Local Development Plan Main Issues Report Representations East

Kris Furness SITA UK 24/03/2014 Project Quality Assurance Information Sheet

Aberdeen Local Development Plan, Main Issues Report Representations Altens East

Report Status: FINAL

Report Date: March 2014

Prepared by: Kris Furness SITA UK Assistant Planning Manager

Main Kris Furness Contributors: SITA UK Assistant Planning Manager

Reviewed by: Carol Jacques SITA UK Senior Bid Manager

Peter Lawrence Aberdeen City Council Waste and Recycling Manager Contents EXECUTIVE SUMMARY...... ii REPRESENTATIONS...... 1 1. INTRODUCTION...... 1 2. BACKGROUND AND NEED...... 4 3. THE SITE AND PROPOSAL...... 12 4. POTENTIAL ENVIRONMENTAL IMPACTS...... 24 5. PLANNING POLICY...... 26 6. ALTERNATIVES ...... 32 7. CONCLUSIONS...... 37

Drawings 5125176/C/P/200 Rev 05 - Site Layout, MRF, RDF & Depot

Page i of ii Aberdeen Zero Waste Project – Planning Appraisal, Altens East EXECUTIVE SUMMARY

This development plan representation has been prepared by SITA UK with the assistance of Aberdeen City Council Waste and Recycling Department (ACCWRD) as part of the Aberdeen Zero Waste Project (AZWP). It requests that the forthcoming Aberdeen Local Development plan includes the allocation of additional land adjacent to the existing Altens East, Opportunity Site 70 / OP70 designation. This additional land would be used for the co-location of a depot with the already allocated waste management facilities.

This representation has followed a significant period of evaluation and assessment for the potential development of waste management facilities in Aberdeen City. There is a clear and identified need for new waste management infrastructure to manage municipal wastes and achieve statutory targets and comply with relevant legislation. Significant benefits can also be realised by co-locating the depot on the same site was the waste management facilities and there is an identified need to relocate the depot due to the Berryden Corridor proposals. However, the existing Altens East ‘OP70’ site is too small for the development of priority waste facilities and the depot.

This document demonstrates that there are no viable alternative sites available for the development of the co-located facilities in the City. Furthermore, taking account of the existing Altens East ‘OP70’ designation for waste management infrastructure which has established the principle of development of the bordering land, SITA UK and ACCWRD consider that the extension of the designation would be unlikely to result in significant impacts on the environment.

Taking these factors into consideration, SITA UK and ACCWRD request that this representation to extend the Altens East ‘OP70’ allocation is given full support and included within the forthcoming Aberdeen Local Development Plan.

Page ii of ii Aberdeen Zero Waste Project – Planning Appraisal, Altens East REPRESENTATIONS – ALTENS EAST

1. INTRODUCTION

1.1. This representation has been prepared by SITA UK with the assistance of Aberdeen City Council (ACC) Waste and Recycling Department (WRD).

1.2. SITA UK is ACC’s Waste Management Services Contractor (WMSC) and is responsible for the management of waste in Aberdeen City and the operation of the required waste management facilities.

1.3. As part of the WMSC, SITA UK has been working with ACCWRD on a project known as the Zero Waste Management Project (ZWMP). ACCWRD have established this project with the intention of developing infrastructure for the sustainable management of municipal waste in the city.

1.4. The primary aim of the project was to identify one site which would be capable of containing several new waste strategic management facilities, including an Energy from Waste plant (EFW) Materials Recycling Facility (MRF) and an In- Vessel Composting (IVC) or Anaerobic Digestion plant (AD).

1.5. Some of the above infrastructure, such as the MRF is required immediately in order to comply with formal targets and legislation. The EFW is a longer term project, but in order to deal with municipal residual waste (‘black bag’ waste that remains after recycling) an interim measure is planned to divert the material from landfill in the meantime.

1.6. This interim measure is known as a Refuse Derived Fuel (RDF) plant. RDF is a process where the municipal residual waste is processed in order to create a fuel. This fuel can then be exported to an appropriate facility elsewhere to recover energy from the material.

Page 1 of 38 Aberdeen Zero Waste Project – Representations, Altens East 1.7. The RDF facility would recover energy from residual wastes until such a point as ACC could deliver a standalone EFW or identify an alternative long term solution. This would drive the waste up the hierarchy and provide a more sustainable solution than continued landfilling.

1.8. Following a review of the market, the primary target of identifying one suitable, available and viable site capable of delivering all of the facilities within the City has been unsuccessful. The ZWMP has, therefore, resolved to proceed with the identification of a site suitable for the immediate delivery of the MRF and RDF plant.

1.9. A site suitable for the development of these facilities has already been allocated within the existing Aberdeen Local Development Plan (ALDP). The site is referred to as ‘Altens East’ – ‘Opportunity Site 70’ or ‘OP70’. It is located at the edge of the established Altens industrial estate and adjacent to Peterseat Employment Park.

1.10. As part of the ZWMP, it was also identified that significant efficiencies and savings can be generated by co-locating the ACC vehicle depot, which is currently located at , on the same site as the new waste management infrastructure.

1.11. The present ACC vehicle depot is located on land that will be redeveloped as part of the Berryden Corridor works associated with the the new third River Don crossing. It is, therefore, necessary to develop an alternative depot within the same timeframe as the waste facilities.

1.12. Due to the development footprint of the MRF and RDF, it is not possible to accommodate these facilities and the depot on the existing Altens East ‘OP70’ allocation (around 2.9 hectares). Therefore, the purpose of this representation is to request the allocation of additional surrounding land, totalling approximately 1 hectare within the forthcoming ALDP for the development of

Page 2 of 38 Aberdeen Zero Waste Project – Representations, Altens East the depot on the same site, in order to realise the benefits and efficiencies identified.

1.13. These representations detail the background for the project along with justification for the designation of additional land at Altens East for the depot.

Page 3 of 38 Aberdeen Zero Waste Project – Representations, Altens East 2. BACKGROUND AND NEED

2.1. In April 2010, ACC adopted the Aberdeen City Waste Strategy 2010-2025 (ACWS). The document “provides a statement of the key outcomes for all waste management in the city for the next 15 years and provides a framework for the development of the next generation of waste infrastructure and services”.

2.2. The key driver of ACWS is to move the city from a position where materials are landfilled to one where they should be put to some form of beneficial use, in accordance with European, National, Regional and Local targets and relevant legislation.

2.3. Section 4.22 in ACWS highlights the waste production in Aberdeen at the time of publishing (2007/2008 figures). This highlights that Aberdeen produced 138,459 tonnes of Municipal Solid Waste (MSW) – waste that falls under the control of a local authority, such as that produced by households, taken to Household Waste Recycling Centres (HWRC), street cleaning and litter etc.

2.4. Of the 138,459 tonnes collected in 2007/2008, 107,658 (77.8%) was landfilled and 30801 tonnes (22.2%) was recycled or composted. The most recent figures which can be directly compared are from 2010/2011, in this period Aberdeen had a total collection of 118,049 tonnes, with 80,578 tonnes (68.3%) landfilled and 37,471 tonnes (31.7%) recycled or composted.

2.5. The reporting definitions changed from 2011 and it is difficult to directly compare with the previous figures, nonetheless, the most recent available data for the 2012 calendar year indicates that Aberdeen had total household waste arisings of 97,242 tonnes, which was broken down into 60,988 tonnes landfilled (62.7%) and 36,242 tonnes (37.3%) recycled or composted.

2.6. The above figures demonstrate that some progress is being made on driving waste up the hierarchy and reducing disposal. However, the best performing Page 1 of 38 Aberdeen Zero Waste Project – Representations, Altens East authorities were recycling/composting up to 58.9% of their materials in 2012 and the average for Scotland was 41.2%. ACC are keen to make further improvements in the short term.

Drivers for Change

2.7. There are a wide variety of drivers for change in the waste management industry including regulatory, financial and national, regional and local waste policies.

2.8. Regulatory issues include those such as the European Union (EU) ‘Waste Framework Directive’ and ‘The Waste (Scotland) Regulations 2012’. This legislation introduced statutory measures and targets which, in turn, drives the need to deliver modern infrastructure:

 A target of 50% MSW recycling and composing by 2020 (Waste Framework Directive);  A ban on any metal, plastic, glass, paper and card collected separately for recycling from going to incineration or landfill from 2014 (The Waste (Scotland) Regulations 2012); and  A ban on biodegradable municipal waste going to landfill by the end of 2020 (The Waste (Scotland) Regulations 2012).

2.9. The main financial incentive which has an impact on waste management is landfill tax, which is paid on all active waste sent to landfill and is set to increase to £80 per tonne in April 2014. ACC paid over £5 million in landfill tax in 2013 alone, funds which could be set against the development of new infrastructure with associated environmental and social benefits.

2.10. In terms of national waste policies, the major driver in Scotland is the Zero Waste Plan (ZWP). The ZWP sets out a vision where all waste is seen as a resource, waste is minimised, disposal to landfill is reduced and most

Page 2 of 38 Aberdeen Zero Waste Project – Representations, Altens East materials are sorted and recycled/re-used, leaving only a small amount to be treated.

2.11. The ZWP sets out several targets which are to be implemented through ‘The Waste (Scotland) Regulations 2012’ and future legislation. It outlines that recycling rates of waste arising from households should reach 50% by 2013, 60% by 2020 and 70% by 2025. In addition the document states that no more than 5% of all waste should be directed to landfill by 2025.

2.12. The need for waste management infrastructure is stressed throughout national planning policy. National Planning Framework 2 (NPF2), which was published in 2009, highlights the importance that the Scottish Government are placing on the development of waste infrastructure stressing:

“Development of the necessary infrastructure is a Government Priority” (NPF 2 Para 166)

2.13. The Proposed NPF 3 was laid in the Scottish Parliament on 14 January 2014 and is subject to parliamentary scrutiny for a 60 day period until 24 March 2014. The document highlights the target of 70% recycling by 2020.

2.14. The adopted Scottish Planning Policy (SPP) highlights that the Scottish Government has adopted Zero Waste as a policy goal and notes that this will require both a reduction in waste production and also a significant increase in waste management infrastructure. The document also stresses that the planning system has a crucial role to play in delivering this infrastructure:

“A significant commitment to enabling the development of new waste management infrastructure through the planning system is required.” (SPP Para 212)

2.15. In addition, the forthcoming SPP highlights that the planning system should:

Page 3 of 38 Aberdeen Zero Waste Project – Representations, Altens East  “Support the delivery of new waste management infrastructure needed to increase capacity to manage all waste sustainably;  Contribute to the achievement of Scotland’s Zero Waste targets” (Proposed SPP Para 249)

2.16. National policy and targets feed down into ‘regional’ and local policies. Aberdeen City and Shire Structure Plan (the Structure Plan) was published in August 2009 with the aim of setting a direction for the future of development of Aberdeen City and Aberdeenshire. It is anticipated that it will be replaced by Aberdeen City and Shire Strategic Development Plan in March 2014.

2.17. The Structure Plan highlights the need for new waste management infrastructure and includes a target that no more than 54,000 tonnes of biodegradable municipal waste shall be landfilled by 2020. This has now been superseded by the total ban set out in ‘The Waste (Scotland) Regulations 2014’.

2.18. Aberdeen City and Shire Strategic Development Plan – Proposed Plan February 2013 (the Strategic Development Plan) has been developed from the Aberdeen City and Shire Structure Plan 2009. The document is currently undergoing examination and is anticipated to be approved by Scottish Ministers, with amendments, in spring 2014.

2.19. The Strategic Development Plan highlights the requirement for investment in waste management infrastructure such as recycling, composting and energy from waste and notes that this should be directed towards the strategic growth area close to Aberdeen or in Aberdeen (see Figure 2.1). Furthermore the Strategic Development Plan notes that the objective is to meet waste management needs locally to ensure that value is retained in the local area and the environmental impacts of transport are kept to a minimum. This aspect is particularly relevant to these representations which aim to co-locate the council depot with the waste management facilities in order to further reduce transport impacts.

Page 4 of 38 Aberdeen Zero Waste Project – Representations, Altens East 2.20. Paragraph 4.15 of the Strategic Development Plan identifies that there is a need for around 300,000 tonnes of waste treatment capacity and this is one of the key targets set out further within section 4.0 of the document.

Figure 2.1 – Strategic Growth Areas.

2.21. The adopted ALDP provides a framework for the strategic development of Aberdeen City and policies which need to be taken account of when determining planning applications.

2.22. ALDP recognises the need for new waste infrastructure in accordance with the requirements set out in ACWS. At paragraph 3.98 the document highlights that the following facilities are required to deal with municipal waste:

 A Materials Recycling Facility;  An anaerobic or in-vessel composting facility; and  A new transfer station.

Page 5 of 38 Aberdeen Zero Waste Project – Representations, Altens East 2.23. Policy R4 safeguards sites for new waste management facilities and includes the Altens East ‘OP70’ site, to which this representation relates. The site is safeguarded for “materials recycling facility/an anaerobic digestion or in- vessel composting facility/ and or a transfer station.

2.24. There is, therefore a clear and demonstrable need for new waste management facilities within Aberdeen City and policy support for development at Altens East ‘OP70’.

Infrastructure Requirements

2.25. Following the adoption of ACWS, ACC developed the ZWMP and established a Zero Waste Management Sub-Committee (ZWMSC).. The role of the ZWMSC is to be the key decision makers for the project. The sub-committee consists of a core group of members from various parties and will decide on the delivery of major service change and infrastructure delivery.

2.26. In 2011/2012 ACC undertook an options appraisal on collection and treatment. The appraisal identified that the best method for collecting recyclable wastes in the city was by a process known as ‘co-mingling’ where all recyclables are placed into one container by the householder and then separated using mechanical and optical systems at a MRF. It was concluded that this solution should be developed in Aberdeen in order to ensure that the maximum value from the recycled products was retained in the City.

2.27. Upon completion of the options appraisal and following recommendations made by the ZWMSC, in April 2012 an Outline Business Case (OBC) was undertaken to assess the best means of implementing the services identified. In Oct 2012 the OBC was presented to ZWMSC and subsequently the following recommendations were approved by full Council:

“Adopt the following reference case, further defined in the OBC as the reference for the next phase of the Zero Waste Management Project: Page 6 of 38 Aberdeen Zero Waste Project – Representations, Altens East  Construct a new, local windrow composting plant delivered within Waste Management Services Contract;  Construct a new, local In-Vessel Composting plant delivered within Waste Management Services Contract;  Construct a new, local MRF (inc. glass) delivered within Waste Management Services Contract;  Construct facilities for the interim export of waste, delivered within Waste Management Services Contract; and  Resolve site, planning and financing issues and procure a new Energy from Waste (EFW) facility in Aberdeen for delivery around 2020.”

2.28. Further to the above, a key additional activity identified in the OBC recommendations was the need to develop a RDF facility in Aberdeen as an interim alternative to landfill.

Council Depot

2.29. The current ACC depot is located off the A96 at Kittybrewster in an area known as the Berryden Corridor (see figure 2.2). The depot contains all of the vehicles associated with ACC municipal waste collection along with other environmental services and general ACC fleet.

2.30. The Berryden Corridor is a busy route which presently suffers from significant congestion. As part of the ‘Third Don Crossing’ and ‘Access from the North Proposals’ it will become an increasingly important part of the road network. Therefore, plans have been prepared for improvements which include dualling / realignment. Phase 1 of the project has been awarded funding for construction and a detailed programme is awaited.

Page 7 of 38 Aberdeen Zero Waste Project – Representations, Altens East Figure 2.2 – ACC Kittybrewster Depot

2.31. The Berryden Corridor proposals result in the loss of a significant area of the ACC depot to the new road footprint (see figure 2.3). As a result it is essential to identify a new depot as soon as possible.

2.32. At the present time, Refuse Collection Vehicles (RCV’s) located at the depot exit the site in the morning to begin collection rounds, the vehicles then need to dispose of their loads several times a day at the relevant WTS, before returning to the depot in the evening.

2.33. There are, therefore, several benefits associated with co-locating major waste and recycling infrastructure with the depot, including:

 Reduction in road miles - as the RCV’s would be based at the final disposal point, this would eliminate the journey from the final WTS to the depot, reducing costs, carbon footprint and emissions; and  Increased efficiency - as a result of removing the final journey as outlined above around 30 minutes could be saved on some collection routes.

Page 8 of 38 Aberdeen Zero Waste Project – Representations, Altens East Figure 2.3 – Berryden Corridor Proposals

2.34. The advantages of co-locating the depot and waste management infrastructure were reported to the ZWMSC in April 2013. The recommendation of the ZWMSC following this report was to undertaken further work to identify a suitable site for the co-location of facilities.

2.35. Taking account of the above factors it is practical and prudent to identify a site for development which allows for the co-location of waste management infrastructure and the depot.

Site Identification

2.36. ACC developed an initial criteria for municipal waste infrastructure and undertook a site search with planners and asset management. In parallel with this process, the development sector in Aberdeen was asked to submit expressions of interest in February 2013 against the Council’s requirement.

2.37. The site search process resulted in a total of 11 sites being presented to ZWMSC for consideration, including a small selection from the development sector.

Page 9 of 38 Aberdeen Zero Waste Project – Representations, Altens East 2.38. Following this process, ZWMSC recommended that officers undertake further work to select a preferred site for an EFW, MRF, Depot and, if in the north of the city a new Household Waste Recycling Centre (HWRC). From the 11 identified, the following sites were to be considered in more detail:

 The Core, Aberdeen, Beryhill, ;  Duffshill, Portlethen; and  Drive (OP32).

2.39. Furthermore, ACC officers were instructed to consider alternative sites that may become available during the process and report back to ZWMSC.

2.40. The three sites outlined above were all considered but progressively withdrew from the process by September 2013. This left none of the sites from the identification process available for a shared facility containing the entire specified infrastructure.

2.41. Following a report to the ZWMSC in October 2013 the site search was reconfigured to include land suitable for the development of the priority infrastructure - the MRF, RDF and depot. Further work was then undertaken to identify a site for these facilities.

2.42. The site search included a review of the previously submitted sites and also any new sites which may be considered. At this stage, the Altens East, ‘OP70’ site was identified as the most viable, as it is within ACC ownership and has a designation for waste uses within ALDP.

2.43. The main outstanding issue was that there was insufficient land to develop the depot within the existing allocation. However, adjacent land which has not been allocated for development within ALDP is developable and within ACC ownership and should this land be included within the development footprint, it would create a suitably sized site for all of the facilities to be co-located.

Page 10 of 38 Aberdeen Zero Waste Project – Representations, Altens East 2.44. In December 2013 a further report with recommendations was presented to the ZWMSC and subsequently referred to and approved by Finance, Policy and Resources committee.

2.45. The key recommendation reported in the minutes to the ZWMSC meeting in relation to site selection was:

“That the Sub-committee approves the selection of land at an undisclosed location or locations for the development of a Materials Recycling Facility, the Waste Collection Depot and a Refuse Derived Fuel Production Facility.”

2.46. ACC officers have confirmed to SITA UK that the undisclosed location referred to in the report is the Altens East ‘OP70’ allocation to the Coast Road.

Page 11 of 38 Aberdeen Zero Waste Project – Representations, Altens East 3. THE SITE AND PROPOSALS

Existing Altens East ‘OP70’ Allocation

3.1. The Altens East ‘OP70’ allocation is a greenfield site at the edge of Altens industrial estate, located approximately 2 km south of Aberdeen City Centre (see figure 3.1). As aforementioned, the site has already been safeguarded for the development of waste management infrastructure and the principle of development here is, therefore, established.

Figure 3.1 – ALDP OP70 Designation, Altens East

3.2. The current Altens East ‘OP70’ designation extends to 2.9 hectares as illustrated in figure 4.1. The site is currently put to occasional agricultural use by the adjacent Doonies Rare Breeds Farm which is located to the north. Doonies Rare Breeds Farm is a working farm and also a visitor attraction with

Page 12 of 38 Aberdeen Zero Waste Project – Representations, Altens East some educational facilities. The direct surroundings are illustrated in Figure 3.2.

3.3. Doonies Rare Breeds Farm is the nearest sensitive receptor to the Altens East ‘OP70’ designation, with a network of footpaths which run partially along the northern boundary between Altens East ‘OP70’ and the farm. It is also understood that the buildings on the farm site contain a dwelling which would be the nearest residential receptor, at approximately 200 metres from the Altens East Boundary.

Figure 3.2 - Altens East Context

3.4. To the south of the site there is an existing industrial development on Hareness Place known as Swire Oilfield Services, which involves container storage and distribution for the offshore industry. Further south is the established Altens Industrial estate with a variety of industrial uses.

3.5. The western boundary of the existing Altens East designation rises quickly up to the Peterseat employment park where there are several industrial and employment uses. Page 13 of 38 Aberdeen Zero Waste Project – Representations, Altens East 3.6. To the east of the site, there is further agricultural land outside of the Altens East ‘OP70 designation’, followed by the Coast Road, which is a single carriageway. The main rail line runs parallel to the Coast Road and part of the network of ‘Core Paths’ (footpaths) pass between the rail line and the coast.

Proposed Altens East ‘OP70’ Extension

3.7. The existing Altens East ‘OP70’ allocation is sufficiently sized for the development of the MRF and RDF facilities, however, it is the co-location of the depot which requires the additional footprint and is the subject of this representation.

Figure 3.3 – Outline Site Layout

Page 14 of 38 Aberdeen Zero Waste Project – Representations, Altens East 3.8. SITA UK and ACCWRD have developed several layouts for the site including the MRF, RDF and depot. The current ‘outline layout’ is illustrated on drawing 5125176/C/P/200 Rev 05, ‘Site Layout, MRF, RDF and Depot’ and figure 3.3.

3.9. It is important to stress that a significant amount of further design and consultation would be undertaken prior to developing any final proposals for the site, however, this does provide a practical representation of the layout and the required footprint of the different facilities.

3.10. The proposal has been developed through a detailed analysis of the waste stream collected in Aberdeen and the equipment required to process this.

3.11. A MRF is a facility which receives mixed recyclable materials and processes these through a variety of sorting equipment. Essentially mixed recyclable materials, for example cans, glass bottles and plastic bottles are loaded into the equipment at the beginning and the output is individual streams of each material which can be exported to a re-processor.

3.12. In the case of the MRF, the footprint of the facility is determined by the amount of equipment that is required to segregate the materials. Generally speaking, for greater levels of segregation, more equipment will be required and the larger the facility will be.

3.13. Similarly, an RDF facility processes municipal residual waste into a fuel which can be exported to an appropriate facility for energy recovery. This requires a certain specification of equipment/infrastructure and determines the building footprint. Some efficiency has been achieved by combining the two facilities within the same building footprint.

3.14. Working with ACC Roads department and based upon the specification set out for the infrastructure at the existing depot at Kittybrewster, it has been possible to determine a footprint for the proposed depot.

Page 15 of 38 Aberdeen Zero Waste Project – Representations, Altens East 3.15. When combined with the MRF and RDF, taking account of the shared infrastructure such as access roads and landscaping the total site area required for the development is approximately 4 hectares (10 acres). This is an additional 1.1 hectares compared to the existing Altens East ‘OP70’ allocation. As illustrated by figure 3.3, it is clear that it is only the depot which can not be accommodated on the existing Altens East ‘OP70’ designation.

3.16. SITA UK and ACCWRD, therefore, propose that the Altens East ‘OP70’ designation is extended to include approximately 1.1 hectares of land between the site and the Coast Road. This land is currently adopted green belt within ALDP and the approximate extension is illustrated in figure 3.4. The additional land is within the ownership of ACC.

Figure 3.4 – Proposed Altens East Extension

3.17. As demonstrated by drawing 5125176/C/P/200 Rev 05, ‘Site Layout, MRF, RDF and Depot’ and figure 3.3, the waste management infrastructure would be located within the current designation towards the west of the site, furthest Page 16 of 38 Aberdeen Zero Waste Project – Representations, Altens East away from the Coast Road. As aforementioned, the principle of development on this Altens East ‘OP70’ designation has already been established.

3.18. The extension of the site allocation would allow the depot to be located towards the eastern boundary. Much of the land required by the depot is for ground level parking rather than physical structures. The proposal can, therefore, be developed to include landscape and screening proposals to the eastern boundary with the Coast Road to limit the impact of this parking when viewed from outside of the site.

3.19. Based upon the current layout, approximately 30% of the additional 1 hectare of green belt land has been proposed as landscaping (see drawing 5125176/C/P/200 Rev 05, ‘Site Layout, MRF, RDF and Depot’). A significant corridor of landscaping has been retained between the proposed extension and the coast road.

3.20. No screening or landscape proposals have been developed at this early stage but this would be subject to significant assessment as the project progresses. However, it is important to highlight that the principle of developing on the existing Altens East ‘OP70’ allocation has already been established and would be likely to include a requirement for screening and landscaping from the coast road. This proposed extension would require the same level of screening.

3.21. Consideration has been given to the use of a multi-storey car park to condense the parking area required by the depot, however, it would not be possible to assess the impacts of this until the detailed design stage. A multi storey car park may reduce the footprint of the parking, but it would be a physical structure of some height and would, therefore, be much more difficult to screen and it would also be significantly more expensive than ground level parking. Should the project progress, this would be investigated in more detail at future stages, however, for the purposes of the current process the most sensible option is to request the land required for the outline site layout.

Page 17 of 38 Aberdeen Zero Waste Project – Representations, Altens East 3.22. SITA UK and ACCWRD are currently identifying the ownership of small parcel of land to the west of the site. This land currently rises steeply to the Peterseat Employment Park, however, should the land be available and development be practical and viable, it may allow the physical development to move further towards the west. This would provide additional footprint for landscaping and screening at the east of the site.

3.23. As previously outlined, there is an existing industrial use to the south (Swire Oilfield Services) and Doonies Rare Breeds farm to the north, therefore, it is not possible to extend the site in either of those directions.

Figure 3.5 – Turning Head on Hareness Place

3.24. Furthermore, the determination of any planning application for the site would include the need for assessment of any potential impacts on the environment, such as landscape and visual. There is a commitment from SITA UK and ACCWRD to develop the design taking account of these sensitivities. Page 18 of 38 Aberdeen Zero Waste Project – Representations, Altens East 3.25. As demonstrated by drawing 5125176/C/P/200 Rev 05, ‘Site Layout, MRF, RDF and Depot’ and figure 3.3, access to the site will be taken from Hareness Place to the south, where there is an existing turning head (see figure 3.5). This would apply to access to the existing Altens East, ‘OP70’ allocation and the proposed extension.

3.26. SITA UK and ACCWRD are aware of the potential expansion of Aberdeen Harbour as identified as a national development within the draft NPF.

Figure 3.6 – Aberdeen Harbour Coast Road Access

Page 19 of 38 Aberdeen Zero Waste Project – Representations, Altens East 3.27. At the present time, Aberdeen Harbour have identified expansion into Nigg Bay as the proposed facility. This option would potentially involve the use of the coast road as the main strategic access (see figure 3.6).

3.28. The Aberdeen Harbour, ‘Case for Growth’ document notes that the Coast Road would require improvements and widening in areas in order to accommodate the proposed traffic. There is no reason that the allocation of additional land at Altens East would prejudice this development, however, SITA UK and ACCWRD would work with Aberdeen Harbour to ensure that any proposals are complementary.

Page 20 of 38 Aberdeen Zero Waste Project – Representations, Altens East 4. POTENTIAL ENVIRONMENTAL IMPACTS

4.1. As previously outlined, the existing Altens East ‘OP70’ designation has already been designated for waste management uses and the principle of development has, therefore, been established. This section only considers the potential impacts of the allocation of additional green belt land for the development of the depot.

4.2. The overall potential impacts of any proposed development at the site would be assessed comprehensively at planning application stage and would include consideration of issues such as landscape and visual impact, biodiversity, cultural heritage and transport impact.

Transport

4.3. The inclusion of the depot within the site is the primary reason for the requirement to extend the development allocation.

4.4. The co-location of the depot with the facilities will have some additional ‘local’ impact. As traffic associated solely with the depot, such as staff transport to and from work and vehicles not associated with waste collection would be accessing the site. However, these movements are already on the wider road network in Aberdeen related to the depot at Kittybrewster. Furthermore, as aforementioned, the proposal to co-locate the facilities removes the need for collection vehicles to undertaken the final journey from disposal point back to the depot, reducing road miles overall.

4.5. The transport impact over and above the current allocation, is therefore, not considered to be significant. Nevertheless, transport impact would be assessed comprehensively through any planning application for the development of the site.

Page 21 of 38 Aberdeen Zero Waste Project – Representations, Altens East Landscape and Visual Impact

4.6. The allocation of the additional green belt land for the development of the depot would result in the physical development being brought closer to the coast road than envisaged by the current ALDP.

4.7. The current ‘outline site layout’ illustrates approximately 30 metres of additional built development into the green belt, with further land set aside for landscaping (see drawing 125176/C/P/200 Rev 05, ‘Site Layout, MRF, RDF and Depot’).

4.8. As detailed within the previous section, most of the development associated with the depot is ‘ground level’ comprising of vehicle parking or landscaping.

Figure 4.1 – View towards Altens East from Coast Road to the South

4.9. The land surrounding the site rises and falls significantly and this, along with existing landscape features, has a significant impact on visibility. Approaching Altens East from the south along the Coast Road, the site is not prominently

Page 22 of 38 Aberdeen Zero Waste Project – Representations, Altens East visible due to the landform, existing industrial estate development and the bund to the south west of the site (see figure 4.1).

4.10. From the north, the land rises up to the existing Doonies Rare Breed Farm and the site is only clearly visible once passed the farm (see figure 4.2).

Figure 4.2 – View towards Altens East from north of Doonies Farm

4.11. Altens East is clearly visible from Coast Road directly to the east of the site, where the land is generally at the same elevation and there are no landscape features interrupting views (see figure 4.3).

4.12. However, because the land shares the same elevation at this point, land uses would be screened from the road relatively easily by the use of earth bunding or other landscape features. Furthermore as previously highlighted, the depot uses are generally at land level and are more easily screened than significant buildings such as the waste management infrastructure which will be occupying the existing Altens East ‘OP70’ designation.

Page 23 of 38 Aberdeen Zero Waste Project – Representations, Altens East 4.13. Landscape and visual impact would be comprehensively assessed throughout the design process associated with any planning application. This would be likely to include evaluation of different layout options on the site, photomontages and detailed landscape screening proposals and mitigation where necessary.

4.14. Overall, it is evident that while landscape and visual impact are likely to be key issues in any planning application for the development of Altens East ‘OP70’ or the extension, due to the existing landform and surrounding land uses this is not likely to be an insurmountable impact.

Figure 4.3 – View towards Altens East from Coast Road to East

4.15. The potential landscape and visual impact from the adjacent core paths network would also need to be considered through any planning application. However, the footpath is routed across the coast road some distance to the south of the site and then runs to the east of the rail lines, therefore, views to the site are already disturbed and would be easily screened as previously detailed (see figure 4.4).

Page 24 of 38 Aberdeen Zero Waste Project – Representations, Altens East Figure 4.4 – Core Path Network

Noise and Amenity

4.16. The development of waste management infrastructure on the existing Altens East ‘OP70’ site will already have an impact on noise which would need to be comprehensively assessed through any planning application.

4.17. While the extension of the site to include the depot will introduce another use to the area, this is not an unacceptable use of land in a predominantly industrial setting.

4.18. Noise impact would be assessed throughout any planning application for the depot and mitigation provided where appropriate or necessary. Landscaping features such as bunds, which screen the visual impact of the site, also have an impact on noise and space has been set aside for landscaping within the current outline layout (see drawing 125176/C/P/200 Rev 05, ‘Site Layout, MRF, RDF and Depot’).

Page 25 of 38 Aberdeen Zero Waste Project – Representations, Altens East 5. PLANNING POLICY

5.1. This section outlines the planning policy considerations relevant to the proposed allocation of additional land at Altens East for the depot.

Adopted Scottish Planning Policy (SPP)

5.2. SPP was published in February 2010 and consolidated several separate topic specific policy statements into one document.

5.3. Paragraph 5 of SPP highlights that development plans should lead and guide change and that the requirement to keep them up to date will ensure that they reflect and respond to emerging pressures and issues. This statement is particularly relevant to this representation, which has set out the issues which are impacting waste management in Aberdeen City and how this relates to the request to allocate further land for the development of the depot on the land adjacent to Altens East ‘OP70’.

5.4. The main issues associate with the allocation of the additional land is the current green belt designation within the adopted ALDP. With regard to green belt, SPP highlights it is designed to direct growth to the most appropriate areas, protect the character, landscape setting and identity of towns and cities and protect and give access to open space around towns and cities.

5.5. As illustrated within this report, with the imposition of landscape and screening features it is considered that the integrity of the landscape setting and character of the area will not be compromised by the release of additional land for development adjacent to Altens East ‘OP70’.

5.6. SPP also stresses that the green belt designation should be used to direct development to suitable locations, rather than prevent it (para 159) and that development in the green belt may be considered appropriate to meet an established need and where no other site is available (para 163). The need

Page 26 of 38 Aberdeen Zero Waste Project – Representations, Altens East for the additional allocation and the issues identifying an alternative site have been highlighted within these representations.

Scottish Planning Policy Consultation Draft

5.7. On 18 September 2012 the Scottish Government announced a review of SPP, the draft document was published on 30 April 2013 which was followed by a 12 week period of consultation ending on 23 July 2013. On 4 September 2013 the Minister for Local Government and Planning announced that the review would be completed in June 2014.

5.8. The draft SPP opts for a similar policy to the adopted SPP with regard to the green belt. Paragraph 51 highlights that development meeting an established need might is suitable, if no alternative site is available.

Aberdeen Local Development Plan 2012

5.9. The existing Altens East ‘OP70’ site allocation and the accompanying Policy R4, ‘Sites for New Waste Management Facilities’ specifically reserves the site for waste related uses:

“Altens East/Doonies (OP70) – materials recycling facility / an anaerobic digestion or in-vessel composting facility / and or a transfer station.”

5.10. As discussed within the previous sections of this document, the proposed additional land is within the green belt and this has already been discussed. However, consideration has been given to other local factors within the existing ALDP and how the proposal would comply with those, within the following text

Page 27 of 38 Aberdeen Zero Waste Project – Representations, Altens East Green Space Network

5.11. The additional land required for the development is identified as green belt but is not within the green space network. However, the surrounding land to the north, east and south is within the green space network, therefore, Policy NE1, Green Space Network’ is relevant:

“The City Council will protect, promote and enhance the wildlife, recreational and access value of the Green Space Network. Proposals for development that are likely to destroy or erode the character or function of the Green Space Network will not be permitted. Where major infrastructure projects or other developments necessitate crossing the Green Space Network, such developments shall take into account the coherence of the network. In doing so measures shall be taken to allow access across roads for wildlife and for access and outdoor recreation purposes.

Masterplanning of new developments should determine the location and extent of the Green Space Network within these areas.

Development which has any impact on existing wildlife habitats, or connections between them, or other features of value to natural heritage, open space, landscape and recreation must be mitigated through enhancements of Green Space Network”.

5.12. Similarly, policy NE9, ‘Access and Informal Recreation’, which requires that new development should not compromise the integrity of paths or green space for recreation.

5.13. Any landscaping which was proposed at the site in order to protect integrity of the surrounding green belt would also be relevant to the Green Space Network and it is unlikely that the extension of the allocation will result in a significant impact.

Page 28 of 38 Aberdeen Zero Waste Project – Representations, Altens East New Waste Management Facilities

5.14. ALDP recognises the requirement for new waste management facilities and includes a policy (R3, ‘New Waste Management Facilities’) which supports their development, provided they comply with several considerations:

“Applications for waste management facilities will be supported provided they:

1) conform to the Zero Waste Plan and Aberdeen Waste Strategy;

2) meet a clear need for the development to serve local and/or regional requirements for the management of waste;

3) represent the Best Practicable Environmental Option for that waste stream;

4) will not compromise health and safety;

5) minimise the transport of waste from its source;” (ALDP Policy R3).

5.15. Policy R3 also continues to outline the details that will be required to accompany any planning application for a new waste management facility.

5.16. The development of the depot, which is closely related to the operation of the RDF and MRF facility, does have support through this policy. The co-location with the depot will also strengthen the position on minimising the transport associated with waste (road miles), providing a similar outcome to point 5 of policy R3.

Page 29 of 38 Aberdeen Zero Waste Project – Representations, Altens East Aberdeen City and Shire Structure Plan 2009 and Aberdeen City and Shire Strategic Development Plan – Proposed Plan February 2013

5.17. As outlined within section 2.0 of this document – ‘Background and Need’, Both Aberdeen City and Shire Structure Plan and Aberdeen City and Shire Strategic Development Plan stress the need for additional waste management infrastructure.

5.18. Although the depot is not strictly a waste management operation, its function is clearly linked to the waste infrastructure it serves and the benefits of co- location are clear and significant.

Planning Advice Note 63, ‘Waste Management Planning’

5.19. While the depot is not waste management infrastructure, its role is clearly connected to the management of waste in the city. The proposed Altens East ‘OP70’ extension has, therefore, been considered against the content of Planning Advice Note 63 (PAN 63) which provides guidance regarding the location and development of waste infrastructure.

5.20. Paragraph 22 states that in general, the most appropriate locations are those with the least adverse impacts on the local community and the environment. The following are specifically noted as potential locations:

 “Industrial areas, especially those containing other heavy or specialised industrial uses;  Degraded, contaminated or derelict land. Well-located, planned, designed and operated waste management facilities may provide good opportunities for remediating and enhancing sites which are damaged or otherwise of poor quality, or bringing derelict or degraded land back into productive uses;

Page 30 of 38 Aberdeen Zero Waste Project – Representations, Altens East  Working and worked out quarries. Landfill is commonly used in quarry restoration but there may be opportunities for other types of waste management facilities;  Existing landfill sites where, for instance, Energy from Waste (EfW), materials reclamation or composting facilities may be conveniently located;  Existing or redundant sites or buildings which could be used, or adapted for incineration or materials reclamation facilities, or composting operations;  Sites previously occupied by other types of waste management facilities; and  Other suitable sites located close to railways or water transport wharves, or major junctions in the road network” (PAN 63, Para 22)

5.21. The extension of the Altens East ‘OP70’ allocation for the depot would clearly satisfy the first of these considerations. It would be located within an established industrial area and directly connected to land which has already been allocated for waste management uses,

Page 31 of 38 Aberdeen Zero Waste Project – Representations, Altens East 6. ALTERNATIVES

6.1. Section 2.0, ‘Background and Need’ summarises the process that has been undertaken to request the allocation of additional land adjacent to Altens East ‘OP70’.

6.2. This section provides some further detail on the alternatives that have been considered but were not appropriate.

6.3. It is important to bear in mind that, following the unsuccessful primary aim of the ZWMP to identify one site for all of the strategic waste management facilities, the project was limited to developing the infrastructure that was required as a priority, to achieve targets set by legislation and policy.

6.4. The existing Altens East ‘OP70’ site already has an allocation for waste management uses. This is the only waste management allocation within the current ALDP which is suitable for the development of a MRF and RDF and there is, therefore, no better site from a planning perspective.

6.5. The co-location of the depot is requested for reasons of practicality and efficiency as outlined within this representation. However, there is also a need to relocate the depot in the short term due to the Berryden Corridor works.

6.6. It may be possible to identify land which is appropriately sized for the depot, elsewhere in the city. However, this would not realise any of the benefits associated with the co-location of the facilities. The alternative sites considered, therefore, need to be suitably sized to accommodate all of the facilities at an approximate footprint of 4 hectares (10 acres).

6.7. In order to be a preferential site it would need to be outwith the green belt, suitable for development, available for development and also, critically, viable for development.

Page 32 of 38 Aberdeen Zero Waste Project – Representations, Altens East 6.8. The following sites have been considered as an alternative to the proposed extension at Altens East ‘OP70’. However, none were considered to be preferable for the reasons outlined. All of the other opportunity sites within ALDP are either too small, or allocated for alternative uses such as housing.

Site Aberdeen Local Development Plan Allocation Reasons that the site was deemed Unsuitable OP1 – Hill of Tramaud  Green Belt; and  The site is within the Green Belt and (16 hectares)  Landfill, followed by reinstatement to uses is therefore, not preferable from a acceptable to the Council. planning perspective to Altens East; and  The former landfill use of much of the site would constrain development. OP3 – Berryhill, Murcar  Business and Industrial; and  The site owner / developer is (68.4 hectares)  Green Space Network. marketing this site to an alternative profile / sector than waste management or recycling and the site is not available for development for the proposed uses. OP4 – Findlay Farm,  Specialist Employment Area; and  This is a ‘Specialist Employment Area Murcar  Extension to Aberdeen Science and Energy Park. within ALDP and policy BI2 applies, restricting uses to ‘Class 4 Business

Page 33 of 38 Aberdeen Zero Waste Project – Representations, Altens East Uses’.  The site owner / developer is marketing this site to an alternative profile / sector than waste management or recycling and the site is not available for development for the proposed uses. OP12 - Grandholme  Land Release Policy; and  Approximately 4 hectares of this site  Green Space Network. has been set aside for employment land. However, this is for Class 4 Business Uses and is not appropriate for the proposed uses. OP22 – Mugiemoss Mill  Mixed Use.  This site has been subject to a Development Framework for a mixed use redevelopment including residential, retail and community uses. It is, therefore, not appropriate for the proposed uses. OP28 – Rowett North  Land Release Policy; and  This site has been selected for the  Green Space Network. Exhibition and Conference Centre and is not available for the proposed uses. Page 34 of 38 Aberdeen Zero Waste Project – Representations, Altens East OP32 – Dyce Drive  Specialist Employment; and  Much of the site is allocated as a  Green Space Network. ‘Specialist Employment Area within ALDP and policy BI2 applies, restricting uses to ‘Class 4 Business Uses’.  There is insufficient ‘industrial’ land available for development for the proposed uses. OP40 – West Hatton and  Land Release Policy; and  This site is for the development of Home Farm,  Green Space Network. high quality businesses or company headquarters.  The site owner / developer is marketing this site to an alternative profile / sector than waste management or recycling and the site is not available for development for the proposed uses. OP45 - Greenferns  Land Release Policy; and  This is a residential led masterplan  Green Space Network with insufficient ‘industrial’ land available for development for the proposed uses. Page 35 of 38 Aberdeen Zero Waste Project – Representations, Altens East OP58 - Counteswells  Land Release Policy; and  The development timeframe (10-15  Green Space Network years for phase 1) for this site is too long term to satisfy the requirements of the search. OP69 – Aberdeen  Business and Industrial Land;  There is insufficient ‘industrial’ land Gateway / Moss-side /  Green Belt; and available for development for the Mains of Cairnrobin  Land Release Policy. proposed uses. OP77 - Loirston  Land Release Policy; and  The approved development  Green Space Network framework for these sites indicates a OP78 - Charleston  Land Release Policy residential led masterplan.  The development timeframe for the site is too long term to satisfy the requirements. Employment uses are post 2020.

6.9. The above details indicate the difficulties associated with identifying a site suitable for the development of the MRF, RDF and depot together. It is, therefore, considered that the extension of the Altens East ‘OP70’ allocation is the only viable option.

Page 36 of 38 Aberdeen Zero Waste Project – Representations, Altens East 7. CONCLUSIONS

7.1. This representation has been prepared by SITA UK with the assistance of ACCWRD in order to request additional land directly adjacent to the existing Altens East ‘OP70’ site allocation. The additional land would be used for the development of a depot.

7.2. This representation has followed a long process of evaluating the options available for the development of waste management infrastructure in the City.

7.3. This document has demonstrated that there is a clear and identified need for waste management facilities and that those facilities will occupy almost all of the existing Altens East ‘OP70’ designation.

7.4. Furthermore, it is clear that efficiencies can be delivered by co-locating the waste management infrastructure and the depot and also there is an identified and short term need to relocate the existing depot due to the forthcoming Berryden Corridor works.

7.5. The co-location of the waste management facilities would result in development savings through the use of shared infrastructure at the site. Furthermore operational efficiencies would be achieved both in terms of road miles/sustainability and costs and also practical efficiencies related to time saved through missing journeys to and from the depot.

7.6. Furthermore, taking account of the existing Altens East ‘OP70’ designation for waste management infrastructure which has established the principle of development of the bordering land, SITA UK and ACCWRD consider that the extension of the designation would be unlikely to result in significant impacts on the environment.

7.7. Finally, the alternative site search process clearly illustrates the difficulties associated with identifying a suitable alternative site for the co-location of the waste management facilities and the MRF. The proposed extension to the Page 37 of 38 Aberdeen Zero Waste Project – Representations, Altens East Altens East ‘OP70’ allocation is the only option available for co-location within the City.

7.8. Taking these factors into consideration, SITA UK and ACCWRD request that this representation to extend the Altens East ‘OP70’ allocation is given full support and included within the forthcoming Aberdeen Local Development Plan.

Page 38 of 38 Aberdeen Zero Waste Project – Representations, Altens East Drawings

Aberdeen Zero Waste Project – Representations, Altens East 0 10 MILLIMETRES 50

IN ADDITION TO THE HAZARDS/RISKS NORMALLY ASSOCIATED WITH THE TYPES OF WORK DETAILED ON THIS DRAWING, NOTE THE FOLLOWING SIGNIFICANT RESIDUAL RISKS :-

ITEM HAZARD RISK

05 RDF AND SITE LAYOUT RJ 06/02/14 MH MH AMENDMENTS

04 SITE LAYOUT AMENDMENTS RJ 31/01/14 MH MH

03 MRF & RDF LAYOUT CH 28/01/14 MH MH AMENDMENTS

02 AMENDMENTS MADE TO RJ 20/01/14 MH MH REFLECT CLIENTS COMMENTS

REV DESCRIPTION BY DATE CHK'D AUTH

Atkins Limited Albany Court Newcastle Business Park Newcastle Upon Tyne NE4 7YB England

Telephone +44(0)191 2334466 Fax +44(0)191 2235224

CLIENT:

PROJECT: ABERDEEN CITY COUNCIL ZERO WASTE FACILITY ALTENS EAST

TITLE: SITE LAYOUT MRF, RDF & DEPOT

SCALE: ORIGINAL SIZE: DESIGNED: DRAWN: CHECKED: AUTHORISED: A3 MH RJ MH RA 1:1000 OFFICE: DATE: DATE: DATE: DATE: NCO 12/12/13 12/12/13 12/12/13 12/12/13 PROJECT NO: DISCIPLINE: TYPE: CODE: DRG NO: REV: 5125176 C P 200 05