Waste and Minerals Monitoring Report 2012/13
Contents
Waste and Minerals Plan - Annual Monitoring Report 2012 - 13
1 Executive Summary 4 2 Context and Role of the Monitoring Report 15 3 Characteristics of East Sussex 18 4 Progress of the Waste & Minerals Local Plan 22 5 Duty to Co-operate 26 6 Monitoring the Plan 29 7 Overarching Strategy 32 8 Providing for Waste 40 9 Providing for Minerals 51 10 Overarching Policies 60 11 Development Management Polices 61 12 Enforcement 62 13 Monitoring Issues 65
Appendices
A Structure of the Waste and Minerals Policy Documents 67 B Programme for the Waste and Minerals Development Scheme 68 C Municipal and Household Waste Arisings in East Sussex and Brighton & Hove 69 D Other Targets for the Management of LACW 71 E Secondary and Recycled Aggregates Facilities in East Sussex and Brighton & Hove 72 F Permitted Mineral Workings in East Sussex 2012/13 74 G Permitted Waste Management Sites in East Sussex and Brighton & Hove 75 79 Waste and Minerals Monitoring Report 2012/13
Contents
H Permitting of Significant Waste Management Capacity in East Sussex 2006/7 - 2012/13 I Review of Mineral Permissions 81 J Local Aggregate Assessment 83 Waste and Minerals Monitoring Report 2012/13 3 Waste and Minerals Plan - Annual Monitoring Report 2012 - 13 4 Waste and Minerals Monitoring Report 2012/13
1Executive Summary 1 Executive Summary
Introduction
1.1 East Sussex County Council, as a Waste and Minerals Planning Authority, provides planning policies for waste management and minerals production. Current policies are contained in the East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan, and saved policies within the Waste Local Plan and Minerals Local Plan. The Council is required to monitor implementation of these policies by the Planning and Compulsory Purchase Act 2004, as amended by the Localism Act 2011(1), and partly does this by producing a Waste & Minerals Monitoring Report. The content of Monitoring Reports is also prescribed by the Town & Country Planning (Local Planning) Regulations 2012.This Monitoring Report covers the period 1 April 2012 to 31 March 2013. Monitoring Reports from previous years can be found at the following website: www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste/amr1.Htm
Progress on the Waste & Minerals Local Plan
Minerals & Waste Development Scheme
1.2 In July 2011 a revised Minerals and Waste Development Scheme, containing the timetable for the preparation of the documents that form the Waste and Minerals Local Plan was approved by the County Council. A further update was agreed in July 2012. In light of changes to legislation(2), there is no longer a requirement to submit the Scheme to Government for approval. The Minerals and Waste Development Scheme can be found at the following website: http://www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste
Waste & Minerals Plan
1.3 During the monitoring period, work was completed on the Draft Waste and Minerals Plan. The draft Plan had been submitted to Government in June 2012 for Public Examination. In September 2012 Public Examination Hearings into the Plan were convened by independent Planning Inspector Mrs Susan Holland. The Public Hearings lasted two weeks.
1.4 Issues discussed at the Hearings included the Plan's strategy for waste, the treatment capacity data, as well as locational factors relating to the Areas of Focus for waste. The movement of minerals and waste, the Duty to Cooperate and apportionment of land-won aggregates were also covered.
1 In previous years this requirement was set out in the Planning and Compulsory Purchase Act 2004 which required the production of an Annual Monitoring Report. Changes, including the title of the report have been introduced by the Localism Act 2011. 2 Localism Act 2011, section 111. Waste and Minerals Monitoring Report 2012/13 5
Executive Summary1
1.5 As a result of the Hearings only one 'Main Modification' to the Plan was proposed relating to the 'presumption in favour of sustainable development' as set out in the National Planning Policy Framework. A consultation on this Main Modification was carried out in October 2012.The results were considered by the Inspector.
1.6 The Inspector's Report was published in January 2013 and the Plan was found 'sound', subject to the one Main Modification. A number of minor modifications were made to the Plan. In the Report, the Inspector noted that the Plan had been positively prepared with a strong commitment to moving away from landfill as a way of disposing of waste. It concluded that the Plan was legally compliant and provided an appropriate basis for planning in the area over the next 15 years. The Inspector also accepted the approach that the Plan Area should not take waste from London.
1.7 In February 2013 the Waste and Minerals Plan was adopted, and is now being used in the determination of planning applications.
1.8 The Waste and Minerals Plan includes an updated set of monitoring indicators. With the adoption of the Plan these indicators now must be monitored. In this and future Monitoring Reports, the indicators reported reflect those found in the Waste and Minerals Plan (2013). Continuity of data is very important, therefore information that has been reported in previous Monitoring Reports will continue to be recorded and published as before, but these will be referenced under different indicators.
Saved Policies in the Waste and Minerals Local Plans
1.9 With the adoption of the Waste and Minerals Plan (see above) the majority of policies that were previously saved have now been replaced. Site specific planning policies in the Waste Local Plan (WLP) and Minerals Local Plan (MLP) continue to be saved until they are replaced by those in the Waste and Minerals Sites Document as set out in the Minerals and Waste Development Scheme.
Waste & Minerals Sites Plan
1.10 The approved Minerals and Waste Development Scheme sets out a timetable for the preparation of the Waste and Minerals Sites Plan as follows:
Stage When
Public 'Call for Sites' Summer 2013
Public consultation on a shortlist of sites Spring 2014
Public consultation on a proposed Submission Summer 2015 Plan
Submission of Plan to Government Late 2015 6 Waste and Minerals Monitoring Report 2012/13
1Executive Summary
Stage When
Public Examination Early Spring 2016
Adoption Early Summer 2016
1.11 This document will include allocation of land to meet the requirements for additional capacity for the management of waste and identification of Minerals Safeguarding Areas.
1.12 The Call for Sites commenced on15 July 2013 and closed on 15 September 2013, the results of which will be published in due course. Site assessments are currently being undertaken.
Construction and Demolition Waste (C&D) Supplementary Planning Document (SPD)
1.13 The C&D Waste SPD provides additional guidance concerning the production and management of C&D waste. The SPD needs to be reviewed to ensure that it reflects the ongoing changes to planning policy and regulations relating to Site Waste Management Plans. However due to ongoing constraints on resources it has not yet been possible to complete this review.
Statement of Community Involvement
1.14 The Statement of Community Involvement indicates how the Council will engage with with the public and stakeholders in the development of any planning documents that the Council produces. It gives information as to when a consultation takes place, when and where planning documents will be available for inspection, and how the public will be notified about consultations. In light of revised Regulations(3), a review of the SCI began in 2012 and the reviewed SCI was subject to consultation over the summer of 2012. The Council adopted the revised document in February 2013. There are currently no plans to revise the SCI at this time.
Local Aggregate Assessment
1.15 The National Planning Policy Framework (NPPF) states that mineral planning authorities should plan for a steady and adequate supply of aggregates by preparing a Local Aggregate Assessment (LAA) based on a rolling average of 10 years sales data and other relevant local information, including an assessment of all supply options including marine dredged, secondary and recycled sources. Recent Government guidance states that LAAs should be included in AMRs. The detailed LAA adopted by the County Council is therefore appended to this year's AMR. A substitute figure has been used rather than a rolling average of 10 years sales.
3 The Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 and the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2009. Waste and Minerals Monitoring Report 2012/13 7
Executive Summary1
Duty to Cooperate
1.16 A section has been included in this Monitoring Report which is intended to satisfy a requirement in the Town & Country Planning (Local Planning) Regulations 2012(4) that requires local planning authorities to provide details in their Monitoring Reports of the steps taken to comply with the new 'Duty to Cooperate'. The Duty(5) requires County Councils, local planning authorities and other bodies (as prescribed(6)), to co-operate with each other while preparing plan documents. The Duty to Cooperate is limited to those topics that are considered as a strategic matters. Waste and Minerals has been identified as one such strategic matter. Cooperation has taken place with various bodies during the preparation of the Waste and Minerals Plan and this is outlined in Section 5.
Achievement of Waste and Minerals Policies
1.17 The performance of policies contained within the Waste and Minerals Plan, hereafter referred to as 'the Plan' is monitored using the indicators shown below. Full details can be found in section 6 of this Monitoring Report. In contrast to previous Monitoring Reports, this section now closely follows the structure of the Waste and Minerals Plan.
Overarching Strategy Progress
1.18 The overarching strategy of the Plan sets out the very board principles that guide the detailed policies found later in the Plan. It includes Policies WMP1, WMP2, WMP3 and WMP4. While Policies WMP3 and WMP4 appear in this section in the Plan, for ease of reading, these are reported under Providing for Waste and Providing for Minerals respectively in this Report.
Policy WMP1 - Presumption in Favour of Sustainable Development
1.19 Policy WMP1 reflects that overall approach of the Plan. As such, it is monitored through an assessment of the performance of the policies set out below. At this time, due to the recent adoption of the Plan there is insufficient evidence to draw any conclusions about the overall effect of the Policy.
Policy WMP2 - Minerals and Waste Development in the South Downs National Park.
1.20 The importance of conserving and enhancing the South Downs National Park is recognised in the Plan. Policy WMP2 indicates the considerations related to major development in the National Park. It is monitored through an assessment of if the amount of waste capacity, and minerals for extraction that have been permitted in the National Park within the monitoring period. Since the Plan's adoption there has not been an increase in permitted waste capacity or minerals production within the SDNP.
4 Regulation 34 of The Town and Country Planning (Local Planning) (England) Regulations 2012 5 See Section 110 of the Localism Act 2011 6 See Regulation 4 of The Town and Country Planning (Local Planning) (England) Regulations 2012 8 Waste and Minerals Monitoring Report 2012/13
1Executive Summary
Providing for Waste
1.21 The Plan contains a comprehensive suite of policies relating to waste. These cover a range of topics including minimising it's creation, ensuring that it is managed in the right place, and being put to best use. Waste is split into three main waste streams, these are:
Local Authority Collected Waste (LACW), formally known as Municipal Solid Waste, (MSW); Commercial and Industrial Waste (C&I); and Construction, Demolition and Excavation Waste (CDEW).
Policy WMP3a - Promoting Waste Prevention, Re-use and Waste Awareness
1.22 Policy WMP3a seeks to minimise the amount of waste that is produced. Municipal waste arisings (now known as Local Authority Collected Waste, LACW) for the Plan Area in 2012/13 were approximately 359,700 tonnes, this total is similar to the previous year. Municipal and household waste arisings are still at their lowest level since combined data for East Sussex and Brighton & Hove was first made available in 2003/04. Since the publication of the last Monitoring Report, no new information has become available regarding the overall production of C&I and CDEW.
Policy WMP3b - Turning Waste into a Resource
1.23 The Plan aims to manage waste in accordance with the Waste Hierarchy. The Plan looks to minimise the amount of waste sent to landfill and maximise the amount of waste that is recycled and recovered. Policy WMP3b sets high targets for the recovery of waste.
1.24 The WMP has a target to recycle 45%, and recover 98% of LACW waste by 31 March 2016. At the end of the monitoring period the recycling rate (including reuse, recycling and composting) for the Plan Area was 36%; the overall recovery rate was 94%. These currently do not meet the 2016 targets. Since the publication of the last Monitoring Report, no new information has become available regarding the recycling and recovery rates of C&I and CDEW.
1.25 Approximately 57,000 tonnes of LACW and C&I waste was exported for land disposal at facilities outside of the Plan Area during 2012, (73,000 tonnes of waste was sent to landfill inside the Plan Area). The amount of LACW being sent to landfill has continued to fall since the end of 2011 due to the Newhaven Energy Recovery Facility becoming fully operational. This is an improvement on 2010 when approximately 300,000 tonnes was sent for land disposal outside the Plan Area.
Policy WMP3c - Production of Energy from Waste (EfW) Waste and Minerals Monitoring Report 2012/13 9
Executive Summary1
1.26 Policy WMP3c requires that recovery facilities maximise their recovery of energy in line with the EU Waste Framework Directive. The only energy from waste facility in the Plan Area is the Newhaven Energy Recovery Facility. This produces 19 megawatts of electricity and meets the requirements of this policy.
Policy WMP5 - Provision of Built Waste Facilities
1.27 Policy WMP5 contains the requirements for the amount of additional capacity that is required for the recycling and recovery of waste for the Plan Area. This takes into account the need to ensure net self sufficiency. By 2015/16 up to 80,000 tonnes of recycling capacity and between 60,000 and 200,000 tonnes of recovery capacity() will be required. The granting of planning permissions for waste management in the Plan Area helps to meet this requirement.
1.28 The total new permitted throughput capacity within the East Sussex and Brighton & Hove in the monitoring period is:
50,000 tpa in commercial and industrial waste recycling/composting. 21,000 tpa construction, demolition and excavation waste (CDEW) recycling/recovery;
Policy WMP7a - Sustainable Locations for Waste Development (Excluding Land Disposal)
1.29 Policy WMP7a sets out broad Areas of Focus in which waste facilities should be located. These relate to within or close to urban areas, good transport connections and outside designated areas such as the AONB and SDNP.
1.30 The majority of the capacity permitted (as set out above), was located within the Areas of Focus.
Policy WMP7b - More Detailed Criteria for Waste Development
1.31 Policy WMP7b provides additional guidance for potentially suitable sites. These include: industrial land; employment land; previously developed land; and land that was already in waste management uses. Policy WMP7b assists the development management decisions on new capacity.
Policy WMP8a - Land Disposal for Non-Inert Waste
1.32 Policy WMP8a sets strict criteria by which applications for land disposal for non-inert waste would be assessed. There have been no applications to establish new Non-Inert Landfill/ Landraise during the monitoring period.
Policy WMP8b - Deposit of Inert Waste on Land for Beneficial Uses 10 Waste and Minerals Monitoring Report 2012/13
1Executive Summary
1.33 During the monitoring period, permission was granted for 42,000 tonnes of inert material to be deposited on land for beneficial use. (32,000 of which is to be used as part of the restoration of the former Ready Mixed Concrete Plant at British Gypsum Limited, Robertsbridge Works.)
Other Waste Policies
1.34 The most appropriate method of monitoring some policies contained in the Plan will be by periodic review. In these reviews the policies will be assessed to see if they are being implemented as intended, and if there are any implications. The results of these reviews will be reported in future Monitoring Reports as they are undertaken. This applies to the following policies:
Policy WMP3d - Minimising and Managing Waste During Construction, Demolition and Excavation Policy WMP3e - Waste Management in New Development in the Plan Area Policy WMP8c - Management of Landfill Gas Policy WMP9b - Low Level Radioactive Waste Policy WMP9a - Hazardous Waste Policy WMP10 - Management of Waste Water and Sewage Sludge
1.35 In addition the following Policy will be implemented as part of the Waste and Minerals Sites Plan, and will be monitored following it's adoption.
Policy WMP6 - Safeguarding Waste Sites
Providing for Minerals
1.36 The Plan contains a number of policies which aim to deliver different mineral resources for the Plan period. Note, there are currently no operational chalk quarries in East Sussex and the Waste and Minerals Plan does not safeguard chalk resources as there is little demand for the material.
Policy WMP4 - Sustainable Provision of Minerals
1.37 This Policy requires sustainable use and production of minerals in the Plan Area using the minerals hierarchy, for example by promoting secondary and recycled materials. Information on secondary and recycled aggregates continues to be limited by constraints in national and local surveys although background work for the Waste and Minerals Plan indicates that at present the best estimate is 240,000 tonnes per annum (tpa) of recycled aggregate is produced in the Plan Area. Around 10,000 tonnes of waste bricks are produced per annum and around 58,000 tonnes of bottom ash are produced per annum from the Newhaven Energy Recovery Facility. This gives a total estimated figure of around 310,000tpa. Adding this to glass and tyre waste, the Authorities currently have capacity for 0.63 mtpa of CDEW recycling. Sites with planning permission to produce recycled aggregates in the Plan Area are detailed in the Appendices of this document. Waste and Minerals Monitoring Report 2012/13 11
Executive Summary1
Policy WMP11 - Provision of Aggregates
1.38 Policy WMP11 maintains provision of land-won aggregates and a landbank of at least 7 years for the extraction of sand and gravel. Actual data on aggregates production is mainly confidential due to the small number of producers in the area. The Plan has used the Secretary of State's Proposed Modifications of Policy M3 of the South East Plan (March 2010) revised apportionment figure for the Plan Area of 100,000 tonnes per annum. Currently the apportionment and landbank requirement can still be met through the quarry at Stanton’s Farm and production at Lydd Quarry on the Kent border. The existing permissions for extraction adjacent to the proposed Dungeness to Pett Level Special Protected Area (SPA) and Ramsar site will be subject to a Review of Consent process once the designations have been confirmed.
1.39 Data is also limited for the assessment of landings of marine dredged aggregates and other imports. Imports of marine dredged aggregate to East Sussex ports have shown an overall decline in the last 10 years. There was a small upturn in 2007, but imports have fallen sharply since 2010. Crushed rock imports have decreased since 2008 at Newhaven Port, and there are no figures available from 2010. Marine dredged imports into Shoreham Port as a whole increased between 2009 and 2011, and then fell slightly in 2012.
1.40 Marine aggregate reserves within the licensed area serving the South East region are substantial and the level of imports of crushed rock to the county is considered to be significant. Principal constraints on the level of marine landings are considered to be: the security of port access; channel and berth restrictions in relation to the current fleet; vessel availability and the level of investment in modern wharf infrastructure.
1.41 Crushed rock imports from outside the South East region (mainly Wales and Somerset) contribute a sizeable proportion of aggregates to the Plan area. These imports are transported by a mixture of sea, rail and road.
1.42 The whole position on future demand and future supply is considered in the LAA appended to this Monitoring Report. The expectation is that future imports of aggregates and marine dredged materials will continue to be a major source for construction use in East Sussex.
Policy WMP12 - Provision of Gypsum
1.43 Policy WMP12 requires that reserves are maintained from the British Gypsum mine throughout the Plan period. The Gypsum mine at Robertsbridge has at least 20 years of reserves remaining. Demand for plasterboard products is still growing and the mined gypsum is complementing use of imported DSG (Desulphogypsum). In 2012 a planning permission was granted for a strategic DSG storage area and associated development for a period of 10 years at the site. An application for a review of mineral planning conditions has recently been approved (subsequent to the monitoring period in this Report). 12 Waste and Minerals Monitoring Report 2012/13
1Executive Summary
Policy WMP13 - Provision of Clay
1.44 Continued production at existing brickworks will be supported and Policy WMP13 safeguards and maintains sufficient supplies of clay for brick and tile manufacture. Since 2005, the Council has recorded brick clay output and reserves via a yearly survey of clay workings in the County (although this has not taken place in the last 2 years). The data is currently too limited to reveal a definitive picture. Data from the Office of National Statistics confirms that clay production is stable, although some smaller sites are pooling physical resources.
Policy WMP14 - Safeguarding Mineral Resources
1.45 Policy WMP14 sets out how minerals resources will be safeguarded from unnecessary sterilisation by alternative development. Safeguarding areas will be identified in the Waste and Minerals Sites Plan.
Policy WMP15 - Safeguarding Wharves and Railheads
1.46 Policy WMP15 safeguards railheads, wharves and rail sidings for existing and future mineral imports, and in particular overall mineral wharf capacity in ports. Capacity and activity at existing wharves will be monitored, and information on rail imports at British Gypsum will also be sought through the preparation of the Waste and Minerals Sites Plan.
Policy WMP16 - Exploration for Oil and Gas
1.47 Policy WMP16 provides a policy framework for any potential oil and gas exploration, appraisal and production. There is no commercial production of hydrocarbons in East Sussex, although several licences exist which allow exploratory research (subject to the necessary planning permission) by hydrocarbons operators. Considerable interest has arisen with regard to hydraulic fracturing (fracking) and further information has been published on the Council's website.
Overarching Policies
1.48 Overarching policies are those that can relate to both minerals and waste development, or are for use by other planning authorities in determination of their applications.
Policy WMP18 - Transport - Road, Rail and Water
1.49 Policy WMP18 seeks to promote alternatives to road transport. This policy is to be periodically reviewed (see below). At this time it should be noted that in 2011/12 a planning permission was granted for a waste transfer station railhead at the Newhaven ERF Site. This transfer station continues to provide capacity for up to 78,000 tonnes per annum of Incinerator Bottom Ash to be transported out of County by rail for use in construction projects. Additionally Newhaven port continues to be used for the export of a significant quantity of scrap metal from East Sussex by sea. Waste and Minerals Monitoring Report 2012/13 13
Executive Summary1
Other Overarching Policies
1.50 It has been determined the most appropriate method of monitoring the Policies below is by periodic review. In these reviews the Policies are assessed to see if they are being implemented as intended, and if there are any implications. The results of these reviews will be reported in future Monitoring Reports as they are undertaken. This applies to the following policies:
Policy WMP17 - Restoration Policy WMP18 - Transport - Road, Rail and Water Policy WMP19 - Co-location of Complementary Facilities Policy WMP20 - Community Involvement and Benefits Policy WMP21 - Opportunities for Sustainable Waste Management and Minerals Production in Other Development
Policy WMP22 - Expansion and Alterations Within Existing Facilities
1.51 Policy WMP22 provides for the determination of facilities wishing to expand within their existing curtilage. In future this will be recorded as part of the capacity data, and will be reported in the Monitoring Report.
Development Management Policies
1.52 Development management policies address specific matters that are considered in planning proposals. One indication related to their effectiveness is the number of enforcement cases. The total enforcement caseload of the County Council has remained relatively low, with 17 cases outstanding at the end of the third quarter of 2013.
1.53 In addition to the enforcement information it has been determined the most appropriate method of monitoring the Policies below will be by periodic review. In these reviews the Policies are assessed to see if they are being implemented as intended, and if there are any implications. The results of these Reviews will be reported in future Monitoring Reports as they are undertaken. This applies to the following policies:
Policy WMP23a - Design Principles for Built Waste Facilities Policy WMP23b - Operation of Sites Policy WMP24a - Climate Change Policy WMP24b - Resource and Energy Use Policy WMP25 - General Amenity Policy WMP26 - Traffic Impacts Policy WMP27 - Environment and Environmental Enhancement Policy WMP28a - Flood risk Policy WMP27b - Water Resources and Water Quality 14 Waste and Minerals Monitoring Report 2012/13
1Executive Summary
Key Findings
Key findings in this year's AMR are as follows:
Waste Management:
The total percentage (94%) of municipal waste (LACW) being recycled (including composted) and recovered is just below the 2015/16 WMP target (98%). The amount of LACW being recycled (including composted) has not yet met the 2015/16 WMP targets; Annual municipal and household waste arisings remained virtually static in the monitoring period at 359,690 compared to last year's total of 359,991 tonnes; In 2012/13, 6% of LACW waste was sent for land disposal. This has decreased from 40% in 2010/11. In 2012 a total of 130,000 tonnes of waste was sent for land disposal. This was a reduction from 2010 when a total of 533,000 tonnes of waste was disposed to land.
Minerals Production:
The proposed provision for land won aggregates in the adopted WMP can be met; Imports of marine dredged and crushed rock material continue to make an important contribution to aggregate consumption in the Plan Area; Clay and gypsum continued to be extracted at the levels in accordance with policy; There continue to be no active working chalk quarries within the County.
Development Plan Documents:
With regard to the WMP, following a Public Examination, the three Authorities consulted on one Main Modification to the Plan to include a new sustainable development policy. In January 2013 the Government Planning Inspector found the WMP 'sound'. The WMP for East Sussex, South Downs and Brighton & Hove was adopted in February 2013 and is now used in the determination of planning applications. Work has commenced on the Waste and Minerals Sites Plan. A Call for Sites commenced in July 2013. Site assessments are currently being undertaken. Waste and Minerals Monitoring Report 2012/13 15 Context and Role of the Monitoring Report2 2 Context and Role of the Monitoring Report
2.1 East Sussex County Council, as a Waste and Minerals Planning Authority, provides planning policies for waste management and minerals production, which are prepared jointly with Brighton & Hove City Council and the South Downs National Park Authority. The Council is required to monitor implementation of these policies by the provisions in Planning and Compulsory Purchase Act 2004 and does this by producing a Waste & Minerals Monitoring Report, which also provides data and commentary on trends in waste management and minerals production.
2.2 Specific guidance on the content of monitoring reports was removed by the Coalition Government(7), and new requirements inserted by the Localism Act(8). The County Council intends to continue to publish Monitoring Reports annually in order to maintain consistency and enable easy comparison of indicators with previous years. In response to the changes in the Localism Act, the County Council will seek to make data available on it's website on an ongoing basis.
2.3 New Government Regulations introduces additional requirements for monitoring reports. In particular, where the authorities have co-operated with another relevant body the monitoring report must give details of what action has been taken during the period. The new Regulations also require authorities to publish relevant information as soon as possible after the data is available.
2.4 This Monitoring Report covers the period 1 April 2012 to 31 March 2013. AMRs from previous years can be found at the following website: www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste/amr1.htm
2.5 Some reporting of significant developments that have taken place between 31 March 2012 and the preparation of this document are also included.
2.6 This Monitoring Report covers only waste and minerals matters. Other forms of development and development planning in East Sussex, for example housing or employment land, are dealt with by the City, Borough, and District Councils, and National Park Authorities in their own existing and emerging Local Plans and Monitoring Reports.
2.7 The Monitoring Report reports against the following key monitoring tasks for the Plan Area which includes Brighton & Hove and part of the South Down National Park:
Assessing the extent to which saved policies in the Waste Local Plan and Minerals Local Plan are being implemented;
7 Letter from Bob Neill MP to Local Planning Authorities, 30 March 2011 8 Section 113 Localism Act 2011. 16 Waste and Minerals Monitoring Report 2012/13 2Context and Role of the Monitoring Report
reviewing progress in preparing the Development Plan Documents that form the Waste and Minerals Plan against the timetable and milestones in the Minerals and Waste Development Scheme; checking performance against indicators and local objectives for waste and minerals.
Existing Planning Policy Framework
2.8 The Development Plan for the area comprises the Waste and Minerals Plan, the Saved Policies in the Waste Local Plan and the Minerals Local Plan, as well as all the Local Plans produced by the district planning authorities (including the plans adopted by the Brighton & Hove City Council). A Waste and Minerals Sites Plan is currently being prepared. Planning law requires planning applications to be determined in accordance withe the development plan, unless material considerations indicate otherwise. National Policy is a material consideration.
Waste and Minerals Plan
2.9 The Waste and Minerals Plan was adopted on 19 February 2013 following a Public Examination at which the Planning Inspector found the Plan "sound" (See Section 4 of this Report). The Plan sets out the policy framework for waste and minerals development up to 2026. The Plan has strategic and development management policies but the Plan does not allocate specific sites. The Plan includes a set of monitoring indicators.
Waste Local Plan
2.10 As a result of the adoption of the Waste and Minerals Plan, the majority of previously saved policies have now been replaced. The policies not replaced cover site specific allocations under Policies WLP7, WLP8 and WLP9.
2.11 Further details can be found on the Council’s website at: www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste/wastelocalplan.htm
Minerals Local Plan
2.12 Similarly, as a result of the adoption of the Waste and Minerals Plan, the majority of previously saved policies in the Minerals Local Plan have also now been replaced. The policies not replaced cover site specific and safeguarding policies under Policies 3, 4, 32 and 36.
2.13 The Minerals and Waste Local Plans can be viewed on the East Sussex County Council website (see above) and hard copies are available for inspection at County Hall, Lewes or can be obtained from the Planning Service in the Communities, Economy, and Transport Department by telephone on 01273 481846, or by email to [email protected]. Waste and Minerals Monitoring Report 2012/13 17 Context and Role of the Monitoring Report2
National Policy
2.14 The National Planning Policy Framework (NPPF) was published on 27 March 2012 and came into immediate effect. It does not change the status of the development plan as the starting point for decision making. At the heart of the NPPF is a presumption in favour of sustainable development. Following a 12 months transitional arrangement, due weight should be given to relevant policies in existing plans according to their degree of consistency with the NPPF. The Framework does not contain specific waste policies but regard should be had to NPPF policies so far as relevant. There are policies facilitating the use of minerals and a complete suite of policies covering many aspects of planning.
2.15 The Government has launched new National Planning Policy Guidance which has refreshed, streamlined and brought up to date existing planning guidance. However, the new Guidance is only available in Beta form and existing guidance remains. Current planning guidance will be cancelled once the new guidance is in place and live.
2.16 The Government has published in 2011 a Review of the National Waste Policy for England (2007). The Government has consulted on a new national waste planning policy statement to replace Planning Policy Statement10 but a final version has yet to be issued.
Local Aggregate Assessment
2.17 The NPPF states that the relevant authorities should prepare an annual Local Aggregate Assessment (LAA). The NPPF states that authorities should plan for a steady and adequate supply of aggregates. It is advised that the LAA is based on a rolling average of 10 years sales data and other relevant local information. The LAA has to consider all supply options including land won, marine, secondary and recycled material. The County Council has decided not to use 10 years sales data for the Plan Area as this is too volatile to form the basis for robust planning. The LAA utilises a substitute figure for land won aggregates based on an apportionment figure used in the adopted Waste and Minerals Plan. The authorities will monitor how supplies decline over time. The LAA 2013 has been adopted and is appended to this Report. 18 Waste and Minerals Monitoring Report 2012/13
3Characteristics of East Sussex 3 Characteristics of East Sussex
Environmental Designations
3.1 The South Downs National Park was officially designated on 31 March 2010, and replaces the Sussex Downs Area of Outstanding National Beauty (AONB). The boundary of the new designation is different to that of the AONB, including the town of Lewes and other areas to the north of the AONB. The National Park and the High Weald AONB together cover two thirds of the Plan area.
3.2 Other tracts of land are additionally designated as being of international and national environmental importance and are shown in Map 1 below.
Demography
3.3 The rate of production of waste and consumption of minerals has been shown to have a relationship with population growth; an increasing population produces more waste and has a greater demand for minerals.
3.4 The Plan Area has a total population of approximately 800,161, of which about two thirds live in East Sussex (see below) and the remainder in Brighton & Hove. Approximately 29,000 people live within the Plan Area part of the South Downs National Park. Over the period 2011-2021, the population in East Sussex is predicted to increase by 2.48%. The average household size is expected to decrease from 2.16 in 2011 to 2.06 in 2026.
Table 1 East Sussex and Brighton & Hove Population Projections 2011 to 2021
Year East Sussex Brighton and Hove Plan Area Population Population Population 2011 527,209 272,952 800,161 2016 530,061 282,753 812,814 2021 530,184 289,902 820,086
3.5 The figures in the table above are based on the Office for National Statistics: Sub-national population projections for England, Interim 2011-based, (released 28 September 2012)(9)
9 www.ons.gov.uk/ons/rel/snpp/sub-national-population-projections/Interim-2011-based/index.html
Waste and Minerals Monitoring Report 2012/13 21
Characteristics of East Sussex3
Economy
3.6 The structure of the economy in the Plan Area is dominated by service industries, and this affects the nature of commercial and industrial waste arisings and the need for particular minerals.
3.7 In 2009, 85% of jobs in the County were in the service sector, 7% in manufacturing, 7% in construction and 1% in agriculture, fishing, mining and utilities. One-third of all people who work in East Sussex are employed in public administration, education or health. Wholesale and retail trade; and accommodation and food service activities account for 27% of people who work in the County. In Brighton & Hove the employment structure is dominated by higher value sectors such as health, business & public administration, professional, scientific & technical sectors & education.
3.8 The economy in East Sussex is characterised by its high number of small businesses. The average business in the UK had just over seven employees in 2008, whereas in East Sussex three-quarters of businesses employ five or less people, and 88% of companies employ 10 or fewer people. The situation is similar in Brighton & Hove, with 86.4% of businesses employing less than ten people in 2010.
3.9 Tourism and the conference trade is a key element in the local economy, contributing around 10 million visitors per annum and significantly increasing the amount of waste to be managed.
3.10 The South Downs within the Plan Area has a predominantly rural economy, with the exception of the busy market town of Lewes.
3.11 Two Local Enterprise Partnerships (LEPs) cover the Plan Area. The 'Coast to Capital' LEP includes Brighton & Hove, while East Sussex is part of the South East LEP that also covers Kent and Essex. LEPs are partnerships between local authorities and businesses that aim to drive economic growth and job creation.
3.12 Further detail on the environmental and social characteristics of East Sussex and Brighton & Hove is available at www.eastsussexinfigures.org.uk and in the Authorities’ Information Paper 6 - 'Spatial Portrait of East Sussex and Brighton & Hove', published to accompany the Waste & Minerals Development Plan. It is available to download at: www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste/downloadpapers.htm 22 Waste and Minerals Monitoring Report 2012/13 4Progress of the Waste & Minerals Local Plan 4 Progress of the Waste & Minerals Local Plan
Progress on the Waste & Minerals Local Plan
4.1 East Sussex County Council, as a Waste and Minerals Planning Authority, provides planning policies for waste management and minerals production. Current policies are contained in the East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan, and saved policies within the Waste Local Plan and Minerals Local Plan. The Council is required to monitor implementation of these policies by the Planning and Compulsory Purchase Act 2004, as amended by the Localism Act 2011 In previous years this requirement was set out in the Planning and Compulsory Purchase Act 2004 which required the production of an Annual Monitoring Report. Changes, including the title of the report have been introduced by the Localism Act 2011, and partly does this by producing a Waste & Minerals Monitoring Report. The content of Monitoring Reports is also prescribed by the Town & Country Planning (Local Planning) Regulations 2012.This Monitoring Report covers the period 1 April 2012 to 31 March 2013. Monitoring Reports from previous years can be found at the following website: www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste/amr1.Htm
4.2 The WMLP is being jointly produced by East Sussex County Council, Brighton & Hove City Council and the South Downs National Park Authority (SDNPA). The WMLP also includes a Supplementary Planning Document (SPD) that covers the production and management of construction and demolition waste. Separately the Authorities produce Statements of Community Involvement.
Minerals & Waste Development Scheme
4.3 A Minerals and Waste Development Scheme (MWDS) is produced by the County Council to provide a timetable for the production of these documents which is mirrored by Brighton & Hove City Council and the South Downs National Park Authority.
4.4 In July 2011 a revised Minerals and Waste Development Scheme, containing the timetable for the preparation of the documents that form the Waste and Minerals Local Plan was approved by the County Council. A further update was agreed in July 2012. In light of changes to legislation(10), there is no longer a requirement to submit the Scheme to Government for approval. The Minerals and Waste Development Scheme can be found at the following website: http://www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste
10 Localism Act 2011, section 111. Waste and Minerals Monitoring Report 2012/13 23 Progress of the Waste & Minerals Local Plan4
Waste & Minerals Plan
4.5 During the monitoring period, work was completed on the Draft Waste and Minerals Plan. The draft Plan had been submitted to Government in June 2012 for Public Examination. In September 2012 Public Examination Hearings into the Plan were convened by independent Planning Inspector Mrs Susan Holland. The Public Hearings lasted two weeks.
4.6 Issues discussed at the Hearings included the Plan's strategy for waste, the treatment capacity data, as well as locational factors relating to the Areas of Focus for waste. The movement of minerals and waste, the Duty to Cooperate and apportionment of land-won aggregates were also covered.
4.7 As a result of the Hearings only one 'Main Modification' to the Plan was proposed relating to the 'presumption in favour of sustainable development' as set out in the National Planning Policy Framework. A consultation on this Main Modification was carried out in October 2012.The results were considered by the Inspector.
4.8 The Inspector's Report was published in January 2013 and the Plan was found 'sound', subject to the one Main Modification. A number of minor modifications were made to the Plan. In the Report, the Inspector noted that the Plan had been positively prepared with a strong commitment to moving away from landfill as a way of disposing of waste. It concluded that the Plan was legally compliant and provided an appropriate basis for planning in the area over the next 15 years. The Inspector also accepted the approach that Plan Area should not take waste from London.
4.9 In February 2013 the Waste and Minerals Plan was adopted, and is now being used in the determination of planning applications.
4.10 The Waste and Minerals Plan includes an updated set of monitoring indicators. With the adoption of the Plan these indicators now must be monitored. In this and future Monitoring Reports, the indicators reported reflect those found in the Waste and Minerals Plan (2013). Continuity of data is very important, therefore information that has been reported in previous Monitoring Reports will continue to be recorded and published as before, but these will be referenced under different indicators.
4.11 In November 2013, the County Council along with Brighton & Hove City Council and South Downs National Park Authority won a Commendation for the Innovative Use of the Planning Process for the work on the Waste and Minerals Plan. The judges were particularly impressed with the imaginative way community involvement had been used and the ground breaking work on the Duty to Co-operate. They said this was exemplified by the Local Government Association's Planning Advisory Service having produced a best practice note on the co-operation techniques used by the Authorities in producing the Waste and Minerals Plan. 24 Waste and Minerals Monitoring Report 2012/13 4Progress of the Waste & Minerals Local Plan
Saved Policies in the Waste and Minerals Local Plans
4.12 With the adoption of the Waste and Minerals Plan (see above) the majority of policies that were previously saved have now been replaced. Site specific planning policies in the Waste Local Plan (WLP) and Minerals Local Plan (MLP) continue to be saved until they are replaced by those in the Waste and Minerals Sites Document as set out in the Minerals and Waste Development Scheme.
Waste & Minerals Sites Plan
4.13 The approved Minerals and Waste Development Scheme sets out a timetable for the preparation of the Waste and Minerals Sites Plan as follows:
Stage When
Public 'Call for Sites' Summer 2013
Public consultation on a shortlist of sites Spring 2014
Public consultation on a proposed Submission Summer 2015 Plan
Submission of Plan to Government Late 2015
Public Examination Early Spring 2016
Adoption Early Summer 2016
4.14 This document will include allocation of land to meet the requirements for additional capacity for the management of waste and identification of Minerals Safeguarding Areas.
4.15 The Call for Sites commenced on 15 July 2013 and closed on 15 September 2013, the results of which will be published in due course. Site assessments are currently being undertaken.
Construction & Demolition Waste SPD
4.16 The C&D Waste SPD provides additional guidance concerning the production and management of C&D waste. The SPD needs to be reviewed to ensure that it reflects the ongoing changes to planning policy and regulations relating to Site Waste Management Plans. However due to ongoing constraints on resources it has not yet been possible to complete this review. Waste and Minerals Monitoring Report 2012/13 25 Progress of the Waste & Minerals Local Plan4
Statement of Community Involvement
4.17 The Statement of Community Involvement indicates how the Council will engage with with the public and stakeholders in the development of any planning documents that the Council produces. It gives information as to when a consultation takes place, when and where planning documents will be available for inspection, and how the public will be notified about consultations. In light of revised Regulations(11), a review of the SCI began in 2012 and the reviewed SCI was subject to consultation over the summer of 2012. The Council adopted the revised document in February 2013. There are currently no plans to revise the SCI at this time.
Key Findings:
Following a Public Examination, the three Authorities consulted on one Main Modification to the WMP to include a new sustainable development policy. In January 2013 the Government Planning Inspector found the WMP 'sound'. The WMP for East Sussex, South Downs and Brighton & Hove was adopted in February 2013 The County Council along with Brighton & Hove City Council and South Downs National Park Authority won a Commendation for the Innovative Use of the Planning Process for the work on the Waste and Minerals Plan. Work has commenced on the Waste and Minerals Sites Plan. A Call for Sites commenced in July 2013. Site assessments are currently being undertaken. The Construction & Demolition Waste SPD and the has not yet been reviewed due to constraints on resources. The Council adopted a revised SCI in February 2013.
11 The Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 and the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2009. 26 Waste and Minerals Monitoring Report 2012/13
5Duty to Co-operate 5 Duty to Co-operate
5.1 This section is intended to satisfy a new statutory requirement(12) that requires local planning authorities to provide details in their monitoring reports of the steps taken to comply with the new 'Duty to Cooperate'. This duty is set out in Section 110 of the Localism Act 2011 and requires county councils, local planning authorities and other bodies (as prescribed(13)), to co-operate with each other while preparing plan documents. The Duty to Cooperate is limited to those topics that are considered as a strategic matters. Waste and Minerals has been identified as one such strategic matter.
Regional Fora
5.2 The Authorities' membership of waste and minerals planning fora which cover the whole of the South-East (as described below) has been an important basis for cross boundary on key strategic waste management and minerals production matters.
5.3 The South East Waste Planning Advisory Group (SEWPAG) provides a regular opportunity for cooperation on planning for waste management across administrative boundaries in the South-East.
5.4 The South East England Aggregates Working Party (SEEAWP) exists to co-ordinate the steady and adequate supply of aggregate across the South-East.
Waste and Minerals Plan
5.5 During the production of the Waste and Minerals Plan there was ongoing co-operation between East Sussex County Council, Brighton & Hove City Council, and the South Downs National Park Authority and the other prescribed bodies. Cross boundary matters requiring particular attention included the following:
Potential export of residual waste to land disposal Importation of London’s Waste Minerals West Sussex
5.6 Further information on cooperation associated with these matters is set out below:
12 Regulation 34 of The Town and Country Planning (Local Planning) (England) Regulations 2012 13 See Regulation 34 of The Town and Country Planning (Local Planning) (England) Regulations 2012 Waste and Minerals Monitoring Report 2012/13 27
Duty to Co-operate5
Potential export of residual waste to land disposal and the Importation of London’s Waste
5.7 Following the Public Examination and subsequent adoption of the Waste and Minerals Plan, it is considered that, at this time, the topics of the potential export of residual waste to land disposal and the importation of London's Waste are resolved. Should these issues reemerge the Authorities will seek to engage with the appropriate prescribed bodies.
Minerals
5.8 As mentioned above, the Authorities primary engagement mechanism relating to the aggregates apportionment of has been through SEEAWP. The Authorities also discussed the implications of development plan proposals for aggregates production with the relevant District Councils.
5.9 Landings of marine aggregates at Shoreham Harbour are a cross border issue and this is being considered as part of the work being undertaken by Brighton and Hove City Council, Adur District Council, West Sussex County Council (WSCC), and the Shoreham Port Authority, on the Joint Area Action Plan and the West Sussex Minerals Local Plan.
5.10 The following outcomes on minerals has resulted:
5.11 Aggregates Apportionment: East Sussex was viewed as a ‘special case’ through the Review of Policy M3 of the South East Plan. The apportionment for the Plan Area reflects actual availability of resources.
5.12 Soft Sand: The South Downs National Park Authority has undertaken a study to assess the potential resource across the Park and alternative sources outside the Park boundary.
5.13 Mineral Wharves: The policies within the Plan include flexibility to ensure that existing capacity can be maintained within regeneration proposals for each Port. Additionally, the Assent for activities in Rye Harbour was updated to allow working for another five years, in response to concerns relating to the proposed extension to the Dungeness to Pett Level SPA.
West Sussex
5.14 As there are existing shared interests been the Authorities and West Sussex County Council, there is ongoing engagement with WSCC on aggregates and the provision of soft sand, movements of waste across boundaries, and aggregate imports at Shoreham Port. 28 Waste and Minerals Monitoring Report 2012/13
5Duty to Co-operate
Waste and Minerals Sites Plan
5.15 Work on the Waste and Minerals Sites Plan has now commenced, and there has been ongoing co-operation between East Sussex County Council, Brighton & Hove City Council, and the South Downs National Park Authority and the other prescribed bodies. Cross boundary matters requiring particular attention included site selection and waste water.
Site Selection
5.16 At this early stage, a proactive approach has been taken with the local District and Boroughs to seek their input on the site selection process, with the aim of building as much consensus as possible. Initial meetings were held where a provisional Long List, (and a number of sites of interest), were discussed. The outcome of these meetings fed into the site screening process. A the provisional Long List was revised and the Districts and Boroughs were asked if they had any further comments prior to detailed assessments being undertaken on this Long List. These discussions have eliminated a significant number of sites from further assessment.
Waste Water
5.17 A meeting was held with Southern Water regarding their ambitions, however the different timing of the WMSP and Southern Water's plans may be problematic. Waste and Minerals Monitoring Report 2012/13 29
Monitoring the Plan6 6 Monitoring the Plan
6.1 Section 7 of the Waste and Minerals Plan sets out a comprehensive list of monitoring indicators. These have been reviewed, and in places refined. Further details can be found in the following sections:
Table 2
Section Policies
7. Overarching WMP1 - Presumption in Favour of Sustainable Development Strategy WMP2 - Minerals and waste development affecting the South Downs National Park
8. Providing for *WMP3a - Promoting waste prevention, re-use and waste Waste awareness
*WMP3b - Turning waste into a resource
*WMP3c - Production of energy from waste
*WMP3d - Minimising and managing waste during construction, demolition and excavation
*WMP3e - Waste management in new development
WMP5 - Provision of Built Waste Facilities
WMP6 - Safeguarding Waste Sites
WMP7a - Sustainable locations for waste development (excluding land disposal)
WMP7b - More detailed criteria for waste development
WMP8a - Land disposal of non-inert waste
WMP8b - Deposit of inert waste on land for beneficial purposes
WMP8c - Management of landfill gas
WMP9a - Hazardous waste
WMP9b - Low level radioactive waste
WMP10 - Management of waste-water and sewage sludge 30 Waste and Minerals Monitoring Report 2012/13
6Monitoring the Plan
Section Policies
9. Providing for *WMP4 - Sustainable provision and use of minerals in the Plan Minerals WMP11 - Provision of Aggregates
WMP12 - Provision of Gypsum
WMP13 - Provision of Clay
WMP14 - Safeguarding Minerals Resources
WMP15 - Safeguarding Wharves and Railheads
WMP16 - Exploration for Oil and Gas
10. Overarching WMP17 - Restoration Policies WMP18 - Transport - road, rail and water
WMP19 - Co-location of complementary facilities
WMP20 - Community involvement and benefits
WMP21 - Opportunities for sustainable waste management and minerals production in other developments
WMP22 - Expansion and alterations to waste facilities
11. WMP23a - Design principles for built waste facilities Development Management WMP23b - Operation of sites Policies WMP24a - Climate change
WMP24b - Resource and energy
WMP25 - General amenity
WMP26 - Traffic Impacts
WMP27 - Environment and Environmental Enhancement
WMP28a - Flood risk
WMP28b - Groundwater and water quality Waste and Minerals Monitoring Report 2012/13 31
Monitoring the Plan6
6.2 WMP3a-e and WMP4 in the Waste and Minerals Plan are located under the Overarching Strategy section, however are located under Providing for Waste and Providing for Minerals respectively in this monitoring report.. 32 Waste and Minerals Monitoring Report 2012/13
7Overarching Strategy 7 Overarching Strategy
7.1 The overarching strategy of the Waste and Minerals plan sets out what the County Council wants to achieve in terms of waste and minerals development and underpins the Plan's detailed policies. It is governed by four principle policies:
Policy WMP1 - Presumption in Favour of Sustainable Development Policy WMP2 - Minerals and Waste Development in the South Downs National Park Policy WMP3(a - e) - Implementing the Waste Hierarchy Policy WMP4 - Sustainable Provision and Use of Minerals
7.2 This section of the AMR will concentrate on policies WMP1 and WMP2. Policy WMP3 and WMP4 are reported under the sections Providing for Waste and Providing for Minerals, respectively.
Progress of the Overarching Strategy Policies
Policy WMP1 - Presumption in Favour of Sustainable Development
7.3 The presumption in favour of sustainable development in a key aspect of Central Government planning policy and is at the heart of the National Planning Policy Framework. The inclusion of this policy as part of East Sussex County Council's overarching strategy is to ensure sustainable development is at the heart of planning policy in the county and that decisions are taken in line with this presumption.
7.4 The policy reflects the overall approach of the plan. To reflect this, Policy WMP1 shall be monitored through assessing the performance of the Plan's policies more generally, as set out elsewhere in the AMR, and referring back to how decisions reflect the presumption in favour of sustainable development. The Plan's relatively recent adoption, however, means that at the time of writing there is insufficient evidence to draw any conclusions about the overall effect of the Policy on decisions taken within the County.
Use of Policy
7.5 In addition to the above policies, in future monitoring reports this section will also report the number of times each policy within the Plan has been used in the year. This provides information as to how often policies are used. This information is used when considering the indicators set out below. (Note, if a policy is cited more than once in a development management report, it only is counted once.)
7.6 Total number of county matter decisions issued between 19/02/13 (date of WMP adoption) and 31/03/13 (end of monitoring period): 1 Waste and Minerals Monitoring Report 2012/13 33
Overarching Strategy7
7.7 Total number of county matter decisions issued between 01/04/13 (start of next years monitoring period) and 31/12/13 (6 months): 12
7.8 # No information regarding indicator direction at this time; + Positive direction; - Negative direction.
Table 3
Overarching Strategy
Policy Purpose No of times policy No of times policy Indicator cited in report. cited in report. Direction
19/02/13 - 01/04/13-31/12/13 (# Insufficient 31/03/13 Information;
+ Positive ; - Negative.)
WMP1 - Presumption in To ensure that decisions are taken in line with 0 2 # Favour of Sustainable the presumption in favour of sustainable Development development as set out in the National Planning Policy Framework (NPPF).
WMP2 - Minerals and To ensure development is sustainable and 0 1 + waste development appropriate to the purposes and duties of the affecting the South South Downs National Park Authority. Downs National Park
WMP3a - Promoting To prevent waste occurring in order to reduce 0 1 # waste prevention, the amount of waste treatment capacity re-use and waste needed. To provide commitment to awareness contributing to wider strategies about waste awareness and sustainable resource use; To facilitate movement to the upper tiers in the waste hierarchy, and particularly to increase preparation for re-use, which will involve industries and developments beyond waste management facilities; For development management authorities, this policy provides a clear framework for ensuring that sustainable waste management is taken into account in planning decisions about non-waste developments.
WMP3b - Turning waste To encourage the development of new waste 1 5 + into a resource recycling and recovery infrastructure which ensures waste which has been produced is managed as far up the waste hierarchy as possible and in a manner which minimises the production of greenhouse gases.
WMP3c - Production of To recognise that energy recovery is lower in 0 0 # energy from waste the waste hierarchy than other processes so proposals will need to be justified accordingly, and ensure that where energy recovery does take place, the capture of heat and/or energy from those processes should be in the most sustainable and efficient manner possible. This includes taking into account the EU Waste Framework Directive as well as Government policy about increasing use of renewable energy and decentralised power sources, and more broadly about mitigating against climate change.
WMP3d - Minimising To ensure that the waste hierarchy is taken 0 1 # and managing waste into account during construction and during construction, demolition activities associated with all new development which require planning 34 Waste and Minerals Monitoring Report 2012/13
7Overarching Strategy
Overarching Strategy
demolition and permission (not just those that involve the excavation management of waste); To encourage architects, project funders, and contractors to minimise waste through the life-cycle of a project by 'designing out waste';This policy can be implemented by all planning authorities in the Plan Area.
WMP3e - Waste To ensure that new developments take place 0 0 # management in new in a manner which allows for the convenient development sustainable management of waste. For example the policy will ensure that, where appropriate, space is made available for the storage and collection of separated recyclable materials e.g. bring banks; It is envisaged that this policy will be implemented by all planning authorities in the Plan Area.
WMP4 - Sustainable To deliver the sustainable use and production 0 0 # provision and use of of minerals using the minerals hierarchy, for minerals in the Plan example by promoting secondary and recycled materials.
Table 4
Providing for Waste
Policy Purpose No of times policy No of times policy Indicator cited in report. cited in report. Direction
19/02/13 - 01/04/13-31/12/13 (# Insufficient 31/03/13 Information;
+ Positive ; - Negative.)
WMP5 - Provision of To identify the future need for recycling and 0 0 + Built Waste Facilities recovery facilities, and avoid any adverse effects that over-provision of capacity could bring; To provide flexibility in the Plan to demonstrate 'net self sufficiency' by allowing for additional recovery capacity of an amount equivalent to that amount that is identified as needing to be exported for disposal to land.
WMP6 - Safeguarding To safeguard existing waste management 0 0 # Waste Sites facilities as appropriate.
To safeguard certain areas in order to support the delivery of waste management facilities in the most appropriate locations.
To safeguard Waste Local Plan site-specific allocations for waste management facilities.
WMP7a - Sustainable To identify broad areas (Areas of Focus) 0 4 + locations for waste within the Plan Area within which the best development opportunities for locating waste recycling and (excluding land recovery facilities are more likely to be found. disposal) The Areas of Focus identified in this policy, WMP7b - More detailed and shown on the Waste Key Diagram, will 0 3 + criteria for waste guide preparation of the Waste and Minerals development Sites Plan. Waste and Minerals Monitoring Report 2012/13 35
Overarching Strategy7
Providing for Waste
WMP8a - Land disposal To identify the need for land disposal of 0 0 # of non-inert waste non-inert and inert waste. To provide a policy approach if such applications are submitted WMP8b - Deposit of and to ensure that landfill gas produced by 1 3 + inert waste on land for land disposal facilities is captured and used beneficial purposes as a fuel.
WMP8c - Management 0 0 # of landfill gas
WMP9a - Hazardous To allow for new waste water treatment 0 0 # waste capacity to be developed as appropriate.
To provide additional waste water treatment works capacity in the Hailsham area and additional sewage sludge treatment capacity in the period up to 2026, in accordance with identified needs.
Appropriate sites for both types of facilities will be considered in more detail in the Waste and Minerals Sites Plan.
WMP9b - Low level This policy is intended to ensure that: where 0 0 # radioactive waste viable, Low Level Radioactive Waste (LLW) management capacity is provided in the Plan Area such that LLW can be managed close to its source of production;in particular, the development of LLW incineration capacity, if incorporated as part of a wider scheme for the Plan Area, can be supported; additional capacity could be provided to manage LLW from beyond the Plan Area but only where this would help achieve 'net self-sufficiency'; and where additional capacity is developed for the management of LLW from beyond the Plan Area, that this capacity makes a significant contribution to the management of LLW arising within the Area.
WMP10 - Management To allow for new waste water treatment of waste-water and capacity to be developed as appropriate. sewage sludge To provide additional waste water treatment works capacity in the Hailsham area and additional sewage sludge treatment capacity in the period up to 2026, in accordance with 0 0 # identified needs.
Appropriate sites for both types of facilities will be considered in more detail in the Waste and Minerals Sites Plan.
Table 5
Providing for Minerals
Policy Purpose No of times policy No of times policy Indicator cited in report. cited in report. Direction
19/02/13 - 01/04/13-31/12/13 (# Insufficient 31/03/13 Information;
+ Positive ; - Negative.) 36 Waste and Minerals Monitoring Report 2012/13
7Overarching Strategy
Providing for Minerals
WMP11 - Provision of To account for the proposed government Aggregates apportionment for aggregates in order to 0 1 # assess the need for any further allocations of primary aggregates production.
WMP12 - Provision of To safeguard and maintain supplies to and Gypsum from the British Gypsum works throughout 0 0 # the Plan period.
WMP13 - Provision of To safeguard and maintain sufficient supplies 0 0 # Clay of clay for brick and tile manufacture.
WMP14 - Safeguarding To set out how mineral resources will be Minerals Resources safeguarded by identifying Mineral Safeguarding Areas (areas of known resources) and Mineral Consultation Areas (areas where the district or borough council should notify 0 0 # the Authorities of any alternative development proposals). Identifying Consultation Areas does not necessarily imply that the resource will be worked.
WMP15 - Safeguarding To safeguard railheads, wharves and rail Wharves and Railheads sidings for existing and future mineral imports and processing. In particular to safeguard overall mineral wharf capacity in ports 0 0 # subject to no net loss of capacity, and to encourage co-location with processing capacity.
WMP16 - Exploration To provide a policy framework for any for Oil and Gas potential oil and gas exploration, appraisal 0 0 # and production.
Table 6
Overarching Policies
Policy Purpose No of times policy No of times policy Indicator cited in report. cited in report. Direction
19/02/13 - 01/04/13-31/12/13 31/03/13
WMP17 - Restoration To secure appropriate restoration of mineral workings and waste sites. Restoration should seek environmental and amenity benefits reflecting local circumstances and relevant 0 1 # landscape and biodiversity objectives. Proposed afteruses are likely to require ongoing management.
WMP18 - Transport - To minimise the environmental and amenity road, rail and water effects of the transport of waste and minerals by promoting rail and water transport as an 0 0 # alternative to road transport; (Detailed, site-specific, transport impacts are covered by Policy WMP 26.)
WMP19 - Co-location of To encourage co-location of complementary complementary waste or minerals processing facilities and facilities associated industries, where this would offer 0 0 # either operational or cost efficiencies or transport benefits. Waste and Minerals Monitoring Report 2012/13 37
Overarching Strategy7
Overarching Policies
WMP20 - Community To encourage developers to take a more involvement and proactive approach and engage with local benefits communities as early as possible to help avoid misunderstandings and reduce anxiety related to waste or minerals-related developments, and also to ensure that where there are potential benefits for the community, that those benefits are realised by people living or working close by; The policy aims to 0 0 # readdress a perceived lack of engagement between host communities and developers/the waste and minerals industry in the submission of planning applications for waste or minerals developments. It seeks not only to reduce negative experiences of communities but actually to secure positive benefits for host communities.
WMP21 - Opportunities To ensure that objectives of sustainable waste for sustainable waste management and minerals production are management and considered in the preparation and minerals production in determination of non-waste and minerals other developments applications, where appropriate; This policy is concerned with maximising opportunities for improving the sustainable management and transport of waste that has already been 0 0 # produced - prevention of waste is dealt with elsewhere in this Plan; This policy is not intended to address the management of waste arising from construction and demolition which is dealt with separately by Policy WMP 3d; It is envisaged that this policy will be implemented by all planning authorities in the Plan Area.
WMP22 - Expansion and To enable expansions of capacity or alterations to waste alterations to operations within existing waste 0 4 + facilities management facilities.
Table 7
Development Management Policies
Policy Purpose No of times policy No of times policy Indicator cited in report. cited in report. Direction
19/02/13 - 01/04/13-31/12/13 (# Insufficient 31/03/13 Information;
+ Positive ; - Negative.)
WMP23a - Design To provide guidance about more detailed principles for built design and operational aspects for built waste 0 3 # waste facilities facilities, and to support the spatial policies regarding waste facilities. It focuses on WMP23b - Operation of non-functional components of waste facilities sites and does not seek to address issues associated with technical design, but recognises that the interface between the two is important; The policy also links with the Community Involvement and Benefits policy (WMP 20), about involving host communities in the 0 1 # design of facilities, with the Climate Change policy (WMP 24) which seeks design aspects which contribute to minimising greenhouse gas emissions, and with the Resource and Energy policy (WMP 24b). 38 Waste and Minerals Monitoring Report 2012/13
7Overarching Strategy
Development Management Policies
WMP24a - Climate To set out how waste and minerals 0 0 # change developments should seek to mitigate and adapt to climate change; It supplements the WMP24b - Resource guidance about climate change set out in the and energy National Planning Policy Framework because a) the Plan Area is coastal so climate change is a particular concern, and b) national policy about design is not specific to waste or minerals developments; Proposals for waste and minerals development should set out how they will minimise greenhouse gas emissions, either through design, construction or operations; Diversion of waste from landfill 0 0 # and movement up the waste hierarchy also contributes to mitigating climate change - this is covered in Policy WMP 3 Implementing the Waste Hierarchy. Policy WMP 24 deals with the more detailed aspects of how waste or minerals operations themselves can take measures to mitigate and adapt to the impacts of climate change.
WMP25 - General To protect local communities from the amenity potential negative impacts of waste and minerals development such as those resulting 1 11 # from noise, dust, fumes, windblown litter, and visual intrusion.
WMP26 - Traffic To ensure that proposals fully address the Impacts site-specific issues related to road transport and traffic of waste or minerals 1 7 # developments; (This policy links with WMP 18 Transport - Road, Rail and Water.)
WMP27 - Environment To protect and enhance the built and natural and Environmental environment including: Natural assets; Enhancement Biodiversity; Landscapes; Historic environment; Geology and geomorphology; 1 6 # Heritage assets; and Landscape character. (This policy also links with the policy about design of built facilities.)
WMP28a - Flood risk To ensure that flood risk and potential 0 1 # impacts on groundwater and water quality WMP28b - are taken into consideration in determining Groundwater and water waste and minerals development proposals. 0 2 # quality
Policy WMP2 - Minerals and Waste Development in the South Downs National Park
7.9 Parts of East Sussex, including Lewes, Midhurst and Petersfield, are located within The South Downs National Park. Policy WMP2 seeks to ensure that development is sustainable and appropriate to the purpose and duties of the South Downs National Park in accordance with the wider presumption in favour of sustainable development as outlined in WMP1.
7.10 WMP2 outlines the considerations taken into account with regards waste and minerals development within the National Park. The effectiveness of the policy is monitored through assessment of the levels of waste capacity and minerals extraction that have been permitted in the National Park within the monitoring period. Waste and Minerals Monitoring Report 2012/13 39
Overarching Strategy7
7.11 There has not been an increase in permitted waste capacity or minerals production within the National Park since the Plans adoption in February 2013. This is expected given the relatively recent adoption of the Plan and the time lag between waste and minerals permissions and implementations. 40 Waste and Minerals Monitoring Report 2012/13
8Providing for Waste 8 Providing for Waste
Waste in East Sussex
8.1 It is currently estimated that around 1.7 million tonnes of solid waste are handled in East Sussex and Brighton & Hove each year. The main types are:
Local Authority Collected Waste (LACW) - LACW is waste that is collected by local authorities, and it is estimated to make up about 21% of all wastes in the Plan Area. Household waste comprises approximately 95% of municipal waste, the remainder coming from sources such as street sweepings and public parks and gardens. Commercial and Industrial Waste (C&I) - This is produced from shops, food outlets, businesses, and manufacturing activities and comprises about 27% of wastes in the Plan area. Construction, Demolition and Excavation Waste (CDEW) - Produced from building activity, with a considerable proportion of it is considered to be inert. CDEW comprises an estimated 51% of all waste arisings. Other wastes - This includes hazardous waste, liquid waste (other than wastewater), and wastes arising from the agricultural sector. Although hazardous waste streams only make up approximately 1% of the total waste stream, they still need to be planned for and often require specialist treatment facilities and include stringent environmental controls.
Figure 3 Proportion of Solid Waste Arising in East Sussex and Brighton & Hove Waste and Minerals Monitoring Report 2012/13 41
Providing for Waste8
8.2 The County Council monitors the quantity of municipal waste but it does not directly monitor the quantity of commercial and industrial waste or construction, demolition and excavation waste arisings. No direct monitoring of C&I and CDEW waste management is undertaken but estimates of arisings can be derived from data provided by the Environment Agency and other surveys.
8.3 There are various facilities to treat and dispose of waste, including recycling centres, transfer stations, treatment sites and landfill sites. A list of current sites with planning permission for the management of waste in East Sussex and Brighton & Hove, together with their estimated capacities, is provided in Appendix H. 8.1 Local Authority Collected Waste
Arisings
8.4 Municipal waste arisings and management for the Plan Area for the years 2003/04 to 2011/13 are shown in Figure 3 below.
Figure 4 Municipal Waste Arisings and Management for the Plan Area 2006/07 - 2012/13
8.5 Municipal and household waste arisings are at their lowest level since combined data for East Sussex and Brighton & Hove was first available in 2003/04. The economic downturn is likely to be continuing to depress levels of arisings(14). Campaigns and media coverage aimed at reducing waste and a wider awareness amongst the public of the need to minimise waste are likely to be continuing to have an effect. In addition, the County Council’s Permit Scheme for reducing the amount of commercial waste being deposited at household waste sites remains in operation.
14 Historically there has been a relationship between economic growth and growth in waste arisings. 42 Waste and Minerals Monitoring Report 2012/13
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8.6 Over the long term municipal waste arisings are still expected to grow with increased population and number of households. Any return to significant economic growth may also have an impact. The County Council has identified a number of possible scenarios for future municipal waste growth, and current estimates suggest that the level of municipal waste in future years will be between the range shown in Table 2(15).
Table 8 Estimated Future Arisings for LACW
Year Min Growth Max Growth 2015/16 361,000 392,000 2020/21 356,000 414,000 2025/26 352,000 437,000
Management
8.7 Tables 9 and 10 on the following pages, together with Figure 5 above, show the total municipal and household waste arisings in East Sussex and Brighton & Hove by management approach and the percentage for each management type over the last five years(16).
8.8 Table 9 shows that the proportions of municipal waste by each management type remained broadly similar to those in 2010/11 with regards to reuse, recycling and composting. But there was a significant increase in the amount of waste being diverted to energy recovery. This is due to the Newhaven ERF coming on stream. This facility also allows waste previously exported to ERFs and landfills in neighbouring areas to be treated within the County's boundaries and reduce the considerable distance it currently travels by road.
8.9 There are currently no non-inert landfills operating or proposed for development within the Plan Area.
Table 9 Local Authority Collected Waste in East Sussex and Brighton & Hove (tonnes)
2008/09 2009/10 2010/11 2011/12 2012/13
Recycled 80,463 (22%) 77,993(21%) 77,845 (21%) 74,285 (21%) 72,513 (20%)
Reuse 9,714 (3%) 8,659 (2%) 6,938 (2%) 7,300 (3%) 9,917 (3%)
Composted 37,027 (10%) 41,340 (11%) 43,940 (12%) 48,279 (13%) 48,461 (13%)
Energy 73,806 (20%) 96,198 (26%) 89,917 (25%) 155,504 (43%) 206,625 (57%) Recovery
Disposal to 170,135 (46%) 142,554 (39%) 147,100 (40%) 74,623 (21%) 22,163 (6%) Land
Total 371,145 366,744 365,741 359,991 359,690
15 For further information see: 'Information Paper 1' (June 2012) available at http://consult.eastsussex.gov.uk 16 The Waste Local Plan definition of recovery includes recycling, reuse and composting as well as energy recovery Waste and Minerals Monitoring Report 2012/13 43
Providing for Waste8
Table 10 Household Waste Arisings in East Sussex and Brighton & Hove (tonnes)
2008/09 2009/10 2010/11 2011/12 2012/13
Recycled 80,463 (23%) 76,899 (22%) 76,740 (22%) 73,248 (21%) 70,685 (21%) (17) Reused N/A N/A 1,480 (0.4%) 2,111 (1%) 1,052 (<1%)
Composted 37,027 (10%) 41,010 (12%) 43,542 (12%) 47,856 (14%) 48,025 (14%)
Energy 73,806 (21%) 96,198 (28%) 89,917 (26%) 153,670 (45%) 201,950 (59%) Recovery
Disposal to 161,435 (46%) 134,107 (39%) 136,910 (39%) 65,497 (19%) 18,787 (6%) Land
Total 352,731 348,214 348,590 342,382 340,498
8.2 Commercial & Industrial Waste
Arisings
8.10 Accurate records of total C&I waste arisings are very difficult to obtain. As reported in the Annual Monitoring Report for 2010/11 the 'AEA Review of Future Waste Management Capacity Requirements - East Sussex and Brighton & Hove' concluded that the most reliable estimate of C&I Waste in 2008/09 was 475,000 tonnes, (this was based on an average of two approaches - the 'management approach' and the 'point of production'). This report also made predictions of the anticipated arisings which are reflected above. There has been no new information since the publication of that report. It is hoped that an updated estimate will be made available and reported in next years Monitoring Report.
Management
8.11 Accurate records of total C&I management methods are very difficult to obtain. As reported in the Annual Monitoring Report for 2010/11 the 'AEA Review of Future Waste Management Capacity Requirements - East Sussex and Brighton & Hove' concluded that the most reliable estimate of C&I Waste management methods in 2008/09 were: 67% material recycled and composted; 29% disposed to land; and 4% reused. This information is illustrated in the figure above. There has been no new information since the publication of that report, but, as stated above, it is hoped that an updated estimate will be made available and reported in next years Monitoring Report. 8.3 Construction, Demolition & Excavation Waste
Arisings
8.12 Information relating to CDEW has been very difficult to obtain. The 'AEA Review of Future Waste Management Capacity Requirements - East Sussex and Brighton & Hove' concluded that the most reliable estimate of CDE Waste arisings
17 Reuse of household waste was not recorded separately until 2010/11 44 Waste and Minerals Monitoring Report 2012/13
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in 2008/09 was 906,000 tonnes. This report also made predictions of the anticipated arisings. There has been no new information since the publication of that report. It is hoped that an updated estimate will be made available and reported in next years Monitoring Report.
Management
8.13 Information relating to CDEW has been very difficult to obtain. The 'AEA Review of Future Waste Management Capacity Requirements - East Sussex and Brighton & Hove' concluded that the most reliable estimate of CDE Waste management methods in 2008/09 were: 45% of all material being recycled; 15% being sent to landfill and the remainder (40%) being disposed of using alternative methods. Alternative methods include management of waste outside the recorded system such as reuse on site, use in small scale landscaping projects etc. There has been no new information since the publication of that report, but it is hoped that an updated estimate will be made available and reported in next years Monitoring Report. 8.4 Disposal to Land
8.14 There are times when waste can not be reused, recycled or recovered. This may be because there is insufficient capacity to recycle or recover the material, it may be uneconomical, or it may be impractical do to so. In these instances it must be disposed of to landfill or land-raise sites, collectively known as land-disposal. The information below illustrates where waste produced in the Plan Area, when destined for land disposal, is sent to. This information is based on Environment Agency data. It should be noted that unlike the information elsewhere in this document this data is based on the calendar year 1 January to 31 December, and not the financial year 1 April to 31 March.
Figure 5 Destination of waste from East Sussex and Brighton & Hove destined for land disposal by year. (Sites receiving 1,000 tonnes or more in any single year only)
8.15 Location of land disposal sites listed above: Waste and Minerals Monitoring Report 2012/13 45
Providing for Waste8
Greatness Quarry - Kent Redhill - Surrey Lidsey - West Sussex Brookhurst Wood - West Sussex Beddingham - East Sussex (closed) Pebsham - East Sussex (closed in 2013) Horton - West Sussex 8.5 Waste Management Capacity
8.16 The current total capacity provided by facilities managing waste in the Plan Area is set out in Table 11 below. This table identifies different types of activity which represent the key differences between the ways in which waste is managed. It includes facilities that are operating or currently not operating, but could be re-opened. It includes all facilities with planning permission, but excludes those which have closed permanently.
Table 11 Waste Management Capacity
Type of Activity Total Capacity (as Total Capacity as of Total Capacity as of quoted in the Waste 01/04/2012 01/04/2013 and Minerals Plan) (tonnes per annum) (tonnes per annum)
Recycling & Composting 490,000 502,320 545,335
Bulk Metal (e.g. Scrapyards) 441,000 440,323 440,323
Recovery 210,000 210,000 210,000
CDEW Recycling 630,000 648,995 669,278
Specialist Treatment (Hazardous) 61,000 71,429 71,429
Inert Landfill (including inert for 15,000 15,000 57,620 beneficial use WMP8b)
Non-Hazardous (including Stable 150,000 150,000 30,000 Non-Reactive Hazardous Wastes) (total void space in cubic metres)
Hazardous Landfill 0 0 0
8.17 Specialist Treatment are facilities that only take a very specific type of waste that must be dealt with in a specialised way. Examples in the East Sussex and Brighton & Hove area are plasterboard recycling, oil recycling and waste solvent recovery. 46 Waste and Minerals Monitoring Report 2012/13
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New Waste Management Capacity
8.18 Details of planning permissions granted within the monitoring period which provide new waste management capacity are shown in Table 12 below. In many cases there is limited information available regarding capacity, however Appendix J provides a summary of the permitted waste management capacity in East Sussex and Brighton & Hove.
Table 12 Planning Permissions Granted for New Waste Management Capacity in the Monitoring Period (1 April 2012 to 31 March 2013)
Site Planning Permission Details New Throughput Capacity (tpa) (if known)
Golf Course Farm, South Road, Creation of a lake including the construction 5,000 tonnes (inert for Wivelsfield Green, RH17 7QS. of a bund using imported waste soils. beneficial use)
KSD Environmental Services Ltd, Change of use of existing building (B2/B8) to 50,000 tpa (recycling) Warehouse to rear of Reprodux a Materials Recycling Facility (MRF) - House, Beach Close, Newhaven. considered to be a waste management (sui generis) use.
Smart Waste Recycling Ltd Change of use to accommodate a waste 5,000 tpa (transfer) transfer station.
Shredded Neat, Units M & N, SM Change of use to a facility for the sorting, 2,000 tpa (recycling) Tidy Industrial Estate, Ditchling treatment, baling and transfer of waste Common, BN6 8SG. cardboard and paper.
British Gypsum Limited, Restoration of part of the former Ready Mixed 32,000 m3 soils (read as Robertsbridge Works, Mountfield, Concrete (RMC) site to locally occurring inert for beneficial use) Robertsbridge, TN32 5LA. habitats and landscape features through infilling with inert material and road imported soils over a temporary period.
Land at Hole Farm, Westfield Use of land for the importation, deposit, 10,000 tonnes (inert for Lane, Westfield, TN35 4SA. storage and processing of construction and beneficial use) demolition waste (including but not limited to concrete, rubble, soils, sub-soils, metal and plastics) (retrospective), together with the construction of a noise attenuat
Messens Farm, Potmans Lane, Construction of a new manege including raising 4,000 tonnes (inert for Bexhill-on-Sea, TN39 5JL. of ground levels using imported inert waste beneficial use) materials.
Broad Farm, North Street, Change of use to area for the storage, crushing 10,000 tpa (CDEW Hellingly, Hailsham, BN27 4DU and transfer of waste concrete. recycling)
Lower Mays Farm, The Street, Proposed infill of existing slurry lagoon using 1,620 m3 (inert for Selmeston, Polegate, BN26 6TU. imported inert soils. beneficial use)
Wealden Worms, land off Hourne Change of use of part of yard from mixed use 1,000 tpa (CDEW Lane, Steel Cross, Crowborough, for agriculture and worm farming, to a mixed recycling) TN6 2DZ. use for an inert waste processing facility, agriculture and worm farming. Waste and Minerals Monitoring Report 2012/13 47
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Progress on Major Waste Infrastructure
Waste Water Treatment Works & Sludge Recycling Centre, Peacehaven
8.19 Planning permission was issued on 23 October 2008 for a new Waste Water Treatment Works, Sludge Recycling Centre and associated infrastructure at Lower Hodden Farm, Peacehaven. The facility has been built and is now undergoing a commissioning process. It is anticipated to be completed in spring 2013. Once operational, it will provide significantly enhanced waste water treatment for the Brighton & Hove and Peacehaven catchment area, in line with the requirements of the Urban Waste Water Treatment Directive. 8.6 Policy Monitoring
Policy WMP3a - Promoting Waste Prevention, Re-use and Waste Awareness
8.20 Policy WMP3a seeks to minimise the amount of waste that is produced. Municipal waste arisings (now known as Local Authority Collected Waste, LACW) for the Plan Area in 2012/13 were approximately 359,700 tonnes, this total is similar to the previous year. Municipal and household waste arisings are still at their lowest level since combined data for East Sussex and Brighton & Hove was first made available in 2003/04. Since the publication of the last Monitoring Report, no new information has become available regarding the overall production of C&I and CDEW.
Policy WMP3b - Turning Waste into a Resource
8.21 The Plan aims to manage waste in accordance with the Waste Hierarchy. The Plan looks to minimise the amount of waste sent to landfill and maximise the amount of waste that is recycled and recovered. Policy WMP3b sets high targets for the recovery of waste.
8.22 The WMP has a target to recycle 45%, and recover 98% of LACW waste by 31 March 2016. At the end of the monitoring period the recycling rate (including reuse, recycling and composting) for the Plan Area was 36%; the overall recovery rate was 94%. These currently do not meet the 2016 targets. Since the publication of the last Monitoring Report, no new information has become available regarding the recycling and recovery rates of C&I and CDEW.
8.23 Approximately 57,000 tonnes of LACW and C&I waste was exported for land disposal at facilities outside of the Plan Area during 2012, (73,000 tonnes of waste was sent to landfill inside the Plan Area). The amount of LACW being sent to landfill has continued to fall since the end of 2011 due to the Newhaven Energy Recovery Facility becoming fully operational. This is an improvement on 2010 when approximately 300,000 tonnes was sent for land disposal outside the Plan Area. 48 Waste and Minerals Monitoring Report 2012/13
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Policy WMP3c - Production of Energy from Waste (EfW)
8.24 Policy WMP3c requires that recovery facilities maximise their recovery of energy in line with the EU Waste Framework Directive. The only energy from waste facility in the Plan Area is the Newhaven Energy Recovery Facility. This produces 19 megawatts of electricity and meets the requirements of this policy.
Policy WMP5 - Provision of Built Waste Facilities
8.25 Policy WMP5 contains the requirements for the amount of additional capacity that is required for the recycling and recovery of waste for the Plan Area. This takes into account the need to ensure net self sufficiency. By 2015/16 up to 80,000 tonnes of recycling capacity and between 60,000 and 200,000 tonnes of recovery capacity will be required.(18) The granting of planning permissions for waste management in the Plan Area helps to meet this requirement.
8.26 The total new permitted throughput capacity within the East Sussex and Brighton & Hove in the monitoring period is:
50,000 tpa in commercial and industrial waste recycling/composting.
21,000 tpa construction, demolition and excavation waste (CDEW) recycling/recovery;
Policy WMP7a - Sustainable Locations for Waste Development (Excluding Land Disposal)
8.27 Policy WMP7a sets out broad Areas of Focus in which waste facilities should be located. These relate to within or close to urban areas, good transport connections and outside designated areas such as the AONB and SDNP.
8.28 The majority of the capacity permitted (as set out above), was located within the Areas of Focus.
Policy WMP7b - More Detailed Criteria for Waste Development
8.29 Policy WMP7b provides additional guidance for potentially suitable sites. These include: industrial land; employment land; previously developed land; and land that was already in waste management uses. Policy WMP7b assists the development management decisions on new capacity.
Policy WMP8a - Land Disposal for Non-Inert Waste
8.30 Policy WMP8a sets strict criteria by which applications for land disposal for non-inert waste would be assessed. There have been no applications to establish new Non-Inert Landfill/ Landraise during the monitoring period.
18 Recycling capacity may be provided in place of recovery capacity. Waste and Minerals Monitoring Report 2012/13 49
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Policy WMP8b - Deposit of Inert Waste on Land for Beneficial Uses
8.31 During the monitoring period, permission was granted for 42,000 tonnes of inert material to be deposited on land for beneficial use. (32,000 of which is to be used as part of the restoration of the former Ready Mixed Concrete Plant at British Gypsum Limited, Robertsbridge Works.)
Other Waste Policies
8.32 The most appropriate method of monitoring some policies contained in the Plan will be by periodic review. In these reviews the policies will be assessed to see if they are being implemented as intended, and if there are any implications. The results of these reviews will be reported in future Monitoring Reports as they are undertaken. This applies to the following policies:
Policy WMP3d - Minimising and Managing Waste During Construction, Demolition and Excavation
Policy WMP3e - Waste Management in New Development in the Plan Area
Policy WMP8c - Management of Landfill Gas
Policy WMP9b - Low Level Radioactive Waste
Policy WMP9a - Hazardous Waste
Policy WMP10 - Management of Waste Water and Sewage Sludge
8.33 In addition the following Policy will be implemented as part of the Waste and Minerals Sites Plan, and will be monitored following it's adoption.
Policy WMP6 - Safeguarding Waste Sites 50 Waste and Minerals Monitoring Report 2012/13
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8.7 Waste Key Findings
Providing for Waste Key Findings:
The total percentage (94%) of municipal waste (LACW) being recycled (including composted) and recovered is just below the 2015/16 WMP target (98%). The amount of LACW being recycled (including composted) has not yet met the 2015/16 WMP targets; Annual municipal and household waste arisings remained virtually static in the monitoring period at 359,690 compared to last year's total of 359,991 tonnes; In 2012/13, 6% of LACW waste was sent for land disposal. This has decreased from 40% in 2010/11. In 2012 a total of 130,000 tonnes of waste was sent for land disposal. This was a reduction from 2010 when a total of 533,000 tonnes of waste was disposed to land. Waste and Minerals Monitoring Report 2012/13 51
Providing for Minerals9 9 Providing for Minerals
Minerals in East Sussex
9.1 The principal mineral deposits in East Sussex are aggregates (sand and gravel), clay, gypsum and chalk.
Gravel deposits are confined to the coastal areas and river valleys Clay is worked largely in the clay vale of the Low Weald. The South Downs National Park comprises an extensive area of chalk and some soft sand deposits. The largest deposit of gypsum in the United Kingdom is situated at Brightling/Robertsbridge.
9.2 A full list of minerals workings operational in East Sussex in 2012/2013 is provided in Appendix F
9.3 Ongoing mineral production is assessed through consideration of planning applications, continued monitoring of sites and the production of yearly Aggregates Monitoring Reports. Each of the Mineral Planning Authorities in England and Wales collates data from minerals sites and submits the results to the Department of Communities and Local Government, through the relevant Aggregate Working Party. Every four years the survey includes information on the destination of materials.
9.4 Mineral planning permissions are subject to periodic review either through Interim Development Order (IDO) process set out in the Planning and Compensation Act 1991, or through reviews of old minerals permissions (ROMP) granted after 1948 under the Environment Act 1995. The reviews provide for an opportunity to update conditions to provide additional environmental protection in regard to working arrangements and restoration proposals.
9.5 The Growth and Infrastructure Act 2013 has altered the ROMP process in that a minerals planning authority can now adopt their own relevant review dates rather than more rigid 15 yearly reviews. The change is intended to reduce the need for ROMP reviews where existing minerals planning conditions are judged by the Council to be satisfactory.
9.6 A list of permissions and the relevant review dates are included in Appendix I.
9.7 Local Aggregate Assessment
9.8 The National Planning Policy Framework (NPPF) states that mineral planning authorities should plan for a steady and adequate supply of aggregates by preparing a Local Aggregate Assessment (LAA) based on a rolling average of 10 years sales 52 Waste and Minerals Monitoring Report 2012/13
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data and other relevant local information, including an assessment of all supply options including marine dredged, secondary and recycled sources. Recent Government guidance states that LAAs should be included in AMRs.
9.9 The County Council's adopted LAA is therefore appended to this year's AMR. The main findings are detailed below. A substitute figure has been used rather than a rolling average of 10 years sales.
9.10 During preparation of the LAA, taking into account the Duty to Cooperate, consultation has been carried out with the Marine Management Organisation, the Minerals Products Association, Local Economic Partnerships, Natural England, neighbouring minerals planning authorities, and planning authorities covering the source areas for crushed rock imports. Draft Government guidance requires that a LAA should be submitted to the relevant Aggregate Working Party. The draft LAA was considered by the South East England Aggregate Working Party (SEEAWP) on 13 November 2013. The Aggregate Working Party supported the provision of land-won sand and gravel at 0.1mtpa in the LAA, noting that this was the figure in the Adopted Plan..
9.11 The main findings of the LAA are that a significant proportion of local consumption is derived from either marine dredged material, crushed rock or land won aggregates extracted from outside the Plan Area. Imports are conveyed by a combination of sea, road and rail. The Western end of the Plan area is very reliant on imports from West Sussex, particularly via marine wharves. Some marine supplies are also imported through East Sussex ports and an amount of land-won material is extracted from two sites in the Plan area. Secondary and recycled aggregates originating from within and outside the Plan area also contribute to local aggregate demand.
9.12 The LAA concludes that despite the Government guidance recommendations, basing the LAA on 10 years sales data would not be appropriate in this case. Data is too volatile because there are a very small number of production sites and therefore there have been major variations in sales figures from nothing to more substantial output. It is proposed to use the Apportionment figure in the Adopted WMP as a surrogate figure for sales. Using this figure, there is an adequate landbank which will be monitored over time.
9.13 3.5 The lack of a comprehensive land won resource in the County means that there is an expectation that marine imports will continue to be a major source for construction use in East Sussex. The LAA highlights the importance of safeguarding wharves in this respect.
9.14 The LAA also contains suggestions for future monitoring as a means of refining data for the LAA.. Consideration will be given to carrying out these surveys in the next monitoring year. For example, to obtain detailed data on the types and sources of aggregates used in East Sussex and Brighton & Hove, a survey of aggregate users (such as building contractors, tarmacadam producers) could be carried out. In carrying this out it could be useful to determine whether there is Waste and Minerals Monitoring Report 2012/13 53
Providing for Minerals9 likely to be enough of the right type and quality of aggregate in the future for particular uses. Trends in demand related to economic activity could also be monitored.
Assessing Performance of Minerals Policies
9.15 The Plan contains a number of policies which aim to deliver different mineral resources for the Plan period. Note, there are currently no operational chalk quarries in East Sussex and the Waste and Minerals Plan does not safeguard chalk resources as there is little demand for the material.
Policy WMP4 - Sustainable Provision of Minerals
9.16 This Policy requires sustainable use and production of minerals in the Plan Area using the minerals hierarchy, for example by promoting secondary and recycled materials. Information on secondary and recycled aggregates continues to be limited by constraints in national and local surveys although background work for the Waste and Minerals Plan indicates that at present the best estimate is 240,000 tonnes per annum (tpa) of recycled aggregate is produced in the Plan Area. Around 10,000 tonnes of waste bricks are produced per annum and around 58,000 tonnes of bottom ash are produced per annum from the Newhaven Energy Recovery Facility. This gives a total estimated figure of around 310,000tpa. Adding this to glass and tyre waste, the Authorities currently have capacity for 0.63 mtpa of CDEW recycling. Sites with planning permission to produce recycled aggregates in the Plan Area are detailed in the Appendices of this document.
Policy WMP11 - Provision of Aggregates
Much of the evidence required to monitor the implementation of WMP11 is found in the LAA discussed in the previous section and also appended to this document. Policy WMP11 maintains provision of land-won aggregates and a landbank of at least 7 years for the extraction of sand and gravel. Actual data on aggregates production is mainly confidential due to the small number of producers in the area. The Plan has used the Secretary of State's Proposed Modifications of Policy M3 of the South East Plan (March 2010) revised apportionment figure for the Plan Area of 100,000 tonnes per annum. Currently the apportionment and landbank requirement can still be met through the quarry at Stanton’s Farm and production at Lydd Quarry on the Kent border. The existing permissions for extraction adjacent to the proposed Dungeness to Pett Level Special Protected Area (SPA) and Ramsar site will be subject to a Review of Consent process once the designations have been confirmed.
9.17 Data is also limited for the assessment of landings of marine dredged aggregates and other imports. Imports of marine dredged aggregate to East Sussex ports have shown an overall decline in the last 10 years. There was a small upturn in 2007, but imports have fallen sharply since 2010. Crushed rock imports have 54 Waste and Minerals Monitoring Report 2012/13
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decreased since 2008 at Newhaven Port, and there are no figures available from 2010. Marine dredged imports into Shoreham Port as a whole increased between 2009 and 2011, and then fell slightly in 2012.
9.18 Marine aggregate reserves within the licensed area serving the South East region are substantial and the level of imports of crushed rock to the county is considered to be significant. Principal constraints on the level of marine landings are considered to be: the security of port access; channel and berth restrictions in relation to the current fleet; vessel availability and the level of investment in modern wharf infrastructure.
9.19 Crushed rock imports from outside the South East region (mainly Wales and Somerset) contribute a sizeable proportion of aggregates to the Plan area. These imports are transported by a mixture of sea, rail and road.
9.20 The expectation is that future imports of aggregates and marine dredged materials will continue to be a major source for construction use in East Sussex.
9.21 Non-aggregate minerals
9.22 Figure 6 below shows employment in the non-aggregate minerals industry in East Sussex has more than doubled between 2005 and 2011. (19)In the context of production in East Sussex, the term ‘non-aggregate minerals’ refers to chalk, clay, gypsum and hydrocarbons (oil and gas production).
Figure 6 Employment in Non-Aggregate Mineral Operations in East Sussex 2005-2010
Policy WMP12 - Provision of Gypsum
9.23 East Sussex is the only County in the South East to produce gypsum commercially and the Robertsbridge works are identified as having national importance.
19 Source: Mineral Extraction in Great Britain 2011-PA1007 Primary Production, ONS (2010 data is estimated) Waste and Minerals Monitoring Report 2012/13 55
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9.24 Policy WMP12 requires that reserves are maintained from the British Gypsum mine throughout the Plan period. The Gypsum mine at Robertsbridge has at least 20 years of reserves remaining.
9.25 The Brightling mine has a capacity to excavate some 1 million tonnes of gypsum per annum; however at present the mine is not worked to its full potential. In the past the material has been mainly exported from the site by road and used as an essential additive in the manufacture of Portland cement.
9.26 Plasterboard and related products are manufactured at Robertsbridge using mined gypsum, as well as imported natural gypsum imported from countries abroad and Desulphogypsum (DSG) from power stations in other areas in the UK. Typically, over 0.3 million tonnes of gypsum are imported to the site by rail.
9.27 In 2012 a planning permission was granted for a strategic DSG storage area and associated development for a period of 10 years at the site. An application for a review of mineral planning conditions has recently been approved (subsequent to the monitoring period in this Report).
Policy WMP13 - Provision of Clay
9.28 Continued production at existing brickworks is supported and Policy WMP13 safeguards and maintains sufficient supplies of clay for brick and tile manufacture. There are six operational clay sites within East Sussex. Figures for clay production fluctuate as material is stockpiled for working over many months.
9.29 Since 2005, the Council has recorded brick clay output and reserves via a yearly survey of clay workings in the County (although this has not taken place in the last 3 years). The data is currently too limited to reveal a definitive picture. Data from the Office of National Statistics confirms that clay production is stable, although some smaller sites are pooling physical resources.
9.30 Data for Figures 7 and 8 was collated by the Office of National Statistics (ONS) until 2009 but the way information was collected changed over the years making it difficult to make direct year on year comparisons. The ONS figures show a decline of around 8% year on year across the region and this has been used to estimate figures for East Sussex in 2008 and 2009. Figures for sales of clay in 2011 are confidential. 56 Waste and Minerals Monitoring Report 2012/13
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Figure 7 Clay Extraction 2004-2010*
9.31 Figure 7 shows that the production of clay remained relatively stable since 2005, following a drop of over 20,000 tonnes from 2004(20). Figure 8 below shows the decline in the consumption of clay between 2004 and 2009. The continued decline estimated for 2009 is taken from regional data.(21). Local evidence suggests that clay production in East Sussex is stable.
Figure 8 Consumption of clay 2005-2009
Policy WMP14 - Safeguarding Mineral Resources
9.32 Policy WMP14 sets out how minerals resources will be safeguarded from unnecessary sterilisation by alternative development. Safeguarding areas will be identified in the Waste and Minerals Sites Plan.
Policy WMP15 - Safeguarding Wharves and Railheads
20 PA1007 Primary Production, ONS 2005-2009.*Figures after 2008 are estimated from regional information due to lack of data 21 Source: East Sussex County Council. Waste and Minerals Monitoring Report 2012/13 57
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9.33 Policy WMP15 safeguards railheads, wharves and rail sidings for existing and future mineral imports, and in particular overall mineral wharf capacity in ports. Capacity and activity at existing wharves will be monitored, and information on rail imports at British Gypsum will also be sought through the preparation of the Waste and Minerals Sites Plan.
Policy WMP16 - Exploration for Oil and Gas
9.34 Policy WMP16 provides a policy framework for any potential oil and gas exploration, appraisal and production. There is no commercial production of hydrocarbons in East Sussex, although several licences exist which allow exploratory research (subject to the necessary planning permission) by hydrocarbons operators. Considerable interest has arisen with regard to hydraulic fracturing (fracking) and further information has been published on the Council's website.
9.35 There is no commercial production of hydrocarbons in East Sussex, but several licences exist which allow exploratory research (subject to the necessary planning permission) by hydrocarbons operators. The 14th round of licensing will commence once the Department for Energy and Climate Change reviews the responses to the consultation on the Strategic Environmental Assessment it undertook in 2009/2010.
9.36 Chalk
9.37 Historic chalk workings in East Sussex included extraction for cement works. The cement industry declined during the 1960’s and 1970’s, with the last cement plant closing in 1975. Tarring Neville near Newhaven which produced small quantities of chalk for specialised use was the last active chalk site in the County. There are now no operational chalk quarries in East Sussex (and the South Downs).
9.38 There are no chalk sites in Brighton & Hove. Chalk is imported from West Sussex for use in small amounts for ongoing agricultural use and has been used in major road construction works (e.g. the A27 at Beddingham).
9.39 There is little demand for chalk in the county and chalk resources will not continue to be safeguarded by policies in the Waste and Minerals Plan. 58 Waste and Minerals Monitoring Report 2012/13
9Providing for Minerals
Key Findings - Minerals
Provision is made for the production of all minerals exploited commercially in East Sussex to support the local, regional and national economies, where the environmental implications are acceptable.
The County Council has adopted the first Local Aggregate Assessment for East Sussex, South Downs and Brighton & Hove
Secondary and Recycled Aggregates
Information on secondary and recycled aggregates continues to be limited by constraints in national and local surveys although background work for the Waste and Minerals Plan indicates that at present the best estimate is 240,000 tonnes per annum (tpa) of recycled aggregate is produced in the Plan Area.
Aggregate Imports and Marine Dredged Material
Imports of marine dredged and crushed rock material continue to make an important contribution to aggregate consumption in the Plan Area; Imports of marine dredged aggregate to East Sussex ports have shown an overall decline in the last 10 years. There was a small upturn in 2007, but imports have fallen sharply since 2010. Crushed rock imports decreased between 2008 and 2010 at Newhaven Port, and there are no figures available for 2011 and 2012. Marine dredged imports into Shoreham Port as a whole increased between 2009 and 2011, and then fell slightly in 2012. Measures to safeguard facilities dealing with aggregate imports are included in the adopted Waste and Minerals Plan, and will be taken forward through the Waste and Minerals Sites Plan.
Land Won Aggregates
The proposed provision for land won aggregates in the adopted WMP can be met; The proposed sub-regional apportionment for East Sussex and Brighton & Hove is 100,000 tonnes per annum This can be met through the current landbank The Waste and Minerals Plan seeks to maintain the provision to meet the sub regional apportionment, subject to local environmental testing. The Waste and Minerals Plan does not provide for a separate soft sand apportionment and the South Downs National Park Authority have commissioned research into the soft sand resource available across the whole National Park Area
Chalk Waste and Minerals Monitoring Report 2012/13 59
Providing for Minerals9
There continue to be no active working chalk quarries within the County. Most of the resource is within the South Downs National Park. There are no market or policy drivers that indicate this will change in the immediate future.
Clay
Clay continues to be extracted at the levels in accordance with policy;
Gypsum
Gypsum continues to be extracted at the levels in accordance with policy; 60 Waste and Minerals Monitoring Report 2012/13
10Overarching Policies 10 Overarching Policies
10.1 There are six overarching policies which apply to both waste and minerals development and development determined by other planning authorities:
Policy WMP17 - Restoration Policy WMP18 - Transport - Road, Rail and Water Policy WMP19 - Co-location of Complementary Facilities Policy WMP20 - Community Involvement and Benefits Policy WMP21 - Opportunities for Sustainable Waste Management and Minerals Production in Other Developments Policy WMP22 - Increased Operational Capacity within the Site Boundary of Existing Waste Facilities
10.2 The available data at the time of writing is not sufficient to effectively judge the performance of these policies since the Waste and Minerals Plan was adopted in February 2013. The policies shall therefore be monitored periodically and assessed to determine whether they are being implemented as intended. The results of these reviews shall be reported in future annual monitoring reports. Waste and Minerals Monitoring Report 2012/13 61
Development Management Polices11 11 Development Management Polices
11.1 There are nine development management policies within the Waste and Minerals Local Plan used to determine waste and minerals planning applications:
Policy WMP23a - Design Principles for Built Waste Facilities Policy WMP23b - Operation of Sites Policy WMP24a - Climate Change Policy WMP24b - Resource and Energy Use Policy WMP25 - General Amenity Policy WMP26 - Traffic Impacts Policy WMP27 - Environment and Environmental Enhancement Policy WMP28a - Flood Risk Policy WMP28b - Water Resources and Water Quality
11.2 These policies provide a local context and interpretation to national planning policy and are used as a suite of policies with which to determine planning applications. There is not enough data available at the time of writing, however, to assess the effectiveness of these polices given the plan's relatively recent adoption in February 2013. The effectiveness of these development management policies shall be periodically monitored and reported in future annual monitoring reports. This shall be done in accordance with Chapter 7 - Implementation and Monitoring, of the Waste and Minerals Local Plan. In addition to these it is also proposed to track the number of times each policy is used in decision making.
11.3 Feedback on the Development Management policies from officers has been generally positive so far, however, use of the term 'significant' in some policies with regards to assessing impact has been queried. Policies requiring an assessment of significance will therefore be carefully monitored to ensure they are appropriate.
11.4 The number of enforcement cases received is an indicator of policy effectiveness. The total waste enforcement caseload of the County Council stood at 17 outstanding cases at the end of the third quarter of 2013 which is considered relatively low. It is an increase of one compared to the third quarter 2012, and remains well below the peak of second quarter 2007 where 89 cases were outstanding. 62 Waste and Minerals Monitoring Report 2012/13
12Enforcement 12 Enforcement
12.1 The NPPF states that effective enforcement is important as a means of maintaining public confidence in the planning system. The County undertakes regular site monitoring, and investigates any enforcement cases it receives. Figure 9 below shows the total caseload of the Council’s enforcement team, as well as the number of cases received and resolved per quarter, since the start of 2004.
12.2 The number of cases outstanding has remained low, with the caseload standing at 17 in the third quarter of 2013. This remains well below the peak of 89 cases outstanding in the second quarter of 2007.
12.3 The general trend for the number of enforcement cases received in any given quarter, once allowing for seasonal variation, is in general conformity with that of the performance with the local economy. It is suggested that while there is more economic activity, there is a greater possibility for conflict between uses of land. Similarly, the number of minerals and waste planning applications appears to follow a similar trend albeit with a delay, as economic changes take time to impact on activity.
Emerging Trends - Inert Waste
12.4 As part of their regular duties the County Enforcement Officer undertakes inspections of waste sites and has regular discussions with local waste operators. It is emerging that smaller waste operators are having significant issues with the disposal of soil, which in one case lead to a Breach of Condition Notice being served.
12.5 The Enforcement Officer reports that the main issue is that there are no landfills in East Sussex taking soils. Others in surrounding counties will only take soils if the soils have been analysed, and the soil analysis report shows the soils to be uncontaminated. For skip companies with small quantities of soils arriving as part of a skip load of waste this would mean them testing each separate quantity of soil to prove that it is uncontaminated, with each soil analysis costing in the region of £175. Presently the cost of an 8 yard (builders) skip is approximately £200.These small operators cannot pass the cost of the soil analysis onto the customer and very often they don’t know that there is soil in the skip until after it has been returned to the operator and is emptied. As one operator pointed out they cannot hire a skip out to a customer and then tell the customer that they cannot put soil into the skip.
12.6 Large quantities of soils pose less of a problem because it is only one soil analysis test for the soil, once it has been proved to be uncontaminated there is then no issue. As a result small operators are increasingly stockpiling large amounts of soils on their sites. Waste and Minerals Monitoring Report 2012/13 63
Enforcement12
12.7 Additionally Waste Minimisation Plans for large developments are now no longer a requirement so there is nothing to limit the movement of soils from development sites, which will cause more pressure on the few sites that can legitimately accept soils
12.8 In contract to the small operators, larger skip companies appear to have sufficient office staff to chase possible locations to lawfully dispose of these soils by scanning planning permission and approaching landowners who have got these consents to take these soils to further their developments.
12.9 This trend will need to be monitored. 64 W
Figure 9 Enforcement Caseload in East Sussex 12 aste and Enforcement Miner als Monitoring Report 2012/13 Waste and Minerals Monitoring Report 2012/13 65
Monitoring Issues13 13 Monitoring Issues
13.1 There continues to be a lack of information for monitoring implementation in certain areas of the strategy and policies in the Waste and Minerals Plan.
13.2 With regard to minerals, producers are not compelled to provide information on production, reserves and future plans. Due to the small number of producers in the Plan Area, the Authorities, where requested, need to guarantee that any information received will remain confidential to protect commercial interests.
13.3 Obtaining an accurate record of non-municipal waste arisings is also difficult. However, work has been undertaken to establish more accurate data for the C&I and C&D waste streams. The results have been reported in section 8, but maintaining data accuracy remains a challenge, as described below.
13.4 Some information on waste movements is provided from ‘waste returns’ submitted by the waste industry (i.e. the operators of permitted waste facilities) to the Environment Agency. It is often difficult to pinpoint the origin of waste, which may be recorded several times as it passes through different waste facilities for bulking and/or sorting before it is finally recorded as being recovered or disposed of and this can lead to double counting. In an attempt to alleviate this problem, the Environment Agency is piloting a new 'Electronic Duty of Care' system from January 2011 to December 2014 which tracks waste movements digitally(22). It is hoped that in time this will enable much more accurate monitoring of non-municipal waste arisings and treatment methods. In addition, some waste is managed at sites where operators are exempt from the need to provide waste data.
13.5 Capacity figures for new waste facilities are recorded as new planning permissions are granted. However, where data is not submitted as part of a planning application, it may be necessary to request information. In any event, the issue of how to monitor increases in capacity resulting from new facilities or operational changes that do not require a separate planning permission, remains.
22 See www.environment-agency.gov.uk/aboutus/wfo/128930.aspx for more information. Waste and Minerals Monitoring Report 2012/13 66
Appendices Waste and Minerals Monitoring Report 2012/13 67 Structure of the Waste and Minerals Policy DocumentsA Appendix A: Structure of the Waste and Minerals Policy Documents
Figure 10 Waste and Minerals Local Plan Structure (Novemer 2012) 68 W Minerals B aste
Appendix B: Programme for the Waste and Minerals P and rogramme Development Scheme Miner als
Table 13 Programme for the Minerals and Waste Development Scheme (July 2011) Monitoring
Document Status Summary Chain of Conformity Consultation Publication of Date for Public Proposed date for
on draft proposed submission to examination adoption Development
Waste & submission SoS period Report Minerals Plandocument Waste and DPD Sets out the vision, objectives and strategy forGeneral conformity with theOctober - February - June 2012 October 2012 January 2013
Minerals Plan sustainable waste development and minerals South East Plan and nationalDecember March 2012 2012/13 production in the area, and will provide the PPSs. 2011 for policy framework for development control. Minerals Sites DPD Sets out the existing sites and commitments General conformity with theSpring 2014 Summer 2015 Late 2015 Spring 2016 Summer 2016 Development and any new site allocations for minerals South East Plan. Plan Document development the Sites DPD will be in conformity with Waste & Minerals Plan
Minerals DPD Shows on a geographical basis the application In conformity with Waste & N/a Summer 2015 Late 2015 Spring 2016 Summer 2016 W Proposals Map of the policies in the Minerals Development PlanMinerals Plan Scheme Document aste Waste Sites DPD Sets out the existing sites and commitments General conformity with theN/a Summer 2015 Late 2015 Spring 2016 Summer 2016 Development and any new site allocations for waste South East Plan. Plan Document development not covered in the Core Strategy Sites DPD will be in
conformity with Waste & and Minerals Plan
Waste Sites DPD Shows on a geographical basis the application In conformity with the WasteN/a Summer 2015 Late 2015 Spring 2016 Summer 2016 Proposals Map of the policies in the Waste Sites Development& Minerals Plan Plan Document Waste and Minerals Monitoring Report 2012/13 69 Municipal and Household Waste Arisings in East Sussex and Brighton & HoveC Appendix C: Municipal and Household Waste Arisings in East Sussex and Brighton & Hove
Table 14 Local Authority Collected Waste Arisings in East Sussex and Brighton & Hove (tonnes)
Authority 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 Recycled B&H 27,316 27,070 25,447 25,051 32,706 22,955 ES 53,792 53,393 52,546 52,793 50,579 47,730 Reused B&H 2,644 2,628 1,752 1,091 1,647 224 ES 7,542 7,086 6,906 5,848 5,652 828 Composted B&H 3,857 3,889 4,312 3,582 3,801 3,660 ES 29,454 33,138 37,028 40,358 44,479 44,364 Energy B&H 12,037 22,668 30,240 41,562 51,944 69,348 Recovery ES 25,937 51,138 65,958 48,355 103,560 132,601 Disposal to B&H 66,456 52,350 47,444 35,611 22,673 5,405 Land ES 152,480 117,785 95,111 111,488 51,950 13,382 Total B&H 112,310 108,605 109,195 106,897 103,771 101,592 Waste ES 269,305 262,540 257,549 258,843 256,220 238,906 Arisings
Table 15 Local Authority Collected Waste Arisings in East Sussex and Brighton & Hove (%)
Authority 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 Recycled B&H 24 25 23 23 23 23 ES 20 20 20 20 20 21 Reused B&H 2 2 2 1 2 1 ES 3 3 3 2 2 1 Composted B&H 3 4 4 3 4 4 ES 11 13 14 16 17 18 Energy B&H 11 21 28 39 50 51 Recovery ES 10 19 26 19 40 42 Disposal to B&H 59 48 43 33 22 21 Land ES 57 45 37 43 20 18 70 Waste and Minerals Monitoring Report 2012/13 CMunicipal and Household Waste Arisings in East Sussex and Brighton & Hove Table 16 Household Waste Arisings in East Sussex and Brighton & Hove (tonnes)
Authority 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 Recycled B&H 27,316 27,070 25,447 25,051 23,706 23,138 ES 53,792 53,393 51,452 51,689 49,541 49,375 Reused B&H N/a N/a N/a 286 901 2,811 ES N/a N/a N/a 1,194 1,210 7,105 Composted B&H 3,857 3,889 4,312 3,582 3,801 3,660 ES 29,454 33,138 36,698 39,960 44,055 44,812 Energy B&H 12,037 22,668 30,240 41,562 51,944 69,348 Recovery ES 25,937 51,138 65,958 48,355 101,727 137,277 Disposal to B&H 66,378 52,325 46,470 34,110 20,991 5,461 Land ES 144,223 109,110 87,637 102,800 44,506 16,702 Total B&H 109,587 105,952 106,470 104,592 101,342 104,418 ES 253,406 246,779 241,744 243,998 241,040 255,272
Table 17 Household Waste Arisings in East Sussex and Brighton & Hove (%)
Authority 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 Recycled B&H 25 26 24 24 23 22 ES 21 22 21 21 21 19 Reused B&H N/a N/a N/a 0.3 1 3 ES N/a N/a N/a 0.5 1 3 Composted B&H 4 4 4 3 4 4 ES 12 13 15 16 18 18 Energy B&H 11 21 28 40 51 66 Recovery ES 10 21 27 20 42 54 Disposal to B&H 61 49 44 33 21 5 Land ES 57 44 36 42 18 7 Waste and Minerals Monitoring Report 2012/13 71 Other Targets for the Management of LACWD Appendix D: Other Targets for the Management of LACW
D.1 European and national policies require increases in the proportion of waste from which we recover value through recycling, composting and recovery of energy and that the proportion of waste sent to landfill decreases.
D.2 The Waste and Minerals Plan includes challenging targets for recycling and other recovery of waste. These targets are considered achievable as a result of Government policy to reduce reliance on landfill especially using fiscal means, and, because there is a dearth of landfill capacity which is incentivising alternatives to disposal in the ground. Studies undertaken by the County Council have analysed the make up of material currently landfilled and the ability for these materials to be recovered.
D.3 The recycling and composting targets for Local Authority Collected Waste adopted in the Waste and Minerals Plan and other documents is set out in Table 14 below. Similarly, targets for recovery of Local Authority Collected Waste is set out in Table 15.
D.4 Work is underway to identify suitable sites for further waste management facilities. In the meantime, policies for strategic sites for waste recycling and recovery facilities in the Waste Local Plan have been saved to help guide development if early provision is proposed.
Table 18 Comparison of Local Authority Collected Waste Recycling and Composting Targets
Year Waste & ESCC Joint BHCC MWMS Waste Minerals Plan Waste Strategy Strategy 2007 2015/16 45% - 40% 45% 2020/21 50% 50% 45% 50% 2025/26 55% 60% - -
Table 19 Comparison of Local Authority Collected Waste Recovery Targets
Year Waste & ESCC Joint Waste B&HCC Waste Minerals Plan Strategy MWMS Strategy 2007 2015/16 98% - 95% 67% 2020/21 98% Recover 95% of 98% 75% residual waste after recycling 2025/26 98% - - - 72 Waste and Minerals Monitoring Report 2012/13 ESecondary and Recycled Aggregates Facilities in East Sussex and Brighton & Hove Appendix E: Secondary and Recycled Aggregates Facilities in East Sussex and Brighton & Hove
E.1 The current best estimate of secondary and recycled aggregates production in East Sussex and Brighton & Hove is 310,000 tonnes. This is based on an assessment of secondary and recycled aggregates produced as set out below.
Table 20 Recycled Aggregates CDEW Facilities in East Sussex and Brighton & Hove(23)
Operator Address R French & Sons Ltd Woodland House, Drury Lane, Ponswood Industrial Estate, Hastings Rabbit Skips North Quay Road, Newhaven MDJ Light Brothers Greystone Quarry, Southerham, Lewes A M Skip Hire Hazlebank, London Road, Maresfield Haulaway Ltd Premier House, Apex Way, Hailsham SITA Potts Marsh Industrial Estate, Eastbourne Road, Westham Skip-It Containers Gate 5, Basin Road South, Portslade Sussex Skips Unit 25, Cliffe Industrial Estate, Lewes G A Skips Ltd The Old Cement Works, South Heighton, Newhaven PJ Mini Skips Cophall Wood Recycling Centre, Hailsham Road (A22) , Polegate Greenacre Recycling Ltd 16 Tumulus Road, Saltdean, Brighton Links Waste Management Ninfield Road, Bexhill Beach Road, Newhaven Beach Road, Newhaven Unit 3 Cradle Hill Industrial Estate, Seaford Brett Concrete Brett Drive, Bexhill Pebsham Waste Recyclables Freshfield Road, Pebsham Newhaven Roadstone Ltd North Quay Road, Newhaven Sussex Waste Management Ltd Whitworth Road, St Leonards on Sea
23 Sites believed to produce secondary/recycled aggregates as at December 2013 Waste and Minerals Monitoring Report 2012/13 73 Secondary and Recycled Aggregates Facilities in East Sussex and Brighton & HoveE Operator Address Mr D Stone Down Barn farm, Bexhill on Sea Mr Whitaker Unit 3, Cradle Hill Industrial Estate
E.2 Some recycled aggregate is also produced by mobile crushing activities associated with demolition projects. The above facilities do not operate at full capacity and it is estimated that around 240,000 tonnes of recycled aggregate is produced from these sources and mobile crushers on demolition sites.
E.3 Additional recycled aggregate may also be produced from the sites listed below. However the use of the materials as replacement aggregate has not been verified.
Table 21 Recycled Aggregates (non CDEW) Facilities in East Sussex and Brighton & Hove
Operator Facility Quantity and type of material (tpa) Wealden District Council Unit 19 Bellbrook Glass Industrial Estate Veolia ES Ltd Hollingdean MRF and WTS Glass Southern Tyre and Rubber Tyres Recycling Ltd
E.4 In addition, it is estimated that 68,000 tonnes of secondary aggregate are produced from the sources listed below.
Table 22 Secondary Aggregates Facilities in East Sussex and Brighton & Hove
Operator Facility Quantity and type of material (tpa) Ibstock Ltd Ashdown Brickworks Reject bricks - 10,000 Veolia E S Ltd Newhaven ERF Incinerator Bottom Ash - 58,000
E.5 The above facilities provide capacity for 630,000 tonnes of capacity for recycling Construction, Demolition and Excavation waste. 74 Waste and Minerals Monitoring Report 2012/13 FPermitted Mineral Workings in East Sussex 2012/13 Appendix F: Permitted Mineral Workings in East Sussex 2012/13
Table 23 Site Mineral Operational during AMR period? Stanton's Farm and Novington Building Sand No Sandpit, Plumpton Scotney Court, Lydd Sand and gravel Yes Nook Beach, Rye Sand and gravel No - inactive Scotney Court extension / Wall Sand and gravel Yes Farm, Lydd Castle Water, Rye Sand and gravel No - dormant Rye Bay Foreshore Sand and gravel for sea No - permission ceases defence work to have effect Ashdown Brickworks Clay Yes Chailey Brickworks Clay Yes Hastings Brickworks Clay Yes Aldershaw Farm Clay Yes Horam Brickworks Clay No - not yet constructed Little Standard Hill Farm Clay No Hamsey Brickworks Clay No - dormant, brickworks closed Cuckmere Brickworks Clay No - dormant, brickworks closed Ludlay Brickworks Clay No - dormant, brickworks closed Brightling Mine / Robertsbridge Gypsum Yes works Tarring Neville Chalk No Meeching Quarry Chalk No North Quay, Newhaven (Berth 1) Aggregate wharf Yes North Quay, Newhaven, (Berth 2) Aggregate wharf No North Quay, Newhaven,(Berth 3) Aggregate wharf No North Quay, Newhaven (Berth 5) Aggregate wharf No Rastrums Wharf, Rye Aggregate wharf Yes Rye Wharf Aggregate wharf No Waste and Minerals Monitoring Report 2012/13 75 Permitted Waste Management Sites in East Sussex and Brighton & HoveG Appendix G: Permitted Waste Management Sites in East Sussex and Brighton & Hove
Table 24
Facility Name ESCC Type Description District Status 2012ID(1) X Y
1 Bridge Yard Scrap Yard Metal/ELV Facility 583900 113800 Rother Non-operational
3 Cripps Corner Depot Transfer Station taking Rother Non-operational 578300 120900 Non-Biodegradable Wastes
4 Fore Hill Incinerator 541000 104700 Lewes Non-operational
5 Former HIQ Building, Recycling (Metal) Wealden Non-operational 553533 129835 Crowborough
6 Land at Endeavour Works, Transfer Station taking Lewes Operational 545265 100824 Beach Road, Newhaven Non-Biodegradable Wastes
7 Little Exceat farm, South Inert Material Recycling / Recovery Lewes Non-operational 539575 116594 Chailey
8 Old Hamsey Brickworks Waste Water Treatment Works 539803 115849 Lewes Non-operational
9 Selmeston Auto Spares Metal/ELV Facility 544400 100500 Lewes Non-operational
10 Sheepcote Valley Physico-Chemical Treatment Brighton & Hove Non-operational 533878 104897 Facility
11 Skim Corner Transfer Station taking Lewes Non-operational 545000 115658 Non-Biodegradable Wastes
12 The Old Cement Works, Waste Transfer Station Lewes Non-operational 544896 103261 Newhaven
13 The Old Timber Yard Physical Treatment Facility 544660 102020 Lewes Operational
14 Tidy Industrial Estate, Special Waste Transfer Station Lewes Non-operational 533900 118100 Ditchling
15 Unit H, Rich Industrial Estate Waste Transfer Station for Lewes Non-operational 545149 102107 Recyclates
16 Lorel Tree Farm Inert WMP7b 553028 133010 Wealden Non-operational
17 Units 1 & 2, North Crescent Metal/ELV Facility Wealden Non-operational Industrial Estate, Diplocks 558448 109276 Way, Hailsham
18 64 London Road Metal/ELV Facility 573900 107800 Rother Operational
19 Argyle Hall Metal/ELV Facility 530900 105600 Brighton & Hove Operational
20 Barcombe Water Treatment Physico-Chemical Treatment Lewes Operational 543900 114700 Works Facility
21 Beddingham Compost Facility Composting Facility 543500 106500 Lewes Operational
22 Boathouse Farm Composting Facility 544860 116290 Wealden Operational
23 Born Again Plastics Recycling (Plastics Baling) 534300 120900 Wealden Operational
24 Briardene Recycling Site (note says it's mostly Wealden Operational 557230 109708 rag recycling)
25 Bridge Yard, Five Acre Wood Metal/ELV Facility 583900 113600 Rother Operational
26 Brighton General Hospital Clinical Waste Transfer Station 532900 105100 Brighton & Hove Operational
27 Brighton HWRS Household Waste Amenity Site 533900 105000 Brighton & Hove Operational
28 Brighton Motorama Metal/ELV Facility 545030 101822 Lewes Operational 76 Waste and Minerals Monitoring Report 2012/13 GPermitted Waste Management Sites in East Sussex and Brighton & Hove
Facility Name ESCC Type Description District Status 2012ID(1) X Y
29 Bulverhythe Road, St Waste Transfer Station for Hastings Operational 577637 108567 Leonards Recyclates
30 Chamberlaines Lane Metal/ELV Facility 545900 112500 Lewes Operational
31 City Recycling Centre Special Waste Transfer Station 526446 104590 Brighton & Hove Operational
32 Cophall Wood Household, Commercial & Wealden Operational 557740 106820 Industrial Waste Transfer Station
33 Eastbourne Household Waste Household, Commercial & Industrial Eastbourne Operational 562200 100700 Site Waste Recycling & Transfer Station
34 Elmfield Metal/ELV Facility 560594 107686 Wealden Operational
35 Farningham Road HWRS, Household Waste Amenity Site Wealden Operational 553100 129400 Crowborough
36 Finmere Auto Spares Metal/ELV Facility 562300 100800 Eastbourne Operational
37 Forest Row HWRS Household, Commercial & Wealden Operational 542700 135150 Industrial Waste Transfer Station
38 G E Richardson & Sons Ltd Metal/ELV Facility 531100 105400 Brighton & Hove Operational
39 Greystone Quarry Household, Commercial & Lewes Operational Industrial Waste Transfer Station 543000 109100 & Metal / ELV Recyling
40 H Ripley & Co Metal/ELV Facility 558115 109115 Wealden Operational
41 Hole Farm Metal/ELV Facility 581300 113800 Rother Operational
42 Hailsham HWRS Household, Commercial & Wealden Operational 559632 108550 Industrial Waste Transfer Station
43 Happy Hunting Grounds Pet Crematorium 570300 111300 Wealden Operational
44 Haulaway Limited Household, Commercial & Wealden Operational 558115 109115 Industrial Waste Transfer Station
45 A M Skips, Hazelbank Household, Commercial & Wealden Operational 545902 125518 Industrial Waste Transfer Station
46 Hazelmere Metal/ELV Facility 563728 120099 Wealden Operational
47 Heathfield Depot Transfer Station taking Wealden Operational 559433 121965 Non-Biodegradable Wastes
48 Heathfield HWRS Household, Commercial & Wealden Operational 559300 122100 Industrial Waste Transfer Station
49 Heavenly Paws Pet Funeral Pet Crematorium Wealden Operational 557075 114499 Services
50 Hollingdean Depot Special Waste Transfer Station 531600 109000 Brighton & Hove Operational
51 Hollingdean Lane MRF Recycling 531600 105900 Brighton & Hove Operational
52 Hollingdean Lane WTS Material Recycling Treatment Brighton & Hove Operational 531600 105900 Facility
53 Hove HWRS Household Waste Amenity Site 528069 105770 Brighton & Hove Operational
54 Hove HWRS Special Waste Transfer Station 528069 105770 Brighton & Hove Operational
55 Kingspan Waste Recycling Household, Commercial & Brighton & Hove Operational 533140 107490 Industrial Waste Transfer Station
56 Lewes HWRS Household, Commercial & Lewes Operational 542300 109400 Industrial Waste Transfer Station
57 Links Waste Management Household, Commercial & Wealden Operational 571600 110900 Industrial Waste Transfer Station
58 Littlewood Metal/ELV Facility 557275 109768 Wealden Operational
59 Maresfield Camp Household Waste Recycling & Waste Wealden Operational 576900 108900 Transfer Station
60 Mile Oak Depot C&D Recycling 557729 104740 Wealden Operational
61 Millpond Depot A26, Household, Commercial & Wealden Operational 547177 123618 Maresfield Industrial Waste Transfer Station Waste and Minerals Monitoring Report 2012/13 77 Permitted Waste Management Sites in East Sussex and Brighton & HoveG
Facility Name ESCC Type Description District Status 2012ID(1) X Y
62 Mountfield HWRS Household, Commercial & Rother Operational 574600 119500 Industrial Waste Transfer Station
63 Newhaven ERF Energy Recovery Facility 544462 102267 Lewes Operational
64 Newhaven HWRS Household Waste Amenity Site 544090 101810 Lewes Operational
65 North Yard, Pennybridge Lane Waste Transfer Station 560075 128363 Wealden Operational
66 Peaceways Animal Incinerator Lewes Operational 548700 114800 Crematorium
67 Pebsham HWRS Household, Commercial & Rother Operational 576960 109040 Industrial Waste Transfer Station
68 Pebsham Landfill Site Co-Disposal Landfill Site 576940 109050 Rother Operational
69 Pebsham WTS Waste Transfer Station 576900 109800 Rother Operational
70 Picknell Green Specialist Treatment (Oil) 570627 108830 Rother Operational
71 Potts Marsh Household, Commercial & Wealden Operational 563700 103900 Industrial Waste Transfer Station
72 Ringmer Depot C&D Recycling 546200 113100 Lewes Operational
73 Rye Oil Ltd Specialist Treatment (Oil) 593100 119500 Rother Operational
74 Seaford Household Waste Site Household, Commercial & Lewes Operational 549700 100500 Industrial Waste Transfer Station
75 Sidley Depot Household, Commercial & Rother Operational 547022 108800 Industrial Waste Transfer Station
76 Southerham Wharf Metal/ELV Facility 544760 101820 Lewes Operational
77 Southern Tyre & Rubber Physical Treatment Facility / MRF Lewes Operational 545370 100570 Recycling Ltd
78 Sussex Skips Waste Transfer Station 542500 109500 Lewes Operational
79 The Platt Metal/ELV Facility 563800 120200 Wealden Operational
80 Uckfield Mobile Household Household, Commercial & Wealden Operational 547214 121240 Waste Management Facility Industrial Waste Transfer Station
81 Unit 18, Cliffe Industrial WEEE Storage and Treatment Lewes Operational 542660 109590 Estate Facility
82 Unit 19, Bellbrook Industrial Recycling Wealden Operational 546401 120590 Estate
83 Unit 19, Cliffe Industrial Recycling Lewes Operational 542600 109500 Estate
84 Martin James Waste, Unit 3, Transfer Station taking Lewes Operational 549664 100316 Cradle Hill Ind. Est, Seaford Non-Biodegradable Wastes
85 Unit A, Roebuck Centre Metal/ELV Facility 582580 109670 Hastings Operational
96 Units 2G/H, Hawthorn Estate, Transfer Station taking Lewes Operational Avis Way Industrial Area, The Non-Biodegradable Wastes 551400 102100 Drove, Newhaven
87 Wadhurst HWRS Household, Commercial & Wealden Operational 561800 133100 Industrial Waste Transfer Station
88 Waterhall Valley Burn Site Incinerator 528500 109310 Brighton & Hove Operational
89 Wellington Road Metal/ELV Facility 526100 104900 Brighton & Hove Operational
90 Whitworth Road, St. Leonards Transfer Station taking Hastings Operational 579459 113122 Non-Biodegradable Wastes
91 Woodland Centre, Chiddingley Composting Facility 553124 113459 Wealden Operational
92 Woodland House Household, Commercial & Hastings Operational 579280 110780 Industrial Waste Transfer Station
93 British Gypsum Specialist Treatment (Plasterboard) 572692 119731 Operational
94 Church Farm, Chalvington Composting Facility 551891 109189 Wealden Operational 78 Waste and Minerals Monitoring Report 2012/13 GPermitted Waste Management Sites in East Sussex and Brighton & Hove
Facility Name ESCC Type Description District Status 2012ID(1) X Y
95 Newhaven ERF, Rail Transfer Railhead / Waste Transfer Station Lewes Operational 544653 102211 - ERF IBA Only
97 Kingston Transport Waste Transfer Station Lewes Operational 544788 101646 (Newhaven)
98 Environmental Tyres Recycling (Pastics) 534129 118304 Lewes Operational
99 Beddingham Landfill Site Non-Haz Landfill 543764 106395 Lewes Restoration
100 Eastbourne District Hospital Specialist Treatment (Clinlical Eastbourne Operational 560259 101064 Waste)
101 Hove H W S & Transfer Station HWRC & Transfer Station 528154 105809 Brighton & Hove Operational
102 Newhaven Roadstone Ltd Inert Material Recycling / Recovery 544773 101596 Lewes Operational
103 Unit F, Rich Industrial Estate Waste Transfer Station (Asbestos Lewes Operational 545165 102077 Only)
105 Messens Farm Inert Landfill for beneficial use 572006 111261 Wealden Operational
106 Woodland (Earthmoving). Inert Recycling Wealden Operational 557464 112682 Broad Farm
107 Lower Mays Farm Inert Landfill for beneficial use 551388 108439 Wealden Operational
108 Wealden Worms Inert Recycling 552725 132032 Wealden Operational
109 Smart Waste Recycling Transfer Station 545170 100872 Lewes Operational
110 KSD Environmental Services MRF Lewes Operational 545149 101053 Ltd, Newhaven
111 Golf Course Farm Inert Landfill for beneficial use 535487 119276 Lewes Operational
112 Unit 1, Brett Concrete Works Transfer Station 575984 107847 Rother Operational
113 Mr Bristow, Hole Farm Inert Recycling 581005 113840 Rother Operational
1. Sites that are closed are not included in this table. Appendix H: Permitting of Significant Waste Management Management Capacity in East Sussex 2006/7 - 2012/13 P Table 25 ermitting
Year Number of Throughput of received apps Number Approved Number Number pending at end of Significant Refused monitoring period Apps Received
2006/07 4 Recycling: 59,000tpa 6 2 4 Capacity
Transfer: 94,960tpa (110,000 tpa recycling, 121,000 tpa transfer) of 2006/7 2007/08 6 Recycling: 25,000tpa , Composting: 7 None 3 15,000tpa, Transfer: 1,860tpa, Landfill: Significant 122,270tpa, Peacehaven WWTW (25,000 tpa recycling, 5,820 transfer, (59,000tpa recycling, 122,270tpa
61,000 tpa composting, 210,000tpa landfill, Peacehaven WWTW) W aste
recovery, in and Miner - 2008/09 3 25,000tpa CDEW recycling, 6 (59,000tpa recycling, 122,270tpa None None East
landfill, Peacehaven WWTW, 25,000tpa 2012/13 CDEW recycling,) als Monitoring 2009/10 3 74,200tpa transfer 2 (56,200tpa transfer) None 1 Sussex W (18,000tpa transfer) Report aste
2010/11 3 5,260tpa recycling 4 None None 2012/13 H 79 80 W 2006/7 Management H
Year Number of Throughput of received apps Number Approved Number Number pending at end of aste
Significant Refused monitoring period P Apps and ermitting
Received Miner
Replacement Newhaven HWRS (5,260tpa recycling, 18,000tpa als
transfer) Monitoring - 2011/12 4 Recycling: 35000tpa, 4 None 1 2012/13 Report Transfer: 108,000tpa, (Recycling: 35000tpa, (22,500 tonnes of inert material required for restoration WMP8b) 2012/13
Inert material required for restoration Transfer: 108,000tpa, of Capacity (WMPB8): 23,000 tonnes (required after 1 Jan 2012) Inert material required for restoration (WMPB8): 23,000 tonnes (required Significant after 1 Jan 2012))
2012/13 4 Recycling: 50,000tpa 4 None 3
Inert Recycling: 21,000tpa (Increase Composting Capacity to
60,000 at Woodlands Centre; Inert in Inert Material required for beneficial use for beneficial use (WMP8b): 10,000 (WMP8b): 42,000 tonnes; Part C&I and part CDEW:25,000 tpa) East W aste H.1 Note: For consistency the figures presented here are the total throughput i.e. this includes the recycled / recovered / disposed of element and the transfer element. It only includes significant development, smaller permissions do not appear. Sussex Waste and Minerals Monitoring Report 2012/13 81
Review of Mineral PermissionsI Appendix I: Review of Mineral Permissions
I.1 The following table sets out the mineral permissions within East Sussex that will be subject to periodic review over the coming years.
Table 26
Reference Site Mineral Status Review dates MR/1 Filching Quarry Chalk Permission Decision Notice dated 31 October 1997. ceased to have Periodic Review application required by 31 effect October 2012 was not received so planning permission has ceased to have effect. MR/2/3/4 Nook Beach, Rye Sand and Inactive 3 sets of conditions exist covering parts of Harbour gravel the planning application site. Periodic Review application required by 29 July 2014.
MR/5 Novington Sandpit, Building sand(Related Periodic Review application received 11 April Plumpton application 2013. New set of conditions determined under LW/386/CM is reference SDNP/13/01933/ROMP on active). 09/10/13. Next review due 9 October 2028.
MR/6 British Gypsum, Gypsum Active Periodic Review application received by 26 Brightling and March 2013. New set of conditions Robertsbridge. determined under reference MR/16 on 10/09/2013. Next review due 9 September 2028. MR/7/8 Rye Bay Foreshore Sand and Permission Submission of an application for the Periodic gravel for seaceased to have Review was due by 29 May 2013 but none defences effect received. Permission ceases to have effect.
MR/9 Tarring Neville, Chalk Inactive - Periodic Review application received 15 July Newhaven subject to 2013. And a new set of conditions determined restoration. under reference MR/17 on 15/11/2013. It is anticipated that site will be restored prior to next ROMP review date.
MR/10 Ashdown Brickworks Clay Active Periodic Review application required by 27 May 2018. MR/11 Little Standard Hill Clay Inactive Implemented but inactive. Periodic Review Farm application required by 20 October 2018. MR/12 Sussex Bricks Clay Active Periodic Review application required by 11 December 2018. MR/13 Aldershaw Tiles Clay Active Periodic Review application required by 25 November 2024. MR/14 Chailey Brickworks Clay Active Periodic Review application required by 23 July 2025.
MR/15 Scotney Court (Lydd Sand and Active Periodic Review application required by 21 Quarry Area 10) gravel October 2026.
LW/386/CM Stanton's Farm, Building sandActive Planning permission LW/386/CM granted 20 Plumpton (includes October 2003, although commencement did Novington Sandpit) not take place until October 2006. This 82 Waste and Minerals Monitoring Report 2012/13
IReview of Mineral Permissions
Reference Site Mineral Status Review dates permission currently expires in October 2016, which would occur before a review of conditions which is due in 2018. IDO/1A Hamsey Brickworks Clay Dormant IDO registered. IDO/5B Meeching Quarry, Chalk Inactive Committee approved conditions for IDO Newhaven P/49/9 on 3 April 1995 but they were appealed and the appeal was held in abeyance pending the adoption of the Lewes Local Plan at that time. The appeal was withdrawn on 5 April 2004, the date when the conditions were ‘finally determined’ under IDO/5B. Therefore, the Periodic Review application is due by 5 April 2019. RR/362/CM Scotney Court Sand and Active Periodic Review application due by 17 August Extension & Wall Farmgravel 2017. (Areas 11 and 12) WD/307/CMHoram Brickworks Clay Extant and Periodic Review application due by 21 August implemented 2015. but inactive Ludlay Brickworks, Clay Dormant Berwick Cuckmere Brickworks, Clay Dormant Berwick
Castle Water, Rye Sand and Dormant Harbour gravel Waste and Minerals Monitoring Report 2012/13 83
Local Aggregate AssessmentJ Appendix J: Local Aggregate Assessment
Local Aggregate Assessment
East Sussex, South Downs and Brighton & Hove
Local Aggregate Assessment December 2013
East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 1
Introduction1 1 Introduction
1.1 This report is the Local Aggregate Assessment (LAA) for the mineral planning authorities of East Sussex County Council, Brighton & Hove City Council and part South Downs National Park Authority. This LAA is based on the Plan Area for the East Sussex, South Downs and Brighton & Hove Waste & Minerals Plan which was adopted in February 2013. The Plan Area covers the administrative area of East Sussex and Brighton & Hove including those parts that lie within the South Downs National Park.
1.2 The National Planning Policy Framework states that mineral planning authorities should plan for a steady and adequate supply of aggregates by preparing an annual LAA based on a rolling average of 10 years sales data and other relevant local information. The LAA should include an assessment of all supply options including land won, marine dredged, secondary and recycled sources.
1.3 The draft National Planning Practice Guidance indicates that a LAA should contain three elements:
a forecast of the demand for aggregates based on the rolling average of 10-years sales data and other relevant local information; an analysis of all aggregate supply options, as indicated by landbanks, mineral plan allocations and capacity data e.g. marine licences for marine aggregate extraction, recycled aggregates and the potential throughputs from wharves. This analysis should be informed by planning information, the aggregate industry and other bodies such as local enterprise partnerships; and an assessment of the balance between demand and supply, and the economic and environmental opportunities and constraints that might influence the situation. It should conclude if there is a shortage or a surplus of supply and, if the former, how this is being addressed
1.4 The National Planning Practice Guidance also gives further details on the aggregate supply options including:
recycled aggregates, including from construction, demolition and excavation waste; secondary aggregates, whose sources come from industrial wastes such as glass, incinerator bottom ash, railway ballast, and scrap tyres; and industrial and minerals by-products; marine aggregates from The Crown Estate. Information will cover the areas licensed by the Marine Management Organisation for marine sand and gravel dredging and, as they are prepared over time, Marine Plans. The Marine Policy Statement (MPS) is used as the overarching UK policy framework for the production of marine plans and in the absence of an adopted marine plan the MPS will inform decisions in the UK marine area.; 2 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
1Introduction
imports into and exports out of the minerals planning authority area. The minerals planning authority must capture the amount of aggregate that it is importing and exporting as part of its Assessment; and land-won resources, including landbanks and site specific allocations.
1.5 This LAA examines the information available, considers the current guidance on LAAs and identifies how this might be applied to the specific characteristics of the Plan Area. It should be noted that there are particular circumstances in this Plan Area that mean that it is difficult to prepare the LAA totally along the lines indicated in the National Planning Practice Guidance. For the Plan Area there are limited sites producing material in the Plan Area and therefore most production data is covered by confidentiality agreements. There are also major data gaps.
1.6 This LAA will therefore aim to meet the requirements of guidance as much as possible within these constraints. It will include information on the wider regional context, local information as far as possible and constraints relating to future provision, as well as identifying and attempting to fill data gaps identified above. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 3
Geology and mineral uses2 2 Geology and mineral uses
2.1 Geologically sand and gravel aggregate resources within the Plan Area are limited to relatively small outcrops of the sand in the Folkestone Beds, river gravels and foreshore deposits of sand and gravel. Sharp sand and gravel, and soft sand can have different uses. Sharp sand and gravel are primarily used for concreting purposes and this is an essential raw material for the construction industry. Building sand is largely used as fine aggregate in the production of concrete, mortars and asphalt. Both types of material can be used as fill. There are no sand and gravel reserves within the boundary of Brighton & Hove.
2.2 The Folkestone Beds comprise the uppermost division of the Lower Greensand and consist of loosely consolidated fine grained quartzose sands. The outcrop of the deposit is very limited consisting of a narrow strip in the western part of the Plan Area, running eastwards from Ditchling for a relatively short distance. The fine grained nature of the sand means it readily meets British Standards for mortar sand.
2.3 The foreshore resource comprises extensive storm beach deposits along the coast. The wedge shaped accumulations consist almost entirely of flint with only a small proportion of sand. The main areas are between Winchelsea Beach and Rye Harbour, and, the western part of Dungeness around Camber. The resource is mostly used in concreting.
2.4 Substantial marine aggregate resources lie along the South East coast and in the English Channel which are widely extracted under licence by several aggregate companies with landings made at numerous wharves in the region. There are some limited landings at Shoreham Harbour within Brighton & Hove on the border with West Sussex, and until recently, at Newhaven Port. Crushed rock from various sources is also landed at Shoreham, Newhaven and also Rye Port. Other wharves used for marine dredged material are within the Thames Estuary and Hampshire.
2.5 Marine aggregates can yield both sand and gravel. Marine dredged aggregates are mostly utilised for concreting purposes, whilst crushed rock of various types is used locally in an unprocessed form for road construction or subsequently processed for the manufacture of coated roadstone products.
2.6 There are no hard rock aggregate reserves in the Area. Chalk has been the subject of significant levels of quarrying in the past, notably for the cement industry and to produce lime mortar and agricultural lime. Chalk also has the potential to yield crushed rock aggregate fill. However, all chalk extraction operations have now ceased and chalk is unlikely to make anything other than a minor contribution to aggregate production in the area in the foreseeable future.
2.7 A geological plan is included at the end of this document. 4 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
3Demand 3 Demand
Past Demand
National & Regional Guidelines for Aggregates Provision in England 2005 to 2020
3.1 For the Plan Area "demand" is a difficult part of the LAA to determine. This is partly because the consumption picture cannot be ascertained with any certainty (see paragraphs below). The National Planning Practice Guidance states that the Government’s national and sub-national guidelines serve a purpose of providing individual minerals planning authorities, where they are having difficulty in obtaining data, with some understanding or context of the overall demand and possible sources that might be available.
3.2 The latest guidelines – National and Regional Guidelines for Aggregates Provision in England 2005 – 2020 - reflect the overall fall in national demand for aggregates and an increase in use of alternatives to primary aggregates, especially recycled construction and demolition waste. The guidelines are based on outputs from an econometric model of the relationship between construction and aggregate consumption to predict future aggregate need. The main driver of aggregates demand is construction activity, although the Government has recognised that the relationship between the two appeared to weaken in the 1990s. Also there may be changes in aggregate intensity of use for each type of construction. Additionally, the problem of insufficient recycled /alternative aggregate data remains.
National Infrastructure Plan
3.3 The Government published the National Infrastructure Plan in October 2010, outlining its vision for the future of UK economic infrastructure. The Plan contains major commitments for investment in important infrastructure projects, such as road and rail improvements. An infrastructure delivery update issued in March 2013 shows progress made on the top 40 priority investment areas. None of the identified projects are located in the East Sussex and Brighton & Hove area, but others in the region may well have had an effect on the demand for aggregates in the locality.
Past Sales as indicator
3.4 Using past sales data to assess demand is also problematic in the Plan Area. Data for previous extraction is largely confidential and so cannot be published. In addition, with so few sites local sales figures are subject to large production swings and therefore trends cannot be used as a general indicator of demand. For example, at Lydd Quarry up until 2011, production took place in Kent with no returns for East Sussex. Now extraction is all in East Sussex and the operator considers that about half of the aggregate raised is consumed in Kent. Similarly after some years of no soft sand returns, Novington sandpit started extraction in 2007. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 5
Demand3
Substitute local demand indicators
3.5 It must be assumed that as development has taken place in East Sussex and Brighton & Hove, net demand for constructional materials must have been met by a combination of land won aggregates, marine landings, imports and recycled and secondary aggregates.
3.6 Consumption data from the BGS indicates how much aggregate is used in the area and this can also assist in building up a picture of "local" demand. The latest available figures show that in 2009, the Plan Area consumed 80 000 tonnes of land -won sand and gravel, 618 000 tonnes marine sand and gravel, and 199 000 tonnes crushed rock giving a total of about 897 000 tonnes total primary aggregates. Production of recycled and secondary aggregates in 2009 could have been about 250,000 tonnes (see paragraph 4.20)
3.7 The land won sand and gravel in 2009 referred to above came almost entirely from outside the Plan Area. There is also limited destination data on past movements of marine and crushed rock imports. Given the likely economic limits on transporting aggregates by road (approximately 45 km or 30 miles – although this may increase) it is likely that the East of Plan Area is provided by sharp sand and gravel from Lydd quarry, marine landings and imports; and that the Western Area is served by marine and imports. It is assumed that for soft sand the Eastern end of the Plan area is served by imports; and that the Western area is served by Novington and imports.
3.8 It may be appropriate to consider locally derived figures such as construction rates of housing and major infrastructure projects over the last decade. Between 2002 and 2012 there were some 20 250 housing completions in East Sussex and Brighton & Hove. Major infrastructure projects which have been completed in the last 10 years include; Peacehaven Waste Water Treatment Works, Maresfield Woodlands in vessel composting site, Newhaven Energy Recovery Facility, The Keep, B&HA Stadium, Brighton Station developments, Amex House, Jubilee Library and surrounding area, City Park office development, Hollingdean waste facilities and the Royal Alex children’s hospital. Further details of previous housing and major developments in East Sussex and Brighton & Hove are set out in the Appendix A.
3.9 Another measure of demand could be the sources of aggregate used in the plan area. The MASS guidance states that MPAs "should have regard to the intended use of each source of aggregate. There are some uses e.g. Construction fill for which the source may not be important. However, for some uses, it will be necessary to ensure that the quality of the aggregate is appropriate and MPAs should plan accordingly". Some of this information is set out in the previous chapter "Geology and Minerals Uses". In order to obtain detailed data on the types and sources of aggregates used in East Sussex and Brighton & Hove, a survey of aggregate users (such as building contractors, tarmacadam producers) could be carried out. Consideration will be given to undertaking this next year as a means of refining data for the LAA. 6 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
3Demand
Future Demand
National & Regional Guidelines for Aggregates Provision in England 2005 to 2020
3.10 The forecasting model used to calculate the national and regional guidelines utilises predicted growth in gross value added in the construction sector to extend the input data up to 2020. Between 2000 and 2011, annual consumption was expected to increase by about 5%. Resulting rates of construction demand were then extrapolated. The results indicated a reduced demand for primary aggregates even though a growth in construction activity was envisaged.
3.11 These predictions now have to be treated with caution as there has been an ongoing economic downturn with the national economy almost flat. However, the Government is predicting a return to growth in the coming years.
3.12 A recent press release from the Minerals Product Association (26/7/13) states that "growth in second quarter aggregates markets reflects housebuilding improvement and suggests construction activity may be near the bottom of the downward cycle".
Forecast of Demand
3.13 As indicated above, a LAA for the Plan Area based on a rolling average of 10 years sales data is not considered appropriate. Over half of the 10 years period would be zero returns and the rest is a confidential figure due to individual sites being involved. The figure is too volatile and is not a good indicator of demand.
Other Relevant Local Information
3.14 The National Planning Practice Guidance indicates that a LAA could utilise other relevant local information. Details on the local economy are set out in Waste & Minerals Plan Information Paper 6 (Spatial Portrait of East Sussex, Brighton & Hove and the South Downs).
3.15 The level of planned infrastructure in the area can assist in assessing local demand for aggregates. Allocations in Local Plans and Infrastructure Development Plans (IDPs) can indicate future levels of local demand. Six major areas of development requiring new or revised infrastructure provision in the next few years are identified in the Brighton & Hove IDP February 2013. In addition, there are eight strategic Development Areas set out in the submission City Plan where large scale redevelopment is expected over the Plan Period (up to 2030). These developments and infrastructure (which include residential units) will require a supply of aggregates in their construction. Further details of possible allocations in Brighton & Hove are set out in the Appendix A. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 7
Demand3
3.16 An assessment of IDPs covering East Sussex specify a large range of services (including school and hospital provision, and leisure facilities) which may need constructional materials. There are also a number of employment allocations identified in East Sussex Local Plans. Further details are set out in the Appendix A.
3.17 Assessment of the level of housing development needed for the next 10 years or more can also help to indicate the level of demand locally for construction aggregates. At least 21 000 housing units are proposed in East Sussex from now and up to 2030. Details of possible housing allocations in Brighton & Hove are referred to above and set out in the Appendix A. It could be that given the current pressure for housing sites regionally there may be even more development forthcoming than identified in submitted/adopted plans. This could lead to a greater need for aggregates.
Previous Apportionment Figures for Land Won Aggregates
3.18 Land won aggregates extraction in the Plan Area has been patchy for many years. In terms of the more distant past, some beach deposits were extracted in the 1980s but ceased in 1991. There was some further activity followed by a period of no operational sharp sand and gravel sites before extraction commenced for a few years at Lydd Quarry near Camber. The position with soft sand was similar with small extraction followed by years of inactivity.
3.19 Consequently by the time of the South East Plan, the sub regional apportionment for the Plan Area based on average sales over the previous seven years period discounting years with highest and lowest sales was 10,000 tonnes per annum.
3.20 The Partial Review of Regional Spatial Strategy for the South East Policy M3 Primary land-won aggregates and sub regional apportionment proposed alternative apportionments. The Submitted Review in March 2009 identified special cases where the methodology should be modified and it was proposed that East Sussex’s apportionment should be limited to 0.1m tonnes per annum to reflect actual availability of resources and deliverability. The Examination in Public Panel noted that the previous RPG9 Panel had identified that East Sussex had very little remaining resource and had recommended a small apportionment. The Panel felt that there was no evidence to take a different view and the Panel agreed the apportionment should be capped at 0.1m tonnes per annum. The Secretary of State’s Proposed Changes to Policy M3 endorsed this finding, noting that 0.1m tonnes per annum reflected actual availability of resources.
3.21 Whilst the South East Plan has now been abolished, Mineral Planning Authorities have been previously recommended to use the figures from the consultation by the Secretary of State on Review of South East Plan Policy M3, published in 2010 as a starting point for provision, unless the planning authorities have new or different information and a robust evidence base. 8 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
3Demand
3.22 It should be noted that the National Planning Practice Guidance refers to apportionments by the Aggregates Working Party but this has not yet been undertaken by the South East England Aggregates Working Party.
Conclusion on Demand
3.23 Consumption of primary aggregates was about 897,000 tonnes in 2009 plus a possible consumption of 250,000 tonnes of recycled and secondary aggregates. Future demand rates will very much depend on the regional economy’s response to the recent downturn in economic activity and how intensively primary aggregates are used. Over the time period to 2026, the reduced economic activity anticipated in the immediate years is likely to be counterbalanced by increased activity in the latter period. It could therefore be a working assumption that on average, demand will most likely reflect the previous 10 years’ requirements.
3.24 The sources of aggregate are unlikely to change much in the short term and the current supply chains to consumption could be expected to fulfil demand for some years.
3.25 For the reasons stated in the Demand Section above, the forecast of primary land won aggregate demand for the Plan Area will not based on 10 years sales data. As a substitute it is proposed to use the apportionment figure of 0.1m tonnes per annum proposed in the Secretary of State’s Changes to Policy M3 of the South East Plan and utilised in the adopted Waste and Minerals Plan as the principal local indicator of demand.
3.26 As discussed in the past demand section, in order to assess the types of aggregates required in the future a survey of users may be carried out as a future refinement to the Local Aggregates Assessment. In particular, it could be useful to determine whether there is likely to be enough of the right type and quality of aggregate in the future for particular uses.
3.27 Trends in demand related to economic activity will also be monitored. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 9
Supply4 4 Supply
Previous Supply Sales
Land-won sales/production
4.1 A new permission for extraction of building sand at Novington sandpit (Stanton’s Farm) was granted in October 2003 and extraction started in September 2007 of a total reserve of approximately 380,000 tonnes of sand & gravel. The site is located in the South Downs National Park. Annual extraction figures over the last few years are unavailable due to confidentiality constraints. There is no extraction of soft sand currently taking place at the site.
4.2 There are also large scale permitted reserves in the far east of the County, around Scotney Court and Wall Farm. These two permissions, totalling approximately 4.1 million tonnes of sand & gravel, are part of a larger permission for Lydd Quarry which straddles Kent and East Sussex. Production started within East Sussex in 2011. These have been considered as long term allocations for East Sussex and Brighton & Hove.
4.3 Whilst production figures at Lydd Quarry have previously been subject to confidentiality the operator Brett has made information available to assist in the preparation of this Local Aggregate Assessment. The operator also considers that Lydd Quarry sales are split between East Sussex and Kent on an approximate 50/50 basis. However, the consumption data supplied by BGS for 2009 when Lydd Quarry operations were totally in Kent infers for that year, only 19% of sales were consumed in the Plan Area.
Year Sales Volume (Tonnes) 2003 336,016 2004 345,298 2005 290,565 2006 300,860 2007 311,797 2008 312,118 2009 359,745 2010 359,250 2011 199,032 2012 353,371
Table 1 10 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
4Supply
4.4 There are two sand and gravel sites with planning permission to the east of the County at Nook Beach (inactive) and Castle Water (dormant) which contain un-worked reserves. There are significant environmental constraints related to these two sites. Submission of an application for the review of conditions (known as ROMP application) at Nook Beach is due by the end of July 2014.
Marine imports–throughput and sources
4.5 There are three Ports within the Plan Area. The Ports of Shoreham (partial), Newhaven and Rye accommodate various minerals wharves as shown in Table 2:
Port No. of Wharves Active in monitoring period Shoreham 3 1 Newhaven 5 1 Rye 2 1
Table 2 Active Wharves in the Plan Area 2012
4.6 Table 3 below details figures from South East Regional reporting (and other sources) for landings of marine dredged sand and gravel for Rye and Newhaven ports over the last 12 years. (1) (2) 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 (3) (4) Sand 346 430 350 323 302 229 202 217 205 106 155 c 78 and Gravel (5) (6) Crushed 164 37 176 176 176 93 117 181 145 145 129 c n Rock East Sussex, Total 510 467 526 499 478 322 319 398 350 249 284 c N/a
Table 3 Aggregate Imports and Marine Dredged Material Landed at East Sussex Ports 2000-2011 / 000 tonnes South
1. estimated from regional data Downs 2. C =confidential/no return submitted
3. based on new data from NPMP and 4. Crown Estate 2012 5. based on new data from NPMP Brighton 6. n=no data available & Hove, Local Aggregate Assessment, Supply December 2013 4 11 12 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
4Supply
4.7 The following graph shows the figures set out in the previous table.
Picture 1 Aggregate Imports and Marine-Dredged Material
4.8 No returns were submitted for the AM2012 operators' survey for Newhaven and Rye Ports and therefore no data is available for 2012 from this source. However, new data from the Crown Estate for 2012 indicates that 78 691 tonnes of marine dredged material was imported at Newhaven. There appear to be no marine dredged imports at Rye in 2012. Using information from other sources than surveys can give a useful picture of overall trends. For example, data from the Crown Estate indicates that marine dredged imports went up between 2009 and 2010, but were down in 2011 at both Newhaven and Rye Ports. According to the Newhaven Port Masterplan (2012) crushed rock imports decreased between 2008 and 2010 at Newhaven Port.
4.9 The County Council has recently been advised of the closure of plant at Newhaven Port and that marine dredged aggregate imports have currently ceased from May 2013.
4.10 Fluctuations in the figures for Port landings can be partly accounted for by specific large scale projects in the Plan Area. For example, the figure for 2001 is markedly higher than for other years because of the main construction phase of the A27 Polegate By-Pass.
4.11 There are three wharves located at Shoreham Harbour that fall within the Brighton & Hove boundary. Historically, Shoreham Harbour data has been collected by West Sussex County Council, as the majority of the Port lies within West Sussex. The LAA is unable to publish landings figures just for the Brighton & Hove wharves due to the commercial sensitivity of releasing figures for one active wharf. However, regional information published by the Crown Estate indicate that the amount of marine dredged material imported into Shoreham Port as a whole East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 13
Supply4 increased between 2009 and 2011. For 2012, the total of marine dredged primary aggregates imported at Shoreham was 1 052 976 tonnes, representing a small decrease on the previous year.
4.12 Substantial deposits of sand and gravel exist on the seabed of the East England Channel (EEC) region and to a lesser extent the the South Coast region. The EEC has 6 production licences and dredging activity in these areas began in Autumn 2006. Material from the EEC is often destined for wharves on the River Thames, but some material is landed on the South Coast. Material from South coast licences is often landed at Shoreham Harbour(1).
4.13 Detailed statistics on delivery of marine dredged aggregates are set out in “The area involved – 15th annual report “by the Crown Estate and The British Marine Aggregate Producers Association. During 2012, 1.03% of the tonnage dredged from the EEC region (0.04mt) was delivered to the ports within the EEC region (which includes Newhaven), and 0.14% (0.005mt) was delivered to the South Coast (which includes Shoreham). During the same period, 62.44% of the tonnage dredged from the South Coast licences (2.27mt) was delivered to the South Coast, and 3.8% (0.14mt) was delivered to the EEC. In addition, the South Coast region also received amounts of marine dredged material from the Humber, East Coast, and Thames regions. The EEC also received a small amount of marine aggregate from the East Coast region licences.
Imports
4.14 Of the total 698 000 tonnes sand and gravel (land-won and marine) consumed in East Sussex and Brighton & Hove(2): 16% was supplied from East Sussex wharves (all marine dredged), around 70% was supplied from West Sussex (the majority being marine dredged) and around 10% was supplied from Kent. (Further details are set out in the Appendix B) However, it should be noted that as working at Lydd Quarry has progressed, the contribution from Kent has now ceased, and East Sussex is now supplying some land won aggregate to Kent.
4.15 Evidence gathered during the preparation of the Waste and Minerals Plan indicates that almost all aggregates imported into Newhaven Port are used within the Plan Area. Over half of the material imported at Rye is used for the East Sussex market. In 2011 over 60% of sand and gravel received on the Brighton & Hove side of Shoreham Port was used within the Plan Area. Mineral wharves located within West Sussex at Shoreham Port also serve markets in the Plan area.
4.16 BGS data for 2009 indicates that a small proportion of land won sand and gravel has been sourced from West Sussex. Some 18,000 tonnes was imported but confidentiality constraints mean that it is difficult to identify the type and origin of this material.
1 The Crown Estates Licences Summary of Statistics 2012 2 BGS from breakdown of figures in the "Collation of the results of the 2009 aggregate minerals survey for England and Wales" 14 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
4Supply
4.17 There are some sand and gravel workings in Kent on the southern boundary of Tonbridge and Malling based on the Medway Valley sandstone gravel deposits, for example at Stonecastle Farm. There is likely to be some cross boundary movement of these minerals. However, the majority of sand and gravel quarries in this area have been inactive during the recession, so the amounts of sand and gravel from Kent land-won sources destined for East Sussex is likely to be very small in current economic conditions(3).
4.18 Of the total 199 000 tonnes crushed rock consumed in East Sussex and Brighton & Hove(4): Somerset supplied between 60-65%, Conwy supplied between 20-25% of crushed rock imported through wharves. Some 8 % imports of crushed rock were sourced from outside England and Wales. Crushed rock is transported by a mixture of sea, rail, and road. Details of wharves are provided in paragraph 4.6 above. There are currently no aggregate railheads in the Plan Area but closeby are railheads at Crawley and Ardingly in West Sussex.
Secondary/Recycled Aggregates
4.19 The national survey (of the arisings and use of construction, demolition and excavation waste as aggregate in England 2007) provides figures for the whole region; however the response to the survey was too low to provide a county level figure. Evidence produced for the Waste and Minerals Plan confirmed the estimated levels of production set out in previous Annual Monitoring Report. (A list of sites identified in this process can be found in Appendix 7 of the Waste and Minerals Monitoring Report 2011/12).
4.20 The current best estimate of recycled aggregates production in the Plan Area is 240,000 tonnes. This is based on an assessment of recycled aggregates produced at recycled aggregate CDEW facilities in East Sussex and Brighton & Hove. Additional recycled aggregate may also be produced from non CDEW facilities in the Plan area (including sites processing waste glass and tyres). However the use of the materials as replacement aggregate has not been verified.
4.21 In addition, it is estimated that 68,000 tonnes of secondary aggregate are produced from two main sources : Ashdown Brickworks produces about 10 000 tpa of reject bricks and Newhaven Energy Recovery Facility creates about 58 000 tpa of incinerator bottom ash. The latter is exported by rail currently to Brentford for uses including as a road construction material.
4.22 Adding the above provision to glass and tyre waste management, the Plan Area has a capacity for 630,000 tonnes for recycling Construction, Demolition and Excavation Waste.
3 Kent County Council 4 BGS from breakdown of figures in the "Collation of the results of the 2009 aggregate minerals survey for England and Wales" East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 15
Supply4
Future Supply Options
Land-won
4.23 Remaining reserves at Novington sandpit are not known but there is no reason why future extraction could not continue to contribute to the demand for land-won aggregate in East Sussex and Brighton & Hove.
4.24 As indicated earlier , there are large scale permitted reserves in the far east of the County related to Lydd Quarry. There are two major extant planning permissions covering Scotney Court (Area 10) and Scotney Court Extension / Wall Farm (Area 11/12). As reported in the Waste and Minerals Annual Monitoring Report 2011/12, these amount to 3,980,000 tonnes of sand and gravel.
4.25 Planning permission for Scotney Court (Area 10) was granted in 1990 (ref RR/89/2294(CM)). It was anticipated that this planning permission would yield approximately 750,000 tonnes of sand and gravel. Subsequently in 2000, a further 44.5 hectares extension to the west known as Scotney Court Extension / Wall Farm (Area 11/12) was granted planning permission (RR/291/CM). This permission was amended in 2002 to clarify the date by which working would commence (RR/362/CM). The permissions were for the extraction of 3.23m tonnes of sand and gravel
4.26 Extraction commenced in Area 10 in 2011. The operator has mostly completed extraction in this area. Extraction started in Area 11 in January 2013. The operator has indicated that extraction rates are currently higher than expected. It is understood that there are market and business reasons behind their decision.
4.27 The Waste and Minerals Plan, adopted in February 2013, estimated that the extraction at Scotney Court Extension / Wall Farm could last until 2026. Natural England is proposing to extend the Special Protection Area and Ramsar designation covering Dungeness to Pett Level. These are currently candidate sites. This designation covers or is adjacent to all the sand and gravel resource in this part of the County (see paragraph 5.19). Natural England has concerns related to mineral extraction and the Waste and Minerals Plan has a note added, related to Areas 11 & 12 extraction rate, that the estimate is subject to a further Habitat Regulations Assessment. The next process with the opportunity for a hydrological assessment is the Review of Consents under Regulation 63 of the Conservation of Habitats and Species Regulations 2010. It is currently difficult to determine when this will be as DEFRA cannot confirm the timescale for formal designation of the Special Protection Area / Ramsar extension. The estimate for this permission providing supplies until 2026 was also based on the assumption of an average annual extraction rate of 270,000 tonnes.
4.28 Due to their inactive and dormant status and the significant development constraints affecting the Nook Beach and Castle Water sites, it is considered inappropriate to include their remaining reserves within the landbank. 16 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
4Supply
4.29 The Waste and Minerals Plan does not establish the need to identify any new aggregates sites in the Sites Plan. This is on the basis that the landbank requirements based on the Secretary of State’s Proposed Changes to Policy M3 apportionment (see paragraph 3.20) can be achieved through current planning permissions.
Marine
4.30 Although some of the older inshore beds are no longer worked, substantial marine aggregates remain along the South Coast and within the Eastern English Channel regions for the long term. Only a small fraction of the area licensed for extraction by the Department for Communities and Local Government(5) has been worked so far.
4.31 The Marine Management Organisation (MMO) predicts(6) a strong demand for marine aggregates into the foreseeable future as infrastructure in the South of England develops and land-based resources become increasingly constrained. The MMO has set out future scenarios for marine aggregates covering the next six years, and then for six to 20 years. These periods reflect the time frames required for marine dredging licensing renewal. In summary for the next six years:
Active marine aggregate extraction within Licensed areas is likely to remain fairly constant with some possible increase Licensed Areas may increase slightly Output is likely to increase slightly overall Production likely to be higher in the EEC than in the South Coast region Additional demand likely to arise due to climate change and sea level rise and hence beach replenishment
4.32 For the next 20 years the scenario is therefore similar but the increase in Licensed Areas could be partially offset by the surrender of some existing areas. As with the six year projection output is likely to be slightly higher than current levels but will be dependant on large-scale infrastructure projects and coastal defence works. The MMO considers that most marine aggregate regions could be a potential supply source for the Plan Area.
4.33 The Waste and Minerals Plan Policy WMP15 safeguards capacity for landing, processing and handling minerals at Shoreham, Newhaven and Rye Ports. Alternative use proposals would need to demonstrate no net loss of capacity and the mineral planning authorities expect to be consulted on any proposals for non minerals development.
4.34 There are currently several strategies being put forward by other organisations which concern the port areas at Shoreham, Rye and Newhaven. The Authorities will seek to ensure safeguarding of wharf capacity as part of any development at the ports.
5 Licences are now issued by the Marine Management Organisation on the behalf of the Secretary of State 6 South Plan Analytical Report (SPAR) South marine plan area evidence base, 2013 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 17
Supply4
4.35 Proposals for other uses at ports would need to demonstrate that sufficient alternative mineral wharf capacity (tonnage) is deliverable and available to meet needs in the Plan Area for the plan period before the Authorities would accede to alternative development of the site. Proposals for new residential, business or amenity development in proximity to aggregate wharves should be assessed to ensure the impact of existing operations is fully addressed. The safeguarding arrangements would apply to all existing permitted, planned and potential sites regardless of whether they are currently in use.
4.36 Brighton & Hove City Council, Adur District Council and West Sussex County Council are currently drafting a Joint Area Action Plan (JAAP) that will set out the future vision and development policies for the Shoreham Harbour regeneration area in order to guide investment and planning decisions. In October 2010 the Shoreham Port Authority adopted a Port Masterplan setting out the Port’s plans for future growth. The Masterplan has been subject to public consultation and was endorsed by the above three local authorities. Public consultation on the draft JAAP is due in Spring 2014. The Revised Draft Adur Local Plan has been published for consultation (until 7 November 2013).
4.37 Shoreham Port is partly within West Sussex, so landings at wharves in the West Sussex part may also help meet demand in the western part of the Plan Area. On that basis provision of equivalent capacity (tonnage) of minerals wharfage within either part of Shoreham Port may be acceptable subject to similar safeguarding by West Sussex County Council (WSCC) as Minerals Planning Authority. Future joint working by authorities on the JAAP will address these issues. Assessments of existing capacity at the Port as a whole are likely to be undertaken by the authorities in the near future. WSCC have recently commissioned a Wharves and Railhead Study which includes consideration of Shoreham Port.
4.38 Newhaven Port Authority published a Port Masterplan in January 2012. This plan expects to see aggregate imports to continue at North Quay over the short to medium term, and will encourage use of the wharves for aggregates. However, marine dredged aggregate imports ceased at the Port in May 2013 due to the closure of import facilities at Newhaven Imports are therefore now restricted to crushed rock from quarries in Cornwall, Wales, Ireland and France(7).
4.39 There is no information to suggest that imports at Rye Port could not continue.
4.40 With regard to crushed rock landings, the main concern relates to capacity at wharves (see above).
Imports
4.41 The limited imports of land won sand and gravel from West Sussex and Kent are expected to continue.
7 Newhaven Port Authority 18 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
4Supply
4.42 Imports of marine sand and gravel are also likely to continue as there is likely to be sufficient licenced capacity in the English Channel. Providing safeguarding of wharves is maintained at current capacity, supplies should still be able to reach the Plan Area market.
4.43 It is understood that the crushed rock capacity at quarries in Somerset and Conwy have sufficient permitted reserves at the quarries to ensure a steady and continual supply into the Plan Area.
Recycled / Secondary
4.44 There is no current evidence to suggest that the existing capacity for producing recycled and secondary aggregates will not be maintained. The amount of incinerator bottom ash arising from the Newhaven ERF is considered likely to remain constant. It is assumed therefore that facilities in the Plan Area will continue to contribute to aggregates supply in the area. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 19
Environmental constraints5 5 Environmental constraints
The Environment of the Plan Area
Land-won
5.1 Large parts of the Plan Area are subject to environmental constraints. Two thirds of the area is covered the South Downs National Park and the High Weald Area of Outstanding Natural Beauty together, and other tracts of land are also designated as being of international and national environmental importance.
5.2 A number of areas are designated for wildlife conservation. These include two Special Areas of Conservation (SACs) and five Special Protection Areas (SPAs) and one large Ramsar site at Pevensey Levels, with a further proposed Ramsar site near Rye. There are four National Nature Reserves and 25 Local Nature Reserves. National designations include 64 Sites of Special Scientific Interest (SSSIs)(8). There are two Regionally Important Geological sites and numerous Sites of Nature Conservation Importance (SNCIs). One sixth of the area of Brighton & Hove is covered by nature conservation designations. These areas need to be protected in order to maintain the rich and varied landscape character and biodiversity within the Plan Area.
5.3 The South Downs are formed by a line of hills and vales extending along the coast westwards from Eastbourne. It is a unique, open, rolling landscape dissected by major river valleys cut by the Ouse and Cuckmere. Limited quarrying of chalk for agricultural purposes is long established and has had a noticeable impact on the landscape, especially along the scarp slope and around Lewes. To the north of the chalk are the Greensand beds with the Folkestone Formation extending north west from Lewes in East Sussex, across West Sussex and into Hampshire. The area within East Sussex was previously outside the Sussex Downs AONB but it is now located within the South Downs National Park. The South Downs National Park Authority has undertaken a study to assess the potential resource across the Park and alternative sources outside the Park boundary.
5.4 The High Weald AONB is a landscape of rolling hills, scattered farmsteads, small woodlands, irregular-shaped fields, open heaths and ancient routeways. It also includes the Ashdown Forest. The High Weald covers much of the northern, central and eastern parts of the Plan area. It is a faulted structure comprising clays and sandstones (collectively known as the Hastings Beds). This varied and extensively eroded geology has produced an attractive and sensitive landscape, most of which is within the High Weald Area of Outstanding Natural Beauty.
5.5 The Low Weald is a gently undulating clay vale which separates the High Weald from the Chalk Downs to the south.
8 These are split into 391 separate units. 20 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
5Environmental constraints
5.6 The Coastal Marshes are located between Eastbourne and Bexhill, and in the Rye Bay/Camber area either side of the Rother estuary. Inundated by the sea in recent geological times, these areas comprise large flat sheets of alluvium, extending inland over the Pevensey Levels and Romney Marsh.
Environmental Constraints and minerals working
5.7 The Plan Area is therefore heavily affected by environmental constraints. Minerals can only be dug where they naturally occur, and given the exploitation that has already taken place, the very few places in the county where resources occur are constrained by environmental factors. Opportunities for new aggregate production areas will therefore be very challenging.
5.8 Even the current sites for extraction have had further recent environmental constraints emerge. Stanton's Farm Quarry which extracts from a limited exposure of the Folkestone Beds north-west of Lewes was not previously in the AONB, and is now located in the South Downs National Park. The current permission expires in 2015(9).
5.9 The working area at Lydd Quarry is covered by an SSSI (Dungeness, Romney Marsh and Rye Bay). Natural England is proposing to extend and promote an SPA and Ramsar designation covering Dungeness to Pett Level. (see paragraphs 4.26). The forthcoming Review of Consents will have to establish whether any of the Lydd Quarry development already permitted, would have a significant effect on the European site in view of the site’s conservation objectives.
5.10 The environmental impact of marine dredging is controlled and monitored by the Licensing system administered by the MMO. Effects of secondary aggregate production would be regulated by planning and permitting legislation and controls.
9 10 years after development commenced. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 21
Balance6 6 Balance
Balance between Supply and Demand
6.1 The adopted Waste and Minerals Plan’s approach to minerals is to make provision for a steady supply in accordance with National Policy, and to allow primary production where it is demonstrated the need cannot be met by sources of alternative materials and that there is evidence of viable resource.
6.2 The evidence base for the Waste and Minerals Plan examined the particular circumstances related to aggregates. The Plan Area needs a mixture of land won production, marine landings, imports and recycled & secondary aggregates. The Plan Area already has a significant reliance on the contribution from marine sources. This section looks at the balance between supply and demand across all sources and considers whether there will be any shift in dependency.
Land-won
6.3 The joint East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan (WMP) was adopted in February 2013. The aggregate policy (WMP11) in this Plan seeks to maintain provision for the production of land-won aggregates at a rate of 0.10 mtpa throughout the plan period and to maintain a landbank of at least 7 years of planning permissions. The Authorities considered at the time existing planning permissions provided this requirement up to 2026.
6.4 With regard to the landbank, the requirement over the 17 years of the Plan is 1.7m tonnes, which is more than met by the permissions at Lydd Quarry amounting to 3.98m tonnes.
6.5 In terms of future demand, as indicated in Section 3 above, the forecast of primary land won aggregate demand for all the Plan Area will not be based on sales data. As a substitute, it is intended to use as the principal indicator of demand the apportionment figure of 0.1m tonnes p.a. put forward in the Secretary of State’s Proposed Changes to Policy M3 and as utilised in the Adopted Waste and Minerals Plan.
6.6 It is essential that the position is monitored over time. If it turns out that the mineral reserves at Lydd Quarry are below estimates or that the rate of extraction is increased, then this scenario would alter the position.
6.7 The Adopted Waste and Minerals Plan includes a commitment that if it appears the provision for the production of land won aggregates is not being maintained, a specific review of Policy WMP11 will be carried out. The Waste and Minerals Plan further indicates that the review would cover the possibility of identifying further feasible reserves. The Plan states that if this is not possible, the Authorities will consider other options with adjoining Minerals Planning Authorities and the Marine Management Organisation. 22 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
6Balance
Marine Sources
6.8 As can be seen from paragraphs 4.30 – 4.32 above, substantial marine aggregates reserves exists along the South Coast. The picture here is that there is more than adequate supply and that there is a potential resource that could meet additional demand if land won sources were to be further depleted in the South East.
6.9 The principal constraint on the level of marine landings during the Plan period is therefore not considered to be the level of marine reserves, but the security of port access (loss of wharves to other uses), channel and berth restrictions, vessel availability and investment in modern wharf infrastructure. The British Marine Aggregate Producers Association (BMAPA) maintain that there is a long term future for smaller vessels to import to smaller wharves and local operators have indicated that this is the case in East Sussex.
6.10 The importation of crushed rock from the UK or further afield is limited by wharf capacity and market forces. As there is no availability of this material from within the Plan Area, landings directly reflect demand. Crushed rock can be landed to non-specialist wharves, improving flexibility within port areas(10).
6.11 According to the Port Authorities at Shoreham, Newhaven and Rye, sufficient wharf capacity apparently remains in the Plan Area to allow significant landings to continue for the foreseeable future. As spare capacity exists at the present time for marine and crushed rock landings (due to the inactive wharves at all Ports in the Plan area (see Table 1)), these established operations provide flexibility to deliver additional supplies should they be required to meet demand in peak years.
6.12 However, in order to maintain potential wharf capacity for the future it is essential that adequate safeguarding measures are in place to enable the authorities to respond to threats of redevelopment of wharves from alternative uses. Comprehensive safeguarding policy will be an important tool in achieving strategic provision of wharf capacity within the various emerging plans for ports in the plan are (see Supply chapter).
Imports
6.13 Again, with regards to marine imports, safeguarding wharves is key to the future security of landings. It is also crucial that rail import facilities are protected from redevelopment, even though these are currently located out of the Plan area. WMP Policy WMP15 seeks to safeguard existing, planned and potential railheads and minerals wharves, and to monitor the need for these facilities. Regional discussion will be required to secure rail and wharf facilities which contribute provision to the Plan Area. Positive dialogue with adjoining and more distant mineral planning authorities will also be needed to check and maintain security of
10 As the method of landing crushed rock is simpler than landing marine aggregates there is less attraction to move to larger vessels to reduce costs and crushed rock does not require specialist handing equipment. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 23
Balance6 supply of aggregates, particularly crushed rock. This should be enabled through good practice, aggregate working party arrangements and Duty to Cooperate requirements.
Recycled / Secondary
6.14 Secondary aggregates provide an alternative to primary aggregates, and subject to technological advancement, there is potential scope to substitute more recycled aggregates. Economic instruments such as the Landfill Tax have had a considerable impact on the level of material available, forcing previously landfilled CD&E waste to be processed into secondary aggregate.
6.15 There are moves to increase utilisation of alternative sources with a consequential increased contribution to total demand. However, the availability and utilisation rate remains unpredictable and substitution is not always possible. Primary resources will be required to a significant extent for the foreseeable future.
Overall Diagram
6.16 A diagrammatic plan is included at the end of this document which summarises the origin of locally won and produced aggregates, as well as the nature of imports into the Plan area. 24 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
7Conclusions 7 Conclusions
7.1 A significant proportion of local consumption is derived from either marine dredged material, crushed rock or land won aggregates extracted from outside the Plan Area. The lack of a comprehensive land won resource in the County means that there is an expectation that marine imports will continue to be a major source for construction use in East Sussex.
7.2 Land-won aggregates
Can’t use past 10 years sales data as this is too volatile because there is a very small number of production sites and therefore there has been major variations in sales figures from nothing to more substantial output We propose to use the Apportionment figure in the Adopted WMP as a surrogate figure for sales. Using Apportionment figure, we have an adequate landbank We will monitor over time the rate the landbank declines. This will be a consideration in a decision to review Policy WMP11 of the Waste and Minerals Plan.
7.3 Marine landings
Plan Area, especially the western end, is very dependent (80/85% in 2009) on marine landings Need to protect wharf capacity
Reasonable to plan on basis that marine licences will be maintained in future
7.4 Imports
Contribution from Kent up to 2009 now ceased. We are now supplying Kent Small contribution from West Sussex Railheads likely to continue Marine landings including crushed rock likely to continue
7.5 Recycled/secondary aggregates
Continuing contribution
7.6 Conclusions
Differently calculated LAA Short / medium term prospects secure Will monitor to appraise long term situation East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 25
Past and Future DevelopmentA Appendix A: Past and Future Development
Past Development
East Sussex
Between 2002 and 2012 there were some 14760 housing completions in East Sussex. There has been no major road infrastructure built in the past 10 years.
Over the last decade the following major infrastructure projects have been completed: Peacehaven Waste Water Treatment Works, Maresfield Woodlands in vessel composting site, Newhaven Energy Recovery Facility,
Brighton & Hove
Between 2002 and 2012 there were some 5490 housing completions in Brighton & Hove.
Major infrastructure projects that have taken place in Brighton & Hove over the last decade include The Keep, B&HA Stadium, Brighton Station developments, Amex House, Jubilee Library and surrounding area, City Park office development, Hollingdean waste facilities and the Royal Alex children’s hospital
Future development
East Sussex
Based on an assessment of Local Plans (at various stages up to adoption), there are a number of allocations for housing and employment in the East Sussex area which could involve construction aggregates in their development. The various allocations cover a period longer than 10 years (up to 2027 and 2031). Overall, at least 21 147 dwellings and 445 000 square metres of employment floorspace are proposed.
A review of Infrastructure Development Plans in the county highlights a number of projects in the short (the next 5 years) and medium (5-10 years) term. These include increased school, library, hospital and sports and leisure provision. Also identified are coast and flood protection, and sewerage improvements. Whilst the precise aggregate requirements for these developments are currently unknown, some sand and gravel material is likely to needed during constructional phases.
Some strategic road improvements in the county are planned including the Bexhill Hastings Link Road.
Brighton & Hove 26 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
APast and Future Development
Six major areas of development requiring new or revised infrastructure provision in the next few years are identified in the Brighton & Hove Infrastructure Development Plan February 2013. In addition there are eight strategic Development Areas set out in the submission City Plan where large scale redevelopment is expected over the Plan Period (up to 2030). These developments and infrastructure will require a supply of aggregates in their construction. These are:
Shoreham Harbour Development Area -Upgraded flood defence and essential on-site highways – if land uses change from current port water compatible uses Brighton Marina – flood defence measures City College - erection of an 8 storey College building of 12,056 sqm and ancillary accommodation (use class D1), erection of a 10 storey building of 12,647 sqm to provide 442 student residential units and ancillary accommodation with associated access, infrastructure; erection of up to 125 residential units (use class C3) (access, layout and scale). University of Sussex - Redevelopment of various buildings to provide new teaching and residential accommodation. Phased delivery from now until 2020. University of Brighton – new student accommodation Royal Sussex County Hospital - Expansion of health facilities at main hospital siteEastern Roadwith 74,000sqm net floorspace.
A summary of proposals for each is as follows:
DA1 Brighton Centre andChurchill Squarearea: Extension of Churchill Square to provide 20,000m2 retail floorspace. New Brighton Centre (25,000m2 conference centre) DA2 Brighton Marina, Gas works and Black rock: 1,940 residential units, 5000m2 retail, 2000m2 B1 floorspace, 10500m2 leisure and recreation floorspace, health facility, primary school DA3 Lewes Road: 810 residential units, 15600m2 employment floorspace, 16000m2 business school, 1300 student rooms, 5,000m2 B1 floorspace DA4 New England Quarter/London Road: 20,000m2 office floorspace, , 1185 residential units, 300 bed space student housing DA5 Eastern RoadandEdward Streetarea: 470 residential units, Hospital rebuild (see above), 400 bed student accommodation, 3,800m2 education floorspace, GP surgery, community building DA6 Hove Station area: 630 residential units, retention or replacement of 13,000m2 employment floorspace DA7 Toads Hole Valley: 700 residential units, 25,000m2 employment floorspace, new secondary school DA8 Shoreham Harbour: 400 residential units; 7500 m2 employment floorspace (within B&H part of the Harbour East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013 27
Imports into plan areaB Appendix B: Imports into plan area
Of the total 698 000 tonnes sand and gravel (land-won and marine) consumed in East Sussex and Brighton & Hove:(11)
16% was supplied from within East Sussex (100% of sand and gravel from East Sussex was marine-dredged and comprised 18% of total marine sand and gravel consumption).
70% was supplied from West Sussex (96% of sand and gravel from West Sussex was marine-dredged and comprised 77% of total marine sand and gravel consumption). 474 793 tonnes of marine sand and gravel landed in West Sussex was exported to East Sussex and Brighton and Hove. 18,074 tonnes of land won sand and gravel was imported from West Sussex(12).
About 10% was supplied from Kent (10% of sand and gravel from Kent was marine-dredged comprising 1% of marine sand and gravel consumption). In 2010 4% of all minerals imported into Kent and Medway by Dredger, Ship and Rail were exported to East Sussex(13). In descending order, Medway and Surrey each supplied between 1-5%. (All of that from Medway was marine dredged comprising 5% of total marine sand and gravel consumption). 3,011 tonnes of land-won sharp sand and gravel, and 102 tonnes of soft sand were exported by road from Surrey to East Sussex and Brighton & Hove in 2009(14).
In descending order, Hampshire, Greater London, Cambridgeshire and Oxfordshire each supplied less than 1%. (40% of that from Hampshire was marine-dredged and 100% of that from Greater London was marine dredged. Together these contributed the final 1% of marine-dredged aggregate). Note: Berkshire and Gloucestershire also supplied less than 1% each but tonnages from both sources are small as to represent only a (few) lorry load(s).
Of the total 199 000 tonnes crushed rock consumed in East Sussex and Brighton & Hove(15):
Somerset supplied between 60-65% , and 60% of this is received by rail (the remainder being by road). Conwy supplied between 20-25% (delivered by water and therefore will have been landed at a wharf) In descending order, Imports from ‘outside England and Wales’ and imports from Powys each supplied between 5-10%.
11 Data provided by BGS from breakdown of figures in the "Collation of the results of the 2009 aggregate minerals survey for England and Wales" 12 West Sussex County Council 13 Kent County Council 14 Surrey County Council 15 Data provided by BGS from breakdown of figures in the "Collation of the results of the 2009 aggregate minerals survey for England and Wales" 28 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2013
BImports into plan area
In descending order, West Sussex and Cumbria each supplied less than 1%. Note: In descending order, South Gloucestershire, Northumberland (inc Northumberland National Park) and Gloucestershire also supplied less than 1% each but the tonnages are small as to represent only a (few) lorry load(s). British Gypsum Mines )"^_ Scotney Court Farm Castle WaterScotney Court Extension and WXWall Farm Nook BeXYachXY XY *#Chailey Brickworks Rye Bay ForeshawXY Î *#Hamsey Brickworks *#Horam Brickworks Rye *#Aldershaw Far*#m Hastings Brickworks WX Stanton's Farm
*#Little Standard Hill Farm
*#Ashdown Brickworks Legend *#*#Ludlay Brickworks Cuckmere Brickworks )" Gypsum Mine *# Clay Green: operational facility Red: unimplemented permission or Î $+ Chalk dormant, inactive facility Shoreham Tarring Neville$+ Filching Quarry$+ ^_ WX Aggregates Site/Safeguarded Area Potential or Existing Railheads Meeching Quarry$+^_ ^_ Î Î Ports/Aggregate Wharves Newhaven Predominantly Chalk Predominantly Clay Predominantly Ashdown Formation Predominantly Greensand ¯ Predominantly Sandstone Hastings Beds Folkestone Formation South Downs National Park
Waste and Minerals Policy Team Planning Service - Transport & Environment East Sussex County Council PlanningCounty PolicyHall and Development Management PlanningSt Anne’s Service Crescent - Communities, Economy & Transport EastLewes Sussex County Council CountyEast Sussex Hall StBN7 Anne’s 1UE Crescent Lewes East01273 Sussex 481846 BN7 1UE 01273Planning 481 846 Strategy & Projects Brighton & Hove City Council PlanningHove Town Strategy Hall & Projects BrightonNorton Road& Hove City Council HoveHove Town Hall NortonEast Sussex Road HoveBN3 3BQ East01273 Sussex 292505 BN3 3BQ 01273 292 505
[email protected] http://consult.eastsussex.gov.uk
East Sussex County Council County Hall St Anne's Crescent Lewes BN7 1UE Phone: 0345 60 80 190 Fax: 01273 481 261 Website: eastsussex.gov.uk/contact us
December 2013
ISBN: 978-08-6147-535-3