eastsussex.gov.uk
East Sussex Waste and Minerals Monitoring Report 2018/19
April 2020
Waste and Minerals Monitoring Report 2018/19
Contents
Waste and Minerals Local Plan - Annual Monitoring Report 2018-19
1 Executive Summary 4 2 Context and Role of the Monitoring Report 7 3 Characteristics of East Sussex 9 4 Progress of the Waste & Minerals Local Plan 14 5 Duty to Co-operate 16 6 Monitoring the Plan 18 7 Overarching Strategy 21 8 Providing for Waste 29 9 Providing for Minerals 44 10 Overarching Policies 49 11 Development Management Policies 50 12 Enforcement 51 13 Monitoring Issues 54
Appendices
A Structure of the Waste and Minerals Local Plan 56 B Programme for the Waste and Minerals Development Scheme 57 C Duty to Co-operate 58 D LACW and Household Waste Arisings in East Sussex and Brighton & Hove 68 E Other Targets for the Management of LACW 69 F Permitted Waste Management Sites in East Sussex and Brighton & Hove 70 G Permitting of Significant Waste Management Capacity in East Sussex 2006/7 - 2018/19 76 H Permitted Mineral Workings in the Plan Area 2018/19 80 Waste and Minerals Monitoring Report 2018/19
Contents
I Secondary and Recycled Aggregates Facilities in East Sussex and Brighton & Hove 82 J Review of Mineral Permissions 84 K Local Aggregate Assessment 87 Waste and Minerals Monitoring Report 2018/19 3 Waste and Minerals Local Plan - Annual Monitoring Report 2018-19 4 Waste and Minerals Monitoring Report 2018/19
1Executive Summary 1 Executive Summary
Introduction
1.1 East Sussex County Council, as a Waste and Minerals Planning Authority, provides planning policies for waste management and minerals production. Current policies are contained in the East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan and the East Sussex, South Downs and Brighton & Hove Waste and Sites Plan. The Council is required by the Planning and Compulsory Purchase Act 2004, as amended by the Localism Act 2011, to monitor implementation of these policies and partly does this by producing an annual Waste & Minerals Monitoring Report (AMR). The content of Monitoring Reports is prescribed by the Town & Country Planning (Local Planning) Regulations 2012. This Monitoring Report covers the period 1 April 2018 to 31 March 2019. Monitoring Reports from previous years can be found on our website www.eastsussex.gov.uk.
Key Findings of 2018/19
1.2 Below are the key findings of the East Sussex Waste and Minerals Monitoring Report 2018/19:
Progress on the Waste & Minerals Local Plan
1.3 Following the adoption of the Waste and Minerals Plan (WMP) in February 2013, East Sussex County Council working jointly with the South Downs National Park Authority and Brighton & Hove City Council adopted the Waste and Minerals Sites Plan (WMSP) in February 2017. The WMSP triggered a review of the Waste and Minerals Local Plan which is currently underway. Between September 2017 and November 2017 a Call for Evidence and Sites was undertaken. The Review timetable has been extended due to ongoing discussions regarding sand/gravel sites in the east of the County. It is now anticipated that a consultation will take place during 2020.
Duty to Co-operate
1.4 East Sussex County Council continues to work jointly with the South Downs National Park and Brighton & Hove City Council in undertaking the Review of the Waste and Minerals Local Plan. The preparation of this Review has involved working closely with the Districts and Boroughs within and nearby to East Sussex. The Authorities actively participate in regional fora such as the South East Waste Planning Advisory Group and the South East England Aggregates Working Party. The Authorities published an updated Duty to Cooperate Scoping Document for the Waste and Minerals Local Plan Review in September 2017.
Providing for Waste Waste and Minerals Monitoring Report 2018/19 5
Executive Summary1
1.5 A total of 366,000 tonnes of Local Authority Collected Waste was managed in 2018/19 which is an decrease of 6,000 tonnes from 2017/18. 39% of this waste was recycled (including composted) which is below the 2015/16 WMP target of 45%, but does represent a slight increase from the 2014/15 outturn of 38%. The review of the Commercial & Industrial Waste arisings has been updated with 2017 data, preliminary results indicate a significant reduction in waste arisings during the recession, but these have now exceeded pre-recession levels. No new information relating to Construction, Demolition and Excavation Waste is available. The amount of Local Authority Collected Waste and Commercial & Industrial Waste being sent to landfill increased from 45,000 tonnes in 2017 to 47,000 tonnes in 2018. The proportion of Local Authority Collected Waste that was recycled, composted or recovered has been slowly increasing, from 94% in 2013/14 to 96% in 2018/19. The Waste and Minerals Plan target for recovery for 2015/16 (98%) was not achieved.
1.6 No capacity for inert material to be used for beneficial use was permitted (granted planning permission) in 2018/19. The Waste and Minerals Plan 2015/16 target for recovery and recycling capacity provision were met.
Providing for Minerals
1.7 The County Council has published the (2018) sixth Local Aggregate Assessment (LAA) for East Sussex, South Downs and Brighton & Hove (which is appended to this document). The overall picture of aggregate supply to the Plan area is of heavy dependence on imports by road, sea and rail. Significant levels of marine imports (marine dredged and crushed rock) are received through Shoreham Port and to a lesser extent Newhaven and Rye. Crushed rock, recycled aggregate and sand and gravel are imported by rail at Newhaven. Land-won sand and gravel is extracted in the east of the Plan area at Lydd with about 50% of material being consumed in East Sussex. A steady supply of recycled material is produced from construction waste management facilities across the Plan area. A continuing demand for construction materials is anticipated.
1.8 The NPPF requires that the LAA considers all supply options (land-won, marine, secondary and recycled material), and be based on a rolling average of 10 years sales data and other relevant local information. In past years the Authorities' assessment was that there were particular circumstances in this Plan Area that made it difficult to prepare the LAA totally along the lines indicated in the NPPG. Previous LAAs concluded that the assessment could not use past 10 years sales data as this was too volatile because there is a very small number of production sites and therefore there has been major variation in sales figures from nothing to more substantial output. Past LAAs instead used the Apportionment figure in the Adopted WMLP as a surrogate figure for forward planning.
1.9 In 2016 a Public Examination on the soundness and legal compliance of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan was held. Hearings focused on the whether the Plan provided a sufficient and adequate supply of aggregates. Whilst the Inspector found the Sites Plan sound, in his Report 6 Waste and Minerals Monitoring Report 2018/19
1Executive Summary
he identified that the current rate of land-won aggregates in the WMP could not be maintained with the current allocated sites and indicted the need for a Review of the aggregate minerals policies. The Authorities have since agreed to a Review of the Waste and Minerals Local Plan (WMLP) which commenced in September 2017. The Review will re-evaluate the aggregate provision figures for the Plan Area.
1.10 Clay and gypsum continued to be extracted at levels that support brick and tile production, plasterboard and cement production in accordance with policy.
Overarching Policies & Development Management Policies
1.11 A review of the Overarching Policies and Development Management Policies is being undertaken as part of the Review into the Waste and Minerals Local Plan.
Enforcement
1.12 The number of cases outstanding has remained historically low, with the caseload standing at 12 in the fourth quarter of 2019. This remains well below the peak in 2015.(1)
1 The quarters referred to are calendar quarters. Waste and Minerals Monitoring Report 2018/19 7 Context and Role of the Monitoring Report2 2 Context and Role of the Monitoring Report
2.1 East Sussex County Council, as a Waste and Minerals Planning Authority, provides planning policies for waste management and minerals production, which are prepared jointly with Brighton & Hove City Council and the South Downs National Park Authority. The Council is required to monitor implementation of these policies by the provisions in the Planning and Compulsory Purchase Act 2004 and does this by producing a Waste & Minerals Monitoring Report, which also provides data and commentary on trends in waste management and minerals production.
2.2 This Monitoring Report covers the period 1 April 2018 to 31 March 2019. AMRs from previous years can be found on the Council's annual monitoring report webpage.
2.3 Some reporting of significant developments that have taken place between 31 March 2019 and the preparation of this document are also included.
2.4 This Monitoring Report covers only waste and minerals matters. Other forms of development and development planning in the Plan Area, for example housing or employment land, are dealt with by the City, Borough, and District Councils, and the National Park Authority in their own existing and emerging Local Plans and Monitoring Reports.
2.5 The Monitoring Report reports against the following key monitoring tasks for the Plan Area which includes Brighton & Hove and part of the South Down National Park:
Assessing the extent to which policies in the Waste and Minerals Plan and Waste and Minerals Sites Plan are being implemented; reporting on the Review into the Waste and Minerals Local Plan against the timetable and milestones in the Minerals and Waste Development Scheme; checking performance against indicators and local objectives for waste and minerals.
Existing Planning Policy Framework
2.6 The Development Plan for the area comprises the Waste and Minerals Plan (WMP), the Waste and Minerals Sites Plan (WMSP), as well as all the Local Plans produced by the district and borough planning authorities, and the South Downs National Park Authority (including the plans adopted by the Brighton & Hove City Council). A review of the Waste and Minerals Local Plan which consists of the WMP, WMSP and the East Sussex and Brighton & Hove Construction and Demolition SPD is currently being undertaken. Planning legislation requires planning applications to be determined in accordance with the Development Plan, unless material considerations indicate otherwise. National Policy is a material consideration. 8 Waste and Minerals Monitoring Report 2018/19 2Context and Role of the Monitoring Report
Waste and Minerals Plan
2.7 The Waste and Minerals Plan was adopted on 19 February 2013 following a Public Examination at which the Planning Inspector found the Plan "sound". The Plan sets out the policy framework for waste and minerals development up to 2026. The Plan has strategic and development management policies but the Plan does not allocate specific sites. The Plan includes a set of monitoring indicators.
Waste and Minerals Sites Plan
2.8 The Waste and Minerals Sites Plan (WMSP) was the subject of a Public Examination in the summer of 2016. In November 2016 the Inspector holding the Public Examination found the WMSP, subject to a number of modifications, to be 'sound' and legally complaint. The WMSP was adopted in February 2017. This plan replaced the remaining saved policies that were contained in the Waste Local Plan (2006) and the Minerals Local Plan (1999).
National Policy
2.9 The current National Planning Policy Framework (NPPF) was published during February 2019. The National Planing Policy for Waste was published on the 16 October 2014.
2.10 Planning Practice Guidance was first published on 6 March 2013. Planning Practice Guidance - Waste was subsequently published on the 16 October 2014. This document guides how the NPPF is interpreted, how planning applications should be determined, and how local plans should be prepared. Since the publication of the guidance sections have been, and continue to be, periodically updated.
2.11 The NPPF states that the relevant authorities should prepare an annual Local Aggregate Assessment (LAA). The LAA 2019 is appended to this Report. More details on the requirements of the LAA are set out in Chapter of this report. Waste and Minerals Monitoring Report 2018/19 9
Characteristics of East Sussex3 3 Characteristics of East Sussex
Environmental Designations
3.1 The South Downs National Park (SDNP) was officially designated on 31 March 2010, and replaced the Sussex Downs Area of Outstanding National Beauty (AONB). The boundary of the SDNP is different to that of the AONB, and includes the town of Lewes and other areas to the north of the AONB. The National Park and the High Weald AONB together cover two thirds of the Plan Area. (See Maps 1 and 2 below).
3.2 Other tracts of land are additionally designated as being of international and national environmental importance and are shown in Map 2 below.
Demography
3.3 The rate of production of waste and consumption of minerals has been shown to have some relationship with population growth; an increasing population produces more waste and has a greater demand for minerals.
3.4 In 2016 the Plan Area had a total population of approximately 836,800 of which about two thirds live in East Sussex (see below) and the remainder in Brighton & Hove. Approximately 30,000 people live within the Plan Area part of the South Downs National Park. Over the period 2016-2026, the population in East Sussex is predicted to increase by approximately 7.35%. The average household size is expected to decrease from 2.22 in 2014 to 2.06 in 2039.
Table 1 East Sussex and Brighton & Hove Population Projections 2016 to 2041
Year East Sussex Brighton and Hove Plan Area Population Population Population
2016 549,600 287,200 836,800 2021 571,600 296,700 868,300 2026 594,000 304,300 898,300 2031 614,400 313,300 927,700 2036 632,700 320,700 953,400 2041 649,100 327,300 976,400
3.5 The figures in the table above are rounded to the nearest 100, and are based on the Office for National Statistics: Sub-national population projections for England, 2016-based, (released 24 May 2018)(2)
2 https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populationprojections/datasets/localauthoritiesinenglandtable2
12 Waste and Minerals Monitoring Report 2018/19
3Characteristics of East Sussex
Economy
3.6 The rate of production of waste and consumption of minerals has been shown to have a relationship with economic activity; in general a more buoyant economy produces more waste and has a greater demand for minerals. The structure of the economy in the Plan Area affects the nature and volume of commercial and industrial waste arisings and the need for particular minerals.
3.7 In 2018, 75.8% of jobs in the Plan Area were in the service sector, 5.3% in production, 13.5% in construction and 5.4% in agriculture, forestry and fishing. 31.2% of all people who work in East Sussex are employed in the professional, scientific & technical sectors, business administration and support services, education or health. Wholesale and retail trade; and accommodation and food service activities account for 19.8% of people who work in the County. (3) In Brighton & Hove the employment structure is dominated by high value sectors such as health, business & public administration, professional, scientific & technical sectors & education.
3.8 The economy in East Sussex is characterised by its high number of small businesses. 90.3% of businesses in East Sussex employ less than 10 people, which is slightly higher than the national average of 89.5%. In Brighton & Hove, 90.7% of businesses employ less than 10 people. Only 0.2% of businesses in East Sussex employ over 250 people, compared to 0.3% of businesses in Brighton and Hove and the national average of 0.4%. (4) Tourism and the conference trade is a key element in the local economy, contributing around 10 million visitors per annum and significantly increasing the amount of waste to be managed.
3.9 The South Downs within the Plan Area has a predominantly rural economy, with the exception of the busy market town of Lewes.
Local Enterprise Partnerships
3.10 Two Local Enterprise Partnerships (LEPs) cover the Plan Area. The 'Coast to Capital' LEP includes Brighton & Hove, while East Sussex is part of the South East LEP that also covers Kent and Essex. LEPs are partnerships between local authorities and businesses that aim to drive economic growth and job creation.
Enterprise Zones
3.11 Newhaven Enterprise Zone officially commenced in April 2017. It is estimated that EZ status will lead to the creation of around 55,000m² of new commercial floor space, refurbish a further 15,000m² of commercial floor space and create and sustain around 2,000 jobs over the Zone’s 25-year lifespan. Alongside the other Newhaven-focused regeneration activity, the Enterprise Zone has the potential to have a significant positive impact on local residents, businesses and economic growth.
3 "Local business units by industry group UK SIC(2007), 2009-2018 - districts" - East Sussex in Figures: http://www.eastsussexinfigures.org.uk/webview/welcome.html 4 "Business enterprises by size of business, 2004-2018 - districts" - East Sussex in Figures: http://www.eastsussexinfigures.org.uk/webview/welcome.html" Waste and Minerals Monitoring Report 2018/19 13
Characteristics of East Sussex3
3.12 Further detail on the environmental and social characteristics of East Sussex and Brighton & Hove is available on East Sussex in Figures . 14 Waste and Minerals Monitoring Report 2018/19 4Progress of the Waste & Minerals Local Plan 4 Progress of the Waste & Minerals Local Plan
Progress on the Waste & Minerals Local Plan (WMLP)
4.1 East Sussex County Council, as a Waste and Minerals Planning Authority, provides planning policies for waste management and minerals production. Current policies are contained in the East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan and Waste and Minerals Sites Plan (WMLP). (5)
4.2 The WMLP is being jointly reviewed by East Sussex County Council, Brighton & Hove City Council and the South Downs National Park Authority (SDNPA). The WMLP also includes a Supplementary Planning Document (SPD) that covers the production and management of construction and demolition waste. Separately the Authorities produce Statements of Community Involvement.
Minerals & Waste Development Scheme
4.3 A Minerals and Waste Development Scheme (MWDS) is produced by the County Council to provide a timetable for the production of these documents which is mirrored by Brighton & Hove City Council and the South Downs National Park Authority.
4.4 In February 2020 a revised Minerals and Waste Development Scheme, (6) containing the timetable for the preparation of the First Review of the Waste and Minerals Local Plan was approved by the County Council.
Waste & Minerals Plan
4.5 In February 2013 the Waste and Minerals Plan was adopted, and it is now being used for development management purposes, including the determination of planning applications.
Waste & Minerals Sites Plan
4.6 The Waste and Minerals Sites Plan was adopted in February 2017. The Site Plan identifies specific areas of land where it is considered that the management of waste and production of minerals could take place in the future. The document includes allocation of land to meet the requirements for additional capacity for the management of waste and the identification of Minerals Safeguarding Areas.
5 http://www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste/amr1.Htm 6 http://www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste Waste and Minerals Monitoring Report 2018/19 15 Progress of the Waste & Minerals Local Plan4
Waste and Minerals Local Plan Review
4.7 The Authorities are currently undertaking a review of the Waste and Minerals Plan and Waste and Minerals Sites Plan (collectively known as the Waste and Minerals Local Plan). This review focuses on minerals provision and the safeguarding of minerals and minerals related infrastructure. The Authorities are also using the review as an opportunity to improve the effectiveness of some policies. A Call for Evidence and Sites was held in 2017. The Authorities are currently preparing a Draft Revised Policies Document which is scheduled to be be available for public consultation in early 2020.
Construction & Demolition Waste SPD
4.8 The C&D Waste SPD provides additional guidance concerning the production and management of C&D waste. The SPD needs to be reviewed to ensure that it reflects the ongoing changes to planning policy and regulations relating to Site Waste Management Plans(7). However, due to ongoing constraints on resources it has not yet been possible to complete this review.
7 These were revoked on 1 December 2013 16 Waste and Minerals Monitoring Report 2018/19
5Duty to Co-operate 5 Duty to Co-operate
Duty to Co-operate
5.1 Regulation 34 of The Town and Country Planning (Local Planning) (England) Regulations 2012 requires local planning authorities to provide details in their monitoring reports of the steps taken to comply with the 'Duty to Co-operate'. This duty is set out in Section 110 of the Localism Act 2011 and requires county councils, local planning authorities and other bodies as prescribed by Regulation 4 of The Town and Country Planning (Local Planning) (England) Regulations 2012, to co-operate with each other. The Duty to Co-operate is limited to those topics that are considered as a strategic matters. Waste and Minerals is one such strategic matter. A log of activities undertaken by the Council in relation to the Duty can be found in Appendix C.
Regional Fora
5.2 The Authorities' membership of waste and minerals planning fora which cover the whole of the South-East (as described below) has been an important basis for cross boundary liaison on key strategic waste management and minerals production matters.
5.3 The South East Waste Planning Advisory Group (SEWPAG) provides a regular opportunity for cooperation on planning for waste management across administrative boundaries in the South-East.
5.4 The South East England Aggregates Working Party (SEEAWP) exists to co-ordinate the steady and adequate supply of aggregate across the South-East.
5.5 The Ashdown Forest Officer Group exists to address the cross border issue of nitrogen levels in the Ashdown Forest Special Area of Conservation.
Waste and Minerals Local Plan Review
5.6 A review of the Waste and Minerals Local Plan commenced in September 2017, and there has been continuing co-operation between East Sussex County Council, Brighton & Hove City Council, and the South Downs National Park Authority and the other prescribed bodies. The Authorities published a Duty to Cooperate Scoping Document for the Local Plan Review in September 2017. Four cross boundary strategic matters were identified as requiring particular attention and include the following:
Minerals Provision Safeguarding Minerals & Minerals Infrastructure Land-won aggregates provision in Plan Area Ashdown Forest Special Area of Conservation (SAC) Waste and Minerals Monitoring Report 2018/19 17
Duty to Co-operate5
5.7 Further information on cooperation associated with these matters is set out below.
5.8 Initial meetings were held with the Authorities where a Policy Assessment was undertaken to determine the effectiveness and relevance of the existing policies within the Waste and Minerals Local Plan. The outcome of these meetings fed into formulating the proposed scope of the review. As a result of the calls for evidence and sites consultation, four responses out of the nineteen received to the consultation specified that the preferred approach would be by correspondence only or where consultation is required by legislation. Meetings with the district and borough councils within the Plan Area were also held.
5.9 The effect of development on Ashdown Forest SAC is a cross border issue. This is being considered by the relevant authorities as part of regular officer group meetings originally set up by the South Downs National Park Authority. In April 2018, a Statement of Common Ground was signed. Discussions continue on this matter.
5.10 Several meetings were held in 2018 to discuss cross boundary issues relating to the Plan review. These included discussions with Kent County Council, West Sussex County Council and Natural England.
Other Communications
5.11 East Sussex County Council, Brighton & Hove City Council, and the South Downs National Park Authority receive regular communication from other prescribed bodies in relation to the Duty to Co-operate. Cross boundary matters requiring particular attention include waste data, continued provision of adequate waste management capacity, and the safeguarding of the Brentford Rail Head to which bottom-ash from the Newhaven Energy Recovery Facility is transported by rail, and import of land-won and marine aggregates. Full details of the activities undertaken in relation to cooperation over strategic issues is set out in Appendix C. 18 Waste and Minerals Monitoring Report 2018/19
6Monitoring the Plan 6 Monitoring the Plan
6.1 Section 7 of the Waste and Minerals Plan sets out a comprehensive list of monitoring indicators. These have been reviewed, and in places refined. Further details can be found in the following sections:
Table 2
Monitoring Policies Report Section
7. Overarching WMP1 - Presumption in Favour of Sustainable Development Strategy WMP2 - Minerals and waste development affecting the South Downs National Park
8. Providing for *WMP3a - Promoting waste prevention, re-use and waste Waste awareness
*WMP3b - Turning waste into a resource
*WMP3c - Production of energy from waste
*WMP3d - Minimising and managing waste during construction, demolition and excavation
*WMP3e - Waste management in new development
WMP5 - Provision of Built Waste Facilities
WMP6 - Safeguarding Waste Sites
WMP7a - Sustainable locations for waste development (excluding land disposal)
WMP7b - More detailed criteria for waste development
WMP8a - Land disposal of non-inert waste
WMP8b - Deposit of inert waste on land for beneficial purposes
WMP8c - Management of landfill gas
WMP9a - Hazardous waste
WMP9b - Low level radioactive waste
WMP10 - Management of waste-water and sewage sludge Waste and Minerals Monitoring Report 2018/19 19
Monitoring the Plan6
Monitoring Policies Report Section
9. Providing for *WMP4 - Sustainable provision and use of minerals in the Plan Minerals WMP11 - Provision of Aggregates
WMP12 - Provision of Gypsum
WMP13 - Provision of Clay
WMP14 - Safeguarding Minerals Resources
WMP15 - Safeguarding Wharves and Railheads
WMP16 - Exploration for Oil and Gas
10. Overarching WMP17 - Restoration Policies WMP18 - Transport - road, rail and water
WMP19 - Co-location of complementary facilities
WMP20 - Community involvement and benefits
WMP21 - Opportunities for sustainable waste management and minerals production in other developments
WMP22 - Expansion and alterations to waste facilities
11. Development WMP23a - Design principles for built waste facilities Management Policies WMP23b - Operation of sites WMP24a - Climate change
WMP24b - Resource and energy
WMP25 - General amenity
WMP26 - Traffic Impacts
WMP27 - Environment and Environmental Enhancement
WMP28a - Flood risk
WMP28b - Groundwater and water quality 20 Waste and Minerals Monitoring Report 2018/19
6Monitoring the Plan
* Policies WMP3a-e and WMP4 in the Waste and Minerals Plan are located in the Overarching Strategy section. However in the Monitoring Report, they are considered under Providing for Waste and Providing for Minerals respectively.
6.2 The Policies within the Waste and Minerals Sites Plan build on those in the Waste and Minerals Plan and are being monitored through the monitoring of the policies above. Waste and Minerals Monitoring Report 2018/19 21
Overarching Strategy7 7 Overarching Strategy
7.1 The overarching strategy of the Waste and Minerals Plan sets out what the Authorities want to achieve in terms of waste and minerals development and underpins the Plan's detailed policies. It is governed by four principal policies:
Policy WMP1 - Presumption in Favour of Sustainable Development Policy WMP2 - Minerals and Waste Development in the South Downs National Park Policy WMP3(a - e) - Implementing the Waste Hierarchy Policy WMP4 - Sustainable Provision and Use of Minerals
7.2 This section of the AMR will concentrate on Policies WMP1 and WMP2. Policies WMP3 and WMP4 are reported under the sections Providing for Waste and Providing for Minerals, respectively.
Progress of the Overarching Strategy Policies
Policy WMP1 - Presumption in Favour of Sustainable Development
7.3 The presumption in favour of sustainable development is a key aspect of Central Government planning policy and is at the heart of the National Planning Policy Framework. The inclusion of this policy as part of East Sussex County Council's overarching strategy is to ensure sustainable development is at the heart of planning policy in the county and that decisions are taken in line with this presumption.
7.4 The policy reflects the overall approach of the plan. In reflection of this, Policy WMP1 shall be monitored through assessing the performance of the Plan's policies more generally, as set out elsewhere in the AMR, and referring back to how decisions reflect the presumption in favour of sustainable development. The indicator direction in the table below reflects the progress reported in this Monitoring Report.
7.5 The table below also shows the number of times each policy within the Plan has been used to date and in the last year. The use of policy provides an indication of the reliability of any monitoring of each policy, i.e there is more information likely to be available to inform monitoring where a policy has been used more often. (Note, if a policy is cited more than once in a development management report, it only is counted once.) 22 W
Table 3 Number of times policy cited in reports. (East Sussex and Brighton & Hove including the National Park within. 7 aste Overarching
19/02/13 (date of 01/04/13-31/03/14 01/04/14-31/03/15 01/04/15-31/03/16 01/04/16-31/03/17 01/04/17-31/03/18 01/04/18 - 01/04/19-31/12/19 and adoption) - (12 months) (12 months) (12 months) (12 months) (12 months) 31/03/19 31/03/13 ( end of (12 months) (9 months) Miner monitoring period) als Monitoring County Matter 1 15 16 19 14 16 12 8 decisions issued Report Policy Purpose Applications Applications 01/04/18 Comment (If applicable) Indicator 19/02/13 - - 31/03/19 Direction date 2018/19
Overarching Strategy Strategy
WMP1 - Presumption in To ensure that decisions are taken in line with the presumption in favour of sustainable 9 0 # Favour of Sustainable development as set out in the National Planning Policy Framework (NPPF). Development
WMP2 - Minerals and waste To ensure development is sustainable and appropriate to the purposes and duties of the South 6 0 + development affecting the Downs National Park Authority. South Downs National Park
WMP3a - Promoting waste To prevent waste occurring in order to reduce the amount of waste treatment capacity needed. 3 0 # prevention, re-use and waste To provide commitment to contributing to wider strategies about waste awareness and awareness sustainable resource use; To facilitate movement to the upper tiers in the waste hierarchy, and particularly to increase preparation for re-use, which will involve industries and developments beyond waste management facilities; For development management authorities, this policy provides a clear framework for ensuring that sustainable waste management is taken into account in planning decisions about non-waste developments.
WMP3b - Turning waste into To encourage the development of new waste recycling and recovery infrastructure which 50 5 2015/16 targets for LACW O / # a resource ensures waste which has been produced is managed as far up the waste hierarchy as possible recycling and recovery not and in a manner which minimises the production of greenhouse gases. met. Recycling / recovery rates consistent for last three years. No new information on C&I or CDEW.
WMP3c - Production of To recognise that energy recovery is lower in the waste hierarchy than other processes so 3 1 # energy from waste proposals will need to be justified accordingly, and ensure that where energy recovery does take place, the capture of heat and/or energy from those processes should be in the most Policy Purpose Applications Applications 01/04/18 Comment (If applicable) Indicator 19/02/13 - - 31/03/19 Direction date
sustainable and efficient manner possible. This includes taking into account the EU Waste Framework Directive as well as Government policy about increasing use of renewable energy and decentralised power sources, and more broadly about mitigating against climate change.
WMP3d - Minimising and To ensure that the waste hierarchy is taken into account during construction and demolition 8 0 # managing waste during activities associated with all new development which require planning permission (not just construction, demolition and those that involve the management of waste); To encourage architects, project funders, and excavation contractors to minimise waste through the life-cycle of a project by 'designing out waste';This policy can be implemented by all planning authorities in the Plan Area.
WMP3e - To ensure that new developments take place in a manner which allows for the convenient 2 0 # sustainable management of waste. For example the policy will ensure that, where appropriate, Waste management in new space is made available for the storage and collection of separated recyclable materials e.g. development bring banks; It is envisaged that this policy will be implemented by all planning authorities in the Plan Area. Overarching
WMP4 - Sustainable provision To deliver the sustainable use and production of minerals using the minerals hierarchy, for 2 1 # and use of minerals in the example by promoting secondary and recycled materials. Plan
Providing for Waste
WMP5 - Provision of Built To identify the future need for recycling and recovery facilities, and avoid any adverse effects 4 1 2015/16 combined target + Waste Facilities that over-provision of capacity could bring; To provide flexibility in the Plan to demonstrate met. W aste 'net self sufficiency' by allowing for additional recovery capacity of an amount equivalent to that amount that is identified as needing to be exported for disposal to land. and
WMP6 - Safeguarding Waste To safeguard existing waste management facilities as appropriate. To safeguard certain areas 23 4 This policy is currently # Miner Sites in order to support the delivery of waste management facilities in the most appropriate being considered as part
locations. To safeguard Waste Local Plan site-specific allocations for waste management of the review into the Strategy als facilities. WMLP. Monitoring
WMP7a - Sustainable To identify broad areas (Areas of Focus) within the Plan Area within which the best 35 2 Most / all development + locations for waste opportunities for locating waste recycling and recovery facilities are more likely to be found. located with Area of development (excluding land Focus. disposal) The Areas of Focus identified in this policy, and shown on the Waste Key Diagram, will guide Report preparation of the Waste and Minerals Sites Plan. WMP7b - More detailed 10 0 + criteria for waste 2018/19 development 7 23 24 W 7
Policy Purpose Applications Applications 01/04/18 Comment (If applicable) Indicator aste 19/02/13 - - 31/03/19 Direction Overarching
date and
WMP8a - Land disposal of To identify the need for land disposal of non-inert and inert waste. To provide a policy 1 0 # Miner non-inert waste approach if such applications are submitted and to ensure that landfill gas produced by land
disposal facilities is captured and used as a fuel. als
WMP8b - Deposit of inert 12 0 + Monitoring waste on land for beneficial purposes
WMP8c - Management of 4 0 # landfill gas Report
WMP9a - Hazardous waste To allow for new waste water treatment capacity to be developed as appropriate. To provide 1 0 # 2018/19 additional waste water treatment works capacity in the Hailsham area and additional sewage sludge treatment capacity in the period up to 2026, in accordance with identified needs. Appropriate sites for both types of facilities will be considered in more detail in the Waste Strategy and Minerals Sites Plan.
WMP9b - Low level This policy is intended to ensure that: where viable, Low Level Radioactive Waste (LLW) 0 0 # radioactive waste management capacity is provided in the Plan Area such that LLW can be managed close to its source of production;in particular, the development of LLW incineration capacity, if incorporated as part of a wider scheme for the Plan Area, can be supported; additional capacity could be provided to manage LLW from beyond the Plan Area but only where this would help achieve 'net self-sufficiency'; and where additional capacity is developed for the management of LLW from beyond the Plan Area, that this capacity makes a significant contribution to the management of LLW arising within the Area.
WMP10 - Management of To allow for new waste water treatment capacity to be developed as appropriate. To provide 17 5 # waste-water and sewage additional waste water treatment works capacity in the Hailsham area and additional sewage sludge sludge treatment capacity in the period up to 2026, in accordance with identified needs. Appropriate sites for both types of facilities will be considered in more detail in the Waste and Minerals Sites Plan.
Providing for Minerals
WMP11 - Provision of To account for the proposed government apportionment for aggregates in order to assess the 1 0 This policy is currently # Aggregates need for any further allocations of primary aggregates production. being considered as part of the review into the WMLP.
WMP12 - Provision of Gypsum To safeguard and maintain supplies to and from the British Gypsum works throughout the Plan 1 0 # period. Policy Purpose Applications Applications 01/04/18 Comment (If applicable) Indicator 19/02/13 - - 31/03/19 Direction date
WMP13 - Provision of Clay To safeguard and maintain sufficient supplies of clay for brick and tile manufacture. 1 1 #
WMP14 - Safeguarding To set out how mineral resources will be safeguarded by identifying Mineral Safeguarding 1 0 This policy is currently # Minerals Resources Areas (areas of known resources) and Mineral Consultation Areas (areas where the district or being considered as part borough council should notify the Authorities of any alternative development proposals). of the review into the Identifying Consultation Areas does not necessarily imply that the resource will be worked. WMLP.
WMP15 - Safeguarding To safeguard railheads, wharves and rail sidings for existing and future mineral imports and 3 0 This policy is currently # Wharves and Railheads processing. In particular to safeguard overall mineral wharf capacity in ports subject to no being considered as part net loss of capacity, and to encourage co-location with processing capacity. of the review into the WMLP.
WMP16 - Exploration for Oil To provide a policy framework for any potential oil and gas exploration, appraisal and 0 0 # Overarching and Gas production.
Overarching Policies
WMP17 - Restoration To secure appropriate restoration of mineral workings and waste sites. Restoration should 7 1 Evidence of application of + seek environmental and amenity benefits reflecting local circumstances and relevant landscape policy. and biodiversity objectives. Proposed afteruses are likely to require ongoing management. W
WMP18 - Transport - road, To minimise the environmental and amenity effects of the transport of waste and minerals 4 1 # aste rail and water by promoting rail and water transport as an alternative to road transport; (Detailed,
site-specific, transport impacts are covered by Policy WMP 26.) and Miner WMP19 To encourage co-location of complementary waste or minerals processing facilities and 1 0 # associated industries, where this would offer either operational or cost efficiencies or transport Strategy als - Co-location of benefits. complementary facilities Monitoring
WMP20 - Community To encourage developers to take a more proactive approach and engage with local communities 1 0 # involvement and benefits as early as possible to help avoid misunderstandings and reduce anxiety related to waste or Report minerals-related developments, and also to ensure that where there are potential benefits for the community, that those benefits are realised by people living or working close by; The
policy aims to readdress a perceived lack of engagement between host communities and 2018/19 developers/the waste and minerals industry in the submission of planning applications for
waste or minerals developments. It seeks not only to reduce negative experiences of 7 communities but actually to secure positive benefits for host communities. 25 26 W 7
Policy Purpose Applications Applications 01/04/18 Comment (If applicable) Indicator aste 19/02/13 - - 31/03/19 Direction Overarching
date and
WMP21 - Opportunities for To ensure that objectives of sustainable waste management and minerals production are 0 0 # Miner sustainable waste considered in the preparation and determination of non-waste and minerals applications,
management and minerals where appropriate; This policy is concerned with maximising opportunities for improving the als production in other sustainable management and transport of waste that has already been produced - prevention developments of waste is dealt with elsewhere in this Plan; This policy is not intended to address the Monitoring management of waste arising from construction and demolition which is dealt with separately by Policy WMP 3d; It is envisaged that this policy will be implemented by all planning authorities in the Plan Area. Report WMP22 - Expansion and To enable expansions of capacity or alterations to operations within existing waste management 35 7 Expansions to existing + alterations to waste facilities facilities. waste sites have come forward. 2018/19
Development Management Policies Strategy
WMP23a - Design principles To provide guidance about more detailed design and operational aspects for built waste 39 5 Evidence of application of + for built waste facilities facilities, and to support the spatial policies regarding waste facilities. It focuses on policy. non-functional components of waste facilities and does not seek to address issues associated with technical design, but recognises that the interface between the two is important; The policy also links with the Community Involvement and Benefits policy (WMP 20), about involving WMP23b - Operation of sites host communities in the design of facilities, with the Climate Change policy (WMP 24) which 13 0 Evidence of application of + seeks design aspects which contribute to minimising greenhouse gas emissions, and with the policy. Resource and Energy policy (WMP 24b).
WMP24a - Climate change To set out how waste and minerals developments should seek to mitigate and adapt to climate 1 0 # change; It supplements the guidance about climate change set out in the National Planning Policy Framework because a) the Plan Area is coastal so climate change is a particular concern, and b) national policy about design is not specific to waste or minerals developments; Proposals WMP24b - Resource and for waste and minerals development should set out how they will minimise greenhouse gas 0 0 # energy emissions, either through design, construction or operations; Diversion of waste from landfill and movement up the waste hierarchy also contributes to mitigating climate change - this is covered in Policy WMP 3 Implementing the Waste Hierarchy. Policy WMP 24 deals with the more detailed aspects of how waste or minerals operations themselves can take measures to mitigate and adapt to the impacts of climate change.
WMP25 - General amenity To protect local communities from the potential negative impacts of waste and minerals 86 12 Evidence of application of + development such as those resulting from noise, dust, fumes, windblown litter, and visual policy. intrusion.
WMP26 - Traffic Impacts To ensure that proposals fully address the site-specific issues related to road transport and 62 9 Evidence of application of + traffic of waste or minerals developments; (This policy links with WMP 18 Transport - Road, policy. Rail and Water.) Policy Purpose Applications Applications 01/04/18 Comment (If applicable) Indicator 19/02/13 - - 31/03/19 Direction date
WMP27 - Environment and To protect and enhance the built and natural environment including: Natural assets; 48 4 Evidence of application of + Environmental Enhancement Biodiversity; Landscapes; Historic environment; Geology and geomorphology; Heritage assets; policy. and Landscape character. (This policy also links with the policy about design of built facilities.)
WMP28a - Flood risk To ensure that flood risk and potential impacts on groundwater and water quality are taken 24 4 Evidence of application of + into consideration in determining waste and minerals development proposals. policy.
WMP28b - Groundwater and 8 2 Evidence of application of + water quality policy.
Indicator direction: # Insufficient Information; + Positive ; - Negative; O: No change. Overarching W aste and Miner Strategy als Monitoring Report 2018/19 7 27 28 Waste and Minerals Monitoring Report 2018/19
7Overarching Strategy
Policy WMP2 - Minerals and Waste Development in the South Downs National Park
7.6 Parts of East Sussex, including Lewes, are located within The South Downs National Park. Policy WMP2 seeks to ensure that development is sustainable and appropriate to the purpose and duties of the South Downs National Park in accordance with the wider presumption in favour of sustainable development as outlined in Policy WMP1.
7.7 Policy WMP2 outlines the considerations taken into account with regards waste and minerals development within the National Park. The effectiveness of the policy is monitored through assessment of the levels of waste capacity and minerals extraction that have been permitted in the National Park within the monitoring period.
Table 4
Monitoring Application Additional Capacity? Period
2013/14 SNDP/12/02843/CW - Greystone Quarry - expansion of N fridge processing area. [Approved]
2014/15 SDNP/15/00790/CW - Falmer Court Farm - Retention N of imported waste material and profiling of existing materials to raise the level of a paddock for drainage improvements. [Refused]
2015/16 SDNP/15/05347/CW - Land at Northern Tip of Industrial Y - 15,000 tpa Recycling. Yard, New Road Industrial Area, Newhaven, East Note: this site is mostly Sussex, BN9 0HE - Change of use of existing Industrial within East Sussex (ESCC unit and yard into a construction and demolition waste Planning Reference: transfer station. [Approved] LW/767/CM), with a small area within the South Downs National Park.
2016/17 SDNP/16/04886/CNDC - Novington Sand Pit, Plumpton Permitted reserves of soft Lane, Plumpton, East Sussex - Variation of condition sand can continue to be 2 of LW/386/CM to allow the extraction of sand and extracted for 10 years restoration of the site to be completed not later than 2nd October 2026. [Approved]
2017/18 SDNP/17/02297/FUL - Golf Farm, Devil's Dyke Road, Y - 670,000 tonnes inert fill. Brighton, BN1 8YJ - Re-landscaping farmland through the importation of approximately 670,000 tonnes of inert material. [Approved]
2018/19 None N Waste and Minerals Monitoring Report 2018/19 29
Providing for Waste8 8 Providing for Waste
Waste in East Sussex
8.1 It is currently estimated that around 1.7 million tonnes of solid waste are handled in East Sussex and Brighton & Hove each year. The main types are:
Local Authority Collected Waste (LACW) - LACW is waste that is collected by local authorities, and it is estimated to make up about 21% of all wastes in the Plan Area. Household waste comprises approximately 95% of municipal waste, the remainder coming from sources such as street sweepings and public parks and gardens. Commercial and Industrial Waste (C&I)- This is produced from shops, food outlets, businesses, and manufacturing activities and comprises about 27% of wastes in the Plan area. Construction, Demolition and Excavation Waste (CDEW)- Produced from building activity, with a considerable proportion of it considered to be inert. CDEW comprises an estimated 51% of all waste arisings. Other wastes- This includes hazardous waste, liquid waste (other than wastewater), and wastes arising from the agricultural sector. Although hazardous waste streams only make up approximately 1% of the total waste stream, they still need to be planned for and often require specialist treatment facilities and include stringent environmental controls.
Figure 1 Proportion of Solid Waste Arising in East Sussex and Brighton & Hove 30 Waste and Minerals Monitoring Report 2018/19
8Providing for Waste
8.2 The Authorities monitor the quantity of local authority collected waste but it does not directly monitor the quantity of commercial and industrial waste or construction, demolition and excavation waste arisings. No direct monitoring of C&I and CDEW waste management is undertaken but estimates of arisings can be derived from data provided by the Environment Agency and other surveys.
8.3 There are various facilities to treat and dispose of waste, including recycling centres, transfer stations, treatment sites and landfill sites. A list of current sites with planning permission for the management of waste in East Sussex and Brighton & Hove, together with their estimated capacities, is provided in Appendix F.
Local Authority Collected Waste
Arisings
8.4 Local Authority waste arisings and management for the Plan Area for the years 2007/08 to 2018/19 are shown in Figure 2 below.
Figure 2 Local Authority Collected Waste Arisings and Management for the Plan Area 2006/07 - 2017/18
8.5 Local authority collected waste and household arisings fell slightly in 2018/19 compared to 2017/18. LACW arisings have been depressed for a number of years, and this has been attributed to the economic downturn(8). Over the long term local authority collected arisings are still expected to grow with increased population and number of households. Any return to significant economic growth may also have an effect.
8 Historically there has been a relationship between economic growth and growth in waste arisings. Waste and Minerals Monitoring Report 2018/19 31
Providing for Waste8
Table 5 Estimated Future Arisings for LACW
Year Min Growth (Tonnes) Max Growth (Tonnes) 2015/16 361,000 392,000 2020/21 356,000 414,000 2025/26 352,000 437,000
Management
8.6 Tables 6 and 7 on the following pages, together with Figure 2 above, show the total local authority collected waste and household waste arisings in East Sussex and Brighton & Hove by management approach and the percentage for each management type over the last five years(9).
8.7 Table 6 shows that since 2010/11 there has been a significant increase in the amount of waste being diverted to energy recovery along with a corresponding decrease in the amount sent to landfill. The proportion of waste recycled has also increased. The increase in recovery is due to the Newhaven ERF coming on stream which allows waste which was previously exported to ERFs and landfills in neighbouring areas to be treated within the Plan Area's boundaries. This in turn reduces the considerable distance it previously travelled by road.
8.8 There are currently no non-inert landfills operating or proposed for development within the Plan Area.
9 The Waste Local Plan definition of recovery includes recycling, reuse and composting as well as energy recovery 32 W
Table 6 Local Authority Collected Waste in East Sussex and Brighton & Hove (tonnes) 8 aste P
2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 and roviding
Recycled 81,108 80,463 77,993 77,845 74,285 72,513 79,042 83,746 98,449 87,680 86,461 84,790 Miner (21%) (22%) (21%) (21%) (21%) (20%) (22%) (23%) (26%) (23%) (23%) (23%) als Reuse 10,187 9,714 8,659 6,938 7,300 9,917 10,816 12,557 12,539 14,050 13,531 12,224 Monitoring (3%) (3%) (2%) (2%) (3%) (3%) (3%) (3%) (3%) (4%) (4%) (3%)
Composted 33,311 37,027 41,340 43,940 48,279 48,461 44,345 41,034 39,653 46,439 45,596 47,423 (9%) (10%) (11%) (12%) (13%) (13%) (12%) (12%) (10%) (12%) (12%) (13%) Report Energy 37,973 73,806 96,198 89,917 155,504 206,625 203,772 216,219 211,706 208,887 208,651 207,022 Recovery (10%) (20%) (26%) (25%) (43%) (57%) (57%) (59%) (56%) (56%) (56%) (57%) for 2018/19 Disposal to 219,035 170,135 142,554 147,100 74,623 22,163 20,018 11,589 17,774 17,157 17,826 14,447 Land (57%) (46%) (39%) (40%) (21%) (6%) (6%) (3%) (5%) (5%) (5%) (4%) W Total 381,614 371,145 366,744 365,741 359,991 359,690 357,995 365.145 380,120 374,213 372,065 365,906 aste Table 7 Household Waste Arisings in East Sussex and Brighton & Hove (tonnes)
2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19
Recycled 81,108 80,463 76,899 76,740 73,248 70,685 77,872 82,422 83,176 86,125 85,229 83,656 (22%) (23%) (22%) (22%) (21%) (21%) (22%) (24%) (24%) (24%) (24%) (24%)
Reused N/A N/A N/A 1,480 2,111 1,052 443 506 513 1,520 1,728 1,838 (10) (0.4%) (1%) (<1%) (<1%) (<1%) (<1%> (<1%) (<1%) (1%)
Composted 33,311 37,027 41,010 43,542 47,856 48,025 44,106 41,034 39,653 45,615 44,925 46,660 (9%) (10%) (12%) (12%) (14%) (14%) (13%) (12%) (11%) (13%) (13%) (14%)
Energy 37,973 73,806 96,198 89,917 153,670 201,950 201,648 214,021 209,931 206,164 204,563 201,884 Recovery (10%) (21%) (28%) (26%) (45%) (59%) (59%) (61%) (60%) (58%) (58%) (58%)
Disposal to 210,601 161,435 134,107 136,910 65,497 18,787 19,366 10,888 15,831 15,217 14,593 11,934 Land (58%) (46%) (39%) (39%) (19%) (6%) (6%) (3%) (5%) (4%) (4%) (3%)
Total 362,993 352,731 348,214 348,590 342,382 340,498 343,489 348,891 349,104 354,642 351,037 345,409 P roviding W aste and Miner for als Monitoring W aste Report 2018/19 8
10 Reuse of household waste was not recorded separately until 2010/11 33 34 Waste and Minerals Monitoring Report 2018/19
8Providing for Waste
Commercial & Industrial Waste
Arisings
8.9 Accurate records of total C&I waste arisings are difficult to obtain. The 'AEA Review of Future Waste Management Capacity Requirements - East Sussex and Brighton & Hove (2011)' (AEA Review 2011) concluded that the most reliable estimate of C&I Waste in 2008/09 was 475,000 tonnes, (this was based on an average of two approaches - the 'management approach' and the 'point of production'). This report also made predictions of the anticipated arisings.
8.10 A first review and update of the C&I management method arisings estimate first was presented in the 2013/14 AMR and has been subsequently updated. The management method provides an estimate of the minimum level of waste arisings based on Environment Agency Waste Data Interrogator and Waste Data Flow data. The waste data and method used to calculate these values is complex and makes a number of assumptions; as a result there are a number of areas of uncertainty and the data should be treated with caution.
8.11 The results as shown in Table 8 and Figure 3 below indicate that C&I waste arisings were significantly reduced during the recession and have slowly been recovering. The 2018 estimate appears to be slightly lower than the 2017. The exact cause for the decrease is unknown, but it may be that the decrease accurately reflects an increase in C&I arisings or it may be a result of other factors such as better reporting, the number of housing completions, economic activity, or new factors that the calculation methodology does not allow for; alternatively it may be a combination of these and other factors.
8.12 It should be noted that unlike the information elsewhere in this document this data is based on the calendar year 1 January to 31 December, and not the financial year 1 April to 31 March.
Figure 3 Review C&I management method waste arising estimates Waste and Minerals Monitoring Report 2018/19 35
Providing for Waste8
Table 8 First review of the C&I management method arisings estimate
Year 2008 2009 2010 2011 2012 2013
Arisings 422,353 458,721 377,296 341,898 412,201 426,825 estimate
Year 2014 2015 2016 2017 2018 2019
Arisings 462,189 450,822 556,393 557,789 516,420 No data. estimate
Management
8.13 The AEA Review 2011 concluded that the most reliable estimate of C&I Waste management methods in 2008/09 were: 67% material recycled and composted; 29% disposed to land; and 4% reused. The landfill data in Table 9 suggests that these proportions may have changed, but further research is required to establish if this is correct.
Construction, Demolition & Excavation Waste
Arisings
8.14 The AEA Review 2011 concluded that the most reliable estimate of CDE Waste arisings in 2008/09 was 906,000 tonnes. This report also made predictions of the anticipated arisings. There has been no new information since the publication of that report.
Management
8.15 The 'AEA Review of Future Waste Management Capacity Requirements - East Sussex and Brighton & Hove' concluded that the most reliable estimate of CDE Waste management methods in 2008/09 were: 45% of all material being recycled; 15% being sent to landfill and the remainder (40%) being disposed of using alternative methods. Alternative methods include management of waste outside the recorded system such as reuse on site, use in small scale landscaping projects etc. There has been no new information since the publication of that report.
8.16 Monitoring of CDEW sites to obtain data for the AM 2018 survey indicates that within the Plan Area there is at least 515 000 tonnes of recycled aggregates being produced from CDEW each year.
Disposal to Land
8.17 There are times when waste can not be reused, recycled or recovered. This may be because there is insufficient capacity to recycle or recover the material, it may be uneconomical, or it may be impractical do to so. In these instances it must be disposed of to landfill or land-raise sites, collectively known as land-disposal. The information below illustrates where LACW and C&I waste produced in the Plan Area, when destined for land disposal, is sent to. This 36 Waste and Minerals Monitoring Report 2018/19
8Providing for Waste
information is based on Environment Agency data. It should be noted that unlike the information elsewhere in this document this data is based on the calendar year 1 January to 31 December, and not the financial year 1 April to 31 March. It is also important to note that origin information in the EA data is not comprehensive. Table 9 Waste disposed to land / Landfills receiving more than 1,000 tpa from East Sussex.
Location Site Name 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
East Sussex Beddingham 49,836 X X X X X X X X X (1) East Sussex Pebsham 61,279 234,066 175,066 72,834 46,786 X X X X X
West Horton 153,433 272,205 196,564 X X X X X X X Sussex
Surrey Redhill 10,856 1,197 6,085 1,978 5,592 5,585 17,790 11,056 5,016
West Lidsey 5,230 12,239 15,908 20,294 24,388 31,983 22,419 X X X Sussex
Kent Greatness Quarry 7,156 1,206 2,178
West Brookhurst Wood 12,727 44,100 35,996 20,926 18,446 6,431 33,800 22,566 11,618 P
Sussex roviding (2) Hampshire Squabb Wood Landfill Site 5,574 X X X
Essex Pitsea Landfill 1,995 2,762 W
Havering Rainham Landfill 4,754 5,080 aste
Buckinghamshire Springfield Farm Landfill 2,095 7,226 and Miner
Thurrock Ockendon Area II & III Landfill 1,309 15,915 for als Total 287,790 532,434 437,723 129,124 99,651 56,020 35,640 53,585 44,541 47,033 Monitoring
1. Closed in 2013. W 2. Site closed and restoration commenced September 2016. aste
X:Site closed. Report 2018/19 8 37 38 Waste and Minerals Monitoring Report 2018/19
8Providing for Waste
Waste Management Capacity
8.18 The current total capacity provided by facilities managing waste in the Plan Area is set out in Table 10 below. This table identifies different types of activity which represent the key differences between the ways in which waste is managed. It includes facilities that are operating or currently not operating, but could be re-opened. It includes all facilities with planning permission, but excludes those which have closed permanently. The capacity values are estimated using information from the planning application and any environmental permits.
Changes between 2017/18 and 2018/19
8.19 While undertaking this years review of the waste management capacity it was identified that a number of facilities had closed, and some of these closures occurred in previous years, but not been accounted for. The estimate capacity now reflects this updated information. In addition the capacity estimates are now being shown as rounded to the nearest 1,000 tonnes to better reflect the uncertainty surrounding the data. Table 10 Waste Management Capacity
Type of Activity Total Capacity (tonnes per annum) as
Waste and 01/04/2012 01/04/2013 01/04/2014 01/04/2015 01/04/2016 01/04/2017 01/04/2018 01/04/2019 Minerals Plan
Recycling & Composting 490,000 500,000 545,000 566,000 609,000 563,000 573,000 573,000 595,000
Bulk Metal (e.g. Scrapyards) 441,000 440,000 440,000 440,000 435,000 435,000 436,000 435,000 435,000
(1) (1) (1) 1) Recovery 210,000 210,000 210,000 210,000 210,000 210,000 210,000 210,000 210,000(
CDEW Recycling 630,000 649,000 669,000 714,000 671,000 689,000 667,000 667,000 632,000
Specialist Treatment 61,000 71,000 71,000 66,000 67,000 67,000 67,000 67,000 67,000 (Hazardous)
Inert Landfill (including inert 15,000 15,000 58,000 17,000 15,000 15,000 15,000 692,000 336,000 P
for beneficial use WMP8b) roviding
Non-Hazardous (including 150,000 150,000 30,000 0 0 0 0 0 0 Stable Non-Reactive (total void space Hazardous Wastes) Landfill (total void space in cubic metres) (total void space
in cubic metres) in cubic metres) W aste
Hazardous Landfill 0 0 0 0 0 0 0 0 0 and Miner
1. The ERF currently operates above the nominal capacity. In 2013 it managed 232,000 tonnes. for als Monitoring W aste Report 2018/19 8 39 40 Waste and Minerals Monitoring Report 2018/19
8Providing for Waste
8.20 Specialist Treatment are facilities that only take a very specific type of waste that must be dealt with in a specialised way. Examples in the East Sussex and Brighton & Hove area are plasterboard recycling, oil recycling and waste solvent recovery.
New Waste Management Capacity
8.21 Details of planning permissions granted within the monitoring period which provide new waste management capacity are shown in Table 11 below. Appendix F lists all permitted waste management sites in East Sussex and Brighton & Hove.
8.22 Both of the permissions granted that contributed waste management capacity were located on a site identified within the WMSP.
Table 11 Planning Permissions Granted for New Waste Management Capacity in the Monitoring Period (1 April 2018 to 31 March 2019
Admin Site Planning Permission Details New Throughput # Capacity (tpa) (if known)
116 Polegate Yard, The expansion of an existing waste 40,000 tpa Summerhill Lane, management use over adjacent land to (Recycling) Hailsham. provide for a fully enclosed Materials Recovery Facility.
151 4A Fisher Terminal, East Proposed Installation & operation of 4,000 tpa (Specialist) Quay, Newhaven, energy conversion plant including Newhaven Port, BN9 0DA receipt and processing of waste feedstock.
Policy Monitoring
Policy WMP3a - Promoting Waste Prevention, Re-use and Waste Awareness
8.23 Policy WMP3a seeks to minimise the amount of waste that is produced. Local Authority Collected Waste arisings for the Plan Area in 2018/19 were approximately 366,000 tonnes, this total is a decrease on the previous year. C&I arisings in 2018 are slightly lower than 2016 & 2017. Since the publication of the last Monitoring Report, no new information has become available regarding the overall production of CDEW.
Policy WMP3b - Turning Waste into a Resource
Table 12 Targets for the Management of Local Authority Collected Waste
Year Recycling Overall Recovery
Target Actual Target Actual
2015/16 45% 40% 98% 95%
2020/21 50% 98% Waste and Minerals Monitoring Report 2018/19 41
Providing for Waste8
Year Recycling Overall Recovery
Target Actual Target Actual
2025/26 55% 98%
8.24 The Plan aims to manage waste in accordance with the Waste Hierarchy. The Plan looks to minimise the amount of waste sent to landfill and maximise the amount of waste that is recycled and recovered. Policy WMP3b sets high targets for the recovery of waste.
8.25 The WMP has a target to recycle 45%, with an overall recovery target of 98% of LACW waste by 31 March 2016. At the end of the monitoring period the recycling rate (including reuse, recycling and composting) for the Plan Area was 40%; the overall recovery rate was 95%. Since the publication of the last Monitoring Report, no new information has become available regarding the recycling and recovery rates of C&I and CDEW.
8.26 Approximately 47,000 tonnes of LACW and C&I waste was exported for land disposal at facilities outside of the Plan Area during 2018. No LACW or C&I waste was sent to landfill inside the Plan Area. The amount of LACW being sent to landfill has fallen from 147,000 tonnes in 2011/12 to 22,000 in 2012/13 and has remained between 22,000 and 12,000 tonnes per annum since then. This is mostly due to the Newhaven Energy Recovery Facility becoming fully operational.
Policy WMP3c - Production of Energy from Waste (EfW)
8.27 Policy WMP3c requires that recovery facilities maximise their recovery of energy in line with the EU Waste Framework Directive. The only specific energy from waste facility in the Plan Area is the Newhaven Energy Recovery Facility. This produces 19 megawatts of electricity and meets the requirements of this policy. There are also a number of small energy generating plant at historic landfill and at waste water treatment works in the Plan Area.
Policy WMP5 - Provision of Built Waste Facilities
8.28 Policy WMP5 contains the requirements for the amount of additional capacity that is required for the recycling and recovery of waste for the Plan Area. This takes into account the need to ensure net self sufficiency. The total new permitted throughput capacity within the East Sussex and Brighton & Hove in the monitoring period is:
40,000 tonnes of capacity for recycling of C&I and CDEW waste; and
4,000 tonnes of specialist non-hazardous waste management capacity. 42 Waste and Minerals Monitoring Report 2018/19
8Providing for Waste
8.29 The table below shows the progress against the targets in the WMP. The 'Combined Provision' column reflects that the WMP permits recycling capacity to be made in lieu of recovery capacity. As of 1 April 2019, after accounting for sites no longer operating, an additional 105,000 tpa of recycling capacity and no recovery capacity had been permitted since the adoption of the WMP. The 2015/16 target was met.
Table 13 Estimated Required Management Capacity as set out in WMP5 and actual results.
Year Recycling Recovery Combined Provision
Estimated Actual Estimated Actual Estimated Actual Management Provision Management Provision Management Provision Tonnage Tonnage Range Tonnage Range Range
2015/16 0 - 80,000tpa 76,500tpa 60,000 - 0tpa 60,000 - 76,500tpa 200,000tpa 280,000tpa
2020/21 0 - 120,000tpa 80,000 - 80,000 - 220,000tpa 340,000tpa
2026/27 30,0000 - 60,000 - 90,000 - 170,000tpa 220,000tpa 390,000tpa
Policy WMP7a - Sustainable Locations for Waste Development (Excluding Land Disposal)
8.30 Policy WMP7a sets out broad Areas of Focus in which waste facilities should be located. These relate to within or close to urban areas, good transport connections and outside designated areas such as the AONB and SDNP. All of the capacity permitted in 2018/19 (as set out above), was located within the Areas of Focus.
Policy WMP7b - More Detailed Criteria for Waste Development
8.31 Policy WMP7b provides additional guidance for potentially suitable sites. These include: industrial land; employment land; previously developed land; and land that was already in waste management uses. Policy WMP7b assists the development management decisions on new capacity. During the monitoring period all of the approved applications were considered to be consistent with WMP7b.
Policy WMP8a - Land Disposal for Non-Inert Waste
8.32 Policy WMP8a sets strict criteria by which applications for land disposal for non-inert waste would be assessed. There have been no applications to establish new Non-Inert Landfill/ Landraise during the monitoring period.
Policy WMP8b - Deposit of Inert Waste on Land for Beneficial Uses
8.33 During the monitoring period, no applications involving deposition of inert material for beneficial use were determined within the Plan Area. Waste and Minerals Monitoring Report 2018/19 43
Providing for Waste8
Other Waste Policies
8.34 The most appropriate method of monitoring some policies contained in the Plan will be by periodic review. In these reviews the policies will be assessed to see if they are being implemented as intended, and if there are any implications. This applies to the following policies:
Policy WMP3d - Minimising and Managing Waste During Construction, Demolition and Excavation
Policy WMP3e - Waste Management in New Development in the Plan Area
Policy WMP6 - Safeguarding Waste Sites
Policy WMP8c - Management of Landfill Gas
Policy WMP9b - Low Level Radioactive Waste
Policy WMP9a - Hazardous Waste
Policy WMP10 - Management of Waste Water and Sewage Sludge
8.35 An initial review of all WMLP policies was undertaken in 2017. The Draft Revised Policies document includes proposals to revised Policies WMP7a and WMP7b. It does not include proposals in relation to any other policies in this section. 44 Waste and Minerals Monitoring Report 2018/19
9Providing for Minerals 9 Providing for Minerals
Minerals in East Sussex
9.1 The principal mineral deposits in East Sussex are aggregates (sand and gravel), clay, gypsum and chalk.
Gravel deposits are confined to the coastal areas and river valleys. Clay is worked largely in the clay vale of the Low Weald. The South Downs National Park comprises an extensive area of chalk and some soft sand deposits. The largest deposit of gypsum in the United Kingdom is situated at Brightling/Robertsbridge.
9.2 A full list of minerals workings operational in the Plan Area in 2018/2019 is provided in Appendix H.
9.3 Ongoing mineral production is assessed through consideration of planning applications, continued monitoring of sites and in the case of sand and gravel the production of yearly Aggregates Monitoring Reports (AMR) on behalf of SEEAWP. Each of the Mineral Planning Authorities in England and Wales collates data from minerals sites and submits the results to the Ministry of Housing, Communities and Local Government, through the relevant Aggregate Working Party. Normally every four years the survey includes information on the destination of materials. The most recent national four yearly Aggregate Minerals (AM) Survey is based on 2014 data. (11) These survey results along with other recent non - confidential local figures from the Aggregates Monitoring 2018 survey, are used to update the AMR and LAA findings for 2018/19.
9.4 Mineral planning permissions are subject to periodic review through the review of old minerals permissions (ROMP) process established by the Environment Act 1995. The reviews provide for an opportunity to update conditions to provide additional environmental protection in regard to working arrangements and restoration proposals. The Growth and Infrastructure Act 2013 has altered the ROMP process in that a minerals planning authority can now adopt their own relevant review dates rather than the more rigid 15 yearly reviews. The change is intended to reduce the need for ROMP reviews where existing minerals planning conditions are judged by the Council to be satisfactory. A list of permissions and the relevant review dates are included in Appendix J.
9.5 Local Aggregate Assessment
9.6 The County Council has published the 2019 Local Aggregate Assessment (LAA) for East Sussex, South Downs and Brighton & Hove based on 2018 data (which is appended to this document). The overall picture of aggregate supply to the Plan
11 Following a delay, the Government is now undertaking the more extensive "four year" survey during 2020. Waste and Minerals Monitoring Report 2018/19 45
Providing for Minerals9 area is of heavy dependence on imports by road, sea and rail. Significant levels of marine imports (marine dredged and crushed rock) are received through Shoreham Port and Newhaven and to a lesser extent Rye. Crushed rock, recycled aggregate and sand and gravel are imported by rail at Newhaven. Land-won sand and gravel is extracted in the east of the Plan area at Lydd with about 50% of material being consumed in East Sussex. It is assumed that all soft sand supply is met by road imports as there are currently no active sites in the Plan Area. (The Authorities are undertaking research to establish the origin of soft sand material used in the Plan area.) A steady supply of recycled material is produced from construction waste management facilities across the Plan area. A continuing and increasing demand for construction materials is anticipated.
9.7 The NPPF requires that the LAA considers all supply options (land-won, marine, secondary and recycled material), and be based on a rolling average of 10 years sales data and other relevant local information. In past years the Authorities' assessment was that there were particular circumstances in this Plan Area that made it difficult to prepare the LAA totally along the lines indicated in the NPPG. Previous LAAs concluded that the assessment could not use past 10 years sales data as this was too volatile because there is a very small number of production sites and therefore there has been major variation in sales figures from nothing to more substantial output. Past LAAs instead used the Apportionment figure in the Adopted WMLP as a surrogate figure for forward planning.
9.8 In 2016 a Public Examination on the soundness and legal compliance of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan was held. Hearings focused on the whether the Plan provided a sufficient and adequate supply of aggregates. Whilst the Inspector found the Sites Plan sound in his Report, he highlighted the need for a Review of the aggregate minerals policies. Taking on board the Inspector's comments the Authorities agreed to a Review of the WMLP and in September 2017 published a consultation on the Call for Evidence & Sites. An extension to an existing sand and gravel quarry in the east of the Plan Area was received at the Call for Sites stage. The Authorities anticipate publishing the next stage of consultation in Spring 2020.
9.9 The LAA examines the latest information and data available on aggregates production and supply patterns in the Plan Area, and aims to inform the forthcoming consultation documents.
Assessing Performance of Minerals Policies
9.10 The Plan contains a number of policies which aim to deliver different mineral resources for the Plan period.
Policy WMP4 - Sustainable Provision of Minerals
9.11 This Policy requires sustainable use and production of minerals in the Plan Area using the minerals hierarchy, for example by promoting secondary and recycled materials. Information on secondary and recycled aggregates has in the past been 46 Waste and Minerals Monitoring Report 2018/19
9Providing for Minerals
limited by constraints in national and local surveys. However, more detailed and updated production figures for the Plan area are now available through the annual aggregate survey which has seen much improved response rates in the last 3 years. More details on recycled/secondary aggregates production (this includes reject brick material from the clay industry) and consumption is contained in the LAA appended to this report .
Policy WMP11 - Provision of Aggregates
9.12 Much of the evidence required to monitor the implementation of Policy WMP11 is found in the LAA discussed in the previous section and appended to this document. The Draft Revised Policies document includes proposals to revise Policy WMP11.
Policy WMP12 - Provision of Gypsum
9.13 East Sussex is the only County in the South East to produce gypsum commercially and the Robertsbridge works are identified as having national importance.
9.14 Policy WMP12 requires that reserves are maintained from the British Gypsum mine throughout the Plan period. The Gypsum mine at Brightling has more than 20 years of reserves remaining.
9.15 The Brightling mine has a capacity to excavate some 1 million tonnes of gypsum per annum; at present the mine is not worked to its full potential, but output has recently increased. In the past the material has been mainly exported from the site by road and used as an essential additive in the manufacture of Portland cement.
9.16 Plasterboard and related products are manufactured at the Robertsbridge Works using mined gypsum, as well as imported natural gypsum imported from countries abroad (such as Spain) and Desulphogypsum (DSG) from power stations in other areas in the UK. Typically, over 0.3 million tonnes of gypsum are imported to the site by rail.
9.17 In 2012 a planning permission was granted for a strategic DSG storage area and associated development for a period of 10 years at the site. An application for a review of mineral planning conditions was approved in 2013.
9.18 An application to vary conditions attached to the permission for the site was approved in 2015. This allows high-grade natural gypsum from outside East Sussex to be used at the Works for manufacturing plasterboard, and also for it to be imported by rail and on a back-haul basis using HGVs that have previously transferred Brightling rock to cement production plants elsewhere.
9.19 In March 2018 planning permission was granted for realignment of a site entrance, and also for provision of a shed for dry storage of mechanical spares for the industrial process. Waste and Minerals Monitoring Report 2018/19 47
Providing for Minerals9
9.20 Plans are currently afoot to use material from the Brightling mine for plasterboard production at the Works.
Policy WMP13 - Provision of Clay
9.21 Continued production at existing brickworks is supported and Policy WMP13 safeguards and maintains sufficient supplies of clay for brick and tile manufacture. There are six operational clay sites within East Sussex. Figures for clay production can fluctuate as material is stockpiled for working over many months. Whilst Government data is now unavailable for clay production figures, local evidence and monitoring suggests that clay production in East Sussex is stable, and indicates that there was robust production of specialised products during the monitoring period.
9.22 In At the end of 2018 permission was granted to allow export of sand/sandy clay and an amended restoration scheme for the Ashdown brickworks quarry.
9.23 The WMP identifies that reserves at Aldershaw Farm are low and further reserves need to be identified if production is to continue in the future. The Draft Revised Policies document includes proposals to revise Policy WMP13.
Policy WMP14 - Safeguarding Mineral Resources
9.24 Policy WMP14 sets out how minerals resources will be safeguarded from unnecessary sterilisation by alternative development. Minerals Safeguarding Areas are identified in the adopted Waste and Minerals Sites Plan. The Draft Revised Policies document includes proposals to revised Policy WMP14.
Policy WMP15 - Safeguarding Wharves and Railheads
9.25 Policy WMP15 safeguards railheads, wharves and rail sidings for existing and future mineral imports, and in particular overall mineral wharf capacity in ports. Capacity and activity at existing wharves and information on rail imports will be monitored. Wharves, railheads and facilities for concrete batching, coated materials manufacture and other concrete products are identified for safeguarding in the adopted Waste and Minerals Sites Plan. The Draft Revised Policies document includes proposals to revised Policy WMP15.
9.26 Adur District Council, Brighton & Hove City Council, West Sussex County Council (WSCC) and Shoreham Port Authority are partners in the adopted Shoreham Harbour Joint Area Action Plan (JAAP) which sets out a 15 – 20 years plan to guide the regeneration of Shoreham Harbour. The JAAP proposals for housing, employment and economy and environmental improvements, include some consolidation of operations and redevelopment of mineral wharves (particularly in West Sussex). It is recognised that the provision and safeguarding of minerals wharfage is a key issue if the JAAP aims are to be achieved. To this end the JAAP partners, together with South Downs National Park Authority, and ESCC have signed a Statement of Common Ground (SOCG) to underpin effective cooperation and 48 Waste and Minerals Monitoring Report 2018/19
9Providing for Minerals
collaboration between the partners in addressing strategic cross-boundary issues as they relate to planning for minerals infrastructure and safeguarding in Shoreham Harbour.
9.27 Ferry Wharf (a vacant mineral wharf) on the Brighton & Hove side of the port is allocated in the JAAP for redevelopment for employment uses, subject to other policies in the development plan being satisfied. Permission was granted in 2019 for flexible B1/B8 floorspace on this site which will preclude its future use for minerals imports. In line with the SOCG which allows for “flexible arrangements such as wharves within the safeguarding area which cater for a range of materials, including minerals, to compensate for the loss of capacity at a specific mineral wharf”, the Port Authority has agreed to the flexible use of the Outer Layby and Brighton Terminal general wharves elsewhere within the Harbour to handle mineral imports when demand requires it. In line with this approach, the Outer Layby wharf has already been used for some mineral imports.
9.28 Policy WMP16 - Exploration for Oil and Gas
9.29 Policy WMP16 provides a policy framework for any potential oil and gas exploration, appraisal and production. There is no commercial production of hydrocarbons in East Sussex.
9.30 The 14th round of bids for onshore licences closed in October 2014 and no new Licence areas were proposed for East Sussex. There is currently only one existing Licence within East Sussex covering 20 square kilometres around North Chailey. There are no current planning applications for any oil and gas exploration in East Sussex.
9.31 Chalk
9.32 Historic chalk workings in East Sussex included extraction for cement works. The cement industry declined during the 1960’s and 1970’s, with the last cement plant closing in 1975. Tarring Neville near Newhaven which produced small quantities of chalk for specialised use at the Artex factory in Newhaven was the last active chalk site in the County. There are now no operational chalk quarries in the Plan Area, and the Waste and Minerals Plan does not safeguard chalk resources. Chalk is imported from West Sussex for use in small amounts for ongoing agricultural use and has in the past been used in road construction works. Waste and Minerals Monitoring Report 2018/19 49
Overarching Policies10 10 Overarching Policies
10.1 There are six overarching policies which apply to both waste and minerals development and development determined by other planning authorities:
Policy WMP17 - Restoration
Policy WMP18 - Transport - Road, Rail and Water
Policy WMP19 - Co-location of Complementary Facilities
Policy WMP20 - Community Involvement and Benefits
Policy WMP21 - Opportunities for Sustainable Waste Management and Minerals Production in Other Developments
Policy WMP22 - Increased Operational Capacity within the Site Boundary of Existing Waste Facilities
10.2 A review of the effectiveness of these policies is currently being undertaken as part of the Review of the Waste and Minerals Local Plan. The Draft Revised Policies document contains no proposals to alter these policies. The usage of these policies is detailed within the Overarching Strategy section of this report. 50 Waste and Minerals Monitoring Report 2018/19
11Development Management Policies 11 Development Management Policies
11.1 There are nine development management policies within the Waste and Minerals Local Plan used to determine waste and minerals planning applications:
Policy WMP23a - Design Principles for Built Waste Facilities Policy WMP23b - Operation of Sites Policy WMP24a - Climate Change Policy WMP24b - Resource and Energy Use Policy WMP25 - General Amenity Policy WMP26 - Traffic Impacts Policy WMP27 - Environment and Environmental Enhancement Policy WMP28a - Flood Risk Policy WMP28b - Water Resources and Water Quality
11.2 These policies provide a local context and in relation to national planning policy and are used as a suite of policies with which to determine planning applications. A review of the effectiveness of these development management policies is currently being undertaken as part of the Review of the Waste and Minerals Local Plan and the Draft Revised Policies document contains proposals to update policy WMP27 - Environment and Environmental Enhancement. The usage of these policies is detailed within the Overarching Strategy section of this report.
11.3 The number of enforcement cases received is an indicator of policy effectiveness. The number of cases received in the fourth (calendar) quarter of 2019 was 12. This is the lowest number for this period since the fourth quarter of 2015, when 11 cases were received. Waste and Minerals Monitoring Report 2018/19 51
Enforcement12 12 Enforcement
12.1 The NPPF states that effective enforcement is important as a means of maintaining public confidence in the planning system. The County Council undertakes regular site monitoring, and investigates complaints received regarding alleged breaches of planning control. The figure overleaf shows the total caseload of the Council’s enforcement team, as well as the number of cases received and resolved per quarter, since the start of 2010.
12.2 The number of cases outstanding has remained historically low, with 13 in the fourth (calendar) quarter of 2019, well below the peak of first quarter 2015.
12.3 The general trend for the number of enforcement cases received in any given quarter, allowing for seasonal variation, is in general conformity with that of the performance of the local economy. It is suggested that when there is more economic activity, there is a greater possibility for conflict between uses of land. Similarly, the number of minerals and waste planning applications received appears to follow a similar trend albeit with a delay, as economic changes take time to impact on activity. 52 W
Figure 4 Enforcement Caseload in East Sussex 12 aste and Enforcement Miner als Monitoring Report 2018/19
Note: Since the publication of the 2012/13 Monitoring Report these figures have been revised and have been updated in a number of places. Waste and Minerals Monitoring Report 2018/19 53
Enforcement12
Enforcement Trends - Inert Waste
12.4 As part of their regular duties the Monitoring & Enforcement Officer undertakes inspections of waste sites and has regular discussions with local waste operators. Smaller waste operators continue to have significant issues with the disposal of soil.
12.5 There is presently only one landfill in East Sussex taking soils for restoration purposes and others in surrounding counties will only take soils if they have been analysed, and the soil analysis report shows the soils to be uncontaminated. Small waste operators continue to find the cost of undertaking a soil analysis on every skip load prohibitively expensive. As a result operators are increasingly stockpiling large amounts of soils on their sites. Once stockpiled, each stockpile can be tested, once it has been proved to be uncontaminated it can then be disposed of. This is more economical, however it does result in larger stockpiles.
12.6 In contrast to the small operators, larger skip companies appear to have sufficient office staff to identify possible locations to lawfully dispose of these soils by scanning planning permission and approaching landowners who have got these consents to take these soils to further their developments. 54 Waste and Minerals Monitoring Report 2018/19
13Monitoring Issues 13 Monitoring Issues
13.1 There continues to be a lack of information for monitoring implementation in certain areas of the strategy and policies in the Waste and Minerals Plan.
13.2 With regard to minerals, producers are not compelled to provide information on production, reserves and future plans, and due to to the small number of producers in the Plan Area confidentiality of data can also be an issue. However, at present, most operators in the Plan area have agreed to making their production figures available for publication, and this greatly assists the Authorities in the annual monitoring process.
13.3 Obtaining an accurate record of non-municipal waste arisings is also difficult. However, work has been undertaken to establish more accurate data for the C&I and C&D waste streams. The results have been reported in Section 8, but maintaining data accuracy remains a challenge, as described below.
13.4 Some information on waste movements is provided from ‘waste returns’ submitted by the waste industry (i.e. the operators of permitted waste facilities) to the Environment Agency. It is often difficult to pinpoint the origin of waste, which may be recorded several times as it passes through different waste facilities for bulking and/or sorting before it is finally recorded as being recovered or disposed of and this can lead to double counting. In an attempt to alleviate this problem, the Environment Agency piloted a new 'Electronic Duty of Care' system from January 2011 to December 2014 which tracks waste movements digitally(12). It is hoped that in time this will enable much more accurate monitoring of non-municipal waste arisings and treatment methods. In addition, some waste is managed at sites where operators are exempt from the need to provide waste data.
13.5 Capacity figures for new waste facilities are recorded as new planning permissions are granted. However, where data is not submitted as part of a planning application, it may be necessary to request information. In any event, the issue of how to monitor increases in capacity resulting from new facilities or operational changes that do not require a separate planning permission, remains.
12 See www.environment-agency.gov.uk/aboutus/wfo/128930.aspx for more information. Waste and Minerals Monitoring Report 2018/19 55
Appendices 56 Waste and Minerals Monitoring Report 2018/19 AStructure of the Waste and Minerals Local Plan Appendix A: Structure of the Waste and Minerals Local Plan
Figure 5 Waste and Minerals Local Plan Structure (Novemer 2012) P Appendix B: Programme for the Waste and Minerals rogramme Development Scheme
Table 14 Programme for the Minerals and Waste Development Scheme (February 2020)
Document Title Subject Matter Geographic Area Authorities (jointly Timetable responsible)
East Sussex Statement of Review of the Statement of County of East Sussex (outside East Sussex County Council Adoption: Summer 2017. for Community Involvement Community Involvement. South Downs National Park) Start of next Review: Spring 2021
First Review of the Waste and A review, as necessary, of the County of East Sussex. East Sussex County Council; Call for Sites / Content (Reg18): Development Minerals Local Plan policies contained within the Local City of Brighton & Hove. South Downs National Park Summer / Autumn 2017; Preferred the East Sussex, South Downs and Plan, (excluding the Construction The area of the South Downs Authority; Strategy Consultation (Reg 18): Brighton & Hove Waste and and Demolition Supplementary National Park that lies within Brighton & Hove City Spring 2020; Pre-Submission Minerals Local Plan: Revised Planning Document, see below). the County of East Sussex. Council. Consultation (Reg 19): Autumn / Policies Winter 2020; Submission: early 2021; W (1) Adoption: Summer 2021. aste
Construction and Demolition A review of the Construction and County of East Sussex. East Sussex County Review of document: Summer / W Supplementary Planning Demolition Supplementary Council; Autumn 2021; Revocation (Reg aste Document - Review Planning Document with a view to 15(b)), if applicable: Spring 2022..(1) City of Brighton & Hove. and
revocation. Brighton & Hove City and Council. Miner als Scheme
1. Timetable subject to review. Monitoring Minerals
B.1 The Adopted Waste and Minerals Policy Map will be revised at the same time as any DPD is adopted so as to illustrate
geographically the application of the policies in the DPD revision (Town and Country Planning (Local Planning) (England) Regulations Report 2012 Reg 9). Please note, this Development Scheme may be subject to change. 2018/19 B 57 58 Waste and Minerals Monitoring Report 2018/19
CDuty to Co-operate Appendix C: Duty to Co-operate Regional Fora
C.1 This section only shows information for the year 2018/19. Please refer to other monitoring reports for historic information. Duty to W aste and Co-operate Miner als Monitoring Report 2018/19 C 59 60 W
Table 15 Log of DtC Activities (2017/18) - Regional Fora C aste Duty Topic(s) SEWPAG: Regional Waste SEEAWP: Aggregate supply and demand Ashdown Forest Officer Group and Miner
Who SEWPAG Authorities SEEAWP Authorities Authorities with a likely effect on the als
Ashdown Forest SAC. Monitoring to
Description SEWPAG meets to discuss waste planning SEEAWP provides technical advice about the The Ashdown Forest Officer Group meets to matters in the South East. A Memorandum supply and demand for aggregates in the discuss the strategic planning issue of Co-operate of Understanding (MoU) regarding the Duty South East to the Secretary of State for nitrogen levels in the Ashdown Forest. The Report to Co-operate is to be signed by all SEWPAG Communities and Local Government and meetings first started out with authorities
members. The MoU was approved by the mineral planning authorities. It also discussing the approaches adopted to 2018/19 Lead Member for Transport and Environment undertakes annual monitoring of aggregates address the identified issues. These on 17 June 2013. The MoU sets out how the production, by type and use, and the levels meetings have since progressed and now SEWPAG Authorities would approach the of permitted reserves. It meets about two authorities meet to discuss the formation Duty and set thresholds below which it was or three times a year. MPAs are required of a Statement of Common Ground (SoCG) considered that the Duty need not apply. to report their draft Local Aggregate which an adviser from the Planning Advisory Assessments to SEEAWP. Service (PAS) is present for.
Meeting Dates 26 April 2018 16 April 2018 7 February 2018 31 July 2018 16 July 2018 4 June 2018 9 October 2018 19 November 2018 29 November 2018
28 February 2019 13 February 2019
20 February 2020
Waste and Minerals Local Plan Review
Main Issues
C.2 1. Provision of recycled, marine and land-won aggregates. C.3 2. Land-won minerals provision in the Plan Area.
C.4 3. Safeguarding minerals and minerals infrastructure.
The safeguarding of mineral resources, specifically, aggregates including soft sand.
The maintenance and enhancement of wharf capacity at Newhaven, Shoreham and Rye.
The safeguarding of railheads at Newhaven and Robertsbridge.
Log of Activities (2018/19)
Table 16 Log of DtC Activities (2018/19) in relation to the Waste and Minerals Local Plan Review Duty Date Topic(s) Who Description
12-Jun-18 Soft Sand Kent CC Meeting regarding the provision of soft sand.
26-Jul-18 Review update All Plan area D&Bs Update provided at Local Plan Managers' meeting. to W
02-Aug-18 Potential extension of Lydd Kent CC, NE, EA and operator/consultants Meeting held to try and identify issues of concern raised by potential aste Quarry allocation of Lydd quarry extension in Kent. ESCC invited as issues thought and to be similar in East Sussex Co-operate Miner 02-Nov-18 Review Update All Plan Area D&Bs and Mid Sussex DC East Sussex Strategic Planning Members Group. Updated given to group
and Tunbridge Wells BC. members, explained that review commenced in 2017. 3 sites have been als
submitted as part of call for sites and evidence which are currently being Monitoring considered. Advised on slippage in timetable - Reg 18 consultation due in early 2019.
14-Nov-18 Review Progress Natural England Meeting with Natural England to discuss the viability of the extension sites Report submitted by Brett Aggregates for the Lydd Quarry site.
04-Dec-18 Review update Adur & Worthing Councils, West Sussex Update of the Local Plan Review given at the Planning Subgroup meeting. 2018/19
CC, ESCC and BHCC C 61 62 W C
Date Topic(s) Who Description aste Duty 11-Dec-18 Soft sand Kent CC, SDNPA, WSCC and ESCC Kent called meeting to discuss provision of soft sand from their Kent Minerals and
Local Plan and initiate a SoCG between the authorities. Miner
04-Sep-19 Content of review policies Escc, Shoreham Harbour Regeneration The importance of maintaining marine imports into the Plan Area and the als
Project/Adur District Council and BHCC role Shoreham Port has to play in this was discussed. The policy for Monitoring
safeguarding wharf capacity from alternative uses and reprovision elsewhere to if necessary, was reiterrated. The new policy requirements for proposed sensitive development which could affect safeguarded wharfage were Co-operate
explained. Report
28-Nov-19 DTC meeting on plan review Meeting with Rother District Council and Initial meetings on draft review plan. Hastings Borough Council 2018/19
11-Dec-19 DTC meeting on plan review Meeting with Lewes and Eastbourne Initial meetings on draft review plan. Councils
Other Communications
C.5 East Sussex County Council is a full member of the Planning Officer Society (POS) Minerals and Waste Learning Group (national forum) and the SDNPA and Brighton & Hove City Council are corresponding members. The County Council is also a member of the POS Minerals and Waste Forum. Officers regularly attend meetings where topical issues particularly concerning plan making are discussed. Membership of these fora has assisted with communication between other mineral and waste authorities during site plan preparation. Other meetings and discussions are listed below.
Main Issues (2013-2019)
1. Waste data and waste movements;
2. Capacity provision in other Plan Areas;
3. Protection of Brentford Rail Transfer; 4. Safeguarding aggregate import facilities at Ports in the Plan Area including Shoreham
5. Aggregate supply and demand in the Plan Area
Log of Activities (2018/19)
Table 17 Log of DtC Activities (2018/19) - Other Communications
Date Topic(s) Who Description
16-Apr-18 AM - meeting of the South East Mineral S/E Mineral Planning Authorities; Both meeting included discussions of Kent's Plans, the Planning Authorities; PM - SEEAWP SEEAWP. Local Aggregates Assessment, soft sand and other regional meeting. planning issues.
18-May-18 DM Forum All Plan area D&Bs D&Bs updated that plan timetable had slipped. DTC meetings are to arranged with D&Bs in due course. Reg Duty 18 likely by end of July 2018.
23-May-18 East Sussex Local Plan Managers Group All Plan Area D&Bs All D&Bs informed of the progress of the Waste and meeting Minerals Local Plan review. ESCC asked D&Bs for
information of developers of large projects to aid with to
the Soft Sand study. W aste and 12-Jun-18 Soft sand Kent County Council, East Sussex County Kent CC requested meeting to discuss soft sand provision Co-operate Council, SDNPA, WSCC in their draft Plan Miner 15-Jun-18 Transport for South East Draft Economic Transport for South East Comments submitted. Connectivity Review als Monitoring 06-Jul-18 Lewes Neighbourhood Plan Lewes District Council Comments submitted.
24-Aug-18 Hastings Town Centre and Bohemia Area Hastings Borough Council Comments submitted. Action Plan Report
07-Sep-18 DM Forum All Plan area D&Bs Update provided on the call for sites and evidence 2018/19 outcomes. D&Bs informed that ESCC will be contact to arrange DTC meeting in due course. C 63 64 W C
Date Topic(s) Who Description aste Duty 29-Oct-18 Rother DaSA Rother District Council Comments submitted. Problems identified regarding the and
soundness of policy DEN3. Miner
20-Nov-18 Waste Movements North Lincolnshire County Council Comments submitted. No changes in movements als
identified. Monitoring to 22-Nov-18 Rye Neighbourhood Plan Rother District Council Regulation 16 consultation. ESCC preparing comments. Co-operate
30-Nov-18 DM Forum All Plan area D&Bs Update of the review provided on the issues related to Report Lydd Quarry. ESCC updated on meeting held with Brett Aggregates, KCC and discussions with MMO in relation to potential routes forward to progress plan. 2018/19
Dec-18 Statement of Common Ground Kent County Council with South Downs Agreed that two separate Statements of Common Ground National Park Authority and Brighton & are required for the issue of soft sand. Hove City Council
Dec 2018 - February Scoping of Wharves and Railheads Study South East England Aggregates Working Discussions of a potential study to assess the current 2019 Party & East of England Aggregates situation of minerals infrastructure, future requirements Working Party; The Crown Estate and also assessing the capacity of railways for transporting aggregates. This study would inform Minerals and Waste Plans.
01-Feb-19 Soft Sand Suppy Kent County Council/Sevenoaks Borough Comments submitted onSevenoaks Borough Council’s Council Regulation 19 Draft Sevenoaks Local Plan
11-Feb-19 Minerals and Waste Local Plan Buckinghamshire County Council Modification Consultation.
21-Feb-19 Kent Draft Mineral Sites Plan Kent County Council Comments submitted.
21-Feb-19 South Downs and West Sussex Single Issue South Downs National Park and West Comments submitted. Soft Sand Review Sussex County Council
22-Feb-19 Surrey Waste Local Plan - Regulation 19 Surrey County Council Comments submitted.
22-Feb-19 Cross border waste movements Surrey County Council Comments submitted. Date Topic(s) Who Description
22-Feb-19 Draft SoCG Soft Sand KCC, ESCC, BHCC and Kent CC, South Downs NPA, Brighton & Comments submitted to clarify some inaccuracies in the SDNPA Hove CC draft version of the document.
25-Feb-19 Newhaven Neighbourhood Plan Lewes District Council Comments submitted.
27-Feb-19 SoCG Meeting Kent CC, South Downs NPA, West Sussex Meeting held with all parties to discuss positions of soft CC sand.
04-Mar-19 Soft Sand Provision Statement of Common SE MPAs Parties asked to provide comments on draft version. Ground
13-Mar-19 Soft Sand Provision Statement of Common SE MPAs Comments submitted. Ground
13-Mar-19 Soft Sand Review of the West Sussex Joint West Sussex County Council Comments submitted.
Minerals Local Plan - Issues and Options Duty Consultation
02-Apr-19 Kent Minerals Sites Plan Kent County Council Comments submitted
04-Apr-19 Statement of Common Ground Surrey and East Sussex County Council Draft version sent for comments. to W
09-Apr-19 Draft SoCG Soft Sand KCC, ESCC, BHCC and Kent CC, South Downs NPA, West Sussex Agreed at SEEAWP. aste SDNPA CC, BHCC and Co-operate
31-May-19 Waste Movements Statement of Common Cambridgeshire & Peterborough Comments submitted - statement of common ground not Miner Ground required. als
06-Sep-19 Waste and Minerals Development Adur and Worthing (Shoreham Harbour Meeting held regarding SOCG for Shoreham Port Monitoring Framework Regeneration) and Brighton & Hove CC
23-Oct-19 Statement of Common Ground Surrey and East Sussex County Council SOCG Signed. Report 06-Dec-19 Eastbourne Issues and Options Plan Eastbourne Borough Council Comments submitted.
20-Dec-19 South London Waste Plan Issues and South London Boroughs Comments Submitted. 2018/19
Preffered Options C 65 66 Waste and Minerals Monitoring Report 2018/19
CDuty to Co-operate
Lists of Statement of Common Ground & Position Statements etc.
C.6 East Sussex County Council, in its role as a Minerals and Waste Planning Authority, is involved in the preparation of and / or is a signatory of the following Duty to Co-operate related documents below. As these documents can involve a number of signatories, the Authority that instigated or requested a review of the document is identified the Lead Authority in the table below.
List of Statements of Common Ground etc.
C.7 The documents below include agreements that East Sussex County Council have agreed to.
Table 18
Lead Authority Title Topic(s) Signatory Date
East Sussex County A Statement of Common Ground Minerals (Sharp Sand and N/A Drafting Council, South Downs regarding the provision of sharp sand Infrastructure) National Park and gravel and the safeguarding of Authority and minerals infrastructure in the East Brighton & Hove City Sussex, Brighton & Hove and South Council. Downs National Park areas [Minerals]
Kent County Council Statement of Common Ground Minerals (Soft Sand) LMTE 20 May (SOCG) on Soft Sand between Kent 2019 County Council (KCC), West Sussex County Council, East Sussex County Council (ESCC), Brighton & Hove City Council and the South Downs National Park Authority
South East Waste Memorandum of Understanding Waste HoPE 13 Jun Planning Authorities between the Waste Planning 2017 Group (SEWPAG) Authorities of the South East of England
South East Waste Statement of Common Ground Waste N/A Drafting Planning Authorities between Waste Planning Authority Group (SEWPAG) members of the South East Waste Planning Advisory Group Concerning Strategic Policies for Waste Management
South Downs Ashdown Forest Statement of Ashdown Forest HoPE 4 Apr National Park Common Ground 2018 Authority (Chair of the
Ashdown Forest Working Group)
Surrey County A Statement of Common Ground Waste HoPE 23 Oct Council between Surrey County Council and 2019 East Sussex County Council et al., concerning waste management Waste and Minerals Monitoring Report 2018/19 67
Duty to Co-operateC
West Sussex County Statement of Common Ground Shoreham Harbour DCET Aug Council between the Shoreham Harbour 2016 Planning Authorities and the Shoreham Port Authority
List of Position Statements etc.
C.8 The documents below contain positions / statements of fact which the signatories are in common agreement about.
Table 19
Lead Authority Title Topic(s) Signatory Date
South East England South East – Mineral Planning Minerals (Soft Sand) LMTE May 2019 Minerals Planning Authorities: Soft Sand Position Authorities (SEEMPA) Statement
South East Waste Planning Joint Position Statement: Wate (Inert landfill / TMPPDM Nov 2019 Authorities Group Permanent Deposit of Inert landraise) (SEWPAG) Waste on Land in the South East of England
South East Waste Planning Joint Position Statement: Waste (Non-inert landfill HoPE May 2018 Authorities Group Non-inert Landfill in the South / landraise) (SEWPAG) East of England
Signatories
LMTE: Lead Member for Transport & Environment (Member level sign-off).
DCET : Director of Communities, Economy & Transport (Officer level sign-off)
HoPE: Head of Planning and Environment (Officer level sign-off).
TMPPDM: Team Manager for Planning Policy and Development Management (Officer level sign off) 68 Waste and Minerals Monitoring Report 2018/19 DLACW and Household Waste Arisings in East Sussex and Brighton & Hove Appendix D: LACW and Household Waste Arisings in East Sussex and Brighton & Hove
D.1 This appendix can now be found in the East Sussex Annual Monitoring Report - Data Book accompanying this document. Waste and Minerals Monitoring Report 2018/19 69 Other Targets for the Management of LACWE Appendix E: Other Targets for the Management of LACW
E.1 European and national policies require increases in the proportion of waste from which we recover value through recycling, composting and recovery of energy and that the proportion of waste sent to landfill decreases.
E.2 The recycling and composting targets for Local Authority Collected Waste adopted in the Waste and Minerals Plan and other documents is set out in Table 21 below. Similarly, targets for recovery of Local Authority Collected Waste is set out in Table 22.
Table 20 Comparison of Local Authority Collected Waste Recycling and Composting Targets
Year Waste & ESCC Joint BHCC Waste Council Directive Minerals Waste MWMS Strategy 2018/851 of 30 May Plan Strategy 2007 2018 on Amending Directive 2008/98/EC on Waste (Text with EEA relevance) 2015/16 45% - 40% 45% 2020/21 50% 50% 45% 50% 2025/26 55% 60% - - 55% 2030/31 60% 2035/36 65%
Table 21 Comparison of Local Authority Collected Waste Recovery Targets
Year Waste & ESCC Joint Waste B&HCC Waste Minerals Plan Strategy MWMS Strategy 2007 2015/16 98% - 95% 67% 2020/21 98% Recover 95% of 98% 75% residual waste after recycling 2025/26 98% - - - 70 Waste and Minerals Monitoring Report 2018/19 FPermitted Waste Management Sites in East Sussex and Brighton & Hove Appendix F: Permitted Waste Management Sites in East Sussex and Brighton & Hove
F.1 Table accurate as at 1 April 2019
Table 22
id Locality Site Name East Sussex Type (1) X Y Status Description
20 Barcombe Barcombe Water Physico-Chemical Operational 329144 329906 Treatment Works Treatment Facility
117 Battle East Sussex & Animal Carcus Storage Operational 343435 343581 Romney Marsh Hunt
21 Beddingham Beddingham Composting Facility Operational 324904 325200 Compost Facility
99 Beddingham Beddingham Non-Haz Landfill Restoration 324545 325787 Landfill Site
112 Bexhill Unit 1, Brett Transfer Station Operational 341878 341967 Concrete Works
18 Bexhill-on-Sea 64 London Road Metal/ELV Facility Operational 340922 340972
70 Bexhill-on-Sea Picknell Green Specialist Treatment Operational 339717 339741 (Oil)
19 Brighton Argyle Hall Metal/ELV Facility Operational 318212 318276
26 Brighton Brighton General Clinical Waste Transfer Operational 318848 319140 Hospital Station
27 Brighton Brighton HWRS Household Waste Operational 319348 319450 Amenity Site
38 Brighton G E Richardson & Metal/ELV Facility Operational 318185 318218 Sons Ltd
134 Brighton Golf Farm (SDNP) WMP8b Operational 317634 318293
50 Brighton Hollingdean Depot Special Waste Transfer Operational 318804 318964 Station
51 Brighton Hollingdean Lane Material Recycling Operational 318745 318900 WTS Treatment Facility
55 Brighton KSD Environmental Household, Commercial Operational 320321 320366 Services Ltd, & Industrial - Waste Brighton Transfer Station
10 Brighton Sheepcote Valley Physico-Chemical Non-operational 319348 319451 Treatment Facility
88 Brighton Waterhall Valley Incinerator Operational 318803 318849 Burn Site Waste and Minerals Monitoring Report 2018/19 71 Permitted Waste Management Sites in East Sussex and Brighton & HoveF
id Locality Site Name East Sussex Type (1) X Y Status Description
91 Chiddingley Woodland Centre, Composting Facility Operational 333193 333419 Chiddingley
3 Cripps Corner Cripps Corner Transfer Station taking Non-operational 349561 349641 Depot Non-Biodegradable Wastes
35 Crowborough Farningham Road Household Waste Operational 341217 341300 HWRS, Amenity Site Crowborough
108 Crowborough Go Green Waste Inert Recycling Operational 342190 342557 Recycling
150 Crowborough South East Metals Metal/ELV Facility Operational 341873 341887 Recycling (Sybron Way)
98 Ditchling Environmental Recycling (Pastics) Operational 326190 326241 Tyres
33 Eastbourne Eastbourne Household, Commercial Operational 331254 331425 Household Waste & Industrial Waste Site Recycling & Transfer Station
36 Eastbourne Finmere Auto Metal/ELV Facility Operational 331549 331640 Spares
123 Eastbourne Unit 2A & 2B Birch MRF Operational 331957 332019 Close
127 Eastbourne Unit 3, The Birch Metal/ELV Facility Operational 331873 331890 Industrial Estate
120 Framfield Allied Waste MRF + Specialist Operational 334586 334676 Management (Asbestos)
119 Framfield GB Metals Metal/ELV Facility Operational 334526 334743
34 Hailsham Elmfield Metal/ELV Facility Operational 334000 334172
40 Hailsham H Ripley & Co Metal/ELV Facility Operational 333482 333670
42 Hailsham Hailsham HWRS Household, Commercial Operational 334057 334105 & Industrial - Waste Transfer Station
44 Hailsham Haulaway Limited Household, Commercial Operational 333556 333652 & Industrial - Waste Transfer Station
58 Hailsham Littlewood Metal/ELV Facility Operational 333460 333624
25 Hastings Bridge Yard, Five Metal/ELV Facility Operational 348729 348884 Acre Wood
41 Hastings Hole Farm Metal/ELV Facility Operational 347371 347559
113 Hastings Mr Bristow, Hole Inert Recycling Operational 347371 347475 Farm 72 Waste and Minerals Monitoring Report 2018/19 FPermitted Waste Management Sites in East Sussex and Brighton & Hove
id Locality Site Name East Sussex Type (1) X Y Status Description
85 Hastings Unit A, Roebuck Metal/ELV Facility Operational 346113 346129 Centre
90 Hastings Whitworth Road, Transfer Station taking Operational 346311 346407 St. Leonards Non-Biodegradable Wastes
92 Hastings Woodland House Household, Commercial Operational 345005 345092 & Industrial - Waste Transfer Station
46 Heathfield Hazelmere Metal/ELV Facility Operational 341876 341976
47 Heathfield Heathfield Depot Transfer Station taking Operational 340627 340744 Non-Biodegradable Wastes
48 Heathfield Heathfield HWRS Household, Commercial Operational 340699 340771 & Industrial - Waste Transfer Station
79 Heathfield The Platt Metal/ELV Facility Operational 341885 341927
118 Hellingly Hunts Metals Metal/ELV Facility Operational 335046 335195
49 Horam Heavenly Paws Pet Pet Crematorium Operational 335708 335875 Funeral Services
101 Hove Hove H W S & HWRC & Transfer Operational 316854 316968 Transfer Station Station
89 Hove Wellington Road Metal/ELV Facility Operational 315366 315421
22 Isfield Boathouse Farm Composting Facility Operational 330331 330720
11 Isfield Skim Corner Transfer Station taking Non-operational 330272 330292 Non-Biodegradable Wastes
39 Lewes Greystone Quarry Household, Commercial Operational 325920 326235 & Industrial - Waste Transfer Station & Metal / ELV Recyling
56 Lewes Lewes HWRS Household, Commercial Operational 325782 325855 & Industrial - Waste Transfer Station
81 Lewes Unit 18, Cliffe WEEE Storage and Operational 326093 326149 Industrial Estate Treatment Facility
45 Maresfield A M Skips, Household, Commercial Operational 335719 335815 Hazelbank & Industrial - Waste Transfer Station
59 Maresfield Maresfield Camp Household Waste Operational 334578 334756 Recycling & Waste Transfer Station
61 Maresfield Millpond Depot Household, Commercial Operational 335315 335426 A26, Maresfield & Industrial - Waste Transfer Station Waste and Minerals Monitoring Report 2018/19 73 Permitted Waste Management Sites in East Sussex and Brighton & HoveF
id Locality Site Name East Sussex Type (1) X Y Status Description
62 Mountfield Mountfield HWRS Household, Commercial Operational 346989 347056 & Industrial - Waste Transfer Station
28 Newhaven Brighton Motorama Metal/ELV Facility Operational 323488 323521
151 Newhaven CTEC Gasification Plant Operational 322803 322926 (Specialist)
124 Newhaven Greenacre Transfer Station taking Operational 323468 323585 Recycling, Titan Non-Biodegradable Maritime Wastes
97 Newhaven Kingston Transport Waste Transfer Station Operational 323160 323305 (Newhaven)
63 Newhaven Newhaven ERF Energy Recovery Operational 323261 323529 Facility
95 Newhaven Newhaven ERF, Rail Railhead / Waste Operational 323333 323532 Transfer Transfer Station - ERF IBA Only
125 Newhaven Newhaven HWRS Household Waste Operational 323326 323437 Amenity Site
102 Newhaven Newhaven Inert Material Recycling Operational 323106 323258 Roadstone Ltd / Recovery
9 Newhaven Selmeston Auto Metal/ELV Facility Non-operational 322417 322473 Spares
109 Newhaven Smart Waste Transfer Station Operational 323008 323034 Recycling
76 Newhaven Southerham Wharf Metal/ELV Facility Operational 323183 323370
13 Newhaven The Old Timber Physical Treatment Operational 323228 323384 Yard Facility
103 Newhaven Unit F, Rich Waste Transfer Station Operational 323613 323648 Industrial Estate (Asbestos Only)
43 Ninfield Happy Hunting Pet Crematorium Operational 340692 340935 Grounds
130 Pebsham Former Hastings Leachate Tanks Operational 342978 343067 Household Waste Recycling Site, Freshfields, off Bexhill Road, Pebsham, Bexhill, TN40 2RZ
67 Pebsham Pebsham HWRS Household, Commercial Operational 342812 342922 & Industrial - Waste Transfer Station
68 Pebsham Pebsham Landfill Co-Disposal Landfill Site Restoration 342804 343766 Site
69 Pebsham Pebsham WTS Waste Transfer Station Operational 342829 342989 74 Waste and Minerals Monitoring Report 2018/19 FPermitted Waste Management Sites in East Sussex and Brighton & Hove
id Locality Site Name East Sussex Type (1) X Y Status Description
32 Polegate Cophall Wood Household, Commercial Operational 332132 332253 & Industrial - Waste Transfer Station
116 Polegate Haulaway Ltd, Material Recycling Operational 332482 332712 Polegate Yard Treatment Facility
60 Polegate Mile Oak Depot C&D Recycling Operational 331131 331216
115 Polegate Paul's Miniskips Waste Transfer Station Operational 332205 332323
30 Ringmer Chamberlaines Metal/ELV Facility Operational 329196 329302 Lane
66 Ringmer Peaceways Animal Incinerator Operational 331006 331208 Crematorium
72 Ringmer Ringmer Depot C&D Recycling Operational 329507 329704
93 Robertsbridge British Gypsum Specialist Treatment Operational 345170 347257 (Plasterboard)
73 Rye Rye Oil Ltd Specialist Treatment Operational 356282 356477 (Oil)
74 Seaford Seaford Household Household, Commercial Operational 325095 325166 Waste Site & Industrial - Waste Transfer Station
84 Seaford Unit 3, Cradle Hill Transfer Station taking Operational 324957 325021 Ind. Est, Seaford Non-Biodegradable Wastes
75 Sidley Sidley Depot Household, Commercial Operational 341332 341427 & Industrial - Waste Transfer Station
7 South Chailey Little Exceat farm, Inert Material Recycling Non-operational 328061 328143 South Chailey / Recovery
8 South Chailey Old Hamsey Waste Water Treatment Non-operational 327757 328112 Brickworks Works
4 Southease Fore Hill Incinerator Non-operational 322880 322911
29 St Bulverhythe Road, Waste Transfer Station Operational 342975 343184 Leonards-on-Sea St Leonards for Recyclates
128 Three Oaks Three Oaks Waste Waste Water Treatment Operational 348836 348957 Water Pumping Works Station
114 Uckfield Born Again Plastics Recycling (Plastics Operational 333724 333912 Baling)
82 Uckfield Unit 19, Bellbrook Recycling Operational 333451 333533 Industrial Estate
87 Wadhurst Wadhurst HWRS Household, Commercial Non-operational 347417 347467 & Industrial - Waste Transfer Station Waste and Minerals Monitoring Report 2018/19 75 Permitted Waste Management Sites in East Sussex and Brighton & HoveF
id Locality Site Name East Sussex Type (1) X Y Status Description
71 Westham Potts Marsh Household, Commercial Operational 333796 333886 & Industrial - Waste Transfer Station
1. Sites that are closed are not included in this table. 76 W 2006/7 Management G aste
Appendix G: Permitting of Significant Waste Management P and ermitting Capacity in East Sussex 2006/7 - 2018/19 Miner als
Table 23 Monitoring - Year Number of Throughput of received apps Number / Capacity Approved Number Number pending at end of
Significant Refused monitoring period 2018/19 Apps Report Received 2018/19 of
2006/07 4 Recycling: 59,000tpa 6 2 4 Capacity
Transfer: 94,960tpa (110,000 tpa recycling, 121,000 tpa transfer) Significant
2007/08 6 Recycling: 25,000tpa , Composting: 7 None 3 15,000tpa, Transfer: 1,860tpa, Landfill: 122,270tpa, Peacehaven WWTW (25,000 tpa recycling, 5,820 transfer, (59,000tpa recycling, 61,000 tpa composting, 210,000tpa 122,270tpa landfill,
recovery, Peacehaven WWTW) in
2008/09 3 25,000tpa CDEW recycling, 6 (59,000tpa recycling, 122,270tpa None None East
landfill, Peacehaven WWTW, 25,000tpa W CDEW recycling,) aste 2009/10 3 74,200tpa transfer 2 (56,200tpa transfer) None 1 Sussex (18,000tpa transfer)
2010/11 3 5,260tpa recycling 4 None None
Replacement Newhaven HWRS (5,260tpa recycling, 18,000tpa transfer) Year Number of Throughput of received apps Number / Capacity Approved Number Number pending at end of Management Significant Refused monitoring period Apps Received
2011/12 4 Recycling: 35000tpa, 4 None 1 P
Transfer: 108,000tpa, (Recycling: 35000tpa, (22,500 tonnes of inert ermitting material required for Inert material required for restoration Transfer: 108,000tpa, restoration WMP8b) (WMPB8): 23,000 tonnes (required after 1 Jan 2012) Inert material required for restoration (WMPB8): 23,000 tonnes (required after 1 Jan 2012)) Capacity
2012/13 4 Recycling: 50,000tpa 4 None 3 of
Inert Recycling: 21,000tpa (Increase Composting 2006/7 Capacity to 60,000 at Inert Material required for beneficial use Woodlands Centre; Inert for Significant (WMP8b): 42,000 beneficial use (WMP8b):
10,000 tonnes; Part C&I and W aste
part CDEW:25,000 tpa) in and - Miner 2013/14 2 Increase Composting Capacity to 60,000 at 5 None None East
Woodlands Centre; Inert for beneficial use 2018/19 als (WMP8b): 2,600 tonnes; Part C&I and part Increase Composting Capacity to 60,000 CDEW Recycling:60,000 tpa at Woodlands Centre; Inert for beneficial Monitoring use (WMP8b): 2,600 tonnes; Part C&I and Sussex
part CDEW Recycling:60,000 tpa W Report aste 2014/15 5 Inert for beneficial use (WMP8b): 4 None 1 3,000tonnes tonnes; Recycling & CDEW 2018/19
Recycling: 74,000 tpa; Specialist Hazardous: G 280 tpa; Bulk Metals: 720 tpa; 77 78 W 2006/7 Management G
Year Number of Throughput of received apps Number / Capacity Approved Number Number pending at end of aste Significant Refused monitoring period P Apps and ermitting
Received Miner
Recycling & CDEW Recycling: 74,000 tpa; als
Specialist Hazardous: 280 tpa; Bulk Metals: Monitoring 720 tpa; - 2018/19
2015/16 5 Recycling: 20,500 tpa; Recycling: 20,500 tpa; None 1 Report CDEW Recycling: 49,500 tpa. CDEW Recycling: 49,500 tpa. 2018/19 of Capacity 2016/17 1 Recycling: 25,000 Recycling: 25,000 Significant (Increase composting 3 1 throughput (waste wood); Specialist (Waste Water) 72,000tpa. Specialist (Waste Water) 72,000tpa. Boathouse Farm, Isfield Road, Isfield, TN22 5JJ)
2017/18 3 in Inert for beneficial use (WMP8b): 677,300 3 Inert for beneficial use (WMP8b): 677,300 1 0 tonnes tonnes East W 2018/19 2 aste Recycling: 40,000tpa
Recycling: 40,000tpa Sussex 2 2 0 Specialist: 4,000tpa Specialist: 4,000tpa G.1 Note: For consistency the figures presented here are the total throughput i.e. this includes the recycled / recovered / Management disposed of element and the transfer element. It only includes significant development, smaller permissions do not appear. P ermitting Capacity of 2006/7 Significant W aste in and - Miner East 2018/19 als Monitoring Sussex W Report aste 2018/19 G 79 80 Waste and Minerals Monitoring Report 2018/19 HPermitted Mineral Workings in the Plan Area 2018/19 Appendix H: Permitted Mineral Workings in the Plan Area 2018/19
Table 24 Site Mineral Operational during AMR period? Stanton's Farm and Novington Building Sand No Sandpit, Plumpton (in SDNPA) Scotney Court, Lydd Sand and gravel Yes Scotney Court extension / Wall Sand and gravel Yes Farm, Lydd Castle Water, Rye Sand and gravel No - dormant Ashdown Brickworks Clay Yes Chailey Brickworks Clay Yes Hastings Brickworks Clay Yes Aldershaw Farm Clay Yes Horam Brickworks Clay No - not yet constructed Little Standard Hill Farm Clay No Hamsey Brickworks Clay No - dormant, brickworks closed Cuckmere Brickworks Clay No - dormant, brickworks closed Ludlay Brickworks Clay No - dormant, brickworks closed Brightling Mine / Robertsbridge Gypsum Yes works Tarring Neville Chalk No - site restored, now in aftercare Meeching Quarry Chalk No- IDO permission ceases to have effect in 2019 North Quay, Newhaven (Berth 1) Aggregate wharf Yes North Quay, Newhaven, (Plot 6 & Aggregate wharf No 7) North Quay, Newhaven, (scrap Aggregate wharf No* metal use) North Quay, Newhaven (Berth 5) Aggregate wharf No Fishers Wharf, East Quay, Aggregate wharf Yes Newhaven Rastrums Wharf, Rye Aggregate wharf Yes Rye Wharf Aggregate wharf No Halls Wharf, Shoreham (Brighton Aggregate wharf Yes & Hove) Britannia Wharf (Brighton & Hove) Aggregate wharf No - in use as an aggregate bagging plant Waste and Minerals Monitoring Report 2018/19 81 Permitted Mineral Workings in the Plan Area 2018/19H
Site Mineral Operational during AMR period? Ferry Wharf (Brighton & Hove) Aggregate wharf No - Was in use as a CDEW recycling facility producing recycled aggregates.**
H.1 *Aggregate received at this wharf at the end of 2019 outside the monitoring period
H.2 ** In 2019, outside the monitoring period, permission was granted for redevelopment of the site for flexible B1/B8 floorspace meaning that it can no longer be used for aggregate imports. However, the Port Authority indicated that replacement import capacity can be provided through the flexible use of the Outer Layby and Brighton Terminal general wharves elsewhere within the Harbour.
H.3 The Adopted WMP in 2013 estimated aggregate reserves to amount to in excess of 4 million tonnes via existing planning permissions in the Plan Area at Lydd Quarry (sharp sand and gravel) and in the SDNP at Stanton's Farm/Novington sandpit (soft sand). However, it was recognised that the availability of the mineral would be phased and may be reduced by local environmental constraints.
H.4 Stanton's Farm/ Novington Sandpit) is currently inactive. A recent renewal of permission for the site indicated that the reserve at Novington is now 350 000 tonnes. Reserves at Lydd Quarry at the end of 2018 were in the region of 658,000 tonnes (150,000 in Kent). (13) This gives a total of 1 008 000 tonnes in the Plan Area at the end of 2018.
H.5 The landbank for the Plan Area has been calculated in the past as the full resource available at Stanton's Farm and the reserve from the permitted sites at Lydd Quarry within the boundary of East Sussex divided by 0.1 mtpa. This gives a landbank figure at the end of 2018 of 10 years. The NPPF requires a landbank of at least 7 years to be maintained. However, the use of 0.1mtpa as the principal indicator of demand, and the method of calculating the landbank is being re-examined as part of the Review of the Waste and Minerals Local Plan. As such the landbank figure for 2018 should only be read as a nominal figure and not as an actual measure of supply in the Plan area.
13 In June 2019 the operator reported at that time that all consented mineral in East Sussex would be exhausted by mid 2020. On that basis less than a year's reserve remain at Lydd Quarry. 82 Waste and Minerals Monitoring Report 2018/19 ISecondary and Recycled Aggregates Facilities in East Sussex and Brighton & Hove Appendix I: Secondary and Recycled Aggregates Facilities in East Sussex and Brighton & Hove
I.1 The current best estimate of secondary and recycled aggregates production in East Sussex and Brighton & Hove is up to 600 000 tonnes. This is based on an assessment of secondary and recycled aggregates facilities and imports as set out below (using 2018 data).
Table 25 Recycled Aggregates Facilities processing CDEW in East Sussex and Brighton & Hove as at April 2019
Operator/site Address
Edburton Ferry Wharf, Portslade (B&H)***
Hailsham Roadway Woodside Depot, Hailsham
R French & Sons Ltd Woodland House, Drury Lane, Ponswood Industrial Estate, St Leonards-on-Sea
MDJ Light Brothers Greystone Quarry, Southerham, Lewes (in SDNP)
A M Skip Hire Hazlebank, London Road, Maresfield
Haulaway Ltd, Premier House Premier House, Apex Way, Hailsham
PJ Mini Skips Cophall Wood Recycling Centre, Hailsham Road (A22), Polegate
Newhaven Roadstone Ltd* North Quay Road, Newhaven *(the facility recycles aggregate on site and reuses the product within the manufacturing process)
Go Green Hourne Lane (Land off), Steel Cross, Crowborough
Pauls Mini Skips** Unit 13, Chaucer Industrial Estate, Polegate Links Waste Management** Units 2A and 2B, Birch Close, Eastbourne
Robins of Herstmonceux Sandbanks, Chilsham Lane, Herstmonceux
Sussex Waste Management** Whitworth Road, St Leonards on Sea
Taskforce Property Services Ltd Land at Hole Farm, Westfield Lane, Westfield
FM Conway**** Plot 6/7 North Quay, Newhaven Waste and Minerals Monitoring Report 2018/19 83 Secondary and Recycled Aggregates Facilities in East Sussex and Brighton & HoveI
Operator/site Address
Greenacre Recycling** New Road, Newhaven
I.2 ***Permission was granted in 2019, outside the monitoring period, for redevelopment of the site meaning that the recycled aggregate production capacity is no longer available.
I.3 ****The recently permitted proposal (Conway) at North Quay Newhaven will also provide 20 000 tpa of recycled aggregate.
I.4 Some recycled aggregate is also produced by mobile crushing activities associated with demolition projects. The above facilities do not operate at full capacity and it is estimated that at least 515,000 tonnes pa (based on 2018 figures) of recycled aggregate is produced from these sources and mobile crushers on demolition sites. Some of the facilities may import CDEW for management but do not currently find it viable to process at the site (in table marked**). Instead the sorted hardcore is sent on to another site for actual processing into secondary aggregate.
I.5 The above facilities are estimated to provide capacity for approximately 632,000 tonnes per annum recycling Construction, Demolition and Excavation Waste as at 1 April 2019. In addition, it is estimated that at least 80,000 tonnes of secondary aggregate are ultimately produced/imported in the Plan area from the sources listed below.
Table 26 Secondary Aggregates Facilities in East Sussex
Operator Facility Quantity and type of material (tpa)
Ibstock Ltd Ashdown Brickworks Reject bricks -up to 14 000t is produced pa and Chailey Brickworks Rastrums Rastrums wharf, Rye Pulverised Fuel Ash (PFA) imported from Harbour Europe used as secondary aggregate Day Newhaven Railhead Incinerator Bottom Ash is exported by rail, Aggregates currently to Brentford, where it is processed into recycled aggregate for uses including as a road construction material. Recycled material is also rail imported back into Newhaven. 84 Waste and Minerals Monitoring Report 2018/19
JReview of Mineral Permissions Appendix J: Review of Mineral Permissions
J.1 The following table sets out the mineral permissions within the Plan Area that will be subject to periodic review over the coming years.
Table 27
Reference Site Mineral Status Review dates
Periodic Review application received 11 April 2013. New set of conditions determined under reference SDNP/13/01933/ROMP on 09/10/13. Next review due 9 Novington October 2028 . (In addition, as Building Inactive MR/5 Sandpit, this site is part of the Stanton's sand Plumpton Farm permission SDNP/16/04886/CNDC, it will be affected by the conditions on that permission which has recently been renewed (see Stanton's Farm below).
Periodic Review application postponement was agreed for 15 years until 27/5/2033. The site Ashdown has a new permission (RR/811/CM) RR/811/CM Clay Active Brickworks dated 6 December 2018 which is the working permission and any subsequent review will be based on that permission.
Implemented but inactive. Periodic Review application was Little Standard required by 20 October 2018. MR/11 Clay Inactive Hill Farm However, a postponement has been agreed for 15 years until 20/10/2033.
A postponement to the Periodic MR/12 Sussex Bricks Clay Active Review application has been agreed to 11 December 2033.
Aldershaw Periodic Review application MR/13 Clay Active Tiles required by 25 November 2024.
Periodic Review application Chailey MR/14 Clay Active required by 23 July 2025. Brickworks
Scotney Court Sand Periodic Review application MR/15 (Lydd Quarry and Active required by 21 October 2026. Area 10) gravel Waste and Minerals Monitoring Report 2018/19 85
Review of Mineral PermissionsJ
Reference Site Mineral Status Review dates
Periodic Review application British received by 26 March 2013. New Gypsum, set of conditions determined MR/16 Gypsum Active Brightling and under reference MR/16 on Robertsbridge. 10/09/2013. Next review due 9 September 2028.
Periodic Review application received 15 July 2013 and a new Tarring Inactive - set of conditions determined MR/17 Neville, Chalk subject to under reference MR/17 on Newhaven aftercare 15/11/2013. Aftercare commenced 2016.
Planning permission LW/386/CM granted 20 October 2003, although commencement did not take place until October 2006. This Stanton's Farm, permission was recently renewed Plumpton Building (ref: SDNP/16/04886/CNDC) to SDNP/16/04886/CNDC (includes Inactive sand allow the extraction of sand and Novington restoration of the site to be Sandpit) completed not later than October 2026. Remaining reserves at the quarry are considered to be in the region of 350 000 tonnes.
IDO registered.
Lewes District Council granted Hamsey planning permission granted for IDO/1A Clay Dormant Brickworks business units and residential properties on site during 2015 (LW/14/0712).
IDO now formally ceases to have Meeching Permission effect therefore the site no IDO/5B Quarry, Chalk ceased to longer has planning permission Newhaven have effect for chalk extraction
Scotney Court Periodic Review application Extension & Sand formally postponed as the extant RR/362/CM Wall Farm and Active conditions are considered fit for (Areas 11 and gravel purpose. Next review due 12) September 2031
Periodic Review application was Extant and Horam due by 21 August 2015; WD/307/CM Clay implemented Brickworks postponement has been agreed but inactive with operator until August 2030.
Ludlay Brickworks, Clay Dormant Berwick
Cuckmere Brickworks, Clay Dormant Berwick 86 Waste and Minerals Monitoring Report 2018/19
JReview of Mineral Permissions
Reference Site Mineral Status Review dates
Sand Castle Water, and Dormant Rye Harbour gravel Waste and Minerals Monitoring Report 2018/19 87
Local Aggregate AssessmentK Appendix K: Local Aggregate Assessment
East Sussex, South Downs and Brighton & Hove Local Aggregate Assessment
December 2019
East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
LAA 2019 - NOTE
East Sussex County Council, Brighton & Hove City Council and the South Downs National Park Authority commenced a Review of their Waste and Minerals Local Plan with a Call for Evidence and Sites consultation at the end of 2017. The Authorities have been in discussions regarding sites put forward during the consultation and so have not yet formerly considered the content of the next stage of the Plan Review. Because of this situation it was not considered appropriate in LAA 2918 to pre-empt possible changes in aggregate supply and future demand and supply scenarios and possible provision levels were therefore not included in that document. Formal consideration of the Review document is now expected in 2020. In order to inform the Review process, this year's LAA 2019 reports on some of the details which were unavailable in 2018. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
Contents
Executive Summary 3 1 Introduction 9 2 Geology and mineral uses 12 3 Demand 14 4 Supply 20 5 Environmental constraints 33 6 Balance 35 7 Conclusions 38 A Past and Future Development 40 B Imports into plan area 42 Map 1: Geological Plan including locations of aggregate wharves and railheads, and existing aggregate sites 43 Map 2: Origin of aggregate imported, produced and consumed in East Sussex and Brighton & Hove during 2014 45 Map 3: Sand and gravel resources in the East English Channel and Thames Estuary (Source: Crown Estate) 47 Map 4: Recycled and secondary aggregates sites 2018/19 49 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 3
Executive Summary Executive Summary
Executive Summary
The first East Sussex, South Downs and Brighton & Hove Local Aggregate Assessment (LAA) was published in December 2013. The LAA has been updated annually and is based on the Plan Area for the adopted East Sussex, South Downs and Brighton & Hove Waste & Minerals Local Plan (WMLP). This document represents the seventh LAA for the mineral planning authorities of East Sussex County Council, Brighton & Hove City Council and the South Downs National Park Authority (the Authorities) and examines updates to the position on aggregates supply and demand since the time of last reporting in 2018.
In past years the Authorities' assessment was that there were particular circumstances in this Plan Area that made it difficult to prepare the LAA totally along the lines indicated in the NPPG. Previous LAAs concluded that the assessment could not use past 10 years sales data as this was too volatile because there is a very small number of production sites and therefore there has been major variation in sales figures from nothing to more substantial output. Past LAAs instead used the Apportionment figure in the Adopted WMLP as a surrogate figure for forward planning.
In 2016 a Public Examination on the soundness and legal compliance of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan was held. Hearings focused on the whether the Plan provided a sufficient and adequate supply of aggregates. Whilst the Inspector found the Sites Plan sound in his Report, he highlighted the need for a Review of the aggregate minerals policies. Taking on board the Inspector's comments the Authorities agreed to a Review of the WMLP and in September 2017 published a consultation on the Call for Evidence & Sites. An extension to an existing sand and gravel quarry in the east of the Plan Area was received at the Call for Sites stage. The timetable for the Review of the WMLP has been delayed and the Authorities have not yet formerly considered the content of the next stage of the Plan Review. Because of this situation in last year's LAA it was not considered appropriate to discuss future demand and supply scenarios and possible provision levels before considering the Review documents.
The Authorities anticipate publishing the next stage of consultation in 2020. This LAA therefore examines the latest information and data available on aggregates production and supply patterns in the Plan Area, and aims to inform the forthcoming consultation documents.
The overall picture of aggregate supply to the Plan area is of heavy dependence on imports by road, sea and rail. Significant levels of marine imports (marine dredged and crushed rock) are received through Shoreham Port and Newhaven and to a lesser extent Rye. Crushed rock, recycled aggregate and sand and gravel are imported by rail at Newhaven. Land-won sand and gravel is extracted in the east of the Plan area at Lydd with about 50% of material being consumed in East Sussex. 4 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
Executive Summary
It is assumed that all soft sand supply is met by road imports as there are currently no active sites in the Plan Area. The Authorities are undertaking research to establish the origin of soft sand material used in the Plan area. A steady supply of recycled material is produced from construction waste management facilities across the Plan area. A continuing and increasing demand for construction materials is anticipated.
The South East England Aggregates Working Party (SEEAWP) has requested that MPAs include a comparative Key Facts table in their LAA. The data included in this table is to be found within the LAA and is pulled together here to enable easier assessment and collation of information. Dashboard
Summary – East Sussex, South Downs and Brighton & Hove for the calendar year 2018
Quarry 2018 Sales (Mt) Average Average LAA Rate Reserve Landbank Allocations Capacity Comments (10-yr) (3-yr) (Mt) (Mt) (years) (years) (Mtpa) Sales & Trend Sales Sales East
& Trend & Trend Sussex,
Soft Sand 0 N/A 0 0 0.35 N/A N/A N/A Extraction commenced in 2007 at Stanton's South Farm/Novington sandpit but no extraction has taken place in recent years. A renewal Downs of permission at this site indicated that the reserve was 350 000 tonnes. As there are no other soft sand sites in the plan area it and
is assumed that demand for this material is Brighton being met by road imports. Executive
Sharp Sand 0.23 N/A 0.32 0.16* 0.508 1.5** N/A N/A * Average of last 3 years divided by two, as & Gravel 50% of material is destined for Kent. & Hove,
**Represents the lifetime of the entire site as all working now in East Sussex. Local Aggregate See FOOTNOTE below Summary Assessment, December 2019 5 6 East 2018 Sales Average Average LAA Reserve Landbank Allocations Capacity Comments Executive
(Mt) (10-yr) (3-yr) Sales Rate(Mt) (Mt) (years) (years) (Mtpa) Sussex, Aggregate Sales Infrastructure Sales & Trend & Trend & Trend South Downs 0.515 N/A 0.378 0.378 N/A N/A 0.74 *** better reporting could be a contributing factor to increase. and Recycled / Secondary (2018)
Aggregates R/SA does not incl. FBA Brighton Summary *** & Hove, Marine Sand & Gravel 0.01 N/A 0.012 0.012 N/A N/A N/A Does not include imported sand and
gravel (not MDA) at Rye which is Local ? confidential Aggregate Does not include marine sand and gravel imported at B&H Shoreham port wharves Assessment,
Rock Imports by Sea 0.048 N/A 0.047 0.047 N/A N/A N/A N/A December Rail Depot Sales (Sand 0.08 N/A 0.041 0.041 N/A N/A N/A 0.25~ ~Capacity is for whole of Newhaven & Gravel) railhead. Possibility that some material may have originally been 2019 imported by sea at Cliffe.
Rail Depot Sales 0.104 N/A 0.083 0.083 N/A N/A N/A 0.25~ ~Capacity is for whole of Newhaven (Crushed Rock) railhead FOOTNOTE: Sharp Sand and Gravel
SEEAWP's consideration of the draft LAA included a discussion regarding the methodology of recording sales from Lydd Quarry and the effect of this on the estimation of the LAA Rate. Some SEEAWP members thought that the East Sussex approach distorted the supply situation. It is generally understood by SEEAWP that East Sussex is an unusual case in that quarry sales are low, which in turn is a function of limited resources, and it is heavily dependent on imports. Nevertheless, SEEAWP members think the LAA Rate, as a measure of demand, should be based on average aggregates sales irrespective of their destination. The implications East of the LAA Rate are then addressed by the examining the supply options and concluding if any action is required. Sussex,
However, the Authorities do not consider that the LAA rate requires amendment. SEEAWP accept this position but have requested South the addition of a footnote in the LAA to reflect the SEEAWP discussion (hence the inclusion of these paragraphs). The Authorities note SEEAWP's comments and concur that the Plan area has a long-standing unique and particular land - won aggregate situation Downs which has been recognised as a "special case". There is only one active sharp sand and gravel site (Lydd Quarry) in the Plan Area where the operator's established arrangement is that 50% of material produced is exported to Kent. The Authorities consider and Brighton therefore that the sharp sand and gravel LAA rate should be calculated by dividing average sales from this site by two, because Executive of the export situation. This gives an LAA rate adjusted to reflect local circumstances which allows for provision to be planned, based on the consumption needs of the Plan Area. The Authorities will consider these matters further as part of the Plan Review & process including the preparation of a Statement of Common Ground with Kent County Council as the adjoining mineral planning Hove,
authority for Lydd Quarry. Local
General Comments Aggregate
Overall picture of aggregate supply – heavily dependant on imports by road, sea and rail; land-won sand and gravel Summary Assessment, extracted in the east of the Plan Area with about 50% of material being exported to Kent. Significant marine imports through Shoreham Port and Newhaven and to an extent Rye, rail imports of crushed rock, recycled aggregate and sand and gravel at Newhaven; and a level of supply from recycled aggregates throughout the Plan Area. Assumed that all soft sand supply is met by road imports. December Significant new aggregate capacity is due to come on board in 2020 in Newhaven with the development of a new aggregate processing plant, bagging plant, concrete batching plant and buildings, utilising aggregates landed at the Port and distribution of products by road and rail including the extension of an existing rail siding. 2019 7 8 East Steady continuing and increasing demand anticipated. Executive The adopted aggregate policies are being reviewed as part of the current Review of the Waste and Minerals Local Plan. A Sussex, consultation on the the call for sites and evidence took place at the end of 2017. The authorities are considering the responses to the call for sites, and anticipate publishing the the next stage of consultation in 2020. South Downs and Brighton Summary & Hove, Local Aggregate Assessment, December 2019 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 9
Introduction1 1 Introduction
1.1 The first East Sussex, South Downs and Brighton & Hove Local Aggregate Assessment (LAA) was published in December 2013 and this document (LAA 2019) represents the seventh LAA for the mineral planning authorities (mpa) of East Sussex County Council, Brighton & Hove City Council and South Downs National Park Authority. The LAA is based on the Plan Area for the adopted East Sussex, South Downs and Brighton & Hove Waste & Minerals Local Plan, and covers the administrative area of East Sussex and Brighton & Hove including those parts that lie within the South Downs National Park.
1.2 The National Planning Policy Framework states that mineral planning authorities should plan for a steady and adequate supply of aggregates by preparing an annual LAA based on a rolling average of 10 years sales data and other relevant local information. The LAA should include an assessment of all supply options including land won, marine dredged, secondary and recycled sources, together with a forecast of demand.
1.3 The National Planning Practice Guidance (NPPG) indicates that a LAA should contain three elements:
a forecast of the demand for aggregates based on the rolling average of 10-years sales data and other relevant local information;
an analysis of all aggregate supply options, as indicated by landbanks, mineral plan allocations and capacity data e.g. marine licences for marine aggregate extraction, recycled aggregates and the potential through-puts from wharves. This analysis should be informed by planning information, the aggregate industry and other bodies such as local enterprise partnerships; and
an assessment of the balance between demand and supply, and the economic and environmental opportunities and constraints that might influence the situation. It should conclude if there is a shortage or a surplus of supply and, if the former, how this is being addressed.
1.4 The NPPG also gives further details on the aggregate supply options including:
recycled aggregates, including from construction, demolition and excavation waste;
secondary aggregates, whose sources come from industrial wastes such as glass, incinerator bottom ash, railway ballast, and scrap tyres; and industrial and minerals by-products;
marine aggregates from The Crown Estate. Information will cover the areas licensed by the Marine Management Organisation for marine sand and gravel dredging and, as they are prepared over time, Marine Plans. The Marine Policy 10 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
1Introduction
Statement (MPS) is used as the overarching UK policy framework for the production of marine plans and in the absence of an adopted marine plan the MPS will inform decisions in the UK marine area;
imports into and exports out of the minerals planning authority area. The minerals planning authority must capture the amount of aggregate that it is importing and exporting as part of its Assessment; and
land-won resources, including landbanks and site specific allocations.
1.5 A revised version of the Practice Guidance on the production and use of Local Aggregates Assessment was prepared in May 2017 by the Minerals Product Association and Planning Officers' Society (MPA/POS) Practice Guidance on the Production and Use of Local Aggregate Assessments The South East England Aggregates Working Party (SEEAWP), to which the Authorities are party, have also produced guidance on the production of LAAs. The Authorities have considered these guidance documents when working on this LAA.
1.6 In past years the Authorities' assessment was that there were particular circumstances in this Plan Area that made it difficult to prepare the LAA totally along the lines indicated in the NPPG. Previous LAAs concluded that the assessment could not use past 10 years sales data as this was too volatile because there is a very small number of production sites and therefore there has been major variation in sales figures from nothing to more substantial output. Past LAAs instead used the Apportionment figure (0.1mtpa) in the Adopted Waste and Minerals Local Plan (WMLP) as a surrogate figure for forward planning.
1.7 In 2016 a Public Examination on the soundness and legal compliance of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan was held. Hearings focused on the whether the Plan provided a sufficient and adequate supply of aggregates. Whilst the Inspector found the Sites Plan sound in his Report he highlighted the need for a Review of the aggregate minerals policies. The Sites Plan was adopted in February 2017. The Authorities have since agreed to a Review of the WMLP and in September 2017 published a consultation on the Call for Sites and Evidence.
1.8 One site received as part of this consultation (albeit after the consultation period) was promoted as an extension to an existing sand and gravel quarry in the east of the Plan Area. Further representations and revisions to the promoted site were received in June 2019. The Authorities are considering the responses to the Call for Sites and anticipate publishing the next stage of consultation in 2020. This LAA therefore examines the latest information and data available on aggregates production and supply patterns in the Plan Area, and aims to inform the forthcoming consultation documents. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 11
Introduction1
1.9 A draft of this LAA was considered by SEEAWP in November 2019. Following comments from SEEAWP a footnote has been added to the Dashboard in the Executive Summary regarding the LAA rate calculation arising from sales data at Lydd Quarry. 12 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
2Geology and mineral uses 2 Geology and mineral uses
2.1 Geologically, sand and gravel aggregate resources within the Plan Area are limited to relatively small outcrops of the sand in the Folkestone Beds, river gravels and foreshore deposits of sand and gravel. Sharp sand and gravel, and soft sand can have different uses. Sharp sand and gravel are primarily used for concreting purposes and this is an essential raw material for the construction industry. Building sand is largely used as fine aggregate in the production of concrete, mortars and asphalt. Both types of material can be used as fill. There are no sand and gravel reserves within the boundary of Brighton & Hove.
2.2 The Folkestone Beds comprise the uppermost division of the Lower Greensand and consist of loosely consolidated fine grained quartzose sands. The outcrop of the deposit is very limited consisting of a narrow strip in the western part of the Plan Area, running eastwards from Ditchling for a relatively short distance. The fine grained nature of the sand means it readily meets British Standards for mortar sand. The area of Lower Greensand within East Sussex was previously outside the Sussex Downs AONB but it is now located within the South Downs National Park (SDNP).
2.3 The foreshore resource comprises extensive storm beach deposits along the coast. The wedge shaped accumulations consist almost entirely of flint with only a small proportion of sand. The main areas are between Winchelsea Beach and Rye Harbour, and, the western part of Dungeness around Camber. The resource is mostly used in concreting.
2.4 Substantial marine aggregate resources lie along the South East coast and in the English Channel which are widely extracted under licence by several aggregate companies with landings made at numerous wharves in the region. There are some landings at Shoreham Harbour within Brighton & Hove on the border with West Sussex, and until recently, at Newhaven Port. Crushed rock from various sources is also landed at Shoreham, Newhaven and also Rye Port. Other wharves used for marine dredged material are within the Thames Estuary and Hampshire.
2.5 Marine aggregates can yield both sand and gravel. Marine dredged aggregates are mostly utilised for concreting purposes, whilst crushed rock of various types is used locally in an unprocessed form for road construction or subsequently processed for the manufacture of coated roadstone products.
2.6 There are no hard rock aggregate reserves in the Area. Chalk has been the subject of significant levels of quarrying in the past, notably for the cement industry and to produce lime mortar and agricultural lime. Chalk also has the potential to yield crushed rock aggregate fill. However, all chalk extraction operations have now ceased and chalk is unlikely to make anything other than a minor contribution to aggregate production in the area in the foreseeable future. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 13
Geology and mineral uses2
2.7 A geological plan including locations of existing minerals facilities (Map 1), and details of sand and gravel resources in the East English Channel and Thames Estuary (Map 3) are included at the end of this document. 14 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
3Demand 3 Demand
Demand
National & Regional Guidelines for Aggregates Provision in England
3.1 The Plan Area "demand" is a difficult part of the LAA to determine. This is partly because the consumption picture cannot be ascertained with any certainty (see paragraphs below). The NPPG states that the Government’s national and sub-national guidelines serve a purpose of providing individual minerals planning authorities, where they are having difficulty in obtaining data, with some understanding or context of the overall demand and possible sources that might be available. Past guidelines are based on outputs from an econometric model of the relationship between construction and aggregate consumption to predict future aggregate need.
3.2 However, the most recent guidelines (National and Regional Guidelines for Aggregates Provision in England 2005 – 2020) will expire next year and are considered no longer helpful to predict demand. There is no indication these will be updated in the near future. The draft LAA guidance prepared by SEEAWP has therefore suggested that instead all mineral planning authorities when preparing their LAAs should take into account the following:
Average of 3 and 10 year aggregate sales data; Economic forecasts; Population, housing and capital programme growth and; Major Infrastructure projects
3.3 The LAA endeavours to cover these aspects below.
3.4 Land won average sales data
3.5 Using past sales data to assess demand has also been problematic in the Plan Area. Data for previous extraction has mainly been confidential and therefore, until recently, it has been unable to be published. In addition, with so few sites local sales figures are subject to large production swings and therefore trends cannot be used as a general indicator of demand. For example, at Lydd Quarry up until 2011, production took place in Kent with no returns for East Sussex. Now extraction is all within East Sussex and the operator considers that about half of the aggregate raised is consumed in Kent.
3.6 Similarly after some years of no soft sand returns, Stanton’s Farm, Novington started extraction in 2007. However the sand quarry has been inactive since at least 2013 and figures for production before then are confidential. It can be assumed therefore that all consumption of soft sand in the Plan Area since 2013 must have been met through imports. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 15
Demand3
3.7 Using figures for 2017 and 2018 (made available through the Annual Monitoring Surveys), it is apparent that sales from Lydd Quarry in the last 6 and 7 years have been higher than the rate anticipated in the planning permission (270 000 tonnes), although the total for 2018 is approximately 144 626 tonnes less than in 2014 (the highest level of production).
3.8 Non confidential figures for production at Lydd quarry are now available from 2006 until 2018 (i.e. a 13 year period). However, extraction on the East Sussex side of the quarry did not commence until 2011 and so it is not possible to give a 10 years sales average for the quarry that would relate specifically to the Plan area. A 10 year sales average of the quarry as a whole can be calculated as just over 343 000t; however this does include earlier extraction in Kent. A three year average can however be calculated as 320 202 tonnes for the quarry (ending in 2018) and can be taken as an accurate reflection of what has been extracted during this time in East Sussex. However, it cannot be used to represent aggregate production for the whole Plan Area as this should include the Stanton’s Farm as well. In addition, 50% of material produced at Lydd quarry is exported to Kent.
3.9 Previous LAAs also established that in actual terms, the 10 years sales figures included confidential information but in total was about 1.5 million tonnes. This was calculated by adding confidential sales data from Stantons Farm in the last 10 years when the quarry was working, and adding to known total production at Lydd quarry in East Sussex. Current data updates indicate that this figure may now exceed 2.7 million tonnes. Sales figures for the Plan Area may therefore offer some limited indication of future needs but they do not reflect the overall picture in the Plan Area. More details on sales and production is given in the next chapter "Supply".
3.10 Consumption (Substitute local demand indicators)
3.11 It must be assumed that as development has taken place in East Sussex and Brighton & Hove, net demand for constructional materials must have been met by a combination of land won aggregates, marine landings, imports and recycled and secondary aggregates. Consumption data from the British Geological Survey (BGS) indicates how much aggregate is used in the area and this can also assist in building up a picture of "local" demand (see Appendix B and Map 2 for more detail).
3.12 The national four yearly Aggregate Minerals (AM) Survey based on 2014 data was published in 2016. DCLG also published a summary "AM2014 source of primary aggregates by sub-region – percent categories" which indicates consumption by sub-region and identifies the source MPAs they are importing aggregates from. The AM2014 indicates that consumption was up in 2014 to 920 000 tonnes sand and gravel (land-won and marine) and 280 000 tonnes crushed rock giving a total of primary aggregates of 1 200 000 tonnes plus a possible 250,000 tonnes of recycled and secondary aggregates. It is understood that specifications for the next AM survey are currently being drawn up. 16 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
3Demand
3.13 The average road delivery distances for aggregates in 2013 was 49.8km (source: MPA) although there have been examples where this distance has been exceeded and movements are not always direct. Given the economic limits on transporting aggregates by road it is likely that the East of Plan Area is provided by sharp sand and gravel from Lydd quarry, marine landings and imports; and that the Western Area is served by marine and imports. It is assumed that for soft sand the Eastern end of the Plan area is served by imports; and that the Western area has in the past been served by Novington and imports. Work is currently being undertaken by the Authorities as part of the WMLP Review to establish the supply pattern of aggregates in the Plan Area.
3.14 In a wider context, the SEEAWP Aggregates monitoring report 2017, indicated that overall aggregate sales over the last two years were at their highest for the last decade. Land won sand gravel and marine dredged aggregate sales are the equal largest component within the overall sales pattern. This contrasts with recent years when marine dredged aggregates sales have been more dominant. The report concluded that 2017 aggregate sales were above both the 3-year and 10-year average and that the demand for aggregates will increase. There are supply implications arising from the Heathrow Expansion and other infrastructure projects including those in London.
Economic Forecasts
3.15 Some mpas have examined a variety of national ‘economic’ statistics to establish a framework for indicating future trends of aggregates demand. In the absence of other information, particularly regional economic and industry forecasts, these may be helpful. However, the MPA have recently published regional profiles which are intended to be regularly updated. The regional construction outlook for the South East indicates an annual growth rate of 1.1% for the five years 2018-2022. This is equivalent to 5.5% and 11.45% growth over five and ten years respectively. It is unlikely that a better sub-national forecast will be available in the near future, so it could be used as an ‘indicator’ for indicating future aggregates demand. Notwithstanding this, they are regional estimates, which might obscure local variations.
3.16 In August 2019 the Minerals Product Association (MPA) reported that "the construction market demand for mineral products has been weak since the start of the year. Following two consecutive quarters of deteriorating markets, sales volumes of aggregates in the first half of 2019 stood 1.9% lower compared to the same period in 2018, 0.3% lower for RMC and 1.1% lower for asphalt. Only mortar sales, closely linked to housebuilding, were 1.4% higher in the first half of the year compared to last year. The fall in sales volumes echo official construction data from the Office for National Statistics and other business surveys, which shows that construction output has flattened in recent months. Poor sales volumes for these heavy building materials provide physical evidence of the current weakness in construction, as well as an early indication of further weakening to come. Aggregates and RMC are used in all areas of construction, from housebuilding to new commercial offices and retail, roads, infrastructure projects, as well as general East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 17
Demand3 repair and maintenance. Mortar by contrast is primarily used in housebuilding, whilst asphalt is closely linked to roadworks. These heavy building materials are mostly used early in a construction project timeline and are not usually stocked for future use. As such, reduced market sales for these materials indicates that the level of new construction work is falling and that the lack of new projects will continue to dampen the sector's activity in the coming months."
3.17 In July 2018 the MPA published their UK Minerals Strategy - Meeting the demand for minerals and mineral products sustainably for the next 25 years.
3.18 Details on the local economy are set out in East Sussex in Figures website (for East Sussex).
Population, Housing and Capital Programme Growth
3.19 Government Infrastructure Planning
3.20 The Government published the National Infrastructure Plan (NIP) in October 2010, outlining its vision for the future of UK economic infrastructure, containing major commitments for investment in important infrastructure projects. National infrastructure pipeline updates were subsequently published annually providing detail on the status of all planned UK infrastructure projects. In 2016 the first National Infrastructure Delivery Plan (NIDP) was published (replacing the NIP) and outlined details of investment in over 600 infrastructure projects and programmes in all sectors and spread across the UK, to 2020-21 and beyond. The NIDP also includes sections on how infrastructure will support large-scale housing and regeneration projects alongside key social infrastructure (schools, hospitals and prisons), in line with the government’s £100 billion commitment. The Plan focuses specifically on nearly £300 billion of the Pipeline that will be delivered over the next 5 years to 2020-21. The pipeline is updated regularly; the most recent was published in November 2018. Projects identified will affect the demand for aggregates in the locality, as will others in the region.
Major Infrastructure Projects.
3.21 In trying to assess future demand It may be appropriate to consider locally derived figures such as construction rates of housing and major infrastructure projects over the last decade. Between 2007/8 and 2017/18 there were some 19 753 housing completions in East Sussex and Brighton & Hove. Several major infrastructure projects have been completed in the last 10 years including Peacehaven Waste Water Treatment Works, Newhaven Energy Recovery Facility, The Keep, Amex Stadium, Falmer, and Bexhill Hastings Link Road (BHLR) . Further details of previous housing and major developments in East Sussex and Brighton & Hove are set out in the Appendix A.
3.22 Another measure of demand could be the sources of aggregate used in the plan area. The NPPG states that "for some types of aggregate (such as high quality polished stone value, concreting sand and building sand), it will be necessary to 18 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
3Demand
carry out a separate assessment for different types of aggregate in preparing a Local Aggregate Assessment. This is critical to ensure that the quality of aggregate is appropriate for its intended use, since not all aggregates can be used for all construction purposes". Some of this information is set out in the previous chapter "Geology and Minerals Uses". It is hoped that more details will become available through the Review of Waste and Minerals Local Plan.
3.23 The level of planned infrastructure in the area i.e. allocations in Local Plans and Infrastructure Development Plans (IDPs) can indicate future levels of local demand. An assessment of IDPs covering East Sussex specifies a large range of services (including school and hospital provision, and leisure facilities) which may need constructional materials. There are also several road schemes and a number of employment allocations identified in East Sussex Local Plans. In Brighton & Hove there are strategic Development Areas set out in the City Plan Part One where large scale redevelopment is expected over the Plan Period (up to 2030). Within these area, a number of major areas of development requiring a significant supply of aggregates in their construction are under construction or are expected to come forward in the forthcoming years. Further details of possible allocations are set out in Appendix A.
3.24 Assessment of the level of housing development needed for the next 10 years or more can also help to indicate the level of demand locally for construction aggregates. At least 35 272 housing units are proposed in East Sussex from now and up to 2032. Details of possible housing allocations in Brighton & Hove are set out in the Appendix A. It could be that given the current pressure for housing sites regionally there may be even more development forthcoming than identified in submitted/adopted plans. This could lead to a greater need for aggregates.
3.25 Calculating aggregate demand by directly correlating planned development and the amount of aggregates needed for construction is a matter of recent discussion between planning authorities and the industry. The British Geological Society for example have suggested that 60 tonnes of aggregate are used to build the average house in the UK and that if the associated infrastructure is included this could be as high as 400 tonnes. The formula for housing requirements is also used by the Minerals Production Association.
3.26 Future demand could also be affected by a number of factors with currently undetermined impacts including Brexit, government house building policy, and Wealden Local Plan policy outcomes on Ashdown Forest (possible additional house building of 13 000 homes).
3.27 Appendix A refers to past and potential development in the Plan Area; however demand for aggregates can come from further afield. Previous developments which have drawn on aggregate demands from a wider, sometimes regional, hinterland than the local area include the construction of the London Olympics Park. Demand from regional infrastructure requirements can be difficult to plan for but should be considered. The conclusions on demand contained within East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 19
Demand3
LAAs prepared by adjoining mineral planning authorities can also be helpful in indicating possible demand for aggregates from adjacent areas. For this Plan Area therefore, the LAAS for Kent, Surrey and West Sussex are of interest. 20 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
4Supply 4 Supply
Supply Sales
Land-won sales/production
4.1 Sharp sand and gravel
4.2 For land-won material in East Sussex most sharp sand and gravel deposits are found in the coastal areas and river valleys; there is currently one working extraction site in the east of the Plan area at Lydd quarry which straddles the East Sussex/Kent border. Extraction is currently taking place within East Sussex. Production started within East Sussex in 2011.
4.3 Whilst production figures at Lydd Quarry have previously been subject to confidentiality the operator Brett has made information available (see table below) to assist in the preparation of the Local Aggregate Assessment. The operator also considers that Lydd Quarry sales are split between East Sussex and Kent on an approximate 50/50 basis.
Year Sales Volume (Tonnes) 2006 300 860 2007 311 797 2008 312 118 2009 359 745 2010 359 250 2011 199 032 (1) 2012 353 371 2013 414,348 2014 441 987 2015 343 818 2016 324 703 2017 338 541 2018 297 361
Table 1 Lydd quarry - sales figures
1. Production started in East Sussex
4.4 Soft sand East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 21
Supply4
4.5 The Folkestone Beds, which contain fine grained sand, run eastwards from Ditchling for a relatively short distance in the western part of the Plan Area. This includes a thin seam of “soft sand” deposit (soft sand is also known as building sand), located entirely in the National Park. A soft sand quarry is located at Stanton’s Farm, Novington which is currently inactive.
4.6 Permission for extraction of building sand at Novington sandpit (Stanton’s Farm) was granted in October 2003 and extraction started in September 2007. Annual extraction figures over the last few years are unavailable due to confidentiality constraints. The permission was renewed by the South Downs National Park Authority early in in 2017 and at that time the planning application stated that reserves at the quarry were 350 000 tonnes. There has been no extraction of soft sand from the site for at least 5 years.
4.7 Annual survey information shows that land-won sand and gravel and soft sand is also imported into the Plan area by road and rail although detailed information on these imports (including the origin of aggregate) in the past has not been available.
4.8 Imports–throughput and sources
4.9 Marine sand and gravels extracted from the seabed are an important supply of aggregates and are imported through the Ports of Shoreham, Newhaven and Rye. Crushed rock used as an aggregate (such as limestone) is also imported through these ports and at a railhead located in Newhaven.
4.10 There are three Ports within the Plan Area. The Ports of Shoreham (partial), Newhaven and Rye accommodate various minerals wharves as shown in Table 2.
Port No. of Active in Details Wharves monitoring period Shoreham 3 1 Halls wharf (operated by Cemex) is an active (Port area wharf which straddles the border between within Brighton & Hove and West Sussex. Hove) Britannia Wharf - Planning permission was granted in 2017 for an aggregate bagging operation at at Shoreham Port, which was formerly inactive. The operation, which has been implemented, is effectively a relocation of previous operations on the western arm of the Harbour in West Sussex. It is understood that the material to be processed at the site will comprise 60% marine-won sourced from 22 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
4Supply
Port No. of Active in Details Wharves monitoring period other minerals operators at the port, and 40% land-won from other location inland in West Sussex.
Until earlier in 2019 Ferry Wharf was occupied by a CDEW recycling facility producing recycled aggregates. However, permission has now been granted on this site for redevelopment of the site for a new development providing 867.8m2 of flexible B1/B8 floorspace. meaning that it can no longer be used for sea-borne mineral imports. However, the Port Authority has indicated that replacement import capacity can be provided through the flexible use of the Outer Layby and Brighton Terminal general wharves elsewhere within the Harbour.
Newhaven 6 2 Five wharves are located at North Quay and one at East Quay.
One wharf (Berth 1) at North Quay was in operation in 2018, and another wharf has been in use for scrap metal. In addition, permission has been granted for an asphalt and concrete batching plant at North Quay (Plots 6 & 7). The intention is to import aggregates by sea using wharves at North Quay to supply the proposed developments. Initially Berth 5 would be used, and at a later stage imports would then take place at one of the wharves adjacent to the proposal.
Permission was also granted in 2018 at Fishers Wharf, East Quay for an aggregate processing plant, aggregate bagging plant, concrete batching plant and buildings, ancillary offices and stores for processing and utilising aggregates landed at Newhaven Port and distribution of the products by road and rail together with access to the public highway and the extension of an existing rail East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 23
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Port No. of Active in Details Wharves monitoring period siding. Implementation of the proposal has begun and once operational the development will provide additional imports of 0.2 mtpa initially, increasing to 0.42 mtpa by the final stage of development (although some of this material would be exported by rail in the later phase). This development will involve the import of marine dredged aggregate (MDA). In 2018 8 600 tonnes of MDA was imported to Fishers Wharf.
Rye 2 1 Rastrums wharf is an active wharf capable of importing all types of aggregate including MDA. It is understood that this wharf has a capacity of at least 150 000tpa.
A further wharf at Rye known locally as "the old ARC wharf" has been inactive for some years, but it capable of being brought back into use (provided river dredging were to take place).
Table 2 Wharves in the Plan Area 2018
4.11 Table 3 below details figures from South East Regional reporting (and other sources) for landings of marine sand and gravel imports for Rye and Newhaven ports over the last 10 years. 24 East (1) (2) 4 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 Sussex, Supply (3) Marine dredged 205 106 155 c 78 27 0 0 N/A N/A 10 material South Crushed Rock 145 145 129 c N/A c c c 52 42 48 Downs TOTAL 350 249 284 c N/A c c c 60 62 58 and Table 3 Aggregate Imports and Marine Dredged Material Landed at East Sussex Ports 2008-2018 ('000 tonnes) Brighton 1. estimated from regional data 2. C =confidential/no return submitted
3. based on data from NPMP & Hove, Local Aggregate Assessment, December 2019 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 25
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4.12 The following graph shows the figures set out in the previous table and data back to 2000 as well to provide historical context.
Figure 1 Aggregate Imports and Marine-Dredged Material (showing only data available in the public domain)
4.13 Crushed rock imports were received at Newhaven and Rye Ports during 2018. A small amount of marine sand and gravel and secondary aggregate was also received at Rye Port.
4.14 Historically, Shoreham Harbour data has been collected by West Sussex County Council, as the majority of the Port lies within West Sussex and the LAA has been unable to publish landings figures just for the Brighton & Hove wharves. However the Crown Estate have now published landing figures apportioned by county. This enables an estimate for imports to Hall/Cemex wharf in Brighton & Hove to be calculated, which was approximately 411 000t of MDA in 2018. Regional information also published by the Crown Estate, indicates that the amount of marine dredged material imported into Shoreham Port as a whole increased between 2009 and 2011. There was a small decrease in 2012 and 2013, but since 2014 imports of aggregates landed at the Port have steadily increased, and in 2018 were at a high of 1 318 508 tonnes.
4.15 The Crown Estate has advised the Authorities that marine aggregate is wholly interchangeable with land based sand and gravel, and can perform the same technical tasks. It is routinely used in the production of ready mixed concrete and mortar in markets where it is imported. The presence of chloride and shell is effectively managed by producers and neither present any technical issues. Much of the ready-mixed concrete in the southern parts of East Sussex, West Sussex and Hampshire is produced with marine dredged aggregate, and there are generally no concerns with its use, or objective preferences in relation to land based material.
4.16 Marine aggregate reserves off the south coast of Sussex and Hampshire are plentiful, with circa 100 million tonnes of consented reserves, providing a maximum output of 8.6 million tonnes and a life of 29 years at current levels of extraction. 26 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
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A major reserve also exists within economic sailing distance of south coast wharves in the East English Channel (EEC). Material from EEC areas has been landed at Newhaven and Rye, and that from South Coast licences is delivered to Shoreham.
4.17 Detailed statistics on delivery of and licences for marine dredged aggregates are set out in “The area involved – 20th annual report" and "Marine aggregates Capability & Portfolio" by the Crown Estate and The British Marine Aggregate Producers Association. In summary the South Coast region has 16 production licences and during 2017, 3.77 million tonnes of construction aggregate were dredged with 78.3 per cent being delivered to the South Coast (2.96m). The East English Channel region has ten production licences and in 2017 3.97mt was dredged. In that year a small amount was delivered to the South Coast.
4.18 Plans of the South Coast Licence and EEC areas for 2018 are shown below.
Figure 2 Plan of the South Coast Licence Areas (Source: Crown Estate) East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 27
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Figure 3 Plan of the East of England Chanel Licence Areas (Source: Crown Estate)
4.19 Data from the British Geological Survey’s Aggregate Minerals Survey 2014 provides more information on consumption of aggregates and the nature of imports. In that year 1 200 000 tonnes of land won and marine and crushed rock were consumed in the Plan Area. Less than 20% of this material (excluding crushed rock as it is not quarried in the Area) was supplied from within East Sussex. Recycled and secondary aggregates produced and imported into the Plan Area are assumed to be consumed within that area. Although this is the most recent survey the data is now some years out of date.
4.20 It is a particular characteristic of the East Sussex, South Downs and Brighton & Hove Plan area (based on 2014 figures) therefore that over 80% of aggregates consumed are imported.
4.21 AM2014 data indicates that in 2014: 42 000 tonnes land-won sand and gravel, 650 000 tonnes of marine - won aggregate and 280 000 tonnes of crushed won was imported into the East Sussex and Brighton & Hove Plan area. The DCLG has recently published the summary "AM2014 source of primary aggregates by sub-region – percent categories" for 2014. This shows that since 2009 total consumption has increased to 280 000 tonnes crushed rock, and that the amounts supplied by Kent has increased to between 30 and 40 %, and the amount supplied by Somerset has dropped to between 20-30%. Cornwall now supplies between 1-10 %, Conwy has reduced to between 1-10% and Powys supplied 1-10%. Crushed rock is transported by a mixture of sea, rail, and road. Details of wharves are provided in the paragraphs above. 28 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
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4.22 A rail-head reinstated at Newhaven in 2014 provides an important important import facility for aggregates including crushed rock and recycled aggregate. The rail head also exports incinerator bottom ash arising from the Newhaven ERF. Data on rail-head sales is set out below.
4.23 Notably this data shows increases in rail imports of crushed rock and recycled aggregatesince 2014. There are also aggregate rail-heads relatively close to the Plan Area at Crawley and Ardingly in West Sussex.
Newhaven Railhead 2014 2015 2016 2017 2018 Material - sales (tonnes)
Imported crushed rock 45 852 99 579 74 602 72 442 104 327 from Somerset
Imported recycled 1 550 24 505 35 658 45 090 48 790 aggregate from Brentford
Imported sharp sand and 0 735 19 248 25 495 80 471(2) gravel(1)
Exported Incinerator 61 283 55 897 44 753 N/A N/A Bottom Ash (IBA)
Table 4 Newhaven rail-head - Sales
1. The majority of primary sand and gravel sold from the rail-head has not been delivered to that point by rail. 2. In addition 22 494 tonnes of soft sand was sold from the rail-head in 2018.
4.24 Secondary/Recycled Aggregates
4.25 Recycled aggregates are also produced through the management of construction and demolition waste, and there are a number of facilities in the Plan area which supply this type of material. In addition, recycled aggregates are also imported by rail to Newhaven. A certain amount of "secondary" aggregate also arises in the Plan area such as "reject" bricks from brickworks which are often used as an aggregate. Secondary aggregate such as furnace bottom ash (FBA) is also imported by sea at Rye.
4.26 Previously a best estimate of recycled aggregates production in the Plan Area has been 240,000 tonnes, based on 2008/9 figures for recycled aggregates produced at construction, demolition and excavated waste (CDEW) management facilities in East Sussex and Brighton & Hove. However, monitoring of sites to obtain data for the last three AM surveys saw a much improved response rate and an overall production figure of at least 452 175 tpa was provided for 2018. A plan showing the location of recycled and secondary aggregate facilities is set out in Map 4, and a list of sites can be found in the Waste and Minerals Monitoring Report 2018/19. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 29
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4.27 In addition, it is estimated that annually up to 80 000 tonnes of secondary aggregate are produced and imported into the Plan Area from the following sources : Ashdown and Chailey Brickworks are thought to produce up to 14 000 tpa of brick waste. The brick waste will either be used on site for quarry roads or in some circumstances sold as hard-core. Newhaven Energy Recovery Facility creates IBA material which is exported by rail (currently to Brentford) where it is processed into recycled aggregate for uses including as a road construction material. In the last few years furnace bottom ash (FBA) has been imported from Europe into Rye Harbour. FBA can be used a secondary aggregate.
4.28 Overall, the Plan Area is considered to have a capacity in the region of 663 000 tonnes for recycling Construction, Demolition and Excavation Waste. (1)
Future Supply Options
4.29 Land-won
4.30 Planning permission was recently renewed at Novington sandpit to allow the extraction of sand and restoration of the site to be completed not later than October 2026. Remaining reserves at the quarry are considered to be in the region of 350 000t of reserves. In 2013 the conditions attached to planning permission MR/5 covering Novington sandpit were reviewed.
4.31 As indicated earlier, there have been large scale permitted reserves in the far east of the County at Lydd Quarry. The quarry straddles the East Sussex/Kent border and extraction commenced within East Sussex in 2011. The Waste and Minerals Plan (adopted 2013) estimated that the extraction at Scotney Court Extension/Wall Farm could last until 2026 based on the assumption of an average annual extraction rate of 270,000 tonnes. However, production figures made publicly available by the operator indicate that extraction rates have been higher than expected over the last few years (see Table 1). Reserves at the end of 2018 were in the region of 658,000 tonnes (150,000 in Kent). In June 2019 the operator reported at that time that all consented mineral in East Sussex will be exhausted by mid 2020. On that basis less than a year's reserve remain at Lydd Quarry.
4.32 The working area at Lydd Quarry is covered by an SSSI (Dungeness, Romney Marsh and Rye Bay). Natural England confirmed the extension of the the Special Protection Area and Ramsar designations covering Dungeness, Romney Marsh and Rye Bay in March 2016. One particular feature of interest identified in the SSSI designation is the importance of the geomorphological resource in this area. The designations cover or are adjacent to all the sand and gravel resource in this part of the County. Natural England confirmed the extension of the the Special Protection Area and Ramsar designations covering Dungeness, Romney Marsh and Rye Bay in March 2016. Natural England previously raised concerns related to mineral
1 Approximate figure as at 1 April 2019 30 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
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extraction, and the Waste and Minerals Plan has therefore a note added, related to Areas 11 & 12 extraction rate, that the estimate is subject to a further Habitat Regulations Assessment.
4.33 As mentioned earlier in this document the Authorities are currently undertaking a review of the Waste and Minerals Local Plan which includes consideration of how much aggregate is required in the Plan area and the way in which this can be delivered. During the Call for Sites and Evidence a site was received and promoted as an extension to an existing sand and gravel quarry (Lydd Quarry) in the east of the Plan Area. The authorities are considering the responses and anticipate publishing the next stage of consultation early in 2020. The situation with regard to future land - won provision will be clarified at the next stage of plan preparation.
4.34 Kent County Council's Minerals Sites Plan is currently the subject of an Examination in Public and Hearings have taken place. An extension to Lydd Quarry on the Kent side was not included in the submitted Kent Minerals Site Plan.
4.35 Due to its dormant status and the significant development constraints affecting the site, it is considered inappropriate to include the remaining reserves at Castle Water as part of the future land-won supply from the Plan area.
4.36 Marine
4.37 The South Marine Plan was published by the MMO for in 2018. Policies in the Plan safeguard aggregate licence areas from other activities, unless it is demonstrated that the other activities are compatible with aggregate extraction, and ensures that proposals consider areas of high potential aggregate resource (as defined by the British Geological Survey).
4.38 The adopted Waste and Minerals Local Plan safeguards capacity for landing, processing and handling minerals at Shoreham, Newhaven and Rye Ports and sets out details of the safeguarded wharf areas. Alternative use proposals would need to demonstrate no net loss of capacity and the mineral planning authorities expect to be consulted on any proposals for non minerals development.
4.39 There are currently several strategies being put forward by other organisations which concern the port areas at Shoreham, Rye and Newhaven. The Authorities will seek to ensure safeguarding of wharf capacity as part of any development at the ports. Proposals for other uses at ports would need to demonstrate that sufficient alternative mineral wharf capacity (tonnage) is deliverable and available to meet needs in the Plan Area for the plan period before the Authorities would accede to alternative development of the site. Proposals for new residential, business or amenity development in proximity to aggregate wharves should be assessed to ensure the impact of existing operations is fully addressed. The safeguarding arrangements would apply to all existing permitted, planned and potential sites regardless of whether they are currently in use. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 31
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4.40 Newhaven Port Authority published a Port Masterplan in January 2012. This plan expects to see aggregate imports to continue at North Quay over the short to medium term, and will encourage use of the wharves for aggregates. Enterprise Zone status commenced in April 2017 on an area of Newhaven covering 8 strategic sites (see Appendix A for details). Marine dredged aggregate imports ceased at the Port in May 2013 and until recently imports were restricted to crushed rock from quarries (including those in Cornwall, Wales, Ireland and France.) However, permission has now been granted for two sites which will import marine dredged aggregates and crushed rock at Newhaven Port, and this should affirm the future role of the Port for importing aggregates.(2) These developments (detailed in Table 1) comprise an asphalt and concrete batching plant at North Quay (Plots 6 & 7), and an aggregate processing plant, aggregate bagging plant, concrete batching plant at Fishers Wharf, East Quay. Once fully operational these facilities, in particular the Fishers Wharf operation, will provide significant additional importing capacity for the Plan area.
4.41 Shoreham Port is partly within West Sussex, so landings at wharves in the West Sussex part also help meet demand in the western part of the Plan Area. On that basis provision of equivalent capacity (tonnage) of minerals wharfage within either part of Shoreham Port may be acceptable subject to similar safeguarding by West Sussex County Council (WSCC) as Minerals Planning Authority.
4.42 Adur District Council, Brighton & Hove City Council, West Sussex County Council (WSCC) and Shoreham Port Authority are partners in the preparation of the Shoreham Harbour Joint Area Action Plan (JAAP) which sets out a 15 – 20 years plan to guide the regeneration of Shoreham Harbour. The now recently adopted JAAP outlines proposals for housing, employment and economy and environmental improvements. In order to achieve this, some consolidation of operations and redevelopment of mineral wharves (particularly in West Sussex) is proposed. It is recognised that the provision and safeguarding of minerals wharfage is a key issue if the JAAP aims are to be achieved. To this end the JAAP partners, together with South Downs National Park Authority, and ESCC have signed a Statement of Common Ground (SOCG). The purpose of the SOCG is to underpin effective cooperation and collaboration between the partners in addressing strategic cross-boundary issues as they relate to planning for minerals infrastructure and safeguarding in Shoreham Harbour. The SoCG was updated in July 2016 to reflect new data and progress in Local Plan preparation. Policy SP 9 in the WMSP will be the mechanism for assessing the impact on wharf capacity at the Brighton & Hove section of the Port from any development proposals in this area.
4.43 Ferry Wharf (a vacant mineral wharf) on the Brighton & Hove side of the port is also allocated in the JAAP for redevelopment for employment uses, subject to other policies in the development plan being satisfied. Permission has recently been granted for 867.8m2 of flexible B1/B8 floorspace on this site which will preclude its future use for minerals imports. In line with the paragraph 5.6 of the Statement of Common Ground which allows for “flexible arrangements such as
2 Newhaven Port Authority 32 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
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wharves within the safeguarding area which cater for a range of materials, including minerals, to compensate for the loss of capacity at a specific mineral wharf”, the Port Authority has agreed to the flexible use of the Outer Layby and Brighton Terminal general wharves elsewhere within the Harbour to handle mineral imports when demand requires it. In line with this approach, the Outer Layby wharf has already been used for some mineral imports.
4.44 The West Sussex joint MLP was adopted in July 2018 and includes proposals for minerals wharfage at Shoreham and Littlehampton in line with the SoCG.
4.45 Imports at Rastrums wharf Rye are anticipated to continue and it is understood that there is surplus capacity available. There is no evidence to suggest that the currently inactive wharf at Rye could not be brought back into use (provided the river is dredged).
4.46 Imports
4.47 It is understood that the crushed rock capacity at quarries in Somerset and Conwy have sufficient permitted reserves at the quarries to ensure a steady and continual supply into the Plan Area.
4.48 Recycled / Secondary
4.49 There is no current evidence to suggest that the existing capacity for producing recycled and secondary aggregates will not be maintained. It is assumed therefore that facilities in the Plan Area will continue to contribute to aggregates supply in the area. The locations of recycled and secondary aggregate facilities in East Sussex and Brighton & Hove are set out in Map 4 at the end of this document.
4.50 The Authorities' survey of recycled aggregates sites in 2018 (for the AM2017 survey) resulted in a very good coverage and response rate this year, which will contribute to improved data in the future. In addition, SEEAWP have been investigating alternative methods of calculating recycled aggregate which could assist in providing better data.
4.51 In 2014 the MMO published a report on the "Use of beneficial dredged materials in the South Inshore and South Offshore Marine Plan Areas". This looks at the existing and potential uses of dredged materials arising from capital or maintenance dredging for coastal defence, beach replenishment or habitat creation. The report states that there is scope for further beneficial use of materials provided that they are suitably matched and that the re-use logistics can be agreed. This source of alternative aggregates may therefore assist in meeting the need for aggregates in the Plan area in the future. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 33
Environmental constraints5 5 Environmental constraints
The Environment of the Plan Area
Land-won
5.1 Large parts of the Plan Area are subject to environmental constraints. Two thirds of the area is covered the South Downs National Park (SDNP) and the High Weald Area of Outstanding Natural Beauty together, and other tracts of land are also designated as being of international and national environmental importance.
5.2 A number of areas are designated for wildlife conservation. These include two Special Areas of Conservation (SACs) and five Special Protection Areas (SPAs) and two large Ramsar sites at Pevensey Levels, and near Rye. There are four National Nature Reserves and 25 Local Nature Reserves. National designations include 64 Sites of Special Scientific Interest (SSSIs)(3). There are two Regionally Important Geological sites and numerous Sites of Nature Conservation Importance (SNCIs). One sixth of the area of Brighton & Hove is covered by nature conservation designations. These areas need to be protected in order to maintain the rich and varied landscape character and biodiversity within the Plan Area.
5.3 The South Downs are formed by a line of hills and vales extending along the coast westwards from Eastbourne. It is a unique, open, rolling landscape dissected by major river valleys cut by the Ouse and Cuckmere. Whilst now no longer active, chalk quarrying was a long established industry in the area, and has had a noticeable impact on the landscape, especially along the scarp slope and around Lewes. To the north of the chalk are the Greensand beds with the Folkestone Formation extending north west from Lewes in East Sussex, across West Sussex and into Hampshire. The area within East Sussex was previously outside the Sussex Downs AONB but it is now located within the South Downs National Park.
5.4 The High Weald AONB is a landscape of rolling hills, scattered farmsteads, small woodlands, irregular-shaped fields, open heaths and ancient routeways. It also includes the Ashdown Forest. The High Weald covers much of the northern, central and eastern parts of the Plan area. It is a faulted structure comprising clays and sandstones (collectively known as the Hastings Beds). This varied and extensively eroded geology has produced an attractive and sensitive landscape, most of which is within the High Weald Area of Outstanding Natural Beauty.
5.5 The Low Weald is a gently undulating clay vale which separates the High Weald from the Chalk Downs to the south.
3 These are split into 391 separate units 34 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
5Environmental constraints
5.6 The Coastal Marshes are located between Eastbourne and Bexhill, and in the Rye Bay/Camber area either side of the Rother estuary. Inundated by the sea in recent geological times, these areas comprise large flat sheets of alluvium, extending inland over the Pevensey Levels and Romney Marsh.
Environmental Constraints and minerals working
5.7 The Plan Area is therefore heavily affected by environmental constraints. Minerals can only be dug where they naturally occur, and given the exploitation that has already taken place, there are limited areas of resource in the Plan Area which are not constrained by environmental factors. Opportunities for new aggregate production areas are therefore highly restricted.
5.8 Current sites for extraction have experienced the application of further environmental constraints. Novington sand pit (Stanton's Farm) which has extracted from a limited exposure of the Folkestone Beds north-west of Lewes which was not previously in the AONB, is now located in the SDNP.
5.9 The working area at Lydd Quarry is covered by an SSSI (Dungeness, Romney Marsh and Rye Bay). Natural England confirmed the extension of the the Special Protection Area and Ramsar designations covering Dungeness, Romney Marsh and Rye Bay in March 2016. One particular feature of interest identified in the SSSI designation is the importance of the geomorphological resource in this area. The designations cover or are adjacent to all the sand and gravel resource in this part of the County.
5.10 The environmental impact of marine dredging is controlled and monitored by the Licensing system administered by the MMO. Effects of secondary aggregate production would be regulated by planning and permitting legislation and controls. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 35
Balance6 6 Balance
Balance between Supply and Demand
6.1 Land-won
6.2 As stated earlier in this document, the Authorities are currently reviewing their Waste and Minerals Local Plan and as part of this will be reassessing aggregate provision and the 0.1mtpa surrogate demand indicator used in the adopted Waste and Minerals Plan.
6.3 Assessments of aggregate provision are considered in the early sections "Demand" and Supply" and potential LAA rates for the different elements of supply are included in the Executive Summary, as requested by SEEAWP. These are also set out below for convenience:
Aggregate type LAA rate (based on 2018 data)
Land won sharp sand and gravel 0.16* (The 3 year average has been halved as 50% material is exported directly to Kent.)
Soft sand 0
Recycled/secondary 0.378
Marine sand and gravel 0.012
Rock imports by sea 0.047
Rail depot - sharp sand and gravel 0.041
Rail depot - crushed rock 0.083
Table 1
6.4 If demand were to remain constant then these rates would need to be maintained overall for provision over the Plan period (15 years from 2019, therefore to 2034). In the next few years there may be reductions in sharp sand and gravel production, however there are large increases in marine imports planned at Newhaven. No other significant changes are anticipated.
6.5 However, the Authorities are also required to assess the effect of demand changes on provision. As discussed earlier in the document there is no absolute method for forecasting demand and figures can only provide a guide. To provide a broad estimate the Authorities have compared housing completions over the last 10 years with projections of homes within the Plan area over the next decade (based on 2017 figures), and then multiplied these figures by 400 tonnes of aggregate (using the BGS methodology). These estimates indicate that at the 36 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
6Balance
highest level of demand, aggregate requirements could increase just over two-fold. It should be noted that these are estimates only and more details will be provided as part of the Plan Review. The Authorities will consider how this demand could be met in the Waste and Minerals Local Plan Review.
6.6 Along with other mineral planning authorities in the South East the Authorities have signed a Position statement which aims to collaboratively address supply issues facing soft sand. This Position Statement will form the basis for ongoing Duty to Cooperate work that may be needed to ensure the steady supply of soft sand as required by the NPPF.
6.7 The Authorities have recently signed a SoCG with Kent County Council and West Sussex County Council on the provision of of soft sand.
6.8 The principal constraint on the level of marine landings during the Plan period is the security of port access (loss of wharves to other uses), channel and berth restrictions, vessel availability and investment in modern wharf infrastructure. The British Marine Aggregate Producers Association (BMAPA) maintain that there is a long term future for smaller vessels to import to smaller wharves and local operators have indicated that this is the case in East Sussex.
6.9 The importation of crushed rock from the UK or further afield is limited by wharf capacity and market forces. As there is no availability of this material from within the Plan Area, landings directly reflect demand. Crushed rock can be landed to non-specialist wharves, improving flexibility within port areas.(4)
6.10 According to the Port Authorities at Shoreham, Newhaven and Rye, sufficient wharf capacity apparently remains in the Plan Area to allow significant landings to continue for the foreseeable future. However, in order to maintain potential wharf capacity for the future it is essential that adequate safeguarding measures are in place to enable the authorities to respond to threats of redevelopment of wharves from alternative uses. Comprehensive safeguarding is an important tool in achieving strategic provision of wharf capacity within the various emerging plans for ports in the plan area.
6.11 It is also crucial that rail import facilities are protected from redevelopment. Waste and Minerals Local Plan policy seeks to safeguard existing, planned and potential railheads and minerals wharves, and to monitor the need for these facilities. Policies to safeguard wharves and railheads, concrete batching, coated materials manufacture and other concrete products facilities are set out in the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan. Regional discussion will be required to secure rail and wharf facilities which contribute provision to the Plan Area. Positive dialogue with adjoining and more distant mineral planning authorities will also be needed to check and maintain
4 As the method of landing crushed rock is simpler than landing marine aggregates there is less attraction to move to larger vessels to reduce costs and crushed rock does not require specialist handing equipment. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 37
Balance6 security of supply of aggregates, particularly crushed rock. This should be enabled through good practice, aggregate working party arrangements and Duty to Cooperate requirements.
6.12 Secondary aggregates can provide an alternative to primary aggregates, and subject to technological advancement, there is potential scope to substitute more recycled aggregates. Economic instruments such as the Landfill Tax have had a considerable impact on the level of material available, forcing previously landfilled CDEW waste to be processed into recycled aggregate.
6.13 There are moves to increase utilisation of alternative sources with a consequential increased contribution to total demand. However, the availability and utilisation rate remains unpredictable and substitution is not always possible.
6.14 A diagrammatic plan summarising the origin of locally won and produced aggregates, as well as consumption and the nature of imports into the Plan area, is included as Map 2 based on 2014 data. 38 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
7Conclusions 7 Conclusions
7.1 This LAA has examined the latest information and data available on aggregates and the key conclusions are:
Overall picture of aggregate supply – heavily dependant on imports by road, sea and rail; land-won sand and gravel extracted in the east of the Plan Area with about 50% of material being exported to Kent. Significant marine imports through Shoreham Port and Newhaven and to an extent Rye, rail imports of crushed rock, recycled aggregate and sand and gravel at Newhaven; and a level of supply from recycled aggregates throughout the Plan Area. Assumed that all soft sand supply is met by road imports.
Significant new aggregate capacity is due to come on board in 2020 in Newhaven with the development of a new aggregate processing plant, bagging plant, concrete batching plant and buildings, utilising aggregates landed at the Port and distribution of products by road and rail including the extension of an existing rail siding.
Steady continuing demand anticipated, (possibly twice as much as the last 10 years).
The adopted aggregate policies are being reviewed as part of the current Review of the Waste and Minerals Local Plan. A consultation on the the call for sites and evidence took place at the end of 2017. The authorities are considering the responses to the call for sites, and anticipate publishing the the next stage of consultation in 2020.
With regards to land-won supply approximately one year or less of reserves remain at Lydd Quarry.
Along with other mineral planning authorities in the South East, the authorities have signed a position statement on soft sand which aims to collaboratively address supply issues facing an important mineral used by the construction industry. Evidence is currently being gathered on the origins of soft sand being imported into the Plan Area.
Since 2014 the the Newhaven railhead has received a steady and increasing supply of imports of crushed rock, recycled aggregate and sand and gravel.
Imports at Shoreham Port have steadily increased, and material from South Coast Licenses forms the majority of the aggregate supply. East Sussex and Brighton & Hove is very dependant on these imports. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 39
Conclusions7
The Authorities' survey of recycled aggregates sites in 2019 (for the AM2018 survey) resulted in an improved coverage and 100% response rate this year, which has provided more accurate data and should contribute to improved information in the future.
7.2 The Authorities consider that where appropriate they have taken into account the requirements for preparing the LAA set by national advice, SEEAWP and the MPA/POS guidance. 40 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
APast and Future Development Appendix A: Past and Future Development
Past Development
East Sussex
Between 2007/8 and 2017/18 there were 15 076 housing completions in East Sussex.
Over the last decade the following major infrastructure projects have been completed within the county: Peacehaven Waste Water Treatment Works, Newhaven Energy Recovery Facility, and the Bexhill Hastings Link Road (BHLR).
Brighton & Hove
Between 2007 and 2017 there were 4,677 housing completions in Brighton & Hove.
Major infrastructure projects that have taken place in Brighton & Hove over the last decade include The Keep, and Amex Stadium, Falmer.
Future development in the Plan Area
A.1 Within the Plan area, a number of major areas of development requiring a supply of aggregates in their construction are under construction or are expected to come forward in in the forthcoming years. These include:
Rampion Windfarm East Quay, Newhaven Port Flood defence Newhaven Newhaven town centre redevelopment Newhaven: Harbour Heights - 700 new homes Phase 2 of the Newhaven Port Access Road (completion due 2020) A27 East of Lewes small scale interventions – construction 2020 to 2022 Ashdown Forest – new school Hailsham A22 improvements – Hailsham to Stone Cross section North Bexhill: 2,000 new homes and 60,000sqm of employment space HSR1 Ashford to Eastbourne – improvements at Ashford International Station and line speed improvements on the Marshlink line Brighton Marina - Flood defence measures Shoreham Harbour development area City College Uni Developments University of Sussex – East and West Slope redevelopments Preston Barracks, Brighton - major regeneration scheme Royal Sussex County Hospital – Major hospital rebuild and expansion Brighton Marina, Gas works & Black Rock East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 41
Past and Future DevelopmentA
Lewes Road Development, Brighton New England Quarter/London Road, Brighton Sackville Trading Estate redevelopment, Hove Eastern Road & Edward Street Area, Brighton: 470 residential units, hospital rebuild, 400 bed student accomodation, 3,800 sqm education floorspace, GP Surgery, Community Building Hove Station Area: 630 residential units, retention or replacement of 13,000 sqm Toads Hole Valley, Hove - major greenfield development area Shoreham Harbour: 400 residential units, 7500 sqm floorspace (within B&H part of the harbour) 42 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019
BImports into plan area Appendix B: Imports into plan area
NOTE
B.1 The data in this Appendix is based on that provided by BGS as a summary from AM2014 on consumption by sub-region of crushed rock and sand and gravel. Consumption of both sand and gravel and crushed rock has increased since 2009. Information currently available is not as detailed as that from the 2009 collation and does not include data on transport modes. Where applicable the 2009 import percentage figure is shown is brackets after that for 2014 to indicate any change that has occurred.
Data
B.2 Of the total 920 000 tonnes sand and gravel (land-won and marine) consumed in East Sussex and Brighton & Hove;
20 -30% (16%) was supplied from within East Sussex. 60-70% (70%) was supplied from West Sussex. About 1-10 (10) % was supplied from Kent Medway and Surrey each supplied between 1-10 (5)%. Greater London East supplied 1-10% Oxfordshire, South Downs, and Central Bedfordshire each supplied less than 1%.
B.3 Of the total 280 000 tonnes crushed rock consumed in East Sussex and Brighton & Hove:
Kent supplied between -30 and 40 % Somerset supplied between 20-30 % (60-65%), Cornwall supplied between 1-10 % Conwy supplied between 1-10% (20-25%) Powys supplied 1-10% 20 - 30% of crushed rock is supplied from outside England and Wales Leicestershire, the Peak District National Park and Shropshire each supplied less than 1%. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 43 Map 1: Geological Plan including locations of aggregate wharves and railheads, and existing aggregate sites Map 1: Geological Plan including locations of aggregate wharves and railheads, and existing aggregate sites
East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 45 Map 2: Origin of aggregate imported, produced and consumed in East Sussex and Brighton & Hove during 2014 Map 2: Origin of aggregate imported, produced and consumed in East Sussex and Brighton & Hove during 2014
East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 47 Map 3: Sand and gravel resources in the East English Channel and Thames Estuary (Source: Crown Estate) Map 3: Sand and gravel resources in the East English Channel and Thames Estuary (Source: Crown Estate) 48 East Estuary the Map Sussex, South East 3: Downs Sand (Source: and English Brighton & and Hove, Local Channel Crown Aggregate gravel Assessment, Estate) resources December and 2019 Thames in Sand and gravel resources in the East English Channel and Thames Estuary (Source: Crown Estate) East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2019 49 Map 4: Recycled and secondary aggregates sites 2018/19 Map 4: Recycled and secondary aggregates sites 2018/19
East Sussex County Council County Hall St Anne's Crescent Lewes BN7 1UE Phone: 0345 60 80 190 Website: eastsussex.gov.uk
South Downs National Park Authority South Downs Centre North Street Midhurst GU29 9DH Phone: 0300 30 31 053 Website: southdowns.gov.uk
Brighton & Hove City Council Hove Town Hall Norton Road Hove BN3 2BQ Website: brighton-hove.gov.uk
December 2019
East Sussex County Council County Hall St Anne's Crescent Lewes BN7 1UE Phone: 0345 60 80 190 Website: eastsussex.gov.uk
April 2020
ISBN: 978-0-86147-547-6