eastsussex.gov.uk
East Sussex Waste and Minerals Monitoring Report 2017/18
February 2019
Waste and Minerals Monitoring Report 2017/18
Contents
Waste and Minerals Local Plan - Annual Monitoring Report 2017-18
1 Executive Summary 4 2 Context and Role of the Monitoring Report 7 3 Characteristics of East Sussex 9 4 Progress of the Waste & Minerals Local Plan 14 5 Duty to Co-operate 16 6 Monitoring the Plan 18 7 Overarching Strategy 21 8 Providing for Waste 29 9 Providing for Minerals 44 10 Overarching Policies 49 11 Development Management Policies 50 12 Enforcement 51 13 Monitoring Issues 54
Appendices
A Structure of the Waste and Minerals Local Plan 56 B Programme for the Waste and Minerals Development Scheme 57 C Duty to Co-operate 58 D LACW and Household Waste Arisings in East Sussex and Brighton & Hove 67 E Other Targets for the Management of LACW 69 F Permitted Waste Management Sites in East Sussex and Brighton & Hove 70 G Permitting of Significant Waste Management Capacity in East Sussex 2006/7 - 2017/18 77 H Permitted Mineral Workings in East Sussex 2017/18 80 Waste and Minerals Monitoring Report 2017/18
Contents
I Secondary and Recycled Aggregates Facilities in East Sussex and Brighton & Hove 82 J Review of Mineral Permissions 84 K Local Aggregate Assessment 87 Waste and Minerals Monitoring Report 2017/18 3 Waste and Minerals Local Plan - Annual Monitoring Report 2017-18 4 Waste and Minerals Monitoring Report 2017/18
1Executive Summary 1 Executive Summary
Introduction
1.1 East Sussex County Council, as a Waste and Minerals Planning Authority, provides planning policies for waste management and minerals production. Current policies are contained in the East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan and the East Sussex, South Downs and Brighton & Hove Waste and Sites Plan. The Council is required by the Planning and Compulsory Purchase Act 2004, as amended by the Localism Act 2011, to monitor implementation of these policies and partly does this by producing an annual Waste & Minerals Monitoring Report (AMR). The content of Monitoring Reports is prescribed by the Town & Country Planning (Local Planning) Regulations 2012.This Monitoring Report covers the period 1 April 2017 to 31 March 2018. Monitoring Reports from previous years can be found on our website www.eastsussex.gov.uk.
Key Findings of 2017/18
1.2 Below are the key findings of the East Sussex Waste and Minerals Monitoring Report 2017/18:
Progress on the Waste & Minerals Local Plan
1.3 Following the adoption of the Waste and Minerals Plan (WMP) in February 2013, East Sussex County Council working jointly with the South Downs National Park Authority and Brighton & Hove City Council adopted the Waste and Minerals Sites Plan (WMSP) in February 2017. The WMSP triggered a review of the Waste and Minerals Local Plan which is currently underway. Between September 2017 and November 2017 a Call for Evidence and Sites was undertaken. The Review timetable has been extended due to ongoing discussions regarding sand/gravel sites in the east of the County. It is now anticipated that a Regulation 18 consultation will take place during 2019.
Duty to Co-operate
1.4 East Sussex County Council continues to work jointly with the South Downs National Park and Brighton & Hove City Council in undertaking the Review of the Waste and Minerals Local Plan. The preparation of this Review has involved working closely with the Districts and Boroughs within and nearby to East Sussex. The Authorities actively participate in regional fora such as the South East Waste Planning Advisory Group and the South East England Aggregates Working Party. The Authorities published an updated Duty to Cooperate Scoping Document for the Waste and Minerals Local Plan Review in September 2017.
Providing for Waste Waste and Minerals Monitoring Report 2017/18 5
Executive Summary1
1.5 A total of 372,000 tonnes of Local Authority Collected Waste was managed in 2017/18 which is an decrease of 2,000 tonnes from 2016/17. 39% of this waste was recycled (including composted) which is below the 2015/16 WMP target of 45%, but does represent an increase from the 2014/15 outturn of 38%. The review of the Commercial & Industrial Waste arisings has been updated with 2017 data, preliminary results indicate a significant reduction in waste arisings during the recession, but these have now exceeded pre-recession levels. No new information relating to Construction, Demolition and Excavation Waste is available. The amount of Local Authority Collected Waste and Commercial & Industrial Waste being sent to landfill declined from 54,000 tonnes in 2016 to 45,000 tonnes in 2017. The proportion of Local Authority Collected Waste that was recycled, composted or recovered has broadly remained stable, from 94% in 2016/17 to 95% in 2017/18. The Waste and Minerals Plan target for recovery for 2015/16 (98%) was not achieved.
1.6 A total of 677,000 tonnes of capacity for inert material to be used for beneficial use was permitted (granted planning permission) in 2017/18. The Waste and Minerals Plan 2015/16 target for recovery and recycling capacity provision were met.
Providing for Minerals
1.7 The County Council has published the (2018) sixth Local Aggregate Assessment (LAA) for East Sussex, South Downs and Brighton & Hove (which is appended to this document). The overall picture of aggregate supply to the Plan area is of heavy dependence on imports by road, sea and rail. Significant levels of marine imports (marine dredged and crushed rock) are received through Shoreham Port and to a lesser extent Newhaven and Rye. Crushed rock, recycled aggregate and sand and gravel are imported by rail at Newhaven. Land-won sand and gravel is extracted in the east of the Plan area at Lydd with about 50% of material being consumed in East Sussex. A steady supply of recycled material is produced from construction waste management facilities across the Plan area. A continuing demand for construction materials is anticipated.
1.8 The NPPF requires that the LAA considers all supply options (land-won, marine, secondary and recycled material), and be based on a rolling average of 10 years sales data and other relevant local information. In past years the Authorities' assessment was that there were particular circumstances in this Plan Area that made it difficult to prepare the LAA totally along the lines indicated in the NPPG. Previous LAAs concluded that the assessment could not use past 10 years sales data as this was too volatile because there is a very small number of production sites and therefore there has been major variation in sales figures from nothing to more substantial output. Past LAAs instead used the Apportionment figure in the Adopted WMLP as a surrogate figure for forward planning.
1.9 In 2016 a Public Examination on the soundness and legal compliance of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan was held. Hearings focused on the whether the Plan provided a sufficient and adequate supply of aggregates. Whilst the Inspector found the Sites Plan sound, in his Report 6 Waste and Minerals Monitoring Report 2017/18
1Executive Summary
he identified that the current rate of land-won aggregates in the WMP could not be maintained with the current allocated sites and indicted the need for a Review of the aggregate minerals policies. The Authorities have since agreed to a Review of the Waste and Minerals Local Plan (WMLP) which commenced in September 2017. The Review will re-evaluate the aggregate provision figures for the Plan Area.
1.10 Clay and gypsum continued to be extracted at levels that support brick and tile production, plasterboard and cement production; it continues to be extracted at the levels in accordance with policy.
Overarching Policies & Development Management Policies
1.11 A review of the Overarching Policies and Development Management Policies is being undertaken as part of the Review into the Waste and Minerals Local Plan. The results will be published in due course.
Enforcement
1.12 The number of cases outstanding has remained historically low, with the caseload standing at 12 in the third quarter of 2018. This remains well below the peak in 2007.(1)
1 The quarters referred to are calendar quarters. Waste and Minerals Monitoring Report 2017/18 7 Context and Role of the Monitoring Report2 2 Context and Role of the Monitoring Report
2.1 East Sussex County Council, as a Waste and Minerals Planning Authority, provides planning policies for waste management and minerals production, which are prepared jointly with Brighton & Hove City Council and the South Downs National Park Authority. The Council is required to monitor implementation of these policies by the provisions in the Planning and Compulsory Purchase Act 2004 and does this by producing a Waste & Minerals Monitoring Report, which also provides data and commentary on trends in waste management and minerals production.
2.2 This Monitoring Report covers the period 1 April 2017 to 31 March 2018. AMRs from previous years can be found on the Council's annual monitoring report webpage.
2.3 Some reporting of significant developments that have taken place between 31 March 2018 and the preparation of this document are also included.
2.4 This Monitoring Report covers only waste and minerals matters. Other forms of development and development planning in the Plan Area, for example housing or employment land, are dealt with by the City, Borough, and District Councils, and the National Park Authority in their own existing and emerging Local Plans and Monitoring Reports.
2.5 The Monitoring Report reports against the following key monitoring tasks for the Plan Area which includes Brighton & Hove and part of the South Down National Park:
Assessing the extent to which policies in the Waste and Minerals Plan and Waste and Minerals Sites Plan are being implemented; reporting on the Review into the Waste and Minerals Local Plan against the timetable and milestones in the Minerals and Waste Development Scheme; checking performance against indicators and local objectives for waste and minerals.
Existing Planning Policy Framework
2.6 The Development Plan for the area comprises the Waste and Minerals Plan (WMP), the Waste and Minerals Sites Plan (WMSP), as well as all the Local Plans produced by the district and borough planning authorities, and the South Downs National Park Authority (including the plans adopted by the Brighton & Hove City Council). A review of the Waste and Minerals Local Plan which consists of the WMP, WMSP and the East Sussex and Brighton & Hove Construction and Demolition SPD is currently being undertaken. Planning legislation requires planning applications to be determined in accordance with the Development Plan, unless material considerations indicate otherwise. National Policy is a material consideration. 8 Waste and Minerals Monitoring Report 2017/18 2Context and Role of the Monitoring Report
Waste and Minerals Plan
2.7 The Waste and Minerals Plan was adopted on 19 February 2013 following a Public Examination at which the Planning Inspector found the Plan "sound". The Plan sets out the policy framework for waste and minerals development up to 2026. The Plan has strategic and development management policies but the Plan does not allocate specific sites. The Plan includes a set of monitoring indicators.
Waste and Minerals Sites Plan
2.8 The Waste and Minerals Sites Plan (WMSP) was the subject of a Public Examination in the summer of 2016. In November 2016 the Inspector holding the Public Examination found the WMSP, subject to a number of modifications, to be 'sound' and legally complaint. The WMSP was adopted in February 2017. This plan replaced the remaining saved policies that were contained in the Waste Local Plan (2006) and the Minerals Local Plan (1999).
National Policy
2.9 The revised National Planning Policy Framework (NPPF) was published on 24 July 2018 replacing the 2012 framework. The National Planing Policy for Waste was published on the 16 October 2014. (2)
2.10 Planning Practice Guidance was first published on 6 March 2013. Planning Practice Guidance - Waste was subsequently published on the 16 October 2014. This document guides how the NPPF is interpreted, how planning applications should be determined, and how local plans should be prepared. Since the publication of the guidance sections have been, and continue to be, periodically updated.
Local Aggregate Assessment
2.11 The NPPF states that the relevant authorities should prepare an annual Local Aggregate Assessment (LAA). The NPPF also states that authorities should plan for a steady and adequate supply of aggregates. It is advised that the LAA is based on a rolling average of 10 years sales data and other relevant local information. The LAA has to consider all supply options including land won, marine, secondary and recycled material. The County Council has previously decided not to use 10 years sales data for the Plan Area as this is too volatile to form the basis for robust planning. The LAA has previously utilised a substitute figure for land won aggregates based on the figure for land-won provision used in the adopted Waste and Minerals Plan. The Authorities have monitored how supplies change over time. As referred to above, the WMP minerals policies are currently under review and the responses from the call for evidence and sites consultation are being analysed. The Review is re-evaluating the aggregate provision figures for the Plan Area. The LAA 2018 is appended to this Report.
2 Between the writing and publication of this monitoring report a second revised National Policy Framework was released in February 2019. Waste and Minerals Monitoring Report 2017/18 9
Characteristics of East Sussex3 3 Characteristics of East Sussex
Environmental Designations
3.1 The South Downs National Park (SDNP) was officially designated on 31 March 2010, and replaced the Sussex Downs Area of Outstanding National Beauty (AONB). The boundary of the SDNP is different to that of the AONB, and includes the town of Lewes and other areas to the north of the AONB. The National Park and the High Weald AONB together cover two thirds of the Plan Area. (See Maps 1 and 2 below).
3.2 Other tracts of land are additionally designated as being of international and national environmental importance and are shown in Map 2 below.
Demography
3.3 The rate of production of waste and consumption of minerals has been shown to have some relationship with population growth; an increasing population produces more waste and has a greater demand for minerals.
3.4 In 2016 the Plan Area had a total population of approximately 836,800 of which about two thirds live in East Sussex (see below) and the remainder in Brighton & Hove. Approximately 30,000 people live within the Plan Area part of the South Downs National Park. Over the period 2016-2026, the population in East Sussex is predicted to increase by approximately 7.35%. The average household size is expected to decrease from 2.22 in 2014 to 2.06 in 2039.
Table 1 East Sussex and Brighton & Hove Population Projections 2016 to 2041
Year East Sussex Brighton and Hove Plan Area Population Population Population
2016 549,600 287,200 836,800 2021 571,600 296,700 868,300 2026 594,000 304,300 898,300 2031 614,400 313,300 927,700 2036 632,700 320,700 953,400 2041 649,100 327,300 976,400
3.5 The figures in the table above are rounded to the nearest 100, and are based on the Office for National Statistics: Sub-national population projections for England, 2016-based, (released 24 May 2018)(3)
3 https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populationprojections/datasets/localauthoritiesinenglandtable2
12 Waste and Minerals Monitoring Report 2017/18
3Characteristics of East Sussex
Economy
3.6 The rate of production of waste and consumption of minerals has been shown to have a relationship with economic activity; in general a more buoyant economy produces more waste and has a greater demand for minerals. The structure of the economy in the Plan Area affects the nature and volume of commercial and industrial waste arisings and the need for particular minerals.
3.7 In 2018, 75.8% of jobs in the Plan Area were in the service sector, 5.3% in production, 13.5% in construction and 5.4% in agriculture, forestry and fishing. 31.2% of all people who work in East Sussex are employed in the professional, scientific & technical sectors, business administration and support services, education or health. Wholesale and retail trade; and accommodation and food service activities account for 19.8% of people who work in the County. (4) In Brighton & Hove the employment structure is dominated by high value sectors such as health, business & public administration, professional, scientific & technical sectors & education.
3.8 The economy in East Sussex is characterised by its high number of small businesses. 90.3% of businesses in East Sussex employ less than 10 people, which is slightly higher than the national average of 89.5%. In Brighton & Hove, 90.7% of businesses employ less than 10 people. Only 0.2% of businesses in East Sussex employ over 250 people, compared to 0.3% of businesses in Brighton and Hove and the national average of 0.4%. (5) Tourism and the conference trade is a key element in the local economy, contributing around 10 million visitors per annum and significantly increasing the amount of waste to be managed.
3.9 The South Downs within the Plan Area has a predominantly rural economy, with the exception of the busy market town of Lewes.
Local Enterprise Partnerships
3.10 Two Local Enterprise Partnerships (LEPs) cover the Plan Area. The 'Coast to Capital' LEP includes Brighton & Hove, while East Sussex is part of the South East LEP that also covers Kent and Essex. LEPs are partnerships between local authorities and businesses that aim to drive economic growth and job creation.
Enterprise Zones
3.11 Newhaven Enterprise Zone officially commenced in April 2017. It is estimated that EZ status will lead to the creation of around 55,000m² of new commercial floor space, refurbish a further 15,000m² of commercial floor space and create and sustain around 2,000 jobs over the Zone’s 25-year lifespan. Alongside the other Newhaven-focused regeneration activity, the Enterprise Zone has the potential to have a significant positive impact on local residents, businesses and economic growth.
4 "Local business units by industry group UK SIC(2007), 2009-2018 - districts" - East Sussex in Figures: http://www.eastsussexinfigures.org.uk/webview/welcome.html 5 "Business enterprises by size of business, 2004-2018 - districts" - East Sussex in Figures: http://www.eastsussexinfigures.org.uk/webview/welcome.html" Waste and Minerals Monitoring Report 2017/18 13
Characteristics of East Sussex3
3.12 Further detail on the environmental and social characteristics of East Sussex and Brighton & Hove is available on East Sussex in Figures . 14 Waste and Minerals Monitoring Report 2017/18 4Progress of the Waste & Minerals Local Plan 4 Progress of the Waste & Minerals Local Plan
Progress on the Waste & Minerals Local Plan (WMLP)
4.1 East Sussex County Council, as a Waste and Minerals Planning Authority, provides planning policies for waste management and minerals production. Current policies are contained in the East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan and Waste and Minerals Sites Plan (WMLP). (6)
4.2 The WMLP is being jointly reviewed by East Sussex County Council, Brighton & Hove City Council and the South Downs National Park Authority (SDNPA). The WMLP also includes a Supplementary Planning Document (SPD) that covers the production and management of construction and demolition waste. Separately the Authorities produce Statements of Community Involvement.
Minerals & Waste Development Scheme
4.3 A Minerals and Waste Development Scheme (MWDS) is produced by the County Council to provide a timetable for the production of these documents which is mirrored by Brighton & Hove City Council and the South Downs National Park Authority.
4.4 In February 2017 a revised Minerals and Waste Development Scheme, (7) containing the timetable for the preparation of the First Review of the Waste and Minerals Local Plan was approved by the County Council.
Waste & Minerals Plan
4.5 In February 2013 the Waste and Minerals Plan was adopted, and it is now being used for development management purposes, including the determination of planning applications.
Waste & Minerals Sites Plan
4.6 The Waste and Minerals Sites Plan was adopted in February 2017. The Site Plan identifies specific areas of land where it is considered that the management of waste and production of minerals could take place in the future. The document includes allocation of land to meet the requirements for additional capacity for the management of waste and the identification of Minerals Safeguarding Areas.
6 http://www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste/amr1.Htm 7 http://www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste Waste and Minerals Monitoring Report 2017/18 15 Progress of the Waste & Minerals Local Plan4
Waste and Minerals Local Plan Review
4.7 The Authorities are currently undertaking a review of the Waste and Minerals Plan and Waste and Minerals Sites Plan (collectively known as the Waste and Minerals Local Plan). This review focuses on minerals provision and the safeguarding of minerals and minerals related infrastructure. The Authorities are also using the review as an opportunity to improve the effectiveness of some policies. A Call for Evidence and Sites was held in 2017. The Authorities are currently preparing a Draft Revised Policies Document which is scheduled to be be available for public consultation in 2019.
Construction & Demolition Waste SPD
4.8 The C&D Waste SPD provides additional guidance concerning the production and management of C&D waste. The SPD needs to be reviewed to ensure that it reflects the ongoing changes to planning policy and regulations relating to Site Waste Management Plans(8). However, due to ongoing constraints on resources it has not yet been possible to complete this review.
8 These were revoked on 1 December 2013 16 Waste and Minerals Monitoring Report 2017/18
5Duty to Co-operate 5 Duty to Co-operate
Duty to Co-operate
5.1 Regulation 34 of The Town and Country Planning (Local Planning) (England) Regulations 2012 requires local planning authorities to provide details in their monitoring reports of the steps taken to comply with the 'Duty to Co-operate'. This duty is set out in Section 110 of the Localism Act 2011 and requires county councils, local planning authorities and other bodies as prescribed by Regulation 4 of The Town and Country Planning (Local Planning) (England) Regulations 2012, to co-operate with each other. The Duty to Co-operate is limited to those topics that are considered as a strategic matters. Waste and Minerals is one such strategic matter. A log of activities undertaken by the Council in relation to the Duty can be found in Appendix C.
Regional Fora
5.2 The Authorities' membership of waste and minerals planning fora which cover the whole of the South-East (as described below) has been an important basis for cross boundary liaison on key strategic waste management and minerals production matters.
5.3 The South East Waste Planning Advisory Group (SEWPAG) provides a regular opportunity for cooperation on planning for waste management across administrative boundaries in the South-East.
5.4 The South East England Aggregates Working Party (SEEAWP) exists to co-ordinate the steady and adequate supply of aggregate across the South-East.
5.5 The Ashdown Forest Officer Group exists to address the cross border issue of nitrogen levels in the Ashdown Forest Special Area of Conservation.
Waste and Minerals Local Plan Review
5.6 A review of the Waste and Minerals Local Plan commenced in September 2017, and there has been continuing co-operation between East Sussex County Council, Brighton & Hove City Council, and the South Downs National Park Authority and the other prescribed bodies. The Authorities published a Duty to Cooperate Scoping Document for the Local Plan Review in September 2017. Four cross boundary strategic matters have been identified as requiring particular attention and include the following:
Minerals Provision Safeguarding Minerals & Minerals Infrastructure Land-won aggregates provision in Plan Area Ashdown Forest Special Area of Conservation (SAC) Waste and Minerals Monitoring Report 2017/18 17
Duty to Co-operate5
5.7 Further information on cooperation associated with these matters is set out below.
5.8 Initial meetings were held with the Authorities where a Policy Assessment was undertaken to determine the effectiveness and relevance of the existing policies within the Waste and Minerals Local Plan. The outcome of these meetings fed into formulating the proposed scope of the review. As a result of the calls for evidence and sites consultation, four responses out of the nineteen received to the consultation specified that the preferred approach would be by correspondence only or where consultation is required by legislation. Meetings with the district and borough councils within the Plan Area were also held.
5.9 The effect of development on Ashdown Forest SAC is a cross border issue. This is being considered by the relevant authorities as part of regular officer group meetings originally set up by the South Downs National Park Authority. In November 2017, discussions commenced on the formation of a Statement of Common Ground on the issue in relation to this matter.
5.10 Several meetings were held in 2018 to discuss cross boundary issues relating to the Plan review. These included discussions with Kent County Council, West Sussex County Council and Natural England.
Other Communications
5.11 East Sussex County Council, Brighton & Hove City Council, and the South Downs National Park Authority receive regular communication from other prescribed bodies in relation to the Duty to Co-operate. Cross boundary matters requiring particular attention include waste data, continued provision of adequate waste management capacity, and the safeguarding of the Brentford Rail Head to which bottom-ash from the Newhaven Energy Recovery Facility is transported by rail, and import of land-won and marine aggregates. Full details of the activities undertaken in relation to cooperation over strategic issues is set out in Appendix C. 18 Waste and Minerals Monitoring Report 2017/18
6Monitoring the Plan 6 Monitoring the Plan
6.1 Section 7 of the Waste and Minerals Plan sets out a comprehensive list of monitoring indicators. These have been reviewed, and in places refined. Further details can be found in the following sections:
Table 2
Monitoring Policies Report Section
7. Overarching WMP1 - Presumption in Favour of Sustainable Development Strategy WMP2 - Minerals and waste development affecting the South Downs National Park
8. Providing for *WMP3a - Promoting waste prevention, re-use and waste Waste awareness
*WMP3b - Turning waste into a resource
*WMP3c - Production of energy from waste
*WMP3d - Minimising and managing waste during construction, demolition and excavation
*WMP3e - Waste management in new development
WMP5 - Provision of Built Waste Facilities
WMP6 - Safeguarding Waste Sites
WMP7a - Sustainable locations for waste development (excluding land disposal)
WMP7b - More detailed criteria for waste development
WMP8a - Land disposal of non-inert waste
WMP8b - Deposit of inert waste on land for beneficial purposes
WMP8c - Management of landfill gas
WMP9a - Hazardous waste
WMP9b - Low level radioactive waste
WMP10 - Management of waste-water and sewage sludge Waste and Minerals Monitoring Report 2017/18 19
Monitoring the Plan6
Monitoring Policies Report Section
9. Providing for *WMP4 - Sustainable provision and use of minerals in the Plan Minerals WMP11 - Provision of Aggregates
WMP12 - Provision of Gypsum
WMP13 - Provision of Clay
WMP14 - Safeguarding Minerals Resources
WMP15 - Safeguarding Wharves and Railheads
WMP16 - Exploration for Oil and Gas
10. Overarching WMP17 - Restoration Policies WMP18 - Transport - road, rail and water
WMP19 - Co-location of complementary facilities
WMP20 - Community involvement and benefits
WMP21 - Opportunities for sustainable waste management and minerals production in other developments
WMP22 - Expansion and alterations to waste facilities
11. Development WMP23a - Design principles for built waste facilities Management Policies WMP23b - Operation of sites WMP24a - Climate change
WMP24b - Resource and energy
WMP25 - General amenity
WMP26 - Traffic Impacts
WMP27 - Environment and Environmental Enhancement
WMP28a - Flood risk
WMP28b - Groundwater and water quality 20 Waste and Minerals Monitoring Report 2017/18
6Monitoring the Plan
* Policies WMP3a-e and WMP4 in the Waste and Minerals Plan are located in the Overarching Strategy section. However in the Monitoring Report, they are considered under Providing for Waste and Providing for Minerals respectively.
6.2 The Policies within the Waste and Minerals Sites Plan build on those in the Waste and Minerals Plan and are being monitored through the monitoring of the policies above. Waste and Minerals Monitoring Report 2017/18 21
Overarching Strategy7 7 Overarching Strategy
7.1 The overarching strategy of the Waste and Minerals Plan sets out what the Authorities want to achieve in terms of waste and minerals development and underpins the Plan's detailed policies. It is governed by four principal policies:
Policy WMP1 - Presumption in Favour of Sustainable Development Policy WMP2 - Minerals and Waste Development in the South Downs National Park Policy WMP3(a - e) - Implementing the Waste Hierarchy Policy WMP4 - Sustainable Provision and Use of Minerals
7.2 This section of the AMR will concentrate on Policies WMP1 and WMP2. Policies WMP3 and WMP4 are reported under the sections Providing for Waste and Providing for Minerals, respectively.
Progress of the Overarching Strategy Policies
Policy WMP1 - Presumption in Favour of Sustainable Development
7.3 The presumption in favour of sustainable development is a key aspect of Central Government planning policy and is at the heart of the National Planning Policy Framework. The inclusion of this policy as part of East Sussex County Council's overarching strategy is to ensure sustainable development is at the heart of planning policy in the county and that decisions are taken in line with this presumption.
7.4 The policy reflects the overall approach of the plan. In reflection of this, Policy WMP1 shall be monitored through assessing the performance of the Plan's policies more generally, as set out elsewhere in the AMR, and referring back to how decisions reflect the presumption in favour of sustainable development. The indicator direction in the table below reflects the progress reported in this Monitoring Report.
7.5 The table below also shows the number of times each policy within the Plan has been used to date and in the last year. The use of policy provides an indication of the reliability of any monitoring of each policy, i.e there is more information likely to be available to inform monitoring where a policy has been used more often. (Note, if a policy is cited more than once in a development management report, it only is counted once.) 22 W
Table 3 Number of times policy cited in reports. (East Sussex and Brighton & Hove including the National Park within. 7 aste Overarching
19/02/13 (date of adoption) - 01/04/13-31/03/14 01/04/14-31/03/15 01/04/15-31/03/16 01/04/16-31/03/17 01/04/17-31/03/18 01/04/18 - 31/12/18 and 31/03/13 ( end of monitoring (12 months) (12 months) (12 months) (12 months) (12 months) (6 months)
period) Miner als
County Matter 1 15 16 19 14 16 11 Monitoring decisions issued
Policy Purpose Applications Applications 01/04/17 Comment (If applicable) Indicator Report 19/02/13 - - 31/03/18 Direction date 2017/18 Overarching Strategy
WMP1 - Presumption in To ensure that decisions are taken in line with the presumption in favour of sustainable 9 1 # Strategy Favour of Sustainable development as set out in the National Planning Policy Framework (NPPF). Development
WMP2 - Minerals and waste To ensure development is sustainable and appropriate to the purposes and duties of the South 6 1 + development affecting the Downs National Park Authority. South Downs National Park
WMP3a - Promoting waste To prevent waste occurring in order to reduce the amount of waste treatment capacity needed. 2 0 # prevention, re-use and waste To provide commitment to contributing to wider strategies about waste awareness and awareness sustainable resource use; To facilitate movement to the upper tiers in the waste hierarchy, and particularly to increase preparation for re-use, which will involve industries and developments beyond waste management facilities; For development management authorities, this policy provides a clear framework for ensuring that sustainable waste management is taken into account in planning decisions about non-waste developments.
WMP3b - Turning waste into To encourage the development of new waste recycling and recovery infrastructure which 47 7 2015/16 targets for LACW O / # a resource ensures waste which has been produced is managed as far up the waste hierarchy as possible recycling and recovery not and in a manner which minimises the production of greenhouse gases. met. Recycling / recovery rates consistent for last three years. No new information on C&I or CDEW.
WMP3c - Production of To recognise that energy recovery is lower in the waste hierarchy than other processes so 1 0 # energy from waste proposals will need to be justified accordingly, and ensure that where energy recovery does take place, the capture of heat and/or energy from those processes should be in the most Policy Purpose Applications Applications 01/04/17 Comment (If applicable) Indicator 19/02/13 - - 31/03/18 Direction date
sustainable and efficient manner possible. This includes taking into account the EU Waste Framework Directive as well as Government policy about increasing use of renewable energy and decentralised power sources, and more broadly about mitigating against climate change.
WMP3d - Minimising and To ensure that the waste hierarchy is taken into account during construction and demolition 7 2 # managing waste during activities associated with all new development which require planning permission (not just construction, demolition and those that involve the management of waste); To encourage architects, project funders, and excavation contractors to minimise waste through the life-cycle of a project by 'designing out waste';This policy can be implemented by all planning authorities in the Plan Area.
WMP3e - To ensure that new developments take place in a manner which allows for the convenient 0 0 # sustainable management of waste. For example the policy will ensure that, where appropriate, Waste management in new space is made available for the storage and collection of separated recyclable materials e.g. development bring banks; It is envisaged that this policy will be implemented by all planning authorities in the Plan Area. Overarching
WMP4 - Sustainable provision To deliver the sustainable use and production of minerals using the minerals hierarchy, for 2 0 and use of minerals in the example by promoting secondary and recycled materials. Plan
Providing for Waste
WMP5 - Provision of Built To identify the future need for recycling and recovery facilities, and avoid any adverse effects 3 0 2015/16 combined target + Waste Facilities that over-provision of capacity could bring; To provide flexibility in the Plan to demonstrate met. W aste 'net self sufficiency' by allowing for additional recovery capacity of an amount equivalent to that amount that is identified as needing to be exported for disposal to land. and
WMP6 - Safeguarding Waste To safeguard existing waste management facilities as appropriate. To safeguard certain areas 20 3 This policy is currently # Miner Sites in order to support the delivery of waste management facilities in the most appropriate being considered as part
locations. To safeguard Waste Local Plan site-specific allocations for waste management of the review into the Strategy als facilities. WMLP. Monitoring
WMP7a - Sustainable To identify broad areas (Areas of Focus) within the Plan Area within which the best 34 3 Most / all development + locations for waste opportunities for locating waste recycling and recovery facilities are more likely to be found. located with Area of development (excluding land Focus. disposal) The Areas of Focus identified in this policy, and shown on the Waste Key Diagram, will guide Report preparation of the Waste and Minerals Sites Plan. WMP7b - More detailed 10 1 + criteria for waste 2017/18 development 7 23 24 W 7
Policy Purpose Applications Applications 01/04/17 Comment (If applicable) Indicator aste 19/02/13 - - 31/03/18 Direction Overarching
date and
WMP8a - Land disposal of To identify the need for land disposal of non-inert and inert waste. To provide a policy 1 1 # Miner non-inert waste approach if such applications are submitted and to ensure that landfill gas produced by land
disposal facilities is captured and used as a fuel. als
WMP8b - Deposit of inert 11 3 + Monitoring waste on land for beneficial purposes
WMP8c - Management of 4 2 # landfill gas Report
WMP9a - Hazardous waste To allow for new waste water treatment capacity to be developed as appropriate. To provide 1 0 # 2017/18 additional waste water treatment works capacity in the Hailsham area and additional sewage sludge treatment capacity in the period up to 2026, in accordance with identified needs. Appropriate sites for both types of facilities will be considered in more detail in the Waste Strategy and Minerals Sites Plan.
WMP9b - Low level This policy is intended to ensure that: where viable, Low Level Radioactive Waste (LLW) 0 0 # radioactive waste management capacity is provided in the Plan Area such that LLW can be managed close to its source of production;in particular, the development of LLW incineration capacity, if incorporated as part of a wider scheme for the Plan Area, can be supported; additional capacity could be provided to manage LLW from beyond the Plan Area but only where this would help achieve 'net self-sufficiency'; and where additional capacity is developed for the management of LLW from beyond the Plan Area, that this capacity makes a significant contribution to the management of LLW arising within the Area.
WMP10 - Management of To allow for new waste water treatment capacity to be developed as appropriate. To provide 16 2 # waste-water and sewage additional waste water treatment works capacity in the Hailsham area and additional sewage sludge sludge treatment capacity in the period up to 2026, in accordance with identified needs. Appropriate sites for both types of facilities will be considered in more detail in the Waste and Minerals Sites Plan.
Providing for Minerals
WMP11 - Provision of To account for the proposed government apportionment for aggregates in order to assess the 1 0 This policy is currently # Aggregates need for any further allocations of primary aggregates production. being considered as part of the review into the WMLP.
WMP12 - Provision of Gypsum To safeguard and maintain supplies to and from the British Gypsum works throughout the Plan 1 0 # period. Policy Purpose Applications Applications 01/04/17 Comment (If applicable) Indicator 19/02/13 - - 31/03/18 Direction date
WMP13 - Provision of Clay To safeguard and maintain sufficient supplies of clay for brick and tile manufacture. 1 0 #
WMP14 - Safeguarding To set out how mineral resources will be safeguarded by identifying Mineral Safeguarding 1 0 This policy is currently # Minerals Resources Areas (areas of known resources) and Mineral Consultation Areas (areas where the district or being considered as part borough council should notify the Authorities of any alternative development proposals). of the review into the Identifying Consultation Areas does not necessarily imply that the resource will be worked. WMLP.
WMP15 - Safeguarding To safeguard railheads, wharves and rail sidings for existing and future mineral imports and 2 0 This policy is currently # Wharves and Railheads processing. In particular to safeguard overall mineral wharf capacity in ports subject to no being considered as part net loss of capacity, and to encourage co-location with processing capacity. of the review into the WMLP.
WMP16 - Exploration for Oil To provide a policy framework for any potential oil and gas exploration, appraisal and 0 0 # Overarching and Gas production.
Overarching Policies
WMP17 - Restoration To secure appropriate restoration of mineral workings and waste sites. Restoration should 6 2 # seek environmental and amenity benefits reflecting local circumstances and relevant landscape and biodiversity objectives. Proposed afteruses are likely to require ongoing management. W
WMP18 - Transport - road, To minimise the environmental and amenity effects of the transport of waste and minerals 4 2 # aste rail and water by promoting rail and water transport as an alternative to road transport; (Detailed,
site-specific, transport impacts are covered by Policy WMP 26.) and Miner WMP19 To encourage co-location of complementary waste or minerals processing facilities and 1 0 # associated industries, where this would offer either operational or cost efficiencies or transport Strategy als - Co-location of benefits. complementary facilities Monitoring
WMP20 - Community To encourage developers to take a more proactive approach and engage with local communities 1 1 # involvement and benefits as early as possible to help avoid misunderstandings and reduce anxiety related to waste or Report minerals-related developments, and also to ensure that where there are potential benefits for the community, that those benefits are realised by people living or working close by; The
policy aims to readdress a perceived lack of engagement between host communities and 2017/18 developers/the waste and minerals industry in the submission of planning applications for
waste or minerals developments. It seeks not only to reduce negative experiences of 7 communities but actually to secure positive benefits for host communities. 25 26 W 7
Policy Purpose Applications Applications 01/04/17 Comment (If applicable) Indicator aste 19/02/13 - - 31/03/18 Direction Overarching
date and
WMP21 - Opportunities for To ensure that objectives of sustainable waste management and minerals production are 0 0 # Miner sustainable waste considered in the preparation and determination of non-waste and minerals applications,
management and minerals where appropriate; This policy is concerned with maximising opportunities for improving the als production in other sustainable management and transport of waste that has already been produced - prevention developments of waste is dealt with elsewhere in this Plan; This policy is not intended to address the Monitoring management of waste arising from construction and demolition which is dealt with separately by Policy WMP 3d; It is envisaged that this policy will be implemented by all planning authorities in the Plan Area. Report WMP22 - Expansion and To enable expansions of capacity or alterations to operations within existing waste management 32 4 Expansions to existing + alterations to waste facilities facilities. waste sites have come forward. 2017/18
Development Management Policies Strategy
WMP23a - Design principles To provide guidance about more detailed design and operational aspects for built waste 36 7 Evidence of application of + for built waste facilities facilities, and to support the spatial policies regarding waste facilities. It focuses on policy. non-functional components of waste facilities and does not seek to address issues associated with technical design, but recognises that the interface between the two is important; The policy also links with the Community Involvement and Benefits policy (WMP 20), about involving WMP23b - Operation of sites host communities in the design of facilities, with the Climate Change policy (WMP 24) which 12 2 Evidence of application of + seeks design aspects which contribute to minimising greenhouse gas emissions, and with the policy. Resource and Energy policy (WMP 24b).
WMP24a - Climate change To set out how waste and minerals developments should seek to mitigate and adapt to climate 1 0 # change; It supplements the guidance about climate change set out in the National Planning Policy Framework because a) the Plan Area is coastal so climate change is a particular concern, and b) national policy about design is not specific to waste or minerals developments; Proposals WMP24b - Resource and for waste and minerals development should set out how they will minimise greenhouse gas 0 0 # energy emissions, either through design, construction or operations; Diversion of waste from landfill and movement up the waste hierarchy also contributes to mitigating climate change - this is covered in Policy WMP 3 Implementing the Waste Hierarchy. Policy WMP 24 deals with the more detailed aspects of how waste or minerals operations themselves can take measures to mitigate and adapt to the impacts of climate change.
WMP25 - General amenity To protect local communities from the potential negative impacts of waste and minerals 80 12 Evidence of application of + development such as those resulting from noise, dust, fumes, windblown litter, and visual policy. intrusion.
WMP26 - Traffic Impacts To ensure that proposals fully address the site-specific issues related to road transport and 59 10 Evidence of application of + traffic of waste or minerals developments; (This policy links with WMP 18 Transport - Road, policy. Rail and Water.) Policy Purpose Applications Applications 01/04/17 Comment (If applicable) Indicator 19/02/13 - - 31/03/18 Direction date
WMP27 - Environment and To protect and enhance the built and natural environment including: Natural assets; 44 10 Evidence of application of + Environmental Enhancement Biodiversity; Landscapes; Historic environment; Geology and geomorphology; Heritage assets; policy. and Landscape character. (This policy also links with the policy about design of built facilities.)
WMP28a - Flood risk To ensure that flood risk and potential impacts on groundwater and water quality are taken 21 4 Evidence of application of + into consideration in determining waste and minerals development proposals. policy.
WMP28b - Groundwater and 8 2 Evidence of application of + water quality policy.
Indicator direction: # Insufficient Information; + Positive ; - Negative; O: No change. Overarching W aste and Miner Strategy als Monitoring Report 2017/18 7 27 28 Waste and Minerals Monitoring Report 2017/18
7Overarching Strategy
Policy WMP2 - Minerals and Waste Development in the South Downs National Park
7.6 Parts of East Sussex, including Lewes, are located within The South Downs National Park. Policy WMP2 seeks to ensure that development is sustainable and appropriate to the purpose and duties of the South Downs National Park in accordance with the wider presumption in favour of sustainable development as outlined in Policy WMP1.
7.7 Policy WMP2 outlines the considerations taken into account with regards waste and minerals development within the National Park. The effectiveness of the policy is monitored through assessment of the levels of waste capacity and minerals extraction that have been permitted in the National Park within the monitoring period.
Table 4
Monitoring Application Additional Capacity? Period
2013/14 SNDP/12/02843/CW - Greystone Quarry - expansion of N fridge processing area. [Approved]
2014/15 SDNP/15/00790/CW - Falmer Court Farm - Retention N of imported waste material and profiling of existing materials to raise the level of a paddock for drainage improvements. [Refused]
2015/16 SDNP/15/05347/CW - Land at Northern Tip of Industrial Y - 15,000 tpa Recycling. Yard, New Road Industrial Area, Newhaven, East Sussex, Note: this site is mostly BN9 0HE - Change of use of existing Industrial unit and within East Sussex (ESCC yard into a construction and demolition waste transfer Planning Reference: station. [Approved] LW/767/CM), with a small area within the South Downs National Park.
2016/17 SDNP/16/04886/CNDC - Novington Sand Pit, Plumpton Permitted reserves of soft Lane, Plumpton, East Sussex - Variation of condition 2 sand can continue to be of LW/386/CM to allow the extraction of sand and extracted for 10 years restoration of the site to be completed not later than 2nd October 2026. [Approved]
2017/18 SDNP/17/02297/FUL - Golf Farm, Devil's Dyke Road, Y - 670,000 tonnes inert fill. Brighton, BN1 8YJ - Re-landscaping farmland through the importation of approximately 670,000 tonnes of inert material. [Approved] Waste and Minerals Monitoring Report 2017/18 29
Providing for Waste8 8 Providing for Waste
Waste in East Sussex
8.1 It is currently estimated that around 1.7 million tonnes of solid waste are handled in East Sussex and Brighton & Hove each year. The main types are:
Local Authority Collected Waste (LACW) - LACW is waste that is collected by local authorities, and it is estimated to make up about 21% of all wastes in the Plan Area. Household waste comprises approximately 95% of municipal waste, the remainder coming from sources such as street sweepings and public parks and gardens. Commercial and Industrial Waste (C&I)- This is produced from shops, food outlets, businesses, and manufacturing activities and comprises about 27% of wastes in the Plan area. Construction, Demolition and Excavation Waste (CDEW)- Produced from building activity, with a considerable proportion of it considered to be inert. CDEW comprises an estimated 51% of all waste arisings. Other wastes- This includes hazardous waste, liquid waste (other than wastewater), and wastes arising from the agricultural sector. Although hazardous waste streams only make up approximately 1% of the total waste stream, they still need to be planned for and often require specialist treatment facilities and include stringent environmental controls.
Figure 1 Proportion of Solid Waste Arising in East Sussex and Brighton & Hove 30 Waste and Minerals Monitoring Report 2017/18
8Providing for Waste
8.2 The Authorities monitor the quantity of local authority collected waste but it does not directly monitor the quantity of commercial and industrial waste or construction, demolition and excavation waste arisings. No direct monitoring of C&I and CDEW waste management is undertaken but estimates of arisings can be derived from data provided by the Environment Agency and other surveys.
8.3 There are various facilities to treat and dispose of waste, including recycling centres, transfer stations, treatment sites and landfill sites. A list of current sites with planning permission for the management of waste in East Sussex and Brighton & Hove, together with their estimated capacities, is provided in Appendix F.
Local Authority Collected Waste
Arisings
8.4 Municipal waste arisings and management for the Plan Area for the years 2006/07 to 2017/18 are shown in Figure 2 below.
Figure 2 Local Authority Collected Waste Arisings and Management for the Plan Area 2006/07 - 2017/18
8.5 Local authority collected waste and household arisings fell slightly in 2017/18 compared to 2016/17. LACW arisings have been depressed for a number of years, and this has been attributed to the economic downturn(9). However in the past two years arisings have returned to forecast levels. Over the long term local
9 Historically there has been a relationship between economic growth and growth in waste arisings. Waste and Minerals Monitoring Report 2017/18 31
Providing for Waste8 authority collected arisings are still expected to grow with increased population and number of households. Any return to significant economic growth may also have an effect.
Table 5 Estimated Future Arisings for LACW
Year Min Growth (Tonnes) Max Growth (Tonnes) 2015/16 361,000 392,000 2020/21 356,000 414,000 2025/26 352,000 437,000
Management
8.6 Tables 6 and 7 on the following pages, together with Figure 2 above, show the total municipal and household waste arisings in East Sussex and Brighton & Hove by management approach and the percentage for each management type over the last five years(10).
8.7 Table 6 shows that since 2010/11 there has been a significant increase in the amount of waste being diverted to energy recovery along with a corresponding decrease in the amount sent to landfill. The proportion of waste recycled has also increased. The increase in recovery is due to the Newhaven ERF coming on stream which allows waste which was previously exported to ERFs and landfills in neighbouring areas to be treated within the Plan Area's boundaries. This in turn reduces the considerable distance it previously travelled by road.
8.8 There are currently no non-inert landfills operating or proposed for development within the Plan Area.
10 The Waste Local Plan definition of recovery includes recycling, reuse and composting as well as energy recovery 32 W
Table 6 Local Authority Collected Waste in East Sussex and Brighton & Hove (tonnes) 8 aste P
2006/07 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 and roviding
Recycled 73,650 81,108 80,463 77,993 77,845 74,285 72,513 79,042 83,746 98,449 87,680 86,461 Miner (19%) (21%) (22%) (21%) (21%) (21%) (20%) (22%) (23%) (26%) (23%) (23%) als Reuse 10,975 10,187 9,714 8,659 6,938 7,300 9,917 10,816 12,557 12,539 14,050 13,531 Monitoring (3%) (3%) (3%) (2%) (2%) (3%) (3%) (3%) (3%) (3%) (4%) (4%)
Composted 31,191 33,311 37,027 41,340 43,940 48,279 48,461 44,345 41,034 39,653 46,439 45,596 (8%) (9%) (10%) (11%) (12%) (13%) (13%) (12%) (12%) (10%) (12%) (12%) Report Energy 8,295 37,973 73,806 96,198 89,917 155,504 206,625 203,772 216,219 211,706 208,887 208,651 Recovery (2%) (10%) (20%) (26%) (25%) (43%) (57%) (57%) (59%) (56%) (56%) (56%) for 2017/18 Disposal to 266,542 219,035 170,135 142,554 147,100 74,623 22,163 20,018 11,589 17,774 17,157 17,826 Land (68%) (57%) (46%) (39%) (40%) (21%) (6%) (6%) (3%) (5%) (5%) (5%) W Total 390,653 381,614 371,145 366,744 365,741 359,991 359,690 357,995 365.145 380,120 374,213 372,065 aste Table 7 Household Waste Arisings in East Sussex and Brighton & Hove (tonnes)
2006/07 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18
Recycled 73,650 81,108 80,463 76,899 76,740 73,248 70,685 77,872 82,422 83,176 86,125 85,229 (20%) (22%) (23%) (22%) (22%) (21%) (21%) (22%) (24%) (24%) (24%) (24%)
Reused N/A N/A N/A N/A 1,480 2,111 1,052 443 506 513 1,520 1,728 (11) (0.4%) (1%) (<1%) (<1%) (<1%) (<1%> (<1%) (<1%)
Composted 31,191 33,311 37,027 41,010 43,542 47,856 48,025 44,106 41,034 39,653 45,615 44,925 (8%) (9%) (10%) (12%) (12%) (14%) (14%) (13%) (12%) (11%) (13%) (13%)
Energy 8,295 37,973 73,806 96,198 89,917 153,670 201,950 201,648 214,021 209,931 206,164 204,563 Recovery (2%) (10%) (21%) (28%) (26%) (45%) (59%) (59%) (61%) (60%) (58%) (58%)
Disposal to 257,879 210,601 161,435 134,107 136,910 65,497 18,787 19,366 10,888 15,831 15,217 14,593 Land (70%) (58%) (46%) (39%) (39%) (19%) (6%) (6%) (3%) (5%) (4%) (4%)
Total 371,015 362,993 352,731 348,214 348,590 342,382 340,498 343,489 348,891 349,104 354,642 351,037 P roviding W aste and Miner for als Monitoring W aste Report 2017/18 8
11 Reuse of household waste was not recorded separately until 2010/11 33 34 Waste and Minerals Monitoring Report 2017/18
8Providing for Waste
Commercial & Industrial Waste
Arisings
8.9 Accurate records of total C&I waste arisings are difficult to obtain. The 'AEA Review of Future Waste Management Capacity Requirements - East Sussex and Brighton & Hove (2011)' (AEA Review 2011) concluded that the most reliable estimate of C&I Waste in 2008/09 was 475,000 tonnes, (this was based on an average of two approaches - the 'management approach' and the 'point of production'). This report also made predictions of the anticipated arisings.
8.10 A first review and update of the C&I management method arisings estimate first was presented in the 2013/14 AMR and has been subsequently updated. The management method provides an estimate of the minimum level of waste arisings based on Environment Agency Waste Data Interrogator and Waste Data Flow data. The waste data and method used to calculate these values is complex and makes a number of assumptions; as a result there are a number of areas of uncertainty and the data should be treated with caution.
8.11 The results as shown in Table 8 and Figure 3 below indicate that C&I waste arisings were significantly reduced during the recession and have slowly been recovering. The 2017 estimate appears to be similar to the 2016 estimate which appeared to indicate a large increase in C&I waste. The exact cause for the increase is unknown, but it may be that the increase accurately reflects an increase in C&I arisings or it may be a result of other factors such as better reporting, the effect of a relatively high number of housing completions that year or new factors that the calculation methodology does not allow for; alternatively it may be a combination of these and other factors.
8.12 It should be noted that unlike the information elsewhere in this document this data is based on the calendar year 1 January to 31 December, and not the financial year 1 April to 31 March.
Figure 3 Review C&I management method waste arising estimates Waste and Minerals Monitoring Report 2017/18 35
Providing for Waste8
Table 8 First review of the C&I management method arisings estimate
Year 2008 2009 2010 2011 2012
Arisings estimate 458,721 377,296 341,898 412,201 426,825
Year 2013 2014 2015 2016 2017
Arisings estimate 422,353 462,189 450,822 556,393 557,789
Management
8.13 The AEA Review 2011 concluded that the most reliable estimate of C&I Waste management methods in 2008/09 were: 67% material recycled and composted; 29% disposed to land; and 4% reused. The landfill data in Table 9 suggests that these proportions may have changed, but further research is required to establish if this is correct.
Construction, Demolition & Excavation Waste
Arisings
8.14 The AEA Review 2011 concluded that the most reliable estimate of CDE Waste arisings in 2008/09 was 906,000 tonnes. This report also made predictions of the anticipated arisings. There has been no new information since the publication of that report.
Management
8.15 The 'AEA Review of Future Waste Management Capacity Requirements - East Sussex and Brighton & Hove' concluded that the most reliable estimate of CDE Waste management methods in 2008/09 were: 45% of all material being recycled; 15% being sent to landfill and the remainder (40%) being disposed of using alternative methods. Alternative methods include management of waste outside the recorded system such as reuse on site, use in small scale landscaping projects etc. There has been no new information since the publication of that report.
8.16 Recent monitoring of CDEW sites to obtain data for the AM 2017 survey saw a much improved response rate compared with previous years, and an overall production figure of at least 278 000 tpa recycled aggregates has been calculated.
Disposal to Land
8.17 There are times when waste can not be reused, recycled or recovered. This may be because there is insufficient capacity to recycle or recover the material, it may be uneconomical, or it may be impractical do to so. In these instances it must be disposed of to landfill or land-raise sites, collectively known as land-disposal. The information below illustrates where LACW and C&I waste produced in the Plan Area, when destined for land disposal, is sent to. This information is based on Environment Agency data. It should be noted that unlike 36 Waste and Minerals Monitoring Report 2017/18
8Providing for Waste
the information elsewhere in this document this data is based on the calendar year 1 January to 31 December, and not the financial year 1 April to 31 March. It is also important to note that origin information in the EA data is not comprehensive. Table 9 Waste disposed to land / Landfills receiving more than 1,000 tpa from East Sussex.
Location Site Name 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
East Sussex Beddingham 225,871 49,836 X X X X X X X X (1) East Sussex Pebsham 141,223 61,279 234,066 175,066 72,834 46,786 X X X X
West Horton 81,770 153,433 272,205 196,564 X X X X X X Sussex
Surrey Redhill 4,945 10,856 1,197 6,085 1,978 5,592 5,585 17,790 11,056
West Lidsey 5,230 12,239 15,908 20,294 24,388 31,983 22,419 X X Sussex
Kent Greatness Quarry 7,156 1,206
West Brookhurst Wood 12,727 44,100 35,996 20,926 18,446 6,431 33,800 22,566 P
Sussex roviding (2) Hampshire Squabb Wood Landfill Site 5,574 X X
Essex Pitsea Landfill 1,995 2,762 W
Havering Rainham Landfill 4,754 aste
Buckinghamshire Springfield Farm Landfill 2,095 and Miner
Thurrock Ockendon Area II & III Landfill 1,309 for als Total 453,809 287,790 532,434 437,723 129,124 99,651 56,020 35,640 53,585 44,541 Monitoring
1. Closed in 2013. W 2. Site closed and restoration commenced September 2016. aste
X:Site closed. Report 2017/18 8 37 38 Waste and Minerals Monitoring Report 2017/18
8Providing for Waste
Waste Management Capacity
8.18 The current total capacity provided by facilities managing waste in the Plan Area is set out in Table 10 below. This table identifies different types of activity which represent the key differences between the ways in which waste is managed. It includes facilities that are operating or currently not operating, but could be re-opened. It includes all facilities with planning permission, but excludes those which have closed permanently. The capacity values are estimated using information from the planning application and any environmental permits. Table 10 Waste Management Capacity
Type of Activity Total Capacity (tonnes per annum) as
Waste and Minerals 01/04/2012 01/04/2013 01/04/2014 01/04/2015 01/04/2016 01/04/2017 01/04/2018 Plan
Recycling & Composting 490,000 502,320 545,335 564,135 609,995 566,522 581,907 581,055
Bulk Metal (e.g. Scrapyards) 441,000 440,323 440,323 440,323 434,764 434,764 436,164 435,064
(1) (1) (1) Recovery 210,000 210,000 210,000 210,000 210,000 210,000 210,000 210,000
CDEW Recycling 630,000 648,995 669,278 724,278 725,118 742,278 742,768 738,924
Specialist Treatment 61,000 71,429 71,429 71,429 71,709 71,709 71,709 71,709 (Hazardous)
Inert Landfill (including inert 15,000 15,000 57,620 17,400 15,000 15,000 15,000 692,241 P
for beneficial use WMP8b) roviding
Non-Hazardous (including 150,000 150,000 30,000 0 0 0 0 0 Stable Non-Reactive Hazardous (total void space in Wastes) Landfill (total void space in cubic metres) (total void space
cubic metres) in cubic metres) W aste
Hazardous Landfill 0 0 0 0 0 0 0 0 and Miner
1. The ERF currently operates above the nominal capacity. In 2013 it managed 232,000 tonnes. for als Monitoring W aste Report 2017/18 8 39 40 Waste and Minerals Monitoring Report 2017/18
8Providing for Waste
8.19 Specialist Treatment are facilities that only take a very specific type of waste that must be dealt with in a specialised way. Examples in the East Sussex and Brighton & Hove area are plasterboard recycling, oil recycling and waste solvent recovery.
New Waste Management Capacity
8.20 Details of planning permissions granted within the monitoring period which provide new waste management capacity are shown in Table 11 below. Appendix F lists all permitted waste management sites in East Sussex and Brighton & Hove.
8.21 Only one of the permissions granted that contributed waste management capacity was located on a site identified within the WMSP.
Table 11 Planning Permissions Granted for New Waste Management Capacity in the Monitoring Period (1 April 2017 to 31 March 2018
Site Planning Permission Details New Throughput Capacity (tpa) (if known)
Unit 2, 5 Sybron Way, WD/788/CM - Change of use of 100 tpa metal recycling. Millbrook Industrial Estate, building for the processing, storage Crowborough, TN6 3DZ [WMSP and transfer of non-ferrous metals. / SoSIE Site]
Land south of Northiam Road, RR/793/CM - Infilling depression in 2,200 Inert void; completion (B2165), Staplecross, East field with inert waste material. expected by 1/4/2019. Sussex
Brede Barn Farm, Brede Lane, RR/783/CM - Infilling of slurry pit and 3,600 Inert void,completion Sedlescombe, TN33 0PG regrading of adjacent land with inert expected by 1/4/2019. waste material.
Golf Farm, Devil's Dyke Road, SDNP/17/02297/FUL - Re-landscaping New capacity void space for Brighton, BN1 8YJ farmland through the importation of ~670,000 tonnes of inert approximately 670,000 tonnes of inert material to be filled over two material. years.
Policy Monitoring
Policy WMP3a - Promoting Waste Prevention, Re-use and Waste Awareness
8.22 Policy WMP3a seeks to minimise the amount of waste that is produced. Local Authority Collected Waste arisings for the Plan Area in 2017/18 were approximately 363,000 tonnes, this total is a decrease on the previous year. C&I arisings in 2017 are comparable with 2016. Since the publication of the last Monitoring Report, no new information has become available regarding the overall production of CDEW. Waste and Minerals Monitoring Report 2017/18 41
Providing for Waste8
Policy WMP3b - Turning Waste into a Resource
Table 12 Targets for the Management of Local Authority Collected Waste
Year Recycling Overall Recovery
Target Actual Target Actual
2015/16 45% 40% 98% 95%
2020/21 50% 98%
2025/26 55% 98%
8.23 The Plan aims to manage waste in accordance with the Waste Hierarchy. The Plan looks to minimise the amount of waste sent to landfill and maximise the amount of waste that is recycled and recovered. Policy WMP3b sets high targets for the recovery of waste.
8.24 The WMP has a target to recycle 45%, with an overall recovery target of 98% of LACW waste by 31 March 2016. At the end of the monitoring period the recycling rate (including reuse, recycling and composting) for the Plan Area was 40%; the overall recovery rate was 95%. Since the publication of the last Monitoring Report, no new information has become available regarding the recycling and recovery rates of C&I and CDEW.
8.25 Approximately 45,000 tonnes of LACW and C&I waste was exported for land disposal at facilities outside of the Plan Area during 2017 No waste was sent to landfill inside the Plan Area. The amount of LACW being sent to landfill has fallen since the end of 2011 due to the Newhaven Energy Recovery Facility becoming fully operational. This is an improvement on 2010/11 when approximately 147,000 tonnes of LACW was sent for land disposal outside the Plan Area.
Policy WMP3c - Production of Energy from Waste (EfW)
8.26 Policy WMP3c requires that recovery facilities maximise their recovery of energy in line with the EU Waste Framework Directive. The only specific energy from waste facility in the Plan Area is the Newhaven Energy Recovery Facility. This produces 19 megawatts of electricity and meets the requirements of this policy. There are also a number of small energy generating plant at historic landfill and at waste water treatment works in the Plan Area.
Policy WMP5 - Provision of Built Waste Facilities
8.27 Policy WMP5 contains the requirements for the amount of additional capacity that is required for the recycling and recovery of waste for the Plan Area. This takes into account the need to ensure net self sufficiency. The total new permitted throughput capacity within the East Sussex and Brighton & Hove in the monitoring period is:
677,000 tonnes of capacity for inert material to be used for beneficial use. 42 Waste and Minerals Monitoring Report 2017/18
8Providing for Waste
8.28 The table below shows the progress against the targets in the WMP. The 'Combined Provision' column reflects that the WMP permits recycling capacity to be made in lieu of recovery capacity. As of 1 April 2018, after accounting for sites no longer operating, an additional 91,000tpa of recycling capacity and no recovery capacity had been permitted since the adoption of the WMP. The 2015/16 target was met.
Table 13 Estimated Required Management Capacity as set out in WMP5 and actual results.
Year Recycling Recovery Combined Provision
Estimated Actual Estimated Actual Estimated Actual Management Provision Management Provision Management Provision Tonnage Tonnage Range Tonnage Range Range
2015/16 0 - 80,000tpa 76,500tpa 60,000 - 0tpa 60,000 - 76,500tpa 200,000tpa 280,000tpa
2020/21 0 - 120,000tpa 80,000 - 80,000 - 220,000tpa 340,000tpa
2026/27 30,0000 - 60,000 - 90,000 - 170,000tpa 220,000tpa 390,000tpa
Policy WMP7a - Sustainable Locations for Waste Development (Excluding Land Disposal)
8.29 Policy WMP7a sets out broad Areas of Focus in which waste facilities should be located. These relate to within or close to urban areas, good transport connections and outside designated areas such as the AONB and SDNP.
8.30 All of the capacity permitted in 2016/17 (as set out above), was located within the Areas of Focus.
Policy WMP7b - More Detailed Criteria for Waste Development
8.31 Policy WMP7b provides additional guidance for potentially suitable sites. These include: industrial land; employment land; previously developed land; and land that was already in waste management uses. Policy WMP7b assists the development management decisions on new capacity. During the monitoring period all of the approved applications were considered to be consistent with WMP7b.
Policy WMP8a - Land Disposal for Non-Inert Waste
8.32 Policy WMP8a sets strict criteria by which applications for land disposal for non-inert waste would be assessed. There have been no applications to establish new Non-Inert Landfill/ Landraise during the monitoring period. Waste and Minerals Monitoring Report 2017/18 43
Providing for Waste8
Policy WMP8b - Deposit of Inert Waste on Land for Beneficial Uses
8.33 During the monitoring period, two applications involving deposition of inert material for beneficial use were determined within the East Sussex Planning Authority Area, one was determined by the South Downs National Park Authority within the Park.
RR/793/CM - Infilling depression in field with inert waste material. RR/783/CM - Infilling of slurry pit and regrading of adjacent land with inert waste material SDNP/17/02297/FUL - Re-landscaping farmland through the importation of approximately 670,000 tonnes of inert material.
Other Waste Policies
8.34 The most appropriate method of monitoring some policies contained in the Plan will be by periodic review. In these reviews the policies will be assessed to see if they are being implemented as intended, and if there are any implications. This applies to the following policies:
Policy WMP3d - Minimising and Managing Waste During Construction, Demolition and Excavation
Policy WMP3e - Waste Management in New Development in the Plan Area
Policy WMP6 - Safeguarding Waste Sites
Policy WMP8c - Management of Landfill Gas
Policy WMP9b - Low Level Radioactive Waste
Policy WMP9a - Hazardous Waste
Policy WMP10 - Management of Waste Water and Sewage Sludge
8.35 An initial review of all WMLP policies was undertaken in 2017. The initial review identified that Policy WMP6 may require a formal review as part of the review of minerals provision as documented in the Call for Evidence and Sites Consultation Document 2017. Policy WMP6 is currently being reviewed as part of the Waste and Minerals Local Plan Review. The remaining policies above were not identified as requiring review at that time. 44 Waste and Minerals Monitoring Report 2017/18
9Providing for Minerals 9 Providing for Minerals
Minerals in East Sussex
9.1 The principal mineral deposits in East Sussex are aggregates (sand and gravel), clay, gypsum and chalk.
Gravel deposits are confined to the coastal areas and river valleys. Clay is worked largely in the clay vale of the Low Weald. The South Downs National Park comprises an extensive area of chalk and some soft sand deposits. The largest deposit of gypsum in the United Kingdom is situated at Brightling/Robertsbridge.
9.2 A full list of minerals workings operational in East Sussex in 2017/2018 is provided in Appendix H.
9.3 Ongoing mineral production is assessed through consideration of planning applications, continued monitoring of sites and in the case of sand and gravel the production of yearly Aggregates Monitoring Reports (AMR) on behalf of SEEAWP. Each of the Mineral Planning Authorities in England and Wales collates data from minerals sites and submits the results to the Ministry of Housing, Communities and Local Government, through the relevant Aggregate Working Party. Every four years the survey includes information on the destination of materials. The most recent national four yearly Aggregate Minerals (AM) Survey is based on 2014 data. These survey results along with other recent non - confidential local figures from the Aggregates Monitoring 2017 survey, are used to update the AMR and LAA findings for 2017/18.
9.4 Mineral planning permissions are subject to periodic review through the review of old minerals permissions (ROMP) process established by the Environment Act 1995. The reviews provide for an opportunity to update conditions to provide additional environmental protection in regard to working arrangements and restoration proposals. The Growth and Infrastructure Act 2013 has altered the ROMP process in that a minerals planning authority can now adopt their own relevant review dates rather than the more rigid 15 yearly reviews. The change is intended to reduce the need for ROMP reviews where existing minerals planning conditions are judged by the Council to be satisfactory. A list of permissions and the relevant review dates are included in Appendix J.
9.5 Local Aggregate Assessment
9.6 The County Council has published the 2018 Local Aggregate Assessment (LAA) for East Sussex, South Downs and Brighton & Hove (which is appended to this document). The overall picture of aggregate supply to the Plan area is of heavy dependence on imports by road, sea and rail. Significant levels of marine imports (marine dredged and crushed rock) are received through Shoreham Port Waste and Minerals Monitoring Report 2017/18 45
Providing for Minerals9 and to a lesser extent Newhaven and Rye. Crushed rock, recycled aggregate and sand and gravel are imported by rail at Newhaven. Land-won sand and gravel is extracted in the east of the Plan area at Lydd with about 50% of material being consumed in East Sussex. A steady supply of recycled material is produced from construction waste management facilities across the Plan area. A continuing demand for construction materials is anticipated.
9.7 The NPPF requires that the LAA considers all supply options (land-won, marine, secondary and recycled material), and be based on a rolling average of 10 years sales data and other relevant local information. In past years the Authorities' assessment was that there were particular circumstances in this Plan Area that made it difficult to prepare the LAA totally along the lines indicated in the NPPG. Previous LAAs concluded that the assessment could not use past 10 years sales data as this was too volatile because there is a very small number of production sites and therefore there has been major variation in sales figures from nothing to more substantial output. Past LAAs instead used the Apportionment figure in the Adopted WMLP as a surrogate figure for forward planning.
9.8 In 2016 a Public Examination on the soundness and legal compliance of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan was held. Hearings focused on the whether the Plan provided a sufficient and adequate supply of aggregates. Whilst the Inspector found the Sites Plan sound, in his Report he identified that the current rate of land-won aggregates in the WMP could not be maintained with the current allocated sites and indicted the need for a Review of the aggregate minerals policies. The Authorities have since agreed to a Review of the Waste and Minerals Local Plan (WMLP) and in September 2017 published a consultation on the Call for Evidence and Sites. This Review will re-evaluate the aggregate provision figures for the Plan Area.
Assessing Performance of Minerals Policies
9.9 The Plan contains a number of policies which aim to deliver different mineral resources for the Plan period. It should be noted that there are currently no operational chalk quarries in East Sussex and the Waste and Minerals Plan does not safeguard chalk resources as there is little demand for the material.
Policy WMP4 - Sustainable Provision of Minerals
9.10 This Policy requires sustainable use and production of minerals in the Plan Area using the minerals hierarchy, for example by promoting secondary and recycled materials. Information on secondary and recycled aggregates continues to be limited by constraints in national and local surveys.
9.11 Some data on recycled/secondary aggregates is currently based on that from 2008/9. The Authorities will endeavour to update this information as part of the Review of the Waste and Minerals Local Plan. However, updated recycled 46 Waste and Minerals Monitoring Report 2017/18
9Providing for Minerals
aggregate production figures for the Plan area are now available. More details on recycled/secondary aggregates production and consumption is contained in the LAA appended to this report.
Policy WMP11 - Provision of Aggregates
9.12 Much of the evidence required to monitor the implementation of Policy WMP11 is found in the LAA discussed in the previous section and also appended to this document.
Policy WMP12 - Provision of Gypsum
9.13 East Sussex is the only County in the South East to produce gypsum commercially and the Robertsbridge works are identified as having national importance.
9.14 Policy WMP12 requires that reserves are maintained from the British Gypsum mine throughout the Plan period. The Gypsum mine at Brightling has more than 20 years of reserves remaining.
9.15 The Brightling mine has a capacity to excavate some 1 million tonnes of gypsum per annum; at present the mine is not worked to its full potential, but output has recently increased. In the past the material has been mainly exported from the site by road and used as an essential additive in the manufacture of Portland cement.
9.16 Plasterboard and related products are manufactured at Robertsbridge using mined gypsum, as well as imported natural gypsum imported from countries abroad (such as Spain) and Desulphogypsum (DSG) from power stations in other areas in the UK. Typically, over 0.3 million tonnes of gypsum are imported to the site by rail.
9.17 In 2012 a planning permission was granted for a strategic DSG storage area and associated development for a period of 10 years at the site. An application for a review of mineral planning conditions was approved in 2013.
9.18 An application to vary conditions attached to the permission for the site was approved in 2015. This allows high-grade natural gypsum from outside East Sussex to be used at the Works for manufacturing plasterboard, and also for it to be imported by rail and on a back-haul basis using HGVs that have previously transferred Brightling rock to cement production plants elsewhere.
9.19 In March 2018 planning permission was granted for realignment of a site entrance, and also for provision of a shed for dry storage of mechanical spares for the industrial process.
Policy WMP13 - Provision of Clay Waste and Minerals Monitoring Report 2017/18 47
Providing for Minerals9
9.20 Continued production at existing brickworks is supported and Policy WMP13 safeguards and maintains sufficient supplies of clay for brick and tile manufacture. There are six operational clay sites within East Sussex. Figures for clay production can fluctuate as material is stockpiled for working over many months. Whilst Government data is now unavailable for clay production figures, local evidence and monitoring suggests that clay production in East Sussex is stable, and indicates that there was robust production of specialised products during the monitoring period.
9.21 In At the end of 2018 (outside the monitoring period) permission was granted to allow export of sand/sandy clay and an amended restoration scheme for the Ashdown brickworks quarry.
9.22 Paragraph 4.28 in the WMP identifies that reserves at Aldershaw Farm are low and further reserves need to be identified if production is to continue in the future.
Policy WMP14 - Safeguarding Mineral Resources
9.23 Policy WMP14 sets out how minerals resources will be safeguarded from unnecessary sterilisation by alternative development. Minerals Safeguarding Areas are identified in the adopted Waste and Minerals Sites Plan.
Policy WMP15 - Safeguarding Wharves and Railheads
9.24 Policy WMP15 safeguards railheads, wharves and rail sidings for existing and future mineral imports, and in particular overall mineral wharf capacity in ports. Capacity and activity at existing wharves and information on rail imports will be monitored. Wharves, railheads and facilities for concrete batching, coated materials manufacture and other concrete products are identified for safeguarding in the adopted Waste and Minerals Sites Plan (Policies SP 9 and 10).
9.25 Adur District Council, Brighton & Hove City Council, West Sussex County Council (WSCC) and Shoreham Port Authority are partners in the preparation of the Shoreham Harbour Joint Area Action Plan (JAAP) which aims to guide the regeneration of Shoreham Harbour. It is recognised that the provision and safeguarding of minerals wharfage is a key issue if the JAAP aims are to be achieved. To this end the JAAP partners, together with South Downs National Park Authority, and ESCC signed a Statement of Common Ground (SOCG) in 2014 to underpin effective cooperation and collaboration relating to planning for minerals infrastructure and safeguarding in Shoreham Harbour. The SoCG was updated in July 2016 to reflect new data and progress in Local Plan preparation. An Examination into the JAAP was held in September 2018. Policy SP 9 in the WMSP will be the mechanism for assessing the impact on wharf capacity at the Brighton & Hove section of the Port from any development proposals in this area.
Policy WMP16 - Exploration for Oil and Gas 48 Waste and Minerals Monitoring Report 2017/18
9Providing for Minerals
9.26 Policy WMP16 provides a policy framework for any potential oil and gas exploration, appraisal and production. There is no commercial production of hydrocarbons in East Sussex.
9.27 Following the Department for Energy and Climate Change review of the responses to the consultation on the Strategic Environmental Assessment Report a new round of licensing commenced. The 14th round of bids for onshore licences closed on 28th October 2014 and no new Licence areas were proposed for East Sussex. There is currently only one existing Licence within East Sussex covering 20 square kilometres around North Chailey. There are no current planning applications for any oil and gas exploration in East Sussex.
9.28 Chalk
9.29 Historic chalk workings in East Sussex included extraction for cement works. The cement industry declined during the 1960’s and 1970’s, with the last cement plant closing in 1975. Tarring Neville near Newhaven which produced small quantities of chalk for specialised use at the Artex factory in Newhaven was the last active chalk site in the County. There are now no operational chalk quarries in East Sussex, including the area covered by the South Downs.
9.30 There are no chalk sites in Brighton & Hove. Chalk is imported from West Sussex for use in small amounts for ongoing agricultural use and has in the past been used in road construction works. There is little demand for chalk in the county and chalk resources are not safeguarded by policies in the Waste and Minerals Local Plan. Waste and Minerals Monitoring Report 2017/18 49
Overarching Policies10 10 Overarching Policies
10.1 There are six overarching policies which apply to both waste and minerals development and development determined by other planning authorities:
Policy WMP17 - Restoration
Policy WMP18 - Transport - Road, Rail and Water
Policy WMP19 - Co-location of Complementary Facilities
Policy WMP20 - Community Involvement and Benefits
Policy WMP21 - Opportunities for Sustainable Waste Management and Minerals Production in Other Developments
Policy WMP22 - Increased Operational Capacity within the Site Boundary of Existing Waste Facilities
10.2 A review of the effectiveness of these policies is currently being undertaken as part of the Review of the Waste and Minerals Local Plan and will be reported in a future monitoring report. The usage of these policies is detailed within the Overarching Strategy section of this report. 50 Waste and Minerals Monitoring Report 2017/18
11Development Management Policies 11 Development Management Policies
11.1 There are nine development management policies within the Waste and Minerals Local Plan used to determine waste and minerals planning applications:
Policy WMP23a - Design Principles for Built Waste Facilities Policy WMP23b - Operation of Sites Policy WMP24a - Climate Change Policy WMP24b - Resource and Energy Use Policy WMP25 - General Amenity Policy WMP26 - Traffic Impacts Policy WMP27 - Environment and Environmental Enhancement Policy WMP28a - Flood Risk Policy WMP28b - Water Resources and Water Quality
11.2 These policies provide a local context and in relation to national planning policy and are used as a suite of policies with which to determine planning applications. A review of the effectiveness of these development management policies is currently being undertaken as part of the Review of the Waste and Minerals Local Plan and will be reported in a future monitoring report. The usage of these policies is detailed within the Overarching Strategy section of this report.
11.3 The number of enforcement cases received is an indicator of policy effectiveness. The number of cases received in the third (calendar) quarter of 2018 was 15. This is the same as it was in the third quarter of 2017. Waste and Minerals Monitoring Report 2017/18 51
Enforcement12 12 Enforcement
12.1 The NPPF states that effective enforcement is important as a means of maintaining public confidence in the planning system. The County Council undertakes regular site monitoring, and investigates complaints received regarding alleged breaches of planning control. The figure overleaf shows the total caseload of the Council’s enforcement team, as well as the number of cases received and resolved per quarter, since the start of 2009.
12.2 The number of cases outstanding has remained historically low, with 12 in the third (calendar) quarter of 2018, a decrease of eleven compared to the third quarter of 2016, and well below the peak of second quarter 2009.
12.3 The general trend for the number of enforcement cases received in any given quarter, allowing for seasonal variation, is in general conformity with that of the performance of the local economy. It is suggested that when there is more economic activity, there is a greater possibility for conflict between uses of land. Similarly, the number of minerals and waste planning applications received appears to follow a similar trend albeit with a delay, as economic changes take time to impact on activity. 52 W
Figure 4 Enforcement Caseload in East Sussex 12 aste and Enforcement Miner als Monitoring Report 2017/18
Note: Since the publication of the 2012/13 Monitoring Report these figures have been revised and have been updated in a number of places. Waste and Minerals Monitoring Report 2017/18 53
Enforcement12
Enforcement Trends - Inert Waste
12.4 As part of their regular duties the Monitoring & Enforcement Officer undertakes inspections of waste sites and has regular discussions with local waste operators. Smaller waste operators continue to have significant issues with the disposal of soil.
12.5 There is presently only one landfill in East Sussex taking soils for restoration purposes and others in surrounding counties will only take soils if they have been analysed, and the soil analysis report shows the soils to be uncontaminated. Small waste operators continue to find the cost of undertaking a soil analysis on every skip load prohibitively expensive. As a result operators are increasingly stockpiling large amounts of soils on their sites. Once stockpiled, each stockpile can be tested, once it has been proved to be uncontaminated it can then be disposed of. This is more economical, however it does result in larger stockpiles.
12.6 In contrast to the small operators, larger skip companies appear to have sufficient office staff to identify possible locations to lawfully dispose of these soils by scanning planning permission and approaching landowners who have got these consents to take these soils to further their developments. 54 Waste and Minerals Monitoring Report 2017/18
13Monitoring Issues 13 Monitoring Issues
13.1 There continues to be a lack of information for monitoring implementation in certain areas of the strategy and policies in the Waste and Minerals Plan.
13.2 With regard to minerals, producers are not compelled to provide information on production, reserves and future plans, and due to to the small number of producers in the Plan Area confidentiality of data can also be an issue. However, at present, most operators in the Plan area have agreed to making their production figures available for publication, and this greatly assists the Authorities in the annual monitoring process.
13.3 Obtaining an accurate record of non-municipal waste arisings is also difficult. However, work has been undertaken to establish more accurate data for the C&I and C&D waste streams. The results have been reported in Section 8, but maintaining data accuracy remains a challenge, as described below.
13.4 Some information on waste movements is provided from ‘waste returns’ submitted by the waste industry (i.e. the operators of permitted waste facilities) to the Environment Agency. It is often difficult to pinpoint the origin of waste, which may be recorded several times as it passes through different waste facilities for bulking and/or sorting before it is finally recorded as being recovered or disposed of and this can lead to double counting. In an attempt to alleviate this problem, the Environment Agency piloted a new 'Electronic Duty of Care' system from January 2011 to December 2014 which tracks waste movements digitally(12). It is hoped that in time this will enable much more accurate monitoring of non-municipal waste arisings and treatment methods. In addition, some waste is managed at sites where operators are exempt from the need to provide waste data.
13.5 Capacity figures for new waste facilities are recorded as new planning permissions are granted. However, where data is not submitted as part of a planning application, it may be necessary to request information. In any event, the issue of how to monitor increases in capacity resulting from new facilities or operational changes that do not require a separate planning permission, remains.
12 See www.environment-agency.gov.uk/aboutus/wfo/128930.aspx for more information. Waste and Minerals Monitoring Report 2017/18 55
Appendices 56 Waste and Minerals Monitoring Report 2017/18 AStructure of the Waste and Minerals Local Plan Appendix A: Structure of the Waste and Minerals Local Plan
Figure 5 Waste and Minerals Local Plan Structure (Novemer 2012) P Appendix B: Programme for the Waste and Minerals rogramme Development Scheme
Table 14 Programme for the Minerals and Waste Development Scheme (February 2017)
Document Title Subject Matter Geographic Area Authorities (jointly Timetable responsible)
East Sussex Statement of Review of the Statement of County of East Sussex (outside East Sussex County Council Adoption: Summer 2017. for Community Involvement Community Involvement. South Downs National Park)
First Review of the Waste A review, as necessary, of the County of East Sussex. East Sussex County Council; Call for Sites / Content (Reg18): Development and Minerals Local Plan policies contained within the Local City of Brighton & Hove. South Downs National Park Summer / Autumn 2017; Preferred the Plan, (excluding the Construction The area of the South Downs Authority; Strategy Consultation (Reg 18): and Demolition Supplementary National Park that lies within Brighton & Hove City Spring 2018; Pre-Submission Planning Document, see below). the County of East Sussex. Council. Consultation (Reg 19): Autumn / Winter 2018; Submission: early 2019; W (1) Adoption: Summer 2019. aste
Construction and A review of the Construction and County of East Sussex. East Sussex County Council; Review of document: Summer / W Demolition Supplementary Demolition Supplementary Planning Autumn 2017; Revocation (Reg aste Planning Document - Document with a view to revocation. 15(b)), if applicable: Spring 2018.(1) City of Brighton & Hove. Brighton & Hove City and
Review Council. and Miner als
1. Timetable subject to review. Scheme Monitoring Minerals Report 2017/18 B 57 58 Waste and Minerals Monitoring Report 2017/18
CDuty to Co-operate Appendix C: Duty to Co-operate Regional Fora
C.1 This section only shows information for the year 2017/18. Please refer to other monitoring reports for historic information. Duty to W aste and Co-operate Miner als Monitoring Report 2017/18 C 59 60 W
Table 15 Log of DtC Activities (2017/18) - Regional Fora C aste Duty Topic(s) SEWPAG: Regional Waste SEEAWP: Aggregate supply and demand Ashdown Forest Officer Group and Miner
Who SEWPAG Authorities SEEAWP Authorities Authorities with a likely effect on the als
Ashdown Forest SAC. Monitoring to
Description SEWPAG meets to discuss waste planning SEEAWP provides technical advice about the The Ashdown Forest Officer Group meets to matters in the South East. A Memorandum supply and demand for aggregates in the discuss the strategic planning issue of Co-operate of Understanding (MoU) regarding the Duty South East to the Secretary of State for nitrogen levels in the Ashdown Forest. The Report to Co-operate is to be signed by all SEWPAG Communities and Local Government and meetings first started out with authorities
members. The MoU was approved by the mineral planning authorities. It also discussing the approaches adopted to 2017/18 Lead Member for Transport and Environment undertakes annual monitoring of aggregates address the identified issues. These on 17 June 2013. The MoU sets out how the production, by type and use, and the levels meetings have since progressed and now SEWPAG Authorities would approach the of permitted reserves. It meets about two authorities meet to discuss the formation Duty and set thresholds below which it was or three times a year. MPAs are required of a Statement of Common Ground (SoCG) considered that the Duty need not apply. to report their draft Local Aggregate which an adviser from the Planning Advisory Assessments to SEEAWP. Service (PAS) is present for.
Dates 24 April 2017 3 July 2017 21 June 2017 13 July 2017 6 November 2017 30 August 2017 11 October 2017 16 April 2018 13 October 2017 16 January 2018 16 July 2018 10 November 2017 (SoCG) 26 April 2018 19 November 2018 23 November 2017 (SoCG) 31 July 2018 18 January 2018 9 October 2018 7 February 2018 4 June 2018 29 November 2018
Waste and Minerals Local Plan Review
Main Issues
C.2 1. Provision of recycled, marine and land-won aggregates.
C.3 2. Land-won minerals provision in the Plan Area. C.4 3. Safeguarding minerals and minerals infrastructure.
The safeguarding of mineral resources, specifically, aggregates including soft sand.
The maintenance and enhancement of wharf capacity at Newhaven, Shoreham and Rye.
The safeguarding of railheads at Newhaven and Robertsbridge.
Log of Activities (2017/18)
Table 16 Log of DtC Activities (2017/18) in relation to the Waste and Minerals Local Plan Review
Date Topic(s) Who Description Duty
April 2017 N/A N/A Work on the review of the Waste and Minerals Local Plan commenced.
25 April 2017 Review progress ESCC, SDNPA and BHCC Meeting held to discuss the workings of each policy within the Waste to
and Minerals Local Plan. W aste 25 July 2017 Review progress All Plan area D&Bs Update provided at Local Plan Managers' meeting. and Co-operate Miner 7 August 2017 Review Update Wealden District Council Briefing on forthcoming Call for Evidence and Sites. als
8 August 2017 Review Update Hastings Borough Council & Rother Briefing on forthcoming Call for Evidence and Sites. Monitoring District Council
9 August 2017 Review Update Lewes District Council & Eastbourne Briefing on forthcoming Call for Evidence and Sites.
Borough Council Report
September 2017 N/A N/A Call for evidence and sites on the content of the Waste and Minerals 2017/18 Local Plan Review commenced. C 61 62 W C aste
20 September 2017 Review update BHCC, Adur & Worthing Councils, Update provided at Shoreham Harbour Planning Policy Sub Group. Duty West Sussex, Environment Agency and Miner 28 September 2017 Review progress All Plan area D&Bs Update provided at Local Plan Managers' meeting. als Monitoring 20 October 2017 Review progress N/A End of the consultation period for the call for sites and evidence. 19 to responses were received to the consultation. Co-operate Report 25 January 2018 Review progress All Plan area D&Bs Update provided on the latest position of the review at Local Managers' meeting. D&Bs were informed that a meeting would be held prior to the 2017/18 regulation 18 consultation.
30 January 2018 Cross boundary issues Kent County Council Meeting held to discuss cross border movements of sand and gravel and soft sand and also to discuss specific issues relating to production and supply patterns at Lydd Quarry, Ashdown Forest SAC, marine imports/wharf capacity loss and discussion of the prospect of having a joint approach to aggregates provision.
27 March 2018 Review update All Plan area D&Bs Update provided at Local Plan Managers' meeting.
12 June 2018 Soft Sand Kent CC Meeting regarding the provision of soft sand.
26 July 2018 Review update All Plan area D&Bs Update provided at Local Plan Managers' meeting.
2 August 2018 Potential extension of Lydd Kent CC, NE, EA and Meeting held to try and identify issues of concern raised by potential Quarry operator/consultants allocation of Lydd quarry extension in Kent. ESCC invited as issues thought to be similar in East Sussex
2 November 2018 Review Update All Plan Area D&Bs and Mid Sussex East Sussex Strategic Planning Members Group. Updated given to group DC and Tunbridge Wells BC. members, explained that review commenced in 2017. 3 sites have been submitted as part of call for sites and evidence which are currently being considered. Advised on slippage in timetable - Reg 18 consultation due in early 2019.
14 November 2018 Review Progress Natural England Meeting with Natural England to discuss the viability of the extension sites submitted by Brett Aggregates for the Lydd Quarry site. 4 December 2018 Review update Adur & Worthing Councils, West Update of the Local Plan Review given at the Planning Subgroup meeting. Sussex CC, ESCC and BHCC
11 December 2018 Soft sand Kent CC, SDNPA, WSCC and ESCC Kent called meeting to discuss provision of soft sand from their Kent Minerals Local Plan and initiate a SoCG between the authorities.
Other Communications
C.5 East Sussex County Council is a full member of the Planning Officer Society (POS) Minerals and Waste Learning Group (national forum) and the SDNPA and Brighton & Hove City Council are corresponding members. The County Council is also a member of the POS Minerals and Waste Forum. Officers regularly attend meetings where topical issues particularly concerning plan making are discussed. Membership of these fora has assisted with communication between other mineral and waste authorities during site plan preparation. Other meetings and discussions are listed below.
Main Issues (2013-2018) Duty
1. Waste data and waste movements;
2. Capacity provision in other Plan Areas; to W aste 3. Protection of Brentford Rail Transfer; and Co-operate
4. Safeguarding aggregate import facilities at Ports in the Plan Area including Shoreham Miner als
5. Aggregate supply and demand in the Plan Area Monitoring Report 2017/18 C 63 64 W C
Log of Activities (2017/18) aste Duty
Table 17 Log of DtC Activities (2017/18) - Other Communications and Miner Date Topic(s) Who Description als Monitoring to 28 Apr 2017 DM Forum All Plan area D&Bs
May 2017 Hazardous Waste Movements. London Borough of Tower Hamlets Regulation 19 Consultation by LB of Tower Hamlets on the matter Co-operate of waste movement. Comments submitted on consultation. Further Report Regulation 19 consultation to follow. 2017/18 May 2017 Local Plan Modifications Arun District Council Comments submitted on the proposed modifications on the Arun Local Plan 2011-2031.
May 2017 Lewes Town Neighbourhood Plan; Lewes District Council Comments submitted on the two neighbourhood plans. Newhaven Neighbourhood Plan.
25 May 2017 Local Plan Managers' Meeting All Plan area D&Bs Meeting attended to discuss general duty to cooperate issues.
June 2017 Shoreham Joint Area Action Plan Shoreham Harbour Partnership/ Consultation on the proposed amendments to the draft plan. Adur and Worthing Councils Comments submitted.
17 July 2017 Statement of Common Ground on soft South East Mineral Planning East Sussex County Council agreed to sign. sand Authorities
21 July 2017 DM Forum All Plan area D&Bs
August 2017 Strategic Waste Movements Central and Eastern Berkshire Comments submitted on consultation.
August 2017 Waste Capacity Needs Assessment Kent County Council Consultation with Waste Industry on Waste Capacity Needs Assessment. Comments submitted.
September 2017 Development Management Policies Lewes District Council Consultation for DM policies and site allocations. Comments submitted.
October 2017 Waste Local Plan Surrey County Council Consultation regarding waste movements. 20 October 2017 DM Forum All Plan area D&Bs Update given on the review, D&Bs informed that the review is focused on minerals due to a shortfall of aggregates.
06 November 2017 Local Aggregates Assessment SEEAWP SEEAWP consideration of local authorities' Local Aggregates Assessments. The 2017 Local Aggregates Assessment for East Sussex, South Downs and Brighton & Hove was approved by SEEAWP at this meeting.
17 November 2017 Shoreham Joint Area Action Plan Shoreham Harbour Partnership Supportive representation made on Shoreham Harbour Pre-submission Joint Area Action Plan
November 2017 Local Aggregates Assessment Cornwall Comments sought on draft LAA.
24 November 2017 ARC site at Rye Harbour - planning Rother District Council Consultation for planning application received at a safeguarded application RR/2017/977/P minerals wharf. Comments submitted.
31 January 2018 Cross boundary DtC meeting Kent County Council Meeting to discuss cross border movements of sand, gravel and
soft sand, Lydd quarry, marine imports and wharf capacity, joint Duty approach to aggregates provision and Ashdown Forest SAC.
23 February 2018 DM Forum All Plan area D&Bs D&Bs updated on the results of the Call for Sites and Evidence consultation. to
27 March 2018 East Sussex Local Plan Managers Group All Plan area D&Bs All D&Bs informed about the need to take into account minerals W meeting and waste safeguarding areas in their Local Plans as ESCC have aste recently had some cases where proposals have come forward and and ESCC have not been consulted. Co-operate
Rother DC were made aware of 2 cases relating to safeguarded Miner wharves where they had been unaware of MSAs. Advised that they
needed to be added to the Rother Plan. Invited Rother to discuss als
safeguarding prior to Reg 18 consultation. Monitoring
16 April 2018 AM - meeting of the South East Mineral S/E Mineral Planning Authorities; Both meeting included discussions of Kent's Plans, the Local Planning Authorities; PM - SEEAWP SEEAWP. Aggregates Assessment, soft sand and other regional planning
meeting. issues. Report
18 May 2018 DM Forum All Plan area D&Bs D&Bs updated that plan timetable had slipped. DTC meetings are to arranged with D&Bs in due course. Reg 18 likely by end of July 2017/18
2018. C 65 66 W C
23 May 2018 East Sussex Local Plan Managers Group All Plan Area D&Bs All D&Bs informed of the progress of the Waste and Minerals Local aste
meeting Plan review. ESCC asked D&Bs for information of developers of Duty large projects to aid with the Soft Sand study. and Miner 12 June 2018 Soft sand Kent County Council, East Sussex Kent CC requested meeting to discuss soft sand provision in their
County Council, SDNPA, WSCC draft Plan als Monitoring
15 June 2018 Transport for South East Draft Transport for South East Comments submitted. to Economic Connectivity Review Co-operate
6 July 2018 Lewes Neighbourhood Plan Lewes District Council Comments submitted. Report
24 August 2018 Hastings Town Centre and Bohemia Hastings Borough Council Comments submitted. Area Action Plan 2017/18
7 September 2018 DM Forum All Plan area D&Bs Update provided on the call for sites and evidence outcomes. D&Bs informed that ESCC will be contact to arrange DTC meeting in due course.
29 October 2018 Rother DaSA Rother District Council Comments submitted. Problems identified regarding the soundness of policy DEN3.
20 November 2018 Waste Movements North Lincolnshire County Council Comments submitted. No changes in movements identified.
22 November 2018 Rye Neighbourhood Plan Rother District Council Regulation 16 consultation. ESCC preparing comments.
30 November 2018 DM Forum All Plan area D&Bs Update of the review provided on the issues related to Lydd Quarry. ESCC updated on meeting held with Brett Aggregates, KCC and discussions with MMO in relation to potential routes forward to progress plan.
December 2018 Statement of Common Ground Kent County Council with South Agreed that two separate Statements of Common Ground are Downs National Park Authority and required for the issue of soft sand. Brighton & Hove City Council in Appendix D: LACW and Household Waste Arisings in East LACW Sussex and Brighton & Hove East
Table 18 Local Authority Collected Waste Arisings in East Sussex and Brighton & Hove (tonnes) and Sussex Authority 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 Recycled B&H 27,316 27,070 25,447 25,051 32,706 23,138 22,379 22,298 21,947 22,869 24,219 ES 53,792 53,393 52,546 52,793 50,579 49,375 56,663 61,449 76,502 64,812 62,242 Reused B&H 2,644 2,628 1,752 1,091 1,647 2,811 2,896 2,974 2,693 3,119 3,164 Household ES 7,542 7,086 6,906 5,848 5,652 7,105 7,920 9,583 9,846 10,931 10,367 Composted B&H 3,857 3,889 4,312 3,582 3,801 3,660 3,481 3,537 3,177 4,169 3,083
ES 29,454 33,138 37,028 40,358 44,479 44,812 40,864 37,497 36,457 42,270 42,514 and Energy B&H 12,037 22,668 30,240 41,562 51,944 69,348 67,515 74,196 76,315 74,749 75,130 Recovery ES 25,937 51,138 65,958 48,355 103,560 137,277 136,259 142,023 135,391 134,138 133,521 Disposal to B&H 66,456 52,350 47,444 35,611 22,673 5,461 7,383 4,198 4,469 5,234 5,824 Land ES 152,480 117,785 95,111 111,488 51,950 16,702 12,636 7,391 13,305 11,923 12,002 Brighton Total B&H 112,310 108,605 109,195 106,897 103,771 104,418 103,653 107,182 108,601 110,140 111,420 Waste ES 269,305 262,540 257,549 258,843 256,220 255,272 254,342 257,993 380,120 264,074 60,646 Arisings W aste W Table 19 Local Authority Collected Waste Arisings in East Sussex and Brighton & Hove (%) and aste Authority 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 Miner Recycled B&H 24 25 23 23 23 22 22 21 20 21 22
ES 20 20 20 20 20 19 22 24 28 25 24 als &
Reused B&H 2 2 2 1 2 3 3 3 2 3 3 Monitoring
ES 3 3 3 2 2 3 3 4 4 4 4 Arisings
Composted B&H 3 4 4 3 4 4 3 3 3 4 3 Hove ES 11 13 14 16 17 18 16 15 14 17 17 Energy B&H 11 21 28 39 50 66 65 69 70 68 67 Report Recovery ES 10 19 26 19 40 54 54 55 50 51 51
Disposal to B&H 59 48 43 33 22 5 7 4 4 5 5 2017/18
Land ES 57 45 37 43 20 7 5 3 5 5 5 D 67 68 W
Table 20 Household Waste Arisings in East Sussex and Brighton & Hove (tonnes) in D aste
Authority 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 LACW and
Recycled B&H 27,316 27,070 25,447 25,051 23,706 22,955 22,182 22,099 21,760 22,664 24,217 East ES 53,792 53,393 51,452 51,689 49,541 47,730 55,690 60,343 75,582 63,461 61,012 Miner Reused B&H N/a N/a N/a 286 901 224 26 21 29 295 312 als ES N/a N/a N/a 1,194 1,210 828 417 485 624 1,225 1,416 Monitoring Composted B&H 3,857 3,889 4,312 3,582 3,801 3,660 3,481 3,517 3,177 4,169 3,083 Sussex
ES 29,454 33,138 36,698 39,960 44,055 44,364 40,679 37,497 36,475 41,446 41,842 and Energy B&H 12,037 22,668 30,240 41,562 51,944 69,348 67,515 74,196 76,308 74,120 72,633
Recovery ES 25,937 51,138 65,958 48,355 101,727 132,601 134,133 139,825 132,848 132,044 131,930 Report Disposal to B&H 66,378 52,325 46,470 34,110 20,991 5,405 8,753 4,152 3,514 4,087 3,559
Land Household
ES 144,223 109,110 87,637 102,800 44,506 13,382 10,613 6,737 15,494 11,131 11,035 2017/18 Total B&H 109,587 105,952 106,470 104,592 101,342 101,592 101,957 104,005 104,788 105,335 103,804 ES 253,406 246,779 241,744 243,998 241,040 238,906 241,531 244,888 261,024 249,306 247,234 and
Table 21 Household Waste Arisings in East Sussex and Brighton & Hove (%)
Authority 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18
Recycled B&H 25 26 24 24 23 23 22 21 21 22 23 Brighton ES 21 22 21 21 21 20 23 25 29 25 25 Reused B&H N/a N/a N/a 0.3 1 0 0 0 0 0 0 ES N/a N/a N/a 0.5 1 0 0 0 0 0 1
Composted B&H 4 4 4 3 4 4 3 3 3 4 3 W ES 12 13 15 16 18 19 17 15 14 17 17
Energy B&H 11 21 28 40 51 68 66 71 73 70 70 aste Recovery ES 10 21 27 20 42 56 56 57 51 53 53 Disposal to B&H 61 49 44 33 21 5 9 4 3 4 3
Land ES 57 44 36 42 18 6 4 3 6 4 4 & Arisings Hove Waste and Minerals Monitoring Report 2017/18 69 Other Targets for the Management of LACWE Appendix E: Other Targets for the Management of LACW
E.1 European and national policies require increases in the proportion of waste from which we recover value through recycling, composting and recovery of energy and that the proportion of waste sent to landfill decreases.
E.2 The Waste and Minerals Plan includes challenging targets for recycling and other recovery of waste. These targets are considered achievable as a result of Government policy to reduce reliance on landfill especially using fiscal means, and, because there is a dearth of landfill capacity which is incentivising alternatives to disposal in the ground. Studies undertaken by the County Council have analysed the make up of material currently landfilled and the ability for these materials to be recovered.
E.3 The recycling and composting targets for Local Authority Collected Waste adopted in the Waste and Minerals Plan and other documents is set out in Table 22 below. Similarly, targets for recovery of Local Authority Collected Waste is set out in Table 23.
Table 22 Comparison of Local Authority Collected Waste Recycling and Composting Targets
Year Waste & ESCC Joint BHCC MWMS Waste Minerals Plan Waste Strategy Strategy 2007 2015/16 45% - 40% 45% 2020/21 50% 50% 45% 50% 2025/26 55% 60% - -
Table 23 Comparison of Local Authority Collected Waste Recovery Targets
Year Waste & ESCC Joint Waste B&HCC Waste Minerals Plan Strategy MWMS Strategy 2007 2015/16 98% - 95% 67% 2020/21 98% Recover 95% of 98% 75% residual waste after recycling 2025/26 98% - - - 70 Waste and Minerals Monitoring Report 2017/18 FPermitted Waste Management Sites in East Sussex and Brighton & Hove Appendix F: Permitted Waste Management Sites in East Sussex and Brighton & Hove
F.1 Table accurate as at 1 April 2018
Table 24
id2012 Locality Site Name East Sussex Type (1) X Y Status Description
20 Barcombe Barcombe WWTW Physico-Chemical Operational 544029 114981 Treatment Facility
117 Battle The Hunt Kennels, Animal Carcus Operational 572275 114731 Catsfield Storage
21 Beddingham Beddingham Compost Composting Facility Operational 543581 106544 Facility
99 Beddingham Beddingham Landfill Non-Haz Landfill Restoration 543868 106400 Site
112 Bexhill Brett Concrete Works Transfer Station Operational 576000 107843 - Unit 1, Brett Drive
18 Bexhill-on-Sea London Road - No. 64 Metal/ELV Facility Operational 573992 107903
70 Bexhill-on-Sea Sandhurst Lane - Specialist Treatment Operational 570638 108817 Bungalow, The (Oil)
19 Brighton Argyle Hall, Campbell Metal/ELV Facility Operational 530887 105606 Road
26 Brighton Brighton General Clinical Waste Operational 532833 105147 Hospital Transfer Station
27 Brighton Brighton HWRC, Household Waste Operational 533891 104894 Wilson Ave Amenity Site
134 Brighton Golf Farm, Devil's WMP8b Operational 528022 108026 Dyke Road
50 Brighton Hollingdean Depot, Special Waste Operational 531657 106098 Hollingdean Lane Transfer Station
51 Brighton Hollingdean MRF & Material Recycling Operational 531672 105959 WTS, Hollingdean Treatment Facility Lane
55 Brighton Moulsecoomb Way, Household, Operational 533186 107500 Moulsecoomb Commercial & Industrial - Waste Transfer Station
38 Brighton New England Street Metal/ELV Facility Operational 531025 105377 (G E Richardson & Sons Ltd) Waste and Minerals Monitoring Report 2017/18 71 Permitted Waste Management Sites in East Sussex and Brighton & HoveF
id2012 Locality Site Name East Sussex Type (1) X Y Status Description
10 Brighton Sheepcote Valley Physico-Chemical Non-operational 533891 104894 Treatment Facility
88 Brighton Waterhall Valley Burn Incinerator Operational 528596 109056 Site
91 Chiddingley Woodlands Centre Composting Facility Operational 553160 113481
3 Cripps Corner Cripps Corner Depot Transfer Station Non-operational 578264 120938 taking Non-Biodegradable Wastes
35 Crowborough Crowborough HWRC, Household Waste Operational 553069 129447 Farningham Road Ind. Amenity Site Estate
108 Crowborough Hourne Lane (Land Inert Recycling Operational 552741 132112 off), Steel Cross
150 Crowborough Millbrook Industrial Metal/ELV Facility Operational 553960 129800 Estate - 5 Sybron Way, Unit 2
16 Crowborough Laurel Tree Farm, Inert WMP7b Operational 552952 133077 Eridge Road
98 Ditchling SM Tidy Ind. Estate - Recycling (Tyres) Operational 534127 118304 Compound 13 (Environmental Tyres), Ditchling Common
123 Eastbourne Birch Close Ind. MRF Operational 562648 101322 Estate - Unit 2A & 2B
127 Eastbourne Birch Close Ind. Metal/ELV Facility Operational 562431 101330 Estate - Unit 3
33 Eastbourne Eastbourne HWRC, St Household, Operational 562072 100608 Philip’s Avenue Commercial & Industrial Waste Recycling & Transfer Station
36 Eastbourne Finmere Close Metal/ELV Facility Operational 562280 100902 (Finmere Auto Spares)
37 Forest Row Forest Row HWRC Household, Operational 542858 135251 Commercial & Industrial - Waste Transfer Station
120 Framfield Knights Business MRF + Specialist Operational 550810 118449 Centre - Unit 8, (Asbestos) Squires Farn Ind. Estate
119 Framfield Knights Business Metal/ELV Facility Operational 550913 118408 Centre (GB Metals), Squires Farn Ind. Estate 72 Waste and Minerals Monitoring Report 2017/18 FPermitted Waste Management Sites in East Sussex and Brighton & Hove
id2012 Locality Site Name East Sussex Type (1) X Y Status Description
44 Hailsham Apex Way (Haulaway Household, Operational 558067 109137 Ltd) Commercial & Industrial - Waste Transfer Station
40 Hailsham Apex Way Ind. Estate Metal/ELV Facility Operational 558004 109127 (H Ripley & Co), Diplocks Way
34 Hailsham Elmfield, Saltmarsh Metal/ELV Facility Operational 560603 107577 Lane
42 Hailsham Hailsham HWRC Household, Operational 559652 108507 Commercial & Industrial - Waste Transfer Station
58 Hailsham Littlewood, Metal/ELV Facility Operational 557377 109704 Hempstead Lane
25 Hastings Bridge Yard, Five Acre Metal/ELV Facility Operational 583938 113682 Wood, Rock Lane
113 Hastings Hole Farm, Westfield Inert Recycling Operational 581004 113839 Lane, Baldslow
41 Hastings Home Farm, Metal/ELV Facility Operational 581136 113803 Westfield Lane
85 Hastings Roebuck Centre - Unit Metal/ELV Facility Operational 582591 109650 A , Roebuck Street
90 Hastings Whitworth Road, St Transfer Station Operational 579520 113203 Leonards-on-Sea taking Non-Biodegradable Wastes
92 Hastings Woodland House, Household, Operational 579305 110798 Ponswood Ind. Commercial & Estate, St Industrial - Waste Leonards-on-Sea Transfer Station
46 Heathfield Hazlemere, Three Metal/ELV Facility Operational 563770 120074 Cups Corner
47 Heathfield Heathfield Depot Transfer Station Operational 559400 121973 taking Non-Biodegradable Wastes
48 Heathfield Heathfield HWRC Household, Operational 559356 122112 Commercial & Industrial - Waste Transfer Station
79 Heathfield The Platt, Three Cups Metal/ELV Facility Operational 563664 120144 Corner
118 Hellingly North Street - Broad Metal/ELV Facility Operational 557646 112593 Farm (Hunt Metals)
106 Hellingly North Street - Broad Inert Recycling Operational 557457 112684 Farm (The Granary Waste and Minerals Monitoring Report 2017/18 73 Permitted Waste Management Sites in East Sussex and Brighton & HoveF
id2012 Locality Site Name East Sussex Type (1) X Y Status Description
Rural Business Centre)
49 Horam Heavenly Paws Pet Pet Crematorium Operational 557040 114543 Funeral Services, Swansbrook Lane
101 Hove Hove HWRC, Old HWRC & Transfer Operational 528071 105746 Shoreham Road Station
89 Hove Wellington Road Metal/ELV Facility Operational 525786 105000 (Hove Car Spares)
22 Isfield Boathouse Farm Composting Facility Operational 544860 116186
11 Isfield Skim Corner, Isfield Transfer Station Non-operational 544895 115668 Road taking Non-Biodegradable Wastes
81 Lewes Cliffe Ind. Estate - WEEE Storage and Operational 542650 109591 Unit 18 Treatment Facility
78 Lewes Cliffe Ind. Estate - Waste Transfer Closed 542630 109425 Unit 25-26 Station
39 Lewes Greystone Quarry, Household, Operational 543121 109101 Southerham Commercial & Industrial - Waste Transfer Station & Metal / ELV Recyling
56 Lewes Lewes HWRC Household, Operational 542289 109344 Commercial & Industrial - Waste Transfer Station
45 Maresfield Hazelbank, A22 Household, Operational 545975 125572 Commercial & Industrial - Waste Transfer Station
59 Maresfield Maresfield Camp Household Waste Operational 545703 123632 HWRC & WTS Recycling & Waste Transfer Station
61 Maresfield Mill Pond Depot, Mill Highways Depot Operational 547164 123569 Pond Road
65 Mayfield North Yard, Penny Waste Transfer Operational 560101 128352 Bridge Lane Station
62 Mountfield Mountfield HWRC Household, Operational 574572 119468 Commercial & Industrial - Waste Transfer Station
125 Newhaven Avis Way / New Road Household Waste Operational 544995 101762 Ind. Estate - Amenity Site Newhaven HWRC 74 Waste and Minerals Monitoring Report 2017/18 FPermitted Waste Management Sites in East Sussex and Brighton & Hove
id2012 Locality Site Name East Sussex Type (1) X Y Status Description
124 Newhaven Avis Way / New Road Transfer Station Operational 544655 102406 Ind. Estate - Titan taking Works (Greenacre) Non-Biodegradable Wastes
109 Newhaven Endeavour Works - Transfer Station Operational 545169 100872 Unit G, Beach Road
95 Newhaven Newhaven ERF Rail Railhead / Waste Operational 544654 102213 Transfer, North Quay Transfer Station - ERF IBA Only
28 Newhaven North Ind. Estate Metal/ELV Facility Operational 544632 102375 (Brighton Motorama), New Road
13 Newhaven North Quay - Old Physical Treatment Operational 544599 102029 Timber Yard, The Facility
76 Newhaven North Quay - Metal/ELV Facility Operational 544637 101909 Southerham Wharf
97 Newhaven North Quay (Kingston Waste Transfer Operational 544796 101662 Transport Station (Newhaven))
102 Newhaven North Quay Inert Material Operational 544765 101593 (Newhaven Roadstone Recycling / Recovery Ltd (West))
9 Newhaven Quarry Road - Unit 7 Metal/ELV Facility Non-operational 544374 100521 (Selmeston Auto Spares)
103 Newhaven Rich Industrial Estate Waste Transfer Operational 545181 102079 - Unit F (Amstech Station (Asbestos Contracts Ltd) Only)
43 Ninfield Little Park Farm Pet Crematorium Operational 570324 111315 (Happy Hunting Grounds), Hooe Road
67 Pebsham Pebsham HWRC, Household, Operational 576956 108776 Freshfields Commercial & Industrial - Waste Transfer Station
130 Pebsham Pebsham Landfill Leachate Tanks Operational 576970 109069 Leachate Tanks, Freshfields
68 Pebsham Pebsham Landfill Site, Co-Disposal Landfill Restoration 577233 109419 Freshfields Site
69 Pebsham Pebsham WTS, Waste Transfer Operational 576910 108899 Freshfields Station
115 Polegate Chaucer Ind. Estate - Waste Transfer Operational 559823 104691 Unit 13 Station
32 Polegate Cophall Wood WTS, Household, Operational 557646 106748 A22 Commercial & Waste and Minerals Monitoring Report 2017/18 75 Permitted Waste Management Sites in East Sussex and Brighton & HoveF
id2012 Locality Site Name East Sussex Type (1) X Y Status Description
Industrial - Waste Transfer Station
60 Polegate Mile Oak Depot, A27 C&D Recycling Operational 557583 104782
116 Polegate Polegate Yard, A22 Inert Recycling Operational 558243 106987
31 Portslade Basin Road South Special Waste Operational 526466 104624 Transfer Station
30 Ringmer Chamberlains Lane Metal/ELV Facility Operational 545877 112611 (Cooper AA)
72 Ringmer Ringmer Depot C&D Recycling Operational 546214 112992
66 Ringmer The Broyle Incinerator Operational 547925 114293 (Peaceways Animal Crematorium)
93 Robertsbridge British Gypsum Specialist Treatment Operational 572584 119617 (Plasterboard)
73 Rye Rye Oil Ltd, Harbour Specialist Treatment Operational 593149 119606 Road (Oil)
74 Seaford Cradle Hill Ind. Estate Household, Operational 549766 100492 - Seaford HWRC Commercial & Industrial - Waste Transfer Station
84 Seaford Cradle Hill Ind. Estate Transfer Station Operational 549671 100313 - Unit 3 taking Non-Biodegradable Wastes
133 Sedlescombe Brede Barn Farm, WMP8b Operational 579018 118344 Brede Lane
75 Sidley Sidley Depot Household, Operational 574001 108757 Commercial & Industrial - Waste Transfer Station
7 South Chailey Little Exceat Farm, Inert Material Operational 539489 116723 A275 Recycling / Recovery
8 South Chailey Old Hamset Waste Water Non-operational 539893 115991 Brickworks, A275 Treatment Works
4 Southease Fore Hill, nr. South Incinerator Non-operational 541065 104725 Farm Bungalow
29 St Bulverhythe Depot, Waste Transfer Operational 577610 108561 Leonards-on-Sea Bulverhythe Road Station for Recyclates
132 Staplecross Land south of WMP8b Operational 578523 122191 Northiam Road (B2165), Northiam Road (B2165) 76 Waste and Minerals Monitoring Report 2017/18 FPermitted Waste Management Sites in East Sussex and Brighton & Hove
id2012 Locality Site Name East Sussex Type (1) X Y Status Description
128 Three Oaks Three Oaks WWTW Waste Water Operational 583512 114292 Treatment Works
82 Uckfield Bellbrook Ind. Estate Recycling Operational 546397 120588 - Unit 19
114 Uckfield Oak Ferrars Farm Recycling (Plastics Operational 544652 122945 (Born Again Plastics), Baling) Batts Bridge Road, Piltdown
131 Uckfield Uckfield WWTW, Metal/ELV Facility Operational 546499 120497 Bridge Farm Road
87 Wadhurst Wadhurst HWRC, Household, Operational 561775 133109 Faircrouch Lane Commercial & Industrial - Waste Transfer Station
71 Westham Potts Marsh Ind. Household, Operational 563660 104014 Estate - Unit 27 Commercial & Industrial - Waste Transfer Station
1. Sites that are closed are not included in this table. Appendix G: Permitting of Significant Waste Management Management Capacity in East Sussex 2006/7 - 2017/18 P Table 25 ermitting
Year Number of Throughput of received apps Number / Capacity Approved Number Number pending at end of Significant Refused monitoring period Apps Received
2006/07 4 Recycling: 59,000tpa 6 2 4 Capacity
Transfer: 94,960tpa (110,000 tpa recycling, 121,000 tpa transfer) of 2006/7 2007/08 6 Recycling: 25,000tpa , Composting: 7 None 3 15,000tpa, Transfer: 1,860tpa, Landfill: Significant 122,270tpa, Peacehaven WWTW (25,000 tpa recycling, 5,820 transfer, (59,000tpa recycling,
61,000 tpa composting, 210,000tpa 122,270tpa landfill, W aste
recovery, Peacehaven WWTW) in and - Miner 2008/09 3 25,000tpa CDEW recycling, 6 (59,000tpa recycling, 122,270tpa None None East
landfill, Peacehaven WWTW, 25,000tpa 2017/18 CDEW recycling,) als Monitoring 2009/10 3 74,200tpa transfer 2 (56,200tpa transfer) None 1 Sussex W (18,000tpa transfer) Report aste
2010/11 3 5,260tpa recycling 4 None None 2017/18 G Replacement Newhaven HWRS (5,260tpa recycling, 18,000tpa transfer) 77 78 W 2006/7 Management G
Year Number of Throughput of received apps Number / Capacity Approved Number Number pending at end of aste Significant Refused monitoring period P Apps and ermitting
Received Miner
2011/12 4 Recycling: 35000tpa, 4 None 1 als Monitoring Transfer: 108,000tpa, (Recycling: 35000tpa, (22,500 tonnes of inert material required for -
Inert material required for restoration Transfer: 108,000tpa, restoration WMP8b) 2017/18 (WMPB8): 23,000 tonnes (required after 1 Report Jan 2012) Inert material required for restoration
(WMPB8): 23,000 tonnes (required after 2017/18 of
1 Jan 2012)) Capacity
2012/13 4 Recycling: 50,000tpa 4 None 3 Significant
Inert Recycling: 21,000tpa (Increase Composting Capacity to 60,000 at Woodlands Inert Material required for beneficial use Centre; Inert for beneficial (WMP8b): 42,000 use (WMP8b): 10,000 tonnes; Part C&I and part CDEW:25,000 tpa) in
2013/14 2 Increase Composting Capacity to 60,000 at 5 None None East
Woodlands Centre; Inert for beneficial use W (WMP8b): 2,600 tonnes; Part C&I and part Increase Composting Capacity to 60,000
CDEW Recycling:60,000 tpa at Woodlands Centre; Inert for beneficial aste use (WMP8b): 2,600 tonnes; Part C&I and Sussex part CDEW Recycling:60,000 tpa
2014/15 5 Inert for beneficial use (WMP8b): 4 None 1 3,000tonnes tonnes; Recycling & CDEW Recycling: 74,000 tpa; Specialist Hazardous: 280 tpa; Bulk Metals: 720 tpa; Year Number of Throughput of received apps Number / Capacity Approved Number Number pending at end of Management Significant Refused monitoring period Apps Received
Recycling & CDEW Recycling: 74,000 tpa; Specialist Hazardous: 280 tpa; Bulk P Metals: 720 tpa; ermitting
2015/16 5 Recycling: 20,500 tpa; Recycling: 20,500 tpa; None 1 CDEW Recycling: 49,500 tpa. CDEW Recycling: 49,500 tpa. Capacity 2016/17 1 Recycling: 25,000 Recycling: 25,000
(Increase composting of
3 1 throughput (waste wood); 2006/7 Specialist (Waste Water) 72,000tpa. Specialist (Waste Water) 72,000tpa. Boathouse Farm, Isfield Road,
Isfield, TN22 5JJ) Significant W
2017/18 3 aste in
Inert for beneficial use (WMP8b): and 3 Inert for beneficial use (WMP8b): 1 0 677,300tonnes - Miner 677,300tonnes East 2017/18 als Monitoring G.1 Note: For consistency the figures presented here are the total throughput i.e. this includes the recycled / recovered /
disposed of element and the transfer element. It only includes significant development, smaller permissions do not appear. Sussex W Report aste 2017/18 G 79 80 Waste and Minerals Monitoring Report 2017/18 HPermitted Mineral Workings in East Sussex 2017/18 Appendix H: Permitted Mineral Workings in East Sussex 2017/18
Table 26 Site Mineral Operational during AMR period? Stanton's Farm and Novington Building Sand No Sandpit, Plumpton (in SDNPA) Scotney Court, Lydd Sand and gravel Yes Scotney Court extension / Wall Sand and gravel Yes Farm, Lydd Castle Water, Rye Sand and gravel No - dormant Ashdown Brickworks Clay Yes Chailey Brickworks Clay Yes Hastings Brickworks Clay Yes Aldershaw Farm Clay Yes Horam Brickworks Clay No - not yet constructed Little Standard Hill Farm Clay No Hamsey Brickworks Clay No - dormant, brickworks closed Cuckmere Brickworks Clay No - dormant, brickworks closed Ludlay Brickworks Clay No - dormant, brickworks closed Brightling Mine / Robertsbridge Gypsum Yes works Tarring Neville Chalk No - site restored, now in aftercare Meeching Quarry Chalk No North Quay, Newhaven (Berth 1) Aggregate wharf Yes North Quay, Newhaven, (Berth 2) Aggregate wharf No North Quay, Newhaven,(Berth 3) Aggregate wharf No North Quay, Newhaven (Berth 5) Aggregate wharf No Rastrums Wharf, Rye Aggregate wharf Yes Rye Wharf Aggregate wharf No
H.1 The Adopted WMP in 2013 estimated aggregate reserves to amount to in excess of 4 million tonnes via existing planning permissions in the Plan Area at Lydd Quarry (sharp sand and gravel) and in the SDNP at Stanton's Farm/Novington sandpit (soft sand). However it was recognised that the availability of the mineral would be phased and may be reduced by local environmental constraints. Waste and Minerals Monitoring Report 2017/18 81 Permitted Mineral Workings in East Sussex 2017/18H
H.2 Stanton's Farm/ Novington Sandpit) is currently inactive. A recent renewal of permission for the site indicated that the reserve at Novington is now 350 000 tonnes. Estimates indicate that 1 million tonne of reserve remained at Lydd Quarry at the end of 2017. These are on the East Sussex side of the quarry. This gives a total of 1 350 000 tonnes at the end of 2017.
H.3 The landbank for the Plan Area has been calculated in the past as the full resource available at Stanton's Farm and the reserve from the permitted sites at Lydd Quarry within the boundary of East Sussex divided by 0.1 mtpa. This gives a landbank figure at the end of 2017 of 13.5 years. The NPPF requires a landbank of at least 7 years to be maintained. However, the use of 0.1mtpa as the principal indicator of demand, and the method of calculating the landbank will be re-examined as part of the Review of the Waste and Minerals Local Plan. As such the landbank figure for 2017 should only be read as a nominal figure and not as an actual measure of supply in the Plan area. 82 Waste and Minerals Monitoring Report 2017/18 ISecondary and Recycled Aggregates Facilities in East Sussex and Brighton & Hove Appendix I: Secondary and Recycled Aggregates Facilities in East Sussex and Brighton & Hove
I.1 The current best estimate of secondary and recycled aggregates production in East Sussex and Brighton & Hove is up to 363,000 tonnes. This is based on an assessment of secondary and recycled aggregates facilities and imports as set out below.
Table 27 Recycled Aggregates Facilities processing CDEW in East Sussex and Brighton & Hove as at April 2017
Operator/site Address Edburton Ferry Wharf, Portslade Hailsham Roadway Woodside Depot, Hailsham R French & Sons Ltd Woodland House, Drury Lane, Ponswood Industrial Estate, St Leonards-on-Sea MDJ Light Brothers Greystone Quarry, Southerham, Lewes (in SDNP) A M Skip Hire Hazlebank, London Road, Maresfield Haulaway Ltd, Premier House Premier House, Apex Way, Hailsham Wealden Demolition North Quay Road, Newhaven PJ Mini Skips Cophall Wood Recycling Centre, Hailsham Road (A22), Polegate Newhaven Roadstone Ltd* North Quay Road, Newhaven *(the facility recycles aggregate on site and reuses the product within the manufacturing process) Go Green Hourne Lane (Land off), Steel Cross, Crowborough Pauls Mini Skips** Unit 13, Chaucer Industrial Estate, Polegate Links Waste Management** Units 2A and 2B, Birch Close, Eastbourne Robins of Herstmonceux Sandbanks, Chilsham Lane, Herstmonceux Sussex Waste Management** Whitworth Road, St Leonards on Sea Taskforce Property Services Ltd Land at Hole Farm, Westfield Lane, Westfield Greenacre Recycling** New Road, Newhaven
I.2 Some recycled aggregate is also produced by mobile crushing activities associated with demolition projects. The above facilities do not operate at full capacity and it is estimated that at least 278,000 tonnes (based on 2017 figures) Waste and Minerals Monitoring Report 2017/18 83 Secondary and Recycled Aggregates Facilities in East Sussex and Brighton & HoveI of recycled aggregate is produced from these sources and mobile crushers on demolition sites. Some of the facilities may import CDEW for management but do not currently find it viable to process at the site (sites in table marked**). Instead the sorted hardcore is sent on to another site for actual processing into secondary aggregate.
I.3 In addition, it is estimated that at least 85,000 tonnes of secondary aggregate are ultimately produced/imported in the Plan area from the sources listed below.
Table 28 Secondary Aggregates Facilities in East Sussex and Brighton & Hove
Operator Facility Quantity and type of material (tpa)
Ibstock Ltd Ashdown Brickworks Reject bricks -up to 14 000t is produced pa and Chailey Brickworks Rastrums Rastrums wharf, Rye Pulverised Fuel Ash (PFA) imported from Harbour Europe used as secondary aggregate Day Newhaven Railhead Incinerator Bottom Ash is exported by rail, Aggregates currently to Brentford, where it is processed into recycled aggregate for uses including as a road construction material. During 2017, 45 090 tonnes of recycled material was rail imported back into Newhaven.
I.4 The above facilities are estimated to provide capacity for approximately 739,000 tonnes per annum recycling Construction, Demolition and Excavation Waste as at 1 April 2018. 84 Waste and Minerals Monitoring Report 2017/18
JReview of Mineral Permissions Appendix J: Review of Mineral Permissions
J.1 The following table sets out the mineral permissions within East Sussex that will be subject to periodic review over the coming years.
Table 29
Reference Site Mineral Status Review dates
Periodic Review application received 11 April 2013. New set of conditions determined under reference SDNP/13/01933/ROMP on 09/10/13. Next review due 9 Novington October 2028 . (In addition, as Building Inactive MR/5 Sandpit, this site is part of the Stanton's sand Plumpton Farm permission SDNP/16/04886/CNDC ,it will be affected by the conditions on that permission which has recently been renewed (see Stanton's Farm below).
Periodic Review application postponement was agreed for 15 years until 27/5/2033. The site has a new permission (RR/811/CM) Ashdown MR/10 Clay Active dated 6 December 2018. Once Brickworks implemented, it will be the working permission and any subsequent review will be based on that permission.
Implemented but inactive. Periodic Review application was Little Standard required by 20 October 2018. MR/11 Clay Inactive Hill Farm However, a postponement has been agreed for 15 years until 20/10/2033.
A postponement to the Periodic MR/12 Sussex Bricks Clay Active Review application has been agreed to 11 December 2033.
Aldershaw Periodic Review application MR/13 Clay Active Tiles required by 25 November 2024.
Periodic Review application Chailey MR/14 Clay Active required by 23 July 2025. Brickworks
Scotney Court Sand Periodic Review application MR/15 (Lydd Quarry and Active required by 21 October 2026. Area 10) gravel Waste and Minerals Monitoring Report 2017/18 85
Review of Mineral PermissionsJ
Reference Site Mineral Status Review dates
Periodic Review application British received by 26 March 2013. New Gypsum, set of conditions determined MR/16 Gypsum Active Brightling and under reference MR/16 on Robertsbridge. 10/09/2013. Next review due 9 September 2028.
Periodic Review application received 15 July 2013 and a new Tarring Inactive - set of conditions determined MR/17 Neville, Chalk subject to under reference MR/17 on Newhaven aftercare 15/11/2013. Aftercare commenced 2016.
Planning permission LW/386/CM granted 20 October 2003, although commencement did not take place until October 2006. This Stanton's Farm, permission was recently renewed Plumpton Building (ref: SDNP/16/04886/CNDC) to SDNP/16/04886/CNDC (includes Inactive sand allow the extraction of sand and Novington restoration of the site to be Sandpit) completed not later than October 2026. Remaining reserves at the quarry are considered to be in the region of 350 000 tonnes.
IDO registered.
Lewes District Council granted Hamsey planning permission granted for IDO/1A Clay Dormant Brickworks business units and residential properties on site during 2015 (LW/14/0712).
Meeching The Periodic Review application IDO/5B Quarry, Chalk Inactive is due by 5 April 2019. Newhaven
Scotney Court Periodic Review application Extension & Sand formally postponed as the extant RR/362/CM Wall Farm and Active conditions are considered fit for (Areas 11 and gravel purpose. 12)
Periodic Review application was Extant and Horam due by 21 August 2015; WD/307/CM Clay implemented Brickworks postponement has been agreed but inactive with operator until August 2030.
Ludlay Brickworks, Clay Dormant Berwick
Cuckmere Brickworks, Clay Dormant Berwick 86 Waste and Minerals Monitoring Report 2017/18
JReview of Mineral Permissions
Reference Site Mineral Status Review dates
Sand Castle Water, and Dormant Rye Harbour gravel Waste and Minerals Monitoring Report 2017/18 87
Local Aggregate AssessmentK Appendix K: Local Aggregate Assessment
East Sussex, South Downs and Brighton & Hove Local Aggregate Assessment
December 2018
East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
NOTE
In September 2017 East Sussex County Council, Brighton & Hove City Council and the South Downs National Park Authority commenced a Review of their Waste and Minerals Local Plan. A Call for Evidence and Sites consultation was held at the end of 2017. The Authorities are currently in discussions regarding sites put forward during this consultation and so have not yet formerly considered the content of the next stage of the Plan Review. It would not therefore be appropriate to pre-empt possible changes in aggregate supply in this LAA. Discussion of future demand and supply scenarios and possible provision levels are not therefore included in this year's LAA. However, these details will be assessed at the next stage of the Local Plan Review process and reported on in the next LAA. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
Contents
Executive Summary 3 1 Introduction 11 2 Geology and mineral uses 14 3 Demand 16 4 Supply 22 5 Environmental constraints 34 6 Balance 36 7 Conclusions 40 A Past and Future Development 42 B Imports into plan area 47 C LAA Requirements 48 Map 1: Geological Plan including locations of aggregate wharves and railheads, and existing aggregate sites 50 Map 2: Origin of aggregate imported, produced and consumed in East Sussex and Brighton & Hove during 2014 52 Map 3: Sand and gravel resources in the East English Channel and Thames Estuary (Source: Crown Estate) 54 Map 4: Recycled and secondary aggregates sites 2017/18 56 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 3
Executive Summary Executive Summary
Executive Summary
The first East Sussex, South Downs and Brighton & Hove Local Aggregate Assessment (LAA) was published in December 2013. The LAA has been updated annually and is based on the Plan Area for the adopted East Sussex, South Downs and Brighton & Hove Waste & Minerals Local Plan (WMLP). This document represents the sixth LAA for the mineral planning authorities of East Sussex County Council, Brighton & Hove City Council and the South Downs National Park Authority (the Authorites) and examines updates to the position on aggregates supply and demand since the time of last reporting in 2017.
In past years the Authorities' assessment was that there were particular circumstances in this Plan Area that made it difficult to prepare the LAA totally along the lines indicated in the NPPG. Previous LAAs concluded that the assessment could not use past 10 years sales data as this was too volatile because there is a very small number of production sites and therefore there has been major variation in sales figures from nothing to more substantial output. Past LAAs instead used the Apportionment figure in the Adopted WMLP as a surrogate figure for forward planning.
In 2016 a Public Examination on the soundness and legal compliance of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan was held. Hearings focused on the whether the Plan provided a sufficient and adequate supply of aggregates. Whilst the Inspector found the Sites Plan sound in his Report he highlighted the need for a Review of the aggregate minerals policies. Taking on board the Inspector's comments the Authorities agreed to a Review of the Waste and Minerals Local Plan (WMLP) and in September 2017 published a consultation on the Call for Evidence & Sites . Two sites received as part of this consultation are promoted as extensions to an existing sand and gravel quarry in the east of the Plan Area.
As the WMLP aggregate policies are currently under review, this LAA will seek to provide updated background information for the Review. The Authorities are currently in discussions regarding sites put forward during this consultation and so have not yet formerly considered the content of the next stage of the Plan Review. It is not therefore appropriate to pre-empt possible changes in aggregate supply in this document. Discussion of future demand and supply scenarios and possible provision levels are not therefore included in this year's LAA. However, these details will be assessed at the next stage of the Local Plan Review process and reported on in the next LAA.
This LAA therefore examines the latest information and data available on aggregates production and supply patterns in the Plan Area. 4 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
Executive Summary
The overall picture of aggregate supply to the Plan area is of heavy dependence on imports by road, sea and rail. Significant levels of marine imports (marine dredged and crushed rock) are received through Shoreham Port and to a lesser extent Newhaven and Rye. Crushed rock, recycled aggregate and sand and gravel are imported by rail at Newhaven. Land-won sand and gravel is extracted in the east of the Plan area at Lydd with about 50% of material being consumed in East Sussex. It is assumed that all soft sand supply is met by road imports. The Authorities are currently undertaking research to establish the origin of soft sand material used in the Plan area. A steady supply of recycled material is produced from construction waste management facilities across the Plan area. A continuing demand for construction materials is anticipated.
The South East England Aggregates Working Party (SEEAWP) has requested that MPAs include a comparative Key Facts table in their LAA. The data included in this table is to be found within the LAA and is pulled together here to enable easier assessment and collation of information. Key Facts
East Sussex, South Downs and Brighton Hove & 20181
Sales2 (Mt) Av3 Av3 (3y) Trend4 LAA5 Reserve6 Landbank7 Capacity8 Comments9 (10y) Sales rate (Mt.) (Yrs) (Mtpa) East
(Mt) (Mt) Sussex, Sales (Mt) South
Sharp Sand & Gravel 0.3 (2017) N/A 0.3 N/A 1.0 N/A No All of the sharp sand and gravel produced in the Plan Area Downs restrictions originates from Lydd Quarry which straddles the East Sussex/Kent border. A 10 year average is not applicable as working has only been in East Sussex since 2011. and Brighton Executive Sales in the last 3-4 years have have been higher than the rate anticipated in the planning permission, although the most recent
3 year average has reduced from 0.4 to 0.3 since LAA 2017. & Hove, The reserve figure has recently been recalculated by the operator
and of the 1.0 mt remaining 150,000 is located in Kent. Under Local terms of conditions working must cease by end of 2022. Aggregate
Soft sand 0 c N/A N/A 0.35 N/A Market Extraction commenced in 2007 at Stanton's Farm/Novington
- led? sandpit but no extraction has taken place in recent years. Recent Summary renewal of permission at this site indicated that reserve was 350 Assessment, 000 tonnes. As there are no other soft sand sites in the plan area it is assumed that demand for this material is being met by road imports. December All Sand and Gravel c 0.3 0.1 1.35 13.5* As per The landbank for the Plan Area has been calculated in the past as market the full resource available at Stanton's Farm and the reserve from 0.3 (2017) demand the permitted sites at Lydd Quarry within the boundary of East Sussex divided by 0.1 mtpa. This gives a landbank figure at the 2018 5 6 East East Sussex, South Downs and Brighton Hove & 20181 Executive Sussex,
end of 2017 of 13.5 years. However, the use of 0.1mtpa as a the South principal indicator of demand, and the method of calculating the landbank is being re-examined as part of the Review of the Waste Downs and Minerals Local Plan. *As such the landbank figure for 2017 should only be read as a nominal figure and not as an actual
measure of supply in the Plan area It should also be noted that and 50% of sharp sand and gravel produced in East Sussex is exported Brighton to Kent. Summary
Crushed rock N/A N/A N/A N/A N/A 0 0 0 No crushed rock produced in the Area but imports are significant &
element of supply. Hove, Local Aggregate Assessment, December 2018 East Sussex, South Downs and Brighton Hove & 20181
Recycled/Secondary 0.28 N/A Not N/A 0.7 Previously sales figures were taken from 2008/9 estimates, Aggregates (2017)* known (2017) However, monitoring of sites for 2016 and 2017 for the SEEAWP AM survey saw a good response rate compared with previous years.
0.04 The production figure* 278 423 tpa for 2017 taken from the AM East (2017)** survey is therefore considered an accurate minimum. Sussex, Rail imports** of recycled material have increased steadily over the last 4 years. South
Marine sand and 0.02* N/A N/A N/A Not Safeguarding of wharves is a crucial issue. Sales of marine imports Downs gravel (2017) known received at Shoreham Port (which is partly within Brighton & Hove)
are monitored by West Sussex County Council. These sales also and contribute to the supply for the East Sussex, South Downs and Brighton
Brighton & Hove area. In the last few years and until recently Executive import figures have been confidential. *The figure given is from East Sussex Ports only. & Rock Imports by Sea 0.04* N/A N/A N/A N/A Safeguarding of wharves is a crucial issue. In the last few years Hove, (2017) and until recently import figures have been confidential. *The figure given is from East Sussex Ports only. Local
Rail depot sales (S&G) 0.025 N/A 0.015 N/A Not Relatively new imports of recycled and sand and gravel making Aggregate (2017) known important contribution to supply particularly for recent infrastructure projects. Both types marked increases over last 3
years. Summary Assessment,
Rail Depot Sales 0.07 (2017) N/A 0.08 N/A Not Relatively new imports of crushed rock making important (Crushed Rock) known contribution to supply particularly for recent infrastructure projects. Imports have varied over last 3 years. December Comments9 Overall picture of aggregate supply – heavily dependant on imports by road, sea and rail; land-won sand and gravel in the west of the Plan Area; significant marine imports through Shoreham Port and to lesser extent Newhaven and Rye, rail imports of crushed rock, recycled aggregate and sand and gravel at Newhaven; and a level of supply from recycled aggregates throughout the Plan Area. Assumed that all soft sand supply is met by road imports. 2018 7 8 East East Sussex, South Downs and Brighton Hove & 20181 Executive Sussex,
Steady continuing demand anticipated. South The adopted aggregate policies are being reviewed as part of the current Review of the Waste and Minerals Local Plan. A consultation on
the the call for sites and evidence took place at the end of 2017. The authorities are currently considering the responses to the consultation. Downs
Table 1 and Brighton
KEY Summary & Hove,
Sales up Local Aggregate
No real change in sales over last 3 years Assessment,
Sales Down No clear trend, including where figures are confidential December
See over page for Table Notes 2018 Table Notes:
1 Publication date.
2 Figures in millions of tonnes rounded to one decimal place. AMR year in brackets.
3 Averages based on last ten/three year sales. East Sussex, 4 An indicator whether there is growth or decline in sales.
5 LAA Rate is the LAA Provision Rate as determined by the mpa as the suitable measure for estimating the landbank for land-won South
aggregates. Downs
6 Reserves are the amount of mineral with planning permission for extraction. and Brighton 7 Landbank calculation is the reserve divided by LAA Rate to indicate life in years of the mpa reserve. Executive
8 Capacity is an estimate of how much the quarry or site could produce based on plant capability and planning restrictions. & Hove, 9 Brief summary on aggregate supply and any issues. Local
c = confidential Aggregate Summary Assessment, December 2018 9 10 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
Executive Summary East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 11
Introduction1 1 Introduction
1.1 The first East Sussex, South Downs and Brighton & Hove Local Aggregate Assessment (LAA) was published in December 2013 and this document (LAA 2018) represents the sixth LAA for the mineral planning authorities (mpa) of East Sussex County Council, Brighton & Hove City Council and South Downs National Park Authority. The LAA is based on the Plan Area for the adopted East Sussex, South Downs and Brighton & Hove Waste & Minerals Local Plan, and covers the administrative area of East Sussex and Brighton & Hove including those parts that lie within the South Downs National Park.
1.2 The Revised National Planning Policy Framework (2018) states that mineral planning authorities should plan for a steady and adequate supply of aggregates by preparing an annual LAA based on a rolling average of 10 years sales data and other relevant local information. The LAA should include an assessment of all supply options including land won, marine dredged, secondary and recycled sources, together with a forecast of demand.
1.3 The National Planning Practice Guidance (NPPG) indicates that a LAA should contain three elements:
a forecast of the demand for aggregates based on the rolling average of 10-years sales data and other relevant local information;
an analysis of all aggregate supply options, as indicated by landbanks, mineral plan allocations and capacity data e.g. marine licences for marine aggregate extraction, recycled aggregates and the potential through-puts from wharves. This analysis should be informed by planning information, the aggregate industry and other bodies such as local enterprise partnerships; and
an assessment of the balance between demand and supply, and the economic and environmental opportunities and constraints that might influence the situation. It should conclude if there is a shortage or a surplus of supply and, if the former, how this is being addressed
1.4 The NPPG also gives further details on the aggregate supply options including:
recycled aggregates, including from construction, demolition and excavation waste;
secondary aggregates, whose sources come from industrial wastes such as glass, incinerator bottom ash, railway ballast, and scrap tyres; and industrial and minerals by-products;
marine aggregates from The Crown Estate. Information will cover the areas licensed by the Marine Management Organisation for marine sand and gravel dredging and, as they are prepared over time, Marine Plans. The Marine Policy 12 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
1Introduction
Statement (MPS) is used as the overarching UK policy framework for the production of marine plans and in the absence of an adopted marine plan the MPS will inform decisions in the UK marine area;
imports into and exports out of the minerals planning authority area. The minerals planning authority must capture the amount of aggregate that it is importing and exporting as part of its Assessment; and
land-won resources, including landbanks and site specific allocations.
1.5 A revised version of the Practice Guidance on the production and use of Local Aggregates Assessment was prepared in May 2017 by the Minerals Product Association and Planning Officers' Society (MPA/POS).
1.6 In past years the Authorities' assessment was that there were particular circumstances in this Plan Area that made it difficult to prepare the LAA totally along the lines indicated in the NPPG. Previous LAAs concluded that the assessment could not use past 10 years sales data as this was too volatile because there is a very small number of production sites and therefore there has been major variation in sales figures from nothing to more substantial output. Past LAAs instead used the Apportionment figure in the Adopted Waste and Minerals Local Plan (WMLP) as a surrogate figure for forward planning.
1.7 In 2016 a Public Examination on the soundness and legal compliance of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan was held. Hearings focused on the whether the Plan provided a sufficient and adequate supply of aggregates. Whilst the Inspector found the Sites Plan sound in his Report he highlighted the need for a Review of the aggregate minerals policies. The Sites Plan was adopted in February 2017. The Authorities have since agreed to a Review of the WMLP and in September 2017 published a consultation on the Call for Sites and Evidence.
1.8 Two sites received as part of this consultation are promoted as extensions to an existing sand and gravel quarry in the east of the Plan Area. The authorities are currently considering the responses to the Call for Sites and evidence. It is not therefore appropriate to pre-empt possible changes in aggregate supply and demand in this document and so discussion of future demand and supply scenarios and possible provision levels is not included in this year's LAA. However, these details will be assessed at the next stage of the Local Plan Review process and reported on in the next LAA.
1.9 This LAA therefore examines the latest information and data available on aggregates production and supply patterns in the Plan Area.
1.10 A draft of this LAA was considered by SEEAWP at the end of 2018. SEEAWP made comments relating to the amount of aggregate produced, the provision level, the land bank and the demand trend for aggregates arising in the Plan Area. These East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 13
Introduction1 comments have been noted and where appropriate clarifications have been made in the document. Particular detailed points will be considered further during the Review and will reported on in next year's LAA.
1.11 Various statutory bodies and organisations were consulted on the draft document, including Natural England, the relevant Local Enterprises Partnerships, the Marine Management Organisation and mineral planning authorities covering areas of aggregate resource imported into the LAA area. 14 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
2Geology and mineral uses 2 Geology and mineral uses
2.1 Geologically, sand and gravel aggregate resources within the Plan Area are limited to relatively small outcrops of the sand in the Folkestone Beds, river gravels and foreshore deposits of sand and gravel. Sharp sand and gravel, and soft sand can have different uses. Sharp sand and gravel are primarily used for concreting purposes and this is an essential raw material for the construction industry. Building sand is largely used as fine aggregate in the production of concrete, mortars and asphalt. Both types of material can be used as fill. There are no sand and gravel reserves within the boundary of Brighton & Hove.
2.2 The Folkestone Beds comprise the uppermost division of the Lower Greensand and consist of loosely consolidated fine grained quartzose sands. The outcrop of the deposit is very limited consisting of a narrow strip in the western part of the Plan Area, running eastwards from Ditchling for a relatively short distance. The fine grained nature of the sand means it readily meets British Standards for mortar sand. The area of Lower Greensand within East Sussex was previously outside the Sussex Downs AONB but it is now located within the South Downs National Park (SDNP). The SDNP Authority has undertaken a study to assess the potential resource across the Park and alternative sources outside the Park boundary. Along with other mineral planning authorities in the South East, the Authorities have recently signed a Statement of Common Ground on soft sand which aims to collaboratively address supply issues facing an important mineral used by the construction industry.
2.3 The foreshore resource comprises extensive storm beach deposits along the coast. The wedge shaped accumulations consist almost entirely of flint with only a small proportion of sand. The main areas are between Winchelsea Beach and Rye Harbour, and, the western part of Dungeness around Camber. The resource is mostly used in concreting.
2.4 Substantial marine aggregate resources lie along the South East coast and in the English Channel which are widely extracted under licence by several aggregate companies with landings made at numerous wharves in the region. There are some landings at Shoreham Harbour within Brighton & Hove on the border with West Sussex, and until recently, at Newhaven Port. Crushed rock from various sources is also landed at Shoreham, Newhaven and also Rye Port. Other wharves used for marine dredged material are within the Thames Estuary and Hampshire.
2.5 Marine aggregates can yield both sand and gravel. Marine dredged aggregates are mostly utilised for concreting purposes, whilst crushed rock of various types is used locally in an unprocessed form for road construction or subsequently processed for the manufacture of coated roadstone products.
2.6 There are no hard rock aggregate reserves in the Area. Chalk has been the subject of significant levels of quarrying in the past, notably for the cement industry and to produce lime mortar and agricultural lime. Chalk also has the potential to East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 15
Geology and mineral uses2 yield crushed rock aggregate fill. However, all chalk extraction operations have now ceased and chalk is unlikely to make anything other than a minor contribution to aggregate production in the area in the foreseeable future.
2.7 A geological plan including locations of existing minerals facilities (Map 1), and details of sand and gravel resources in the East English Channel and Thames Estuary (Map 3) are included at the end of this document. 16 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
3Demand 3 Demand
Past Demand
National & Regional Guidelines for Aggregates Provision in England 2005 to 2020
3.1 For the Plan Area "demand" is a difficult part of the LAA to determine. This is partly because the consumption picture cannot be ascertained with any certainty (see paragraphs below). The NPPG states that the Government’s national and sub-national guidelines serve a purpose of providing individual minerals planning authorities, where they are having difficulty in obtaining data, with some understanding or context of the overall demand and possible sources that might be available.
3.2 The most recent guidelines – National and Regional Guidelines for Aggregates Provision in England 2005 – 2020 - reflect the overall fall in national demand for aggregates and an increase in use of alternatives to primary aggregates, especially recycled construction and demolition waste. The guidelines are based on outputs from an econometric model of the relationship between construction and aggregate consumption to predict future aggregate need. The main driver of aggregates demand is construction activity, although the Government has recognised that the relationship between the two appeared to weaken in the 1990s. Also there may be changes in aggregate intensity of use for each type of construction. Additionally, the problem of insufficient recycled /alternative aggregate data remains, although locally the situation may be improving. The issue of revising the guidelines was raised during the recent consultation on the NPPF changes but no conclusion was reached.
National Infrastructure Plan
3.3 The Government published the National Infrastructure Plan in October 2010, outlining its vision for the future of UK economic infrastructure. The Plan contains major commitments for investment in important infrastructure projects, such as road and rail improvements. A national infrastructure pipeline update was published in Autumn 2017 and provides detail on the status of all planned UK infrastructure projects. In the Plan Area the pipeline includes the Newhaven Enterprise Zone including the Port Access Road which is programmed to commence in 2018. Online improvements to the A27, due to be delivered by Highways England under their current Road Investment Strategy are also included. Such projects will affect the demand for aggregates in the locality, as will others in the region.
3.4 In July 2015 the then Government published "Fixing the Foundations" a plan to boost the UK’s productivity growth. It set out the government’s long-term strategy to raise productivity by encouraging long term investment, and promoting a dynamic economy. In February 2017 the Government published its Housing White paper "Fixing our Broken Housing Market" and then published consultation proposals "Planning for the right homes in the right places" on detailed aspects of theWhite East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 17
Demand3 paper. In July 2018 the Government published a revised NPPF which consolidated its previous plans and included revised calculations for determining housing need to support the Governments’ ambition to deliver 300,000 new homes per annum. Implementation of these proposals will have an impact on aggregate demand especially from housing growth and improvements to the transport system.
3.5 Using past sales data to assess demand has also been problematic in the Plan Area. Data for previous extraction has mainly been confidential and therefore, until recently, it has been unable to be published. In addition, with so few sites local sales figures are subject to large production swings and therefore trends cannot be used as a general indicator of demand. For example, at Lydd Quarry up until 2011, production took place in Kent with no returns for East Sussex. Now extraction is all in East Sussex and the operator considers that about half of the aggregate raised is consumed in Kent. Similarly after some years of no soft sand returns, Novington sandpit started extraction in 2007. (The site is not currently active). As confidentiality restrictions are being lifted, past sales figures will become more useful in the future.
Substitute local demand indicators
3.6 It must be assumed that as development has taken place in East Sussex and Brighton & Hove, net demand for constructional materials must have been met by a combination of land won aggregates, marine landings, imports and recycled and secondary aggregates.
3.7 Consumption data from the British Geological Survey (BGS) indicates how much aggregate is used in the area and this can also assist in building up a picture of "local" demand (see Appendix B and Map 2 for more detail).
3.8 The national four yearly Aggregate Minerals (AM) Survey based on 2014 data was published in 2016. DCLG also published a summary "AM2014 source of primary aggregates by sub-region – percent categories" which indicates consumption by sub-region and identifies the source MPAs they are importing aggregates from. AM2014 indicates that consumption was up in 2014 to 920 000 tonnes sand and gravel (land-won and marine) and 280 000 tonnes crushed rock giving a total of primary aggregates of 1 200 000 tonnes. In 2009 production of recycled and secondary aggregates was estimated at about 250,000 tonnes, and recent data (collected for the AM survey) indicates production is now at least 278 000 tpa.
3.9 The average road delivery distances for aggregates in 2013 was 51.5km (source: MPA) although there have been examples where this distance has been exceeded and movements are not always direct. Given the economic limits on transporting aggregates by road it is likely that the East of Plan Area is provided by sharp sand and gravel from Lydd quarry, marine landings and imports; and that the Western Area is served by marine and imports. It is assumed that for soft sand the Eastern end of the Plan area is served by imports; and that the Western area 18 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
3Demand
has in the past been served by Novington and imports. Work is currently being undertaken by the Authorities as part of the WMLP Review to establish the supply pattern of aggregates in the Plan Area.
3.10 In a wider context, the draft SEEAWP Aggregates monitoring report 2017, indicates that overall aggregate sales over the last two years are at their highest for the last decade. Land won sand gravel and marine dredged aggregate sales are the equal largest component within the overall sales pattern. This contrasts with recent years when marine dredged aggregates sales have been more dominant. The draft report concludes that 2017 aggregate sales are above both the 3-year and 10-year average and that the demand for aggregates will increase. There are supply implications arising from the Heathrow Expansion and other infrastructure projects including those in London.
3.11 It may be appropriate to consider locally derived figures such as construction rates of housing and major infrastructure projects over the last decade. Between 2007/8 and 2017/18 there were some 19 753 housing completions in East Sussex and Brighton & Hove. Major infrastructure projects which have been completed in the last 10 years include; Peacehaven Waste Water Treatment Works, Maresfield Household Waste Recycling Centre, Woodlands in vessel composting site, Newhaven Energy Recovery Facility, The Keep, Amex Stadium, Falmer, Brighton Station developments, Amex House, Hollingdean waste facilities, the Royal Alexandra children’s hospital, Bexhill Hastings Link Road (BHLR) and four school developments. Further details of previous housing and major developments (including the BHLR) in East Sussex and Brighton & Hove are set out in the Appendix A.
3.12 Of interest is that in 2014 approximately 192 000 tonnes of aggregate was used in the construction of the BHLR. Over 30% of this material was imported from Lydd quarry and about 18% from rail borne imports transported from Newhaven. Overall construction of the road has involved 550 000 tonnes of material with over 40% being recycled construction aggregate. More details are given in Appendix A.
3.13 Another measure of demand could be the sources of aggregate used in the plan area. The NPPG states that "for some types of aggregate (such as high quality polished stone value, concreting sand and building sand), it will be necessary to carry out a separate assessment for different types of aggregate in preparing a Local Aggregate Assessment. This is critical to ensure that the quality of aggregate is appropriate for its intended use, since not all aggregates can be used for all construction purposes". Some of this information is set out in the previous chapter "Geology and Minerals Uses". It is hoped that more details will become available through the Review of Waste and Minerals Local Plan. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 19
Demand3
Future Demand
National & Regional Guidelines for Aggregates Provision in England 2005 to 2020
3.14 The forecasting model used to calculate the national and regional guidelines utilises predicted growth in gross value added in the construction sector to extend the input data up to 2020. Between 2000 and 2011, annual consumption was expected to increase by about 5%. Resulting rates of construction demand were then extrapolated. The results indicated a reduced demand for primary aggregates even though a growth in construction activity was envisaged.
3.15 These predictions should be treated with caution because of the changes in the economy over the last 10 years. Since the start of the 2008 recession, the construction sector in the UK has significantly contracted. However, with the economic recovery underway, the demand for construction is starting to rise again, and significant increases in employment and output are predicted for the sector in the future. The upturn in the prosperity of the sector is bringing about a renewed focus on issues such as ‘green’ and sustainable construction practices (1).
3.16 Similar trends can be observed in the construction sector in East Sussex. Construction is an important sector for the county, which contributes around 8.4% of overall GVA in the county, and accounts for 6.2% of local employment. There are 3,390 businesses in East Sussex engaged in construction (14.8% of all businesses). There are significant planned developments in house-building as well as development of business facilities and of infrastructure in the county over the next few years, and construction employment and output are predicted to increase. Growth in the county’s construction industry is being further stimulated by initiatives such as Build East Sussex, a network led by East Sussex County Council that aims to develop the construction supply chain across the county(2). The construction industry is one of the sectors anticipated to grow fastest in terms of employment between 2013-2020 in the county.
3.17 In August 2018 the Minerals Product Association (MPA) reported that "the construction market demand for mineral products rebounded in 2018 Q2 from a very poor first quarter of the year, when activity had been affected by the cumulative effect of exceptionally bad weather and the collapse of the construction company, Carillion. After accounting for typical seasonal variations, sales volumes for aggregates and ready-mixed concrete saw an increase by 9.2% and 9.8% respectively in 2018 Q2 compared to the previous quarter, and by 11.3% for asphalt. Materials such as aggregates and ready-mixed concrete are used across all types of construction work, primarily earlier in project timelines. The recovery in sales volumes for these materials is a clear indication that general construction activity also rebounded from the slow start of the year."
1 East Sussex in Figures 2 East Sussex in Figures 20 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
3Demand
3.18 In July 2018 the MPA published their UK Minerals Strategy - Meeting the demand for minerals and mineral products sustainably for the next 25 years.
3.19 Forecast of Demand
3.20 As indicated above, in the past a LAA for the Plan Area based on a rolling average of 10 years sales data was not been considered appropriate. Future demand rates will very much depend on the local economy’s response to growth in economic activity and how intensively primary aggregates are used. Consumption of primary aggregates was about 1,200,000 tonnes in 2014 plus a possible consumption of 250,000 tonnes of recycled and secondary aggregates. The Review of the Waste and Minerals Local Plan seeks to establish the demand for construction aggregates in the Plan Area.
Other Relevant Local Information
3.21 The NPPG indicates that a LAA could utilise other relevant local information. Details on the local economy are set out in East Sussex in Figures website (for East Sussex).
3.22 The level of planned infrastructure in the area can assist in assessing local demand for aggregates. Allocations in Local Plans and Infrastructure Development Plans (IDPs) can indicate future levels of local demand. An assessment of IDPs covering East Sussex specifies a large range of services (including school and hospital provision, and leisure facilities) which may need constructional materials. There are also several road schemes and a number of employment allocations identified in East Sussex Local Plans. In Brighton & Hove there are eight strategic Development Areas set out in the City Plan Part One where large scale redevelopment is expected over the Plan Period (up to 2030). Within these area, a number of major areas of development requiring a significant supply of aggregates in their construction are under construction or are expected to come forward in Brighton & Hove in the forthcoming years. Further details of possible allocations including those in the SDNPA are set out in Appendix A.
3.23 Assessment of the level of housing development needed for the next 10 years or more can also help to indicate the level of demand locally for construction aggregates. At least 35 272 housing units are proposed in East Sussex from now and up to 2032. Details of possible housing allocations in Brighton & Hove and the SDNPA are referred to above and set out in the Appendix A. It could be that given the current pressure for housing sites regionally there may be even more development forthcoming than identified in submitted/adopted plans. This could lead to a greater need for aggregates.
3.24 The Review of the Waste and Minerals Local Plan will focus in particular on the connection between future development and demand for aggregates aiming to establish accurate forecasts of materials that may be needed. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 21
Demand3
Previous Apportionment Figures for Land Won Aggregates
3.25 Land won aggregates extraction in the Plan Area has been patchy for many years. Some beach deposits were extracted in the 1980s but ceased in 1991. There was some further activity followed by a period of no operational sharp sand and gravel sites before extraction commenced for a few years at Lydd Quarry near Camber. The position with soft sand was similar with small extraction followed by years of inactivity.
3.26 Consequently by the time of the South East Plan, the sub regional apportionment for the Plan Area based on average sales over the previous seven years period discounting years with highest and lowest sales was 10,000 tonnes per annum.
3.27 The Partial Review of Regional Spatial Strategy for the South East Policy M3 Primary land-won aggregates and sub regional apportionment proposed alternative apportionments. The Submitted Review in March 2009 identified special cases where the methodology should be modified and it was proposed that East Sussex’s apportionment should be limited to 0.1m tonnes per annum to reflect actual availability of resources and deliverability. The Examination in Public Panel noted that the previous RPG9 Panel had identified that East Sussex had very little remaining resource and had recommended a small apportionment. The Panel felt that there was no evidence to take a different view and the Panel agreed the apportionment should be capped at 0.1m tonnes per annum. The Secretary of State’s Proposed Changes to Policy M3 endorsed this finding, noting that 0.1m tonnes per annum reflected actual availability of resources.
3.28 Whilst the South East Plan has now been abolished, Mineral Planning Authorities have been previously recommended to use the figures from the consultation by the Secretary of State on Review of South East Plan Policy M3, published in 2010 as a starting point for provision, unless the planning authorities have new or different information and a robust evidence base.
3.29 It should be noted that the NPPG refers to apportionments by the Aggregates Working Party but this has not yet been undertaken by the South East England Aggregates Working Party.
3.30 The Review of the Waste and Minerals Local Plan will consider and assess the methodology for proposing a figure for aggregates forward planning. 22 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
4Supply 4 Supply
Previous Supply Sales
Land-won sales/production
4.1 Permission for extraction of building sand at Novington sandpit (Stanton’s Farm) was granted in October 2003 and extraction started in September 2007 of a total reserve of approximately 380,000 tonnes of sand & gravel. The site is located in the South Downs National Park. Annual extraction figures over the last few years are unavailable due to confidentiality constraints. The permission was renewed by the South Downs National Park Authority early in in 2017 and at that time the planning application stated that reserves at the quarry were at 350 000 tonnes. There is no extraction of soft sand currently taking place at the site.
4.2 There are also large scale permitted reserves in the far east of the County, around Scotney Court and Wall Farm. These two permissions, originally totalling approximately 4.0 million tonnes of sand & gravel, are part of a larger permission for Lydd Quarry which straddles Kent and East Sussex. Production started within East Sussex in 2011. These reserves have been considered previously as long term allocations for the Plan Area.
4.3 Whilst production figures at Lydd Quarry have previously been subject to confidentiality the operator Brett has made information available to assist in the preparation of the Local Aggregate Assessment. The operator also considers that Lydd Quarry sales are split between East Sussex and Kent on an approximate 50/50 basis.
Year Sales Volume (Tonnes) 2006 300 860 2007 311 797 2008 312 118 2009 359 745 2010 359 250 2011 199 032 (1) 2012 353 371 2013 414,348 2014 441 987 2015 343 818 2016 324 703 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 23
Supply4
2017 338 541
Table 1
1. Production started in East Sussex
4.4 Marine imports–throughput and sources
4.5 There are three Ports within the Plan Area. The Ports of Shoreham (partial), Newhaven and Rye accommodate various minerals wharves as shown in Table 1:
Port No. of Wharves Active in monitoring period Shoreham (Port area within Hove) 3 1 (1)
Newhaven (2) 5 1
Rye 2 1
Table 2 Wharves in the Plan Area 2017
1. Planning permission was granted in November 2017 (reference BH2017/02819) for the erection of plant building and enclosures for aggregate bagging operation at Britannia Wharf at Shoreham Port, which was formerly vacant. The proposed development is effectively a wholesale relocation of the applicant's existing operations at Kingston Railway Wharf on the western arm of the Harbour, which falls under the jurisdiction of West Sussex County Council as Minerals Planning Authority. It is understood that the material to be processed at the site will comprise 60% marine-won sourced from other minerals operators at the port, and 40% land-won from other location inland in West Sussex. 2. Whilst only one wharf (Berth 1) was in operation in 2017, another wharf has been in use for scrap metal. In addition, permission has recently been granted for an asphalt and concrete batching plant at North Quay in Newhaven. The intention is to import aggregates by sea using wharves at North Quay to supply the proposed developments. Initially Berth 5 would be used, and at a later stage imports would then take place at one of the wharves adjacent to the proposal. Permission was also granted in 2017 at Fishers Wharf, East Quay for the construction and use of plant, namely aggregate processing plant, aggregate bagging plant, concrete batching plant and buildings, ancillary offices and stores for processing and utilising aggregates landed at Newhaven Port and distribution of the products by road and rail together with access to the public highway and the extension of an existing rail siding.
4.6 Table 2 below details figures from South East Regional reporting (and other sources) for landings of marine dredged sand and gravel for Rye and Newhaven ports over the last 16 years. In the last two years operators have kindly allowed us to make import figures public to aid reporting. 24 East 4 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 (2) (1) 2011 2012 2013 2014 2015 2016 2017 Sussex, Supply
(3) (4) Marine 346 430 350 323 302 229 202 217 205 106 155 c 78 27 0 0 8 20
dredged South Sand and Downs Gravel
(5) (6) and Crushed 164 37 176 176 176 93 117 181 145 145 129 c n c c c 52 42 Rock Brighton
Total 510 467 526 499 478 322 319 398 350 249 284 c N/a c c c 60 62 &
Table 3 Aggregate Imports and Marine Dredged Material Landed at East Sussex Ports 2000-2017 ('000 tonnes) Hove,
1. estimated from regional data Local 2. C =confidential/no return submitted 3. based on data from NPMP 4. Crown Estate 2012 Aggregate 5. based on data from NPMP 6. n=no data available Assessment, December 2018 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 25
Supply4
4.7 The following graph shows the figures set out in the previous table.
Figure 1 Aggregate Imports and Marine-Dredged Material (showing only data available in the public domain)
4.8 Crushed rock imports were received at Newhaven and Rye Ports during 2017. A small amount of marine sand and gravel and secondary aggregate was also received at Rye Port.
4.9 There are three wharves located at Shoreham Harbour that fall within the Brighton & Hove boundary (one active, two inactive). Historically, Shoreham Harbour data has been collected by West Sussex County Council, as the majority of the Port lies within West Sussex. The LAA is unable to publish landings figures just for the Brighton & Hove wharves due to the commercial sensitivity of releasing figures for one active wharf. Regional information published by the Crown Estate indicates that the amount of marine dredged material imported into Shoreham Port as a whole increased between 2009 and 2011. There was a small decrease in 2012 and 2013, but since 2014 imports of aggregates landed at the Port have steadily increased, and in 2017 were at a high of 1 307 447 tonnes.
4.10 Evidence gathered during the preparation of the Waste and Minerals Plan (in 2011) indicates that over 60% of sand and gravel received on the Brighton & Hove side of Shoreham Port was used within the Plan Area. Mineral wharves located within West Sussex at Shoreham Port also serve markets in the Plan area.
4.11 Substantial deposits of sand and gravel exist on the seabed of the East England Channel (EEC) region, and to a lesser extent the the South Coast region. The EEC has 11 production licences and dredging activity in these areas began in Autumn 2006. Material from the EEC is often destined for wharves on the River Thames (in 2016 65.8% of the tonnage dredged was delivered to the Thames Estuary), but a small amount of material is landed on the South Coast. There are 13 production licences in the South Coast region. 26 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
4Supply
4.12 The amount of aggregate landed at Shoreham Harbour from the South Coast in 2015 was 1 119 773 tonnes, this being 36.7% of the total dredged from the south coast Licenced area (source:The Crown Estate). Other ports receiving imports include Southampton and Langstone (Hayling Island).
4.13 Plans of the EEC and South Coast Licence areas for 2017 are shown below.
Figure 2 Plan of the EEC Licence areas (Source: Crown Estate) East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 27
Supply4
Figure 3 Plan of the south coast Licence areas (Source: Crown Estate)
4.14 Detailed statistics on delivery of marine dredged aggregates are set out in “The area involved – 19th annual report" by the Crown Estate and The British Marine Aggregate Producers Association)During 2016, 0.5% (0.03mt) of the tonnage dredged from the EEC region (4.65mt) was delivered to the South Coast, which includes Shoreham Port.
4.15 During the same period, 96% (2.98mt) of the tonnage dredged from the South Coast licences (3.10 mt total) was delivered to the South Coast, 0.3% to mainland Europe and 3.6% to the Thames Estuary. In terms of imports the South Coast region also received small amounts of marine dredged material from the Thames Estuary, , and South West r regions.
Imports
4.16 AM2014 data indicates that in 2014: 42 000 tonnes land-won sand and gravel, 650 000 tonnes of marine - won aggregate and 280 000 tonnes of crushed won was imported into the East Sussex and Brighton & Hove Plan area. The DCLG has recently published the summary "AM2014 source of primary aggregates by sub-region – percent categories" for 2014. This shows that since 2009 total consumption has increased to 280 000 tonnes crushed rock, and that the amounts supplied by Kent has increased to between 30 and 40 %, and the amount supplied by Somerset has dropped to between 20-30%. Cornwall now supplies between 1-10 %, Conwy has reduced to between 1-10% and Powys supplied 1-10%. Crushed rock is transported 28 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
4Supply
by a mixture of sea, rail, and road. Details of wharves are provided in the paragraphs above. More details will be on obtained on modes of transporting aggregates as part of the Review of the Waste and Minerals Local Plan review.
4.17 A railhead has been reinstated at Newhaven. Imports of crushed rock into Newhaven commenced in 2014, initially to serve the Bexhill - Hastings Link Road construction project. Sales totals for materials imported by rail to Newhaven over the last four years are set out below. Exports of IBA are also set out for information. Notably this data shows a marked increase in rail imports of sharp sand and gravel, and recycled aggregate since 2014. There are also aggregate railheads close to the Plan Areas at Crawley and Ardingly in West Sussex.
Newhaven Railhead 2014 2015 2016 Sales 2017 Sales Material in (tonnes) Sales Sales
Imported crushed rock from 45 852 99 579 74 602 72 442 Somerset
Imported recycled aggregate 1 550 24 505 35 658 45 090 from Brentford
Imported sharp sand and 0 735 19 248 25 495 gravel
Exported Incinerator Bottom 61,283 55,897 44 753 N/A Ash (IBA)
Table 4
Secondary/Recycled Aggregates
4.18 Previously a best estimate of recycled aggregates production in the Plan Area has been 240,000 tonnes, based on 2008/9 figures for recycled aggregates produced at construction, demolition and excavated waste (CDEW) management facilities in East Sussex and Brighton & Hove. However, recent monitoring of sites to obtain data for 2017 saw a much improved response rate compared with previous years, and an overall production figure of at least 278 000 tpa has been calculated. A plan showing the location of current recycled and secondary aggregate facilities is set out in Map 4, and a list of sites can be found in the Waste and Minerals Monitoring Report 2017/18.
4.19 In addition, it is estimated that annually up to 80 000 tonnes of secondary aggregate are produced and imported into the Plan Area from the following sources : Ashdown and Chailey Brickworks are thought to produce up to 14 000 tpa of brick waste. The brick waste will either be used on site for quarry roads or in some circumstances sold as hard-core. Newhaven Energy Recovery Facility creates between 44 000 and 61 000 tpa of IBA (see table 4 above). The IBA material is exported by rail (currently to Brentford) where it is processed into recycled aggregate for uses including as a road construction material. Over the last three East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 29
Supply4 years the amount of this material rail imported back into Newhaven has grown significantly. In the last few years furnace bottom ash (FBA) has been imported from Europe into Rye Harbour. FBA can be used a secondary aggregate.
4.20 Overall, the the Plan Area is considered to have a capacity in the region of 739 000 tonnes for recycling Construction, Demolition and Excavation Waste (3)
Future Supply Options
Land-won
4.21 Planning permission was recently renewed at Novington sandpit to allow the extraction of sand and restoration of the site to be completed not later than October 2026. Remaining reserves at the quarry are considered to be in the region of 350 000 mt of reserves. In 2013 the conditions attached to planning permission MR/5 covering Novington sandpit were reviewed.
4.22 As indicated earlier, there are large scale permitted reserves in the far east of the County related to Lydd Quarry. There are two extant planning permissions covering Scotney Court (Area 10) and Scotney Court Extension/Wall Farm (Area 11/12). These permissions originally amounted to 3.23m tonnes of sand and gravel. Extraction commenced in Area 10 in 2011. The operator has mostly completed extraction in this area. Extraction started in Area 11 in January 2013 and is almost complete. A condition attached to the permission would require a renewal application in 2021.
4.23 The Waste and Minerals Plan, adopted in February 2013, estimated that the extraction at Scotney Court Extension/Wall Farm could last until 2026 based on the assumption of an average annual extraction rate of 270,000 tonnes. Production figures made publicly available by the operator indicate that extraction rates have been higher than expected over the last few years (see Table 1). Reserves at the end of 2017 were in the region of 1 million tonne and the operator reported at that time that only about three years of supply remained at current levels of production. More recent (Nov 2018) reports indicate that this figure may now be less than two years.
4.24 Natural England confirmed the extension of the the Special Protection Area and Ramsar designations covering Dungeness, Romney Marsh and Rye Bay in March 2016. The designations cover or are adjacent to all the sand and gravel resource in this part of the County (see paragraph 5.9). Natural England previously raised concerns related to mineral extraction, and the Waste and Minerals Plan has therefore a note added, related to Areas 11 & 12 extraction rate, that the estimate is subject to a further Habitat Regulations Assessment. The next opportunity for a hydrological assessment is the Review of Consents (RoC) under Regulation 63 of the Conservation of Habitats and Species Regulations 2010. The RoC process is now underway.
3 Approximate figure as at 1 April 2018 30 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
4Supply
4.25 As mentioned earlier in this document the Authorities will be considering whether any additional resources are required to meet demand for land-won aggregates through the Review of the Waste and Minerals Local Plan.
4.26 Due to its dormant status and the significant development constraints affecting the site, it is considered inappropriate to include the remaining reserves at Castle Water as part of the future land-won supply fro the Plan area.
4.27 Marine
4.28 The Marine Management Organisation (MMO) reports(5) that the South Marine Plan Areas (covering the East English Channel and South Coast region) are currently the second busiest area in England for marine aggregate extraction in terms of tonnage dredged, licensed area, and area dredged. Over the past 20 years the area permitted for dredging has changed. Many of the historic licence areas have reduced in size, and over the same time new production licence areas have been awarded. The MMO considers that the following are potential core issues for the the marine aggregate industry in the South Marine Plan Area:
Determination of the 15 years marine licence applications for dredging within the South Marine Plan will mean that the marine plans, with their 20-years focus, will have an influence on the marine aggregate industry over a 30-years period
The current dredging fleet is aged and the South Plans could influence the marine aggregate industry’s next cycle of capital investment, estimated to be £1 billion
With the effects of climate change posed by sea level rise, the role of the aggregates industry in supplying marine sand and gravel for coast protection and amenity purposes will become increasingly important over the lifetime of the marine plans
requirements for large volumes of construction aggregate to support local major infrastructure projects taking place in the marine plan area (port developments, offshore wind farms) can be expected to increase over the marine plan period, and marine sand and gravel is expected to play a role in meeting this need.
4.29 The South Marine Plan was published by the MMO for in 2018.
4.30 The adopted Waste and Minerals Local Plan safeguards capacity for landing, processing and handling minerals at Shoreham, Newhaven and Rye Ports and sets out details of the safeguarded wharf areas. Alternative use proposals would need to demonstrate no net loss of capacity and the mineral planning authorities expect to be consulted on any proposals for non minerals development.
5 South Inshore and South Offshore Marine Plan Areas, South Plan Analytical Report (SPAR) 2014 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 31
Supply4
4.31 There are currently several strategies being put forward by other organisations which concern the port areas at Shoreham, Rye and Newhaven. The Authorities will seek to ensure safeguarding of wharf capacity as part of any development at the ports. Proposals for other uses at ports would need to demonstrate that sufficient alternative mineral wharf capacity (tonnage) is deliverable and available to meet needs in the Plan Area for the plan period before the Authorities would accede to alternative development of the site. Proposals for new residential, business or amenity development in proximity to aggregate wharves should be assessed to ensure the impact of existing operations is fully addressed. The safeguarding arrangements would apply to all existing permitted, planned and potential sites regardless of whether they are currently in use.
4.32 Shoreham Port is partly within West Sussex, so landings at wharves in the West Sussex part also help meet demand in the western part of the Plan Area. On that basis provision of equivalent capacity (tonnage) of minerals wharfage within either part of Shoreham Port may be acceptable subject to similar safeguarding by West Sussex County Council (WSCC) as Minerals Planning Authority.
4.33 Adur District Council, Brighton & Hove City Council, West Sussex County Council (WSCC) and Shoreham Port Authority are partners in the preparation of the Shoreham Harbour Joint Area Action Plan (JAAP) which sets out a 15 – 20 years plan to guide the regeneration of Shoreham Harbour. The draft JAAP outlines proposals for housing, employment and economy and environmental improvements. In order to achieve this, some consolidation of operations and redevelopment of mineral wharves (particularly in West Sussex) is proposed. Ferry Wharf (a vacant mineral wharf) on the Brighton & Hove side of the port is proposed for redevelopment. The Public Examination into the JAAP was held in September this year.
4.34 It is recognised that the provision and safeguarding of minerals wharfage is a key issue if the JAAP aims are to be achieved. To this end the JAAP partners, together with South Downs National Park Authority, and ESCC have signed a Statement of Common Ground (SOCG). The purpose of the SOCG is to underpin effective cooperation and collaboration between the partners in addressing strategic cross-boundary issues as they relate to planning for minerals infrastructure and safeguarding in Shoreham Harbour. The SoCG was updated in July 2016 to reflect new data and progress in Local Plan preparation. Policy SP 9 in the WMSP will be the mechanism for assessing the impact on wharf capacity at the Brighton & Hove section of the Port from any development proposals in this area.
4.35 It is hoped that future joint working by authorities will address the safeguarding issues. The West Sussex joint MLP was adopted in July 2018 and includes proposals for minerals wharfage at Shoreham and Littlehampton in line with the SoCG.
4.36 Newhaven Port Authority published a Port Masterplan in January 2012. This plan expects to see aggregate imports to continue at North Quay over the short to medium term, and will encourage use of the wharves for aggregates. 32 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
4Supply
Marine dredged aggregate imports ceased at the Port in May 2013 due to the closure of import facilities at Newhaven. Currently imports are restricted to crushed rock from quarries including those in Cornwall, Wales, Ireland and France. However, permission has been granted for two sites which will import aggregates (see Footnote Table 1) at Newhaven Port, and this should affirm the future role of the Port for importing aggregates.(6). Enterprise Zone status commenced in April 2017 on an area of Newhaven covering 8 strategic sites (see Appendix A for details).
4.37 There is no information to suggest that imports at Rye Port could not continue.
Imports
4.38 Imports of marine sand and gravel are also likely to continue as there is likely to be sufficient licenced capacity in the English Channel (see paragraphs above). Providing safeguarding of wharves is maintained at current capacity, supplies should still be able to reach the Plan Area market.
4.39 It is understood that the crushed rock capacity at quarries in Somerset and Conwy have sufficient permitted reserves at the quarries to ensure a steady and continual supply into the Plan Area. The DCLG summary report identifies 20-30% of imports consumed in the Plan Area in 2014 were from Cornwall. Future monitoring will establish whether this new source of material turns out to be a long term supply.
Recycled / Secondary
4.40 There is no current evidence to suggest that the existing capacity for producing recycled and secondary aggregates will not be maintained. The amount of incinerator bottom ash arising from the Newhaven ERF is considered likely to remain constant, although technically it cannot be counted as a secondary aggregate until it has been processed, and this does not occur in the Plan Area. However, in the last three years processed material in the form of recycled aggregate was rail imported back into the Plan Area at Newhaven. It is assumed therefore that facilities in the Plan Area will continue to contribute to aggregates supply in the area. The locations of recycled and secondary aggregate facilities in East Sussex and Brighton & Hove are set out in Map 4 at the end of this document.
4.41 The Authorities' survey of recycled aggregates sites in 2018 (for the AM2017 survey) resulted in a very good coverage and response rate this year, which will contribute to improved data in the future. In addition, SEEAWP have been investigating alternative methods of calculating recycled aggregates and this may assist in providing better data.
4.42 In 2014 the MMO published a report on the "Use of beneficial dredged materials in the South Inshore and South Offshore Marine Plan Areas". This looks at the existing and potential uses of dredged materials arising from capital or
6 Newhaven Port Authority East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 33
Supply4 maintenance dredging for coastal defence, beach replenishment or habitat creation. Up to 2 million tonnes of dredge material could be produced annually from maintenance dredging. This is likely to comprise silts and clay but also could be some sand and gravel. A further 31 million tonnes could be produced from capital dredging over the next 10 years. Some projects have already taken place using these materials and further use is planned. The report states that there is scope for further beneficial use of materials provided that they are suitably matched and that the re-use logistics can be agreed. This source of alternative aggregates may therefore assist in meeting the need for aggregates in the Plan area in the next decade. 34 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
5Environmental constraints 5 Environmental constraints
The Environment of the Plan Area
Land-won
5.1 Large parts of the Plan Area are subject to environmental constraints. Two thirds of the area is covered the South Downs National Park (SDNP) and the High Weald Area of Outstanding Natural Beauty together, and other tracts of land are also designated as being of international and national environmental importance.
5.2 A number of areas are designated for wildlife conservation. These include two Special Areas of Conservation (SACs) and five Special Protection Areas (SPAs) and two large Ramsar sites at Pevensey Levels, and near Rye. There are four National Nature Reserves and 25 Local Nature Reserves. National designations include 64 Sites of Special Scientific Interest (SSSIs)(7). There are two Regionally Important Geological sites and numerous Sites of Nature Conservation Importance (SNCIs). One sixth of the area of Brighton & Hove is covered by nature conservation designations. These areas need to be protected in order to maintain the rich and varied landscape character and biodiversity within the Plan Area.
5.3 The South Downs are formed by a line of hills and vales extending along the coast westwards from Eastbourne. It is a unique, open, rolling landscape dissected by major river valleys cut by the Ouse and Cuckmere. Whilst now no longer active, chalk quarrying was a long established industry in the area, and has had a noticeable impact on the landscape, especially along the scarp slope and around Lewes. To the north of the chalk are the Greensand beds with the Folkestone Formation extending north west from Lewes in East Sussex, across West Sussex and into Hampshire. The area within East Sussex was previously outside the Sussex Downs AONB but it is now located within the South Downs National Park.
5.4 The High Weald AONB is a landscape of rolling hills, scattered farmsteads, small woodlands, irregular-shaped fields, open heaths and ancient routeways. It also includes the Ashdown Forest. The High Weald covers much of the northern, central and eastern parts of the Plan area. It is a faulted structure comprising clays and sandstones (collectively known as the Hastings Beds). This varied and extensively eroded geology has produced an attractive and sensitive landscape, most of which is within the High Weald Area of Outstanding Natural Beauty.
5.5 The Low Weald is a gently undulating clay vale which separates the High Weald from the Chalk Downs to the south.
7 These are split into 391 separate units East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 35
Environmental constraints5
5.6 The Coastal Marshes are located between Eastbourne and Bexhill, and in the Rye Bay/Camber area either side of the Rother estuary. Inundated by the sea in recent geological times, these areas comprise large flat sheets of alluvium, extending inland over the Pevensey Levels and Romney Marsh.
Environmental Constraints and minerals working
5.7 The Plan Area is therefore heavily affected by environmental constraints. Minerals can only be dug where they naturally occur, and given the exploitation that has already taken place, the very few places in the county where resources occur are constrained by environmental factors. Opportunities for new aggregate production areas will therefore be very challenging.
5.8 Even the current sites for extraction have had further recent environmental constraints emerge. Novington sand pit (Stanton's Farm) which has extracted from a limited exposure of the Folkestone Beds north-west of Lewes was not previously in the AONB, and is now located in the SDNP.
5.9 The working area at Lydd Quarry is covered by an SSSI (Dungeness, Romney Marsh and Rye Bay). Natural England confirmed the extension of the the Special Protection Area and Ramsar designations covering Dungeness, Romney Marsh and Rye Bay in March 2016. The designations cover or are adjacent to all the sand and gravel resource in this part of the County. The Review of Consents will have to establish whether any of the Lydd Quarry development already permitted, would have a significant effect on the European site in view of the site’s conservation objectives.
5.10 The environmental impact of marine dredging is controlled and monitored by the Licensing system administered by the MMO. Effects of secondary aggregate production would be regulated by planning and permitting legislation and controls. 36 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
6Balance 6 Balance
Balance between Supply and Demand
6.1 The adopted Waste and Minerals Local Plan’s approach to minerals is to make provision for a steady supply in accordance with National Policy, and to allow primary production where it is demonstrated the need cannot be met by sources of alternative materials and that there is evidence of viable resource.
6.2 The evidence base for the Waste and Minerals Plan examined the particular circumstances related to aggregates. The Plan Area needs a mixture of land won production, marine landings, imports and recycled & secondary aggregates. The Plan Area already has a significant reliance on the contribution from marine sources. This section looks at the balance between supply and demand across all sources. However detailed analysis and possible changes to patterns of supply and demand will be considered as part of the Review of the Waste and Minerals Local Plan.
6.3 Regionally, South east England consumed more primary aggregate in 2014 than sales of the regions resources in the same period. Net imports as a percentage of consumption were 26%, continuing a rising trend. The largest sources of imports are crushed rock from Somerset and Leicestershire. In addition, 0.5 mt of sand and gravel is imported by sea from outside England and Wales. There has been a general decline in sales over the last decade and the soft sand contribution has increased.
6.4 Land-won
6.5 As mentioned in the Introduction, the adopted joint East Sussex, South Downs and Brighton & Hove Waste and Minerals Local Plan (WMLP) seeks to maintain provision for the production of land-won aggregates at a rate of 0.10 mtpa throughout the plan period, and to maintain a landbank of at least 7 years of planning permissions. The WMLP considered that existing planning permissions provided this requirement up to 2026 and that the landbank would be more than met by current permissions.
6.6 In terms of future demand, past LAAs established that the forecast of primary land won aggregate demand for all the Plan Area would not be based on sales data. As a substitute, the Apportionment figure in the Adopted WMLP of 0.1m tonnes p.a was used as the principal indicator of demand. Previous LAAs also established that in actual terms, the 10 years sales figures included confidential information but in total was about 1.5 million tonnes. Current data updates indicate that this figure may now exceed 2.4 million tonnes.
6.7 The landbank for the Plan Area has been calculated in the past as the full resource available at Stanton's Farm plus the reserve from the permitted sites at Lydd Quarry within the boundary of East Sussex divided by 0.1mtpa. Applying this method gives a landbank figure at the end of 2017 of 13.5 years. However, the use East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 37
Balance6 of 0.1mtpa as the principal indicator of demand, and the method of calculating the landbank in future, will be re-examined as part of the Review of Waste and Minerals Local Plan. As such the landbank for 2017 should only be read as a nominal figure and not as an actual measure of supply in the Plan area. Local information indicates that the landbank could well be lower than 13.5 years, and the Lydd quarry operators state that the current permitted resource is less than two years supply (Nov 2018). In addition 50% of the material extracted in East Sussex is exported to Kent.
6.8 Along with other mineral planning authorities in the South East, the authorities have signed a Statement of Common Ground on soft sand which aims to collaboratively address supply issues facing an important mineral used by the construction industry. Amongst various actions identified in the SoCG one is for authorities to safeguard the entire soft sand resource in their Mineral Local Plans (MLPs) from surface development that would otherwise sterilise the mineral, and to include policies for the prior extraction of the mineral.
6.9 Soft sand is required to make mortar for housebuilding. It is distinct from both coarse sand and gravel, and also distinct from silica sand. The main source of soft sand in the South East is the Folkestone Beds, which run through Kent, East Sussex, West Sussex, Hampshire and Surrey. The only current source of soft sand within the Plan Area is an existing permission at Novington Sandpit, which is wholly within the SDNP.
6.10 All the Mineral Planning Authorities of the former South East Region form the South East England Aggregate Working Party (SEEAWP) along with representatives from industry and mineral operators. This group is the focus for working together on cross-boundary and Duty to Cooperate issues. Following on from work undertaken for the original soft sand SoCG, the South East Minerals Planning Authorities have agreed to produce a Position Statement to cover the issue for the whole region. This Position Statement will form the basis for ongoing Duty to Cooperate work that may be needed to ensure the steady supply of soft sand as required by the NPPF.
6.11 The authorities are working on SoCGs with Kent County Council and with West Sussex County Council as part of the joint work on the Review of the Waste and Minerals Plan.
Marine Sources
6.12 As can be seen from paragraph 4.11, substantial marine aggregates reserves exist along the South Coast. The picture here is that there is more than adequate supply and that there is a potential resource that could meet additional demand if land won sources were to be further depleted in the South East.
6.13 The principal constraint on the level of marine landings during the Plan period is therefore not considered to be the level of marine reserves, but the security of port access (loss of wharves to other uses), channel and berth 38 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
6Balance
restrictions, vessel availability and investment in modern wharf infrastructure. The British Marine Aggregate Producers Association (BMAPA) maintain that there is a long term future for smaller vessels to import to smaller wharves and local operators have indicated that this is the case in East Sussex.
6.14 The importation of crushed rock from the UK or further afield is limited by wharf capacity and market forces. As there is no availability of this material from within the Plan Area, landings directly reflect demand. Crushed rock can be landed to non-specialist wharves, improving flexibility within port areas.(8)
6.15 According to the Port Authorities at Shoreham, Newhaven and Rye, sufficient wharf capacity apparently remains in the Plan Area to allow significant landings to continue for the foreseeable future. As spare capacity appears to exist at the present time for marine and crushed rock landings (some wharfage is underused at all Ports in the Plan area - see Table 1), these established operations provide flexibility to deliver additional supplies should they be required to meet demand in peak years.
6.16 However, in order to maintain potential wharf capacity for the future it is essential that adequate safeguarding measures are in place to enable the authorities to respond to threats of redevelopment of wharves from alternative uses. Comprehensive safeguarding policy will be an important tool in achieving strategic provision of wharf capacity within the various emerging plans for ports in the plan area (see Supply chapter).
Imports
6.17 Again, with regards to marine imports, safeguarding wharves is key to the future security of landings. It is also crucial that rail import facilities are protected from redevelopment. Waste and Minerals Local Plan policy seeks to safeguard existing, planned and potential railheads and minerals wharves, and to monitor the need for these facilities. Policies to safeguard wharves and railheads, concrete batching, coated materials manufacture and other concrete products facilities are set out in the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan. Regional discussion will be required to secure rail and wharf facilities which contribute provision to the Plan Area. Positive dialogue with adjoining and more distant mineral planning authorities will also be needed to check and maintain security of supply of aggregates, particularly crushed rock. This should be enabled through good practice, aggregate working party arrangements and Duty to Cooperate requirements.
8 As the method of landing crushed rock is simpler than landing marine aggregates there is less attraction to move to larger vessels to reduce costs and crushed rock does not require specialist handing equipment. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 39
Balance6
Recycled / Secondary
6.18 Secondary aggregates can provide an alternative to primary aggregates, and subject to technological advancement, there is potential scope to substitute more recycled aggregates. Economic instruments such as the Landfill Tax have had a considerable impact on the level of material available, forcing previously landfilled CDEW waste to be processed into recycled aggregate.
6.19 There are moves to increase utilisation of alternative sources with a consequential increased contribution to total demand. However, the availability and utilisation rate remains unpredictable and substitution is not always possible. Primary resources may well be required to a significant extent for the foreseeable future.
6.20 A diagrammatic plan summarising the origin of locally won and produced aggregates, as well as consumption and the nature of imports into the Plan area, is included as Map 2 based on 2014 data. 40 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
7Conclusions 7 Conclusions
7.1 The Authorities are undertaking a review of the Waste and Minerals Local Plan and this will focus in particular on aggregate policies, and therefore on different supply options and ways of meeting demand for construction demand. There are ongoing discussions regarding sites submitted as part of the Call for Sites and Evidence consultation , and adoption of this LAA is planned before formal consideration of these responses. It would not therefore be appropriate to pre-empt possible changes in aggregate supply in this document. Discussion of future demand and supply scenarios is therefore not included. These details will be assessed at the next stage of the Local Plan Review process.
7.2 This LAA has therefore examined the latest information and data available on aggregates and the key conclusions are:
With regards to land-won supply there has been a small decrease in the three year average production at Lydd Quarry compared to last year's LAA reported figure. However the rate of production is still above the anticipated rate in the current planning application. At the end of 2017 one million tonnes of reserves remained at Lydd Quarry.
Along with other mineral planning authorities in the South East, the authorities have signed a SOCG on soft sand which aims to collaboratively address supply issues facing an important mineral used by the construction industry. The requirements of the SoCG will be examined as part of the Review of the Waste and Minerals Local Plan. Evidence is currently being gathered on the origins of soft sand being imported into the Plan Area.
There is small but steady supply of marine imports at Newhaven Port, and Rye.
Since 2014 the the Newhaven railhead has received a steady supply of imports of crushed rock, and increasing amounts of recycled aggregate and sand and gravel.
Imports at Shoreham Port have steadily increased, and material from South Coast Licenses forms the majority of the aggregate supply. East Sussex and Brighton & Hove is very dependant on these imports.
Planning permission was granted this year for Installation and operation of asphalt, concrete batching, & gully waste plants, and ancillary development and access at North Quay, Newhaven. Some crushed rock materials will be brought in by ship using a nearby wharf. Planning permission has also recently been granted for an aggregate processing plant, aggregate bagging plant, concrete batching plant and buildings, ancillary offices and stores for processing and utilising aggregates landed at Newhaven Port (marine dredged aggregate and crushed rock) and distribution of the products by road and rail together with access to the public highway and the extension of an existing rail siding. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 41
Conclusions7
Ultimately this permission could result in an additional 420 000 tonnes pa of marine imported aggregates although some of the material will be exported out of Plan Area. These permissions re affirm the future role of Newhaven Port for the import of aggregate materials.
The East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan was adopted in February 2017, and emphasises the importance of safeguarding wharves and railheads, and other minerals infrastructure for aggregate imports.
The Statement of Common Ground on safeguarding minerals wharfage at Shoreham Port sets the framework for positive co-operation between the relevant authorities. This should strengthen aims to protect wharf capacity from redevelopment and to support and increase marine imports.
The Authorities' survey of recycled aggregates sites in 2018 (for the AM2017 survey) resulted in an improved coverage and almost 100% response rate this year, which has provided more accurate data for this year and should contribute to improved information in the future.
7.3 The Authorities consider that where appropriate they have taken into account the requirements for preparing the LAA set by national advice, SEEAWP and the MPA/POS guidance. There are certain areas where more work is required, such as justification of a LAA provision rate, and analysis of further resource opportunities and limitations on local land-won supply. These matters will be assessed in detail as part of the Review of the Waste and Minerals Local Plan. 42 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
APast and Future Development Appendix A: Past and Future Development
Past Development
East Sussex
Between 2007/8 and 2017/18 there were 15 076 housing completions in East Sussex.
Over the last decade the following major infrastructure projects have been completed within the county: Peacehaven Waste Water Treatment Works, Maresfield Household Waste Recycling Centre, Woodlands in vessel composting site, Newhaven Energy Recovery Facility, Bexhill Hastings Link Road (BHLR), four school developments, and North East Bexhill Gateway Road.
Bexhill Hastings Link Road (BHLR)
Construction of the the BHLR started in 2013 and opened at the end of 2015 and is known as the Combe Valley Way. The BHLR used both recycled aggregate and primary aggregate in its construction. Figures are available for the period September 2013 – March 2016 which indicate the sources of aggregate material used in the road construction. The total amount of aggregate used in construction is approximately 550 000 tonnes. Since construction began in 2013 over 40% of the material has been recycled construction aggregate. The total amount of aggregates used per year (in tonnes) is as follows:
Year Tonnes
2013 41 761
2014 192 407
2015 317 148
2016 96 (recycled material for the Greenway)
TOTAL 551 413
Table 1 Amount of aggregates used in construction of the BHLR
The early stages of road construction in 2013 involved formation of piling platforms, haul roads and compounds using aggregates from East Sussex and Kent. In the later stages of construction during 2014 and 2015, primary aggregate was sourced from Lydd Quarry in East Sussex, and Denge and Blaise Farm quarries in Kent (49 km and 58km from road site respectively). From 2014 significant amounts of crushed limestone were also imported from Day Aggregates. Before reaching the BHLR site East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 43
Past and Future DevelopmentA by road, this material was imported to the railhead at Newhaven. It is believed that the majority of the limestone originated from Somerset. During 2014 Day Aggregates also rail imported some recycled material from their processing facility at Brentford London for use in the BHLR.
In 2014 approximately 192 000 tonnes of aggregate was used in the construction of the BHLR. Over 30% of this material was imported from Lydd quarry and about 18% from rail borne imports transported from Newhaven.
In 2015 317 148 tonnes was used in construction - 60% was imported from Blaise Quarry in Kent, 5% from the railhead at Newhaven, and 7.5% from Lydd Quarry. These percentages largely reflect the situation over the the whole construction period.
Brighton & Hove
Between 2007 and 2017 there were 4,677 housing completions in Brighton & Hove.
Major infrastructure projects that have taken place in Brighton & Hove over the last decade include The Keep, Falmer Stadium, Brighton Station developments, Amex House, Hollingdean waste facilities and the Royal Alex children’s hospital.
Future development
East Sussex including the area covered by the South Downs National Park
Based on an assessment of Local Plans (at various stages up to adoption), there are a number of allocations for housing and employment in the East Sussex area which could involve construction aggregates in their development. The various allocations cover a period longer than 10 years (up to 2032). Overall, at least 35 272 dwellings and 331,350 square metres of employment floorspace are proposed.
A review of Infrastructure Development Plans in the county highlights a number of projects in the short (the next 5 years) and medium (5-10 years) term. These include increased educational, library, health treatment, education, community centres, and sports and leisure provision. Also identified are coast and flood protection, waste water treatment and sewerage improvements. Whilst the precise aggregate requirements for these developments are currently unknown, some sand and gravel material is likely to needed during constructional phases.
The Rampion Windfarm as well as new operation and maintenance infrastructure at East Quay, Newhaven Port is underway. Construction of the Rampion operations and maintenance infrastructure at East quay in Newhaven started during the Summer 2017. All of the 116 turbines at Rampion are now able to generate electricity and deliver power to the grid. Works will continue both on and offshore, to prepare the site for full operation later this year (2017). this will include full reinstatement of the onshore cable. 44 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
APast and Future Development
Some strategic road improvements in the county are also planned. Strategic Economic Plans produced for the Local Economic Partnerships covering the county also identify a number of transport related schemes, including Phase 2 of the Newhaven Port Access Road planned to commence at the end of October 2018.
Enterprise Zone (EZ) status commenced in April 2017 on an area of Newhaven covering 8 strategic sites. It is estimated that EZ status will lead to the creation of around 55,000m² of new commercial floor space, refurbish a further 15,000m² of commercial floor space and create and sustain around 2,000 jobs over the Zone’s 25-year lifespan. Alongside the other Newhaven-focused regeneration activity, the Enterprise Zone has the potential to have a significant positive impact on local residents, businesses and economic growth. There are likely to be aggregate demand requirements arising from such development.
A single carriageway road between the A21 Sedlescombe Road North and Queensway (Queensway Gateway Road) will facilitate access to employment sites in north Hastings. Construction has commenced and the scheme is programmed for completion in 2019 (Autumn).
The North Bexhill Access Road (a 2.4km single carriageway road link between the A269 Ninfield Road and the Bexhill Hastings Link Road) will unlock housing and employment in the North Bexhill area. Construction commenced in August 2016 and will be completed late 2018 or early 2019.
Following the publication of Highways England’s (HE) Roads Investment Strategy in March 2015, Highways England consulted on proposals for a package of smaller scale improvements for the A27 east of Lewes part of the strategic road network in late 2016. HE made their preferred route announcement on the package of smaller scale improvements in September 2016 which comprises:
Improvement to the A27/A2270 signalised junction and two lanes in both directions to Cophall Roundabout as well as signalisation of Gainborough Lane junction
Ghost Island junction improvement and cross facilities at Wilmington to improve safety
Enlarged roundabout with two lane entry on both the east and westbound A27 arms at Drusillas to improve capacity
Shared use path between Beddingham and Polegate.
HE are currently programming construction commencing in 2020. These improvements will seek to address the short term capacity issues on the A27 corridor. However the A27 Reference Group, successfully lobbied for £3m of funding to help develop a strategic outline business case for offline dual carriageway option which will be required to support the housing and employment growth in the area in the medium and long term. HE have commissioned a consultant to undertake East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 45
Past and Future DevelopmentA this work and it is expected that the final business case will be completed in June 2018. The business case will then be submitted by HE to the Department for Transport for their consideration, along with all the other competing schemes, for inclusion in the Roads Investment Strategy 2 which will cover the period 2020 – 2025. RIS 2 is expected to be published next summer due in May and that will set out which schemes are developed further/funded in that five year period.
A.1 The SDNPA submitted its Local Plan to government at the end of April 2018. The Submission Plan sets out a medium level of growth across the SDNP and this includes a modest level of growth within East Sussex. The North Street Quarter in Lewes was previously allocated in the Lewes and South Downs Joint Core Strategy and this allocation is included in the SDNP Submission Local Plan as a strategic site including approximately 415 residential units and at least 5,000 square metres of B1a/B1c floorspace.
A.2 Additionally, in the East Sussex part of the SDNP, a further 278 dwellings and 7,040 sq/m of employment land.sites are proposed for residential and employment development at Alfriston, Kingston-near-Lewes and Lewes.
A.3 Brighton & Hove
There are eight strategic Development Areas set out in the City Plan Part One where large scale redevelopment is expected over the Plan Period (up to 2030). A summary of proposals for each is as follows:
• DA1 Brighton Centre and Churchill Square area: Extension of Churchill Square to provide 20,000m2 retail floorspace. New Brighton Centre (25,000m2 conference centre);
• DA2 Brighton Marina, Gas works and Black rock: 1,940 residential units, 5000m2 retail, 2000m2 B1 floorspace, 10500m2 leisure and recreation floorspace, health facility, primary school;
• DA3 Lewes Road: 810 residential units, 15600m2 employment floorspace, 16000m2 business school, 1300 student rooms, 5,000m2 B1 floorspace;
• DA4 New England Quarter/London Road: 20,000m2 office floorspace, , 1185 residential units, 300 bed space student housing;
• DA5 Eastern Road and Edward Street area: 470 residential units, Hospital rebuild (see above), 400 bed student accommodation, 3,800m2 education floorspace, GP surgery, community building;
• DA6 Hove Station area: 630 residential units, retention or replacement of 13,000m2 employment floorspace;
• DA7 Toads Hole Valley: 700 residential units, 25,000m2 employment floorspace, new secondary school; 46 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
APast and Future Development
• DA8 Shoreham Harbour: 400 residential units; 7500 m2 employment floorspace (within B&H part of the Harbour).
Within these area, a number of major areas of development requiring a significant supply of aggregates in their construction are under construction or are expected to come forward in Brighton & Hove in the forthcoming years. These include the University of Sussex, Preston Barracks, Circus Street, a new King Alfred Leisure Centre, Royal Sussex County Hospital, Brighton Waterfront project, former Amex House site, and Sackville Trading Estate and Coal Yard. East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 47
Imports into plan areaB Appendix B: Imports into plan area
NOTE
B.1 The data in this Appendix is based on that provided by BGS as a summary from AM2014 on consumption by sub-region of crushed rock and sand and gravel. Consumption of both sand and gravel and crushed rock has increased since 2009. Information currently available is not as detailed as that from the 2009 collation and does not include data on transport modes. Where applicable the 2009 import percentage figure is shown is brackets after that for 2014 to indicate any change that has occurred.
Data
B.2 Of the total 920 000 tonnes sand and gravel (land-won and marine) consumed in East Sussex and Brighton & Hove;
20 -30% (16%) was supplied from within East Sussex. 60-70% (70%) was supplied from West Sussex. About 1-10 (10) % was supplied from Kent Medway and Surrey each supplied between 1-10 (5)%. Greater London East supplied 1-10% Oxfordshire, South Downs, and Central Bedfordshire each supplied less than 1%.
B.3 Of the total 280 000 tonnes crushed rock consumed in East Sussex and Brighton & Hove:
Kent supplied between -30 and 40 % Somerset supplied between 20-30 % (60-65%), Cornwall supplied between 1-10 % Conwy supplied between 1-10% (20-25%) Powys supplied 1-10% 20 - 30% of crushed rock is supplied from outside England and Wales Leicestershire, the Peak District National Park and Shropshire each supplied less than 1%. 48 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018
CLAA Requirements Appendix C: LAA Requirements
Minerals Product Association and Planning Officers Society Guidance
C.1 A revised version of the Practice Guidance on the production and use of Local Aggregates Assessment was prepared in May 2017 by the Minerals Product Association and Planning Officers Society. This guidance provides a checklist for consideration by mineral planning authorities and aggregate working parties in assessing the adequacy of local aggregate assessments as follows:
C.2 CHECKLIST
C.3 1. Is the draft LAA comprehensive in assessing all supply options:
C.4 a) Recycled and secondary aggregates? b) Marine dredged aggregate? c) Imports and exports by sea, rail and road? d) Land-won resources of rock and sand and gravel?
C.5 2. Are the assessments realistic and supported by evidence:
C.6 a) Has the mpa used sales returns from and capacity at sites with extant permission? b) Does it identify reasons for significant changes in sales over last 10 years? Does ‘other relevant local information’ justify further investigation or deviation from use of 10 year average of sales? c) Has the mpa used AM data and Crown Estate landing figures and data on licensed reserves? d) Is there reliable evidence on the maintenance of supply, and is there adequate capacity at wharves and rail depots to handle the LAA figure for existing and potential landings and imports? e) Has the mpa considered a ten year sales average? If it is proposing an alternative figure to this, is there adequate justification regarding other relevant local information? f) Is it necessary to carry out a separate assessment and present information for different types of sand and gravel aggregate ? g) Are the assumed and planned contributions from the different sources feasible? h) Is the estimate for the availability and use of recycled and secondary aggregate a rigorous assessment?
C.7 3. Does the draft LAA suitably assess the changes likely to impact on supply and demand over the plan period – has it:
C.8 a) Given consideration of the planned levels of development and infrastructure, including relevant major construction projects outside the mpa area and how these compare to previous years? b) Considered the constraints on resources, production and capacity to supply? c) Taken into account economic and environmental considerations? d) Assessed the implications of such considerations in other authority areas that supply the mineral planning authority? e) Identified a shortage of supply (based on forecast of demand, reserves and capacity)? If so, has this been suitably addressed? East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 49
LAA RequirementsC
C.9 In preparing the LAA has the mpa consulted with (to contribute to meeting the Duty to Cooperate, especially if the LAA is being used as evidence to support preparation of an MLP):
C.10 a) Other relevant mpas including those from/to whom supplies are imported/exported? b) The aggregate industry? c) Environmental bodies? d) Other organisations such as Local Enterprise Partnerships?
C.11 5. What are the implications of the draft LAA figures for the AWP area:
C.12 a) On planned provision in the AWP area? b) On the overall contribution of the AWP to national & local supply, compared with the current Guidelines (or the London Plan)? 50 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 Map 1: Geological Plan including locations of aggregate wharves and railheads, and existing aggregate sites Map 1: Geological Plan including locations of aggregate wharves and railheads, and existing aggregate sites
52 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 Map 2: Origin of aggregate imported, produced and consumed in East Sussex and Brighton & Hove during 2014 Map 2: Origin of aggregate imported, produced and consumed in East Sussex and Brighton & Hove during 2014
54 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 Map 3: Sand and gravel resources in the East English Channel and Thames Estuary (Source: Crown Estate) Map 3: Sand and gravel resources in the East English Channel and Thames Estuary (Source: Crown Estate) the Map East Estuary 3: East Sand Sussex, English South Downs (Source: and and Channel Brighton gravel & Hove, Local Crown Aggregate resources and Assessment, Thames Estate) December in
Sand and gravel resources in the East English Channel and Thames Estuary (Source: Crown Estate) 2018 55 56 East Sussex, South Downs and Brighton & Hove, Local Aggregate Assessment, December 2018 Map 4: Recycled and secondary aggregates sites 2017/18 Map 4: Recycled and secondary aggregates sites 2017/18
East Sussex County Council County Hall St Anne's Crescent Lewes BN7 1UE Phone: 0345 60 80 190 Website: eastsussex.gov.uk
South Downs National Park Authority South Downs Centre North Street Midhurst GU29 9DH Phone: 0300 30 31 053 Website: southdowns.gov.uk
Brighton & Hove City Council Hove Town Hall Norton Road Hove BN3 2BQ Phone: 0127 32 92 505 Website: brighton-hove.gov.uk
December 2018
East Sussex County Council County Hall St Anne's Crescent Lewes BN7 1UE Phone: 0345 60 80 190 Website: eastsussex.gov.uk
February 2019
ISBN: 978-0-86147-546-9