning
Authority (WPA) areas11. This cross- boundary movement is typical of the way
in which waste is managed in general. Table 6 shows the balance between
waste exported from West London and received at West London waste
management facilities in 2023. This indicates that overall, a balance is
achieved with the exported amount equating to the imported amount. The
totals shown in Table 6 do not correspond to the arisings totals given for each
waste stream above. This is because an additional tonnage of C,D & E waste
has been accounted for, that is not actually attributed to West London in the
source dataset12, the Waste Data Interrogator (WDI), and therefore cannot be
9 London Plan Footnote 164
10 Totals less than the 52,500t total above as these are the principal waste components.
11 See ‘Identification of Strategically Significant Cross Boundary Waste Movements from
West London’, BPP Consulting, October 2025
12 See Construction, Demolition & Excavation Waste Arising in West London to 2041 BPP Consulting
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allocated by management location.
Table 6: Adjusted Tonnages of West London waste managed in permitted facilities within West
London and outside West London, and tonnage of imported waste to West London facilities
Source: WDI 2023
West London arisings Managed in West London
West London
waste
managed
outside West
London
West
London
waste
managed in
West
London
Waste
imported
to West
London
Total
Managed
in West
London
2,806,945 869,932 2,796,481 3,666,413
Total West
London waste
managed
3,676,877
4.25 Figure 213 displays the balance between imports and exports by waste
management method and waste type to and from West London in 2023.
Figure 2:: Flows of Waste for Management at Permitted Facilities
October 2025
13 Note that Figure 2 only includes waste managed at permitted sites in England and does not include
any waste exported to Wales, Scotland or further afield as this is not reported in the WDI.
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4.26 Certain flows of waste from West London have been assessed to be of such a
strategic nature to the management of waste arising in West London over the
Plan period. The WPAs hosting the receiving facilities of this waste will be
contacted to confirm that such flows may continue over the Plan period.
Existing Waste Management Sites in West London
4.27 There are a range of existing waste management facilities located in West
London that manage waste both arising within and outside West London. It is
intended that 68 sites would be safeguarded through the Plan for ongoing
waste management uses and their location is shown in Figure 3 below.
Figure 3: Map of West London Existing Waste Sites Proposed to be Safeguarded
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5 The Policy Context
5.1 The policy context within which the new WLWP sits is illustrated in Figure 4
below.
5.2 To be found sound the updated WLWP will need to be in general conformity
with the London Plan and consistent with national policy. The WLWP is also
aligned with the policies of the adopted Local Plans in West London. The
WLWP may update relevant aspects of the Development Plan and where any
conflict between policies exists the policy to have been adopted most recently
generally takes precedent in decision making. Once adopted, the policies in
the updated WLWP will supersede the policies in the existing WLWP.
Appendix 4 sets out how the existing WLWP policies will be replaced by those
set out in the updated WLWP.
5.3 Once adopted the updated WLWP will form part of the statutory development
plan for the WLLPAs, to guide decision-making on planning applications in
relation to waste management and related developments. The WLWP is in
accordance with national policy by applying a presumption in favour of
sustainable development. The Planning and Compulsory Purchase Act 2004
requires that “... for the purpose of making any determination under the
planning Acts, the determination must be made in accordance with the plan
unless material considerations indicate otherwise”.
Figure 4: The Policy Context for the new WLWP
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5.4 The development plan is to be read as a whole. Most adopted plans within a
borough’s Development Plan, such as a Local Plan, are likely to have policies
which are also relevant to a waste application. Each borough may also have
adopted Supplementary Planning Documents which may be relevant.
Furthermore, applications will also be decided according to the policies in the
London Plan, which also forms part of the development plan. Therefore, when
proposing waste related development, a number of adopted plans and
supplementary planning documents will have to be consulted.
National Policy
5.5 The key objective of national policy for waste14 is to protect the environment
and human health by:
• preventing or reducing the generation of waste;
• where its production is unavoidable, reducing the adverse
impacts of its generation and management; and
• reducing the overall impacts of the use of resources from
which waste may arise and improving the efficiency of such
use.
5.6 The National Planning Policy for Waste 2014 (NPPW)15, associated Planning
Practice Guidance16 and the Resources and Waste Strategy for England 2018
(RWS) 17 currently set the national policy context for waste planning in
England. Whilst the NPPF does not contain policies specific to waste, its
principles remain relevant. The Waste Management Plan for England 18
signposts policies concerning waste management in England.
5.7 The ‘Waste Hierarchy’ is one of the keystone principles of sustainable waste
management and is enshrined into English Law. This categorises different
methods of managing waste and ranks them in order of preference. This is
illustrated in Figure 5 below. This shows that ‘Prevention’ is the most preferred
option with ‘Disposal’ at the bottom being the option of last resort. Application
of the Waste Hierarchy in priority order i.e. from the top down is a legal
requirement19.
14 See The Waste (England and Wales) Regulations 2011 and The Waste (Circular Economy)
(Amendment) Regulations 2020
15 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/364759/141015_Nation
al_Planning_Policy_for_Waste.pdf
16 https://www.gov.uk/guidance/waste
17 https://www.gov.uk/government/publications/resources-and-waste-strategy-for-england
18 https://www.gov.uk/government/publications/waste-management-plan-for-england-2021
19 Part 6 of the Waste (England and Wales) Regulations 2011 sets out the duties placed on all
planning authorities with regard to application of the hierarchy in decision making.
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5.8 The RWS was published in December 2018 and set out Government thinking
on waste management in England at that time. This included five strategic
ambitions:
• To work towards all plastic packaging placed on the market
being recyclable, reusable or compostable by 2025;
• To work towards eliminating food waste to landfill by 2030;
• To eliminate avoidable plastic waste by the end of 2042;
• To double resource productivity by 2050; and
• To eliminate avoidable waste of all kinds by 2050.
5.9 The RWS introduced the concept of Circular Economy into waste
management policy for the first time. The London Plan 2021 defines Circular
Economy as "..where materials are retained in use at their highest value for
as long as possible and are then re-used or recycled, leaving a minimum of
residual waste." (Para 9.7.1).
Figure 5: The Waste Hierarchy
Graphic from the Mayor's Environment Strategy (Figure 44)
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5.10 The central role waste management plays in the material cycle as part of more
circular economy is illustrated in Figure 6 below.
Figure 6: Circular Economy
Source: Resources and Waste Strategy, DEFRA, 2018
5.11 The Circular Economy is also a tool for tackling the climate emergency. When
applied to the built environment, circular economy principles significantly reduce
greenhouse gas emissions by avoiding extraction of raw materials, reducing
production of virgin construction materials, retaining embodied carbon and
eliminating waste.
5.12 The Government set the following targets in the Environmental Improvement
Plan 202320 (EIP), which build on existing recycling and landfill diversion
targets:
• eliminate avoidable waste by 2050 and double resource
productivity by 2050;
• explore options for the near elimination of biodegradable
municipal waste to landfill from 2028;
• eliminate avoidable plastic waste by 2042;
• seek to eliminate waste crime by 2042; and,
• halve ‘residual’ waste (excluding major mineral waste)
produced per person by 2042.
20https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1
168372/environmental-improvement-plan-2023.pdf
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5.13 The target for the reduction in residual waste is enshrined in The Environmental
Targets (Residual Waste) (England) Regulations 202321 which came into force
on 30 January 2023. The waste target is for the reduction of residual waste
(excluding major mineral wastes) on a kg per capita 22 basis by 50% by 2042
from 2019 levels (574 kg per capita). Accordingly, the residual waste long-term
target is that by the end of 31 December 2042 the total mass of residual waste
for the calendar year 2042 does not exceed 287 kg per capita. Waste routes
which will count as residual are:
• sent to landfill in the United Kingdom;
• put through incineration in the United Kingdom;
• used in energy recovery in the United Kingdom; or
• sent outside the United Kingdom for energy recovery.
5.14 The EIP also set the following interim targets for the residual waste target to be
achieved by 31 January 2028:
• Reduce residual waste (excluding major mineral waste)
produced per person by 24%.
• Reduce residual waste (excluding major mineral waste) in
total tonnes by 21%.
• Reduce municipal residual waste produced per person by
29%.
In addition, the following material specific targets were set:
• Reduce residual municipal food waste produced per person
by 50%.
• Reduce residual municipal plastic waste produced per
person by 45%.
• Reduce residual municipal paper and card waste produced
per person by 26%.
• Reduce residual municipal metal waste produced per person
by 42%.
• Reduce residual municipal glass waste produced per person
by 48%.
21 The Environmental Targets (Residual Waste) (England) Regulations 2023
https://www.legislation.gov.uk/en/uksi/2023/92/made
22 Per head of population in England
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