Bath & North East Somerset Local Plan Revised Deposit 2003

Chapter B8. Waste

INTRODUCTION

B8.1 The Council in its roles as Waste Collection and Waste Disposal Authority has responsibility to collect and manage household waste together with some trade wastes. Nationally, this waste "stream" accounts for about 15% of the total amount of controlled wastes arising. The remaining wastes – including industrial/commercial wastes, construction/demolition wastes, and special wastes - are managed by the private-sector waste management industry.

B8.2 In its role as Waste Planning Authority the Council has statutory responsibility to make adequate provision through the development plan for the control of development involving waste management and for future requirements for facilities to cater for controlled wastes arising within its area.

B8.3 JRSP policy 29 sets the context for the waste management policies of this Plan.  The Joint Committee for Strategic Planning and Transportation has resolved to review policy 29 in order to provide an appropriate framework for co-ordinated implementation of strategic waste planning policy by the four planning authorities of the former Avon sub-region.  The outcome of the review is to be incorporated in the first review of the adopted Structure Plan.  An early review of the adopted Structure Plan is anticipated in the light of the recently published Regional Planning Guidance. A sub-regional investigation of waste management in the former Avon area is being undertaken and will be used by the four Unitary Authorities to inform the planning process; this study will facilitate an appropriate review of the Plan.

WASTE ARISINGS[1] AND MANAGEMENT IN B&NES BATH & NORTH EAST SOMERSET – THE CURRENT POSITION (see note 1)  

 B8.4 Data for Council-collected wastes are reliable and readily available.  In respect of other major waste “streams” – industrial and commercial wastes and construction and demolition waste – the position is less reliable.  The most recent comprehensive study of arisings of these wastes is the Environment Agency’s Strategic Waste Management Assessment 2000 (SWMA).  GG Other available data is old and its reliability is questionable. Data in the SWMA are is presented largely at county level or above.  Figures for Bath & North East Somerset are therefore subsumed within an aggregate figure for former Avon .  Whilst data have has been extrapolated from the SWMA figures to arrive at an estimate for Bath & North East Somerset, there is potentially a wide margin for error and the estimates cannot be taken as being more than indicative. Details of the movement of Council collected wastes are given in paragraph B8.5.  Information relating to the movement of other waste streams out of Bath & North East Somerset or into the District from other areas is not readily available, but may be forthcoming from the investigations of the Regional Technical Advisory Body on Waste and those to be undertaken as part of the sub-regional study on waste management in the 'Avon' area.  In view of the limited waste management facilities that are available within the District, it is likely that currently only small amounts of waste are imported into the District from other areas for either treatment or disposal.

Council–collected wastes

B8.5 Arisings in this category are presented at Table 4 below. The Council recycles approximately 22% of the waste it collects. The remainder – some 70,000 tonnes per annum – is transported by rail to Buckinghamshire or by road to Dimmer in Somerset for disposal to landfill. The rail contract was renewed in April 2001 for 7 years with an option to extend this arrangement for another 3 years. The Council is at present reviewing its Waste Management and Recycling Strategy. Options for future management of unrecoverable wastes will be considered as part of the review.

Industrial and Commercial Wastes (see note 2)

B8.6 It is estimated that arisings of industrial and commercial waste in B&NES Bath & North East Somerset broadly are in the order of 180,000 tonnes per annum.  About 52% of arisings are industrial waste (92,000 tonnes) and 48% (86,000 tonnes) are commercial waste.  The trend for the South West is 55%:45%, whilst nationally the split is 70%:30%.

Construction and Demolition Wastes (see note 3)

B8.7 Approximately 54,000 tonnes of construction and demolition wastes were deposited at the two active landfills in the district (at Wellow and Camerton) in 1998/99.  The average over a 3-year period is about 45,000 tonnes.  On the basis of recent research and having regard to the absence in B&NES Bath & North East Somerset of exempt sites or non-inert landfills requiring daily cover, it is estimated that this figure represents about 65% of the total arisings of waste in this category.  The remaining 35% comprises wastes which are recycled or re-used.  On this basis it is estimated for B&NES that arisings of wastes in this category typically are in the order of 70,000 tonnes each year.

B8.8 Major new development or infrastructure projects occurring during the Plan period will render this figure obsolete. Anticipated projects may generate over 500,000 tonnes of C&D wastes during the Plan period.

Clinical and Special wastes (see note 4)

B8.9 The SWMA indicates that 1,000 tonnes of special wastes were transferred from the District in 1998-99.  There are no waste management facilities licensed to accept special wastes in B&NES Bath & North East Somerset.  It is considered therefore that this figure broadly represents arisings in this waste stream.

Top of page

Table 4 : Current wastes arising

B8.10 Table 5  sets out in broad terms how wastes arising in B&NES Bath & North East Somerset currently are managed.

Table 5: Management of Waste Arisings

* estimate

Top of page

PREDICTED WASTE ARISINGS DURING THE PLAN PERIOD

B8.11 Considerations discussed at paragraph B8.4 apply similarly to prediction of future arisings. In addition there is a wide range of factors – for example, change in the nature of employment, population growth, legislative change – that will influence the quantity of waste needing to be managed in the future. The principal issues are discussed in paragraphs B8.16 – B8.30. The overall trend indicates an increase in waste arisings, particularly in arisings of household waste.

Council-collected wastes

B8.12 At present the trend in B&NES Bath & North East Somerset is an increase in arisings of about 3% per annum.  This estimate accords with the National Waste Strategy estimate for increases in arisings in this category.

Table 6: Estimated Council-collected Waste Arisings 1997 – 2012 (including home composting)

B8.13 The number of dwellings in B&NES Bath & North East Somerset is predicted to rise from 71,200 in 2001 to 73,700 by 2006 and 75,600 by 2011.  The B&NES Bath & North East Somerset Waste Strategy suggests that the average household produces about 1.24 tonnes of waste annually.  Based on this figure and taking account of annual increases in waste arisings of 3%, it is considered that the figures set out in Table 6 should be added to as follows:

Industrial & Commercial Wastes

B8.14   Preliminary forecasts of employment growth[1] have been used in an attempt to predict future change in waste arisings.  The majority of employment growth for B&NES Bath & North East Somerset is likely to be within the commercial sector. The largest growth area (computing) is not likely to be the major generator of waste materials. Other likely growth areas such as general services and retailing are more significant. Whilst overall employment growth may be in the order of 15%, it is considered that the major waste generating employment sectors may account for some 10% of growth.  On this basis it is provisionally estimated that commercial waste arisings may increase over the Plan period by some 10% from about 86,000 tonnes in 1998 to about 95,000 tonnes in 2011.  Industrial employment may continue to decline, and a 23% decrease in arisings[2] in this sector is possible. 

Top of page

Construction & Demolition wastes

B8.15 Arisings of wastes in this stream are predicted to rise by about 5% over the Plan period. Arisings in 2011/12 may consequently be in the order of 75,000 tonnes.

B8.16 The JRSP requires that provision be made for 6,200 dwellings between 1996 and 2011 of which 2,330 had been completed by April 2001. Together with increased household waste arisings, in waste management terms a significant impact of housing growth will be the generation of about 300,000 tonnes of construction industry waste over the Plan period. This figure is arrived at on the basis of 75 tonnes of waste arising per unit. It should be borne in mind that this figure may be revised upward having regard to the outcome of the Secretary of State’s Direction on JRSP housing figures.

B8.17 Transportation development proposed for 2001/2006 is set out in the Bath and North East Somerset Local Transport Plan. Over £49m of development is proposed including traffic management, highway improvements/maintenance and a major scheme at Western Riverside.

B8.18 Several major developments are scheduled to begin during the Plan period. These include storm water drainage infrastructure proposed by Wessex Water, the Combe Down Stone Mines Remediation Project, employment and commercial redevelopment at Western Riverside in Bath, M.O.D. Foxhill and expansion of the Bath University campus. Taken together, these developments are likely to generate significant quantities of excavation spoil and demolition/ construction wastes. It is not possible to predict the amount of waste likely to arise but it is likely to be in the order of several hundred thousand tonnes.

Clinical and Special Wastes

B8.19 The Avon Waste Management Plan 1996 indicates that for the Plan period there is sufficient existing capacity in the sub-region to cater for wastes arising in these categories. This is confirmed in the relevant draft Waste Local Plans of neighbouring WPAs.

Conclusions

B8.20 On the basis of these provisional data, by 2011/12 arisings of industrial/commercial and construction/demolition wastes could result in about 240,000 tonnes requiring management of one kind or another.  By 2011/12 total annual waste arisings in B&NES Bath & North East Somerset could be in the order of 375,000 tonnes – an overall increase in total waste arisings of about 10% on 1999/2000 figures.  The biggest growth area is in Council-collected household and trade wastes.

Top of page

FUTURE WASTE MANAGEMENT

Waste Strategy 2000 for England and Wales (The National Waste Strategy)

B8.21 Utilising assessment of the Best Practicable Environmental Option (BPEO) for each waste stream as its underpinning theme (see paragraph B9.58 for definition), the National Waste Strategy incorporates several key targets directly relevant to land-use policies for waste management:

• reduce the amount of industrial and commercial waste landfilled to 85% of 1998 levels by 2005;

• ·         recycle/compost at least 25% of household waste by 2005, rising to 30% by 2010 and 33% by 2015 (statutory performance standards for B&NES Bath & North East Somerset are 33% by 2003/4 and 36% by 2005/6);

• recover (see note 7) value from 40% of municipal waste by 2005, 45% by 2010 and 67% by 2015 ;

• production of Municipal Waste Management Strategies to be mandatory.

The Strategy also sets out in Chapter 3 of Part 2 the role of the land-use planning system in achieving the far-reaching changes required towards more sustainable management of waste.  This chapter of the Local Plan therefore contains a range of land use policies aimed at meeting these targets.

EC Landfill Directive

B8.22 Implementation of the Landfill Directive in July 2001 will introduced key changes to current UK landfill practice. Landfilling of biodegradeable household waste is to be was reduced to 75% of 1995 levels by 2010, 50% by 2013 and 35% by 2020.  Other requirements included:

• banning co-disposal of hazardous and non-hazardous wastes, and requiring separate landfills for hazardous, non-hazardous and inert wastes;

• banning landfill of whole tyres by 2003;

• national strategy for reduction of all biodegradeable waste disposed of by landfill to be in place by 2003;

• tradeable permits to be introduced to restrict on the basis of set tonnages the amount of biodegradeable municipal waste to be sent to landfill.

B8.23 The Directive states that only waste that has been subject to treatment may be landfilled. A significant consequence will be a greater demand for treatment facilities, including those for recycling and similar activities. Implementation of the Directive is also likely to increase the cost of disposal of waste to landfill leading to greater emphasis on waste minimisation, re-use and recycling. All new landfills from 16th July 2001 must comply with the full requirements of the Directive, existing landfills must comply by July 2009.

Landfill Tax.

B8.24 Landfill Tax on all non-inert wastes disposed of to landfill is £12 per tonne at present (2001). Tax on inert wastes is frozen at £2 per tonne. The Government is committed to a tax escalator (£1 per tonne) for landfilling non-inert wastes which will be reviewed in 2004. It is expected that Landfill Tax will continue to increase. The principal effect of increases in tax is greater disposal costs to landfill. In due course this will contribute towards making alternative management methods more attractive in economic terms.

Aggregates Levy and recycling initiatives

B8.25 Demand for primary (see note 8) aggregates dropped by 23% - 30% between 1989 and 1999. For the same period sales of secondary or recycled materials increased by some 50%. Current estimates are that about 35m tonnes of the total supply of aggregates comprises secondary or recycled materials. Currently the Government’s target is 55m of total aggregate demand being met from recycled sources by 2006, therefore an additional 20m tonnes per annum will be needed by the end of the next 5-year period. Better source separation of wastes could release 10m tonnes, whilst removal of the exemptions from Waste Management Licensing could release another 8m tonnes. A levy of £1.60 per tonne on primary aggregates will be introduced in 2002.

B8.26 It is considered likely that the Aggregates Levy and related initiatives will result in increased demand over the Plan period for sites for production of recycled or secondary materials arising from construction industry and mineral wastes.  Whilst Bath & North East Somerset is not an aggregate producer, it could nevertheless contribute to provision of facilities of this type if appropriate sites are available in the District.  Moreover, policies to encourage source separation of wastes could make a valuable indirect contribution to overall supply.

Top of page

Producer Responsibility for Packaging Waste

B8.27 Packaging constitutes about 9% of Council-collected and commercial and industrial wastes.  Annual arisings nationally are estimated to be approximately 10m tonnes.  About 4.5m tonnes arises in the Council-collected waste stream.  Having regard to the data set out in tables above, it is estimated that around 21,500 tonnes of packaging waste arises in B&NES Bath & North East Somerset every year.  About 10,000 tonnes of this arises as MSW. 

B8.28 The Producer Responsibility Obligations (Packaging Waste) Regulations 1997 oblige qualifying businesses, amongst other things, to:

• recover specified tonnages of packaging waste;
• inform consumers about their role in increasing recovery and recycling.

B8.29 Statutory targets, to be met by the end of June 2001, are:

• to recover between 50% and 65% of packaging waste;
• to recycle between 25% and 45% of packaging waste;
• to recycle at least 15% of each material.

B8.30 The Government considers that a major expansion in collection and recovery capacity, particularly for plastics and aluminium, is needed to ensure that the UK can keep step with Directive targets. At present the 25% threshold target for recycling overall has been exceeded by 2%. As for individual materials, only aluminium and plastics are falling short of the 15% target (13% and 8% respectively). Overall recovery will need to rise by 17% if the 50% Directive target is to be met on time.

Top of page

CURRENT PROVISION FOR WASTE MANAGEMENT IN B&NES BATH & NORTH EAST SOMERSET AND THE NEED FOR ADDITIONAL AND REPLACEMENT FACILITIES DURING THE PLAN PERIOD

B8.31 For B&NES Bath & North East Somerset, the total number of waste management facilities licensed (see note 9) or exempt from licensing under the Environmental Protection Act 1990 is as follows:

• 10 landfills;
• 7 metal recyclers (scrapyards and vehicle dismantlers);
• 9 waste transfer stations (incorporating 3 Household Waste and Recycling Centres);
• 1 composting facility (Charlton Fields).

B8.32 In addition, there is one temporary composting facility at Wellow; one temporary inert materials recovery/landfill operation at Charlton Fields; and one inert materials recovery facility at Marsh Lane, Temple Cloud. With the exception of the Wellow composting site, these developments have only recently become operational.

Landfill

B8.33 The status of the 10 licensed landfills is:

• 5 closed ; (see note 10)
• 1 dormant ; (see note 11)
• 2 private active ; (see note 12)
• 2 merchant active ; (see note 13)

B8.34 The active merchant landfills are licensed only to accept inert soils, subsoils and construction industry wastes. In terms of capacity, Willow Farm Landfill has voidspace of less than 100,000 m3. Camerton Landfill has capacity of less than 10,000 m3. The temporary facility at Charlton Fields will accommodate about 20,000 tonnes of inert wastes over its 5-year life. Total capacity therefore at active merchant landfills is at most 130,000 tonnes. Having regard to estimated annual arisings of inert wastes, it is considered that there is less than 2 years’ capacity at currently active sites.

B8.35 Stowey Quarry is an active surface mineral working (dimension stone).  Part of the site has planning permission or restoration by this use of inert waste materials, although this use is dormant at present.  Land adjoining the quarry is identified in Section C6 (Minerals) as suitable for extension of the workings.  It is estimated that the potential voidspace at Stowey Quarry could exceed 1Mm3 1.7Mm3.  Provided the development accords with policies set out below, this would give a capacity for disposal of some 1.5 tonnes of inert waste and would provide about 20 years capacity for disposal of such wastes arising in Bath & North East Somerset.

B8.36 The active private "factory curtilage" landfills are not run commercially. Whilst they contribute to the range of facilities they are small in scale and in general of marginal significance.

Metal recycling

B8.37 There are 7 sites in this category. Discussion with the largest operator reveals that whilst there is sufficient existing capacity at present, the sites are not advantageously located in respect of access to principal traffic routes. There may be greater demand for additional or expanded facilities when EC Directives relating to End-of-Life Vehicles and Electronic and Electrical Equipment are implemented.

Top of page

Waste Transfer Stations/Household Waste & Recycling Centres (HW&RCs)

B8.38 With the exceptions of a commercial and industrial waste transfer station near Windsor Bridge in Bath and a small "factory curtilage" station at Midsomer Norton, B&NES Bath & North East Somerset operates all transfer stations and HW&RCs in the district. The road-rail transfer facility for Council-collected wastes is at Westmorland Road in Bath. There is a combined HW&RC/transfer station/MRF at Bath and a HW&RC/transfer station at Midsomer Norton together with a HW&RC at Keynsham. Development of Western Riverside in Bath will result in the need to relocate the HW&RC/waste transfer/MRF facilities in the city.

B8.39 The Strategic Waste Management Assessment 2000 states that the capacity of existing open-gate non-inert waste transfer stations in B&NES Bath & North East Somerset is 534,000 tpa. This figure includes the Westmorland Road railhead facility.

Composting

B8.40 The 2 composting sites in the district have a combined capacity of about 10,000 tonnes per annum. Both sites are temporary and replacement sites may be needed during the Plan period. In any event, greater capacity is needed to meet statutory recycling targets for recovery of household wastes.

Need for additional or replacement facilities

B8.41 The need for additional and replacement waste management facilities for wastes arising during the Plan period should be based on the Best Practicable Environmental Option (BPEO) for each waste stream. It is considered that the BPEO should be assessed within the context of a sub-regional land-use planning strategy for waste management. A robust sub-regional strategy will take account of the need to contribute to regional self-sufficiency in waste management. A sub-regional strategy must be based upon reliable data on waste arisings together with an appraisal of the nature and capacity of existing sites. In the absence of these prerequirements it is difficult to apply with any degree of confidence the BPEO and hence to predict need and make appropriate allocations of land for the siting of new or replacement facilities. Nevertheless, the Government, through, PPG 10 Planning and Waste Management and PPG 12 Development Plans, encourages Waste Planning Authorities to prepare their policies and proposals for waste management development on the basis of the best available information.

B8.42 On the basis of existing data and having regard to material considerations such as the National Waste Strategy, statutory recycling targets and forthcoming legislation, it is considered that the following are likely to be needed for management of B&NES Bath & North East Somerset’ wastes during the Plan period:

• materials recovery facilities for Council-collected wastes;

• disposal facilities for non-inert industrial and commercial wastes;

• permanent composting facilities;

• materials recovery and processing facilities for industrial and commercial wastes, and for construction industry wastes;

• HW&RC/waste transfer/MRF facility(ies) to replace the facility at Midland Road, Bath;

• sites for community recycling and/or composting facilities.

The precise location, nature and mix of facilities will be a matter largely for the BPEO process as applied within a sub-regional context.

B8.43 In the absence of a sub-regional framework for implementation of JRSP policy 29 (see paragraph B8.54), it is proposed to provide the context for meeting this need through a combined approach of identification of potentially suitable sites and criteria-based policies designed both to guide potential developers and provide a rigorous framework for development control decisions. Whilst it is anticipated that existing Council policies for waste reduction will be reviewed and built upon in the revised Waste Management Strategy, the effect of waste reduction and other initiatives set out in the National Waste Strategy on the need for additional waste management facilities is unquantifiable at this time.

Top of page

PLANNING POLICY CONTEXT

National planning policy guidance

B8.44 The principal source of policy guidance for waste management planning is PPG10 Planning and Waste Management. Other relevant guidance is contained in PPG 23 Planning and Pollution Control, PPG11 Regional Planning Guidance and PPG12 Development Plans together with a range of other PPGs and MPGs.

B8.45 PPG10 reiterates many of the underpinning principles of the National Waste Strategy. Waste Planning Authorities should develop waste planning strategies which take account of:

• obligations required by European legislation;
• the policies and principles of the National Waste Strategy;
• national and regional planning guidance on waste; and
• strategies prepared by the Regional Technical Advisory Body (RTAB).

B8.46 WPAs should:

• draw upon all relevant sources of information and establish the amounts of waste which will need to be managed in their area over the plan period.

• identify existing waste management sites with capacity for the future and, where practicable, new or extended sites sufficient to make adequate future provision.

• identify preferred locations where new or replacement facilities are needed.

• if specific locations are not identified, areas of search should be indicated or comprehensive criteria put forward against which applications for facilities can be considered;

• if an approach other than identification of preferred sites is adopted, the WPA will need fully to justify why a different approach has been taken.

B8.47 Planning for provision of facilities should be consistent with forecasts of local and regional requirements. WPAs should not prohibit the development of particular types of waste facility unless they are confident that adequate alternative facilities will be available in their area.

Regional Planning Guidance for the South West (RPG10)

B8.48 Policy RE5 of RPG10 generally reiterates advice in relevant PPGs and the National Waste Strategy. It encourages adoption of regional targets and urges development plans to develop a collaborative approach to the formulation of regional and sub-regional policies. This includes the need to:

• Establish a mix of waste recovery methods regionally and sub-regionally to reduce reliance on landfill or any other single method;

• Give priority to the provision of waste management facilities that will recover value from waste at or near Principal Urban Areas; and

• Ensure that sub-regional requirements are taken into account in structure and waste local plans and in waste planning decisions

Draft Joint Replacement Structure Plan

B8.49 JRSP policy 29 advocates a sub-regional (former Avon area) approach to provision of waste management facilities. The emphasis is on sustainable waste management. The concepts of BPEO and proximity principle should be employed in assessment of proposals. The policy encourages use of previously developed land in preference to "green field" sites. General guidance on location is provided. Policy 28 encourages provision of environmentally acceptable facilities for production of secondary and recycled materials for use in substitution for primary aggregates.

Top of page

B&NES Bath & North East Somerset Waste Management Plan and draft Recycling Plan (December 1998)

B8.50 This document currently is under review.  In October 2001, the Council adopted the concept of zero waste as a long term goal.  The concept, which envisages maximum recycling and re-use of waste with no disposal of residual and re-use of waste, will underpin the review of the Waste Management Strategy.  A revised combined Plan will be available for consultation in 2001.  The waste policies of the Plan assist towards realisation of this goal as far as it relates to the use of land.

B8.51 The Waste Management and Recycling Plan sets out a number of targets. From a land-use planning viewpoint the most relevant include:

• increase recycling of Council-collected wastes to 30% in 2000/01 and 35% in 2002/03 - the current recycling rate is about 21% (or 29% if home composting and demolition materials brought to HW&RCs are included);

• allocate more bays at Household Waste and Recycling Centres (HW&RCs) to collect garden waste for central composting;

• improve layout and design of HW&RCs to allow greater flexibility in recycling options available and to increase capacity;

• seek to establish alternative forms of waste treatment for use soon after existing landfill contracts end.

B8.52 The Council has for some time been investigating the possibility of developing an integrated waste management facility (or "Environment Park") to manage the waste it collects. A closed landfill site together with other land at Broadmead Lane in Keynsham has been identified as a suitable location and is allocated in policy GDS.1 (site K3). The facility would focus on recovery of value from wastes including recycling, composting and energy. A Project Team recently has been set up to carry forward the Environment Park project and to advise the Council on other waste management issues and site requirements.

Relevant development plans of neighbouring waste planning authorities

B8.53 South Gloucestershire Council has produced a Minerals and Waste Local Plan. North Somerset Council has produced a Waste Local Plan. Both plans are at Deposit Draft stage. Public Local Inquiries into both Plans have been completed.

Top of page

POLICIES

B8.54 Policy 29 of the Joint Replacement Structure Plan requires the constituent Waste Planning Authorities of the former County of Avon to make provision of land for the safe management, recycling, treatment and disposal of forecast waste arising in the area. At present there is no co-ordinated approach to implementation of this policy. In her report on the Public Inquiry into the South Gloucestershire Minerals and Waste Local Plan the Inspector makes several references to the need for a collaborative approach to waste management planning in the former Avon area and comments that this would be "the most effective way of addressing many of the issues that have arisen in the preparation of this Plan, and no doubt others in the former Avon area (see note 14)" . Whilst the Joint Committee for Strategic Planning and Transportation has resolved to review the mechanism for implementation of Policy 29, it will be some time before an agreed approach is in place. The Council believes moreover that a sub-regional approach will provide the most appropriate framework for each of the constituent authorities to achieve consistency between their statutory Waste Management Strategies and to contribute to the self-sufficiency of the south-west region in waste management.

B8.55 In the interim the Council must discharge its statutory obligation to prepare development plan policies and proposals for waste management development. The Council believes that until an agreed sub-regional strategy is in place it is important that major waste management development which potentially could prejudice implementation or compromise formulation of a sub-regional policy framework is resisted.

B8.56 The proximity principle – that waste generally should be disposed of as near to its place of origin as possible - is a useful concept in this respect.

B8.57 In accordance with the proximity principle, the importation movement of waste into or out of the District for processing and/or disposal is unsustainable.  Development of all facilities must however, represent the BPEO for the waste streams to be managed.  That is the Council’s first position.  However, in anticipating the development of a joint approach to implementation of strategic policy, which would justify elevation of the proximity principle to the level of the former Avon area, an exception to this stance is warranted in the case of development of facilities to deal with wastes arising in the sub-region, particularly for example in respect of provision of reprocessing / manufacturing facilities and infrastructure for recycled materials.  PPG10 requires Waste Planning Authorities to establish the amounts of waste which will need to be managed over a period of at least 10 years.  It is expected that the sub-regional investigations to be undertaken for the ‘ Avon ’ area will provide such data and form the basis of an approach to the proximity principle at this level.  In all cases however, development of such a facility waste management facilities must however represent the BPEO for the waste streams to be managed.

B8.58 The keystone of the Council’s policies for waste management is the BPEO. BPEO is defined as the outcome of a systematic and consultative decision-making procedure which emphasises the protection and conservation of the environment across land, air and water. The …. procedure establishes, for a given set of objectives, the option that provides the most benefits or the least damage to the environment as a whole, at acceptable cost, in the long term as well as in the short term BPEO provides an overarching framework within which both the economic and environmental elements of proposals for waste management development can be assessed. The Waste Planning Authority will expect prospective developers to address the BPEO in planning applications.

Top of page

Top of page

B8.59 Subsumed within the BPEO are two associated concepts: the waste hierarchy and the concept of regional self-sufficiency in waste management. The waste hierarchy is a guide to assessing, in broad terms, the sustainability of a proposal for waste management development. It is an adjunct to, not a replacement for, the more rigorous BPEO procedure. The hierarchy is:

B8.59A In determining whether a particular waste management facility represents BPEO, the Council will take into account the long term vision and aspiration for the Council to achieve zero waste and whether the proposed facility will assist in achieving this by moving up the waste hierarchy wherever possible

B8.60 Waste reduction is clearly the most sustainable form of waste management. Re-use – of packaging waste or components – is clearly preferable to simply throwing things away. Recovery involves the salvage of value from wastes either by recycling or composting, or by recovering the energy inherent in the materials. Finally, at the bottom of the hierarchy is waste disposal.

Top of page

Reduction and Re-Use

B8.61 The scope for effectiveness of the town and country planning system in reduction and re-use of solid or liquid wastes is limited. The planning system is principally concerned with regulating the development of land in the public interest. Waste reduction and re-use is a matter largely of change in socio-economic behaviour and values. The Government has implemented a range of initiatives aimed at reducing waste including the Producer Responsibility for Packaging Waste legislation. Whilst this and other initiatives will have some impact on future need for waste management facilities, its effect is at present uncertain. The Council intends to build on its record in recycling by introducing trials to collect and compost green waste and investigate ways to reduce, repair and re-use wastes through implementation of policies and setting of targets in its Waste Management Strategy.

B8.62 The planning system can have most impact on reduction and re-use in terms of waste generated during the development of land. Policy WM.3 places a requirement on prospective developers of schemes involving a land area of more than 0.5ha or 10 houses (0.4ha or 1000m2 floorspace in the case of industrial and/or commercial development) to submit a "waste audit" with their planning applications.

B8.63 Developers will be expected to provide an estimate of the type and quantity of waste likely to be generated and to consider, in consultation with the Waste Planning Authority, ways of reducing or eliminating its generation and of re-using unavoidable waste on the site – in landscaping or in noise attenuation bunding, for example.

B8.64 Applications for planning permission will be expected to be accompanied by a detailed written statement covering:

1. the nature and estimated quantity of waste to be produced; and

2. the steps to be taken to eliminate and minimise the generation of waste and to re-use and/or recycle wastes for incorporation in the development; and

3. for wastes which cannot be accommodated in the development project provision, where practicable, for on-site separation of hard wastes such as concrete and stone from soils and subsoils prior to transportation off-site; and which will generate waste as part of the physical development process

Top of page

Top of page

Recovery

B8.65 This part of the waste hierarchy incorporates recycling, composting and energy recovery. The three categories of recovery do not share equal status in respect of national policy. Government advises that incineration with energy recovery is expected to be considered after opportunities for recycling and composting have been explored. As a Beacon Authority for waste recycling, the Council supports this objective (see policy WM 10).

Recycling

B8.66 Having regard to the Council’s commitment and growing reputation in household waste recycling, it is important that every effort is made to build on current success.  Central government has, for B&NES Bath & North East Somerset, imposed statutory performance standards for household waste recycling of 33% by 2003/4 and 36% by 2005/6 – far in excess of national targets of 25% by 2005 and 30% by 2010.  These targets are likely to increase demand in the district for new or expanded Household Waste Recycling Centre facilities (see Policy WM 10). (see Policy WM 10).

B8.67 One of the most difficult problems in increasing the quantity of waste recycled is the segregation of different materials so that cross-contamination is minimised. The collection and sorting of mixed recyclable materials can be labour-intensive and expensive, and whilst this may create employment it equally can undermine the economic viability of initiatives. New development proposals will therefore be expected to incorporate facilities for the segregation and collection of waste materials within their design. This will help to increase the quantity of wastes available for recycling in the district. In order to assist determination of planning applications, information detailing the provision for long-term management of the facilities will be required. Planning obligations will be sought where necessary.

Top of page

B8.68 At a broader level, the effects of the Landfill Tax escalator, implementation of the EC Landfill Directive and introduction the Aggregates Levy are likely to stimulate demand for more Materials Recovery Facilities (MRFs). Apart from Council-run sites and scrapyards, there are only two operational recycling facilities in the district at present. Both accept only inert construction and demolition wastes.

B8.69 Inappropriately designed and located MRFs can give rise to environmental problems as a result of traffic, noise, visual intrusion and other amenity impacts. MRFs should ideally be sited in areas designated for industrial or waste management uses. In operational terms, the processing and stockpiling of materials should take place under cover in order to control noise and dust emissions and to reduce visual impact.

B8.70 In some instances redundant agricultural buildings may be capable of accommodating facilities of this type. This will depend upon the siting of the buildings together with their quality and design. The control of noise from a MRF located in a quiet rural area may be a particular difficulty as will generation of atypical levels and/or types of traffic. Impact on residential amenity and the environment will be important considerations. Proposals will be assessed against relevant policies of the Plan.

B8.71 Waste Transfer Stations (WTS) are often associated with MRFs, although the two activities are distinct. The primary purpose of a WTS is to "bulk up" wastes from smaller to larger containers for onward transit to a processing or disposal site. This reduces costs and can be less damaging to the environment. The environmental and amenity impacts of a WTS are broadly similar to those which can be expected from a MRF.

Top of page

B8.72 The recovery of materials brought to landfill sites is a paradox. Whilst the benefits may seem obvious, it may be that the site has been permitted for a temporary period in order, for example, to improve derelict land or restore a quarry. Landfill sites are normally located in comparatively remote, rural areas. If recovery of materials would have the effect of reducing the rate of fill at such a site the result may be that the environmental impact of the landfill would be unacceptably prolonged. A balance must therefore be struck between the desire to recover materials which otherwise would be lost and the desire to see restoration of a site take place quickly and effectively. If permission is granted for materials recovery, linked to the life of the landfill, and subsequently an application is received to significantly extend the life of the landfill this is likely to be unacceptable unless the proposal represents the BPEO for the waste streams involved.

B8.73 Household Waste Recycling Centres (HW&RCs - formerly called “Civic Amenity” sites) have a crucial role to play in meeting B&NES’ Bath & North East Somerset ’s recycling targets and making management of waste generated in the district more sustainable.  The Council has a legal obligation to provide HW&RCs.  In development terms, the principal planning issue raised by HW&RCs centres on traffic (access, manoeuvring, loading and offloading).  HW&RCs must be sited carefully to avoid traffic congestion and unsustainable cross-city car journeys.  Other potential issues include noise and odour. Alongside general development control considerations in policy WM.191, the criteria for consideration of any new site are set out in policy WM117.

Top of page

Top of page

Composting

B8.74 Except for paper, wood and some textiles, most biodegradeable waste cannot be recycled. Under the right conditions and with proper management most can be composted to produce a substitute for peat and fertiliser.

B8.75 Composting facilities can be large and centralised or be designed to serve a particular community, or simply be a heap or bin in the back garden. There are several composting techniques, ranging from the "low tech" open-air windrow system and simple bins to more "high-tech" in-vessel methods involving computer-controlled temperature regulation and purpose-designed silos.

B8.76 Regardless of scale, all have an important role to play in making the management of B&NES’ Bath & North ’s waste more sustainable.  An emphasis on composting is particularly timely having regard to the implications of the Landfill Directive for the landfilling of bio-degradable wastes. 

B8.77 Composting can be both environmentally safe and economically successful provided that the facility is properly managed and the end-product is marketable. Badly managed composting potentially can result in ground and surface water pollution if leachate is not controlled adequately. Odour and vermin can result if the process is not properly designed and monitored. Large piles of unprocessed waste can be visually unattractive. A satisfactory working and management plan for the facility including provision for annual review and having particular regard to minimising environmental impact and to site security is likely to be required as part of any planning application.

B8.78 At present the biggest obstacle to successful commercial-scale composting is market resistance. In the past, waste-derived compost products have varied considerably in quality and this has affected sales. A major problem facing commercial composters is contamination of raw materials, principally with plastics. This is not a matter directly for the development plan, but the Council is considering what steps it may be able to take to minimise this problem in respect of its HW&RCs and waste collection rounds.

B8.79 Centralised or community composting facilities must be carefully sited. Large-scale recycling centres and landfill sites can be suitable locations for centralised facilities subject to relevant policies. Community composting facilities clearly must be located in publicly accessible areas. They must have regard to safeguarding amenity together with traffic control and management. The facility must be compatible with adjoining land-uses. Land adjoining allotments, market gardens or leisure facilities such as sports centres or libraries may have potential, as may underused or brownfield land. In line with Policy WM8 new housing developments should make provision for community composting facilities in their design.

B8.80 Alongside problems outlined at B8.77 community composting facilities may face the additional problem of fly-tipping if the site is not secured when not in use. It is therefore essential that the facility is responsibly managed. In order to safeguard local amenities and to ensure that potential problems are minimised planning permission for community composting facilities should in the first instance normally be granted on a temporary basis. Permission for establishment of permanent community composting facilities should be considered on their merits and in light of responses to consultation and other material considerations.

B8.81 The Council will produce guidance on establishing and managing community composting facilities.

Top of page

Top of page

Energy recovery

B8.82 Energy can be recovered from waste either by direct treatment or as a by-product of other forms of waste management. The most common form of direct treatment is mass burn incineration, but other methods of thermal processing such as gasification (see note 15), pyrolysis (see note 16) and plasma arc heating are emerging. By-products are combustible gases (principally methane) recovered from landfills and anaerobic digestion - a form of accelerated composting. The gases can be collected and burned to generate electricity.

B8.83   Depending on the scale of the plant, mass burn incinerators commonly need a guaranteed feedstock of 100,000 – 400,000 tonnes per annum and long-term disposal contracts in order to make investment in development and the cost of staffing, running and maintaining the plant economically viable. An average mass burn will require a site of between 3 and 5 hectares and will involve construction of a large Having regard to the Council's waste management policy to develop a waste strategy that has a long term vision and aspiration to achieve zero waste, proposals for the thermal treatment of unsegregated domestic waste streams, which require large feedstocks and binding contracts are unlikely to come forward during the Plan period.  Such facilities are not favoured because it is considered that they would restrict opportunities to re-use and recycle waste materials to their maximum potential.

 B8.84   It is considered in some quarters that an increasing emphasis on recycling and composting, which may remove materials with high calorific value from the potential feedstock, casts doubt on the long-term future of mass-burn incineration.  On the other hand, the consequences of implementation of the Landfill Directive may encourage more proposals for this type of development to come forward.  Having regard to comparatively small arisings of suitable waste in B&NES, the overarching policy direction centring on recycling and composting, and the lack of suitable sites in suitable locations, it is considered unlikely that proposals for development of a mass burn incinerator in the district will come forward during the plan period.

B8.85 Whilst the processes involved in gasification and pyrolysis are not new, the application of these techniques to waste management is comparatively recent. Both processes are currently in a process of transition between small experimental pilot schemes and commissioned full-scale plants. It is clearly important that any proposal which comes forward uses technology that is tried and tested at full scale over a reasonable period of time for specified waste streams.

B8.86 It is considered that direct thermal treatment of wastes arising in B&NES Bath & North East Somerset should more appropriately take the form of these smaller, more flexible treatment methods.  Treatment of wastes by these methods would follow recycling and composting, focusing on wastes unsuitable for such treatments, and consequently would be unacceptable other than in a supporting role.  Proposals for thermal treatment without energy recovery would be unsustainable and unacceptable.

Top of page

Top of page

Disposal to land

B8.87 Unless it represents the Best Practicable Environmental Option, disposal of waste to land represents the bottom rung of the waste hierarchy. It is nevertheless likely to remain the principal method of waste management during the plan period. There will always to be a need for facilities of this nature for disposal of residues remaining after recovery of materials and/or energy or for disposal of wastes which do not readily lend themselves to such treatment (for example, subsoils from construction work). Owing to the range of variables involved (including the EC Landfill Directive and the Aggregates Levy), it currently is not possible to predict with any degree of confidence the reduction in demand for voidspace or airspace that may result.

B8.88 The Council considers that disposal of waste to land should be undertaken principally with the objective of improving or restoring degraded land to an environmentally beneficial and appropriate afteruse. In this context, it should by its nature be a temporary activity and demonstrably be a means to an end rather than an end in itself.

B8.89 In many cases disposal to land takes place in association with or following mineral extraction. It is important to note that it is not always the case that filling a disused quarry will bring about an environmental benefit, particularly if the site has naturally regenerated and has nature conservation, recreational or geological value.

B8.90 The District historically has experienced intensive extraction of coal, stone and fuller’s earth by underground mining.  In contrast, surface mineral working has and continues to be low-key in nature.  This is partly attributable to the geology of the district and the absence of deposits of limetones generally suitable for volume production of aggregates.  In consequence there are very few mineral working voids of significance.  At present time there are only 2 operational surface mineral working sites: Upper Lawn Quarry at Combe Down and Stowey Quarry at Bishop Sutton.  Both primarily are produce building and walling stone producers, but in recent years Stowey quarry has also produced a large quantity of material for aggregate purposes.  There is are a small number of disused or dormant sites including Queen Charlton Quarry near Keynsham and Mount Pleasant Quarry at Combe Down.

Top of page

Top of page

Top of page

B8.91 Disposal of inert wastes to land can often take place as a means of improving agricultural productivity. In some instances whether or not a material improvement results is open to doubt. The Council considers that a more rigorous approach to the evaluation of planning applications of this nature is needed.

B8.92 Applicants should be able to demonstrate that the land is in need of improvement, that other methods of improvement are not feasible and that there is sufficient availability of suitable fill materials. Planning applications will be expected to be supported by information prepared by a suitably qualified independent person(s) demonstrating:

• that improvement is reasonably necessary for the purposes of agriculture within the agricultural unit;

• how the proposed development will significantly improve the land;

• why the improvement cannot practicably (excluding financial reasons) be achieved by other land management methods.

• that the agricultural improvements will not have an adverse effect on environmental interests.

B8.93 The Landfill Tax has inadvertently diverted a great deal of inert waste material formerly used for agricultural improvement schemes to projects exempt from waste management licensing and tax. Increased recycling is likely to reduce further the availability of materials of this type. It will in many cases be undesirable to allow significant time extensions to complete schemes if the site is sensitively located and the original decision was finely balanced having regard to environmental or amenity considerations.

Top of page

B8.94 Applicants will need to take a realistic view of the availability of suitable materials together with the time needed to undertake the proposed work, and plan accordingly. Conditions will be imposed requiring appraisal of the likelihood of work being completed within the permitted time. If the appraisal suggests that further time is needed and "low level" restoration is feasible there will be a requirement for submission of schemes for completion of work using materials already deposited on the site. Applications for time extension will be refused where it appears to the Local Planning Authority that the land can be restored to an acceptable standard using materials already deposited.

Top of page

Planning applications, conditions and obligations

B8.95 The Waste Planning Authority will expect planning applications to contain sufficient detail to enable efficient and rigorous assessment of the proposed development. For most waste management developments, informal pre-application meetings are very useful. They can enable issues to be identified at an early stage, the developer’s intentions and WPA’s requirements to be made clear and discussion of Development Plan policy to take place.

B8.96 In the vast majority of cases the grant of planning permission is conditional. Conditions are imposed to control elements of the development which, without regulation, would make it unacceptable. Planning obligations under s.106 of the Act may be sought for the same reason but in respect of off-site matters such as road improvements. Conditions must be necessary, relevant to planning, relevant to the development, enforceable, precise and reasonable in all other respects. A high-quality planning application, made in the light of pre-application discussion with the WPA, may reduce the number of issues needing to be controlled by condition. It is important therefore that planning applications address the full range of issues likely to be raised by the proposed development.

B8.97 Planning applications for waste management development will be required, as appropriate, to address matters and/or provide details including:

• Annual site surveys;
• Archaeology;
• Benchmark (fixed OSD point);
• Best Practicable Environmental Option;
• Birdstrike;
• Building scale, design and external appearance;
• Drainage;
• Duration of development;
• Dust;
• Height of stockpiles;
• Landscape impact and landscaping;
• Litter;
• Lighting;
• Materials to be recovered and/or deposited;
• Nature conservation;
• Noise;
• Odour;
• Plant and machinery;
• Plans (to scale and including proposed buildings; landscaping; layout; existing site topography; pre- and post-settlement levels);
• Public Rights of Way;
• Rates of fill and/or number of traffic movements per day;
• Reinstatement and afteruse;
• Source of materials;
• Site security;
• Stripping, storage and placement of soils and subsoils;
• Temporary buildings and structures;
• Traffic, access and highways;
• Vermin;
• Visual impact;
• Water environment (surface and groundwater);
• Wheelcleaning;
• Working hours;
• Working plans.

Top of page

PROPOSALS

Constraints

B8.98 Over 75% of land in the district is subject to significant constraints on development: 67% is in the Bristol-Bath Green Belt and 31% is within either the Cotswolds or Mendip Hills Areas of Outstanding Natural Beauty (AONB). If land in urban centres is included in the calculation, there remains only some 14% of the district, mostly in the south, which is comparatively free of major urban development or nationally-designated planning constraints. Within that 14% there are Sites of Special Scientific Interest, areas designated as being of landscape and/or nature conservation importance, archaeological sites and so on.

B8.99 Employment land within urban areas can be suitable for certain types of waste management development such as waste transfer and materials recovery facilities. Pressure to develop so-called "brownfield land" for uses other than employment currently is intense, and available sites are scarce.

B8.100 Having regard to PPG7 The Countryside: Environmental Quality and Economic and Social Development, the countryside should be protected for its own sake. Development outside existing settlements should be strictly controlled.

B8.101 The remaining pockets of land across the district which are suitable for development are therefore at a premium and naturally subject to intense competition from developers.

Opportunities

B8.102 Bearing these constraints in mind and within the context of policies set out above the Plan allocates a site under policy GDS.1 (K3) for a waste management facility at Broadmead, Keynsham. The majority of the site previously was allocated in the draft Wansdyke Local Plan for employment development. Any waste development on the site will be subject to the normal planning process, including assessment of BPEO, Environmental Impact Assessment where appropriate, together with the Integrated Pollution Prevention Control (IPPC) regime administered by the Environment Agency. Identification therefore does not mean that planning permission automatically will be granted or that other sites automatically will be excluded. Any potential site coming forward which is not in the Plan will be assessed against relevant policies.

B8.103 The 4.3 ha site comprises a closed and poorly restored former municipal landfill.  The Environment Agency has confirmed that the entire former landfill lies outside the floodplain of the River Avon, but that the access road remains in the flood plain.  They have further advised that the road can be protected by providing compensatory modification of the northern boundary of the site.  It is proposed in paragraphs C1.22 and C1.23 of the Green Belt chapter to amend the Green Belt boundary which cuts through the northern 3^rd of the site.  This will enable the whole site to be redeveloped and put to beneficial use.

B8.105 The site is remote from housing development. Whilst public views of the site are limited, it is considered that the nature of surrounding topography and landscape setting necessitates sensitive design and boundary treatment. Nature conservation interests will need to be taken into account in any redevelopment proposals. Improvements to the existing access under the railway bridge at Broadmead Lane will be required if the full potential of the site is to be realised. Potential ground stability and contamination issues relating to the former landfill will need to be addressed.

B8.106      The site is considered suitable for use as an integrated waste management facility. Detailed proposals for the site will come forward through the Council’s Waste Management Strategy.  However, the key features of the proposed development are likely to include:

•          A maximum capacity of 70,000 tonnes per annum of domestic waste.  Limited amounts of organic industrial wastes may also be processed.

•          Waste will be delivered by road.  The majority of waste will be delivered in refuse collection vehicles and the “green box” collection vehicles.

•          The Materials Recycling Facility processes will include the pulverisation and separation of black bag domestic refuse.  Reception and segregation of the waste will be undertaken within enclosed buildings to ensure that it will not give rise to odour.

•          Green waste and the putrescible fraction of the mixed domestic refuse will be composted in vertical, closed vessel units.

•          Energy recovery will be by gasification/pyrolysis of the residual organic fractions of the wastes and possibly sewage sludges and some commercial waste.

•          All releases to air will meet emission limits specified by the Environment Agency under IPC Guidance Note S2 5.01: Processes subject to Integrated Pollution Control: Waste Incineration and the EC Directive on the Incineration of Waste EC98/0289.

•          A Sort-It-Centre, primarily for the recovery and recycling of waste electrical and electronic goods

•          An education centre

•          Manufacturing units, which will utilise recycled materials.

Top of page

Notes

1. Waste "arisings" refers to the baseline quantity of waste being generated i.e. before treatment or disposal
2. Waste from premises used wholly or mainly for the purposes of a trade or business or for sport, recreation or entertainment, and wastes from any factory or such other specified premises.
3. Waste arising from the construction and maintenance of buildings or other civil engineering works.
4. Waste arising from medical, pharmaceutical or related practices which may present risks of infection, & wastes as defined in the Control of Pollution (Special Wastes) Regs 1980.
5. Based on 1996 data contained within the Local Economy Forecasting Model designed principally for application at regional level.
6. The 1996 Avon Waste Management Plan predicts for that annual industrial & commercial waste arisings will in total decrease by about 11% in the period 1993/94 – 2004. Within this waste stream the WMP predicts that between 1994 and 2004 there will be a marked difference in rates of waste arisings. Industrial waste arisings are predicted to decrease by about 23%, while commercial waste arisings are predicted to increase by approximately 6%.
7. "recover" means recycling, composting, other forms of material recovery and energy recovery.
8. "Primary" aggregates are crushed rock and sand/gravel won from quarrying or dredging. "Secondary" aggregates generally are materials produced from quarry waste, "recycled" aggregates generally are produced from demolition and construction wastes.
9. The number of licensed sites does not represent the number of active sites. Closed sites may continue to be licensed until the Environment Agency accepts surrender of the licence.
10. Four Winds, Swainswick; Frys Bottom, Chelwood; Midford Hill; Lady Farm, Chelwood; Hinton Blewett, Temple Cloud. 
11. Stowey Quarry, Bishop Sutton, 
12. St Regis Paper, Keynsham; Bathford Paper Mills, Bathford, 
13. Willow Farm Landfill, Wellow; Camerton Landfill
14. South Gloucestershire Minerals and Waste Local Plan, Inspector’s Report, July 2001 paragraph 7.5.4, p.53
15. Gasification is the heating of waste in the presence of air or steam to produce fuel-rich gases.
16. Pyrolysis involves the heating of waste in the absence of oxygen. It has the advantage of being adaptable to small waste arisings and having a comparatively low incidence of emissions to the environment. The result of the process is the conversion of the waste into a combustible fuel gas together with combustible oils and a small quantity of ash. industrial building, including a prominent chimney stack.

Top of page