Civil Engineers Structural Engineers Highways & Drainage Engineers Party Wall Surveyors Building Surveyors Expert Witness & Litigation Support
PLANNING STATEMENT
on:
PROPOSED AIRCRAFT RECYLING FACILITY, NORWICH AIRPORT, NORWICH.
for:
KLM UK ENGINEERING LIMITED LIBERATOR ROAD, NORWICH AIRPORT, NORWICH, NORFOLK, NR6 6ER
Managing Director: Peter French Bsc(Hons) CEng MICE Consultant: Anthony Canham CEng FICE FCIArb FAE Directors: Chris Dewick Julie Hannant MAAT Rob Panter CEng MIStructE Colin Taylor IEng AMIStructE Mark Bullen BEng (Hons) Vat No. 595 2587 90 Registered in England and Wales Company registration no. 2710417 Registered Office: Canham Consulting Limited, The Old School, School Lane, Thorpe St. Andrew, Norwich NR7 0EP
Proposed Aircraft Recycling Facility, Norwich Airport, Norwich Planning Statement 202257
Contents Amendment Record This report has been issued and amended as follows:
Rev Description Prepared Checked Approved Date
P1 Draft M Hughes B Wilkins B Wilkins 19/06/13 P2 Revised Text M Hughes B Wilkins B Wilkins 20/06/13 P3 Final Submitted M Hughes B Wilkins B Wilkins 21/06/13 P4 Revised Text M Hughes B Wilkins B Wilkins 12/07/13 P5 Final M Hughes B Wilkins B Wilkins 17/07/13 P6 Updated Final Report M Hughes B Wilkins B Wilkins 23/07/13
Canham Consulting Ltd The Old School School Lane Thorpe St. Andrew Norwich NR7 0EP
T 01603 430650 F 01603 430672 [email protected] www.canhamconsulting.co.uk Planning Statement – Aircraft Recycling Facility, Norwich Airport, Norwich July 2013 Issue P6 202257
CONTENTS 1 INTRODUCTION ...... 2 1.1 SITE LOCATION ...... 4 1.2 DESCRIPTION OF THE EXISTING SITE ...... 5 2 PROPOSED OPERATIONS ...... 6 2.1 PROPOSED DEVELOPMENT DETAILS ...... 7 2.2 CONSTRUCTION SPECIFICATION ...... 10 2.3 GEOGRAPHY, GEOLOGY AND HYDRO-GEOLOGY ...... 10 2.4 GROUND CONTAMINATION ...... 11 2.5 TRAFFIC AND ACCESS CONSIDERATIONS ...... 11 2.6 DRAINAGE AND POLLUTION PREVENTION ...... 12 3 PLANNING POLICY ...... 14 3.1 INTRODUCTION ...... 14 3.2 NATIONAL PLANNING POLICY ...... 14 3.2.1 NATIONAL PLANNING POLICY FRAMEWORK (NPPF) ...... 14 3.2.2 PLANNING POLICY STATEMENT 10 – WASTE PLANNING POLICY STATEMENT 16 3.2.3 WASTE STRATEGY 2007 ...... 17 3.3 REGIONAL PLANNING POLICY ...... 20 3.3.1 CORE STRATEGY AND MINERALS AND WASTE DEVELOPMENT MANAGEMENT POLICIES DEVELOPMENT PLAN DOCUMENT ...... 20 3.4 LOCAL PLANNING POLICY ...... 24 3.4.1 JOINT CORE STRATEGY ...... 24 3.4.2 NORWICH CITY COUNCIL REPLACEMENT LOCAL PLAN (2004) ...... 27 3.4.3 BROADLAND DISTRICT LOCAL PLAN (REPLACEMENT, 2006) ...... 29 3.5 SUMMARY ...... 30 4 SUMMARY AND CONCLUSION ...... 31
Appendices
Appendix A - EIA Screening Opinion
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1 INTRODUCTION
KLM UK Engineering Limited are proposing to provide a facility at Norwich Airport for the storage, maintenance and dismantling of end of life aircraft. Figure 1 shows an aerial photograph of the site.
Figure 1: Aerial photograph of the airport site: Bing maps
The development proposals are for the recycling of aircraft, including the recovery of components for re-use and recycling, and the destruction of the airframe and metal recovery for recycling. KLM UK Engineering Limited (KLMUKE) have the full support of AF-KLM, one of the world's largest airlines, to develop this facility as soon as possible, and are pleased that this will bring some of KLM’s work to Norwich. As a subsidiary of KLM Royal Dutch Airlines N.V. and a member of the Air France Industries / KLM Engineering & Maintenance Network, KLMUKE’s primary business at Norwich International Airport (NIA) is the repair and maintenance of aircraft in the 3 hangars which KLMUKE currently occupies. In addition KLMUKE runs: A training college located in premises on Hurricane Way. Extensive workshop facilities in the various airport hangars; and Line maintenance at a wide variety of UK airports. An increasingly important part of the KLMUKE business is attracting aircraft to Norwich where the future of the aircraft is uncertain. KLMUKE’s primary goal is to capture extensive refurbishment work which frequently comprises many thousands of hours. However, on occasion, the cost of returning an aircraft to service is uneconomical when balanced against the value of the component parts of the aircraft. This is where KLMUKE’s market position becomes valuable because there are few providers in the market who can refurbish aircraft in fast turnaround times but alternatively can dismantle
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an aircraft if necessary. So the aircraft owner is not compelled to make an immediate decision when for example a lease to an operator comes to end. However, KLMUKE presently can no longer legitimately dismantle aircraft without having the EA ELV Permit. In turn the EA ELV Permit requires amongst other items: A suitable area to dismantle aircraft Planning Permission (either in the form of Permitted Development or full Planning Permission). In this case we are seeking full Planning Permission. Therefore in order for KLMUKE to maintain and develop this increasingly important strand of business, consent to construct the aircraft dismantling area is vital.
An application for an EA Permit is being undertaken and covers the area shown on the General Arrangement Plan (202257/SK100), as well as an existing section of Hangar 6. The planning application is focused on the area outlined in red as shown in Figure 2 below.
Hangar 6 will continue to be used for the storage for new and reconditioned aircraft components, as at present. It is worth clarifying that engineering components from aircraft of all ages are taken into stores for re-use and reconditioning on planned schedules based on run time, mileage or air time. Once an aircraft is classified as End of Life Vehicles (ELV) and becomes waste the aircraft will be transported to the proposed site area where it will be dismantled. On dismantling the aircraft, the majority of its components are either recycled, reconditioned or reinstated back into the supply chain for re-use. The reconditioned and reinstated components for re-use will then be stored in Hangar 6 until such time that they are re-used or sold for re-use to a different airline. Whilst Hangar 6 is part of the EA ELV application no change of use is intended, therefore it is not within the planning application area.
A drainage management plan and Environmental Risk Assessment will be submitted as part of the Application for the EA permit.
Regional and local planning policies support growth of businesses and increased employment at Norwich Airport.
Consideration has been given to the need for an Environmental Impact Assessment. A request for a screening opinion has been submitted to Norfolk County Council (NCC) which has been determined: an EIA is not required. Norwich International Airport’s request for a screening opinion dated 14th May 2013 and NCC’s letter of 12th June 2013 are attached at Appendix A.
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Figure 2: Site Area
1.1 Site Location The proposed development site is located towards the south east corner of Norwich Airport, as shown on the site location plan in Figure 3 below.
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Figure 3: Site Location Plan
1.2 Description of the Existing Site The site is grassed and forms part of the outfield of Norwich International Airport. It is occupied by the “obstacle clearance zone” associated with the main runway of Norwich Airport, but is beyond the southern edge of the 300m wide “runway strip”, as stipulated by the Civil Aviation Authority. The Norwich Airport Industrial Estate is located to the south of the site. The site is sensibly level at a reduced level above Ordnance datum of approximately 31 metres, with a gentle fall towards the south, away from the main runway. Whilst the total airport site extends to an area of 270Hectares, the proposed development including the access road has an area of 0.34Hectares, i.e. about one tenth of one percent of the airport area. Predominant views at the site are of the airport runways and taxiways to the north, and of the Norwich Airport Industrial Estate to the south, dominated by the industrial buildings comprising large hangars originally constructed to accommodate Liberator bombers during World War 2.
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2 PROPOSED OPERATIONS The site will have an annual throughput of up to 2000 tonnes. This annual throughput includes 1900 tonnes of commercial and industrial materials, mostly metal, and up to 100 tonnes of hazardous materials. Operations include depollution work, site set up procedures, draining remaining fuel, identification of hazardous materials, removing fire bottles and pressured vessels (including accumulators, oleos, oxygen bottles and tyres which are returned to the aircraft owner), parts removal and the final tearing down of airframes using a 360 degree tracked machine with a grapple and loading bucket. Once each airframe is reduced to pieces of manageable size, the metal will be loaded into roll-on-off bulk skips or vehicles for onward transportation to a metal recycling facility. After final destruction of an airframe, operating procedures require the site to be left clean and tidy, all equipment tidied, all materials likely to become a FOD hazard secured, and any areas where hot works have been carried out inspected prior to completing the works. All work must be left in a safe and stable condition. The majority of the aircraft is reused or recycled. It is only necessary to landfill small volumes of materials which currently do not have a recycling option, although technology continues to develop and the ultimate aim is to reuse or recycle 100% of the aircraft. An application for an EA Permit is being undertaken and covers the area shown on the attached layout plan. The development proposals will see 5 new (full time) employees join the existing 348 full time and 10 part time existing KLMUKE staff at Norwich Airport. The proposed hours of opening are for the storage, maintenance and component recovery 24 hours per day (as per existing operation of hangars) and final destruction during daylight hours and within the daily hours of operation of Norwich Airport. For information, the final destruction generally takes 1 to 2 days per aircraft. Plant for the destruction of the airframe and packing the stripped aluminium into skips for transport purposes will comprise a single tracked medium size 3600 excavator, of the pattern used on construction sites everywhere. A typical machine could be the Hitachi Zaxis 120, which has an operating weight of about 12.6tonnes, which is illustrated on the swept path drawing number 202257/500.
Similar excavators are manufactured by a number of plant specialists, and all comply with relevant design and construction regulations. The actual machine to be used will depend upon plant hire arrangements and availability.
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For the purposes of airframe demolition, the excavator will be fitted with a multiprocessor attachment, similar to the one pictured above. These use hydraulic rams connected to the machine’s hydraulic system and hardened jaws, and are capable of crushing concrete sections and steel plate and sections up to certain sizes. The fine aluminium pressings and outer skin of commercial aircraft are readily cut, sheared, separated and compacted for transport and recycling by these attachments.
2.1 Proposed Development Details The proposed development area extends to about 0.34Ha, of which the majority will comprise new hardstandings at or nearly at existing ground level. These will include: A crossover from the existing southern taxiway. The main pad, approx 1342m2, on which the aircraft for recycling will be stood together with containers for the storage of components and materials for re-use. This is also the area on which the 360 degree tracked machine with grapple and loading bucket will operate to finally destruct the airframe for reclamation of metal for recycling. Ancillary hard-standings for the storage of clean components, and to accommodate a self contained welfare unit with toilet and sink, and a mobile generator. The access road within the existing airport site, which is shown on plan 202257/SK108. The proposals are illustrated in plan on the attached drawing 202257/SK100 “General Arrangement Plan”. Drawing 202257/SK101, attached, indicates the facility in cross section.
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Figure 4: General Arrangement Plan
The aircraft dismantling pad area will be fenced in order to prevent personnel and vehicles straying onto the adjacent alpha taxiway. The fence will be located along the green line shown on the General Arrangement Plan in Figure 4 above.
` Figure 5: Fencing Outside Bristows Hangar
Fixed fencing not more than 2m high comprising metal posts and chain link mesh will be employed except at the access for trucks and vans from the access track, and at the cross over for aircraft from alpha taxiway. At these locations, demountable temporary type fencing will be employed, see picture. It is emphasised that no new fencing to the airport perimeter is required, and that this fencing is within the existing operational airport.
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Figure 6: Temporary Fencing
The fencing will be provided to the relevant British Standards as detailed below: The chain link fencing will be provided to BS 1722-1. Hot-dip galvanizing to BS EN ISO 1461.
A typical elevation of a chain link fence is shown in Figure 7.
Figure 7: Typical Elevation of Chain Link Fence
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2.2 Construction Specification Construction traffic will access the airport site via Crash Gate 6 off St Faiths Road. The track leading to taxiway alpha and the taxiway will be used to gain access to the construction area. The taxiway will be regularly swept to avoid hazards to aircraft. There is recent precedent for using this route for construction traffic during the Bristow’s heliport construction and also for airport taxiway and apron work without any known incident. All earthworks will be carried out by tracked excavators and forward tipping site dumpers, the same plant will be utilised to construct the access track and install the below ground drainage. Preparing for the works of the in-situ concrete pad and sump will entail approx 4 deliveries of formwork and reinforcing steel by lorry. Access by civil engineering personnel with van sized vehicles for site preparation, formwork, steel fixing, concreting and finishing operations will follow the earthworks. Concrete and crushed hardcore will be delivered from off-site local suppliers, approx. 30 loads of each material, and on a limited number of occasions a lorry mounted concrete pump may attend site to place wet concrete into the works. The proposed access road will comprise Type 1 granular sub-base, or selected crushed concrete laid to an acceptable size grading, graded to a cambered profile and compacted by vibrating roller. The stoned-up road will be have cross falls to ensure storm water run-off onto the adjacent grass, and will have a passing place widened to 6.5 metres to permit HGVs to pass. Given the free draining nature of the superficial soils revealed by the soils investigation, no positive drainage is required. An existing earth bund will be modified to provide adequate width for the access road, and existing fencing will be modified as necessary with new fencing to meet the requirements of airport operations. The main pad will comprise concrete reinforced with steel fabric reinforcement (“mesh”), laid in-situ on a prepared granular bed of sub-base material. Prior to laying the sub- bases, earthmoving will be carried out to prepare the site levels stipulated in the drainage strategy. Earthworks levels changes will be small, typically + 0.3m. Top soil will be stripped and placed on an existing adjacent soil bund. Any excess sub-soil will also be placed on an existing soil bund, segregated from excavated top soil. The concrete slabs will be determined to have the required level of durability for long life with minimal maintenance despite exposure to extremes of temperature, wet/dry and freeze/thaw cycles, whilst sustaining HGV lorries, heavy plant and stationary aircraft. Additionally, the concrete slabs are of watertight construction and incorporate a reinforced concrete sump to ensure that in the event of a spill of aviation fuel, hydraulic oil or any other contaminative fluid, it will be contained until clean up procedures are invoked. Containment is by means of closing an engineered gate valve at the sump outlet.
2.3 Geography, Geology and Hydro-geology The site is located on the plateau which runs east – west between the valley of the river Wensum to the south and tributaries of the river Bure to the north. The Corton Formation was revealed below the topsoil in all five trial pits excavated as part of the soils investigation for the development on 2nd May 2013. Quoting the soils www.canhamconsulting.co.uk 10 Planning Statement – Aircraft Recycling Facility, Norwich Airport, Norwich July 2013 Issue P6 202257
investigation report prepared by the Norfolk Partnership Laboratory: “The Corton Formation (Happisburgh Glacigenic) is probably glacio-marine in origin and comprises of orange to buff, mostly fine grained sand with subordinate gravel, often gravelly towards the base. A widespread sandy clay or till occurs at the base and is equivalent to the Cromer Till of North Norfolk. Thicknesses up to 10 metres may be present”.
There are no watercourses in the immediate vicinity of the site, the nearest being the river at Horsham St Faith, approximately 3km to the north.
According to the Regional Hydrogeology Map of Northern East Anglia, the Norwich Crag (which underlies the Corton Formation) is the principal aquifer for the area. The estimated minimum hydrostatic level of the Crag water table in the vicinity of the site is about 10 metres above Ordnance Survey Datum. The site is approximately 30 metres above Ordnance Survey Datum. The groundwater table is therefore approximately 20 metres below existing ground level.
A shallow overgrown ditch is present close to the boundary fence with the industrial estate to the east of the site however no surface water was present.
2.4 Ground Contamination As part of the Soils Investigation carried out for KLMUKE by the Norfolk Partnership Laboratory on 2nd May 2013, one topsoil sample was taken from each trial pit and tested for a general contamination Suite SB and screened for asbestos fibres.
No visual or olfactory indication of existing contamination was evident when the trial pits were excavated.
All of the test results were found to be below the SGV's, Atkins ATRISK and LQM / CIEH Assessment Criteria 2nd Edition threshold values for commercial land use using 1% soil organic matter.
No asbestos containing material was detected in any of the samples.
2.5 Traffic and Access Considerations A traffic statement has been prepared in support of this application, and has been the subject of a pre-consultation with relevant officers at Norfolk County Council. During recycling operations, all vehicles are likely to access the site via the existing access, which is a secure access, from Liberator Road through the Norwich Airport Industrial Estate and the newly constructed access track within the airport. However construction traffic will access the airport site via Crash Gate 6 off St Faiths Road. The track leading to Taxiway alpha and the Taxiway will be used to gain access to the construction area. The taxiway will be regularly swept to avoid hazards to aircraft. It is envisaged that two vans and 1 trailer will require parking onsite. No formal designated parking is envisaged as drivers would use whatever space is available. It is understood that the traffic generation associated with the proposed development is 5 employee trips (per day), and 3 road deliveries associated with transport of parts for www.canhamconsulting.co.uk 11 Planning Statement – Aircraft Recycling Facility, Norwich Airport, Norwich July 2013 Issue P6 202257
each aircraft, (1 for say 2 engines removed and 2 for the remaining parts). However, some parts also go by air freight direct from Norwich Airport, on existing flights. The timescale on removal of parts will vary from aircraft to aircraft depending on size of aircraft and resources involved and time constraints, although 2-3 weeks might be expected as a norm. There will also be 6 skip container lorries for each aircraft dismantled i.e. 3 which will be for delivery of containers prior to dismantling of the plane and 3 for removal of containers after dismantling. In summary approx every 3 weeks there will be 9 (two way) trips generated (excluding the staff trips). It is considered that the worst case scenario is that the parts and containers are transported on the same day which would result in 5 employee trips and 6 van / HGV trips. However this would not occur on a daily basis and is not likely to occur more than every 3 weeks as a worst case scenario. Whilst aircraft will be moved onto the site via the adjacent taxiway, Alpha taxiway, cars vans trailers and skip lorries will take an alternative route to the dismantling facility in order to avoid disruption to aviation operations. The proposed access road within the site has an approximate length of 250 metres and is shown on plan SK 108, attached. The access road proposed follows the line of an existing maintenance track used by airport grass cutting machines, and will comprise an informal 4 m wide gravelled track.
2.6 Drainage and Pollution Prevention Drainage has been given due consideration, under the headings of pollution prevention, flood risk and amenity. A Flood Risk Assessment is not required, under the National Planning Policy Framework, because the site is not indicated on the Environment Agency’s flood risk maps to be at risk of fluvial or tidal flooding, and because the site area is under 1 hectare. The Planning officer has endorsed this view. Nonetheless, a strategy is required for the storm-water that may collect on the pad, approx area 1342m2 in severe storms. The proposed strategy is shown on drawing 202257/300. Drainage of clean storm water to infiltration trenches is to be employed because there are no suitable watercourses or public sewers in the vicinity of the site. Additionally, it is government policy, through The Building Regulations, PPS25 and the SUDs manual, to employ infiltration drainage wherever it is feasible in preference to discharging to watercourses and public sewers. The concrete pad will be constructed of in-situ concrete to particular specifications, and incorporating a reinforced concrete sump to ensure that in the event of a spill of aviation fuel, hydraulic oil or any other contaminative fluid, it will be contained until clean up procedures are invoked. Containment is by means of closing an engineered gate valve at the sump outlet. Clean storm water falling onto the pad will be released to a conventional infiltration trench type soakaway. The feasibility of using infiltration drainage has been established by the soils investigation carried out by the Norfolk Partnership Laboratory in May 2013, and hydraulic calculations have been carried out in accordance with current drainage standards and government policy to determine that an appropriate scheme is technically feasible with capacity and compliant half drain time for extreme storms including a 20%
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allowance for climate change as set out in the Technical Guidance to the National Planning Policy Framework (CLG March 2012). Consideration has been given to the risk posed by open water following a major rainfall event. Concern would apply if open water was presented for an extended period of time, due to the hazard presented by flying birds to aircraft flying at low altitude. However hydraulic calculation has established that in the most severe envisaged event, the 100 year event including allowance climate change, storm water will dissipate via the trench soakaways into the ground leaving the slab surface free of ponded water after 5 hours in the critical storm. The outfall to the infiltration trench will incorporate a full retention interceptor specified in accordance with Environment Agency design standard PPG3.
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3 PLANNING POLICY
3.1 Introduction This section considers the relevant local, regional and national planning policy guidance and the applicable waste management strategies and how the proposed site complies with these policies.
3.2 National Planning Policy
3.2.1 National Planning Policy Framework (NPPF) The National Planning Policy Framework sets out the Government’s planning policies for England and how these are expected to be applied. The key element of the NPPF is a ‘Presumption in Favour of Sustainable Development’ and development that offers employment and economic investment. The latter being supported by initiatives such as the Local Enterprise Partnerships and the allocation of Regional Growth Funds. The four objectives for sustainable development, as set out in the Strategy for Sustainable Development in the UK, are: Economic opportunities are maintained and improved; There is increasing social equity for all areas; The environment is protected and enhanced while the distinctiveness of each locality is maintained; and Natural resources are conserved. The NPPF does not contain specific waste policies, as national waste planning policy will be published as part of the National Waste Management Plan for England. However it is noted that regard to policies in the NPPF should still be considered so far as relevant. The Government Review of Waste Policy in England in 2011 – Defra June 2011 sets out the Governments intentions for the review of waste policy and builds on the 2011 revisions to PPS10. Until the National Waste Management Plan for England is published, the Waste Planning Policy Statement (PPS10) is still in place and the leading national Waste Policy.
In the context of waste management the proposed development involves the recycling and reuse of components and metal recovered from end of life aircraft. The development is within the boundary of Norwich International Airport and within the vicinity of an existing industrial area.
Paragraph 7 of the NPPF states that there are three dimensions to sustainable development; economic, social and environmental, that gives rise to the planning system performing a number of roles: an economic role – contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure;
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a social role – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being; and an environmental role – contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.
Within the NPPF between paragraphs 18 to 21, the Government’s commitment to developing a strong competitive economy is outlined. This is highlighted by paragraph 18 which states that “The Government is committed to securing economic growth in order to create jobs and prosperity, building on the country’s inherent strengths, and to meeting the twin challenges of global competition and of a low carbon future.” The proposed development will create jobs and secure growth within the KLM UK Engineering Limited, supporting international KLM business operations. Paragraph 33 outlines that “When planning for ports, airports and airfields that are not subject to a separate national policy statement, plans should take account of their growth and role in serving business, leisure, training and emergency service needs.” Paragraph 56 states “Good design is a key aspect of sustainable development, is indivisible from good planning, and should contribute positively to making places better for people” Section 11 of the NPPF ‘Conserving and enhancing the natural environment’ states at Paragraph 109 that “The planning system should contribute to and enhance the natural and local environment by: protecting and enhancing valued landscapes, geological conservation interests and soils…….. preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate. Paragraph 121 illustrates that planning policies should ensure that “the site is suitable for its new use taking account of ground conditions and land instability, including from natural hazards or former activities such as mining, pollution arising from previous uses and any proposals for mitigation including land remediation or impacts on the natural environment arising from that remediation; after remediation, as a minimum, land should not be capable of being determined as contaminated land under Part IIA of the Environmental Protection Act 1990; and adequate site investigation information, prepared by a competent person, is presented.” Paragraph 123 states “Planning policies and decisions should aim to: avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development; mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions; recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have www.canhamconsulting.co.uk 15 Planning Statement – Aircraft Recycling Facility, Norwich Airport, Norwich July 2013 Issue P6 202257
unreasonable restrictions put on them because of changes in nearby land uses since they were established; and identify and protect areas of tranquility which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason.”
In the context of ‘Conserving and enhancing the natural environment’ the proposed development will be covered by an EA Permit which will ensure that the site is not degraded or polluted in any manner from its existing level and if any pollution does occur then remediation will take place to ensure the site is restored to its original status. In the context of noise pollution it has been shown during consultation with the planner that the proposed development will not create any substantial noise pollution and it has been agreed that subject to the plant specifications(s) being included in the application, we a noise survey would not be required at this stage.
Paragraph 150 outlines “Planning decisions must be taken in accordance with the development plan unless material considerations indicate otherwise.” Paragraph 188 states “Early engagement has significant potential to improve the efficiency and effectiveness of the planning application system for all parties. Good quality pre-application discussion enables better coordination between public and private resources and improved outcomes for the community.”
3.2.2 Planning Policy Statement 10 – Waste Planning Policy Statement PPS10 states that the overall objective of the Governments policy on waste is to protect human health and the environment by producing less waste and by using it as a resource wherever possible. PPS 10 sets outlines that positive planning has an important role in delivering sustainable waste management by providing sufficient opportunities for new waste management facilities of the right type, in the right place and at the right time. Key planning objectives are stated at Paragraph 3 as: help deliver sustainable development through driving waste management up the waste hierarchy, addressing waste as a resource and looking to disposal as the last option, but one which must be adequately catered for; provide a framework in which communities take more responsibility for their own waste, and enable sufficient and timely provision of waste management facilities to meet the needs of their communities; help secure the recovery or disposal of waste without endangering human health and without harming the environment, and enable waste to be disposed of in one of the nearest appropriate installations; reflect the concerns and interests of communities, the needs of waste collection authorities, waste disposal authorities and business, and encourage competitiveness; protect green belts but recognise the particular locational needs of some types of waste management facilities when defining detailed green belt boundaries and, in determining planning applications, that these locational needs, together with the
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wider environmental and economic benefits of sustainable waste management, are material considerations that should be given significant weight in determining whether proposals should be given planning permission; and ensure the design and layout of new development supports sustainable waste management. In identifying suitable sites and areas Paragraph 20 outlines that “planning authorities should consider…. a broad range of locations including industrial sites, looking for opportunities to collocate facilities together and with complementary activities.” PPS10 seeks to drive the management of waste up the waste hierarchy of reduction, re- use, recycling and composting, energy recovery from material defined as biomass under the Renewables Obligation, and as a last resort, disposal. The figure below shows the Waste Hierarchy as shown in Annex C of PPS10.
Figure: Waste Hierarchy, Annex C, PPS10.
3.2.3 Waste Strategy 2007 The Waste Strategy 2007 (WS2007) builds on the Waste Strategy 2000 which emphasised the need to manage waste in a sustainable manner. The new strategy “aims for greater ambition by addressing the key challenges for the future through additional steps. The main elements of the new strategy are to: provide stronger incentives for businesses, local authorities and individuals to reduce waste; encourage much greater consideration of waste as a resource through increased emphasis on re-use, recycling and recovery of energy from waste; make regulation more effective so that it reduces costs to compliant businesses and the regulator while preventing illegal waste activity; target action on materials, products and sectors with greatest scope for improving environmental and economic outcomes; stimulate investment in collection, recycling and recovery infrastructure, and markets for recovered materials that will maximise the value of materials and energy recovered; www.canhamconsulting.co.uk 17 Planning Statement – Aircraft Recycling Facility, Norwich Airport, Norwich July 2013 Issue P6 202257
ensure that, if our waste is recycled overseas, it makes an environmentally sound contribution to reducing demand for global resources; improve national, regional and local governance, with a clearer performance and institutional framework to deliver better coordinated action and services on the ground; and increase the engagement of business and the public by communicating and supporting the changed behavior needed by all us – with Government taking a lead.”
The Waste Hierarchy is presented slightly differently in the WS2007 to in PPS10. WS2007 outlines that “The dividends of applying the waste hierarchy will not just be environmental. We can save money by making products with fewer natural resources, and we can reduce the costs of waste treatment and disposal. Waste is a drag on the economy and business productivity. Improving the productivity with which we use natural resources can generate new opportunities and jobs.”
Figure: The Waste Hierarchy, Waste Strategy 2007.
The proposed development adheres to the WS2007 aim that “Most products should be re-used or their materials recycled”. Paragraph xxii states that the Government is encouraging re-use and re-manufacture of products and material resources and stimulating resource efficiency through business advice services. Chapter 4, paragraph 16 states “Aluminum. The recycling of all metals yields significant greenhouse gas benefits because large amounts of energy are needed to extract and www.canhamconsulting.co.uk 18 Planning Statement – Aircraft Recycling Facility, Norwich Airport, Norwich July 2013 Issue P6 202257
process them. Each tonne of aluminum recycled saves 11 tonnes of CO2. Metals already achieve a high rate of recycling and the greatest further potential lies with non- ferrous metals, and particularly aluminum. High recycling of aluminum already occurs in some industries and for some products, but there are areas where more can be achieved. Small increases in recycling tonnages would yield extensive greenhouse gas benefits.” WS2007 outlines that “The Government will continue to support a range of initiatives to help develop re-use and re-manufacture.” WS2007 states “the development of markets for recycled materials helps ensure that recycling is economically and environmentally viable. The Waste & Resources Action Programme (WRAP), created by the Government, has increased the prospects of the recycling industry by: developing new and profitable applications for recycled material. This includes the development of quality standards to improve market confidence in recycled product quality; levering in investment to the recycling sector; providing robust market analysis to demonstrate the potential for new recycled products in existing markets; and persuading end-users to ‘buy recycled’.” Box 6.1: - Local Authorities – Business Waste and Resources outlines the following points: Lead the way in stimulating markets for recycled products through their procurement decisions Encourage economic regeneration through work with local businesses and Regional Development Agencies to take advantage of the opportunities for reprocessing of waste into resources Manage their own business to reduce waste and increase re-use, recycling and recovery and promote awareness by businesses of their duty to ensure that their waste is managed by legitimate waste management contractors Facilitate engagement with business on advice on how to increase resource efficiency and realise the economic opportunities of re-use, recycling and energy recovery Facilitate the procurement of recycling collection services for businesses and the provision of adequate trade waste sites Engage their communities in local debate about the options for change and what individuals and community organisations can do Encourage the provision of recycling collection facilities in homes, shopping centres, workplaces and schools – using planning and other powers where appropriate Key new targets and actions outlined in WS2007 include: national targets for the recovery of municipal waste – 53% by 2010, 67% by 2015 and 75% by 202 Considering in conjunction with the construction industry, a target to halve the amount of construction, demolition and excavation wastes going to landfill by 2012 as a result of waste reduction, re-use and recycling
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3.3 Regional Planning Policy Regional Strategies at present remain part of the Development Plan until they are abolished using powers provided for by the Localism Act (2011). The NPPF emphasizes the Governments intention to revoke Regional strategies outside of London.
3.3.1 Core Strategy and Minerals and Waste Development Management Policies Development Plan Document The Norfolk Core Strategy and Minerals and Waste Development Management Policies Development Plan Document (DPD), runs for a 17-year period from 1 January 2010 to 31 December 2026. The document is referred to as the ‘Core Strategy’. Paragraph 0.9 states “The strategy for waste management conforms to the Waste Strategy for England 2007 and the national waste hierarchy. The Minerals & Waste LDF will therefore, where practicable, allocate sufficient sites to provide facilities to deliver increased rates of recycling, composting and energy recovery.” The spatial vision of the Core strategy is “By 2026, Norfolk will be a leader in waste prevention and increasing the recycling of resources and recovery of energy from waste….Norfolk’s residents and businesses will have played a full part in achieving these reductions, with a ‘culture change’ in waste minimisation practices observable” General waste management considerations are outlined at paragraph 6.26 and it is stated that “Opportunities for integrated waste management will be encouraged, where various waste management options can be co-located to reduce transport requirements and assist improved levels of waste recovery with the main urban areas.”
Core Strategy Policy CS6 – General waste management considerations Policy CS6 states “Waste sites will need to be developed in accordance with policy CS3 and will be acceptable, provided they would not cause unacceptable environmental impacts, on the following types of land: a) land already in waste management use; b) existing industrial/employment land; c) other previously-developed land; and d) contaminated or derelict land. Sites at existing mineral workings and landfill sites will also be acceptable in principle, but will be restricted to a temporary permission(s) lasting until the cessation date for the mineral operation or landfill site. Unused and under-used agricultural and forestry buildings and their curtilages will also be suitable, in principle, for waste management uses, subject to impacts on the rural environment being acceptable. Paragraph 6.27 states “After waste prevention, the preferred means of managing waste in the hierarchy is reuse……The waste stream where there is the most potential for reuse is construction & demolition waste.”
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Core Strategy Policy CS7 – Recycling, composting, anaerobic digestion and waste transfer stations Policy CS7 states “The expansion of, or development of new, recycling, composting and anaerobic digestion facilities, and waste transfer stations to handle all types of waste (inert, hazardous and non-hazardous), will be considered favorably, so long as they would not cause unacceptable environmental, amenity and/or highways impacts. Proposals for composting plants (both enclosed and open-air) will need to be accompanied by a site-specific risk assessment based on clear evidence which shows that bio-aerosol levels can be maintained throughout the life of the operations, at appropriate levels at dwellings or workplaces within 250m of a facility.
Core Strategy Policy CS14 – Environmental protection Policy CS14 states “The protection and enhancement of Norfolk’s natural and built environments is a vital consideration for future minerals extraction and associated development and waste management facilities in the county. In particular, developments must ensure that there are no unacceptable adverse impacts on, and ideally improvements to: Natural resources, including water, air and soil; The character and quality of the landscape and townscape, including nationally designated landscapes (the Norfolk Coast Area of Outstanding Natural Beauty and the Norfolk and Suffolk Broads); Biodiversity and geodiversity, including nationally and internationally designated sites and species, habitats and sites identified in Biodiversity and Geodiversity Action Plans; Heritage assets and their setting, and cultural assets; and Residential amenity e.g. noise, vibration, dust, lighting, and visual intrusion. Where any development proposals would potentially have adverse impacts on any of the assets listed above, the adequacy of any proposed mitigation measures will be assessed on a case-by-case basis. The highest standards of design, operation and (where relevant) restoration and aftercare of sites must be practiced.”
Paragraph 6.79 of the Core Strategy states “The movement of HGVs to and from minerals and waste sites can have significant effects on roads, other road users, the natural and built environments and local communities. Alternatives to road freight, such as rail and water-borne freight distribution of minerals and waste, will be strongly encouraged but in Norfolk the majority of bulk materials are likely to continue being transported by road.”
Core Strategy Policy CS15 - Transport Policy CS15 states “All proposed minerals extraction and waste management facilities must assess and consider positively the potential for non-HGV transportation of materials to and/or from the facilities, principally by rail or water. This assessment must be included within the Transport Statement/Transport Assessment (see Policy DM10).
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The County Council will consider minerals and waste development proposals to be satisfactory in terms of access where anticipated HGV movements, taking into account any mitigation measures proposed, do not generate: a) Unacceptable risks to the safety of road users and pedestrians; b) Unacceptable impacts on the capacity and/or efficiency of the highway network (including the trunk road network); c) Unacceptable impacts on air quality (particularly in relation to any potential breaches of National Air Quality Objectives and impacts on any Air Quality Management Areas) and residential and rural amenity, including from odour and noise; d) Unacceptable impacts on the natural and historic environment; and e) Unacceptable physical impacts on the highway network (e.g. road or kerbside damage).
Development Management Policy DM3 - Groundwater and surface water Policy DM states “Applicants will need to give due regard to the policies within the Environment Agency's document 'Groundwater Protection: Policy and Practice (GP3)' and demonstrate that proposed developments would not adversely impact upon groundwater quality or resources and surface water quality or resources. A hydrological risk assessment must be submitted, where applicable, to demonstrate this to the satisfaction of the County Planning Authority and the Environment Agency. In line with the Environment Agency’s policy, sites for mineral extraction and associated development will be acceptable in Groundwater Protection Zone 1 provided they are above the water table. Sites for waste management facilities will not be permitted in Groundwater Protection Zone 1.”
Development Management Policy DM4 – Flood risk Policy DM4 states “The Norfolk district councils' Strategic Flood Risk Assessments will be used to inform decisions for mineral extraction and associated development and waste management facilities where appropriate. In accordance with PPS 25, the Sequential Test and, where necessary, the Exception Test must be applied to all proposals. If it is demonstrated that there are no reasonably available sites in areas with a lower probability of flooding that would be appropriate to the type of development or land use proposed, the applicants must demonstrate that they have applied the Sequential Approach on the site itself. In particular, ancillary uses and access roads should preferably be sited in areas at lowest risk of flooding. A Flood Risk Assessment is required for all development in Flood Zones 2 and 3, and for sites greater than 1 hectare. Through consultation with the Environment Agency, the County Planning Authority will expect developers, through site layout, design and access, to ensure flood risk is not increased as a result of all mineral extraction and waste management sites.”
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Development Management Policy DM7 - Safeguarding aerodromes Policy DM7 states “Minerals and waste planning applications that are within safeguarded areas will be the subject of consultation with the operator of the aerodrome or technical site. Proposed developments within 13 km of the centre point of safeguarded aerodromes that have the potential to attract birds, due to landscaping or waste management operations, must be subject to a bird hazard assessment. Where significant risk is identified, developers will be expected to modify their proposals to mitigate this risk and as part of the mitigation it may be necessary to produce and implement a Bird Hazard Management Plan acceptable to the aerodrome concerned.”
Development Management Policy DM10 – Transport Policy DM10 states “All planning applications must be accompanied by a Transport Statement that demonstrates: Suitable highway access and egress in accordance with published highway design guidance; A suitable route to the nearest major road (trunk road or principal road or main distributor road), which may need to be incorporated in a formal Routing Agreement; Consideration of other road users, including cyclists, horse riders and pedestrians; Consideration of sustainable drainage and pollution control measures; and Measures to reduce car travel to the site by workers and visitors”
Development Management Policy DM11 – Sustainable construction and operations Policy DM11 states “Sustainable development will be promoted by requiring proposals for mineral extraction and associated development and waste management facilities to demonstrate consideration of: Design standards: the BREEAM “Very Good” or “Excellent” standard should be aimed for in the design of new buildings or plant; Sustainable materials: the use of recycled and secondary materials (including aggregates) in the construction of the facility and associated transport infrastructure should be maximised; and Water efficient design, including water recycling and sustainable drainage measures. Operators will be encouraged to adopt an environmental management system (EMS), such as ISO 14001, to minimise the environmental impacts from operations. Evidence as to how the sustainable demolition, construction and operation of a proposal will be implemented must accompany the planning application. Any measures required will be secured through planning conditions and/or planning obligations.”
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3.4 Local Planning Policy
3.4.1 Joint Core Strategy The Joint Core Strategy (JCS) is the result of Broadland District Council, Norwich City Council, and South Norfolk Council working together with Norfolk County Council as the Greater Norwich Development Partnership. The relevant JCS policies are detailed below.
Policy 1: Addressing climate change and protecting environmental assets Policy 1 states “To address climate change and promote sustainability, all development will be located and designed to use resources efficiently, minimise greenhouse gas emissions and be adapted to a changing climate and more extreme weather. Development will therefore: be energy efficient provide for recycling of materials use locally sourced materials wherever possible be located to minimise flood risk, mitigating any such risk through design and implementing sustainable drainage minimise water use and protect groundwater sources make the most efficient appropriate use of land, with the density of development varying according to the characteristics of the area, with the highest densities in centres and on public transport routes minimise the need to travel and give priority to low impact modes of travel be designed to mitigate and be adapted to the urban heat island effect in Norwich improve the resilience of ecosystems to environmental change The environmental assets of the area will be protected, maintained, restored and enhanced and the benefits for residents and visitors improved.”
Policy 2: Promoting good Design Policy 2 states “All development will be designed to the highest possible standards, creating a strong sense of place. In particular development proposals will respect local distinctiveness including as appropriate: the historic hierarchy of the city, towns and villages, maintaining important strategic gaps the landscape setting of settlements including the urban/rural transition and the treatment of ‘gateways’ the landscape character and historic environment, taking account of conservation area appraisals and including the wider countryside and the Broads area townscape, including the city and the varied character of our market towns and villages provision of landscaping and public art www.canhamconsulting.co.uk 24 Planning Statement – Aircraft Recycling Facility, Norwich Airport, Norwich July 2013 Issue P6 202257
the need to ensure cycling and walking friendly neighbourhoods by applying highway design principles that do not prioritise the movement function of streets at the expense of quality of place the need to increase the use of public transport, including through ‘public transport oriented design’ for larger development designing out crime the use of sustainable and traditional materials the need to design development to avoid harmful impacts on key environmental assets and, in particular SACs, SPAs and Ramsar sites This will be achieved by ensuring that: major development areas providing over 500 dwellings or 50,000m2 of non- residential Floor space, and areas of particular complexity will be master planned using an inclusive, recognised process demonstrating how the whole scheme will be provided and ensuring that it is well related to adjacent development and infrastructure all residential development of 10 units or more will be evaluated against the Building for Life criteria published by CABE (or any successor to this standard), achieving at least 14 points (silver standard) Design and Access Statements for non residential development will show how the development will meet similar high standards”
Policy 5: Economy Policy 5 states “growth both in urban and rural locations. This will: provide for a rising population and develop its role as an engine of the wider economy facilitate its job growth potential with a target at least 27,000 additional jobs in the period 2008-2026 increase the proportion of higher value, knowledge economy jobs while ensuring that opportunities are available for the development of all types and levels of jobs in all sectors of the economy and for all the workforce. Sufficient employment land will be allocated in accessible locations consistent with the ‘Policies for places’ in this strategy to meet identified need and provide for choice. In particular: the needs of small, medium and start-up businesses will be addressed through the allocation of new smaller scale employment sites and the retention of, and the potential expansion of, a range of existing small and medium employment sites across the area and by requiring the provision of small-scale business opportunities in all significant residential and commercial developments. Flexible building design and innovative approaches will be sought in new and existing residential developments to encourage local working and business opportunities larger scale needs will be addressed through the allocation of sufficient land to provide a choice and range of sites. Development Plan Documents and investment strategies will ensure that a readily available supply of land is maintained throughout the Joint Core Strategy period investment strategies will focus on overcoming constraints to the release and development of key sites
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land identified for employment uses on proposals maps will only be considered for other uses that are ancillary and supportive to its employment role. Employment land with potential for redevelopment for other uses will be identified in supporting DPDs or SPDs. Opportunities for innovation, skills and training will be expanded through: facilitating the expansion of, and access to, vocational, further and higher education provision encouraging links between training/ education provision and relevant business concentrations including co-location where appropriate support for enterprise hubs at Norwich Research Park, the University of East Anglia, EPIC (East of England Production Innovation Centre), and Hethel, and at easily accessible locations in the area”
Policy 6: Access and Transportation Policy 6 states “The transportation system will be enhanced to develop the role of Norwich as a Regional Transport Node, particularly through the implementation of the Norwich Area Transportation Strategy, and will improve access to rural areas. This will be achieved by: implementation of the Norwich Area Transportation Strategy (NATS) including construction of the Northern Distributor Road (NDR) significant improvement to the bus, cycling and walking network, including Bus Rapid Transit on key routes in the Norwich area enhancing the Norwich Park & Ride system promoting enhancement of rail services, including improved journey time and reliability to London and Cambridge, and innovative use of the local rail network provision of an A140 Long Stratton Bypass promoting improvements to the A11 and A47 supporting the growth and regional significance of Norwich International Airport for both leisure and business travel to destinations across the UK and beyond concentration of development close to essential services and facilities to encourage walking and cycling as the primary means of travel with public transport for wider access provision of IT links, telecommunications and promotion of home working protection of the function of strategic transport routes (corridors of movement) continued investigation of and support for rail freight opportunities continuing to improve public transport accessibility to and between Main Towns and Key Service Centres promoting local service delivery continuing to recognise that” Policies 2, 3, 5 and 6 apply to the whole plan area whereas policy 9 only applies to defined parts of the plan area.
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Policy 9: Strategy for growth in the Norwich Policy Area Policy 9 states that “The Norwich Policy Area (NPA) is the focus for major growth and development….. Employment development at strategic locations will include… a new business park of around 30ha associated with the Airport and focused on uses benefiting from an airport location….”
3.4.2 Norwich City Council Replacement Local Plan (2004) Paragraph 214 of the NPPF states that for 12 months from the publication of the NPPF decision takers may continue to give full weight to relevant policies adopted since 2004 even if there is a limited degree of conflict with the NPPF. The City of Norwich Replacement Local Plan was adopted in November 2004 and is, therefore, a material consideration. The Replacement Local Plan provides guidance for developers on the nature of development which may be permitted in certain locations. The emerging Local Plan is a suite of planning policy documents to guide and manage new development in the city of Norwich which will replace the City of Norwich replacement local plan (RLP) which was adopted in 2004. The JCS is one of the documents of the new suite of planning policy documents. It is detailed within the RLP that Norwich “airport has a particularly important role in the economy of the City as well as the Eastern Region, acting as a focus for significant employment expansion” Key Policies in the NCC RLP are detailed below.
Policy TRA1: Norwich Airport to be Supported as Regional Airport Policy TRA1 states “Norwich Airport will continue to develop as a regional airport of significant importance to the local economy. Proposals for the growth of the Airport will be assessed against: • consistency with the national airports policy; • the environmental impact of its development, including any significant increase in aircraft movements; • the diversification and integration of modes of surface access, in order to encourage travellers to use other modes than the private car to access the Airport. The Airport will be promoted as the location of a significant transport interchange with improvements to surface access”
TRA2 - Development within Airport boundary Policy TRA2 states “Within the Airport boundary defined on the Proposals Map operational development for Airport purposes and for the purpose of transport interchange with other modes of travel will be acceptable. Proposals for non-operational uses, related to the Airport’s function will be assessed against: (i) the long term operational development needs of the Airport; (ii) the environmental impact of any proposal, including the potential impact of airport activities and development on the proposed use.”
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EMP2 - Expansion of existing businesses Policy EMP2 states that “Proposals for expansion of existing businesses will be permitted, provided that: (i) there is no adverse environmental or visual impact, taking particular account of the character of any residential areas or other adjoining uses; (ii) development is not over-intensive in relation to the capacity of access, parking facilities and services to the site; (iii) the proposal will not result in an unsatisfactory form of development in terms of access, parking, loading and unloading of vehicles or safety and security for the business concerned or for visitors.”
EMP4 – Policy for Prime Employment Areas Within Policy EMP4 it is outlined that the Airport Industrial Estate (including Iceni Office Park) is a prime employment area. EMP4 also outlines “Other activities will only be permitted where they are clearly complementary to the main uses in terms of their size and functional relationship in providing a service to existing businesses and employees already on the estate... Airport operational activities will be permitted on those parts of the Airport Industrial Estate adjacent to the Airport boundary provided they are compatible with other activities on the estate.”
EP8 – Noise amelioration measures at Norwich Airport Policy EP8 states “Development at Norwich Airport will be subject to the implementation of appropriate measures for noise amelioration in relation to aircraft movements and testing. In addition the implementation of the noise amelioration scheme agreed between Norwich Airport, Norwich City Council and Broadland District Council will be required to be updated to include any significant new airport development at Norwich Airport. Development in proximity to the airport will only be permitted, where noise from the current or likely future level of aircraft movements will not have a significant detrimental effect on people’s amenity. Helicopter landing sites elsewhere in the City will only be permitted where noise will not have a significant detrimental effect on people's amenity.”
EP14 – Protection of Groundwater Source Protection Areas Policy EP14 states “Development will not be permitted in the groundwater source protection zones or where a major aquifer may be affected, unless the developer can demonstrate that appropriate measures will be taken to minimise any risk of pollution to the water source.”
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EP20 - Sustainable use of materials Policy EP20 states “Development will provide for the use of sustainable materials in construction, giving priority to: (i) reusing existing buildings, where they are capable of being adapted to a new use; or, if not capable, (ii) reusing construction materials already present on the site (including crushed concrete on redevelopment sites); and (iii) identifying recycled materials from other sites which can be used; and (iv) using energy efficient materials; and/or (v) where construction is temporary or relatively short-term, ensuring that the future use of the site is considered in the form and layout of the proposals and that materials can be reclaimed and reused.” The Policies detailed above are Policies which remain in use from March 2013 and comply with NPPF.
3.4.3 Broadland District Local Plan (Replacement, 2006) The application site is within the administrative boundary of Norwich City Council and as such the development proposals will be tested against the relevant development plan. However, as part of the airport site lies within Broadland District council (BDC), it is practical to have regard to the strategic policies of BDC. BDC’s Local Plan was adopted in May 2006, and the document updated following JCS adoption in March 2011. BDC’s Local Plan sets out policies to guide development and protect the environment of Broadland up to 2011. The Local Development Framework (LDF) will eventually replace the Local Plan. The relevant policies of BDC Local Plan are detailed below.
TRA9 - Airport Policy TRA9 states “Within the operational boundary of Norwich International Airport shown on the proposals map operational development for airport purposes and development which is not operational but clearly demonstrated to be airport related will be assessed against (a) the long term operational needs of the airport taking into account emerging national and south east regional airports policy (b) their landscape and countryside impact (c) the availability of suitable sites south of the main runway (d) the environmental impact of airport activities on the proposed development (e) the environmental impact of the proposal on neighboring areas (f) surface access considerations.”
BDC Local Plan outlines that Norwich International Airport is recognised for its significant importance to the local economy.
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The proposed development is to the south of the main runway, which is identified in BCD Local Plan as being “viewed as the northern limit of development with the exception of certain specialized developments (aviation museum and fire training).
Therefore the proposed site is within the recognized development area of the airport grounds.
CS12 - Pollution Prevention Policy CS12 states “Development will only be permitted where it will not result in a significant adverse environmental impact: including the effects on health, natural environment, and general amenity. Where there is a risk of pollution by means of release to water, land or air, appropriate pollution prevention and control measures will be required.”
In context of pollution control the development proposals have given regard to risk and potential of pollution arising from the development and any risks have been addressed.
CS14 - Noise Policy CS14 states “Noise levels will be taken into account in the determination of planning applications Noise sensitive development, such as housing, schools and hospitals, will not be permitted in close proximity to high noise generators. Developments which create high noise levels will not be permitted close to existing noise sensitive areas. Where noise levels are not so great, but still a potential problem, any planning permissions will be subject to appropriate conditions or legal agreements requiring mitigating measures to be taken.”
3.5 Summary This Planning Statement relates to a proposed development within Norwich International Airport (NIA). It supports a full planning application that seeks consent for a maintenance and recycling facility.
The principle of the proposal conforms with the National Planning Policy Framework, Waste Planning Policy Statement (PPS10), Waste Strategy 2007, regional planning policies CS6, CS7, CS14, CS15, DM3, DM4, DM7, DM10 and DM11 of Core Strategy and Minerals and Waste Development Management Policies and Local planning policies 1,2, 5, 6 and 9 of the Joint Core Strategy for Broadland, Norwich and South Norfolk, policies TRA1, TRA2, EMP2, EMP4, EP8, EP14 and EP20 of the Norwich City Council Replacement Local Plan (2004) and policies TRA9, CS12 and CS14 of the Broadland District Local Plan.
The Applicant therefore considers that, having regard to all relevant planning policy considerations, NCC can grant full planning permission for this proposal.
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4 SUMMARY AND CONCLUSION
The KLM UK Engineering Limited operation at Norwich Airport is a major employer. Broadening the range of aviation related operations at Norwich International Airport is a significant benefit not only to the business but also to the economic vitality of the region. KLM UK Engineering Limited have prepared development proposals for the recycling of aircraft, including the recovery of components for re-use and recycling, and the destruction of the airframe and metal recovery for recycling. These proposals have been prepared with due regard to meeting relevant regulations to protect the environment, and indeed are the subject of the rigorous Environment Agency licensing process for waste and recycling. The proposed aircraft recycling facility will be located within the existing 270Ha airport site, and the proposed use – the operation and maintenance of aircraft, will be similar to all the other activities at the airport. Impacts of the proposed aircraft recycling facility will be minimal in comparison to the scale of aviation, industrial and commercial activity already occurring at Norwich International Airport and on the adjacent Norwich Airport Industrial Estate. To determine the feasibility of the proposed drainage strategy and inform the engineering drawings, a topographic survey was carried out and the soils investigation was carried out, which considered a) existing (baseline) ground contamination, b) the engineering geology of the near-surface soils and c) the suitability of the soils for infiltration drainage. This application is supported by a Transport Statement and a Design & Access Statement, together with various survey plans and engineering drawings, which we draw to your attention. This development complies with all known planning, development control, engineering and environmental requirements, and we recommend it for approval.
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APPENDIX A EIA Screening Opinion
Norwich International Airport Request for a screening Opinion dated 14th May 2013
NCC EIA screening opinion letter dated 12th June 2013.
www.canhamconsulting.co.uk 32 KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
1. INTRODUCTION In accordance with Regulation 5(2) of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 (as amended), (thereafter referred to as 'the Regulations') this report forms the basis of the formal request for a ‘Screening Opinion' from the Council as the competent authority, as to whether an EIA is required for the proposals described. For this purpose we include:-
A plan identifying the location of the proposed development within the Norwich Airport boundary (Annex A); General arrangements plan (Annex B: Drawing number SK100 P6); An environmental risk assessment (Annex C); A drainage management plan (Annex D); EIA Screening Process (Annex E).
2. BACKGROUND 2.1 There has been a long history of aircraft being dismantled at Norwich Airport. Some of the earlier dismantling events are only anecdotal, e.g. during the war and post war years. However, in more recent times there is more detail available:
Ex Air UK Herald used for towing practice – broken Jan 1985 Fairchild – date not certain 2 x Fokker 27 mid 1996 2 x Fokker 27 by Feb 1997 Another 3 x Fokker 27 around the same period Fokker 100 – Jan 2008 Boeing 737 Feb / Mar 2012 Fokker 50 - Feb / Mar 2012 2 x Fokker 100 – May 2012 Boeing 737 June 2012
This is by no means a comprehensive list as these are only the events known to KLM UK Engineering Limited. (KLMUKE)
2.2 The Environment Agency (EA) have recently confirmed to KLMUKE that dismantling an aircraft falls under the same procedures as the disposal of End of Life Vehicles (ELV). Therefore to continue with this activity KLMUKE must obtain the relevant EA ELV Permit. In order to achieve this KLMUKE must demonstrate that dismantling is under strict control thus preventing contaminants causing damage to the environment, e.g. by entering the ground and water supply.
2.3 Given that there is no suitable existing concrete surfaced site on the airport a new area has been designated for development to meet the exacting requirements of the Environment Agency.
KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
2.4 The request for a Screening Opinion is in respect of the proposal to lay a dish profile impermeable concrete surface with controlled drainage including sump, interceptor, valve and infiltration trench. Further details concerning the control of the drainage are contained at 6.6.1 Portakabin type buildings will be located on the site from time to time. The area is located within the operational boundary of Norwich International Airport, which is owned by the operator Norwich Airport Ltd (NAL), Amsterdam Way, Norwich, NR6 6JA.
3. RATIONALE FOR DEVELOPMENT 3.1 As a subsidiary of KLM Royal Dutch Airlines N.V. and a member of the Air France Industries / KLM Engineering & Maintenance Network, KLMUKE’s primary business at Norwich International Airport (NIA) is the repair and maintenance of aircraft in the 3 hangars which KLMUKE currently occupies. In addition KLMUKE runs:
a training college located in premises on Hurricane Way, extensive workshop facilities in the various airport hangars and line maintenance at a wide variety of UK airports.
3.2 An increasingly important part of the KLMUKE business is attracting aircraft to Norwich where the future of the aircraft is uncertain. Our primary goal is to capture extensive refurbishment work which frequently comprises many thousands of hours. However, on occasion, the cost of returning an aircraft to service is uneconomical when balanced against the value of the component parts of the aircraft. This is where our market position becomes valuable because there are few providers in the market who can refurbish aircraft in fast turnaround times but alternatively can dismantle an aircraft if necessary. So the aircraft owner is not compelled to make an immediate decision when for example a lease to an operator comes to end.
3.3 However, KLMUKE presently can no longer legitimately dismantle aircraft without having the EA ELV Permit. In turn the EA ELV Permit requires amongst other items:
A suitable area to dismantle aircraft Planning Permission (either in the form of Permitted Development or full Planning Permission). In this case we are seeking full Planning Permission.
Therefore in order for KLMUKE to maintain and develop this increasingly important strand of business, consent to construct the aircraft dismantling area is vital.
3.4 KLMUKE operates in a highly regulated industry. KLMUKE is approved by EASA (European Air Safety Agency) under what is known as “Part 145” to maintain the following aircraft: KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
Boeing 737 series Airbus 320 series Fokker 70 Fokker 100 Fokker 50 BAe 146 series Avro RJ series
KLMUKE will only dismantle aircraft within the above list though the list will vary over time as older aircraft are replaced with newer types in order to maintain a balanced portfolio. Also, as stated in 3.2 above the primary goal of KLMUKE is to refurbish aircraft. So the dismantling area is only being constructed with a view to dismantling a relatively small number of aircraft, e.g. perhaps up to 24 in any given year though more likely to be no more than an average of 12 per annum.
4. DESCRIPTION OF SITE, SURROUNDINGS & PROPOSED DEVELOPMENT 4.1 The proposed dismantling area is located next to an operational taxiway (Alpha Taxiway) on an area of apparently previously undisturbed grassland. The site is near the boundary with the nearest buildings being various industrial units sited at the Northern end of Hurricane Way. The boundary is 14.5m from the nearest part of the concrete with a similar distance again to the nearest existing building. There are no residential buildings within the vicinity with the nearest residential receptor being beyond the far end of Meteor Close at a distance from the site of approximately 400m.
4.2 Approximately 1700m2 of impermeable concrete will be laid in an irregular shape to suit the footprint of the largest aircraft to be dismantled (the Airbus A321 – the largest of the A320 family). This area represents less than 0.1% of NIA's 202 hectare area of operations.
4.3 Infiltration tests have been carried out at the site and have positively established that the ground conditions are suitable to create an infiltration trench for rainwater. Therefore surface water drainage will be via a sump central to the concrete pad, an interceptor and an infiltration trench. Manually operated penstock valves will be open when there is zero risk of contamination, e.g. when no aircraft is on the dismantling area and the concrete has been declared clean of contaminants.
KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
4.4 Background testing has also been carried out as part of a baseline assessment for the EA ELV to determine whether or not the ground is currently contaminated. At the time of writing the report KLMUKE await the results of the background tests though the soil condition indicated no extant contamination is anticipated.
4.5 Other than the concrete area and drainage system there will be no other permanent structure. However, the area will be fenced to prevent the spread of FOD onto Airport operational areas though it is not finally decided if this will be of a fixed type of structure or mobile fencing or a combination of both.
4.6 The proposed site is surrounded by the existing airfield from the south west to the north east. The site is 20.4m from Taxiway Alpha to give acceptable clearance from operational aircraft and 200m from the airport’s runway. NIA have confirmed via a safeguarding assessment that there will be no impact on the 150m sterile strip that is required either side of the runway nor any impact on the 1:7 glide slope in the area beyond.
5. THE EIA REGULATIONS 5.1 A Directive of the European Community on the "assessment of the effects of certain public and private projects on the environment" was adopted in 1985 (85/337/EEC) and subsequently amended by Directive 97/11/EC. In order to implement these Directives, the UK Government has made a series of Regulations. The relevant Regulations for projects that require planning permission are the Town and Country Planning (Environmental Impact Assessment) Regulations 1999, as amended.
5.2 The aim of the Regulations is to ensure that major projects that are likely to have impacts on the environment are subject to Environmental Impact Assessment (EIA), and that minor projects and those outside sensitive areas which are extremely unlikely to have significant environmental impacts are automatically excluded from the EIA requirements. To this end, the Regulations identify projects where EIA is mandatory (Schedule 1 Projects) and projects where EIA is required if significant environmental effects are likely (Schedule 2 Projects).
5.3 The area of the development is less than 0.5 hectare, it is significantly less than the 10 hectares guidance threshold advised in paragraph A1 of the annex to Circular 02/99 "Environmental Impact Assessment". The proposal falls within Class 11(b) of the Regulations and at 0.5 hectare is less than the relevant suggested threshold. It is considered the development will have no significant environmental effect. This is established by taking into account the factors listed in Schedule 3 of the Regulations which set out criteria that are used to help identify whether a Schedule 2 development is likely to have significant environmental effects, or not. KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
5.4 Advice contained in Circular 02/99 states that new permanent airfields will normally require an EIA, as will major works (such as new runways or terminals with a site area of more than 10 hectares) at existing airports. However, the Circular also states that smaller scale development at existing airports [e.g. hangar buildings] which are otherwise considered Permitted Development, is unlikely to require EIA unless it would lead to significant increases in air or road traffic. Throughout this report this is shown not to be the case.
5.5 The proposed development falls below the 10 hectare guidance threshold referred to above and will be located within an existing airport. Therefore, the principal potential impacts to be considered in judging its significance are likely to be visual impact, surface water drainage, socio-economic effects, noise and traffic although other categories of potential impact are considered and commented upon appropriately.
6. ENVIRONMENTAL CONSIDERATIONS 6.1 Effects on Population from Socio-Economic Changes The proposed development will have a positive effect on the local economy through ensuring that KLMUKE can maintain a throughput of aircraft into its maintenance facility. As described in 3.2 above aircraft owners need access to aircraft maintenance organisations who can provide a wide variety of services including refurbishment or dismantling.
It is estimated that the dismantling element will add an additional 5 full time jobs within KLMUKE. However, by providing a source of aircraft for refurbishment this proposal helps to secure the jobs of the existing 370 employees at KLMUKE along with up to 80 temporary contractors.
KLMUKE is important to NIA because it the largest tenant at the airport occupying space in all 4 of the largest hangars. With associated aircraft movements and other services provided by NIA to KLMUKE the revenues flowing to NIA are significant.
The existing and additional jobs at KLMUKE along with suppliers, customers and flight crew certainly have a direct benefit on the Norwich economy with those benefits spreading to trade for local hotels and guest houses and businesses such as taxi operators, shops and restaurants.
Construction of the site also has a positive albeit temporary impact on jobs.
KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
6.2 Effects on Population from Noise and Vibration The process of aircraft dismantling makes little noise. The majority of time is spent removing components from the aircraft. In fact the majority of the processing time is for documentation rather than physical component removal. It is only in the final phase of cutting up the aircraft that there will be any noise of note. The process of cutting up an aircraft takes about 4 hours and nevertheless is by no means continuously noisy as there are regular interludes required for packing the waste and tidying the site.
The work will predominantly take place during normal working hours and will thus be indistinguishable above background levels of noise from the Airport operations and the adjacent Norwich Airport Industrial Estate in so far as the nearest residential receptors are concerned.
The positioning of an aircraft on to the area will be by aircraft tug so the aircraft itself will not be under its own power. Covered skips will be positioned on the concrete pad for the waste disposal requiring lorry movements and the heavy machinery required for cutting up the aircraft will also be delivered by lorry. The only other routine noise on the facility will be a small generator required to provide power to welfare facility and Portakabin type buildings.
The construction phase will create some noise due to various machinery required and deliveries to the site. This is expected to be over a period of approximately 6 weeks. There may be some vibration caused during the construction phase, e.g. earth compaction though this will be for only a short period of time.
Aircraft flying into NIA for maintenance or repair is part of the normal course of KLMUKE’s business. Although we anticipate up to 24 aircraft being dismantled in a given year (though more likely an average of 12 per annum) there will be little or no discernible increase in aircraft movements given that for each aircraft being dismantled there is no associated outbound flight.
6.3 Effects on Population from Traffic The routine dismantling process will cause approximately 10 vehicle movements to and from NIA. This is for the delivery and removal of skips and the heavy cutting machinery. It is proposed that vehicles will enter and leave the site via Crash Gate 6 on St Faiths Road, Old Catton which is the shortest route to the site and causes the minimum interference with other Airport operations.
The construction phase will cause some additional traffic though this is anticipated to be for only 6 weeks. The main impact will be from deliveries of concrete and hardcore to site which is expected to require approximately 120 deliveries. These deliveries are likely to occur over a period of 4 weeks to maintain a continuous flow of material to the KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
site. Excavated materials will be re-used on site and will therefore not contribute to additional off site traffic movements.
There will also be delivery and removal of heavy construction equipment from time to time as well as a variety of other materials for the drainage system. However, these movements will be limited and also will be consolidated as far as possible to limit the impact of movements on the operational taxiway.
All construction traffic will be subject to on site wheel washing procedures to minimise the impact of debris on Airport operational taxiways and the local road network.
Finally, there will be daily arrival and departure of construction staff.
Most movements during the construction phase are likely to be via Crash Gate 6 on St Faiths Road, Old Catton.
6.4 Effects on Population from Emissions These will be unchanged as compared to the overall impacts of the Airport operations as a whole throughout the construction phase or during subsequent use of the development facilities.
6.5 Effects on Fauna and Flora As an area of existing airfield comprising mowed grass, the proposed development site provides little in the way of ecological habitat. The whole airport site is designed to discourage birds or their prey in order to avoid unnecessary bird strikes. Thus the grass areas are regularly mown and the growth of habitats, e.g. for nesting, are prevented.
Wider ecological impacts have also been considered within proximity of the site in studies for another recent airport development. The process identified appropriate nature conservation designations and in accordance with best practice, local, national and international sites of nature conservation/importance were identified within 2km and 5km of the site. These are summarised in the tables below and the development is considered to have no greater impact than do the existing operations. Given that the airport is a large site there may be some error in distances from the site concerning the previous study and the proposed dismantling site.
KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
The following designations were identified within 2km of the earlier application site:-
Site Name / Area Description Designation
Band from South East of Horsford Broads Environmentally Sensitive to North of Spixworth Area The Wilderness Ancient Replanted Woodland & Ancient and Semi-natural Woodland Mousehold Heath (part of within Local Nature Reserve 2km – rest within 5km) Wensum Valley (Mile Cross Marsh Local Nature Reserve and Sycamore Cresent) River Tud West of Norwich Broads Environmentally Sensitive Area River Wensum West of Norwich Broads Environmentally Sensitive Area River Wensum SSSI Sweet Briar Meadows SSSI Drayton Lowland Heathland
KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
The following designations were identified within a 5km radius (in addition to those above):-
Site Name / Area Description Designation
River Bure from Brampton to Broads Environmentally Sensitive Area Wroxham Broads National Park Broadland Ramsar site (small section at approx 5km) Broads Special Area of Conservation River Yare south of Norwich from Broads Environmentally Sensitive Area Barford to Kirby Bedon Broads National Park Broads Special Area of Conservation Whitlingham Marsh Local Nature Reserve Whitlingham Country Park Danby Wood Local Nature Reserve Eaton Common Local Nature Reserve Marston Marshes Local Nature Reserve Earlham Park Woods Local Nature Reserve Bowthorpe Marsh Local Nature Reserve River Tud continued out to Broads Environmentally Sensitive Area Honingham River Wensum continued out to Broads Environmentally Sensitive Area Morton On The Hill Wensum Valley (Mile Cross Marsh and Sycamore Crescent) Local Nature Reserve River Wensum Special Area of Conservation Buxton Heath SSSI Norfolk Valley Fens Special Area of Conservation Lion Wood Local Nature Reserve Catton Grove Chalk Pit SSSI Caister St Edmund Chalk Pit SSSI Alderford Common SSSI Eaton Chalk Pit SSSI St James' Pit SSSI Swannington Upgate Common SSSI Crostwick Marsh SSSI Haveringland Broads Environmentally Sensitive Area Swannington Broads Environmentally Sensitive Area
KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
In addition to the above, a number of BAP Priority Sites were identified within 5km of the earlier application site. These included the following designations:- Low dry acidic grassland; Lowland calcareous grassland; Fens; Lowland Meadow; Norwich International Airport Lowland Mixed Deciduous Woodland; Undetermined Woodland; Undetermined Grassland; Upland Oakwoods; Wet Woodland.
When assessing the potential wider impacts upon these areas, these are essentially detailed elsewhere within this document. Off-site impacts will primarily be concerned with a small increase in road traffic movements albeit a temporary increase caused by construction traffic. However, in total there is only a marginal impact when compared to NIA's existing and potential scale of operations.
In summary, the above demonstrates that the surrounding designations approximately within 2km and 5km have previously been fully appraised but the particular nature of the proposals means that there is no likelihood that the proposed development would give rise to any significant impacts which could affect the integrity of these sites. The current application site itself is part of the operational airport and, therefore, has little ecological value.
6.6 Effects on Land – Geology and Soil
6.6.1 Norfolk Laboratories have conducted infiltration testing to determine the drainage characteristics and permeability of the ground. This has confirmed that the ground is suitable for a SUDS.
KLMUKE awaits the results of background soil contamination testing but does not anticipate adverse results.
The most obvious potential risk is contaminants (oils, e.g. fuel oils, hydraulic oils) permeating the soil and ground water. Most importantly KLMUKE’s application for an EA ELV Permit is dependent on the adequate operation of significant controls to prevent the escape of potential contaminants. Appendix C shows the environmental risk assessment being submitted to the EA. Appendix D is the drainage management plan also being submitted to the EA.
During dismantling each process will be carefully controlled according to the inherent risk. So for example the removal of passenger seats from the cabin has no risk of contamination. However, cutting into the KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
fuel tanks for the purpose of draining residual fuel is more risky. When there is a risk the drainage system will be closed to make sure there is no escape in the unlikely event of spill. If there is a spill then it will be immediately cleaned up using on site spill kits, stored in accordance with the Airport SMS. It is worth noting that none of the oils and lubricants used on the aircraft are miscible thus if there is a spill to sump or interceptor these can be detected.
With regard to other types of waste the majority is aluminium making up the frame and skin of the aircraft. Other materials include plastics, fibreglass and carbon fibre. Special consideration will be given to carbon fibre as it needs to be strictly controlled. Once again this will be a matter for agreed procedures with the Environment Agency.
There are specific components such as fire bottles, batteries, oxygen bottles and fluorescent tubes that require careful control although these components would normally be removed from aircraft for recirculation into the parts market.
There is absolutely no asbestos or radioactive material in the aircraft listed at 3.4 and is not likely to ever feature in KLMUKE’s portfolio of aircraft.
In summary there is no reason to suggest that the proposed development will have any adverse effect on geology and soil. Furthermore, the proposed area has been designed alongside an Environmental Consultant and has been presented to the EA who have expressed a positive view on the design.
6.6.2 Potential ground contamination during the construction phase would be prevented by ensuring appropriate construction management systems are put in place. Excavated soils will remain on airport land for reuse and will not be exported off site.
6.7 Effects on Water The site is located within the Environment Agency's Flood Risk Zone 1 (low risk of fluvial flooding). There are no ordinary watercourses on the site, therefore, there is very low risk of fluvial flooding from this source and there is no anecdotal evidence to suggest that flooding has occurred previously at the site.
The sustainable drainage strategy for the site will be focussed on management of surface water on the concrete pad. During periods of rainfall there will be careful control of processes undertaken to avoid mixing of contaminants with rain water. This is detailed in Appendix D.
In normal conditions, i.e. no proceses with inherent risk taking place, rain water will run through the drainage system to soak away via the infiltration trench. During the dismantling process, if there is any occurrence of mixing of contaminant and rain water then a specialist KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
company will be contracted to remove the contaminated water from the sealed system.
It is envisaged that potential groundwater pollution during the construction phase would be prevented through suitable construction management techniques.
6.8 Effects on Air and Climate The site is located at the edge of a light industrial area adjacent to the airport site. There will be no significant increase in traffic movements (either vehicular or aircraft) as a result of the proposed development (in 6.2 above there is an explanation why there is no discernible increase in air traffic movements). It is, therefore, unlikely that there would be an increase in air pollution over existing background levels. All aircraft comply with emissions standards set by the International Civil Aviation Organization (ICAO) which, inter alia, seeks to minimise the effects of aviation on the environment.
Potential dust generation during the construction phase would be prevented through appropriate construction management techniques. This effect is considered to be insignificant and any possible effect would have no residual impact.
6.9 Effects on Landscape and Visual Impacts The proposed development site is located within the existing confines of NIA, in close proximity to existing development on Hurricane Way which forms part of a mainly light industrial location.
The most obvious impact is the positioning of an aircraft on the site. However, it is presumed that aircraft are anticipated to be seen within the airport boundary and nevertheless it is highly unlikely that there will permanently be an aircraft on site due to the sporadic nature of such work.
Given that the proposal is primarily a concrete pad there will be little permanent visual impact or impact on the landscape. There will be some soil scraped from the surface to achieve the appropriate contours and this will be landscaped into the adjacent existing banking.
The site is not located in or adjacent to any areas of designated landscape quality.
3 or 4 Portakabin type buildings will normally be present on the site during operations. However, during long periods of nil activity these temporary buildings may be removed. In addition during final aircraft disposal a few covered skips will be present. 6 foot fencing will surround the site though it is not decided whether this will be of a fixed type of structure or mobile fencing or a combination of both.
KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report
During winter months there may be some illumination via a mobile lighting rig but this is in the context of close proximity to permanently lit aprons and hangars from which the additional impacts will be indistinguishable. However, the majority of processes require daylight so such events are likely to be few and far between.
In summary it is not considered that the proposed development will have any adverse visual impacts or effects on the surrounding landscape.
7. CONCLUSION In conclusion, the primary consideration is the potential impact on the soil and geology. However, this potential impact is mitigated by the design and the processes that KLMUKE must adhere to be issued with and maintain an EA ELV Permit. KLMUKE already works in a highly regulated environment so adherence to procedures to control contamination is considered normal within the organisation.
The proposed development at an existing airport will provide a purpose built environment enabling KLMUKE to continue and enhance its processes in harmony with the relevant legislation.
Using the flow diagram in Annex E it is our view that whilst this development does constitute a Schedule 2 project as described in the EIA Regulations, the nature of the development does not render it being within a sensitive area. Further it does not meet the criteria in column 2 of Schedule 2 because (i) there is no incineration, (ii) the area concerned is less than 0.5 hectare and (iii) the area is greater than 100 m away from, controlled waters. KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex A
KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex C
What do you do that can harm Managing the risk Assessing the risk and what could be harmed
What is the overall Hazard Receptor Pathway Risk Management Probability of exposure Consequence risk? What is the risk that What is at still risk? How can the remains? The What has the What do I hazard get What is the harm balance of potential to wish to the What measures will you take to reduce the risk? How likely is this that probability and cause harm? to protect? receptor? If it occurs ‐ who is responsible for what? contact? can be caused? consequence Discharges to Surface Water, Sewer and Groundwater
Draining of fuel and Surface, land Spillage of oils All liquids to be drained from aircraft while situated on the Low given mitigation Contamination of Low given mitigation hydraulic oil from or when removed, impermeable surface and with drainage system in temporary measures in place, and surface waters measures and aircraft when vehicle groundwater to ground or to 'locked down' sealed state. Defueling to take place by Pressure predictability of event. and/or ground. predictability of arrives on site. surface water defueling (sealed). Hydraulic oils and residual fuels to be drained event. drain. by dribble draining/gravity flow from designated sumps. Potential volumes of oil will therefore be predictable, and release is at a designated time and can be planned for. Containment receptacle positioned under sump to catch oil. Oil then stored in IBC's pending disposal or reuse. Defueling and draining supervised at all times. Spill kits available and all personnel trained in the use of them.
Small oil spillages Surface, land Release to Parts removal to take place on area with impermeable surface Very small amounts of Contamination of Very low risk. Small from aircraft as parts or drain and drainage provisions in place. Oil absorbants/mobile oil involved in this groundwater/land amounts of oil removed or groundwater system/ground. containment measures to be in place subject to specific risk operation. Activity /surface water. involved if any. maintenance carried assessment of component involved. Drip trays used under aircraft supervised and Activity supervised out. at all times. Spill kits available on site. Oil interceptor on surface predictable. and predictable. water system. Activities supervised at all times. Containment measures in place. KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex C
What do you do that can harm Managing the risk Assessing the risk and what could be harmed
Hazard Receptor Pathway Risk Management Probability of exposure Consequence What is the overall risk? What has the What is at How can the What measures will you take to reduce the risk? How likely is this What is the harm What is the risk that potential to risk? hazard get If it occurs ‐ who is responsible for what? contact? that still cause harm? What do I to the can be caused? remains? The wish receptor? balance of to protect? probability and consequence Discharges to Surface Water, Sewer and Groundwater (Continued)
Leaking of oils/liquids Surface, land Leakage of Vehicles to be stored on the permitted pan area which is an Unlikely given the Pollution of Low risk given the from waste vehicles or fuels during impermeable surface. Drainage system to be in 'lock down' purpose built groundwater/surfa nature of the stored on site prior to groundwater storage prior to sealed state. Waste vehicles are unlikely to be in a state of infrastructure ce water/land. vehicles involved, de‐pollution. de‐pollution. disrepair, as they will be flown in to the site in an airworthy state, arrangements, and the and the so leakage of fuels is only a small risk. De‐pollution to occur nature of the waste infrastructure in shortly after arrival at site, so vehicles will not be stored for long aircraft. place. periods in an un‐de‐polluted state.
Residual fuel Groundwater Run off from Recycling pan is purpose built with sufficient impermeable surface All aircraft will contain Contamination of Low given contained in shell of sealed drainage and a fall towards the centre of the pan. Drainage system to be in some residual liquids groundwater in a containment aircraft area to ground 'lock down' sealed state at all times that an aircraft is being that are released at this low sensitivity measures in place. when released recycled (see drainage management plan). Site staff are able to phase. As this is a area. during final predict when this event will occur during destruction and predictable event, it vehicle therefore event can be supervised. Oil absorbent materials and can be contained destruction. drip trays used to contain liquids in the concrete area, and to soak effectively to prevent up/remove from the surface. Volumes of liquid, and nature of release to the liquid released to be documented. environment. KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex C
What do you do that can harm Managing the risk Assessing the risk and what could be harmed
Hazard Receptor Pathway Risk Management Probability of exposure Consequence What is the overall risk? What has the What is at How can the What measures will you take to reduce the risk? How likely is this What is the harm What is the risk that potential to risk? hazard get If it occurs ‐ who is responsible for what? contact? that still cause harm? What do I to the can be caused? remains? The wish receptor? balance of to protect? probability and consequence Discharges to Surface Water, Sewer and Groundwater (Continued)
Release of wastes Surface, land Leakage from All materials to be stored within the permitted area on the pan or Unlikely given the Pollution of land, Low given mitigation stored on site or components/ hanger 6. All materials to be stored in containers fit for purpose. storage/containment surface water, or measures and site following removal groundwater containers to Oils/liquids to be stored in bunded tanks. Spill kits to be kept in measures that will be in groundwater. security measures in from vehicle, and ground or the vicinity of storage facilities. Wastes will only be stored for place. place. prior to dispatch surface water. short periods of time on site before removal. from site for disposal.
Contaminated run off Groundwater Run off from Area to be cleaned down following final destruction phase, and Low due to clean down Contamination of Low given mitigation from breaking area ground water prior to removal of 'lock down' sealed system state. Wash waters measures in place. groundwater measures. following removal of drain during to be removed via tanker and disposed of off site. water. sealed drainage rain. arrangement. KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex C
What do you do that can harm Managing the risk Assessing the risk and what could be harmed
Hazard Receptor Pathway Risk Management Probability of exposure Consequence What is the overall risk? What has the What is at How can the What measures will you take to reduce the risk? How likely is this What is the harm What is the risk that potential to risk? hazard get If it occurs ‐ who is responsible for what? contact? that still cause harm? What do I to the can be caused? remains? The wish receptor? balance of to protect? probability and consequence Discharges to Air/Land
Hazardous materials Contamination Inappropriate Appropriate management systems will be put into place to ensure These materials are Harm to human Low given the form contained in the of identification that hazardous materials are identified as being present on known to be present health and of these materials on infrastructure of the infrastructure and handling, aircraft before any removal of parts or destruction takes place. on aircraft to they are contamination of an aircraft, and the aircraft. and injury to and storage of Appropriate storage facilities to be provided for materials. Policy likely to be land handling systems in public. materials statements and procedures to be in place for identifying whether encountered. Members place on site. during any aircraft may have Radioactive Substances or asbestos. If they of the public unlikely to decommissioni do compliance with RAS to take place. All hazardous wastes to be be exposed if the ng identified, stored appropriately and disposed of in the correct necessary management manner. systems are in place, and appropriate handling of such wastes occurs on site.
Noise
Noise from vehicle People/other Air The recycling pan location is a long way from any sensitive Unlikely to have an Impact on amenity Not significant movements and areas of receptors both on the airport and from neighbouring properties impact given the or operations at machinery airport to the airport. The activities will also be carried out in working context of the works. site. hours thus reducing any potential impact.
KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex C
What do you do that can harm and what could be harmed Managing the risk Assessing the risk Hazard Receptor Pathway Risk Management Probability of exposure Consequence What is the overall risk? What has the What is at How can the What measures will you take to reduce the risk? How likely is this What is the harm What is the risk that potential to risk? hazard get If it occurs ‐ who is responsible for what? contact? that still cause harm? What do I to the can be caused? remains? The wish receptor? balance of to protect? probability and consequence Dusts/Litter/Odour/Pests
Dusts/Litter People/other Wind blown The perimeter of the permitted area around the pan where there Litter likely to be Impact on amenity Very Low remaining following areas of is a potential for litter will be fenced. The fencing will be of a generated during the or operations at decomissioning of airport construction to contain any airbourne litter. Litter to be picked process, but unlikely to site. aircraft from area on ongoing basis. Regular checks to take place for any be generated beyond interior/exterior litter that should escape fenced area. Perimeter checks and litter the exterior fencing. All picks to be carried out regularly, and more frequently in adverse litter contained within weather conditions if required. Works to strip interior of plane to the fencing can be take place internal to plane, materials will be bought out of plane easily removed. Area and placed in a container before being collected by 3rd party adjacent to external waste operator. fence to be checked for litter several times a day. Any litter arising in any of these areas will be removed. At the end of decommissioning, area to be brushed down and inspected. Odour from waste People/other Wind blown Materials handled are unlikely to emit odours. Site of operations Very unlikely that Impact on amenity Very Low areas of is a long distance from any sensitive receptors. odours will be emitted or operations at airport or give rise to amenity site. issues. KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex C
What do you do that can harm and what could be harmed Managing the risk Assessing the risk Hazard Receptor Pathway Risk Management Probability of exposure Consequence What is the overall risk? What has the What is at How can the What measures will you take to reduce the risk? How likely is this What is the harm What is the risk that potential to risk? hazard get If it occurs ‐ who is responsible for what? contact? that still cause harm? What do I to the can be caused? remains? The wish receptor? balance of to protect? probability and consequence Dusts/Litter/Odour/Pests Nuisance and Not significant Air and over harm to Scavenging Local human Very infrequently. land No food waste on site and the waste types handled are not human health animals and population attractive to scavenging animals or birds, therefore the risk is low. from scavenging Site Manager to address if situation arises. All crew food waste waste carried off birds placed in lidded wheely bin, and emptied frequently. site
and faeces.
Exceptional Occurrences
Unauthorised Bodily injury Direct physical Site is subject to airport security so unauthorised access highly Unlikely to happen as Uncontrolled access to site to contact unlikely. access to airport only release of wastes person or permitted with tight or injury to person animal security. Extremely low entering site, or vandalism of site. KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex C
What do you do that can harm and what could be harmed Managing the risk Assessing the risk Hazard Receptor Pathway Risk Management Probability of exposure Consequence What is the overall risk? What has the What is at How can the What measures will you take to reduce the risk? How likely is this What is the harm What is the risk that potential to risk? hazard get If it occurs ‐ who is responsible for what? contact? that still cause harm? What do I to the can be caused? remains? The wish receptor? balance of to protect? probability and consequence Exceptional Occurrences (continued)
Permitted area used Discharges to The area will be leased by KLM UK Engineering on a full time basis Site is highly unlikely to Pollution of Extremely low given Surface, land for other purposes surface water, and therefore there should not be an reason for other companies be used for other surface water, the area is leased on or when not being used land, and to be using the pan. The airport would liaise with KLM (permit purposes and any use groundwater or a full time basis and groundwater for aircraft groundwater. holder) before agreeing for area to be used for other purposes, so would be with prior land by activity out the shared interest of
destruction. that the permit holder can evaluate risk to environment from agreement from KLM. of operators permit holder and
activities. Permit holder to agree that activity should go ahead, KLM and the airport control. airport for not
and on what basis. are aware of the jeopardising integrity
drainage of permitted activity
arrangements, and on site.
impact of pollution from area. KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex D
Appendix 11 (to EA ELV Permit Application) Drainage Management Plan
Operator: KLM UK Engineering Ltd Site: Liberator Road, Norwich Airport, Norwich, Norfolk, NR6 6ER Grid reference: TG 22547 13558
PAGE 1 INTRODUCTION 2 2 ENGINEERING OF DRAINAGE SYSTEM 2 3 DRAINAGE AND AIRCRAFT STAGES 2 4 CONTAMINATED WATERS IN SEALED SYSTEM 5 5 CLEAN DOWN PROCESS 5 6 INTERCEPTOR MAINTENANCE PROGRAMME 5
KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex D
1 Introduction
This document is the written Drainage Management Plan for the aircraft recycling operations that are proposed to be conducted on a dedicated pan on Norwich International Airport. The proposed area to conduct the aircraft recycling has been purpose designed and built by qualified Civil Engineers and Contractors and the containment and management of spill, and protection of ground water has been central throughout the design process.
The operations have not commenced at the point of writing this document and therefore the Drainage Management Plan will be reviewed once operations have commenced to ensure that the Drainage Management Plan is appropriate to the operations.
This document should be read in conjunction with the Environmental Management System Summary1 which lays out the systems in place to comply with the conditions of the Environmental Permit and the Accident Management Plan2.
2 Engineering of Drainage System
The area where the aircraft recycling activity will be carried out has been purpose designed with the following features:
Hard standing constructed in steel fabric reinforced in‐situ concrete with sealed joints, to the consulting civil engineers specification for watertight construction Hard standing dished at approximately 1:80 cross fall to the centre Central drainage channel connected to outfall via a gate valve and full retention interceptor A sump with a removable metal grille, constructed as a down stand of the watertight reinforced concrete paving, amenable to visual inspection Hard standing area and system capable of holding a severe storm of 2 year return period
3 Drainage and Aircraft stages
There are distinct phases in the handling of aircraft on site and KLM UK Engineering will be handling airworthy aircraft and aircraft designated as waste on the pan. An aircraft status board3 will be available at all times to provide details of the aircraft on the pan and whether they are waste or not.
Irrespective of whether the aircraft is waste or not, KLM UK Engineering have a responsibility for the permitted area at all times and therefore must implement the
1 Environmental Management System Summary – Appendix 4 2 Accident Management Plan – Appendix 12 3 Aircraft Status Board – Held and controlled by the production support department KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex D same controls when the same works are being carried out on airworthy or waste aircraft.
De-polluting, defueling and final destruction will take place when dry weather is forecast, to avoid the generation of large volumes of potentially contaminated run off. Should unexpected rainfall occur during de-pollution or destruction, we will in the first instance cease operations. If we are unable to cease operations, or if ceasing operations will not avoid the generation of oil contaminated run off, the sealed sump arrangement will ensure that no potentially contaminated run off will escape to groundwater or aquifer by following the cleaning and disposal route highlighted in sections 3 to 9 below.
In the following table, references in the column headed “Gate Valve” have these meanings: Open = standard below ground gravity drainage system via full interception Class One petrol interceptor to ground disposal employing an infiltration trench Closed = temporary sealed drainage system held by closed gate valve
Work in progress Gate Comments Risk Valve
1 Pan empty and clean down Open Daily checks required Low process complete
2 Storage prior to defueling or Open All aircraft stored are airworthy and in Low de-pollution good order, undergoing weekly maintenance checks. Standard maintenance provisions in place.
3 Defueling Closed Bulk fuel Pressure defuel bowser. This High is a totally enclosed system used throughout the aerospace industry. This task is only completed by authorised personnel employing all necessary precautions. Any spillages on the hard standing reported immediately. If no spill, gate valve opened at conclusion of defueling. Any spillages on the hard standing that may enter the drainage system flow to the low point and collect in the sump, in which case, sump cleaned before gate valve is re- opened.
4 De pollution works Closed Hydraulic oils and any remaining fluid Med removed by draining hydraulic reservoirs and pipe work. This is a controlled process and the activity is supervised at all times. Use of specialist tools and drain pipes employed to KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex D reduce the risk of spillage and escaping fluids. Any spillages on the hard standing reported immediately. If no spill, gate valve opened at conclusion of de-pollution. Any spillages on the hard standing that may enter the drainage system flow to the low point and collect in the sump, in which case, sump cleaned before gate valve is re-opened.
5 Component recovery Closed Spillage containment measures in place Med i.e. drip trays and spill kits. Any spillages on the hard standing reported immediately. If no spill, gate valve opened at conclusion of component recovery. Any spillages on the hard standing that may enter the drainage system flow to the low point and collect in the sump, in which case, sump cleaned before gate valve is re-opened.
6 Storage following de- Closed Aircraft will be monitored daily. Med pollution and component Spillage containment measures in place recovery i.e. drip trays and spill kits. Any spillages on the hard standing reported immediately. If no spill, gate valve opened on a frequent basis to prevent sealed system filling up, as storage may be for a long period. Any spillages on the hard standing that may enter the drainage system flow to the low point and collect in the sump, in which case, sump cleaned before gate valve is re- opened.
7 Final destruction – dry day Closed Spillage containment measures in place Med i.e drip trays and spill kits. Any spillages on the hardstanding reported immediately. If no spill, gate valve opened at conclusion of destruction. Any spillages on the hardstanding that may enter the drainage system flow to the low point and collect in the sump, in which case, sump cleaned before gate valve is re-opened.
8 Final destruction – Closed Rain water accommodated by sump, up Med unexpected shower not to 7 cubic metres4. Spillage containment exceeding 5mm of rain measures in place i.e. drip trays and spill kits. Any spillages on the hard standing reported immediately. If no spill, gate valve opened at conclusion of
4 This measurement is approximate KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex D destruction. Any spillages on the hard standing that may enter the drainage system flow to the low point and collect in the sump, in which case, sump cleaned before gate valve is re-opened.
9 Final destruction – Closed The dished, watertight concrete slabs High unexpected thunder storm will hold over 35 cubic metres5, and considerable volumes corresponding to a two year return of rainfall period, 24 hour duration storm. However the collected water will be up to 250mm6 deep, and all dismantling operations sought to be postponed until the storm water can be proven clean and released to the ground.
4 Contaminated waters in sealed system
If oil contaminated run off is collected in the sealed drainage system, an outside contractor will be employed to suck the contaminated water out of the system and to tanker it away for disposal. The details of this event will be recorded on the Daily Environmental Check Sheet7.
5 Clean down process
At the end of the operations, the area will be swept clean of residual material. Oil absorbent granules will be used to soak up any residual oil. These will be swept up and removed from site as a hazardous waste.
The area will then be cleaned down using a hot pressure wash. Wash waters will then be collected in the sump and pumped to a suitable container. The contents of the containers will be disposed of at a registered facility.
The valve will be opened following this process.
6 Interceptor Maintenance Program
In compliance with PPG3, the interceptor will be subject to a maintenance program as follows:
Weekly – Check audible alarm working. – If there has been a spill, inspect interceptor for significant amounts of contaminant and if necessary employ 3rd party vacuum‐tanker and ensure no seepage into outlet drain
5 This measurement is approximate 6 This measurement is approximate 7 Daily Environmental Check Sheet – Controlled document No.UKE Form TBA KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex D Six-monthly – Lubricate threads on gate valves with very small amount of light grease. – Check for any signs of contaminants (oil) and remove if necessary – Check general condition of structure and gate valves. Repair as necessary.
In the event that contamination should escape into the surface water system beyond the sump, the interceptor will provide a secondary degree of containment. In this instance, a 3rd party vacuum tanker would be employed to suck out contaminated liquids. These liquids will then be taken off site for disposal. KLM UK Engineering Limited / Norwich International Airport Aircraft Dismantling Area – EIA Scoping Report Annex E
Environment, Transport, Development County Hall Martineau Lane Norwich NR1 2SG
Mr Phil Gadd NCC general enquiries: 0344 800 8020 Norwich International Airport Textphone: 0344 800 8011 Amsterdam Way Norwich NR1 6JA
Your Ref: PG/JCV/NCC140513 My Ref: C/4/2013/4001 Date: 12 June 2013 Tel No.: (01603) 222756 Email: [email protected]
Dear Mr Gadd
Norwich International Airport, Amsterdam Way, Norwich, NR6 6JA: Request for EIA Screening Opinion for Aircraft Dismantling Area: Phil Gadd
I refer to your letter of 14 May 2013 in which you requested a Screening Opinion in accordance with Regulation 5 of The Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (‘the EIA Regulations’) for the above development.
The proposed development is for an ‘Aircraft Dismantling Area’ within the existing Norwich International Airport. The development would comprise a 1700m 2 sealed concrete pad to the south/east of the main runways, near to the boundary of the airport, which would be laid in a shape to suit the footprint of the largest aircraft to be dismantled, and would represent a small fraction of Norwich Airport’s existing site. The scheme would also incorporate a surface water drainage system, and fencing to enclose the development. You have estimated that the site would deal with an average of 12 aeroplanes per annum (although up to 24 in any given year) with a maximum of throughput of 2,000 tonnes per annum.
Norwich Airport itself is located directly to the north of the Norwich and to the south of Horsham St Faith village. To the south of the application site, and beyond the airpot boundary, is the Hurricane Way Industrial Estate. The site is not located within or adjacent to any Site of Special Scientific Interest (SSSI), Special Area of Conservation (SAC), Special Protection Area (SPA) or Ramsar Site. The site is not considered to be within a sensitive area in any other respect although it is recognized it situated 3.8 kilometres from the River Wensum SAC (and SSSI) and 4.4 kilometres from Broadland SPA/The Broads SAC/Broadland Ramsar site/Crostwick Marsh SSSI.
The development does not fall within Schedule 1 of the EIA Regulations.
Continuation sheet to: Mr Gadd Dated : 12 June 2013 -2-
As recognized in your letter, the proposed development would fall within paragraph 11(b): Installations for the disposal of waste of the EIA Regulations. In terms of the applicable thresholds and criteria, it is understood incineration would not form part of the process, and the site area at circa 1700metres 2 would not exceed 0.5 hectare. With regard to controlled water, the site would not be within 100 metres of inland freshwaters although it is more than likely to be in 100 metres of groundwater given Norfolk’s geology. I have taken a precautionary approach here and assumed it is meaning that this development meets the thresholds and criteria in Schedule 2.
In accordance with regulation 4(6) of the EIA Regulations, I have taken account of Schedule 3 in determining whether the proposal would require an EIA. Under Schedule 3, the matters to be considered are the characteristics of the development, the location of the development, and the characteristics of the potential impacts.
In terms of the characteristics of the development, the size of the development would be small in the context of the surrounding airport and accordingly it is not considered that there would not be an unacceptable cumulative impact given the surrounding land uses in terms of both the rest of the airport and neighbouring industrial estate.
Because of the nature of the wastes that would be accepted on site (i.e. predominantly non-hazardous wastes), it is not anticipated that there would be an unacceptable risk of pollution and nuisances occurring providing the site is operated to the standards required by the relevant pollution control authority. It is not considered that there would be a high risk of accidents when considering both the wastes treated and the dismantling process proposed.
With regard to the location of the scheme, this nature development would be consistent with the rest of immediate surrounding land use which includes both the airport itself and the industrial area to the south. There would not be a significant impact on the landscape given that building work would be restricted to a concrete pad and drainage scheme. The site is not within a sensitive area in respect of any of the other areas or land uses listed under paragraph 2 of Schedule 3 of the EIA Regulations. Whilst the site is relatively near a densely populated area to the south, it is felt the level/intensity of the operation would not create significant impacts given both the context of the site at an existing airport, and that the operation would be subject to environmental controls in terms of an Environmental Permit.
In terms of the characteristics of the potential impacts, and most notably noise, which could occur when the aeroplanes land or during the final phase of cutting up the aircraft, this would be short in its duration, and infrequent, given the proposed throughput of aeroplanes. Again these impacts would be local in their nature and would be restricted to the neighbouring land which is itself largely used for industrial purposes. Furthermore, it is not felt that any impacts would occur to a great extent.
Continuation sheet to: Mr Gadd Dated : 12 June 2013 -3-
Finally, I have also had regard to paragraph A36 of Annex A to Circular 02/99: ‘Environmental Impact Assessment’. This provides further guidance on screening planning applications for installations for the disposal of non-hazardous waste, and it advises that EIA is more likely to be required where new capacity is created to hold more than 50,000 tonnes of waste per year, or to hold waste on a site of 10 hectares or more. My conclusion that EIA is not required is consistent with this approach albeit this scheme does propose to accept a small element of hazardous waste in addition to non-hazardous waste. As you also recognized in your letter, paragraph A25 of this Circular states that smaller scale development at existing airports in unlikely to require EIA unless it would lead to significant increases in air or road traffic (which this would not).
It is therefore concluded, in consultation with statutory consultees, that EIA is not required in this instance for the development proposed given that it is not considered that there would be significant impacts. Notwithstanding this, an application of this nature will need to be accompanied by sufficient information to ensure all relevant issues are adequately addressed.
Below is a link to the County Council’s Local List in terms of information requirements for planning applications: http://www.norfolk.gov.uk/view/NCC121467 .
If you have any queries please do not hesitate to contact me.
Yours sincerely
Ralph Cox Principal Planner (Development Control)