Local Plan Examination

Permitted Capacity for Commercial and Industrial (C&I) Waste

Note to address the technical/factual challenge to the Council’s evidence on commercial/industrial waste recycling/re-use capacity set out in the pre-hearing statement by Cory Environmental Municipal Services Ltd (Rep 760) under Q7.1.

The Council’s evidence on waste management capacity for recycling/re-use facilities for commercial and industrial waste has been challenged on the basis that: 1. Where sites take both C&I and Construction Demolition and Excavation CD&E waste the study has assumed that all this capacity is available, potentially, for C&I waste 2. Capacity for transfer has been included within the overall capacity for recycling & re-use 3. Capacity that is consented but not operational is included within the overall capacity figure.

Each of these points is addressed below.

In Technical Paper W3 (A.23) Table 3 the overall annual capacity for C&I waste is quoted as being 589,978 tonnes. This has been calculated by adding total capacity at recycling sites listed in Table 3.1 (Technical paper W2 – A.22) where they have capacity for a mix of C&I and Construction and demolition (C&D) or inert wastes together with capacity for metal recycling sites (Table 4.1, Technical paper W2 – A.22). Capacity for sites listed only as C&D or inert (in final right hand column of table 3.1 in A.22) has not been included in the calculation of capacity for C&I waste.

The capacity figure quoted in A.23 (table 3) is 294,984 (metal recycling capacity) plus 294,994 (other C&I capacity) which amounts to 589,978 tonnes.

The availability of capacity at sites taking a mix of C&I and C&D/inert waste Having considered the challenge to the Council’s evidence (that it is unreasonable to assume that all capacity at sites taking C&D and C&I waste would be taken up by C&I) the Council has recalculated the capacity of existing recycling sites (see table 1 attached to this note). In doing this it has been assumed that the proportion available for C&I waste will reflect the proportional throughput of C&I waste (as opposed to C&D/inert waste) in 2013. This has been estimated using throughput data available from the Environment Agency’s ‘Waste Data Interrogator database (2013)’ and is shown in Table 1 attached to this note.

It is understood that Cory Environmental Municipal Services (CEMS Ltd) accept this approach (in which C&I capacity at each site is based on the percentage throughput at that site) for estimating site capacity. However concerns have been raised by the CEMS Ltd that the revised capacity table (table 1) includes sites not previously included in Table 3.1 (Technical paper W2 – A.22) and that for some, the total capacity quoted is different.

With regard to the latter point the Council acknowledge the concerns raised but consider provision of an up to date table reflecting the latest position on site capacity and the number of sites is appropriate. It is acknowledged that revisions to Technical paper W2 (A.22) will need to be made to reflect these changes.

Assumptions regarding transfer facilities Where sites are recorded as having a recycling and transfer element it has been assumed that capacity theoretically exists for all waste accepted at the site to be separated and sorted for onward transport and re-processing/re-use, unless the site is recorded as one where a proportion of waste is sent for disposal.

CEMS Ltd have questioned this approach on the basis recycling/re-use activities require more space than transfer activities and that sites may not have sufficient space to achieve 100% recycling.

In Cornwall most of the sites having a transfer & recycling element undertake a waste separation process in order that these materials can be re-used/recycled. At many of the sites this operation is a fairly simple one where different wastes are held in bays/different parts of the site before onward transport. At other sites the process of separation is more sophisticated with the use of dedicated separation plant. However whatever method is used most of the sites express an intention to recycle as much of waste as possible a position reflected in their promotional literature. The Council therefore consider it reasonable to include capacity recorded as ‘recycling/transfer’ within the overall capacity for recycling/re-use.

At sites recorded as having facilities for transfer and disposal (in addition to recycling capacity) it has been assumed that 20% of the site capacity is catering for transfer and eventual disposal.

CEMS Ltd would appear to agree with the methodology of reducing capacity to account for a proportion that deals with waste destined for disposal but have questioned the percentage reduction (20%) used.

In response the Council acknowledge that this is purely an estimate. It is not supported by data. However it is felt that some sort of reduction is reasonable to reflect the fact that sites identify their activities as those involving recycling, transfer and disposal will inevitably be using part of their site capacity to bilk up waste for disposal.

Composting Previous calculations of C&I capacity had excluded capacity at sites taking C&I waste for composting. Much of this capacity is used for ‘Local Authority Collected Waste and is therefore not available to accommodate compostable material from the C&I waste stream. This position reflects Cory’s experience that there is very little C&I waste composted.

Metal recycling As regards metal recycling facilities the inclusion of the total permitted & operational metal recycling capacity has been challenged on the basis that these sites can only accept one type of waste. It has been suggested that only around 5% of metal recycling should be counted within the overall C&I capacity figure as capacity as this would more closely reflect the proportion of metal waste arising between 2009 – 2012 as a proportion of total C&I arisings in those years (Digest of Waste Resource Statistics 2015, DEFRA).

To address this issue and seek a more local perspective the Council have looked at the metal recycling throughput in 2013 as a percentage of throughput in all sites taking C&I waste. This amounted to 33%. If capacity for metal recycling is taken as 33% of the overall estimated capacity for C&I it would avoid the risk of obscuring the availability of capacity to accommodate other C&I arisings. Taking this approach capacity of metal recycling facilities would amount to 97,345 (as opposed to the actual recorded capacity of 294,984).

CEMS Ltd have questioned the above approach and contest the inclusion of metal recycling capacity within the total capacity for C&I waste. In their view metal recycling should be excluded from the C&I waste stream (as in the Gloucestershire Waste Core Strategy, Technical Paper WCS-A Waste Data (update 2010) provided by CEMS Ltd. CEMS Ltd also question whether the metals recycling capacity figure is double counted.

In the Council’s view inclusion of a percentage of the metals recycling capacity, based on throughput would seem a reasonable albeit cautious approach. If Cornwall’s capacity were to be based on the estimated national figure of metals arising as a proportion of the overall C&I waste stream (~ 5%) it would not reflect the local position in Cornwall. In addition other waste planning authorities have taken a similar approach to Cornwall in including their metals recycling capacity within the total recycling capacity for C&I waste. For instance for Devon’s recently adopted Devon Waste Plan 2011-2031 (December 2014) all capacity for C&I including metals was counted together. Like Cornwall their capacity contained a large proportion of metal recycling facilities.

It is acknowledged that there may be some double counting. This is the case with all types of waste facility. The Waste Interrogator does not enable this to be calculated. The figures are based on the best available data.

Non-operational sites Regarding inclusion of non-operational sites only one within the list of sites included within the capacity assessment has a permission but is not operational (Recycling facility at Hallenbeagle). If capacity at this site were to be excluded the overall figure for recycling/re-use capacity would be reduced by 35,000 tpa.

Overall Capacity for C&I waste Having reviewed the capacity of facilities to accommodate C&I waste, on the basis of the assumptions set out above, this now is estimated to be 303,851. This figure is made up of a 97,345 tonne capacity for metal recycling and a 206,506 tonne capacity for other materials from the C&I waste stream. The overall capacity is marginally more than required to meet capacity at the end of the Plan period (281,996). If meets the requirement for capacity over the Plan period. If the permitted but not yet operational site at Hallenbeagle (CEMS Ltd facility) is excluded from the permitted capacity figure, overall permitted capacity falls just below the projected annual capacity requirement at the end of the Plan period (by around 13,000 tonnes).

Policy approach to recycling Notwithstanding the level of existing recycling/re-use capacity the Council is keen to promote this activity and therefore has a positive policy approach to the development of such sites as expressed in policies 20 & 21. Whilst there would not seem to be a current need for allocation of a strategic facility Local Plan policy does not seek to place a limit or cap on the level of provision in Cornwall.

CEMS Ltd would like to see further clarification on this position in the Plan text.

In response the Council proposed to clarify that proposals for recycling facilities will be considered favourably irrespective of the level of capacity and propose inclusion of the following in Plan text:

Insert after “Plan period” in para 2.87(2.85): “Notwithstanding the existing level of permitted capacity for recycling/re-use and recovery facilities, proposals for additional such facilities will be supported subject to their meeting other policies within the Plan and being in accordance with the ‘Waste Hierarchy”.

Revisions to reflect the changes above will be set out in an addendum to the revised list of proposed further significant changes.

Table 1: Capacity for Commercial and Industrial Waste in Cornwall

Licenced site capacity (per yr) in tonnes

Capacity shown reduced by 20% in brackets to allow for a proportion of Waste Site Name C&I throughput % waste disposal. Estimated Capacity C&I (tonnes) Recycle Kernow Ltd - Kennards House Waste Transfer Station, Launceston 39% 4,999 1,950 Lean Quarry Materials Recovery Facility (MRF), 52% 75,000 39,000 Masters Skips Ltd, 28% 3,999 1,400 St Eval Recycling Company, St Columb 50%* 52,000 (41,600) 20,800 The Waste Transfer Station, (John Jago) 33% 24,999 8,250 Woodlands Transfer Station, 3,160 Summercourt 79% 5,000 (4,000) Parc-an-Chy Transfer Station, Scorrier (Douce) 0% 24,999 0 Chenoweth's Business Park, Ruan High Lane (Maen Karne) 3% 25,000 750 Chypraze Farm, Summercourt (K M Skip Hire) 15% 25000 3,750 Newham Depot (Cory), 100% 5,000 (4,000) 4,000 Dinscott Waste Transfer Site, Kilkhampton, (Bude Skip Hire) 46% 5,000 2,300 Domellick Manor, St Dennis 3% 50,000 (40,000) 1,200 Forth Kegyn Transfer Station, Pool (Ozard) 7% 24,999 1,750 H & A Waste Recycling Ltd (MRF), 100% 29,999 29,999 Herniss Farm Transfer Station, 16% 24,999 (19,999) 3,200 Falmouth Malcolm Drew Tyre Recycling 100% 4,999 4,999 Wilco's Waste Management, 22% 74,999 16500 Specialist Skip Hire, 38% 74999 28500 Hallenbeagle CEMs Ltd Site (permitted / not operational) 100% 35,000

Total Capacity 206,506 *Assumed (based on knowledge of site) proportion of C&I to Inert as a result of no returns received within Waste Interrogator. C&I Capacity Including Non-Operational (permitted) Sites. This excludes 206,506 tonnes Metal Recycling Sites. C&I Capacity excluding Non-Operational (permitted) Sites. This excludes 171,506 tonnes Metal Recycling Sites.

33% of Metal Recycling Capacity Table 4.1 97,345 tonnes C&I Capacity Including Non-Operational (permitted) Sites and 33% of 303,851 tonnes Metal Sites.