Hounslow Council's Cabinet has recommended the approval of the Regulation 19
publication of the Proposed Submission version of the West London Waste Plan (WLWP). This plan, set to cover the period up to 2041, aims to manage waste-related development across the boroughs of Brent, Ealing, Harrow, Hillingdon, Hounslow, and Richmond upon Thames, as well as parts of Brent and Ealing under the Old Oak and Park Royal Development Corporation (OPDC).
The updated WLWP, which aims to replace the current plan adopted in 2015, has undergone revisions following a Regulation 18
consultation held between December 2025 and February 2026. Amendments have been made based on feedback received, addressing concerns regarding waste capacity calculations, the release of safeguarded sites, and the need for additional policies on wastewater treatment infrastructure.
Addressing Waste Capacity Concerns
During the Regulation 18 consultation, concerns were raised regarding the identified capacity of safeguarded sites. Specifically, the Mayor of London/GLA noted that capacity calculations for some sites were based on maximum throughput over the last five years, while others used different data. Some site owners also disagreed with the attributed capacity figures. In response, the Plan has been amended to update figures for the total waste management capacity for processing Household, Industrial and Commercial (HIC) waste, which has decreased slightly from the Regulation 18 version. The Plan also includes additional supporting text to explain how the key provisions of Policy WLWP 1 should be interpreted, particularly regarding 'wider market conditions' when assessing proposals for the release of safeguarded sites.
Safeguarded Sites and Their Future
The West London Waste Plan (WLWP) proposes to safeguard existing waste sites that meet specific criteria to ensure sufficient waste management capacity. These criteria include sites with extant planning permission for waste use, a Certificate of Lawful Existing Use or Development (CLEUD) for waste use, or those deemed lawful through passage of time or ancillary to another lawful use. The Plan identifies 10 existing waste sites in Hounslow for safeguarding, along with sites in other west London boroughs and the OPDC area.
The implications of continued safeguarding are the protection of existing waste management capacity, which is considered sufficient to meet forecast needs and London Plan apportionments. Conversely, the Plan proposes the release of six existing waste sites across west London (one in Hounslow, two in OPDC, and three in Brent) where their continued safeguarding is deemed to conflict with wider regeneration objectives. The release of these sites is justified by an assessed surplus of waste management capacity for HIC and Construction and Demolition (C&D) waste, and in Hounslow's case, the site is surplus to requirements and its release would facilitate a mixed-use scheme. The Plan emphasizes that any release of safeguarded sites must be considered against the London Plan's requirement for compensatory capacity to be provided if sites are redeveloped for non-waste purposes, unless a surplus of capacity is demonstrated. Specific reference has also been added to confirm the release of safeguarded waste sites for other land uses within the OPDC boundaries, and text has been added noting that the proposed expansion of Heathrow Airport may affect certain existing waste sites.
New Policy for Wastewater Treatment Infrastructure
Policy WLWP 7, titled 'Provision of Wastewater Treatment Infrastructure,' has been added to the proposed submission version of the West London Waste Plan. Its purpose is to provide for new wastewater treatment capacity to be developed and existing capacity to be safeguarded and enhanced where needed. The policy acknowledges that wastewater, including sewage sludge (bioresources), is managed by Thames Water Utilities Ltd, with Mogden Sewage Treatment Works in Hounslow being a key facility for the Plan area. The policy also notes that development proximate to wastewater treatment works (up to 800m) may be affected by odour and that the 'Agent of Change' principle should be applied. Proposals for wastewater treatment infrastructure will be permitted if they demonstrate an identified need in that location and are in accordance with other WLWP policies and the relevant borough's development plan. Existing wastewater treatment infrastructure will be safeguarded from development that may conflict with its use, operation, and expansion.
Fostering Circular Economy Hubs
The West London Waste Plan (WLWP) supports the development of 'Circular Economy Hubs' as part of its vision and strategic objectives. The vision aims to keep waste materials in circulation through innovative reuse, repair, and high-quality recycling, fostering local business growth, sustainable entrepreneurship, and job creation. Policy WLWP 6 specifically addresses Circular Economy and Resource Efficiency, requiring proposals for waste-related development to demonstrate how circular economy principles will be integrated into their design, construction, and operation. The expected benefits include reducing demand for virgin materials, lowering associated environmental impacts and carbon emissions, supporting local job creation in emerging green industries, and reducing reliance on landfill and incineration. The Plan encourages the co-location of waste uses with complementary industrial uses to promote resource efficiency opportunities.
Meeting Deadlines and Procedural Matters
The proposed submission version of the WLWP will be published for an eight-week consultation period starting in August 2026. Following this, it will be submitted to the Secretary of State for independent examination. The Council is seeking delegated authority to officers to manage procedural matters related to the submission and examination process to ensure the Plan meets the government's deadline of December 2026.
The WLWP faces a risk of programme slippage, potentially causing it to miss the government's December 2026 deadline for submission to the Secretary of State for examination. This risk is rated as 'medium' and is being mitigated through regular programme management meetings attended by officers from participating boroughs, regular meetings with consultants, and ongoing updates to the project programme. Additionally, there's a risk that consultation arrangements or submission procedures might not comply with statutory requirements, which is being mitigated by a developed Consultation Protocol Document, detailed consultation arrangements, legal review of the process, and ongoing liaison with communications teams.
More information on the Cabinet meeting can be found in the Public reports pack.
