Lower Compton Waste Recovery Facility
Planning Application Supporting Statement
Prepared by Adams Hendry Consulting Limited
August 2011
www.hills-group.co.uk Contents
PAGE
1 Introduction 1 2 Site & Surroundings 5 3 The Proposed Development 11 4 Planning & Environmental Policy Context 23 5 The Need for the Proposed Development 33 6 Planning & Environmental Analysis 43 7 Conclusions 61
Appendix 1 Planning Application Supporting Statement Figures
Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
1 Introduction
1.1 Hills Waste Solutions Ltd (Hills) is seeking planning permission from Wiltshire Council (WC) for a Waste Recovery Facility (WRF) at its Lower Compton Waste Management Facility near Calne, Wiltshire, as shown on drawing HILLS/1011- DWG-001-Rev.A.
1.2 The development will comprise the following:
• The extension and permanent retention of a Materials Recovery Facility and the provision of a Municipal Waste Transfer Station • The construction of a new Industrial and Commercial Waste Materials Recovery and Transfer Facility • Low grade open air windrow composting • The relocation and continued operation of the existing waste wood chipping operations • Reconfiguration of site infrastructure and landscape provisions and planting
1.3 The proposals are located within the administrative area of WC, a unitary authority. The planning application has been submitted to WC as the Waste Planning Authority (WPA). The proposals will meet the need for upgraded and additional infrastructure to provide for the processing of non hazardous wastes in Wiltshire.
The Applicant
1.4 Hills is a wholly owned subsidiary of The Hills Group Limited, a privately owned family company established in 1900. Hills is a significant regional provider of products and services within the waste management sector and offers a range of specialist waste management and recycling services to both the private and public sector.
1.5 These services are provided through a comprehensive network of waste management facilities that is centered on Wiltshire, but also extends into neighbouring counties. Hills is now one of the regionʼs largest providers of waste management solutions. As the recycling and disposal contractor to Wiltshire Council, Hills has also helped to establish the county as one of the UKʼs best performing recyclers of household waste.
1.6 The location of the planning application area for the proposals (subsequently referred to as the application site or the site), shown on drawing HILLS/1011-DWG- 002-Rev.A, is located within the existing Lower Compton Waste Management Facility owned by Hills.
1.7 This existing Lower Compton Waste Management Facility including the application site is strategically important to the management of waste in Wiltshire. It provides essential waste recovery and disposal capacity for the management of a significant proportion of municipal waste arising in the Wiltshire area, and is equally important for waste produced by the industrial and commercial sectors. For both waste streams the existing facility provides a valuable resource for the treatment and diversion of recoverable wastes and the disposal of residual wastes to landfill.
Adams Hendry Consulting Ltd 1 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
1.8 Whilst the existing site continues to play an essential role in the sustainable management of waste in Wiltshire, there is an urgent need for additional infrastructure to be provided and for the existing infrastructure associated with the treatment and recovery of waste at Lower Compton to be upgraded. The proposals will enable Hills to continue to service customer requirements, whilst providing capacity capable of fulfilling a long term role in the management of wastes arising in, and imported for management in, the Wiltshire area.
The Planning Submission
1.11 This statement, and the folder in which it is contained comprise the documentation necessary to ensure that the planning application can be registered, validated and determined by WC. In addition to this statement, the planning submission comprises a number of technical matters, including:
. Planning Application Forms and Certificates . Design and Access Statement (Adams Hendry) . Statement of Community Involvement (Adams Hendry) . Transport Assessment (PFA Consulting) . Ecological Impact Assessment (Johns Associates) . Arboricultural Impact Assessment and Tree Survey (Glendale Countryside) . Flood Risk Assessment and Surface Waste Drainage Strategy (Johns Associates) . Generic and Preliminary Land Quality Risk Assessments (SLR) . Planning Drawings (prepared by Peter Kent Architects and fabric)
1.12 This Planning Application Supporting Statement has been prepared by Adams Hendry Consulting Ltd to support the planning submission. Section 2 identifies the application site and its surroundings, including the relevant planning history for the site, and the proposed development is explained in detail in Section 3. Section 4 identifies the relevant planning and environmental policy context for this planning application, whilst Section 5 explains the need for the development and Section 6 provides an analysis of planning and environmental policy applicable to the proposals. A conclusion is presented in Section 7.
Environmental Impact Assessment (EIA)
1.9 The statutory requirement for Environmental Impact Assessment (EIA) comes from Directive 85/337/EEC (as amended by Directive 97/11/EC and Article 3 of Directive 2003/35/EC), which has been implemented into UK law for present purposes through the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 (as amended) (subsequently referred to as the EIA Regulations).
1.10 The EIA Regulations defines two categories of development: those listed under Schedule 1 of the Regulations and for which EIA is mandatory, and those listed under Schedule 2 and for which a decision has to be made (taking into account various criteria set out in the EIA Regulations) whether it is likely to have significant effects on the environment by virtue of factors such as its nature, size or location, thereby requiring an EIA.
Adams Hendry Consulting Ltd 2 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
1.11 The proposals are not Schedule 1 development. However, the proposed development is considered to fall within the definition set out in Schedule 2, paragraph 11 (b) ʻOther Projectsʼ of the Regulations, which is defined as:
“Installations for the disposal of waste (unless specified in Schedule 1) [where]; (i) The disposal is by incineration; or (ii) the area of the development exceeds 0.5 hectares; or (iii) the installation is to be sited within 100 metres of any controlled waters.”
1.12 The proposals will provide capacity to treat and recover waste on a site that is approximately 8.75 hectares in area. As such it has been necessary to consider whether or not the project would be likely to give rise to significant environmental effects. It was concluded that there was insufficient information available available to be able to confirm that no such significant effects might arise in respect of transportation and access, air quality and odour and noise and vibration matters.
1.13 Concluding that an EIA was required, Hills submitted a request to WC in April 2011 for a Scoping Opinion on information to be included within a proposed EIA. In June 2011 WC provided their Scoping Opinion confirming that the ES for the proposals should provide information in respect of:
• Transport and Access effects; • Air Quality & Odour effects; • Noise & Vibration effects; • Cumulative and In-Combination Effects; • Consideration of Alternatives, and • Planning Policy Implications.
1.14 Consequently, an EIA of the proposed development has been carried out and submitted in support of the planning application. Information relating to transport and access, air quality and odour, and noise and vibration is provided in the accompanying ES at Chapters 9, 10 and 11, respectively. Cumulative and in- combination effects are addressed within each of those chapters, taking account of the information given in Chapter 2 of the ES. Following the EIA scoping process some minor iteration of the proposals was undertaken. As a result of this process it was considered appropriate to also undertake a landscape and visual impact assessment of the proposals. This assessment is reported in Chapter 12 of the ES.
Adams Hendry Consulting Ltd 3 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
Adams Hendry Consulting Ltd 4 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
2 Site & Surroundings
Introduction
2.1 This section describes the site of the proposals at the Lower Compton Waste Management Facility and their surroundings. It is based on site visits, aerial photographs, ordnance survey maps, surveys commissioned for the application documentation and information provided in the adopted and emerging Development Plan.
Site Context and Location
2.2 The existing Lower Compton Waste Management Facility is located approximately 1km to the east of Calne, Wiltshire (see drawing HILLS/1011-DWG-001-Rev.A). Immediately to the south of the site entrance lies the residential area of Lower Compton. Located 950m the south east is the village of Cherhill, and Quemerford is located approximately 950m to the south west. The village of Compton Bassett is located approximately 1.6km to the north east of the facility.
2.3 The Lower Compton Waste Management Facility falls within the administrative jurisdiction of Wiltshire Council, within the Northern Area of the newly formed Unitary Authority (an area formerly known as North Wiltshire District). It is located within and / or adjacent to the parishes of Cherhill and Calne Without.
2.4 The application site is situated within the south-east corner of the wider Lower Compton Waste Management Facility and covers approximately 8.75 hectares. Drawing HILLS/1011-DWG-002-Rev.C shows the boundary of the application site. Vehicular access to the site from the strategic road network is via the C15 road, which is served directly from the A4 from the east and the A3102 and the A4 from the west.
2.5 The section of the C15 road between the A4 and the Hills Lower Compton Waste Management Facility is a two-way road with a speed limit of 60 miles per hour. The site entrance is accessed via a three-arm mini roundabout on the C15, approximately 700m north of a junction with the A4 between Cherhill and Calne.
2.6 Since the 1930s sand extraction has taken place in the area to the east of Calne, initially at Sands Farm (to the west of the application site) and then, since the 1970s, at the Compton Bassett mineral extraction and non hazardous landfill site, which forms part of the wider Lower Compton Waste Management Facility. The landfill operations were taken over by Hills in July 1996 after they were awarded the municipal waste management and disposal contract by Wiltshire County Council.
2.7 The nature and extent of approved waste recovery and processing facilities at the wider Lower Compton facility has since steadily grown both in response to the municipal contracts and market demand, and to meet waste sector controls and requirements since the mid 1990s. The site now operates as an integrated waste management facility providing essential waste collection, processing and disposal services to municipal, industrial and commercial, and demolition and construction waste sectors.
Adams Hendry Consulting Ltd 5 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
Surrounding Context
2.8 The Proposals Map for the Adopted North Wiltshire District Local Plan (2006), which remains in force, identifies that the application site is located outside of the development boundaries of both Calne and Cherhill. The application site is therefore located in the defined countryside, although it is immediately surrounded by the wider existing waste management and mineral extraction operations.
2.9 To the north of the application site is a future mineral extraction and landfill area known as Old Camp Farm. Beyond this to the north is the operational mineral extraction and non hazardous waste landfill extension site known as Low Lane. The western edge of the wider Lower Compton Waste Management Facility adjoins Sands Farm mineral extraction and landfill site operated by Aggregate Industries and Viridor Waste Management.
2.10 To the east and south of the site runs a screening bank, which extends north, adjacent to the Old Camp Farm site. To the east of the screening bank lies grazed agricultural land in the ownership of the applicant, which in turn is bound by the C15
2.11 The C15 also represents part of the western boundary of the North Wessex Downs Area of Outstanding Natural Beauty (AONB) as shown on Figure 1, Appendix 1. Beyond the road within the AONB lies agricultural pasture land and a wooded minor ridgeline. Part of the northern area of this land is designated as Compton Bassett Park, with the north eastern section also lying within the Compton Bassett village Conservation Area. The AONB also extends to the south of the site, at a distance of approximately 1km from the site.
2.12 Immediately to the south of the proposal site is the Former RAF Compton NAAFI, beyond which is the residential area of Lower Compton, itself straddling the minor road between the A4 and the A3102. To the south west, between the existing waste management facilities and Quemerford is a local Wastewater Treatment Works.
2.13 The landscape surrounding the application site has been modified as a result of mineral extraction and landfill activities, and large scale built elements such as agricultural barns and buildings.
2.14 The nearest group of dwellings to the application site are Old Camp Farm (25m to the north east, owned by Hills), Tudor Lodge (200m to the north east), Winterbrook House (110m to the south east) numbers 121 - 137 Spreckley Road which are (approximately 100m from the southern extent of the landscape screening bund). Further properties are located 350m to the south east of the site along Marsh Lane. Figure 1 summarises these features below.
Planning History and Existing Site Layout
2.15 The wider Lower Compton Site has a planning history that dates back to the early 1970s; the original permission for sand extraction was granted in 1972. Since Hills acquired the Lower Compton facility from the former Wiltshire County Council in 1996, the application site and wider Lower Compton Waste Management Facility has been subject to a number of planning applications concerning mineral extraction and waste management operations.
Adams Hendry Consulting Ltd 6 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
2.16 At present the application site is used for a range of waste management activities and contains the following elements, as shown on Figure 2 (Appendix 1):
a) a Materials Recovery Facility and site offices (operational) (time limited – due to close at 2016); b) a landscape screening bund (time limited to 2016); c) a permanent waste wood and industrial and commercial waste recycling and transfer facility (operational); d) a permanent green waste composting facility (operational); e) vehicle parking areas that serve the wider site, and f) site haul roads and weighbridge area.
2.17 The wider existing waste management facility and mineral extraction operations outside of the application site area also shown on Figure 2, and comprises the following:
g) Compton Bassett quarry and landfill mineral extraction and non hazardous waste landfill (operational / mineral extraction to cease by 2042 / landfill operations not time limited and expected to continue post closure of Old Camp Farm Landfill); h) Old Camp Farm mineral extraction (commenced) and non hazardous waste landfill extension (not yet commenced – to be complete by 2022); i) Low Lane mineral extraction and non hazardous waste landfill extension (operational to be complete by 2018); j) concrete batching facility (operational); k) landfill gas management system, gas engines and energy recovery (operational); l) landfill leachate treatment lagoon (operational / permanent or until no longer required); m) water attenuation lagoon(s); n) Household Recycling Centre (operational / permanent), and o) the remainder of the vehicle parking areas and areas for the storage of skips.
Materials Recovery Facility (MRF) and site offices
2.18 Planning permission was granted in March 1997 for the development of a Materials Recovery Facility to manually sort and bulk recyclable materials (Planning permission N.96.2022). The MRF is located in the southern area of the application site. In August 2005, planning permission was granted for the extension of the MRF to provide additional office space and welfare facilities.
2.19 In November 2006 planning permission was granted to extend the hours of operations until 20.00 Monday to Friday and 13.00 on Saturdays. MRF operations are required to cease on or before 31st December 2016.
Landscape screening bund
2.20 The landscape screening bund, labelled as ʻDʼ on Figure 2.3, was granted planning permission in March 1997 (Application No.N.96.2022) as part of the requirements for the provision of screening for the MRF. The bund is 5.6m high at its highest point and is graded to a 1 in 9 slope on the outer (eastern) edge where it meets the existing ground level, and a 1 in 3 slope on the inner (western) edge. The bund is currently grassed and is managed as open pasture and grazing consistent with the
Adams Hendry Consulting Ltd 7 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
adjacent open pasture land immediately to the east. As with the MRF, use of the bund adjacent to the application site is required to cease on or before the 31st December 2016.
Waste wood and industrial and commercial waste recycling and transfer facility
2.21 This facility is located between the composting site and the vehicle parking area (see figure 2.2). The recycling facility was originally granted consent in February 2001 (N002627), which was followed by a further permission for the relocation of the waste recycling and transfer facility to its current location, granted in March 2004 (Planning Ref N033304). The facility accepts waste wood and inert industrial and commercial wastes. This more recent planning permission does not require the development to cease by any stated date.
2.22 The facility is accessed from the existing haul road and consists of an open facility, which is approximately less than 1ha in area within which waste is deposited, sorted, and processed either for recovery or disposal.
Green Waste Composting facility
2.23 This facility is located at the northern extent of the application site covering an area from an access track adjacent to the boundary of the Old Camp Farm mineral extraction and non hazardous waste landfill extension (not yet commenced) southwards towards the wood chipping and waste recycling and transfer area. This facility was granted planning permission in May 2002 (N.01.2802).
2.24 The existing composting facility covers of an area of 1.62 hectares with windrows running from east to west across the site. There is also a storage and sorting area. The total capacity of the composting facility is 32,000 tonnes per annum (tpa) and it currently processes approximately 30,000tpa of green waste.
Vehicle parking areas that serve the wider site
2.25 Vehicle parking is positioned behind the MRF and site offices to provide an area for Hills employees to park. The surface material consists predominantly of gravel.
Site haul roads and weighbridge area
2.26 The site haul road connects to the main site access road which in turn connects to the C15. The haul road runs along the western boundary of the application site and continues north along the boundary with Old Camp Farm mineral extraction and non hazardous waste landfill extension (not yet commenced). The weighbridge area is located adjacent to the MRF.
2.27 Table 2.1 sets out the key planning permissions that are in operation at the application site, whilst Figure 2 provides a summary of these operations.
Adams Hendry Consulting Ltd 8 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
Table 2.1 Relevant Planning Permissions
Facility / operation Planning Description of consented development Permission A MRF N962022 Environmental improvements & the B Landscaping Bund 27.03.1997 provision of a Materials Recovery Facility The end date for the MRF is on or before 31st December 2016. N.05.0731 Planning permission for the extension to 17.11.2005 the MRF to provide additional office space and welfare facilities. The end date for the MRF is on or before 31st December 2016. N0607018 Section 73 Application to extend the 10.11.2006 opening hours. Opening hours extended till 20.00 Monday to Friday and 13.00 on Saturdays. C Waste Wood / Inert N002627 Erection of Recycling Plant and the Industrial and 14.02.2001 Importation of Waste Material for Commercial Waste Recycling Purposes.
Recycling and Transfer Development shall be discontinued and
Facility land reinstated to its former condition on or before 16th February 2014
High Grade N012802 Change of use to a Compositing Facility D Compositing Facility 24.05.2002 and Ancillary Development. N033304 Planning application for the relocation of 25.03.2004 existing recycling & recovery facility and continued permitted use as a compositing. N/09/01498/WC Section 73 application to extend the hours M of operation for the composting facility 11.11.2009 F Weighbridge complex N/09/01499/WC Section 73 application to extend the hours M of operation
Adams Hendry Consulting Ltd 9 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
Adams Hendry Consulting Ltd 10 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
3 The Proposed Development
Overview of the Proposals
3.1 The existing Lower Compton Waste Management Facility provides essential waste recovery and disposal capacity for the management of a significant proportion of municipal waste arising in the Wiltshire area, and is equally important for waste produced by the industrial and commercial sectors.
3.2 The proposal Waste Recovery Facility (WRF) will enable Hills to continue to serve customer requirements, whilst providing capacity capable of fulfilling a long term role in the management of waste arising in, and imported for management in, the Wiltshire area.
3.3 The proposals will provide a total waste recovery capacity for the management of approximately 285,000 tonnes per annum (tpa) of non hazardous wastes from municipal, and industrial and commercial sources. In summary the proposals include:
. The extension and permanent retention of the existing municipal waste Materials Recovery Facility (MRF), and the provision of a municipal Waste Transfer Station (WTS). Combined, the two facilities will process approximately 120,000tpa; . The construction of a new permanent Industrial and Commercial Waste Materials Recovery and Transfer Facility, handling a combined throughput of 135,000tpa; . The provision of a new low grade open air windrow composting facility handling a throughput of up to 15,000tpa of green waste received by the municipal MRF, the infilling of the current compost leachate attenuation pond and provision of new compost leachate attenuation measures. Low grade compost produced will be used within the restoration layers for the adjacent landfill operations; . The relocation and continued operation of the existing wood chip recycling facility, at an approximate throughput of 15,000tpa, and . Reconfiguration of site infrastructure, the provision of landscaping and planting, the removal of 18 trees and provision of 190 new trees.
3.4 The locations of these elements are shown on drawing HILLS/1011-DWG-005 and 006.
3.5 The existing municipal MRF is located in the southern area of the application site and currently operates at a capacity of 36,000tpa, equivalent to 95% of its maximum design capacity. Condition 4 of the planning consent for the existing MRF (reference N.96.2022) requires that on or before 31st December 2016 it will be decommissioned and the land restored within 6 months of that date to the agreed restoration scheme.
3.6 These proposals seek the retention of the MRF and its extension northwards to include the provision of a Municipal Waste Transfer Station and increase the total tonnage handled in comparison with the existing facility.
Adams Hendry Consulting Ltd 11 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
3.7 The site will also accommodate a new permanent Industrial and Commercial Materials Recovery Facility and Waste Transfer Station (I&C MRF / WTS), which will enable industrial and commercial waste to be sorted and recovered in the form of waste derived fuel within a fully enclosed building. A storage and loading area is located to the east of this building.
3.8 In order to accommodate the extension to the Municipal MRF / WTS and the new I&C MRF / WTS the existing infrastructure and operations to the north of the existing MRF will be removed or relocated. The proposals include the removal of the existing car parking area and the high grade compositing operations area and the infilling of the compost leachate attenuation lagoon. The existing waste recycling and transfer facility and wood chipping operation will be relocated to the north of the I&C MRF/WTS. The new low-grade open air windrow compositing facility will also be located in this area of the site. Both operations are shown on drawing HILLS/1011-DWG-005 and 006.
3.9 The proposals would also include various changes to site infrastructure, including new drainage and rainwater harvesting provisions, hard standing, parking areas, access and circulation roads and weighbridges as necessary. These elements of the proposals are also shown on drawing HILLS/1011-DWG-005 and 006.
3.10 It is intended that the proposed development would use the existing consented hours associated with the receipt and processing or municipal and industrial and commercial wastes afforded to current operations at the application site. The proposed operating hours of the WRF for all types of waste would therefore be:
• Monday – Friday: 7am – 8pm • Saturdays: 7am – 1pm • Bank Holidays (not including Christmas Day, Boxing Day or New Years Day): 7am – 8pm
3.11 Further working hours will be required for the receipt of collected or bulked municipal wastes, including household wastes, comprising:
• Saturdays following Good Friday, Easter Monday, Early May Bank Holiday, Spring Bank Holiday, August Bank Holiday, and any other additional Bank Holidays issued in a given year: 7am – 8pm • The two consecutive Saturdays that immediately follow New Years Day: 7am – 8pm.
3.12 Extended Saturday and limited Sunday working is currently consented for the receipt of wastes from household recycling centres by the municipal MRF. To ensure this function can continue, the proposed WRF would also operate as follow:
• Saturdays: receipt of waste from household recycling centres – 1pm – 8pm • Sundays: receipt of waste from household recycling centres – 7am – 6pm
3.13 With the exception of the receipt of waste from household recycling centres, the facility will not operate on Sundays. No operations will take place on Christmas Day, Boxing Day or New Years Day.
Adams Hendry Consulting Ltd 12 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
The Municipal MRF & WTS
3.14 The existing MRF (shown on drawings HILLS/1011-DWG-003 and 004), which has been operational since 1997, will be extended northwards to increase the industrial floorspace by a further 3777m2 to a total industrial floorspace of 5761m2. The existing 329m2 of office space provided over three floors at the southern end of the MRF building will be retained in its current configuraton. The total floorspace of the MRF and WTS will be 6,090m2.
3.15 The height of the building would remain at 8.5 metres to its eaves, whilst its width would retain that of the current building of 41m for the main processing hall, widening to 46m for the offices and the transfer station drive through which forms part of the extension.
3.16 The extension would be constructed of the same materials including a steel frame structure, clad with steel and painted dark green. The roof would be constructed of the same plastic coated steel sheeting materials used on the existing building, coloured to match that existing on the current MRF.
3.17 The internal layout would include a one-way access route through the centre of the building with the entrance positioned on the northern elevation. Two exit points are proposed; one on the western elevation and the other on the southern elevation. Drawings HILLS/1011-DWG-007 and 008 show the proposed layout and elevation plans of the building.
3.18 The MRF operation is expected to operate up to a capacity of 45,000tpa, receiving, sorting, bulking and exporting collected recyclable materials sourced from municipal waste arisings in Wiltshire. The building will principally house mechanical and manual waste sorting systems. Municipal waste for sorting will be deposited in the northern end of the extended building. Once sorted bulked materials will be exported to appropriate off-site reprocessing facilities for recovery or recycling.
3.19 It is expected that the extended municipal MRF operation will be particularly efficient, due to the high level of pre-sorting of materials that takes place via kerbside collections, bring sites and HRCs prior to receipt at the MRF. However, it is anticipated that a proportion of the materials handled, up to 5% of the total process capacity, will not be suitable for recovery, for example through cross contamination with other waste materials. These materials, equating up to approximately 2,500tpa will be landfilled at the adjacent Lower Compton landfill facilities or, when these are fully restored, exported for disposal at a suitably licensed facility.
3.20 The Municipal WTS operation will receive approximately 75,000tpa of collected municipal wastes from Wiltshire which will be sorted and bulked to service three key operations:
(i) the export of green waste for off site high grade composting at Parkgate Farm, Purton; (ii) the export of processed municipal waste to provide feedstock for the Westbury Mechanical Biological Treatment facility (consented but still to be constructed), and (iii) the export of residual municipal wastes suitable for recovery under contract to the Lakeside Energy from Waste recovery facility in Slough.
Adams Hendry Consulting Ltd 13 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
3.21 Any green or residual municipal wastes handled by the combined MRF / WTS that are not suitable for recovery and export will be bulked up for disposal at the adjacent operational landfill facility, although this tonnage is expected to be very low.
3.22 It is envisaged that this facility will continue to employ the existing members of staff, and will also provide employment for an additional 8 members of staff.
3.23 Material storage areas are proposed to the west and east of the proposed municipal MRF / WTS building. The existing parking to the south east of the MRF, adjacent to the office area will be retained. Provision for new car parking will also be made to the west of the Municipal MRF/WTS for 49 spaces (see drawing HILLS/1011-DWG- 005).
The Industrial and Commercial MRF & WTS
3.24 The new industrial and commercial MRF / WTS building is proposed to be located to the north of the municipal MRF / WTS. The building has been designed to have a staggered mono-pitch roof, which will be 11.5 metres high to its eaves on the Western mono-pitch and 8.5m to eaves on the Eastern monopitch. The building will provide an approximate industrial floorspace of 3385m2. The building will also include an integral 3 storey office and mess facility with an approximate combined floorspace of 467m2. The total floorspace to be provided by the industrial and commercial MRF / WTS building will be 3,852m2.
3.25 The building would be constructed of the same materials as the municipal MRF / WTS, comprising of a steel frame structure, clad with steel and painted dark green. The roof would also be constructed of plastic coated steel sheeting materials used on the existing municipal MRF building, coloured to match.
3.26 The building will principally house mechanical and manual waste sorting systems. The internal layout includes a one-way access route through the centre of the building, with the entrance on the southern elevation and the exit on the northern elevation. The proposed layout and elevation plans are shown on drawings HILLS/1011-DWG-009 and 010.
3.27 Industrial and commercial wastes handled by the MRF / WTS would be subjected to a series of screens and shredders to remove any inert fractions and any bulky and oversized materials. The remaining materials would then be subject to further sorting to remove further recoverable materials, such as metals, wood and cardboard. The final materials will then be shredded to produce a solid refuse derived fuel product. Other products from this process will include recovered materials such as metal, wood and cardboards, and inert materials such as soils and hardcore. A fourth by product from the process will be the residual waste fraction.
3.28 Recovered wastes in the form of solid refuse derived fuel will be bulked up, baled, wrapped and exported for treatment off site at suitably licensed waste recovery facilities. Other recovered materials will also be bulked up for export and further recovery. As with the municipal MRF / WTS, any residual wastes that cannot be recovered, which are forecast to comprise 35% by weight of wastes handled, will, for the duration of on site landfilling operations, be disposed of at the adjacent landfill facilities. Upon closure of the landfill, such wastes would be exported for disposal at a suitably licensed facility.
Adams Hendry Consulting Ltd 14 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
3.29 To the east of the building will be a storage yard and baled product loading area. In addition to the car parking provisions associated with the municipal MRF / WTS, a further 21 car parking spaces will be located directly to the west of the industrial and commercial MRF / WTS building as shown on drawing HILLS/1011-DWG-005. The industrial and commercial MRF / WTS will provide employment for up to 11 additional staff.
Low Grade Composting
3.30 As shown on drawing HILLS/1011-DWG-005, land to the north of the industrial and commercial MRF / WTS will accommodate a small scale low grade open air windrow composting operation, which will handle up to 15,000tpa of green waste sourced from municipal collections and transferred from the extended municipal MRF / WTS building.
3.31 This facility is being provided primarily for the purposes of producing material for use within the restoration layers of the adjacent operations taking place within the wider Lower Compton waste management facility. Once landfill operations at Lower Compton have ceased, this facility will also cease operations, and its tonnage will be diverted for composting as part of the wider green waste throughput.
3.32 The low grade composting operations will be located onto retained sections of the existing composting pad in the north of the application site, which will include some amendments to incorporate suitable surface and dirty water drainage provisions. In particular, attenuation measures will be provided in the south west corner of the composting pad to accommodate the required volume of leachate forecast to be produced by the compost operation. This attenuation will either comprise a surface level attenuation pond or a below ground storage tank, and its location is shown on drawing HILLS/1011-DWG-005. The existing compost leachate attenuation pond located within the application site, as shown on drawings HILLS/1011-DWG-003 and 004, will be drained, infilled and leveled for use as car parking.
3.33 The composting operation will require the use of an elevated compost turner and a loading shovel and will employ existing staff associated with current composting operations.
Waste Wood Recycling
3.34 At present, a waste recycling and transfer facility (drawing HILLS/1011-DWG-003) operates on the site handling 25,000tpa of inert industrial and commercial wastes and waste wood. This material is most frequently delivered in skips.
3.35 The proposals seek to relocate and permanently retain the woodchip recycling element of this facility to the north of the proposed industrial and commercial MRF / WTS building, alongside the proposed low grade MSW green waste composting operation, as shown on drawing HILLS/1011-DWG-005. Approximately 80% of the wood waste is generally recovered for re-use off site and this is expected to continue. The wood waste would be disposed of at the adjacent landfills or at suitably licensed facilities.
Adams Hendry Consulting Ltd 15 August 2011 Lower Compton Waste Recovery Facility HILLS/1011 Hills Waste Solutions Ltd Planning Application Supporting Statement
3.36 The handling of inert type material will take place within the new industrial and commercial MRF / WTS building as part of the overall estimated 135,000tpa throughput for that facility.
3.37 The relocated woodchip recycling facility will continue to process approximately 15,000tpa of wood waste materials. The operations will comprise a wood chipper and typically one loading shovel for handling both inputs and recycled products. Vehicles delivering loads to this operation will gain access from the south of the industrial and commercial MRF / WTS building before following a route to the north along the eastern edge of the site.
3.38 Access will be provided at the south east corner of the recycling and composting pad, as shown on drawing HILLS/1011-DWG-005 and loads will enter the recycling / chipping area and deposit their loads as directed. Materials will be sorted and graded by hand and by loading shovel prior to processing by the wood chipper. Recovered materials will be stockpiled on the recycling pad prior to loading for export. Loads for export will follow the same route before exiting the operation via the site exit to the north west of the industrial and commercial MRF / WTS building. It is expected that the facility will continue to employ existing staff as per current operations.
Ancillary Operations
3.39 All vehicles associated with the proposed development will gain entry to the Lower Compton site from the current access adjoining a mini-roundabout with the C15. The C15 will continue to be the means of gaining access to the site from the nearby A4. No other route into or out of the site will be available for waste haulage vehicles. The main access point from the mini-roundabout, as shown on drawing HILLS/1011- DWG-005, will be improved through minor adjustments. This will enable vehicles to negotiate this bend and improve driver visibility in both entry and exit directions.
3.40 Other improvements to the site access road include the widening of the access from its point adjacent to the southern entrance to the existing HRC through to a new exit point from the extended municipal MRF / WTS building (drawing HILLS/1011-DWG- 005). This widening will be sufficient to accommodate a third vehicle lane. As such, there will be two lanes at the sitesʼ main entrance, which shall widen to incorporate a second vehicle entrance lane travelling north into the main waste management site. Implementation of this work will require revisions to the layout of the site access and to the bund in this area, as shown on drawing HILLS/1011-DWG-005.
3.41 General site circulation shall remain similar to existing with certain improvements to accommodate vehicle circulation required within the waste recovery facilities, and to improve the management of vehicle queuing from all waste operations on site. With two lanes providing access for waste deliveries into the site, waste recovery loads will be initially marshaled alongside deliveries to the landfill facilities. The existing weighbridges and office will be retained, with the current outbound weighbridge configured to process inbound vehicles as well. A new weighbridge will be provided as part of the new exit from the municipal MRF / WTS.
3.42 As vehicles continue north from the weighbridge, on-site signage will direct loads to their recipient facilities. If required, banksmen will ensure efficient traffic circulation and delivery of loads to the correct facility. Landfill loads will continue along the site haul road northwards to the landfill cells at Low Lane or Old Camp Farm, or, post
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restoration of Old Camp Farm, westwards into the final disposal cells associated with Lower Compton landfill.
3.43 Deliveries to the new waste recovery facilities will also journey north before being directed into the waste recovery facility to the north of the car park and the municipal MRF / WTS building. From here, vehicles will be managed according to their load. All exports, either to landfill or off site will exit the site by following the site circulation road north towards the composting and recycling pad before traveling west to joining the site haul road and outward flow of site traffic.
3.44 Staff and visitors cars will follow the site haul road north of the weighbridge prior to entering the waste recovery facility area. From here they will be directed via on site signage to on site car parking.
3.45 The site access, haul road improvements, weighbridge relocation, additional exits and weighbridge and new entrance lane will enable the efficient management and marshalling of all waste delivery and export traffic. It will allow for waste traffic to access the site without any conflict with mineral operations being undertaken on site and will provide an important means of alleviating vehicle queuing adjacent to the public HRC. It will also allow for the existing fleet vehicle operations and parking situated to the north of the HRC to operate more efficiently without conflict with public vehicles or with waste deliveries into the site. The existing speed hump located on the site access road will be removed in the interests of controlling amenity impacts.
Drainage and Surface Water Management
3.46 Preparation of the development proposals, and discussions with the Environment Agency, have included consideration of the existing site drainage measures and the future requirements associated with the development of the WRF. Existing drainage is provided by a drainage ditch that runs between the site haul road and the western edge of the current MRF and composting operations and which discharges into existing water courses to the south of the landscape bund.
3.47 In addition, a compost leachate attenuation pond is locate to the north west of the existing MRF. This collects dirty water run off from the composting and woodchip area, which is pumped to the landfill leachate treatment plant or, if sufficiently clean, is pumped to a groundwater sump from where it is discharged.
3.48 The proposed WRF development requires the removal of this attenuation pond and, to ensure there is adequate management of surface water, the provision of the following new drainage measures:
• Either a surface level leachate attenuation pond or below ground leachate attenuation tank for the low grade compost operations. As at present, this will either discharge to the landfill leachate treatment plant, or to a groundwater sump. • A new surface water attenuation pond for the management of surface water flows from the remainder of the WRF development. This pond will be located to the south of the landscape bund and will be fed by flows via the existing on site drainage ditch. Attenuated flows will be managed and discharged to existing water courses to the south of the new pond, in line with current discharge arrangements.
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3.49 Drawing HILLS/1011-DWG-005 shows the location of these proposed drainage details.
Landscape scheme for the application site
3.50 In designing the proposed WRF consideration has been given to the provision of a landscaping scheme that will allow for the development to be implemented with minimum impact upon its surroundings and will fully integrate with the ongoing restoration of the adjacent landfill facilities. These considerations are reported in full in the Landscape and Visual Impact Assessment provided in Chapter 12.
3.51 The provisions of the landscaping scheme are shown on drawing HILLS/1011- DWG-012. Figures 3, 4 and 5 (Appendix 1) contrast these details, and those of the proposed WRF as cross sections through the development site and the adjacent future restored landfilling area to the west of the site.
3.52 The landscape proposals will make full use of the existing landscape screening bund to the east of the current operations. This bund will be retained and enhanced to ensure that the proposed built development is screened and integrated into the surrounding environment. In particular, a new tree belt with understorey planting will be implemented on this bund to allow for sufficient vegetation growth to screen views into the site from the south east and east. It will also provide an improved landscape setting to the North Wessex Downs AONB.
3.53 These works will require some localised excavation of the existing materials within the bund to deepen both the top and sub-soils available to ensure successful plant establishment. Any wastes from this operation will be landfilled at the Lower Compton landfill facilities, and any new soils and materials are expected to be obtained from sources on site. Drawing HILLS/1011-DWG-013 provides further details of these works.
3.54 A combination of tree and shrub planting is also proposed within the application site to reinforce the existing planting and to replace planting that will be removed to facilitate the proposed development.
Amenity Controls, Site Management and Regulation
3.55 The main generator of dust on site will be from vehicles using the internal haul roads. To ensure that dust is not blown up by vehicles traversing the site, haul roads will be dampened down in very dry conditions. The generation of dust from the deposit of waste will be minimised as the majority of inputs (255,000tpa of the total 285,000tpa) will be deposited within one of the MRF / WTS buildings.
3.56 Dust generated by the deposit of green wastes and wood wastes on the processing pad in the north of the site will be minimised by tipping close to the level of the pad and reducing the height from which waste falls.
3.57 Disturbance to the surrounding area due to noise emanating from the site will be controlled through the implementation of good working practices and the fitting of vehicle exhausts with silencers. Key items identified through the proposed noise and vibration mitigation include the retention of the existing screening bund.
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3.58 Whilst site lighting will be kept to a minimum lighting will be required for health and safety reasons. During hours of darkness the site will continue to receive deliveries of waste for processing within the MRF / WTS buildings and lights will therefore be necessary. Security floodlighting has therefore been designed to be put in place around the two main process buildings, as shown on drawing HILLS/1011-DWG- 014. Lighting will also be required to illuminate the new vehicle parking areas.
3.59 The new lighting will only cover the new areas of the site, with the existing floodlighting provided for the current MRF building continuing to light current yard areas. Due to the close proximity of the North Wessex Downs AONB the new lighting will be full cut-off in design so that no light is emitted directly into the sky. The proposed lights will be mounted as low as possible on the buildings, whilst still achieving the required illumination levels and minimising the number of columns required. For the lighting columns provided along the eastern side of the site, these will be at a height of 5m to ensure that they are below the height of the screening bund.
3.60 Litter emanating from the site will be controlled through the use of litter picking teams. To ensure that no litter escapes from vehicles entering or leaving the site all vehicles will be required to have their load areas sheeted, sealed or enclosed. Mud and extraneous materials will be prevented from being carried on to the public highway through the use of wheel washing where required. Flies and vermin will be controlled at the site by a regular management programme.
3.61 The proposed WRF will require a separate permit under the Environmental Permitted Regulations, which is administered by the Environment Agency. Hills anticipate that this process will be undertaken once planning consent for the development is secured.
Operations to be Removed
3.62 The existing high grade green waste composting operations (drawing HILLS/1011- DWG-004) are due to be removed from the Lower Compton site following the implementation of composting operations at Hills Parkgate Farm waste management facility near Purton. The Purton facility is consented to handle up to 25,000tpa of green waste and is currently under construction. Once the Purton facility is operational and high grade composting at Lower Compton ceases operation, the remaining hardstanding at the application site will be prepared for the implementation of the proposed development.
3.63 It is expected that the industrial and commercial MRF / WTS, the low grade composting operation and the woodchip recycling operations will be able to make full use of retained surface hardstandings.
Construction of the Proposed Development
3.64 Construction of the WRF would, subject to consent, take place between 2012 and 2013, and would be phased to ensure that the ongoing operation of the existing, retained facilities at this site can continue.
3.65 The main activities of site clearance, groundworks, delivery of construction materials and process plant, the erection of the new facilities and planting to the landscape bund is anticipated to take place during the first 6 months of the construction period.
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Thereafter, a period of mechanical and electrical engineering and installation will be required prior to the commissioning and operation of the facility.
3.66 The construction works will generate traffic in the form of deliveries to the site by HGVs and low loaders and also through construction worker journeys in cars and vans. It is not expected that any significant amount of material would leave the site during construction. Construction workers will park their cars both in existing parking areas and within the construction site area itself.
3.67 The most significant volumes of construction materials will be associated with the delivery of major items of plant and materials for the main process building structure. Transportation of materials will be via the A4 and onto the A3102 direct to the site. At this stage, abnormal loads are not anticipated.
3.68 During construction there will be a need for temporary accommodation and storage facilities for contractors, plant and materials. It is expected that mess facilities for contractor staff will be provided within the existing MRF building, and that construction compound will be provided within the construction area itself so as to minimise land take and disturbance to ongoing waste management operations. Drawing HILLS/1011-DWG-015 illustrates the area to be utilised during construction.
3.69 Topsoil storage mounds will be no greater than 2m in height and subsoil mounds no greater than 5m. The storage of materials will be kept as low as possible and no higher than the adjacent landscape bund. The following are expected to be required for the works construction compound:
• 5 site cabins / lock up containers of approximate dimensions 40ft x 12ft • an area of materials laydown of approximately 30m x 30m for the storage of loose materials such as pipes, blockwork, steel sections and rebar • an area for the parking of up to 12x cars and vans and the holding of 4x HGVs during the unloading / loading of deliveries • all contractor cabins are to be single storey and of a visually recessive colour to ensure that the visual impact is minimised. • the compound area is to be lit with all lighting columns positioned to be as low as possible and directional.
3.70 It is expected that the construction of the WRF will be phased, commencing with works associated with the municipal MRF / WTS operations and ancillary infrastructure before progressing on to the industrial and commercial MRF / WTS. Table 3.1 sets out the likely timescales for the development:
Table 3.1 Construction Stages
Stage Description Duration Groundworks Drainage of attenuation pond, clearance and 1 month: April 2012 stabilisation prior to infill of pond, levelling of assumed surface area; treatment to inside of landscape bund to protect during construction; provision of tree protection measures where required; planting to eastern face of landscape bund; works to existing MRF building for preparation for extension including the extension of foundations; setting out of compound area; removal of
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Stage Description Duration residual debris from compost pad and preparation of pad / extension of pad area for development works. Main Erect extension to existing MRF building; 15 months: May construction construction of new I&C process building; 2012 – July 2013 implement adjustments to site haul roads, assumed weighbridges, vehicle marshalling areas, parking facilities. Install site drainage provisions and new compost / waste recycling and transfer areas. Install new process equipment into facility buildings. Begin removal construction compound provisions. Commissioning Testing and start up of all plant. Complete 6 months: May – removal of site compounds October 2013 assumed Operations Full processing of waste begins November 2013 commence assumed Landscape Planting of trees and understory vegetation During first proposals to available planting bund season Landscape Planting within the working area to be completed. No later than first proposals planting season internal to site following completion of all construction and commissioning works
3.71 Based upon the above schedule, the following indicative plant has been assumed, although the exact construction methodology will be confirmed by the appointed principal contractor:
. Two excavators; . One bulldozer; . Two dumpers; . Two mobile tower cranes with a maximum operational height of approximately 30 metres; . One concrete mixer utilising on site concrete supplies . Soldering equipment . Lighting rigs . Two generators
3.72 As it is intended to construct the development through the use of floating foundations, utilising the gault clay that underlies the site, there will not be a need for any piling operations to be carried out. This is consistent with the construction methodology used to build the existing MRF building and its current extension.
3.73 It is envisaged that construction works will take place between Monday – Friday (08:00am – 18:00pm) and Saturday (08:00am – 13:00pm). Due to the range of civil, mechanical and electrical engineering works required, the volume of construction traffic will vary throughout the construction programme.
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3.74 Should there be a need for extended working hours these will be agreed in advance to ensure that appropriate measures are in place to mitigate any disruption to local residents.
3.75 Commissioning of the new facility will be taken on the basis of a typical working day as proposed for the operation of the facility, that being between the hours of 07:00 – 20:00 Monday to Friday, and 07:00 – 13:00 on a Saturday.
3.76 The construction process will be undertaken in accordance with a Construction Environmental Management Plan (CEMP), which will set out the measures to be employed during the construction process to secure sustainable and responsible delivery of the development. The CEMP will be prepared by the appointed contractor following the grant of consent for the development.
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4 Relevant Planning Policy
Introduction
4.1 The Planning and Compulsory Purchase Act (2004), Section 38(6) sets out the need for planning applications to be determined in accordance with the Statutory Development Plan unless material considerations indicate otherwise. This section of the Planning Statement provides a summary of the planning policies relevant to the scheme.
Development Plan Framework
4.2 The statutory development plan, against which the planning application for the proposal has to be considered, consists of the following:
• Regional Planning Guidance for the South West (RPG10) (September 2001). • Wiltshire and Swindon Structure Plan 2016 (adopted 2006) (Saved Policies). • Wiltshire and Swindon Waste Core Strategy 2006-2026 Development Plan Document (June 2009). • Wiltshire and Swindon Waste Development Control Policies Development Plan Document (September 2009). • North Wiltshire Local Plan 2011 (Saved policies).
4.3 Other regional and local policy documents that have been considered include:
• Emerging Regional Strategy for the South West (South West Plan). • Third Transport Local Plan 2011-2026 (March 2011) (including the Freight Strategy) • Wiltshire Core Strategy Development Plan Document (in preparation) • Wiltshire and Swindon Waste Site Allocations Development Plan Document (in preparation)
4.4 The development plan, together with European and Government policy on sustainable development, national Planning Policy Guidance (PPGs) Notes and Statements (PPSs), and other statutory and non-statutory guidance documents have been used to inform the detailed proposals, and to assess the adherence of the scheme to planning policy.
European and National Policy
4.5 The following national legislation, policy and guidance are relevant to Lower Compton MRF proposals:
Directive 2008/98/EC on waste European Legislation on waste Directive 99/31/EC on the landfill of waste European Legislation on the landfill of waste The Waste Regulations 2011 Regulations of waste for England and Wales. Waste Strategy 2007: The Governmentʼs waste
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strategy for England Planning Policy Statement 1: Delivering Sustainable Development Planning and Climate Change: Supplement to Planning Policy Statement1 Planning Policy Statement 5: Planning for the Historic Environment Planning Policy Statement 7: Sustainable Development in Rural Areas Planning Policy Statement 9: Biodiversity and Geological Conservation Circular 06/05: Biodiversity and Geological Conservation Planning Policy Statement 10: Planning for Sustainable Waste Management Planning Policy Guidance 13: Transport Planning Policy Statement 22: Renewable Energy Planning Policy Statement 23: Planning and Pollution Control Planning Policy Guidance 24: Planning and Noise Planning Policy Statement 25: Development and Flood Risk Planning Policy Statement 25: Development and Flood Risk Practice Guide
4.6 The 2008 Waste Directive (2008/98/EC) provides the basis for waste management in the EU Member States. Its fundamental aim is to protect human health and the environment from the negative impacts of waste generation and management. The Directive introduces the waste hierarchy as a key principle, which identified a priority order for the ongoing management of all waste of prevention, followed by re-use, then by recycle followed by recovery of value, in preferences to disposal.
4.7 When applying the waste hierarchy, Article 4 states that “Member states shall take measures to encourage the options that deliver the best overall environmental outcome. This may require specific waste streams departing from the hierarchy where this is justified by life-cycle thinking on the overall impacts of the generation and management of such waste”.
4.8 In respect of waste management, the Article 13 of the 2008 Directive also requires Member States to: “take the necessary measures to ensure that waste management is carried out without endangering human health, without harming the environment and, in particular:
a) without risk to water, air, soil, plants or animals; b) without causing a nuisance through noise or odours; and c) without adversely affecting the countryside or places of special interest”
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4.9 The 2008 Directive encourages Member States to take measures to establish an integrated and adequate network of waste disposal installations for the recovery and re-use of waste. Member States should support the use of recyclates in line with the waste hierarchy and the aim of a recycling society, and should not support the landfilling or incineration of recyclates whenever possible (paragraph 29).
4.10 Recovery operations should be undertaken in accordance with Article 4 and 13 of the Directive. To facilitate improved recovery, waste should not be mixed with other waste or materials of different properties and should be collected separately if technically, environmentally and economically practicable (Article 10).
4.11 Article 11 identifies that in order to comply with the objectives of the Directive and move towards a European recycling society with a high level of resource efficiency, Member States shall take the necessary measures designed to achieve the following targets:
(a) “by 2020, the preparing for re-use and the recycling of waste materials such as at least paper, metal, plastic and glass from households and possibly from other origins as far as these waste streams are similar to waste from households, shall be increased to a minimum of overall 50% by weight; (b) by 2020, the preparing for re-use, recycling and other material recovery, including backfilling operations using waste to substitute other materials, of non- hazardous construction and demolition waste excluding naturally occurring material defined in category 17 05 04 in the list of waste shall be increased to a minimum of 70% by weight” (Article 11).
4.12 Article 22: ʻBio-Wasteʼ identifies that Member States should take measures in accordance with Article 4 and 13 to encourage the separate collection of bio-waste with a view to the composting and digestion of bio-waste (Article 22 – Bio-waste).
4.13 The proposals include the provision of a new low grade open air windrow composting facility that will handle up to 10,000tpa of green waste sourced from municipal collections and transferred from the extended MRF building. It will also facilitate the ongoing supply of green waste for composting at the applicantsʼ Parkgate Farm composting facility.
4.14 The proposed development has therefore been designed in direct response to each of the requirements of the Directive listed above. The extended and new capacity will facilitate the increased separation of recoverable materials for supply to the recycling, composting and energy recovery markets, and will lead to a reduction in the quantity of waste landfilled, both at landfill voids adjacent to the application site and in a general sense. In so doing, the facility will play a key role in promoting the management of waste in Wiltshire in a way that places greater emphasis on management methods higher up the waste hierarchy.
4.15 Furthermore, through the assessments of this EIA, and the analyses of the technical planning documents, the design of the proposals has been iterative, responding to the results of assessment work, and consultation, to prepare proposals that provide for the delivery of sustainable waste management capacity that accords with Article 13 of the 2008 Directive.
4.16 The Council Directive on the Landfill of Waste (1999) (99/31/EC) introduced important requirements for the management of waste including the need for
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Members States to set up a national strategy to reduce biodegradable waste going to landfills. The Directive also introduced a ban on certain wastes no longer considered acceptable to go to landfill and specific controls that further restrict the manner in which waste can be disposed of and where.
4.17 It further introduced the need for the pre-treatment of wastes prior to their final disposal to landfill so as to reduce the quantity of recoverable wastes that are avoidably sent to landfill. It divides the landfill facilities into one of three classes: landfill for hazardous waste; landfill from non-hazardous waste. Article 5 of the Directive sets out targets for reducing the amount of biodegradable municipal waste going to landfill.
4.18 The Waste (England and Wales) Regulations 2011 (S.I 2011 No. 988) are likely to have an impact on businesses that produce and are involved in handling and managing waste. Regulation 12 (comes into force on 28 September 2011) sets out duties for those involved in waste management to take reasonable measures to apply the waste hierarchy as a priority order:
“(a) prevention (b) preparing for re-use (c) recycling (d) other recovery (for example energy recovery) (e) disposal”
4.19 When applying the waste hierarchy, options that deliver the best overall environmental outcome will be encouraged, which may allow for a departure for the priority “…where this is justified by life-cycle thinking on the overall impacts of the generation and management of waste” (Regulation 12).
4.20 When considering the overall impacts the following must be taken into account:
“the general environmental protection principles of precaution and sustainability; technical feasibility and economic viability; protection of recourses; the overall environment, human health, economic and social impacts”
4.21 Regulation 7 requires that there is at least one plan containing polices in relation to waste management in England. Plans must conform to the strategy for the reduction of biodegradable waste going to landfill, policies that promote measures to encourage high quality recycling, including separate collections of waste where technically, environmentally and economically practicable, encourage the separate collection of bio-waste with a view to the composting and digestion of bio-waste and promote the re-use of products and preparing for re-use.
4.22 The Governmentʼs vision for sustainable waste management for the period up to 2020 is set out in the Waste Strategy for England (2007). The central message of the Waste Strategy 2007 is “less waste, more material recovery, energy from waste and much less landfill” (Figure E1).
4.23 The Waste Strategy sets higher national targets for the recycling of household waste and the recover of municipal compared to the 2000 strategy. Targets for commercial and industrial waste include a 20% reduction from 2004 levels by 2010.
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4.24 The Government has identified key waste materials where diversion from landfill could realise significant environmental benefits. These include paper, food, glass, aluminum, wood, plastic and textiles. In order to achieve more efficient recovery of materials and energy, the Waste Strategy advocates increased segregation and sorting of waste at (or close to) its source by households and businesses. This requires planning for and investment in infrastructure for the collection, sorting, reprocessing and treatment of waste, by local authorities, business and the third sector (paragraph xxiv).
Regional Planning Policy
4.25 Regional planning policy consists of Regional Planning Guidance Note 10 (RPG10) for the South West adopted in September 2001. It identifies a need for a step change in waste management within the south west in order to move away from the historic dominance of sending waste to landfill. RPG10 policies that are relevant and have informed the proposals include:
Policy VIS 1: Expressing the vision Policy VIS 2: Principles for Future Development Policy VIS 3: Achieving the Vision Policy SS1: Regional Spatial Strategy Policy SS2: Regional Development Strategy Policy SS3: The Sub-Regional Strategy Policy SS19: Rural Areas Policy SS20: Rural Areas (including Urban Fringe) Uses Policy EN1: Landscape and Biodiversity Policy EN2: Air Quality Policy EN3: The Historic Environment Policy EN4: Quality in the Built Environment Policy TRAN1: Reducing the Need to Travel Policy TRAN2: Strategic Inter-Urban and Inter-Regional Transport Networks Policy TRAN 6: Movement of Goods Policy TRAN 7: The Rural Areas Policy RE1: Water Resources and Water Quality Policy RE2: Flood Risk Policy RE5: Management and Transportation of Waste
Local Policy – Identification of Relevant Policies and SPD
4.26 The Wiltshire and Swindon Structure Plan was adopted in April 2006 and covers the period until 2016. The Structure Planʼs strategy for waste includes reducing the volumes of waste requiring disposal by minimizing the production of waste and maximising the re-use of materials and the recycling of household, commercial, industrial and construction waste. The overall aim is to move waste up the hierarchy. Relevant policies contained in the Structure Plan are listed below:
Policy DP1 Sustainable Development Policy DP3 Development Strategy Policy DP9 Reuse of Land and Buildings Policy T8 Transport Provision for New Development Policy T9 Freight Transport Policy C1 Nature Conservation Policy C3 Nature Conservation
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Policy C5 The Water Environment Policy C8 Areas of Outstanding Natural Beauty Policy C13 Land Restoration Policy HE3 Parks and Gardens Policy HE6 Landscape Setting Policy W1 Reducing, Re-using and Recovering Waste Policy W2 Provision of Recycling and Recovery Facilities Policy W4 General Environmental Criteria
4.27 The Wiltshire and Swindon Waste Core Strategy was adopted in July 2009 and provides the strategic policy framework for the management of waste until 2026. Relevant policies contained in the Waste Core Strategy are listed below:
Policy WCS1 The Need for Additional Waste Management Capacity and Self Sufficiency. Policy WCS2 Future Waste Site Locations Policy WCS3 Preferred Locations of Waste Management Facilities by Type and the Provision of Flexibility Policy WCS4 Safeguarding Waste Management Sites Policy WCS5 The Wiltshire and Swindon Waste Hierarchy and Sustainable Waste Management
4.28 The Wiltshire and Swindon Waste Development Control Polices DPD was adopted in September 2009 and contains land use policies for determining planning applications. Relevant policies contained in the Waste Development Control Polices DPD are listed below:
Policy WDC1 Key criteria for ensuring sustainable waste management development Policy WDC2 Managing the Impact of Waste Management Policy WDC3 Water Environment Policy WDC7 Conserving Landscape Character Policy WDC8 Biodiversity and Geological Interest Policy WDC9 Cultural Heritage Policy WDC11 Sustainable Transportation of Waste
4.29 The North Wiltshire Local Plan was adopted in 2006 and covers the period until 2011. The Planʼs vision is to improve North Wiltshire through sustainable development. Relevant ʻSavedʼ policies include:
Policy C1 Sustainability Core Policy Policy C3 Development Control Core Policy Policy NE4 Areas of Outstanding Natural Beauty Policy NE7 Nature Conservation of Local Importance Policy NE9 Protection of Species Policy NE11 Conserving Biodiversity Policy NE14 Trees, Site Features and the Control of New Development Policy NE15 The Landscape Character of the Countryside Policy NE17 Contaminated Land Policy NE18 Noise and Pollution Policy HE3 Historic Parks and Gardens Policy T2 Transport Assessment & Travel Plans
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Emerging Planning Policy and Other Relevant Material Considerations
4.30 In addition to the adopted development plan policies described above, the following emerging planning policy documents have been reviewed and considered:
• Draft Regional Spatial Strategy (South West Plan) - Secretary of Statementʼs Proposed changes (October 2008) (Draft RS, 2008) • Emerging Wiltshire and Swindon Waste Site Allocations DPD • Emerging Wiltshire LDF Core Strategy and other Development Plan Documents
4.31 The following other material policy and strategy documents, have been reviewed and considered:
• The Wiltshire Third Transport Local Plan (2011) • Wiltshire Joint Municipal Waste Management Strategy 2006
4.32 The Draft South West Regional Spatial Strategy (RSS) was submitted to the Government in April 2006 and was open for public consultation until the end of August 2006. The public examination took place in between April and July 2007. The Secretary of State published the Proposed Changes to the South West Regional Strategy on 22 July 2008; public consultation on these amendments ran until 24 October 2008.
4.33 Since then, the Coalition Government, newly elected at May 2010, announced their firm intention to introduces changes to statute that would result in the revocation of all RSSs, with the sole exception of the London Plan. Consequently, no further progress has been made and the South West RSS is still in draft format.
4.34 The weight that should be attached to the policies in the emerging RSS also need to considered in the context of the outcomes of the recent legal challenges by the house builder Cala Homes (south) Ltd against the Governmentʼs intention to revoke RSSs. There have been a series of hearing, counter statements and appeals between Cala Homes and the Government, with the most recent outcome at May 2011 advising that the intention to abolish RSSs could be a material planning consideration in making development control decision, but cannot play the same role in the preparation of development plan policy.
4.35 Notwithstanding this ensuing confusion, one of the key provisions of the South West RSS, its data and identification of waste apportionment requirements for the diversion of waste from landfill, have been confirmed as remaining as a of relevance to the ongoing preparation of waste policy and waste site allocations. Wiltshire Council have also indicated that these data and apportionments remain a material consideration for the policy making and decision making processes.
4.36 With regards to the wider policies of the draft South West RSS, the material weight to be accorded to those provisions continues to be affected by uncertainty. In the light of the recent Court ruling, and mindful that, at the time of submitting this planning application RSS policy, draft or otherwise, may equally be attributed material weight in development control decisions as much as the Governmentʼs decision to revoke the RSS system, an analysis and assessment of the relevant policies of the draft South West RSS has been undertaken below and applied to the development proposals.
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4.37 The draft RSS identifies that “managing waste is one of the greatest challenges facing the region over the period of the RSS” (paragraph 7.4.1). Drawing on the Regional Waste Strategy: ʻFrom Rubbish to Resourceʼ (2004), the South Westʼs approach to waste is to “minimise the amount of waste produced in the region, and then to make a major shift away from the current reliance on landfill of untreated waste, so that by 2010 less than 20% of waste produced in the region will be landfilled” (paragraph 7.4.1). Relevant policies contained in the emerging RSS include:
Policy SD1 The Ecological Footprint Policy SD2 Climate Change Policy SD3 The Environment and Natural Resources Policy SD4 Sustainable Communities Policy CCS The Core Spatial Strategy Development Policy D Infrastructure Policy RTS4 Freight and the Primary Route Network Policy ENV1 Protecting and Enhancing the Regionʼs Natural and Historic Environment Policy ENV2 Landscape Character Area Policy ENV3 Protected Landscapes Policy ENV4 Nature Conservation Policy F1 Flood Risk Policy RE6 Water Resources Policy RE9 Air Quality Policy W1 Provision of Waste Sites Policy W2 Waste Facilities and the Waste Hierarchy
4.38 Wiltshire County Council is in the process of preparing its Wiltshire Core Strategy which will set out the overarching strategic polices and objectives. The Wiltshire Core Strategy will cover the whole of Wiltshire, including the former Salisbury District Council, North Wiltshire District Council. Kennet District Council and West Wiltshire District Council area. When adopted the Core Strategy, will replace the South Wiltshire Core Strategy, which is at a more advanced stage of preparation. Previous work carried out on the former district areas will be built upon in the preparation of the WCC CS.
4.39 Wiltshire Council are currently consulting on the Proposed Submission Draft of the Wiltshire and Swindon Waste Sites Allocations DPD. Once adopted, the Site Allocations DPD will form part of the Wiltshire and Swindonʼs Local Development Framework, the document identifies a range of sites and areas that are the preferred locations to be safeguarded for future waste uses. The anticipated date of adoption is not expected until 2012.
4.40 The draft Site Allocations DPD sets out the waste capacity for municipal, Industrial and Commercial and inert waste as at 2006, taking account of the additional permitted waste management capacity in Witlshire and Swindon between 2006- 2010. The draft DPD shows the site boundaries that will be safeguarded for waste management purposes. The DPD includes the application site (labeled as the Hills Resource Recovery Centre, Compton Bassett), the site assessment indentifies ʻkey issues and mitigation measuresʼ.
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4.41 The Third Local Transport Plan (LTP3) covers the period form March 2011 to March 2026 and seeks to address and support the national transport goals set out in the Department for Transportʼs ʻGuidance on Local Transportʼ (July 2009) and the January 2011 White Paper ʻCreating Growth, Cutting Carbon: Making Sustainable Local Transport Happen.
• Support economic growth • Reduce carbon emissions • Promote equality of opportunity • Contribute to better safety, security and health; and • Improve quality of life and healthy natural environment. • (White Paper ʻCreating Growth, Cutting Carbon: Making Sustainable Local Transport Happen, January 2011). • Offering people sustainable transport choices, particular for shorter journeys, that will stimulate behavioural change; and • Demonstrating how locals and the big society can work for transport.
4.42 There are four supporting strategies that also make up the LTP3: car parking; freight; public transport; and road safety. The Freight Strategy explains that ʻa balance has to be found between the efficient distribution of freight and the effect that this distribution has on society it servesʼ (paragraph 1.2). Within Wiltshire a majority of freight distribution is made by road and this is likely to remain for the foreseeable future (paragraph 1.3).
4.43 Core Strategies guide new development towards the most appropriate locations and provide polices which projects will be assessed against. Paragraph 1.7 advises that alignment with the freight strategy is an important consideration and the ability of the local road network to accommodate development that generates or attracts freight traffic is a compelling factor in determining if proposals are appropriate. However, paragraph 1.8 explains that although the planning and policy of the transportation of minerals and waste has links with policies in the strategy, policies related to these activities are set out in minerals and Waste Core Strategies that Wiltshire have prepared jointly with Swindon Borough Council.
4.44 The routes that constitute the proposed local freight network include the A4 and the A3102. ʻLocalʼ freight routes aim to, wherever possible, avoids less appropriate routes such as residential areas and sensitive areas. A more detailed assessment of routes within the county will need to be undertaken through the freight action plan prior to adopting the advisory freight routing network.
4.45 The Joint Municipal Waste Management Strategy was adopted in 2006 and covers the former four Districts of Wiltshire which now together with county council form Wiltshire Unitary Authority and sets out a framework as well as policies, targets and commitments.
4.46 The Municipal Waste Management Strategy seeks to take account of developments in waste services locally and nationally, such as the Landfill Allowance Trading Scheme (LATS) which aims to reduce the landfilling of biodegradable municipal waste (BMW). The Municipal Waste Management Strategy sets out how Wiltshire will meet their LATS targets. One of the aims is to reduce waste growth to 1% less than the forecast growth rate each year until 2011 and thereafter to grow at a declining rate reaching a nil growth rate by 2015.
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4.47 An ambitious target is proposed for recycling and composting of 50% by 2020 from 31.5% in 2005/6. Principle 2 advocates the separate collection of recyclable and compostable waste materials for reuse and include the following targets:
• 2005/06 – 33% of household waste recycled and/or composted (WWP target2) • 2010/11 – 40% of household waste recycled and/or composted (WWP interim target) • 2019/20 – 50% of household waste recycled and/or composted (WWP target3) • 2010/11 – 95% of households served by kerbside collection of multiple recyclables4 • 2010/11–All collections of residual waste to be fortnightly
4.48 Principle 4 identifies facilities required to meet recycling, composting and overall recovery targets up to 2010/11, 2015/16 and up to 2019/20. Up to 2010/11 facilities are required to maximise the capacity at the Lower Compton MRF (25,000 tonnes per annum) and the Lower Compton outdoor composting facility (30,000 tonnes per annum), as well as provision for an additional outdoor composting facility (up to 20,000 tonnes per annum) and MBT and or Energy from waste or biological treatment to meet a forecast need of 76,000 to 93,000 tonnes per annum in total.
4.49 Additional facilities are also required to meet targets up to 2015/16, including an additional MRF (away from Lower Compton), 3 additional HRCs and an MBT and or Energy from waste or biological treatment to meet a forecast need for 122,00 to 161,000 tonnes per annum in total. Facilities required for 2015/20 include MBT and or Energy from waste or biological treatment to meet a forecast need of 174,000 tonnes per annum in total.
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5 The Need For The Proposed Development
Introduction
5.1 This Section sets out the need which the proposals will meet. In summary this need is two fold. Firstly, there is a requirement to provide upgraded and additional capacity for the management of municipal waste to meet contractual arrangements between Hills and Wiltshire Council as part of the Wiltshire Municipal Waste Contract, consistent with relevant policy. Secondly, there is a requirement identified in relevant policy for new capacity for the recovery and treatment of municipal and industrial and commercial wastes in order to divert waste from landfill.
5.2 There are a series of components that make up the need for the proposals. These are summarised below, and then explained further throughout this Section. In summary therefore, the various components of the need for the proposals are:
1. Municipal Waste Recovery
There is a need for additional municipal waste materials recovery capacity. This is a result of contractual requirements within the Wiltshire Municipal Waste Contract between Hills and Wiltshire Council (WC) and the associated Joint Municipal Waste Management Strategy. It is also a result of policy WCS1 and WCS5 of the Wiltshire and Swindon Waste Core Strategy (WCS) as part of the required sustainable waste management system for Wiltshire.
2. Municipal Waste Transfer
There is a need for new municipal waste management transfer capacity. This results from the requirements set out in Strategic Objective 4 and policy WCS5 of the WCS and policy WDC11 of the Wiltshire and Swindon Waste Development Control Policies DPD (WDC). The transfer capacity forms part of a sustainable transport system within Wiltshire, because it enables the bulking up of sorted and pre treated wastes and their diversion from landfill to recovery capacity located in and out of the County.
3. Municipal Green Waste Composting
There is a need for changes to municipal green waste composting capacity to realise existing capacity and provide for additional capacity, consistent with policies WCS1, WCS3 and WCS5 of the Waste Core Strategy.
4. Industrial and Commercial Waste Recovery & Transfer
There is a need for new industrial and commercial (I&C) waste pre-treatment, recycling, recovery and transfer capacity, including the retention of waste wood recycling capacity. These requirements are set out in Policy WCS3 of the WCS as updated by the Draft Waste Site Allocations DPD.
Policy Regarding the Need for Waste Capacity
5.3 As set out in Section 4 there is a consistent policy context at European, national,
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regional and local levels to improve the management of waste through the implementation of the waste hierarchy, with various policy drivers and targets aimed at moving waste management methods up the waste hierarchy.
5.4 At the European level, the Waste Directive requires that Member States shall take the necessary measures designed to achieve the following targets:
(a) “by 2020, the preparing for re-use and the recycling of waste materials such as at least paper, metal, plastic and glass from households and possibly from other origins as far as these waste streams are similar to waste from households, shall be increased to a minimum of overall 50% by weight; (b) by 2020, the preparing for re-use, recycling and other material recovery, including backfilling operations using waste to substitute other materials, of non- hazardous construction and demolition waste excluding naturally occurring material defined in category 17 05 04 in the list of waste shall be increased to a minimum of 70% by weight” (Article 11).
5.5 The Landfill Regulations explain that, before non hazardous waste is landfilled, it is to be subjected to treatment which must: (a) result in a physical, thermal, chemical or biological process and can include sorting, (b) change the characteristics of the waste being treated and (c) reduce the volume of the waste, or its hazardous nature, or facilitate its handling or enhance its recovery (Regulation 2).
5.6 The pre treatment of waste to accord with this requirement can take place both at source, e.g. at premises where waste is produced through sorting, or via kerbside collection programmes for municipal wastes, and at purpose built facilities. Such facilities would include materials recovery facilities and waste transfer stations where waste can be received, handled, sorted and re-organised into specific materials for the onward export for recovery.
5.7 The Governmentsʼ Waste Strategy sets higher national targets for the recycling of household waste and the recovery of municipal waste compared to the 2000 Strategy. The national target for the amount of household waste not re-used, recycled or composted is a reduction of 45% between 2000 to 2020. The Strategy identifies that achieving these targets will be linked to attaining much higher national targets for recycling compared to those set in 2000.
5.8 Targets for commercial and industrial waste include a 20% reduction from 2004 levels by 2010. The Government has identified key waste materials where diversion from landfill could result in significant environmental benefits. These include paper, food, glass, aluminum, wood, plastic and textiles. In order to achieve more efficient recovery of materials and energy, the Waste Strategy advocates increased segregation and sorting of waste at (or close to) its source by households and businesses. This requires planning for and investment in infrastructure for the collection, sorting, reprocessing and treatment of waste, by local authorities, business and the third sector (paragraph xxiv).
5.9 PPS10 advises that Waste Planning Authorities (WPA) are required to make sufficient and timely provision of waste management facilities, including identifying suitable sites for such development in their Local Development Documents. Guidance is provided in PPS10 to assist with the identification of sites and locations for waste management development. In identifying suitable sites and areas, WPAs should consider:
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• ʻopportunities for on-site management of waste where it arises; • a broad range of locations including industrial sites, looking for opportunities to co-locate waste management facilities together and with complementary activesʼ (Paragraph 20)
5.10 Indicative waste capacity apportionments for the provision of waste management facilities have been included within the Draft Revised Regional Spatial Strategy for the South West incorporating the Secretary of Stateʼs Proposed Changes July 2008 (Draft Revised RSS). This has subsequently formed the basis for waste forecasts and planning policy in Wiltshire and Swindon.
5.11 The Wiltshire and Swindon Waste Core Strategy (WCS) was adopted in 2009 taking into account the requirements of the Draft Revised RSS, and the provisions of the waste contract with Hills and the preparation of the Joint Municipal Waste Management Strategy (JMWMS). The WCS therefore provides clear guidance on the requirements for waste management capacity within Wiltshire, and in Swindon.
5.12 The evidence base for the Draft Revised RSS, used to develop the WCS, is also being carried forward in the preparation of the Wilshire Core Strategy. This evidence base forecasts an increase in population over the next 20 years and subsequent growth in housing and employment across the Strategically Significant Cities or Towns (SSCTs) of Swindon, Chippenham, Trowbridge and Salisbury. This growth in population, housing and employment is likely to lead to higher waste arisings, which in turn will lead to an increased need for additional waste management capacity.
5.13 Therefore, the policy basis for new waste management capacity in Wiltshire is clearly set out, not only for new recovery capacity but also for capacity that will facilitate the ongoing diversion of waste from landfill. In particular, as new facilities are developed and new markets for waste recycling and recovery identified in Wiltshire and further afield, there is a need for capacity that can receive waste materials, process them and bulk them for onward transfer and handling, facilitating sustainable waste management through the use of sustainable waste transportation.
Municipal Waste Requirements
5.14 There is a need to provide additional municipal waste management capacity, both generally to work towards to waste hierarchy and specifically to meet the contractual arrangements between Hills and WC as part of the Wiltshire Municipal Waste Contract. In particular, the contract acts as a driver to realise the ratified approach of Wiltshire Council as it strives to deliver a sustainable waste management system on behalf of Wiltshire residents.
5.15 Decisions taken by the Council to respond to legislative and policy pressure placed upon it to increase the source separation and diversion from landfill of recyclable materials requires the associated development of and investment in infrastructure and capacity to deliver such responses. For source separation programmes, and the management of resulting separated recyclable wastes, this includes provision of MRF and WTS capacity to allow for locally collected loads to be bulked into quantities that can be sustainably exported for further treatment and re-use.
5.16 WCS Policy WCS5 identifies that WC will seek to promote waste management up
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the waste hierarchy and away from disposal. This is consistent with the provisions of the European Waste Directive and with Government and regional waste policy. Policy WCS1 of the WCS makes it clear that capacity will be required to facilitate management of forecast increases in waste arisings associated with the planned growth in the Strategically Significant Cities and Towns (SSCTs) of Swindon, Chippenham, Trowbridge and Salisbury, as identified in the Draft Revised South West RSS.
5.17 The WCS carries forward the capacity requirements for the management of municipal waste identified through the JMWMS and states that ʻadditional recycling facilities will be required to meet the proposed 50% recycling rate target.ʼ (paragraph 2.15, WCS). Additional municipal waste management capacity is also required to facilitate the management of the increased volume of waste which is being diverted from landfill and source-separated for recycling and composting in accordance with planning policy, and the Councilsʼ municipal waste services.
5.18 In particular, Wiltshire Council are seeking to increase their services through the following proposals:
• Household waste collections – fortnightly across Wiltshire from Spring 2012 • Black box recycling – 95% of households to be served by fortnightly collections by 200/2011 • Garden waste collections – fortnightly across Wiltshire from Spring 2012 • Plastic bottles and cardboard – fortnightly collection across Wiltshire from Winter 2011
5.19 To facilitate these proposals, and efficiently operate existing services, there is a need for new municipal materials recovery and waste transfer capacity to be provided. Whilst temporary provisions are to be made available for the handling of collected recyclables at proposed facility at Porte Marsh industrial Estate, Calne, the long term delivery of these proposals requires permanent capacity to be implemented at sites where the full range of waste sorting, bulking and transfer can be undertaken, combining suitable materials for export to suitable end users.
5.20 In accordance with policy WCS1 of the WCS, upgrades are also required to the existing municipal waste management capacity of Wiltshire to reflect the changes in waste management practices, and to increase efficiency within the principles of sustainable development and in accordance with the principles of sustainable transport. Strategic Objective 4 of the WCS and policy WDC11 of the WDC seek, as part of a sustainable waste management system in Wiltshire and Swindon, the minimisation of transportation distances for the movement of waste.
5.21 In particular, municipal waste ariisngs in Wiltshire are to be recovered through treatment processes at facilities both in and out of the County. A new Mechanical Biological Treatment facility is being implemented in Westbury to handle 60,000 tonnes per annum (tpa) of municipal waste, and there is an existing contract for the management of 50,000tpa of municipal waste from Wiltshire and the Lakeside energy from Waste facility in Slough. Provision of the proposed WRF at Lower Compton will also help facilitate the implementation of the strategic composting capacity at Parkgate Farm near Purton.
5.22 Both the Westbury and Purton facilities will be reliant upon deliveries of municipal wastes, both from collection vehicles on localized rounds, and also from bulked up
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transfer of materials from collection rounds located further away from that facility. All deliveries to the Slough facility will require the bulking up of waste materials prior to export to ensure that the each load delivered is as efficient as possible.
5.23 The changes to waste management infrastructure away from disposal to a logistics, processing, handling and treatment based industry will therefore lead to an increasing reliance upon the ability of sustainable waste management systems to be able to receive and sort waste for export to appropriate facilities if the policies identified above are to be met. This is particularly the case in a large rural County such as Wiltshire, where its centres of population are relatively dispersed and the main means of transportation is through reliance upon a well connected road network.
Industrial and Commercial Waste Requirements
5.24 Industrial and commercial waste management is under increased pressure to ensure that all such wastes are pre treated before they are landfilled and that increasing tonnages are diverted from landfill. European legislation in the Waste Directive and Government policy and initiatives for sustainable waste management and environmental management make it clear that these changes are necessary to accord with sustainable waste management policy.
5.25 Consequently, the pressures facing municipal waste as it moves from disposal towards increased transfer, handling and treatment equally face the industrial and commercial waste sector. In particular, facilities for the recovery of such wastes are needed, as are those that can receive, pre-sort, bulk and transfer to suitable recovery facilities.
5.26 These challenges are fully recognised by Wiltshire Councils Waste DPDs, which identify that regional waste management apportionments will necessitate the delivery of suitable waste management sites to provide the capacity to meet need (Policy WCS1). They confirm that suitable types of sites for such capacity need to be clearly identified, including existing waste management facilities, and that the processes need to accord with the waste hierarchy (Policies WCS3 and 5). The draft Waste Site Allocations DPD goes on to confirm the quantity of capacity that must to be provided in Wiltshire to meet waste apportionment needs.
Component 1. The Need for Additional Municipal Waste Materials Recovery Capacity
5.27 The first component for which a need for new waste management capacity has been identified is the provision of additional municipal Materials Recovery capacity.
5.28 There is a need to provide increased municipal waste capacity for the sorting and bulking of recyclable materials for onward transport to the market. This includes all source-segregated materials from household collections, together with materials from Household Recycling Centres (HRCs) and Bring Sites. An increase in capacity is required to provide for the increased waste arisings identified through the Draft South West RSS and the Adopted WCS, together with progress towards achieving a 50% recycling rate target as set out in the Joint Municipal Waste Management Strategy (JMWMS).
5.29 A notable step towards achieving this 50% target will be the introduction of
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household collections for cardboard and plastics as part of the Wiltshire Municipal Waste Contract. This will substantially increase the volume of kerbside and Household Recycling Centre (HRC) collected material that requires sorting and bulking up through a municipal MRF such as the one located at the Lower Compton Site.
5.30 These materials are sourced through existing services and HRCs, new proposals outlined above to increase the collection of recyclables and the recent opening of Marlborough HRC facility. These activities will maintain existing recycling activities and introduce additional volumes of waste that will need to be sorted and bulked up through a municipal MRF such as the one located at the Lower Compton Site.
5.31 The existing municipal MRF facility at the Lower Compton Site has a design capacity of 38,000tpa and is currently operating close to its capacity. This MRF is the only MRF currently servicing collected recyclable municipal waste in Wiltshire. An extension to its capacity will better enable the facility to manage its current throughput and provide for future growth in tonnages collected, both through new collection schemes and tonnage growth. It will not, however, be able to continue to operate in isolation and additional capacity in Wiltshire will be required over time, a fact recognised by the JMWMS.
5.32 The increased capacity of the municipal MRF is in accordance with the Policies WCS1 and WCS5, meeting the needs of municipal waste management strategies and sub regional apportionments, whilst driving waste up the waste hierarchy as part of a sustainable waste management system.
Component 2. The Need for New Municipal Waste Transfer Capacity
5.33 To facilitate the bulking up and transfer of materials for residual treatment and composting as part of a more efficient and sustainable waste management strategy for Wiltshire there is a need for new municipal waste transfer capacity, which forms the second component of the need for the proposals.
5.34 The need for new capacity is set out in Strategic Objective 4 of the WCS and Policy WDC11, as well as obligations within the Wiltshire Municipal Waste Contract. Residual waste and green waste from household collections will be brought to the site and then bulked up for transfer to Westbury MBT and Slough Colnbrook EfW for residual waste treatment and recovery, or to Parkgate Farm in Purton for composting.
5.35 The facility will provide capacity of the bulking up and transfer of approximately 75,000tpa. This will consist of approximately 17,000tpa of green waste for composting to Purton, approximately 29,000tpa of residual waste to Westbury, and 20,000tpa to Colnbrook. The remaining 9,000tpa of capacity is green waste received by the WTS that is re-directed within the site to the low grade composting facility.
5.36 Sufficient municipal waste transfer capacity is a key part of developing and maintaining a sustainable waste management strategy in Wiltshire. The bulking up of green waste and residual wastes should seek to minimise the transportation distances in accordance with Strategic Objective 4 of the WCS and Development Control Policy WDC11 of the Wiltshire and Swindon Waste Development Framework. This should be done in order to reduce overall waste mileage within Wiltshire, and thereby reduce carbon emissions from the management of waste.
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5.37 The provision of municipal waste transfer capacity should be undertaken in a way which ensures that the nearest appropriate facility is being used to manage the waste in accordance with PPS10. Similarly the provision of waste transfer capacity will be in accordance with Policies WCS1 and WCS5 of the Waste Core Strategy, meeting the needs of municipal waste management strategies and sub regional apportionments, and providing the means by which to drive waste management up the waste hierarchy.
Component 3. The Need for Changes to Municipal Waste Composting Capacity
5.38 To enable the proposed Waste Recovery Facility (WRF) to be implemented at the application site there is a site based need to reconsider the type of green waste composting operation undertaken. Consideration of this component of the need for the proposals also allows for a review of available composting capacity to be considered and to seek a means of rationalising available green waste, with available capacity and identified market outlets for compost products.
5.39 Existing capacity at Lower Compton waste management facility for green waste composting currently stands at 32,000tpa, of which approximately 30,000tpa is utilised. Further capacity has been granted, and is being implemented at Parkgate Farm near Purton for a further 25,000tpa, although to date this facility is not yet operated as there has not been sufficient demand for the facility to be brought into operation at the same time as operating a composting facility at Lower Compton.
5.40 The provision of the new WRF capacity in response to the need identified above at the Lower Compton site would allow Hills to focus their strategic composting operations at their Purton site, with a viable tonnage of green waste to be delivered direct or transferred from the WRF to provide sufficient feedstock for its 25,000tpa capacity to be realised. The provision of the new WRF also allows for sufficient space to be made available at the Lower Compton WRF site for additional low grade composting capacity to be created, primarily to produce restoration layer material for the adjacent landfill facilities.
5.41 Should consent be granted for the WRF and its provisions implemented Hills will undertake the strategic composting operation at Parkgate Farm and also undertake low grade composting at Lower Compton, providing capacity for the management 0f 40,000tpa of municipal green waste. This process would also allow for green waste movements to be sustainable managed and for loads to be bulked for transfer reducing the number of delivery miles per tonne of green waste.
5.42 It will also allow for the use of two suitable sites for green waste management, in accordance with the waste hierarchy, diverting a greater tonnage of green waste from landfill than can currently be achieved and make the most efficient use of available waste management sites. As such, this site based response to the need for green waste management is considered to be fully in accordance with WCS policies WSC1, 3 and 5.
Component 4. The Need for Industrial and Commercial Waste Management Capacity
5.43 The fourth component of the need for the proposals relates to the need for additional
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capacity for the pre-treatment, recycling, recovery and transfer of I&C waste to divert waste from landfill and up the waste hierarchy. The need is identified in Policy WCS3 of the WCS, which is based upon Policy W1 of the Draft Revised RSS.
5.44 Specific targets and controls over the management of industrial and commercial wastes have to date been more aspirational than enforceable. The changes to the management of such wastes that are being pushed by recently amended Directives and associated Government Strategies are expected to alter the emphasis that the Government, and therefore local authorities, are expected to place on this issue.
5.45 In particular, it is considered that there will be an increasing expectation at European level, and therefore, as a Member state of the EU, at Government level, that policies and strategies will be prepared so as to accord with the requirements of EU Directives and promote continued improvements in the diversion of such wastes from landfill. Such expectation will also provide the justification for stronger policies to ensure that all waste is pretreated before being allowed to go to landfill, ensuring that landfill is the last option.
5.46 In addition, industry and business standards are evolving to place greater weight and market preference upon those businesses that seek to adopt comprehensive programmes of environmental management. Accreditation schemes such as ISO14001 encourage business and industry to consider the environmental impact of their operations to achieve the standard and make continual improvements. In many cases this is resulting in business and industry seeking to ensure that their waste is reduced, recycled and diverted from landfill to meet the quality standards.
5.47 The proposals will provide essential capacity to manage approximately 150,000tpa of I&C waste. This capacity can be broken down as follows:
• 135,000tpa waste recycling, recovery and transfer capacity, and • 15,000tpa of waste wood recycling capacity.
5.48 The existing waste wood recycling operation will continue as per current operations and will process approximately to 15,000tpa of wood waste, with an estimated 80% recovery rate. The 80% or 12,000tpa of material recovered will be exported from the site, whilst the 3,000tpa of residues would be used within the landfill facilities as daily cover and as part of the restoration layers. This capacity does not constitute new waste management capacity.
5.49 New I&C waste management capacity will be provided through the development of the I&C MRF and WTS. The facility will provide treatment capacity of approximately 135,000tpa diverting approximately 87,750tpa or 65% from landfill. The facility will process a wide range of I&C materials and incorporate the existing I&C waste recycling facility throughput which is approximately 10,000tpa. Consequently, the total new I&C recovery capacity provided by the proposals will be 125,000tpa.
5.50 The provision and operation of I&C waste management capacity is supported and encouraged by planning and environmental policies, from European to local level. The Draft Revised South West RSS identifies indicative allocations for the provision of waste management capacity as required by PPS10, and then transposed in to Wiltshire and Swindonʼs WCS.
5.51 Based upon the indicative allocations set out in Policy W1 of the Draft Revised
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South West RSS, Policy WCS3 in Wilshire and Swindonʼs WCS identifies a need for I&C waste management capacity as follows:
• 250,000tpa of waste treatment capacity • 150,000tpa of recycling capacity
5.52 The need identified in the WCS is based upon data from 2006 and a number of new waste management facilities have since been granted planning permission. The Draft Wiltshire and Swindon Waste Site Allocations DPD (June 2011) provides an update to the waste management capacity in Wiltshire and Swindon and identifies a continuing need for:
• 128,000tpa of treatment capacity • 58,462tpa of recycling capacity
5.53 The total need for I&C treatment and recycling capacity still required by Policy WCS3 of the Wiltshire and Swindon WCS, as modified, is therefore 186,000 tonnes per annum. Even if planning permission is granted for the proposals there will be a continuing need for 61,000tpa [186,000tpa – 125,000tpa] of I&C treatment and recycling capacity elsewhere within the Wiltshire and Swindon area as identified by Policy WCS3 of the WCS.
5.54 The proposals will therefore provide essential I&C treatment capacity for over 65% of the identified need in the Wiltshire and Swindon area. When the 135,000tpa total new I&C capacity is considered, it is clear that the proposed WRF will play an important role in diverting I&C waste from landfill in accordance with Policies WCS1, 3 and 5 of the Waste Core Strategy and the principles of the draft Waste Site Allocations DPD.
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6 Planning and Environmental Analysis
Introduction
6.1 This section of the planning statement considers the principle of development and identifies the planning and environmental issues of relevance to the proposals. The analysis demonstrates how the scheme is in accordance with the development plan or, where appropriate, identifies material considerations which indicate that the scheme should be supported by the planning authorities and planning permission granted.
6.2 The analysis is structured by issue, commencing with strategic planning issues and the considering planning and environmental issues pertinent to the site and its location. Each issue identifies the key policies that are applicable to that analysis, in particular identifying the document and policy addressed. The following document acronyms have been used, alongside which the relevant policy as reviewed will be referenced:
• PPG / PPS Planning Policy Guidance / Planning Policy Statement • RPG Regional Planning Guidance • SWRWS South West Regional Waste Strategy • WSSP Wiltshire & Swindon Structure Plan • WCS Wiltshire & Swindon Waste Core Strategy • WDCP Wiltshire & Swindon Waste Development Control Policies • NWLP North Wiltshire Local Plan • LTP Third Wiltshire Local Transport Plan • JMWMS Wiltshire Joint Municipal Waste Management Strategy • RSS draft South West Regional Spatial Strategy • dWCS draft Wiltshire Core Strategy • WSSA draft Wiltshire & Swindon Waste Site Allocations
Strategic Policy Issues
Principle of Development (Waste Strategy 2007; PPS1; PPS10; RPG10 VIS1; RSS W1; WSSP W1 & W2; WCS WCS1, WCS5)
6.3 Section 5 of this Statement identifies the strategic need for the proposed development and its conformity with waste policy at the European, national, regional and local levels. At the national level Government policy and strategy guides that the waste management industry must make progress in providing for waste management facilities that promote the diversion of waste from landfill. Such facilities should also be designed, located and developed to ensure that waste can be handled at the most appropriate sites and facilitate the management of waste in the nearest available facility.
6.4 Local level waste policy contained in the Wiltshire Structure Plan (Policies W1 and W2) and the Wiltshire & Swindon Waste Core Strategy at policies WCS1 and WCS4 enshrine this approach and confirm that the delivery of sufficient waste management capacity to meet identified needs are central to the sustainable waste management in Wiltshire. Both policy documents recognise the need for diversion of waste from landfill consistent with the aims and objectives of the Waste Hierarchy.
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6.5 PPS10 guides developers and local planning authorities alike that the starting point for determining planning applications for waste development should be the provisions of the up to date development plan. It explains in paragraphs 22 and 23 that where proposals are consistent with an up to date development plan waste planning authorities should not require applicants to demonstrate a quantitative or market need for the proposal. However, whilst the Core Strategy is up to date, being adopted in 2009, it does not provide the degree of clarification required to confirm that development of the proposed WRF at the application site does fully accord with the provisions of the development plan.
6.6 The Wiltshire and Swindon Waste Site Allocations DPD remained in draft form. Whilst this draft document includes proposals to allocate the application site for waste treatment uses, across a near identical site area as the proposed development, its formal status is no more than that of a material consideration. Whilst it is preferable for decisions to be taken with the availability of a fully adopted Development Plan, provisions exist to enable essential waste management capacity to be planned for, consented and delivered whilst policy provisions continue to be drafted by the local planning authority.
6.7 In particular, Policy WCS3 makes it clear that site allocations will be made to meet their identified waste management requirements, and confirms that, for the provision of MRF and WTS capacity, suitable sites will be expected to include current waste management facilities. However, the text to the policy couches this policy approach in terms of sites that the Councils are seeking to allocate, rather than specifically in terms of sites that may be promoted in the absence of any site allocation details in an adopted DPD.
6.8 PPS10 explains at paragraph 24 that “Planning applications for sites that have not been identified, or are not located in an area identified in the development plan document as suitable for new or enhanced waste management facilities should be considered favourably when consistent with:
• the policies of this PPS, including the criteria set out in paragraph 21; • the waste planning authorityʼs core strategy.”
6.9 It is clear that the proposals comply with the need for sites and the intended locations for allocated sites (MRFs / WTSs) set out by Waste Core Strategy policy WCS3. It is also clear that the proposed WRF development is consistent with the following relevant policies of PPS10 with regards to:
• The delivery of waste management capacity that will delivery sustainable development by driving waste management up the waste hierarchy and treat waste as a resource, disposing only of final residues post treatment (PPS10, paragraph 3, bullet point 1);
• The implementation of development that delivers on the strategy, targets and objectives of the national waste strategy and other associated national and European legislation (PPS10, paragraph 3, bullet point 3);
• The recovery of waste without endangering human health or harming the environment, as indicated by the conclusions of this EIA and the provisions of other supporting planning technical documents (PPS10, paragraph 3, bullet
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point 4);
• Enabling the recovery of waste at one of the nearest appropriate installations for the market to be serviced, and the ensuing disposal of any residues at the nearest appropriate landfill facility whilst capacity exists (PPS10, paragraph 3, bullet point 4);
• Reflecting the concerns of local communities and stakeholders, as evidenced through the scale of the proposals and the mitigation selected to ensure that the proposals are acceptable within their receiving environment (PPS10, paragraph 3, bullet point 5);
• The implementation of a design and layout for the proposed development that is fully reflective of its situation in the environment and the provisions necessary to ensure that the development can operate safely and sustainably (PPS10, paragraph 3, bullet point 7);
• Meeting the identified waste management needs of the Wiltshire area, consistent with advice provided through regional assessments of waste management capacity requirements (PPS10, paragraph 4, bullet point 1);
• The successful integration of sustainable waste management capacity with the forecast needs of society and business within the environmental constraints and transportation capacity of the receiving environment (PPS10, paragraph 4, bullet point 2);
• The provision of capacity consistent with requirements for new capacity and its spatial distribution, as evidenced by emerging planning policy for the Wiltshire area and the existing provisions of the Adopted Core Strategy (PPS10, paragraph 4, bullet point 3);
• The provision of permanent waste management capacity capable of meeting the requirements of the development plan for the following 10 year period and beyond (PPS10, paragraph 18, bullet point 1);
• Providing waste capacity alongside existing recycling and disposal provisions, so enabling the management of residues ʻon-siteʼ whilst capacity exists and promoting the co-location of complementary waste management activities within one wider site area, consistent with the concept of resource recovery parks (PPS10, paragraph 20, bullet points 1 and 2);
• Supporting the policies of PPS10 (PPS10, paragraph 21, bullet point (i) 1);
• Representing a suitable site for development with regards to the protection of water resources, land stability, visual intrusion, nature conservation, historic environment and cultural heritage, traffic and access, air emissions including dust, odours, vermin and birds, noise and vibration, litter, and potential land use conflict, as evidenced by this EIA and the wider planning application submissions (PPS10, paragraph 21, bullet point (i) 2 and Annex E);
• Representing a suitable site for the proposed development when considered against the cumulative developments on and off site alongside which it will operate (PPS10, paragraph 21, bullet point (i) 3);
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• The ability of the transport infrastructure upon which the development will rely to accommodate the vehicle movements that will be associated with the recovery of waste by the development (PPS10, paragraph 21, bullet point (i) 4), and
• Providing a means by which improved waste management infrastructure for municipal and I&C wastes required to meet the identified needs of the development plan can be implemented on a previously developed waste site in co location with other complementary waste management activities (PPS10, paragraph 21, bullet point (ii)).
6.10 Consequently, it is not considered that the proposals would represent a departure from the development plan, or be inconsistent with the policies of PPS10. In addition, and despite the absence of a formal waste site allocations document, it is not considered that a decision to grant of planning permission for the proposed development would represent a premature planning decision.
6.11 The issue of prematurity is defined by PPS10 at paragraph 5 bullet point 2, which states that “Any refusal of planning permission on grounds of prematurity will not be justified unless it accords with the policy in The Planning System: General Principles”. This explains at paragraph 17 that refusal of a planning application on the grounds of prematurity may be acceptable where a DPD is being prepared and a development proposal is so substantial, or its cumulative effects so significant, that granting planning permission would prejudice the DPD by predetermining decisions about the scale location or phasing of developments to be allocated by that DPD.
6.12 However, this is qualified by the explanation in the same paragraph that “A proposal for development which has an impact on only a small area would rarely come into this category.” Unless the above circumstances exist, or the proposed development would adversely affect the deliverability of a policy that seeks to promote phasing of development, paragraph 18 advises that “refusal of planning permission on grounds of prematurity will not usually be justified.” It goes on to advise that “Planning applications should continue to be considered in the light of current policies.”
6.13 The guidance does explain that emerging DPDs can be taken into account in the grant of planning permission, with more weight being attached to the provisions of a DPD that has been submitted for examination, and for which the relevant policies have been the subject of little or no objection, thus standing a greater chance of adoption. However, the test of prematurity continues to reside with the fact as to whether or not the proposed development would prejudice the outcome of the DPD process.
6.14 In this respect, there are no clear reasons as to why the proposed development if granted consent would have such an effect. The proposals respond directly to the stated requirements for additional non hazardous waste processing capacity stated in the Waste Core Strategy. They are consistent with the revised requirements that have been stated in the Draft Site Allocations DPD, those requirements being the net difference between the Core Strategy capacity requirements and planning permissions granted for waste capacity since adoption of the Core Strategy. As such, those requirements stated in the Draft DPD are factual.
6.15 Equally, the proposed development is fully consistent with the policies of PPS10 in respect of planning for sustainable waste management and the identification of
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suitable sites for waste development. It also reflects the existing nature of the range of waste management uses for which planning permission has been granted for the management of wastes at this site and continues to make use of an accepted strategic waste management site for these new facilities.
Justifying the Location (PPS10; RPG10 VIS1, VIS2, SS1, SS2, SS3, SS20; RSS W2; WSSP DP3, DP9; WCS WCS2, WCS3; WSSA)
6.16 PPS10 states that when considering sites for waste management uses, priority should be given to the re-use of previously developed land (paragraph 21 (ii)). The re-use of existing land within the Lower Compton waste management facility clearly meets this requirement and indeed, the scheme is able to make use of some of the existing buildings and use areas of land to be vacated by current operations.
6.17 In addition, PPS10 requires the capacity of existing and potential transport infrastructure to support the sustainable movement of waste (paragraph 21 (i)) to be considered. The detailed analysis of transport and access issues in Chapter 9 of the accompanying EIA demonstrate that this requirement is met.
6.18 Annex E of PPS10 sets out further locational criteria to be applied in testing and suitability of sites. It includes identification of sensitive receptors and the extent to which adverse odours and air emissions can be controlled through the use of appropriate equipment. These issues are also addressed at the local level through Policies WCS2 and WCS3 of the Waste Core Strategy, which seek to ensure that the provision of strategic waste facilities accords with Wiltshire Councilsʼ criteria for the identification of sites for waste management.
6.19 The proposed development provides a clear opportunity for the sustainable management of non hazardous waste the site to move up the waste hierarchy in accordance with Government policy without introducing any adverse effects upon the environment. The accompanying EIA and the planning and technical studies that support this application demonstrate that odour and air emissions can be suitably controlled and, as such, will not have any detrimental effects upon the surrounding area.
6.20 Detailed consideration of the selection of the application site over other identified alternatives is provided in Chapter 8 of the Environmental Statement (ES) that accompanies this planning application. Chapter 8 consider the courses of action and sites that might offer alternatives to the proposals. The analysis presented in that Chapter concludes that that the Lower Compton site represents the most appropriate location from those alternatives identified for the development of the WRF capacity and to meet the need identified.
6.21 The ability of the application site to successfully use existing infrastructure such as the municipal MRF building and to upgrade operations to allow for municipal residual waste to handled and exported alongside the pre-treatment of industrial and commercial wastes reflects the current status of the site as a strategic waste management facility. This ability is supplemented by the adjacent non-hazardous waste disposal capacity provided by the Low Lane, Old Camp Farm and Lower Compton landfill facilities. In combination they provide the opportunity for a fully integrated and co-located waste recovery facility.
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6.22 The ability of the proposed development to be accommodated in such a way that does not affect existing surrounding land uses, or future developments will enable the WRF to play a long term and critical role in the sustainable management non hazardous waste in the area. Given this, the absence of suitable alternatives and the proposed facilityʼs compliance with the above policy requirements, it is considered that the provision of the WRF at Lower Compton is appropriate in locational planning and environmental terms.
Sustainable Development (PPS1 including Climate Change Supplement; RPG10 VIS 1, VIS2; RSS SD1 – SD4; WSSP DP1; WDCP WDC1; NWLP C1)
6.23 PPS1 describes the important role of the planning system in achieving sustainable development and building sustainable communities. Its key principles, including effective protection of the environment and prudent use of natural resources, should be followed to ensure planning for sustainable development through development plans and planning applications. PPS ʻPlanning and Climate Changeʼ (December 2007), supplement to PPS1, sets out how spatial planning should contribute to reducing emissions and stabilising climate change (mitigation) and take into account the unavoidable consequences (adaptation).
6.24 Regional planning policy in both the adopted RPG and the draft RSS continue this theme through their policies VIS1 – VIS2 and SD1 – SD4 respectively and the Wiltshire and Swindon Structure Plan addresses the matter at Policy DP1. The key direction of these policies is to ensure that planning decisions require development proposals to minimise their impacts upon natural resources and the countryside, and provide for local needs, having due regard to the requirements to plan for and support the Strategically Significant Cities and Towns in Wiltshire. These issues are all addressed within policy WCS2 of the Waste Core Strategy.
6.25 The development proposals have been designed so that by their very nature they make a significant contribution to the provision of sustainable development in Wiltshire. They directly implement the requirements of waste policy for the pre- treatment of waste and its diversion from landfill, consistent with the requirements of the waste hierarchy. They will also lead to a greater degree of control over the movements made by waste collection and distribution vehicles and an associated rationalisation of the number of vehicle miles that waste must travel in Wiltshire from source, to treatment to recovery or disposal.
6.26 The proposals have also been designed with full regard to the conclusions of the accompanying EIA and the supporting planning technical documents. these have ensured that the capacity, layout, operation and environmental controls for the development avoid any adverse impacts upon the site and its surrounding land uses. In that respect, the proposals represents a form of environmentally acceptable sustainable development that are essential to the waste management capacity needs of Wiltshire.
6.27 Policy WDC1 identifies a number of waste specific development control criteria relevant to the identification of sustainable waste management development, including consideration of cumulative impacts, transportation impacts and impacts on the water environment. It also considers the effects of development upon natural resources and ecology and, as required issues relating to restoration.
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6.28 The remaining analysis of this section addresses many of the issues in greater detail, as to the accompanying EIA and supporting technical planning documents. in summary however, the development proposals are not considered to introduce any impacts upon the surrounding land uses and environment that would have an adverse effect, either alone or in combination with other development projects. Transportation of waste, not just to the application site but generally in terms of the transfer of collected materials to recovery and transfer stations will be improved through the provision of this co-located facility. In particular, the WRF will enable recovered and residual wastes to be bulked up into more sustainable loads and transported using fewer HGVs.
6.29 The design of the development has ensured that the management of surface water drainage will provide sufficient control over flood risk whilst ensuring that general flows and appropriately contained within the site prior to their discharge. The provision of improved landscaping and access arrangements has considered in detail any associated ecological effects and suitable controls have been put in place to ensure that appropriate protection and enhancement measures will be employed.
6.30 Within the operational area of the site the MRF / WTS buildings have been design to site alongside existing operations and integrate into the site and its surroundings without any adverse effects upon the landscape or visual receptors. As the site is to be a permanent facility, the proposals do not include for restoration provisions, although the design does ensure that the WRF can be accommodated alongside the restoration details associated with other activities.
Planning and Environmental Issues
Air Quality & Odour (PPS23; RPG10 EN2; WSSP W4; WDCP WDC2 )
6.31 The boundary of the proposed construction site is approximately 100 metres from the nearest sensitive residential receptors. The inclusion of best practice dust mitigation measures for the construction sector will minimise the impact of construction dust emissions such that there will not be a measurable change in dust deposition rates or PM10 concentrations at the nearest sensitive residential receptors. These measures will be incorporated into the CEMP for the development.
6.32 The air quality impacts associated with the construction and operation of the proposed development have been assessed. Existing conditions within the study area show that air quality objectives are being achieved at most locations; however, Wiltshire Council has identified that the annual mean nitrogen dioxide objective is being exceeded at some locations very close to the A4 in Calne. The Council is currently carrying out a Detailed Assessment to determine whether an Air Quality Management Area will be required.
6.33 The air quality assessment has concluded that concentrations of nitrogen dioxide, PM10 and PM2.5 would remain below the objectives in 2014, when the site is due to become operational, at most relevant locations, whether the scheme is developed or not. However, annual mean nitrogen dioxide concentrations are expected to continue to be above the objective alongside the very narrow section of the A4 (New Road), near to the King George.
6.34 The operational impacts have been assessed and show that the majority of changes in pollutant concentrations will be imperceptible. However, ʻSmallʼ increases of
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nitrogen dioxide concentrations are predicted in the very narrow canyon-like sections of the A4 through Calne, which give rise to a ʻSlight Adverseʼ impact, as concentrations are close to or above the objective at these locations. Elsewhere the impacts are described as ʻNegligibleʼ. Overall, the air quality impacts due to road traffic are judged to be Minor.
6.35 The assessment concludes that the impact of additional traffic generated by the proposals on vegetation within nearby SSSIs will be Insignificant. The proposed development would lead to an overall improvement in odour climate in the area and reduction in bioaerosol emissions, as a result of significantly reducing the amount of composting carried out on the site.
6.36 Construction dust impacts are unlikely to be discernible from other continued mineral extraction, waste recovery and waste disposal operations and are therefore judged to be Insignificant.
Cultural Heritage (PPS5; RPG10 EN3; WSSP HE3, W4; WDCP WDC8; NWLP HE3; RSS ENV1, ENV5)
6.37 The proposed development site has, throughout its entire footprint, been the subject of development of some form. Some ground disturbance has taken place to prepare the site for the laying of existing hardstanding, excavation associated with the existing attenuation pond and for the construction of the existing landscape / screening bund. The development proposals will require similar ground works, for example existing areas of hardstanding will need to be reinforced to support the proposed new build elements and the draining and backfill of the pond area to provide for a consistent surface on which hardstanding can be provided.
6.38 The development site does not lie within an area of archaeological value nor does it contain any protected features of historical or cultural significance. Within 1km of the site there are scheduled monuments and the historic Compton Bassett Park. The Compton Bassett village Conservation Area is approximately 1.6km to the north east of the proposed site. The closest archaeological record to the site is located to the west of Old Camp Farm for a modern 20th Century electrical and wireless school located to the west of Old Camp Farm, as part of the RAF station, and constructed in 1940. Other nearby records include including the presence of Compton Bassett Park, and a number of features at Freeths Farm 1.5km to the north of the WRF proposal site. However, no records are currently known of directly on the application site.
6.39 All construction works are proposed to take place within the existing developed area occupied by the current MRF, waste recycling, composting, vehicle parking and surface water attenuation pond. Some works will also include modifications to the site haul road and the locations of ancillary functions such as the site weighbridge. The construction of the new surface water attenuation pond to the south of the landscape bund will require earthworks to be carried out. All such activity will be limited to the existing developed areas and site access points. As such the ability for the minimal ground disturbance to disturb or destroy any sub surface deposits is considered to be low.
6.40 By virtue of the existing developed nature of the site, the limited need for intrusive activity during construction, the current operational nature of the site and the avoidance of any off site construction works the degree of effect during construction
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upon archaeology and cultural heritage is considered to be low. Once the site is operational, no further ground works will be necessary and the proposed WRF will operate within its approved development footprint. It is considered that the degree of operational effect upon identified sites or monuments will be low to negligible.
Design (PPS1; RPG10 EN4; RSS SD3)
6.41 The Design and Access Statement considers in detail the design principles of the scheme. This section briefly considers how the proposed scheme meets planning policy that seek to influence and shape its design and appearance.
6.42 The Adopted South West RPG and the draft South West RSS contain generic policies which relate to the design of new development. Whilst not all of the criteria of these policies are directly relevant to waste management development of this type, the proposals do achieve the following:
• maximisation of previously developed land; • avoidance of ecological harm and provision of appropriate landscaping; • adoption of a sensitive high quality building and site layout design, and • respecting the local context and character of its surroundings whilst recognising the potential to reduce the visual impact of the application site.
6.43 Chapter 12 of the accompanying ES considers the landscape and visual impact of the development, whilst the accompanying Design and Access Statement provides a detailed assessment of the design and access characteristics, including the provision of detailed computer generated images (CGIs) that place the proposals within their context alongside the adjacent site operations. The CGIs are provided as Appendix 1 to the Design and Access Statement.
6.44 The proposed development will be located on, and adjacent to, existing waste management infrastructure within the Lower Compton waste management facility. This co-location will also form an integral part of the operations within the Lower Compton waste management facility. Over time, the maturing of the proposed planting will further enable the incorporation of the proposed development within the surrounding context, which will include the progressive restoration of the adjacent landfill facilities. In addition to appropriate design and landscaping, in accordance with policy WDC7, particular attention has been paid to lighting provisions to ensure external lighting levels will be low and similar to those associated with the existing waste facilities.
6.45 The proposed development will require the importation of various construction materials to develop the extended and new buildings and to provide for all necessary ancillary site infrastructure. In addition, there will be the need for some soils to be excavated to allow for construction of the widened site access at surface water drainage proposals. Whilst Policy WCS6 of the Waste Core Strategy does not specifically list waste developments as meeting the identified criteria for waste reduction and auditing, the principles of that policy will nonetheless be taken into account as part of the construction of the proposals.
6.46 Where waste materials arise during construction these will in the first instance be put to re-use where appropriate elsewhere within the site. For example, clean excavated soils will, where possible be used to assist the on site re-landscaping of the screening bund. Waste materials generated from the bund itself, and those from
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excess construction materials will be processed by on site waste recovery plant before export for re-use as appropriate. Green waste generated through site clearance and tree felling will be managed with through off site composting operations or through the on site waste wood recycling plant. Only where materials are incapable of re-use or recovery will they be disposed of, in this case in the adjacent landfill facility at Low Lane.
Ecology (PPS9; Circular 06/05; WSSP C1, C2, C3 AMEND ACCORDINGLY; WDCP WDC8; NWLP NE7, NE9, NE11; RSS SD1; ENV4)
6.47 Government guidance in PPS 9: Biodiversity and Geological Conservation sets out planning policies for the protection of biodiversity and geological conservation through the planning system. PPS 9 dictates that legally protected species and Biodiversity Action Plan species are material considerations in the determination of potential planning applications and that an aim of planning decisions should be to prevent harm to biodiversity. Draft South West RSS policies ENV1 and ENV4, and policy WDC8 of the Waste Development Control Policies DPD and its supporting Appendix 2 detail the need for and requirements of ecological survey work undertaken in support of waste planning applications.
6.48 Further to confirmation by Wiltshire Council in its EIA Scoping Opinion for the proposed development that ecology did not require formal assessment in the EIA that accompanies these proposals, Johns Associates were commissioned to undertake an Ecological Impact Assessment (EcIA) of the development. The EcIA draws on desk study and field survey data to define an ecological baseline and has allocated a level of ecological value to recorded species and habitats associated with the Site and the wider Study Area. The EcIA is provided at Tab 8 to the Planning Folder.
6.49 Impacts on the Calstone and Cherhill, Kingʼs Play Hill and Morganʼs Hill SSSIs were considered to establish whether increases in levels of oxides of nitrogen arising from increased HGV movements on the local road network would impact upon these sites. Modelling work undertaken as part of the air quality assessment confirmed that the predicted change in NOx concentration at this location is so small that the model indicates no change at this receptor. Elsewhere within the Calstone and Cherhill SSSI and also in the Kingʼs Play Hill and Morganʼs Hill SSSIs, impacts would be even less perceptible. The same is true for Marsh Lane Meadows County Wildlife Site.
6.50 The majority of broad-leaved semi-natural woodland habitat will be retained and protected throughout the construction period. As such, impacts to this habitat are limited to loss of a narrow strip (estimated to be 5m in total) on the eastern side of the access road, comprising 7 trees in total plus approximately 8 young/ self-sown saplings. Loss of this habitat is offset by substantial tree and shrub planting on the bund to create a new woodland block (see Drawing no HILLS/1011-DWG-012). The small area of habitat to be lost combined with the extensive planting proposals is considered to result in a net positive impact (although this is not predicted to be significant).
6.51 Implementation of good practice control measures within a Construction Environmental Management Plan means that the risk of indirect impacts to the Honeyball Stream and habitats further downstream (including wet woodland and Riverʼs Brook) is reduced to an acceptable and insignificant minimum. During the
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operational phase, the proposed drainage and treatment system will result in negligible and insignificant risk of pollution of these Valued Ecological Receptors. Creation of a new attenuation pond with retained willow pollards and native emergent and marginal plants will result in a net positive impact to wetlands in the area by extending and diversifying the habitat available to wetland fauna (although this is not predicted to be a significant impact).
6.52 The targeted survey confirmed likely absence of reptile species. Once habitat has been restored on the bund following importation of soil and landscape planting, there will be no net loss of potentially-suitable reptile habitat and no significant impacts on reptiles are predicted.
6.53 Targeted survey work confirmed that there are no potential bat roost sites within or immediately adjacent to the development site. All potential foraging and commuting habitat will be retained, including woodland and scrub edge along the southern section of the bund and woodland edge to the east of the access road. New external lighting has been designed to ensure that lux levels at these habitat features are not increased.
6.54 Disturbance to breeding birds is predicted to be negligible given the limited area of works and existing levels of disturbance due to HGV movements. In the long-term, net positive impacts to the local bird population are predicted due to establishment of new breeding habitat (bird boxes and plantation woodland on the bund) (although these are not predicted to be significant).
6.55 There will be some loss of semi-natural habitat in the form of semi-improved grassland on the bund and in the adjacent field during restoration of the bund with soil and tree/ shrub planting. However, areas of more species-rich grassland on the inside of the bund will be retained in the long-term and this is a short-term temporary impact involving loss of common and ubiquitous habitat. Impacts upon dormice and badgers were also considered by the EcIA and concluded to be low to negligible in effect.
6.56 Taking into account all ecological mitigation and enhancement measures, no net negative or net significant impacts are predicted to arise due to development. The development proposals are predicted to result in net positive impacts for biodiversity, in full accordance with Policy WDC8 in the Waste Development Control Policies Development Plan Document (2009).
Landscape (PPS7; RPG10 EN1; WSSP C8, C9, HE6, W4; WDCP WDC2, WDC7; NWLP NE4, NE14, NE15; RSS ENV1, ENV 2, ENV3)
6.57 Wiltshire Structure Plan Policy DP1 states that particular priority should be given to: “Minimising the loss of countryside and protecting and enhancing the plan areaʼs environmental assets.” Policy C8 sets out the requirements for considering development within Areas of Outstanding Natural Beauty (AONB). Whilst the application site lies wholly outside of the NWDAONB, the immediate landscape setting to the AONB remains a key consideration and is to be addressed in the impact assessment.
6.58 Policy WD2 stipulates that any significant adverse impacts which may arise from waste management proposals are adequately mitigated. Landscape character is the subject of Policy WDC7. The policy requires that proposals for waste management
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developments protects, and where possible enhances, the quality and character of the countryside and landscape and includes measures to safeguard the landscape setting and rural amenities to settlements. Proposals are to include landscape proposals appropriate to the location and context and are to include an assessment of the adverse impacts on landscape character.
6.59 North Wiltshire Local Plan Policy NE4 sets out the planning policy in relation to development within Areas of Outstanding Natural Beauty. Whilst the application site lies outside of any designated landscape, the landscape setting to the Area of Outstanding Natural Beauty the landscape and visual effects on the setting to the AONB are a key consideration. In terms of planting and features, Policy NE14 states that proposals should seek to retain and incorporate within the design of the development trees, hedgerows, lakes / ponds or other important landscape or ecological features. Landscape character is the subject of Policy NE15 requiring new developments to conserve and enhance the landscape of North Wiltshire.
6.60 A Landscape and Visual Impact Assessment has been carried out of the proposed development and is reported in the accompanying EIA for these proposals. The application site does not lie within a designated landscape. However, the North Wessex Downs Area of Outstanding Natural Beauty lies to the east of the C15 road corridor, to the east of the application site. Compton Bassett Park is also located to the west of the C15, the villages of Compton Bassett and Cherhill are also designated as a Conservation Area, together with an area in the centre of Calne.
6.61 The application site lies within a valley floor landscape and is visually and physically contained from the wider landscape to the north and west by the local ridgelines. Land uses locally include the working and currently disturbed landscapes associated with the former mineral and landfill areas to the north and west, with a predominantly pastoral agricultural landscape beyond to the north, east and south. The agricultural landscape is interspersed by woodland blocks, treebelts and farmsteads. The settlement of Calne dominates the landscape to the west. The A4 is the main east to west road corridor through the area, with footpaths and bridleways criss-crossing the local landscape.
6.62 Views of the application site are limited to views from the local landscape to the north-east, east and south. These include views from residential properties, road corridors and public rights of way. The visual assessment has identified a range of views from truncated to fully open views in close proximity to the site; partial views where the site and the existing building is visible between or glimpsed through intervening vegetation or as part of a long distance view and wider panorama.
6.63 An Arboricultural Impact Assessment and Tree Survey was undertaken by Glendale Countryside to establish the effects of the removal of a total of 18 trees from the site as part of the proposed development (Tab 9 to the Planning Folder). These trees are to be removed to facilitate the proposed buildings; the widening of the new access road; and for sound arboricultural reasons. In summary, the effects of the removal of these trees was not concluded to be significant. Nonetheless, as part of the landscaping proposals for the proposed development a minimum of 190 trees are proposed to be planted within the application area. This will primarily relate to the need for screening provisions for the proposed development but will also offset the loss of any existing trees.
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6.64 During the construction phase, considering the landscape proposals in place as the final phase of construction, effects on the landscape receptors will be short term, temporary, direct and will range from either no change or negligible, minor negative to major positive significance on the local landscape and visual receptors. Effects on the visual receptors will range from negligible to moderate adverse.
6.65 Effects during the year 1 of operation on the landscape receptors will be temporary, direct and will range from either no change / negligible to minor negative and major positive. Effects on the visual receptors will range from negligible to moderate adverse. Effects at year 10, considering the maturing of the landscape proposals will result in a positive effect on those receptors affected by the proposed development.
6.66 No further mitigation or enhancement measures have been identified over an above those included within the scheme design, as significant impacts have been considered as part of the iterative design process. The landscape and visual effects therefore remain as the residual effects which are of between no change or negligible, to between minor and moderate negative significance, to major positive significance
Land Quality (PPS23; WDCPD WDC2; NWLP NE17)
6.67 PPS23 (Annex 2) provides guidance on how the development of contaminated land can be controlled within the planning process. Historic land contamination is a material planning consideration that must be taken into account at various stages in the planning process, including proposals for the future use and redevelopment of the site. Policy WDC2 of the Waste Development Control Policies DPD applies this guidance at the local level requiring waste development proposals to demonstrate that proposals avoid, mitigate against an compensate where significant adverse impacts arise from development on contaminated land.
6.68 In response to these issues, Generic and Preliminary Land Quality Risk Assessments (GLQRA / PLQRA) have been completed for the application site, as evidenced at Tab 11 of the Planning Folder. These assessments, completed by SLR Consulting Limited, built on the outcomes of the EIA Scoping process, which concluded that, whilst it would be necessary to complete these assessments they should not form part of the EIA that accompanies the planning application.
6.69 The PLQRA contained a preliminary conceptual model which examined the potential contaminant-pathway-receptor linkages in relation to identified or potential land contamination issues at the Site. In particular, the PLQRA identified the following five potential sources of on Site contamination:
• Source 1 – Contaminants within Made Ground (metals, etc – if they are present); • Source 2 – Aggressive compounds (sulphates) within Natural Clays • Source 3 – 4,500 litre gas oil tank – north east corner of MRF; • Source 4 –- 47,500 litre diesel tank and dispenser – north east of MRF; and • Source 5 – Carbon Dioxide Gas.
6.70 The PLQRA report concluded by recommending further risk assessment once:
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• the chemistry of near surface soils in the grassed verges and landscape bund has been established; • the aggressivity of soils in the foundation zone has been established; • additional gas monitoring has determined the gas concentration and flows within the wells that have already been considered; and • the chemistry of near surface soils adjacent to two bulk fuel stores in close proximity to soft ground has been established.
6.71 The results of all subsequent investigations, monitoring and assessment are presented in the Generic Land Quality Risk Assessment (GLQRA) report, which assesses the potential following contaminant-pathway-receptor linkages:
• PPL1 – Exposure of humans & horses to contaminants in surface soils (Source 1); • PPL2 – Exposure of humans to (naturally occurring) carbon dioxide (Source 5); and • PPL3 – Exposure of humans to hydrocarbons in near surface soils adjacent to fuel tanks (Sources 3 & 4).
6.72 Ground investigations to establish the concentrations of key potential contaminants within shallow soils and the ground gas regime, which targeted potential sources of pollution: through Sources 1, 3 and 4, did not reveal gross soil contamination. A conservative risk screening exercise, employing generic assessment criteria, also showed that the soils at the site are largely free from contamination and are fit, on balance, to be used in a residential development used by small children. Given that measure of land quality, there is no need to perform a health risk assessment specific. Adult humans, such as those that will be employed at the Site, are not likely to suffer significant health impacts by being exposed to the low concentrations of the contaminants found at the Site.
6.73 The results of regular ground gas monitoring for licence compliance purposes have been supplemented by four rounds of ground gas monitoring which have included measurements of flow rate. The recent monitoring confirmed that methane is absent. Carbon dioxide is present, although its source is considered to be in the natural clay strata. The gas regime has therefore been preliminarily determined as a Characteristic Situation 1 and therefore requires ʻno special precautionsʼ for protection from land gases. Following completion of these risk assessments it is concluded that any identified can be controlled and the risks are within acceptable limits. In terms of the requirements of policy WDC2, the development will not lead to future contamination of the land in and around the site.
Noise (PPG24; WDCP WDC2; NWLP NE18)
6.74 PPG24 provides advice on how the planning system can be used to minimise the impact on noise without placing unreasonable restrictions on development. Policy WDC2 of the Waste Development Control Policies DPD identifies the need to avoid the adverse impacts of noise and vibration associated with new waste management proposals, or adequately mitigate where this cannot be achieved. It also requires that waste management proposals should be accompanied by assessments of the impacts associated with noise and vibration.
6.75 A noise and vibration assessment is included at Chapter 11 of the accompanying ES. Baseline noise surveys, undertaken at the closest sensitive receptors to
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application site, have enabled a good understanding of the existing noise climate in the area. Regard has been had in utilising this information to the location of the closest sensitive receptor to this planning application boundary, residential properties located approximately 20 metres to the north east and 100 metres to the south, and to the character of the existing waste management facility which is one of a significantly developed and large industrial area.
6.76 During the construction phase, noise levels should not be audible at the nearest receptors except between 0800 to 1800 Monday to Friday and 0800 to 1300 Saturday. However, by employing current best practice measures, including production of a CEMP, it is considered that noise levels as a result of construction activities can be reduced to a minimum and to within levels considered to be in accordance with policy WDC2.
6.77 With regard to operational noise, plant operation and activity on site should not give rise to a BS 4142 rating level greater than the background level at the nearest or worst affected property. Operational noise predictions will be undertaken once a contractor has been appointed and accurate information is available regarding noise levels of the various components of the proposed development. By incorporating any necessary noise attenuation measures, it is likely that appropriate operational noise criterion can be satisfied at the closest noise sensitive receptors to the site
Transport (PPG13; RPG10 TRAN1, TRAN2, TRAN6, TRAN7; WSSP T8, T9, W4; WDCP WDC2, WDC11, LTP; RSS RTS4)
6.78 National planning policy for waste management is set out in PPS10: Planning for Sustainable Waste Management, (March 2011). Paragraph 21 of PPS10 lists a number of criteria against which the suitability of sites for waste management facilities should be assessed, including ʻThe capacity of existing and potential transport infrastructure to support the sustainable movement of waste, and products arising from resource recovery, seeking when practicable and beneficial to use modes other than road transport.ʼ Annex E to PPS10 sets out criteria for testing the suitability of sites and areas for new or enhanced waste management facilities, including: ʻf. traffic and access - Considerations will include the suitability of the road network and the extent to which access would require reliance on local roads.ʼ
6.79 National planning policy on transport is set out in PPG13: Transport (January 2011), with policy on freight set out in paragraphs 45 to 47. Paragraph 46 comments that freight moments are often restricted in their hours of operation through the imposition of conditions because of concerns over disturbance to residents. Policies need to strike a balance between the interests of local residents and those of the wider community. It goes on to explain that local authorities and freight operators should work together within the context of freight quality partnerships to agree lorry routes and other matters.
6.80 The overall thrust of the Structure Plan is to plan development so as to reduce the need to travel. Policy T1 of the North Wiltshire Local Plan relates to minimising the need to travel for new developments. The Third Wiltshire Local Transport Plan (LPT3) covers the period from March 2011 to March 2026, and sets out the councilʼs objectives, implementation plans and targets for transport in Wiltshire. The long term vision of the LTP3 is to develop a transport system which helps support economic growth across Wiltshireʼs communities, giving choice and opportunity for people to safely access essential services. Its emphasis is on transport solutions
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which will be sensitive to the built and natural environment, with a particular emphasis on the need to reduce carbon emissions.
6.81 The Waste Development Control Policies DPD discusses the sustainable transportation of waste in Policy WDC11. This explains that to minimise the impacts of HGV traffic associated with waste management development the reduction of transportation distances should be encouraged wherever possible. It points out that the Wiltshire HGV Route Network sets out the most appropriate routes for HGVs to use, and that the impacts of waste management transportation will be minimised if waste development is located in close proximity to this network. It makes it clear that issues including the number of HGV movements per day will be important considerations, and that a comprehensive Transport Assessment (TA) will need to be submitted with a planning application where a development is likely to have significant transport and related environmental impacts. It also encourages waste site operators to enter into voluntary waste site transport plans.
6.82 The accompanying EIA to the planning application includes an assessment of the transportation and access impacts from the proposed development. A detailed Transport Assessment (TA), as required by Policy WDC11, is also provided at Tab 7 of the Planning Folder. Both Chapter 9 of the ES and the TA explain that Hills have estimated the change in annual loads, which will arise from the proposed development, taking account of the removal of the high grade composting and the reduction in landfill. Once WRF is fully operational in 2014, the annual number of loads associated with the Waste Management Facility is expected to increase from 49,568 to 54,644, an increase of 10.24%. This level of operation is then expected to remain steady for the foreseeable future.
6.83 The proposed development will therefore result in a small increase in traffic of about 10%, using the site access. There is therefore likely to be an impact of low significance on the operation of the site access. However, change in total traffic flows on all routes is predicted to be 6% or less. Consequently, there should be no noticeable effect from severance and the magnitude of severance impact is predicted to be low and therefore insignificant. Driver delay is most likely to be perceived at the junction between the C15 and the A4. The magnitude of driver delay impact is predicted to be low and the impact will therefore be insignificant.
6.84 As the change in HGV flow is predicted to be less than 6%, there should be no noticeable effect on pedestrian amenity. The HGV flow without and with development is less than 1,000 per day. Consequently, there should be no noticeable effect from fear and intimidation. With regards to accident and safety, the predicted increase of 37 light vehicles and 44 HGVs per day on the C15 is expected to have no noticeable effect on accident rates.
6.85 Construction traffic is not expected to exceed 26 HGV movements per day on average, and there will therefore be no effect on the road network. The impact during construction will therefore be insignificant.
6.86 A particular point raised by Wiltshire Councilsʼ Highways Authorityʼs response to both the EIA and Transport Assessment Scoping Reports was that, in the face of local public concern in Calne, an origin and destination survey was required. This survey would need to address HGV movements associated with vehicles taking access to Hillsʼ Lower Compton facility, and to the facilities operated by Aggregate Industries and Viridor at Sands Farm Quarry and Landfill off Sandpit Lane. It was
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advised that this was required to obtain an understanding of the extent to which these arrangements contribute to the totality of HGVs passing through Calne.
6.87 Hills subsequently consulted with both Aggregate Industries and Viridor in respect of their known movements and they informed Hills that their lorry impacts in Calne are currently minimal as their customers are not based in the Calne area, with the majority being located to the north of Calne. Further correspondence was sought with the Highways Authority to agree a more appropriate means of approach this wider issue, that being to focus on movements generated by Hills.
6.88 This reflects the advice provided by Aggregate Industries and Viridor regarding the catchment of their customers, and also the outcomes of EIA and Transport Assessment work for the proposed WRF development which show that impacts from the proposed development upon the highway network are not significant. At the time of submitting the planning application no further response had been received. However, Hills consider that the assessment provided in both the EIA and the TA that accompany the planning application fully and appropriately address the matter initially raised by the Highways Authority.
6.89 Consideration was also given by Hills, Aggregate Industries and Viridor to the feasibility of providing a route between all three land holdings to ʻby-passʼ the need for movements through Calne. Notwithstanding the advice provided by Aggregate Industries and Viridor regarding the direction of the movements being away from Calne, or the outcomes of the EIA and Transport Assessment work, it has been confirmed that the provision of such a route between all three land holdings is not feasible nor operationally desirable.
6.90 Hills will prepare and keep under review a Good Driving code of practice, which includes a reporting mechanism to enable local people to report incidents of bad driving. This code of practice will be regularly updated by Hills and is applicable across all of their business activities in Wiltshire. This code of practice will be in use for all vehicle movements associated by the proposed development and will provide additional benefits to the safe operation of the public highway in the immediate vicinity of the site. This will be an extension of Hillsʼ current customer relations practices and will seek to include other companies in the area to participate.
6.91 Furthermore, and recognising the permanency of their proposed WRF development Hills are seeking to work with Wiltshire Council to make provision for appropriate contributions towards the making and implementing Traffic Regulation Order to introduce a reduced speed limit along the C15. Hills propose to enter into a suitable legal agreement with Wiltshire Council, to formalise this provision. Tab 3 of the Planning Folder includes a Draft Head of Term document to address this particular matter.
6.92 The proposed development will result in a small increase in traffic of about 10%, using the site access. The impact on the local road network concentrated on the impact at 2011 (base year), since this is when the percentage impact will be greatest. As in future years traffic on the network generally is anticipated to grow, but the development traffic is not expected to grow beyond the level presently assessed. Change in total traffic flows on all routes is predicted to be 6% or less. Following completion of the Proposed Development including enhancement measures it is considered that any impact will be insignificant.
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Water Environment (PPS25, Circular 04/06; RPG10 RE1, RE2, RE5; WSSP C5, W4; WDCP WDC2, WDC3, NWLP T2; RSS F1, RE6)
6.93 The application site is located within the Environment Agencyʼs Indicative Flood Zone 1, with a small section of the southern part of the site in Zone 2. The site lies outside of the functional flood plain covered by Zones 2 and 3. In accordance with the requirements of PPS25 and Waste Development Control Policy WDC3, a Flood Risk Assessment (FRA) of the scheme has been undertaken by Johns Associates and is submitted in support of this planning application (Tab 10). This is accompanied by a supporting Surface Water Drainage Assessment prepared by HR Wallingford, as appended to the FRA.
6.94 Policy WDC3 requires waste management development proposals “…to protect and where appropriate enhance the local water environment, including the protection of groundwater resources, watercourses and other surface water bodies in terms of both quality and quantity, and avoidance of flood risk.” Whilst the development proposals will not have any effect upon ground water resources, the FRA and Surface Water Drainage Assessment have had due regard to the effects of the development upon surface water flows, both in terms of their intrinsic management and in terms of flood risk.
6.95 Best practice techniques will be adopted during the construction of the scheme, including adherence to the Environment Agencyʼs Pollution Prevention Guidelines, to minimse any effects of construction on the surrounding water courses. During operation, routine maintenance of the system and best working practices will minimse the risk of any leakages or spillages.
6.96 The proposed development will lead to an overall increase in the amount of impermeable land and surfacing. The surface water that lands on hardstanding and buildings areas, including roads and roofs, will be divided into ʻcontaminatedʼ and ʻuncontaminatedʼ sources. The contaminated flows include the water that falls onto and drains from the low grade composting area in the north of the site. These flows will be directed to either a below ground storage tank or to a suitably sized above ground attenuation pond, the nature of either to be fully determined by the appointed contractor for the development. From here, collected water will be allowed to settle out before it is either pumped for management at the adjacent landfill leachate treatment plant, or if suitably uncontaminated, discharged to groundwater via existing discharge pumping arrangements.
6.97 Other surface water flows from the central and southern areas of the site will be drained to existing watercourses within the site to a new attenuation pond to be located to the south of the screening bund from here, captured flows will be discharged into existing drainage arrangements for the site.
6.98 All attenuation measures have been modelled on the basis of a 1:100 year flooding event allowing for climate change. The resulting attenuation capacity for the uncontaminated surface flows to the new southern attenuation lagoon is greater than the 220m3 of volume required to meet the model requirements. These measures along with the detailed FRA demonstrate that the proposed WRF will not increase on site or downstream flood risk or give rise to any adverse impact upon the existing water environment of the site.
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7 Conclusions
7.1 The proposed development will result in significant improvements to the efficiency with which municipal waste is handled in Wiltshire, and will provide strategically important pre-treatment and recovery capacity for industrial and commercial wastes managed in the County. The need for the proposed development is driven by statutory and policy requirements to secure the management of non hazardous wastes by methods higher up the waste management hierarchy where this is possible.
7.2 The proposed WRF will provide Hills with essential, modern, reliable infrastructure to supplement existing on recycling and disposal capacity operated as part of its wider Lower Compton Waste Management Facility. It will also facilitate the improved handling of wastes to be transferred for recovery and treatment at other facilities both in the County and elsewhere as part of a sustainable network of waste management.
7.3 The proposed development will enable Hills to properly provide this essential capacity both to manage the needs of the existing waste arisings and to service the requirements of the future waste growth within the Wiltshire area so aiding and facilitating ongoing growth.
7.4 The development has been extensively tested against all relevant policy to ensure it is capable of being integrated with the existing land uses and surrounding environment that it will serve and alongside which it will be located. The analyses presented in the accompanying supporting documentation, including the Environmental Impact assessment, conclude comprehensively that, with supporting mitigation as required, these proposals are wholly acceptable in planning policy terms.
7.5 Its provisions to control environmental impacts have lead to the integration of the proposals in construction management, transportation, air quality, noise and vibration, and landscape terms. Consideration of ecological, water environment and land contamination issues have also informed the design of the proposals. Critically, the proposed development provides for the implementation of required waste management capacity whilst ensuring that transportation impacts will not be significant. Design of the proposals have also enabled emissions to air, noise and co-location alongside the North Wessex Downs AONB to be acceptably controlled.
7.6 In combination, these proposals represent a continuation of the approach adopted by Hills to ensure that the best and most appropriate technologies and solutions are employed at their Lower Compton waste management facility to assist both Wiltshire Council and their commercial and industrial customers with the most efficient and sustainable means of managing their wastes.
7.7 Considering the overwhelming positive effects of this proposals, their compliance with policy, their underlying and irrefutable need, and the lack of adverse impacts, it is concluded that there are no material reasons that should prevent Wiltshire Council from granting planning permission for this application in accordance with Section 38 (6) of the Planning and Compulsory Purchase Act (2004), and the Statutory Development Plan.
Adams Hendry Consulting Ltd 61 August 2011 Appendix 1 Planning Application Supporting Statement Figures
Figure 1 Lower Compton Waste Recovery Facility: Surrounding Context Figure 2 Lower Compton Waste Recovery Facility: Existing Waste Uses Figure 3 Lower Compton Waste Recovery Facility: Cross Section Locations Figure 4 Lower Compton Waste Recovery Facility: Cross Sections Sheet 1 Figure 5 Lower Compton Waste Recovery Facility: Cross Sections Sheet 2
Scale 1: 2500 @ A3 Scale 1: 25 000 @ A4
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Figure 1: Surrounding Land Uses and Designations
Scale 1: 10 000 Site of the proposals Conservation Areas Extent of extreme flood (Indicative) 0 500 metres Area of Outstanding Natural Beauty County Wildlife Sites
Based upon the Ordnance Survey map with the permission Scheduled Monuments Flooding from rivers or sea without of The Controller of Her Majesty's Stationery Office © Crown Copyright O.S. Licence No. AL 50068A defences (Indicative)
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Planning Application Area C. Waste recycling and transfer G. Compton Bassett mineral I. Low Lane mineral extraction & L. Landfill leachate treatment lagoon facility (operational) extraction and non hazardous non hazardous waste landfill (operational) Land in the ownership of the waste landfill (operational) extension (operational) Applicant D. Green waste composting M. Water attenuation lagoon facility (operational) H. Old Camp Farm mineral J. Concrete batching facility A. Materials Recovery Facility extraction and non hazardous N. Household Recycling Centre and site offices (operational) E. Vehicle parking areas waste landfill extension K. Landfill gas management (operational) (not yet commenced) system, gas engines and B. Landscape screening bund F. Site haul roads and energy recovery (operational) O. Remainder of vehicle parking weighbridge area areas Lower Compton Waste Recovery Facility, Calne, Wiltshire
Figure 3 – Sections location plan 0 100m Scale Lower Compton Waste Recovery Facility, Calne, Wiltshire
Figure 4 – Sections through the site at the time of planting Lower Compton Waste Recovery Facility, Calne, Wiltshire
Figure 5 – Sections through the site at year 10 after planting