Northamptonshire County Council Duty to Co-operate Minerals and Waste Development Framework Partial Review

Bedford Borough Council

Northamptonshire County Council

Bedford Borough Council Please ask for: Planning Policy Tel: 01604 366014 Consulting Bedford Our ref: BBC_I&O Freepost ANG5840 Your ref: PP/2032/1 Bedford Date: 3 February 2014 MK40 1ZD

Dear Sir/Madam

Consultation on the Issues and Options for the Bedford Borough Local Plan 2032

Thank you for consulting the County Council on the above document.

The Council wishes to comment on paragraph 1.34 in relation to the Minerals and Waste Local Plans. Further details should be added to paragraph 1.34 to provide clarity over the status of the different minerals and waste plans and the different saved policies.

If you require any clarification of the above comments please do not hesitate to contact me.

Yours sincerely

Laura Burton Principal Planner

Planning Services Room 271, County Hall Northampton NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. e. [email protected] Buckinghamshire County Council

From: Shari Macdonald Sent: 18 November 2013 04:02 To: '[email protected]' Subject: RE: Buckinghamshire Local Aggregate Assessment for 2013

Lester

Please find below comments from Northamptonshire County Council on the Buckinghamshire Local Aggregate Assessment 2013. The Councils comments have been divided into more general comments and those focussing on specific content / data / references within the LAA.

Overall there is inadequate discussion around and consideration of crushed rock movements, possible future supply requirements and ensuring continued supply.

Should you have any queries please do not hesitate to contact me via email.

Regards Shari MacDonald

General  Consistency in use of terms - apportionment / provision / supply rate. In many places the document refers to an apportionment level where it would be more appropriate to refer to this as either the provision or supply rate - the use of the term 'apportionment' in these cases may be misleading. However in general the use of these terms is inconsistently applied throughout the document and should be clarified / a uniform approach taken.  Reference to Preferred Areas to be (possibly) included in the Minerals Local Plan (MLP) is made throughout the document. This varies from Preferred Areas being likely to be identified to more definite statements that they will be identified. The councils position should be clarified and a more consistent approach taken.  Document neglects to address site allocations - will the MLP include site allocations?  Was consideration given to adjoining regions AWP annual monitoring reports in identifying imports / exports - there is no mention of this in the document?  It would be useful to include a map of the permitted sites.

Content / data / references  Para 1.2 'this may contain Preferred Areas for future minerals extraction with the aim of ensuring adequate supply of minerals throughout the plan period' - perhaps the use of the word 'delivering' would be more appropriate rather than 'ensuring' as the adopted MWCS and its policies should fulfil this function whereas the site allocations (if any) and preferred areas would act as a delivery mechanism.  Para 1.3 the NPPF is the trigger for the LAA, not the adoption of the MWCS - reword for clarification.  Para 1.3 'as part of its duty to keep the demand and supply of aggregates under regular review' - misleading / confusing use of terms as it would be very difficult for the council to keep the demand for aggregates under review as it has little control over such matters which are driven by market forces. wording should be reviewed to clarify that this is referring to monitoring of demand.  Para 1.6 incorrect definition of land banks. This statement is misleading.  Para 1.10 second sentence reference to providing a landbank for crushed rock should be clarified to state that there is no need to identify provision / supply rate, or maintain a land bank, for this mineral.  Para 2.5 third sentence - incorrect data has been used. AMS 2009 sales recorded for SE are 1.3mt or 2.2% not 1.9mt (AMS 2009 para 3.4). Also this sentence should clarify that it is referring to crushed rock sales.  Para 2.5 last sentence - misleading and incorrect statement 'Buckinghamshire does not have any natural hard rock resources'. Refer to BGS mineral resource reports / maps and draft LAA figure 2 which clearly indicate presence of limestone within the county. This point should be clarified.  Figure 2 is labelled as mineral resources in Buckinghamshire but then underneath is labelled as mineral proposals map.  Table 1 - it would be useful to include information such as permission reference, end date and permitted reserve (and possibly remaining reserve where available).  Table 3 - title or table headings should clarify that the figures are tonnes.  Para 3.15 second sentence - destination of remaining 15% or 0.11mt is not known. Should clarify that this does not include unallocated sales of unknown destination or update figures to include this portion.  Para 3.16 this para starts by discussing sand and gravel, then switches to an overall picture, then back to only sand and gravel. Stating the overall balance shows that the sub-region is a net exporter of sand and gravel is mixing different subject matters and may confuse readers. If you start a sentence with an overall picture the analysis at the end of the sentence should refer to the overall picture for consistency and then subsequent sentences within the para should identify separate import / export balances for the different minerals. As it stands this section 'imports and exports' does not adequately address the fact that Buckinghamshire are major net importers of crushed rock. This is somewhat swept under the rug throughout the entire document and is not addressed in sufficient detail or given due consideration particularly in relation to sources of crushed rock, possible future supply requirements and ensuring continued supply.  Para 3.16 last sentence - 26% (0.24mt) what is the reference for this figure?  Para 3.20 reference is made to existing capacity. Does this mean permitted or operational capacity - this should be clarified in this para and throughout document where appropriate.  Para 3.20 last sentence - reference to tonnes - is this per annum? This should be clarified.  Para 3.20 last sentence - refer to baseline information gathered in 2007/8.Tthis is not the most up to date information available - this para and data should be reviewed and updated to present a more accurate and up to date picture of existing operational / permitted capacity.  Table 5 - would be useful to combine with Table 1 (as per previous comments on Table 1). Also Table 1 lists Spade Oak, Little Marlow yet no mention is made of this site in Table 5 or surrounding text.  Section 4 'Aggregate supply, demand and local considerations' - insufficient exploration and consideration of local considerations is presented with only the economic downturn discussed. What about other factors such as growth projections, major development and infrastructure plans / projects, recovery from the recession, resources and constraints etc. It would be useful to discuss some of the matters raised later in paras 5.8 to 5.9 here.  Para 5.2 - calculations should be based on most up to date data. Current landbank should be shown in years or text changed to state 'current permitted reserves'. Reference to total landbank required is confusing and should refer total provision required.  Para 5.4 last sentence - permitted reserves will only last for a longer period if the decline in sales continues / remains at current levels in the future. There is no evidence to support this assumption.  Para 5.5 and 5.6 reference to remaining plan period. Stated in para 5.5 as 13 years, but in para 5.6 stated as 14 years. The correct figure should be stated and calculations adjusted accordingly.  Para 5.4 to 5.7 - only two options are presented, being the adopted MWCS figure (based on ten year average of sales for 2001-2010) or ten year average of sales for 2003-2012 neither of which actually gives consideration of local factors. Also there seems to be confusion around the purpose of the LAA which is to inform the planning process not to formally adopt an annual supply.  Section 5 'Future provision of sand and gravel' - there is no consideration of the three year average.  Para 5.8 to 5.11 - this information does not appear to be actually applied in the LAA i.e. the section is titled 'adjustments for local considerations' but no adjustments have been made to either of the options presented. The title of the section is misleading and the information may be better presented in the earlier section 'Aggregate supply, demand and local considerations' with the section on future provision detailing how due consideration has been given to these factors (or not) and justification for this.  Para 5.11 reference to the 7.63mt and 6.72mt requirement should be linked back to their origins (i.e. the 'options') to ensure clarity.  Para 6.1 to 6.2 - no consideration of future recovery from recession or evidence presented to indicate that this is unlikely to occur.  Para 6.2 end of first sentence 'demand is likely to continue at a lower level than has historically been the norm, at least in the next five years' where is the evidence to support this assumption?

From: Hannington, Lester [mailto:[email protected]] Sent: 23 October 2013 11:44 To: Brianne Stolper ([email protected]); Planning; Mark Chant; Peter.Day@Oxfordshire.gov.uk; [email protected]; [email protected]; [email protected]; [email protected]; Susan Marsh ([email protected]) Subject: Buckinghamshire Local Aggregate Assessment for 2013 Importance: High

Dear Colleagues

I attach a revised version of the Buckinghamshire Local Aggregate Assessment for 2013, which is to be reported to the South East Aggregate Working Party on November 13th. I would be grateful to receive your comments before that date.

Many thanks

Lester Hannington BSc (Hons) PGDURP MRTPI DipEIA Lead Officer for minerals and waste policy Place Services Buckinghamhire County Council Telephone 01296 383037 E-mail [email protected]

Central Bedfordshire Council

From: Laura Jones [mailto:[email protected]]; Sent: 22/02/2011 10:23:46 To: James Delafield [mailto:[email protected]]; Subject: RE: Waste info request

Morning James,

I have found the 10,000 tpa EFW site Covanta referred to. There is no actual waste planning permission for it as a Certificate of Lawfulness was issued for an industrial conversion (from B2 to B8). This is known as Wykes Engineering / ACL (Ancillary Components Ltd), a thermal treatment facility, located at Goosey Lodge Wymington Lane, Rushden.

The figures I provided in a previous email that related to MSW and C&I waste, I think are incorrect in terms or what you are actually after. I misunderstood what you wanted.

The adopted Core Strategy DPD sets out the anticipated waste arisings and management methods required to meet targets (Table CS2d). By the end of the plan period (2025/26) there will be 236,000 tpa MSW and 98,000 tpa C&I waste (total of 334,000 tpa) available within Northamptonshire for treatment via thermal or energy from waste processes.

The Council is not in a position to determine how Covanta have arrived at the figure of 301,000 tpa over a 35 year period. Unless Covanta are able to provide the methodology for arriving at this figure we will not be able to provide comment on its validity.

I hope this answers your questions. If you are able to find out how Covanta have arrived at the 301,000 tpa figure, I am happy to look into it.

I don’t think I have missed anything out? Let me know if I have!

Regards,

Laura

From: James Delafield [mailto:[email protected]] Sent: 16 February 2011 16:06 To: Laura Jones Subject: RE: Waste info request

Hi Laura,

No problem, we are also used to "major IT issues".

Regards,

James Delafield Minerals and Waste Planning Officer Tel: 0300 300 6271 Ext: 76271 [email protected] Central Bedfordshire Council Development Management Minerals and Waste Team - Shared Service for Bedford Borough and Central Bedfordshire Councils

Priory House Monks Walk Chicksands Shefford SG17 5TQ

Tel: 0300 300 8000 Web: www.centralbedfordshire.gov.uk

From: Laura Jones [mailto:[email protected]] Sent: 16 February 2011 12:14 To: James Delafield Subject: RE: Waste info request

Hi James,

I’ve discussed the data with Shari and haven’t managed to come up with any definite answers, however this is more due to a ‘major IT issue’ which happened here yesterday rather than not being able to find them. We’re still waiting for the system to be fully functioning again which according to IT may not be for a couple of days. I am out of the office now until Monday so I will leave Shari to have a look while I am gone (providing we regain access to our archives in this time!), and will get back to you on Monday. Hopefully with some useful information. Sorry I can’t get you anything sooner.

Kind regards

Laura

From: James Delafield [mailto:[email protected]] Sent: 16 February 2011 10:44 To: Laura Jones Cc: Susan Marsh Subject: RE: Waste info request

Hi Laura,

As discussed there seems to be a significant gap between the figure 76,000 tpa of C&I for 2025/26 you provided and the figure that Covanta are working off in their need assessment of 301,000 tpa of residual C&I potentially being available to them for the 35 year lifetime of the plant (page 55 of their need assessment, with details of the assumptions for arriving at that figure set out in Annex A)

Your comments on the figure that Covanta have arrived at would be appreciated.

Many thanks,

James Delafield Minerals and Waste Planning Officer Tel: 0300 300 6271 Ext: 76271 [email protected] Central Bedfordshire Council Development Management Minerals and Waste Team - Shared Service for Bedford Borough and Central Bedfordshire Councils

Priory House Monks Walk Chicksands Shefford SG17 5TQ

Tel: 0300 300 8000 Web: www.centralbedfordshire.gov.uk

From: Laura Jones [mailto:[email protected]] Sent: 11 February 2011 15:50 To: James Delafield Subject: RE: Waste info request

Hello James,

Please see update on Manton Road below (blue text).

In relation to the 10,000 EfW facility – at the moment I can’t actually work out what site Covanta are referring to. It is possibly part of a larger application and for some reason I can’t find reference to it anywhere. I have also spoken to the DC Planners and they’re also unclear as to what this could be. If you’re able to provide me with any further information then I am happy to keep looking. Maybe Covanta have kept a more in depth record of their communications with Shari than that published in the need assessment? As I said before, I will discuss it with Shari on her return on Wednesday if it is not resolved by then.

Anyway let me know if you come up with anything which would help in the mean time.

Kind regards

Laura

From: James Delafield [mailto:[email protected]] Sent: 09 February 2011 14:35 To: Laura Jones Cc: Natalie Chillcott Subject: RE: Waste info request

Hi Laura,

Thank you for the information that you have provided to my colleague Natalie Chillcott.

Part of the reason why we have been requesting this information is to assist in making our response to the Infrastructure Planning Commission who are considering Covanta Energy's proposed EfW plant at Rookery Pit, Bedfordshire.

I have been looking through the need assessment Covanta has produced and have been seeking to clarify a number of the claims made. The information you have provided has been very useful in that respect.

Covanta have suggested in the need assessment that there are two operational residual waste treatment facilities in Northamptonshire. These include a 10,000 tpa EfW facility (???), which takes MW and a 45,000 tpa AD plant (Westwood), which takes MW and C&I. No further site details are specified. The capacity details of the residual waste facilities that you have provided to Natalie do not appear to accord with these details. Please could you clarify. Covanta have stated that the source of their information was a personal communication with Shari Macdonald.

There are a number of further questions that have emerged on my review of the data you have provided, and we would appreciate if you could provide some clarification on the following:-

1. What waste streams will be accepted at Chelveston? Waste streams at Chelveston will include 2 independent feedstocks. One will include wastage products from slaughter houses, food processing factories, retail outlets and domestic & commercial kitchens. The other being derived from organic waste with energy crops, such as ryegrass, maize and fodder beet. 2. I've found decision notices on your website for Manton Road AD plant and Black Pits Farm AD plant. Your table stated that these were not yet operational but the conditions attached would suggest that the permissions have expired as the commencement deadline was June 2010 for both. Is this the case? Also your note on the Manton Road site suggests 180,000 tpa of trade effluent is processed yet this does not appear to be covered by the 2007 permission. Is there a separate permission for this? Blackpits Farm AD – This permission has been implemented, however AD processing is not yet taking place. Manton Road – Construction of AD Plant started approx 18 months ago and was completed approx 1 year ago. Currently AD does take place, however the required amount of methane is not yet being produced in order to work the turbines and generate power. They are working on this. In relation to the 180,000tpa of trade effluent, this is a ‘co-product’ already located on the site. The company processes fruit and the AD plant uses the waste products from this – this would therefore not require a planning permission in terms of transported inputs. i.e. the effluent is included in the approval of application CO/07/88/C, there is no separate permission. 3. I've found two further decision notices for AD plants on your website. These are Westwood, Higham Park and Rothwell Lodge Farm. Please can you clarify the status of these sites, are they operational? and the waste streams they (will) accept? Both of these sites are now operational In relation to the waste streams accepted; – I am almost certain that Westwood accepts only (C&I) waste. However this must be the 45,000 tpa AD plant you referred to earlier accepting C&I and MSW. As I said if you could forward me the information you have this may help me clarify this. – Rothwell – Accepts farm manure and food waste (C&I) 4. Are there any further applications for residual waste treatment that are awaiting a decision? The only waste applications we have which are currently undecided are 2 variation of conditions applications and a non-material amendment. Neither of which relate to residual waste. 5. Lastly, please could you clarify your forecasted residual waste arisings for MSW and C&I for the end or your plan period? Plan period is up to 2026 Residual MSW (2025/2026) 56,000 tpa, Residual C&I (2025/2026) 75,000 tpa

Thanks again for you help in this matter. Please do get in touch if you require any further clarification on the nature of our request.

Kind regards,

James Delafield Minerals and Waste Planning Officer Tel: 0300 300 6271 Ext: 76271 [email protected] Central Bedfordshire Council Development Management Minerals and Waste Team - Shared Service for Bedford Borough and Central Bedfordshire Councils

Priory House Monks Walk Chicksands Shefford SG17 5TQ

Tel: 0300 300 8000 Web: www.centralbedfordshire.gov.uk

From: Laura Jones [mailto:[email protected]] Sent: 02 February 2011 15:09 To: Natalie Chillcott Subject: Waste info request

Hello Natalie,

We currently have no idea as to when the facilities may become operational, or even if they will under the granted permissions. The applicants as yet have not come up with a suitable technology for the processes in relation to the individual sites. The approvals are only valid for 3 years (some are nearing this limit) and there is the possibility that they may not become operational during this period. There are exercises taking place which suggests that the applicants are still making enquiries into developing this technology on the permitted sites, however we have received no indication as to when this could potentially happen.

Hope this helps, Let me know if I can help with anything else.

Kind regards,

Laura Jones Planning Policy

From: Natalie Chillcott [mailto:[email protected]] Sent: 01 February 2011 16:03 To: Laura Jones Subject: RE: Waste info request

Thanks Laura, that's really useful.

I just have one more question- do you have any idea when the four facilities listed are expected to become operational?

Many thanks

Regards,

Natalie

From: Laura Jones [mailto:[email protected]] Sent: 01 February 2011 15:16 To: Natalie Chillcott Subject: FW: Waste info request

Hi Natalie,

I can confirm that NCC have permitted four waste treatment facilities which can be regarded as either Mechanical Biological Treatment or Advanced Thermal Treatment (Gasification or Pyrolysis). Their details are as follows:

• Think Environmental (renewable energy) – Pyrolysis. Permitted capacity 50,000 tpa. Waste bio-drying but no pyrolysis operations at the moment. • Chelveston Renewable Energy Ltd (renewable energy) – Permitted capacity 48,000 tpa. Not operational. • Larner Pallets, Wellingborough (gasification plant) – Gasification. Permitted capacity 26,000. Not operational. • Shore Energy (MBT treatment) – Permitted capacity 120,000 tpa. Not operational.

Hope this helps. Let me know if you require anything else.

Laura Jones Planning Policy

From: Natalie Chillcott [mailto:[email protected]] Sent: 01 February 2011 10:22 To: Mark Chant Subject: Waste info request

Hi Mark,

Thank you for your assistance this morning. I had another look at the spreadsheets Mark Laurneson kindly provided me last year and have looked at the 2009/10 AMR. I would however be grateful if you could confirm that there are currently four permitted waste treatment facilities which can be regarded as either Mechanical Biological Treatment or Advanced Thermal Treatment (Gasification or Pyrolysis)? :

 Think Environmental (Renewable Energy)- Pyrolysis (50,000 tpa)  Chelveston Renewable Energy Ltd (100,000 tpa) is it operational yet?  Larner Pallets- Wellingborough (Gasification plant)- what is it's permitted and operational capacity?  Shore Energy (Treatment) 120,000tpa- is it operational yet?

(I do not wish to include Anaerobic Digestion, composting, recycling or landfill gas facilities).

If this is the case could you tell me what is their status (are they all operational now) as well as the permitted and operational capacity of the Gasification plant.

Many thanks for your assistance in this matter.

Regards,

Natalie

Natalie Chillcott Minerals and Waste Planning Officer (Policy)

Northamptonshire County Council

Lester Hannington Please ask for: Mark Chant Tel: 01604 236831 Central Bedfordshire Council Our ref: Priory House Your ref: Monks Walk Date: 23 January 2012 Chicksands Shefford Bedfordshire SG17 5TQ

Dear Mr Hannington

Bedford Borough, Central Bedfordshire and Luton Borough Minerals and Waste Core Strategy: Plan for Submission

I refer to your letter of 16 January 2012 regarding the above.

In relation to both Sidegate Lane and King’s Cliffe disposal sites, both are on temporary permissions and neither have any catchment restrictions. Volume is restricted to 250,000 tpa at King’s Cliffe; there is no volume restriction at Sidegate Lane. The temporary permission at King’s Cliffe is to 2013; at Sidegate Lane it is 2017.

In relation to your Plan for Submission the County Council will be making the following representations under separate cover: - There is no policy setting out the criteria on which the planning authorities in Bedfordshire would determine any proposal coming forward for a specific hazardous waste disposal landfill site. A policy stance of not permitting this type of development within the plan area is not sound, particularly with reference to their being no such specific standalone facility within the East of England region and the one in the adjacent East Midlands region at King’s Cliffe only having a temporary permission to 2013. - In similar vein there is no policy setting out the criteria on which the planning authorities in Bedfordshire would determine any proposal for radioactive waste disposal and/or management.

If you require any clarification of the above please come back to me.

Planning Services PO Box 163 County Hall Northampton NN1 1AX w. www.northamptonshire.gov.uk t. 01604 236014 f. 01604 236065 e. [email protected] Yours sincerely

Mark Chant Head of Planning Services

Northamptonshire County Council

Minerals and Waste Planning Team Please ask for: Planning Policy Tel: 01604 367851 Central Bedfordshire Council Our ref: Priory House Your ref: Monks Walk Date: 25 January 2012 Chicksands Shefford Bedfordshire SG17 5TQ

Dear Sir/Madam

Bedford Borough, Central Bedfordshire and Luton Borough Minerals and Waste Core Strategy: Plan for Submission

Thank you for consulting the county council on the above. As a waste planning authority we have comments in relation to hazardous waste provision.

Northamptonshire County Council is concerned that there is no policy setting out the criteria on which the planning authorities in Bedfordshire would determine any proposal coming forward for a specific hazardous waste disposal landfill site. A policy stance of not permitting this type of development within the plan area is not sound, particularly with reference to their being no such specific standalone facility within the East of England region and the one in the adjacent East Midlands region at King’s Cliffe only having a temporary permission to 2013. In similar vein there is no policy setting out the criteria on which the planning authorities in Bedfordshire would determine any proposal for radioactive waste disposal and/or management.

If you require any clarification of the above comments please do not hesitate to contact me.

Yours sincerely

Laura Burton Principal Planner

Planning Services PO Box 163 County Hall Northampton NN1 1AX w. www.northamptonshire.gov.uk t. 01604 236014 f. 01604 236065 e. [email protected]

Northamptonshire County Council

Mr L Hannington Please ask for: Planning Services Tel: 01604 236014 Minerals and Waste Planning Our ref: Central Bedfordshire Council Your ref: MWCS/910 Priory House, Monks Walk Date: 7 February 2012 Chicksands, Shefford Bedfordshire SG17 5TQ

Dear Mr Hannington

Bedford Borough, Central Bedfordshire, and Luton Minerals and Waste Core Strategy

I refer to your letter of 2nd February 2012 regarding the above.

In relation to the site at Pury End for limestone quarrying, I can confirm that we have not allocated an extension to the existing site. Another site located in close proximity to the existing quarry came forward through the call for sites and is now included in the councils Locations for Minerals Development DPD. The DPD reference for this new limestone quarry is MA10.

To ensure future supply of the limestone, the new quarry that is included in the Locations for Minerals DPD will not be allowed to commence working until the existing site is near completion of its operational life. This new site has an expected quantity of 1.5 million tonnes of limestone.

The MWDF Core Strategy does have safeguarding areas for Limestone but these are located in the north of the county. The BGS mapping data did not show any large limestone deposits in the south of the county so it was felt that is could not be included in the MSA.

If you require any clarification of the above please come back to me.

Yours Sincerely

Laura Burton Principal Planner

Planning Policy Guildhall Road Block County Hall Northampton, NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. 01604 236065 e. [email protected] From: Laura Burton Sent: 23 February 2012 14:44 To: '[email protected]' Subject:FW: Minerals and Waste Core Strategy representation Attachments: Let Beds Plan Jan12.doc Importance: High

Good Afternoon

Please find attached an electronic copy of the Northamptonshire County Council response, I have also put a hard copy of the response in the post today.

Regards

Laura Burton

From: Mark Chant Sent: 23 February 2012 14:34 To: Laura Burton Subject: FW: Minerals and Waste Core Strategy representation Importance: High

From: Lester Hannington [mailto:[email protected]] Sent: 23 February 2012 13:52 To: Mark Chant Cc: Natalie Chillcott; Andrew Marsh; Susan Marsh Subject: Minerals and Waste Core Strategy representation Importance: High

Hello Mark

I am aware that Northamptonshire made a representation our recent consultation on issues of soundness. However we appear not to be able to track it down. Is there any scope for a copy being sent to us at the address below?

Many thanks

Lester Hannington

Principal Minerals and Waste Planning Officer

Minerals and Waste Planning Shared Service

Central Bedfordshire Council Priory House, Monks Walk, Chicksands, Shefford, Bedfordshire, SG17 5TQ

Direct dial: 0300 300 6219

Email: [email protected]

Central Bedfordshire Council

Priory House, Monks Walk, Chicksands,

Shefford, Bedfordshire SG17 5TQ [email protected] www.centralbedfordshire.gov.uk

Northamptonshire County Council

Minerals and Waste Planning Team Please ask for: Planning Policy Tel: 01604 367851 Central Bedfordshire Council Our ref: Beds _Sus_Mods Priory House Your ref: Monks Walk Date: 05 July 2012 Chicksands Shefford Bedfordshire SG17 5TQ

Dear Sir/Madam

Bedford Borough, Central Bedfordshire and Luton Borough Minerals and Waste Core Strategy: Plan for Submission with Main and Additional Modifications

Thank you for consulting the County Council on the above.

Northamptonshire County Council still has the same concerns in relation to hazardous and radioactive waste as outlined in our letter dated 25 January 2012 which was sent as our response to the Plan for Submission.

If you require any clarification of the above comments please do not hesitate to contact me.

Yours sincerely

Laura Burton Principal Planner

Planning Services PO Box 163 County Hall Northampton NN1 1AX w. www.northamptonshire.gov.uk t. 01604 236014 f. 01604 236065 e. [email protected] Cheshire County Council

Northamptonshire County Council

Spatial Planning Please ask for: Planning Services Tel: 01604 366014 Cheshire West and Chester Council Our ref: Chest/Pref/Dire The Forum Office Your ref: Chester Date: 5 September 2012 CH1 2HS

Dear Sir/Madam

Cheshire West and Chester Council Local Plan Preferred Policy Direction

Thank you for consulting Northamptonshire County Council on the above.

The County Council wishes to comment in relation to PD22 Managing Waste. A specific policy containing criteria on which proposals for both hazardous and radioactive waste treatment/disposal would be determined should be included within the Local Plan.

If you require any clarification of the above comments please do not hesitate to contact me.

Yours Sincerely

Laura Burton Principal Planner

Planning Policy Guildhall Road Block County Hall Northampton, NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. 01604 366065 e. [email protected] Cornwall County

Council From: Mark Chant Sent: 08 August 2013 10:06 To: '[email protected]' Cc: Laura Burton Subject:RE: Waste Planning: Hazardous Waste Capacity in Northamptonshire

Emily I refer to your letter sent by email on 7 August 2013.

Of the two facilities: - The ESS facility has a permanent permission. - The East Northamptonshire Resource Management Facility has an end date of 2026 and if complete by then, then an extension in area would have a number of key hurdles to cross.

regards Mark

Mark Chant I Head of Planning Services I 01604 366831 I Planning Services, Northamptonshire County

Council, County Hall, Guildhall Road, Northampton NN1 1DN

From: Rubin Emily [mailto:[email protected]] Sent: 07 August 2013 11:33 To: Planning Subject: Waste Planning: Hazardous Waste Capacity in Northamptonshire

Dear Sir/Madam

Please find attached a letter of enquiry into the anticipated capacity of hazardous waste treatment facilities in Northamptonshire. We would be most grateful if you or a colleague can provide any assistance by 23 August 2013. If you have any queries please do not hesitate to contact me.

Many thanks,

Emily Rubin Senior Planning Policy Officer Local Planning Team Planning, Housing and Regeneration Service Cornwall Council Derbyshire County Council

Hi Carol,

In relation to strategic movements of waste from Derbyshire to Northamptonshire:

Q1: The results from the EA Waste Data Interrogator for the strategic sites are attached. You will see that the figure is the same as yours for the Recycle Force (2,637 tonnes) but slightly higher for ENRMF (6,653 tonnes received in 2011 at the Kings Cliffe site with permit YP3138XB) and (1,353 tonnes received in 2011 at the Kings Cliffe site with permit TP3430GW). The Hazardous Waste Interrogator for ENRMF site doesn’t break the data down to such a level as the Waste Data Interrogator, so like yourselves, we used the latter dataset.

Q2: The sites still have a current EA permit and ENRMF is currently operational. We believe Recycle Force are also operational but our Enforcement Officer is going to drive by later on in the week just to double check.

Q3: We are not aware of any planning reasons why the waste movements cannot continue to occur in the future to these sites. There is no permission end date for Recycle Force. ENRMF has permission to treat up to 0.15 Mtpa of soil and dispose of up to 0.25 Mt per annum (Mtpa) of waste under the extant permission (which expires in 2016), after which this will decrease to 0.15 Mtpa (under the ENRMF Order 2013 which came into force 31 July 2013 and expires 31 December 2026). Under the ENRMF Order 2013 the combined total amount of waste that can be imported to the site per annum cannot exceed 0.25 Mtpa. The total amount of Low Activity Low Level Waste that can be disposed of at the site (up to 31 December 2026) is 0.448 Mt or an average of 0.045 Mtpa.

Q4 /Q5: Northamptonshire County Council support self-sufficiency and waste movements should be kept to a minimum where possible however we recognise that some cross boundary movements will occur.

Kind Regards

Laura Davidson

Minerals and Waste Planning Officer

Northamptonshire County Council

Tel: (01604) 367214

E-mail: [email protected]

From: Barnett,Carol (Environmental Services) [mailto:[email protected]]

Sent: 03 September 2013 14:47

To: Laura Davidson

Subject: Derby and Derbyshire Waste Local Plan Duty to Cooperate Strategic Waste Movements

Dear Laura I’m not sure that you are the correct person to email regarding this matter; Bryn Walters has given me your name as an East Midlands RTAB member.

I have previously emailed Sharie Macdonald but I’m not sure that I had her correct email address.

In line with the Duty to Cooperate in preparing development plans we have identified authorities that receive strategic movements of waste from Derbyshire. Please read the attached letter and excel table which explain my request for information from your authority regarding this matter.

Carol Barnett | Senior Planner

Development Plans

Environmental Services | Derbyshire County Council

Shand House, Dale Road South, Matlock, Derbyshire, DE4 3RY

01629 539815

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______From: Mark Chant Sent: 07 May 2013 09:53 To: '[email protected]' Cc: Laura Burton Subject: Derby & Derbyshire Waste Plan - Statistical Basis Published

Good Morning Please see below comments on the Statistical Basis paper from my colleague Shari Macdonald:

 The following additional data sources should also be considered: o EA Infrastructure report and dataset 2010 o WRAP ‘CD&E arisings, use and disposal’ 2008 and ‘CD&E waste generation estimate: England’ 2010  DCLG 2012 Guidance for local planning authorities on implementing planning requirements of the European Union Waste Framework Directive (2008/98/EC): The Article 28 requirement does not appear to have been fully addressed – i.e. indication of the number of facilities required and changes in capacity over the plan period in response to closures or alternately expiry of permissions (where closure information is not required this could be a substitute). If these have been taken into account perhaps additional text / further explanation is needed for clarification. Is the available capacity the capacity in S4 capacity as at 2010/11 or does it take account of closures / expiry of permissions?  DtC / waste movements – Northamptonshire received 12300 t from Derby / Derbyshire in 2011 (4500 t haz) (source: EA waste interrogator dataset). However, little information is provided on cross-border waste movements.  C&I forecasts assume 1% growth p/a in line with EM Regional Plan 2009 zero growth – however, the Regional Plan has been revoked. Policy 38 of the East Midlands Regional Plan 2009 sought to achieve ‘zero growth’ in controlled waste arisings by 2016 – as it is now mid 2013 the council could assess / provide further detail on the feasibility of achieving this target by 2016.  Haz Waste– NCC does not support using the RWS figures for hazardous waste – it is not the best available data and circumstances have changed since the RWS was prepared. The paper acknowledges that Haz Waste is linked to economic profiling – perhaps using the EA dataset combined with economic growth rates would provide a better picture of the local waste arisings over the plan period.  There does not appear to be consideration of residual waste resulting from waste management processes that requires further treatment / disposal  Scenarios including zero waste for disposal / landfill do not seem realistic as it is highly likely that there will continue to be a need for disposal / landfill even if it is just for residues arising from other treatments processes. The continuing need for disposal is recognised through national policy - landfill being the last option but one that must be provided for.  LLW / LALLW not addressed / given consideration.  Need to clearly explain how the Welsh targets apply to UK / Derbyshire rather than simply being more recent than other UK reports and targets (a couple of paragraphs just to present how the context is similar / relates to the local situation and why it is appropriate / fit-for- purpose).

If you require any clarification of the above please come back to me. regards Mark.

Dorset County Council

From: Planning Sent: 03 January 2014 09:54 To: '[email protected]' Subject:FW: Bournemouth, Dorset and Poole Minerals and Waste Planning Consultations

Dear Sir/ Madam

Please find below comments from Northamptonshire County Council in relation to the Waste Plan

Issues Paper.

Waste Plan

* Q3 – 3. Where available local economic projections could be applied to the C&I sectors, or split the C&I waste and apply profiles for commercial growth and ind growth

* Q6 – 1.

* Q7 – No, could be linked to growth projections for C&I.

* KI1 – plan to provide for net self sufficiency and id capacity gap between current and end of plan period based on broad waste management methods / waste hierarchy.

* KI2 – Identify a spatial strategy to provide guidance regarding establishing a network of facilities.

* KI3-6 – Identify the capacity gap and supporting policies that allow such facilities to come forward where appropriate.

* LLW – agree with approach set out in para 9.20

Please confirm receipt of this email.

Kind Regards

Laura Burton

Planning Policy

From: MWDF [mailto:[email protected]] Sent: 18 December 2013 15:09 Subject: Bournemouth, Dorset and Poole Minerals and Waste Planning Consultations

Bournemouth, Dorset and Poole Mineral Sites Plan Bournemouth, Dorset and Poole Waste Plan Issues Paper Town and County Planning (Local Planning) (England) Regulations 2012

Dear Stakeholder

I am writing to let you know that we have now published two emerging planning documents for consultation for an eight week period ending at 4pm on 13 February 2014.

* the Minerals Sites Plan, for which a total of 44 sites nominated to the Mineral Planning

Authority have been assessed against a range of criteria; and

* the Waste Plan, for which an Issues Paper has been prepared. This sets out the anticipated needs for waste management facilities up to 2030 and invites views on a range of issues.

To aid this period of consultation we will be using an interactive version of the consultation document. By following the links below to the consultation portal pages you should be able to login and/or register your details and comment on the document. Once registered, you will be able to log on to the system at any time to track the progress of the comments that you have made. We would strongly encourage you to use this method of commenting.

www.dorsetforyou.com/mineral-sites

www.dorsetforyou.com/waste-plan

The documents can also be viewed at the offices of Dorset County Council, the Borough of

Poole and Bournemouth Borough Council and offices of the district/borough councils.

In addition, a series of planning exhibitions are being arranged throughout Dorset where copies of the documents will be available. Officers will also attend to answer questions about the documents. Details can be found on the attached leaflet.

You have received this email because you have in the past registered an interest in minerals and waste planning policy or perhaps objected to a specific site. Please let us know if you would prefer not to receive information on the two emerging documents referred to above.

If you have any queries or require further information, please do not hesitate to contact the Policy

Team on 01305 228585 or 224675 or email [email protected]

Best Regards

Emma Macdonald

Senior Planning Officer

(Minerals & Waste Planning Policy)

Tel: 01305 228585 (Group B)

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Council From: Shari Macdonald Sent: 30 December 2013 00:26 To: Mark Chant; Laura Burton Subject:RE: LLRW Movements from the North East

Leo, As requested please see below: 1. Do you have any additional waste movement data or information for this stream? The ENRMF site has permission to treat up to 0.1 Mtpa of soil and dispose of up to 0.25 Mtpa of waste under the extant permission (which expires in 2016). The ENRMF was recently granted an extension under the ENRMF Order 2013 which came into force 31 July 2013 and expires 31 December 2026. Under the ENRMF Order 2013, the site has permission to treat up to 0.15 Mtpa of contaminated materials comprising predominantly hazardous wastes and dispose of hazardous waste and LALLW at a direct input rate of up to 0.15 Mtpa. The combined total amount of waste that can be imported to the site per annum cannot exceed 0.25 Mtpa. The total amount of LALLW that can be disposed of at the site (up to 31 December 2026) is 0.448 Mt or an average of 0.045 Mtpa. 2. Please can you confirm the site(s) in your waste planning area at which this LLRW is managed? East Northants Resource Management Facility (ENRMF) Do you know of plans/permissions to extend existing facilities? Planning permission for the ENRMF expires 31 December 2026. 3. Are you aware of any planning reasons why waste movements similar to those stated for 2010 and 2011 cannot continue in the future? Please provide facility end dates where these are known. See Q 2. 4. Do these sites have the capacity to continue to accept waste movements from North East England similar to those stated for 2011 over our plan period, to 2030? See response to Q1. Ability of the facility to accept waste movements from NEE is largely dependant on commercial contractual arrangements. 5. Please identify if you have, or are likely to, safeguard specific sites for the management of this waste stream? Refer Policy CS11 of the adopted MWDF (Policy 33 of the MWLP submission plan). 6. Do you have any general comments or further additional information on the movement of LLRW waste from North East England to your waste planning area? WPAs should plan positively, through their Local Plans, for the provision of facilities for the disposal of LLW and VLLW as appropriate sites, including existing landfill in line with government policy and regulations.

From: Leo Oliver [mailto:[email protected]] Sent: 18 December 2013 11:59 To: Planning Subject: LLRW Movements from the North East

Dear Sir/Madam

Please find attached a letter and report regarding Low Level Radioactive Waste movements from the North East of England to your authority area. Kind regards

Leo

Leo E Oliver Policy Officer Spatial Planning Team Regeneration & Economic Development Durham County Council

03000 263402 Greater London

Authority

From: Mark Chant Sent: 17 December 2012 09:10 To: '[email protected]' Cc: Shari Macdonald Subject: RE: Waste Details

Alien I am fine for you to ask us questions about hazardous waste in the future. The hazardous waste disposal site at King’s Cliffe has permission until 2016 but we expect the National Infrastructure Directorate to permit the current application that is with it for an extension to 2026.

I note from the Interrogator data provided by Shari that most of the waste that came from London in 2011 went to Sidegate Lane. This is the disposal facility that will close in 2017.

regards Mark.

From: Shari Macdonald Sent: 15 December 2012 10:56 To: Mark Chant; '[email protected]' Subject: RE: Waste Details

Alien

‘The EA Waste Interrogator 2011 data indicates a total of 9,320 tonnes of non-inert waste received in Northamptonshire from London for disposal to non-inert landfill.’ Please refer to records pulled from the 2011 EA WI below.

Facility Facility Recorded Origin Tonnes RPA Site Name Operator Type Origin Origin WPA Region Received WELDON WRG Non Haz East LANDFILL Waste (SNRHW) Midlands SITE Services Ltd LF Brent Brent London 796.36 Non East Sidegate SITA UK Hazardous Midlands Lane Landfill Limited LF Newham Newham London 888.58 Non WPA not East Sidegate SITA UK Hazardous codeable Midlands Lane Landfill Limited LF London (London) London 7635.54

Total non-haz landfill London to Northamptonshire 9320.48 tonnes

Sub-total Non haz LF 8524.12

Non haz (SNRHW) LF 796.36

Kind regards, Shari

From: Mark Chant Sent: 14 December 2012 08:59 To: Shari Macdonald Subject: RE: Waste Details

Shari Could you answer the question in the second paragraph? regards Mark.

From: Aliendheasja Fawilia [mailto:[email protected]] Sent: 13 December 2012 16:53 To: Mark Chant Subject: RE: Waste Details

Hello Mark,

Thank you for your reply last week. Sorry for the late reply. This job was handed over to me after Neil left his job last week. I will take over some of his job from now on. My name is Alien and I am currently working with the Waste Team at the GLA.

Your answers are quiet useful. I really appreciate them. I just have one question regarding your answer for waste that Northamptonshire receive frol London. I checked with the waste data interrogator 2011 and I could only see that London sends 7635.54 tonnes to Sidegate Landfill. I couldn't see the 9,320 tonnes figures that you mentioned in your email. Could you confirm which figure that is correct?

I also appreciate your comment on hazardous waste. I am actually working on a hazardous waste strategy right now. We are looking for ways to manage London's hazardous waste within London. As I understand, East Northandts Resource Management Facility receive London hazardous waste but its planning permission will end in 2016. Do you mind if I ask you some questions about hazardous waste in the future (if anything comes up)? Thanks very much.

If you have any questions for me, please do not hesitate to contact me.

Kind regards, Alien

Aliendheasja Fawilia

GREATER LONDON AUTHORITY City Hall The Queen's Walk London SE1 2AA Tel: 020 7983 5897

www.recycleforlondon.com

Like Recycle for London on Facebook and follow us on Twitter @Recycle_London

From: Mark Chant [mailto:[email protected]] Sent: 06 December 2012 12:15 To: Neil Dolan; Aliendheasja Fawilia; Doug Simpson Cc: Shari Macdonald; Wade Siddiqui; Julie Sheen Subject: Waste Details

Neil and colleagues,

Please see below a response to your questions:

1.

2. What is the current total landfill capacity per year within the county?

Data from the EA Waste Interrogator 2011 indicates an operational capacity for non-inert landfill of 496,713 tonnes across five sites: Weldon (end date 28/02/2026), Sidegate Lane (end date 21/07/2017), Cranford (end date 31/10/2017), Rushton (end date 30/09/2017) and Corby (currently inactive) (end date 30/04/2013). We have reports from some of the landfill operators (supporting info from planning applications) showing that they expect to receive significantly more than that reported through the EA – e.g. Cranford expects to receive up to 86,000 tonnes in 2012 reducing to 56,000 tonnes 2013-2014 as part of existing contracts).

What is the anticipated landfill permit expiration date of current sites?

There are at the current time five permitted sites in the county, although one (Corby) has been mothballed for a few years and no-one least of all the operators expects it to re-open . Of the other four, two (Sidegate Lane at Wellingborough and Cranford near Kettering) will stop being operational by 2017. The remaining two (Rushton and Weldon) both of which are in the Corby area have a far longer shelf life. Rushton is now permitted to 2030 but has a catchment restriction on it that means 95% of waste must come from within a 30 miles radius. Weldon is permitted to 2026 and does not have a catchment area restriction on it.

Do you accept waste for landfill from London? If so, what is the annual intake of waste from London?

The EA Waste Interrogator 2011 data indicates a total of 9,320 tonnes of non-inert waste received in Northamptonshire from London for disposal to non-inert landfill. This information is available from the EA Waste Interrogator in more detail. However information from the RTABs in the East of England and South East presented to the North London Waste Plan examination states that in 2010 100k of waste from North London came into the county; it is assumed that most, if not all, of this came to Weldon as it is known that they have a contract to accept London waste.

Are there any restrictions on continuing to receive this waste?

See the comment above in relation to catchment restrictions at Rushton. The sites at Sidegate Lane and Cranford are expected to cease by 2017 and Corby to not re-open. This leaves Weldon as the only long term site that could continue to take London waste. However if there was for any reason a new planning application submitted here, we would do our best to get a more restrictive catchment imposed (we have policies in our adopted MWDF relating to catchment areas and any planning permission granted in the county now has to include a catchment area plan- our adopted policy is not to accept municipal waste from beyond a sub-regional catchment area and this effectively precludes it coming from further afield than an adjacent county.

If you feel there is any additional information that would be relevant please feel free to advise.

Hazardous waste isn’t covered above, but the County Council is concerned that there is an over-reliance across the whole of the wider south-east on a hazardous landfill site within Northamptonshire. This site currently has an end date to 2016 but an application to extend to 2026 is currently with the National Infrastructure Directorate (and with the applicants stating they will sign an agreement not to go beyond this end date). To seek to get other sites/facilities coming forward in the wider south east we object as a matter of course to emerging waste plans that we consider do not tackle this issue. The lack of progress in the development of a Hazardous Waste Strategy for London is a concern to this council and until such progress is made you will be aware that the Mayor/GLA is not complying with Policy 5.19 of the London Plan.

regards Mark.

Mark Chant I Head of Planning Services I 01604 366831 I Planning Services, Northamptonshire County Council, County Hall, Guildhall Road, Northampton NN1 1DN

From: Neil Dolan [mailto:[email protected]] Sent: 05 December 2012 12:59 To: Wastemanagement Subject: Re: Waste Details

Hi Julie, Further to my recent email (see below), could you please send any response to both -

[email protected] [email protected]

Regards Neil Dolan

Hi Julie.

Further to our conversation yesterday I would be grateful if you could assist me in this process and provide me with some further information if at all possible by directing this email to the right person. As I informed you during our phone conversation, the Greater London Authority sends the majority of its waste to be managed by the Counties, most of which ends up as landfill. The Mayor wants London to manage more of its waste within London and reduce its waste management reliance on the regions outside of London. While we have been utilising the EA’s waste interrogator to track where some of this waste goes, we have realised that there are limitations to this tool, hence why we are contacting you and all the other counties directly. If you can shed any light on the following questions it would be great.

3. What is the current total landfill capacity per year within the county?

What is the anticipated landfill permit expiration date of current sites?

Do you accept waste for landfill from London? If so, what is the annual intake of waste from London?

Are there any restrictions on continuing to receive this waste?

If you feel there is any additional information that would be relevant please feel free to advise.

Kind Regards Neil

Neil Dolan Post-Graduate Intern London Plan GREATERLONDONAUTHORITY

[email protected] Tel: 020 7983 5558 Mobile: 078 42852451

Hampshire County

Council From: Mark Chant Sent: 26 November 2012 09:19 To: 'Prowting, Paul' Cc: Laura Burton; Shari Macdonald Subject:RE: Managing Hampshire's hazardous waste

Paul In relation to the two sites: * Wincanton, Daventry Recycling, Unit 10, Heartlands 10, Fawsley Drive, Daventry, Northamptonshire NN11 5UG This operates under a B2 permission issued by Daventry DC. It has been subject to complaints and discussions are ongoing with ourselves and the EA about submitting an application for a permanent waste permission. * WEEE Environmental GB Ltd, Shed 1 Mill Rd Works, Mill Rd, Wellingborough, Northants NN8 1QW This has a permanent permission. regards

Mark.

From: Prowting, Paul [mailto:[email protected]] Sent: 22 November 2012 17:06 To: Planning Cc: Mark Chant Subject: Managing Hampshire's hazardous waste

Dear Sir/Madam, The Hampshire Authorities – Hampshire County Council, Portsmouth and Southampton City Council’s and the New Forest and South Downs National Parks are producing a Plan to deal with waste arising in the Hampshire Plan area up to 2030 - the Hampshire Minerals and Waste Plan. Information gathered from the Environment Agency indicates that hazardous waste was exported to your area from Hampshire in 2010. Due to market forces, it is likely that hazardous waste will continue to be exported to existing waste management facilities in your area and it is important that we establish whether there are any obstacles to this continuing in terms of planning restrictions in the Plan period. The attached letter gives further detail and sets out that which we would like you to comment upon by 17 December 2012 in regard to the movement of waste from Hampshire to your area in future. Kind regards,

Paul Prowting Project Officer County Planning group Economy, Transport & Environment Department, Hampshire County Council, 1st Floor, EII Court West, The Castle, Winchester, Hampshire SO23 8UD Tel: 01962 846591 Fax: 01962 847055 Hertfordshire County Council

Northamptonshire County Council

Trish Carter-Lyons Please ask for: Mark Chant Tel: 01604 366831 Minerals and Waste Team Our ref: Hertfordshire County Council Your ref: Date: 24 May 2013 CHN216 County Hall Hertford Hertfordshire SG13 8DN

Dear Ms Carter-Lyons

Duty to Co-operate- Waste movements from Hertfordshire

I refer to your letter and attachment of 20 May 2013 regarding waste movements into Northamptonshire from Hertfordshire. In respect of the points you wanted answering we have the following comments to make:

(a) We believe the information in the enclosed table is accurate.

(b) All of the sites listed are still operating.

(c) There are planning matters relating to the following sites that you should be aware of: - Sidegate Lane Landfill- This landfill site will reach its capacity in 2017 and will close. - East Northants Resource Management Facility- This site for hazardous (and low level radioactive) waste disposal and for soil treatment only has permission until 2016. An application is with the National Infrastructure Directorate for permission to extend until 2026. If this is granted this is expected to be its final end date with no further extensions in time. - Westwood AD Plant- This site has a catchment restriction to only accept waste from up to 30 miles away. On this basis only waste from the Letchworth/Baldock area should be going into this facility. It appears that as waste from Hertfordshire comprises 5% of the annual throughput allowed at this facility, waste may be coming in from elsewhere in Hertfordshire. We will be pursuing this matter with the operator. - Kirby Lodge Compost Facility- This facility has a catchment restriction to only accept waste from up to 20 miles away. On this basis no waste from Dacorum, or

Planning Services County Hall Northampton NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. 01604 366065 e. [email protected]

indeed anywhere in Hertfordshire, should be going into this facility. We will be pursuing this matter with the operator.

(d) / (e) The County Council adopted the last element of its MWDF in 2011 and is now undertaking a partial review for adoption in 2014. There are adopted policies in the MWDF DPDs relating to including catchments on permissions and these are being carried forward in the partial review. All new permissions now have catchment areas included although these vary on the basis of the status of the facility. However composting and biological treatment at IVC and AD facilities will have a relatively tight catchment area as such facilities should normally be closer to the source of the waste. The catchment area policy stance in Northamptonshire, and which is contained in the development plan, should be noted by your authority in preparing its Waste Site Allocations document and any future review of the Core Strategy and Development Management policies document.

If you require any clarification of the above please do not hesitate to contact me.

Yours sincerely

Mark Chant Head of Planning Services

Kent County Council

From: Planning Sent: 25 September 2013 09:48 To: 'mwdf@kent.gov.uk' Subject:FW: Kent Minerals & Waste Plan - Duty to Co-operate- Waste Management Facilities

April

Please see below comments regarding Kent Minerals & Waste Plan - Duty to Co-operate- Waste Management Facilities.

Please note that most of the information that you have requested is available from the Council or other government websites – please refer to the document as listed below. * Status (including permission end date) of sites identified in Table 1 (i.e. temporary or permanent) – refer to Northamptonshire Minerals and Waste Local Plan (final draft) – Appendix 4. http://www.northamptonshire.gov.uk/en/councilservices/Environ/planning/policy/minerals /Pages/PartialReviewoftheMWDFLocalPlan.aspx * Hazardous landfill capacity over time is identified in the Waste Needs Assessment – Figure 17. http://www.northamptonshire.gov.uk/en/councilservices/Environ/planning/policy/minerals /Pages/PartialReviewoftheMWDFLocalPlan.aspx * Information requested for Table 2 is available from the EA waste infrastructure dataset.

In reference to Table 1 please note that an additional 2498.15 tonnes removed from Kent to facilities (as above) has been returned from the EA WDI database 2011 making a total of 30876.86 tonnes (see below). Kent UP3033UX CSG Aylesford treatment Plant Cleansing Service Group Ltd A17 : Physico-Chemical Treatment Facility Physical-Chemical Treatment Northamptonshire Northamptonshire East Midlands 2049.61 Kent XP3298HV (10367) Countrystyle Composting Facility Countrystyle Recycling Ltd A15 : Material Recycling Treatment Facility Material Recycling Facility Northamptonshire Northamptonshire East Midlands 448.54

It would be appreciated if you could add Northamptonshire Planning Policy to your electronic stakeholder database so that we are notified of future consultations.

Kind Regards Laura Burton Planning Policy

From: Mark Chant Sent: 08 August 2013 10:06 To: '[email protected]' Cc: Laura Burton Subject:FW: Kent Minerals & Waste Plan - Duty to Co-operate- Waste Management Facilities Attachments: Duty to Co-operate - Waste Planning Authority - Northamptonshire County Council.doc

April In relation to your questions: - All the sites have a permanent permission except for the East Northamptonshire Resource Management Facility. - The East Northamptonshire Resource Management Facility has an end date of 2026 and if complete by then, then an extension in area would have a number of key hurdles to cross. - None of your waste currently goes to any landfill facility in Northamptonshire. There will effectively only be two landfills left in the county after 2017 and there is a long term question mark over one of these despite it having a permission to 2026. The other one (Rushton) has permission to 2030 but has catchment restrictions imposed on it.

If you have any further questions please come back to me. regards

Mark

Mark Chant I Head of Planning Services I 01604 366831 I Planning Services, Northamptonshire County Council, County

Hall, Guildhall Road, Northampton NN1 1DN

From: [email protected] [mailto:[email protected]] Sent: 23 July 2013 16:37 To: Planning Subject: Kent Minerals & Waste Plan - Duty to Co-operate- Waste Management Facilities Importance: High

Dear Ms Burton,

As part of Kent County Council's Kent Minerals and Waste Plan (2013-2030), we are obliged to undertake a 'Duty to Co-operate;' comprising organisations and authorities involved in the importation of minerals into the Kent region and receive waste exports arisen in Kent. Please find attached a letter regarding waste management facilities Kent export waste to for your perusal.

Any responses to this letter are to be sent to [email protected].

Thank you for your time.

Yours sincerely

April Newing Assistant Planning Officer Minerals & Waste Planning Policy Team Kent County Council

Internal: 7000 4576

External: 01622 694576

Email: [email protected]

Kirklees Council From: Shari Macdonald Sent: 30 December 2013 00:05 To: Mark Chant; Laura Burton Subject:FW: DTC & Kirklees Waste Movements

Mark / Laura Please see draft response below: [email protected] James, As requested – please see below. Non-Haz

1. Do you consider the information presented to be accurate? Do you have any additional waste movement data or information? Data returned from a search of the EA 2012 Waste interrogator varies from that reported in correspondence from Kirklees: 127.5 tonnes WEEE treatment facility and 17.7 tonnes MRF received from Kirklees to Northamptonshire. 2. Are you aware of any planning reasons why waste movements similar to that stated for 2012 cannot continue in the future? No. Please provide facility end dates where these are known. Please refer: Waste needs assessment Table 6 and 9, Figure 10, para 3.20 – 3.22 http://www.northamptonshire.gov.uk/en/councilservices/Environ/planning/policy/minerals/Docum ents/PDF%20Documents/403%20Waste%20Needs%20Assessment.pdf MWLP submission plan Appendix 4 http://www.northamptonshire.gov.uk/en/councilservices/Environ/planning/policy/minerals/Docum ents/PDF%20Documents/300%20Submission%20Local%20Plan%20Nov%2013.pdf 3. Do you consider that sites within your waste planning area have the capacity to continue to accept waste movements from Kirklees similar to those stated for 2012 over our plan period, from 2016 to 2031? Yes 4. Please identify if you have, or are likely to, safeguard specific sites? Yes, as per policy CS11 of the adopted MWDF (Policy 33 of the MWLP submission plan). 5. Do you have any general comments or further additional information on the movement of waste from Kirklees to your waste planning area? No.

Haz 1. Do you consider the information presented to be accurate? Yes as per data returned from EA 2012 Haz waste interrogator. Do you have any additional hazardous waste movement data or information? No. 2. Are you aware of any planning reasons why hazardous waste movements similar to that stated for 2012 cannot continue in the future? No. Please provide facility end dates where these are known. Please refer: MWLP submission plan Appendix 4 http://www.northamptonshire.gov.uk/en/councilservices/Environ/planning/policy/minerals/Docum ents/PDF%20Documents/300%20Submission%20Local%20Plan%20Nov%2013.pdf 3. Do you consider that sites within your waste planning area have the capacity to continue to accept waste movements from Kirklees similar to those stated for 2012 over our plan period, from 2016 to 2031? Planning permission for the East Northants Resource Management Facility expires 31 December 2026. 4. Please identify if you have, or are likely to, safeguard specific sites? Yes, as per policy CS11 of the adopted MWDF (Policy 33 of the MWLP submission plan). 5. Do you have any general comments or further additional information on the movement of hazardous waste from Kirklees to your waste planning area? No.

From: Local Development [mailto:[email protected]] Sent: 05 December 2013 11:23 To: Development Control Subject: DTC & Kirklees Waste Movements Dear Sir/Madam,

As work progresses on the waste section of the emerging Plan for Kirklees, we now want to check the accuracy of the outflow data we hold for waste. As a waste planning authority who has received waste from Kirklees in 2012 we are writing to you to check the accuracy of this information. Kirklees Council would like your authority's response to the questions raised in the attached letter taking account of the attached waste flow data. Responses can be returned either through the post to:

Planning Policy Group Investment and Regeneration Service PO Box B93 Civic Centre 3 Off Market Street Huddersfield HD1 2JR

Or by email to: [email protected] Leicestershire County Council

From: Planning Sent: 03 January 2014 11:30 To: '[email protected]' Subject:Leicestershire Minerals and Waste Local Plan Consultation

Phil

Please find attached a response from Northamptonshire County Council in relation to the Minerals and Waste Local Plan consultation.

* Q2 – provision of aggregates and the waste arisings / capacity requirements should be updated (as per para 2.6)

* Q3 – Agree, also remove ref to regional targets in waste obj 4. Some of the minerals and waste objectives are similar / related and could be combined to form one set of objectives.

Opportunity to align objectives more closely with nppf re: historic env/assets, flood risk, climate change.

Minerals

* Q4 – unless an increase can be supported by robust evidence base (justifying a specific % increase) then the nppf 10yr avg should be applied.

* Q5/6/7 – a balance between extension of existing sites / new sites within broad areas currently and historically subject to minerals extraction and new sites should be taken forward supporting maximum recovery of resources and id of new sites where environmentally acceptable

* Q8 – if industry / landowners can id viable sites that are determined through assessment to be suitable as being allocations these should be taken forward, where insufficient sites are identified to provide the total aggregate during the plan period ‘areas of search’ should also be id’ed.

* Q11 – if sufficient permitted reserves exist these should be prioritised unless clear justification can be given as to why a new site would be necessary to continue supply of aggs * Q 12 – see Q8

* Q13/14/15/18 – current policies are adequate

* Q 16 /20 – current policy adequate but should amend where necessary to reflect findings of the EH strategic stone study

* Q17 – may need to be amended to reflect ‘positive planning’ instead of a presumption against development

* Q19/23 – may need to expand mcs10 to incl mineral processing facilities as per nppf (if not addressed through another policy)

* Q21 – yes, as stated in para 4.96, ie 200m S&G, 500m Lst

* Q22 – Only define in urban areas where there is a realistic chance of prior extraction associated with large redevelopments e.g. large industrial locations / regeneration projects

Waste

* Q24 – yes

* Q25 – growth rates should align with the municipal waste management strategy

* Q26 – waste mgt targets should align with the municipal waste management strategy, national policy and European directives

* Q27 – No. ADAS survey shows inconsistencies with previous surveys in relation to inclusion / exclusion of certain waste types and C&I sectors (i.e. businesses with less than five employees) – making direct comparison of datasets difficult. Adjustment to the figures can be made to allow for comparison with national datasets e.g. allowance for businesses with less than five employees (ADAS concludes 5% for the East Midlands).

* Q28 – Yes, unless locally based economic data is available to base projections on

* Q29 – Agree with use of 50% however application of targets for C&I waste may not be realistic as this is outside of the County’s control – largely dictated by commercial contracts and market / wider policy drivers and so may not be achievable / realistic or supported by sufficient evidence.

* Q30 – agree with use of wrap study data however consideration should be given to waste arisings identified through plans for both rutland and Leicester city where available to ensure consistency.

* Q31 – Yes, agree with zero % growth for CD&E wastes.

* Q32 - yes, targets should align with national policy and eu directives (e.g. WFD target of reusing, recycling and recovering a minimum of 70% of C&D waste by weight by 2020). at minimum current rates should be applied. Higher rates may be difficult to deliver esp for individual wpas as waste streams such as C&I and CD&E are driven by commercial contracts and market / wider policy drivers and so may not be achievable / realistic or supported by sufficient evidence.

* Q33 - yes

* Q34 - yes

* Q35 - yes

* Q36 - yes, should address development control criteria in the event that an application for such a facility is brought forward

* Q37 - targets for landfill should align with MWMS, national policy and eu directives. at minimum current disposal rates should be applied.

* Q38 - yes, agree that the plan should provide sufficient capacity to manage the equivalent of the waste which arises within the area - check ea dataset exports rutland to leics

* Q39 - yes

* Q40 - yes

* Q41 - yes

* Q42 - wcs8(iii) should also include mineral extraction facilities in order to support restoration of such sites

* Q43 - Where site specific allocations cannot be made it may be prudent to identify industrial or similar areas where waste development would be considered acceptable in principle in order to facilitate delivery of the capacity gap

* Q44 - existing and permitted sites should be safeguarded (some sites may have permission but not yet be operational). this should include both encroachment from incompatible development as well as redevelopment of adjacent sites to an incompatible development / land use. this is because the outcomes from both situations would be similar with the new development potentially being impacted upon by an existing land use - the resulting land use conflict may impede future operations of the waste development.

* dev mgt

* Q45 - it may not be necessary to include exact wording however some reference to the presumption in nppf should be included

* Q46 to 55 - it is for the mpa to determine whether additional policy coverage is required to address local circumstance and address any potential policy gaps between the nppf and local plan

* Q55 - yes in relation to temporary waste development being included under restoration policies

* Q57 to 61 - The approach to the reclamation of mineral workings and landfill sites should take into consideration the surrounding environment - not prioritise one outcome over another as this may not be suitable across the county.

Please confirm receipt of this email, should you have any queries please do not hesitate to contact us Kind Regards Laura Burton Planning Policy

From: Phil Larter [mailto:[email protected]] Sent: 21 November 2013 11:16 Subject: FW: Minerals and Waste Local Plan Consultation

Dear Sir/Madam,

Leicestershire County Council has started to review its current planning policies dealing with mineral extraction and waste management in Leicestershire, which were adopted in 2009. To this end, a consultation document has been prepared which identifies a range of key issues that are likely to influence the future strategy for minerals and waste planning in the County. The attached letter invites you to make comments on this consultation.

Regards,

Phil Larter

Senior Planning Officer

Chief Executive's Department

Planning, Historic and Natural Environment

County Hall

Glenfield

Leicester LE3 8RA

(0116) 305 7292 Lincolnshire County Council

Northamptonshire County Council

Richard Leonard Please ask for: Planning Services Tel: 01604 366014 Strategic Planning Team Our ref: Lincolnshire County Council Your ref: Witham Park House Date: 5 October 2012 Lincoln LN5 7JN

Dear Mr Leonard

Lincolnshire County Council Minerals and Waste Local Plan

Thank you for you letter dated 27th September 2012. Please find below the site information that you requested.

Collyweston Quarry – This is currently used for inert disposal but the current permission requires restoration to be finished by 2017.

Kings Cliffe Hazardous Landfill – This site currently takes hazardous waste and currently only has permission until 2016. But there is a current application with the National Infrastructure Directorate of the Planning Inspectorate to extend the lifetime of the site to 2026.

Should you require any more assistance please do not hesitate to contact us.

Yours Sincerely

Laura Burton Principal Planner

Planning Policy Guildhall Road Block County Hall Northampton, NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. 01604 366065 e. [email protected] Milton Keynes Council

Northamptonshire County Council

Development Plans Please ask for: Planning Policy Tel: 01604 366014 Milton Keynes Council Our ref: MKC I&0 MIN Civic Offices Your ref: 1 Saxon Gate East Date: 16 January 2014 Central Milton Keynes MK9 3EJ

Dear Sir/Madam

Minerals Local Plan Issues and Options Consultation

Thank you for your email on 29 November 2013 inviting Northamptonshire County Council to comment on the Milton Keynes Minerals Local Plan Issues and Options Consultation.

We have read through the document and at this time we do not have any comments to make in relation to the Minerals Local Plan Consultation. We look forward to being kept informed and consulted at any appropriate stage as the Minerals Local Plan progresses.

Please do not hesitate to contact us if you have any queries regarding this matter.

Yours faithfully

Laura Burton Planning Policy

Planning Services Room 271, County Hall Northampton NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. e. [email protected] North East Lincolnshire Council From: Woolmer, Craig [[email protected]] Sent: 13 August 2013 08:55 To: Planning Subject:RE: Hazardous Waste Movements from North East Lincolnshire Hi Mark,

The Hazardous Waste Data Interrogator unfortunately does not list the individual lists receiving waste so I haven’t been able to send a definitive list of sites receiving hazardous waste. Apologies for this. I’ve raised this with the Environment Agency as something they may wish to address in future releases of the database. Regards,

Craig

Craig Woolmer Spatial Planning Officer North East Lincolnshire Regeneration Partnership, Origin One, 1 Origin Way, Europarc, Grimsby, DN37 9TZ

Tel: (01472) 325953 Email: [email protected] North East Lincolnshire Council and Balfour Beatty WorkPlace, working in partnership to deliver a stronger economy and stronger communities.

From: Planning [mailto:[email protected]] Sent: 13 August 2013 08:53 To: Woolmer, Craig Subject: RE: Hazardous Waste Movements from North East Lincolnshire

Craig We didn’t have a separate attachment listing sites so I assumed there was only one destination- the King’s Cliffe site. If there were more destinations then can you send the table through and I will respond. regards Mark.

From: Woolmer, Craig [mailto:[email protected]] Sent: 12 August 2013 15:58 To: Planning Subject: RE: Hazardous Waste Movements from North East Lincolnshire

Dear Mark,

Thank you very much for such a quick and helpful reply.

Kind regards,

Craig

Craig Woolmer BA, PGCert, MSc Spatial Planning Officer North East Lincolnshire Regeneration Partnership, Origin One, 1 Origin Way, Europarc, Grimsby, DN37 9TZ

Tel: (01472) 325953

Email: [email protected]

North East Lincolnshire Council and Balfour Beatty WorkPlace, working in partnership to deliver a stronger economy and stronger communities.

From: Planning [mailto:[email protected]] Sent: 12 August 2013 15:54 To: Woolmer, Craig Subject: RE: Hazardous Waste Movements from North East Lincolnshire

Craig In respect of the questions asked in your letter: 1. We consider the information presented to be accurate. We have no additional waste movement data/information. 2. It is assumed that the site in question to where this waste comes to is the East Northants Resource Management Facility at King’s Cliffe. 3. This specialist landfill site is still operating and has recently had its end date extended to 2026 by the National Infrastructure Directorate. 4. It is uncertain what the future of this site is post 2026. There would be considerable difficulties in extending it by area if it is full by 2026 (or earlier). Please note this site also has permission for low level radioactive waste disposal to the same end date of 2026. 5. All sites with a permanent permission and plan allocations are broadly safeguarded from alternative non-waste use under adopted MWDF policy. This is a non-permanent operational site but there is minimal chance of any proposal for alternative use coming forward. 6. Our adopted MWDF (adopted 2010/11) contains policies that promote catchment areas for waste and proposals for new or changed facilities in the county have to conform to this. However this facility has a national catchment area.

regards

Mark.

Mark Chant I Head of Planning Services I 01604 366831 I Planning Services, Northamptonshire County Council, County Hall, Guildhall Road, Northampton NN1 1DN

From: Woolmer, Craig [mailto:[email protected]] Sent: 12 August 2013 09:17 To: Planning Subject: Hazardous Waste Movements from North East Lincolnshire

Dear Sir/Madam, Please find attached a letter regarding the movement of hazardous wastes from North East Lincolnshire to your waste planning authority area for management. We look forward to hearing from you in due course. Yours faithfully,

Craig Woolmer Spatial Planning Officer North East Lincolnshire Regeneration Partnership, Origin One, 1 Origin Way, Europarc, Grimsby, DN37 9TZ

Tel: (01472) 325953

Email: [email protected]

North East Lincolnshire Council and Balfour Beatty WorkPlace, working in partnership to deliver a stronger economy and stronger communities North London Authorities

From: Onslow, Archie [[email protected]] Sent: 08 May 2013 11:21 To: Mark Chant Cc: Laura Burton; Shari Macdonald Subject: RE: Preparation of local plan for waste in North London

Mark Thank you for your comments which will inform the draft plan which we will consult on next year. We are likely to be in contact with you again fairly soon on the specifics of waste flows to Northamptonshire from North London after we have done a bit more research along the lines you suggest. Regards Archie

From: Mark Chant [mailto:[email protected]] Sent: 08 May 2013 10:45 To: Onslow, Archie Cc: Laura Burton; Shari Macdonald Subject: RE: Preparation of local plan for waste in North London

Archie

The plan period should be to 2031 and net self-sufficiency should be a key objective for the plan with an aspiration for this to be achieved at the earliest opportunity.

The above is the formal response of NCC.

Informally, you need to confirm where landfill waste is currently being exported to and what contracts are in place as it does appear that more and more operators are seeking to close/mothball their sites. We have been told by the operator that one of our landfill sites, and one that has no catchment area restriction, is likely to mothballed by the end of the year and there is considerable uncertainty over its eventual re-opening. This is a site that I think some North London waste may go to. It is also likely that this is being repeated in some of the other counties to which North London waste currently goes to. regards Mark.

From: Onslow, Archie [mailto:[email protected]] Sent: 19 April 2013 15:15 To: Onslow, Archie Subject: Preparation of local plan for waste in North London

Preparation of local plan for waste in North London

The London Boroughs of Barnet, Camden, Enfield, Hackney, Haringey, Islington and Waltham Forest are proposing to prepare a new local plan for waste in their boroughs to take the place of the non-adopted North London Waste Plan (NLWP). This is the start of the process to prepare the new Plan and the boroughs are inviting you to make representations about what it should contain.

After the boroughs had submitted the previous waste plan for examination, the Planning Inspector decided that it failed to meet the Duty to Co-operate and the boroughs have therefore agreed to start again as is required by law. When the boroughs submitted the NLWP, they believed it to be “sound” – that is, in accordance with the relevant tests. The Inspector halted the examination and never went on to consider issues of soundness at the examination. The boroughs therefore consider that the information generated through the preparation of the submission NLWP is a useful starting point from which to develop the new plan. Representations made throughout the preparation of the NLWP will also help inform the work on the new plan. All previous stages of the NLWP are still available to view at www.nlwp.net.

Evidence will be reviewed and updated and account taken of changing circumstances as the plan evolves. The boroughs propose to re-consider information on the amount of waste requiring management in North London and the extent to which it can be managed by the current facilities as well as to identify specific new sites which have potential for waste facilities to manage any shortfall in provision. The plan is intended to provide a framework for planning decisions relating to waste facilities and so will contain policies to be used when the boroughs assess planning applications for such facilities.

We are inviting you to make representations on any matter relating to the new local plan for waste. Your comments are particularly invited on the following matters:

1 The content of the local waste plan: Please let us know what you think the new local plan should contain. Do you think any content was missing from the submission NLWP?

2 The need for new waste facilities: Do you have views on the need for waste facilities in North London to deal with the waste likely to be generated in the next ten to fifteen years? If so, what types and size of facility might be needed?

3 The characteristics of a site suitable for waste use: If sites for new waste facilities are required, what type of site should be chosen? What criteria should the boroughs use to select waste sites? Do you think that the site criteria and assessment method in the submission NLWP are a useful starting point? Can they be improved upon?

4 Proposals for waste sites: Do you have any new suggestions on sites or areas in North London that might be suitable for future use for waste management?

5 Policies: do you have any suggestions for planning policies to ensure that waste developments are suitable in terms of location, environmental impact and any other important consideration? Do you think the policies in the NLWP are a useful starting point? Can they be improved upon?

To respond, please visit the ‘Have Your Say’ section of the NLWP website and use the special link. Or you can send your comments to [email protected]. If possible please return your comments in MS-Word format. If necessary your comments can be posted to:

Archie Onslow North London Waste Plan Camden Town Hall Argyle Street WC1H 8EQ

Please send your comments by 7th June 2013. Comments received after that date may be fed into later revisions of the waste plan.

Meetings with interested groups If you belong to a group and would like to meet staff to discuss these or any other points about the new local plan for waste in North London please get in touch (see details at end).

What happens next? The boroughs will use these initial comments to help draw up a draft new waste local plan that they expect to produce in 2014. There will be further consultation at this stage and subsequent opportunities to give comments on the new plan.

Contact details [email protected] For more information phone 020 7974 5916

Archie Onslow Programme Manager North London Waste Plan Camden Town Hall Argyle Street, London WC1H 8EQ email: [email protected] tel: 020 7974 5916 fax: 020 7974 1930

North London Waste Plan Duty to Co-operate- Response from Northamptonshire County Council

1) The information that you have provided appears correct.

2) Northamptonshire County Council are happy with figures suggested in relation to significant quantities of waste.

3) The County Council considers the hazardous was export to our area to be significant. The East Northants Resource Management Facility currently has an end date of 2026 so will continuing to receive waste until this point. Paragraph 5.91 of the Minerals and Waste Plan: Submission document published in November 2013 and currently under going examination, recognises that the East Northants Resource Management Facility has a national significance and therefore has a national catchment area. For the other current receivers of waste: Monoworld is operating on a site permitted for B2 use under a District permission. The site is currently in breach of this permission (the current operations are probably classed as B8), but we are lead to believe the operator is altering operations at the site and they we be converting to a B2-‘type’ operation in the Spring. Accordingly Monoworld has not yet been subject of planning enforcement action by the County Council. The SIMS group site in Daventry was operating under County Council planning permissions, and was the subject of a Breach of Condition Notice issued by the County Council. The site is now no longer operational as a WEE facility and the operators are looking at how to proceed with the removal of the breach of condition notice and vacating the site . Northamptonshire County Council are happy to continue dialogue with the North London Boroughs in relation to waste movements.

4) Para 2.35 of the Minerals and Waste Local Plan: Submission document published in November 2013 and para 4.15 of the adopted Mineral and Waste Core Strategy adopted May 2010 states that London should endeavour to take responsibility for its own waste – this is in line with communities taking more responsibility for their own waste and moving waste up the hierarchy which is supported by national policy. As previously indicated to you Northamptonshire County Council do implement catchment areas on new waste sites. Details on catchment areas can be found at paragraph 5.104 onwards in the Minerals and Waste Local Plan: Submission document and in the adopted Control and Management of Development DPD adopted June 2011 at paragraph 3.6 onwards.

Northumberland County Council

Northamptonshire County Council

Northumberland County Council Please ask for: Planning Services Spatial Policy and Delivery Team Tel: 01604 366014 Our ref: NC/I&O Development Services Your ref: Local Services Group Date: 7 August 2012 County Hall Morpeth Northumberland NE61 2EF

Dear Sir / Madam

Northumberland Core Strategy Issues and Option Consultation Document May 2012.

Northamptonshire County Council as a waste planning authority would like to comment in relation to Question 56 on the subject of hazardous landfill sites.

Northamptonshire feel that although a specific site for hazardous disposal does not need to be specifically identified in the plan, a policy setting out the criteria on which the planning authority would determine any proposal coming forward for a specific hazardous waste disposal landfill site should be included.

In similar vein there is no policy setting out the criteria on which the planning authority would determine any proposal for radioactive waste disposal and/or management.

If you require any clarification of the above comments please do not hesitate to contact me.

Yours sincerely

Laura Burton Principal Planner

Planning Policy Guildhall Road Block County Hall Northampton, NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. 01604 366065 e. [email protected]

Northamptonshire County Council

Northumberland County Council Please ask for: Planning Services Spatial Policy and Delivery Team Tel: 01604 366014 Our ref: NCC/PO Development Services Your ref: County Hall Date: 12 Feb 2013 Morpeth Northumberland NE61 2EF

Dear Sir / Madam

Northumberland Core Strategy Preferred Options Consultation Document February 2013.

Northamptonshire County Council as a waste planning authority would like to comment in relation to Policy 34 on the subject of hazardous landfill sites.

Northamptonshire feel that although a specific site for hazardous disposal does not need to be specifically identified in the plan, a policy setting out the criteria on which the planning authority would determine any proposal coming forward for a specific hazardous waste disposal landfill site should be included.

In similar vein there is no policy setting out the criteria on which the planning authority would determine any proposal for radioactive waste disposal and/or management.

If you require any clarification of the above comments please do not hesitate to contact me.

Yours sincerely

Laura Burton Principal Planner

Planning Policy Guildhall Road Block County Hall Northampton, NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. 01604 366065 e. [email protected] Nottinghamshire County Council

Northamptonshire County Council

Planning Policy Team Please ask for: Planning Services Tel: 01604 366014 Nottinghamshire County Council Our ref: NCC WCS County Hall Your ref: Date: 13 April 2012 West Bridgford Nottingham NG2 7QP

Dear Sir/Madam

Nottinghamshire and Nottingham Waste Core Strategy Proposed Submission Document

Thank you for consulting the county council on the above. As a waste planning authority we have comments in relation to hazardous waste provision.

Northamptonshire County Council is concerned that there is no specific policy setting out the criteria on which Nottinghamshire County Council would determine any proposal coming forward for a specific hazardous waste disposal facility. Please note the facility mentioned as being in the East Midlands region at King’s Cliffe only has a temporary permission to 2013 and it should therefore not be referred to in the text. In similar vein there is no policy setting out the criteria on which Nottinghamshire County Council would determine any proposal for radioactive waste disposal and/or management.

If you require any clarification of the above comments please do not hesitate to contact me.

Yours sincerely

Laura Burton Principal Planner

Planning Policy Guildhall Road Block County Hall Northampton, NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. 01604 236065 e. [email protected]

Northamptonshire County Council

S Osbourne-James Please ask for: Planning Services Tel: 01604 366014 Nottinghamshire County Council Our ref: NOTTS/DTC County Hall Your ref: West Bridgford Date: 27 November 2012 Nottingham NG2 7QP

Dear Mrs Osborne-James

Nottinghamshire and Nottingham Waste Core Strategy – Duty to Cooperate

Thank you for your letter dated 19th November 2012. We can confirm that Northamptonshire County Council have no further issues to raise in relation to the Waste Core Strategy and are happy with the changes suggested in the Proposed Schedule of Changes.

Yours sincerely

Mark Chant Head of Planning Services

Planning Policy Guildhall Road Block County Hall Northampton, NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. 01604 366065 e. [email protected] Oxfordshire County Council

Northamptonshire County Council

Oxford County Council Please ask for: Planning Services Tel: 01604 366014 Minerals and Waste Policy Team Our ref: OCC_Sub Speedwell House Your ref: Speedwell Street Date: 5 July 2012 Oxford OX1 1NE

Dear Sir/Madam

Minerals and Waste Core Strategy Proposed Submission Document

Thank you for consulting the County Council on the above. As a waste planning authority we have comments in relation to radioactive waste.

Northamptonshire County Council has concerns over Policy W8 and we suggest amended wording below to address these. It is noted that although the policy refers to radioactive waste in its title is does not specify radioactive waste in the body of the policy.

Policy W8: Hazardous and radioactive waste Permission will be granted for facilities for the management of hazardous and radioactive waste where they are designed to meet a requirement for the management of waste produced in Oxfordshire. Facilities that also provide capacity for hazardous and radioactive waste from a wider area should demonstrate that they will meet a need for waste management/disposal that is not adequately provided for elsewhere.

The suggested change would also reflect paragraph 5.70 and provide clarity as hazardous waste and Low Level Radioactive Waste are distinct from one another. It is felt that this lack of wording does not make the plan effective as it is uncertain whether the plan would be able to adequately deal with any proposal that would come forward for radioactive waste disposal in the county.

If you require any clarification of the above comments please do not hesitate to contact me.

Your Sincerely

Laura Burton Principal Planner

Planning Policy Guildhall Road Block County Hall Northampton, NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. 01604 366065 e. [email protected] From: Mark Chant Sent: 05 March 2012 10:02 To: '[email protected]' Cc: Phil Watson; Shari Macdonald Subject: RE: Oxfordshire Minerals and Waste Core Strategy - Preparation of Proposed Submission Document

Trevor

If the revisions were to stay as sent to us, then we would object to the proposed submission document on the basis that:

Policy W8 does not specifically refer to radioactive waste within it- it is only referred to in the title. All references to ‘hazardous’ waste in the policy statement should be amended to ‘hazardous/low level radioactive’ waste. The policy should also refer to ‘management/disposal’. (The explanatory text of policies W8 and W9 should be amended to reflect this policy amendment.)

If the above is done then the re-worded Policy W9 becomes acceptable. regards

Mark.

From: Brown, Trevor - E&E Planning and Regulation Service [mailto:[email protected]] Sent: 29 February 2012 10:16 To: Phil Watson Subject: Oxfordshire Minerals and Waste Core Strategy - Preparation of Proposed Submission Document

Phil, I'm not sure whether you dealt with Northamptonshire's comments on our previous consultation (Sept 2011) - the comments came to us from your general Planning email address; if not, could you please pass this on. Attached is a letter with accompanying documents that set out some changes to our proposed policies on nuclear waste/hazardous waste and waste imports. We do understand how busy everyone is and we will obviously be consulting further when the Proposed Submission Document goes out to consultation, but we did value your earlier comment and if you do find time to have a look at the changes we are making, we would be very grateful. Trevor

Trevor Brown Principal Planning Officer Minerals and Waste Policy Team

Northamptonshire County Council

Minerals and Waste Draft Plan Consultation Please ask for: Planning Policy Tel: 01604 366014 Environment & Economy – Planning Regulation Our ref: Oxfordshire County Council Your ref: S:\SPED\15.1.2\4.10

Speedwell House Date: 13 March 2014 Speedwell Street Oxford OX1 1NE

Dear Sir/Madam

Consultation on Draft Oxfordshire Minerals and Waste Local Plan: Core Strategy

Northamptonshire County Council is not supportive of a plan that does not provide provision figures within a policy (in this case Policy M2). If Oxfordshire are to continue with the method of not providing provision figures, more regard should be paid to the 3 year average sales figures and Para 4.17 should therefore be amended to reflect this.

Northamptonshire County Council is content with Policy W8. However it would wish the positive tone of Policy W8 to be carried over into Policy W9. Policy W9 should therefore be re-worded as follows: Permission will be granted for proposals for the management or disposal of low level radioactive waste where it can be demonstrated that the proposal will make a significant contribution to the management of waste produced in Oxfordshire or it will meet a need for waste management that is not provided elsewhere. Para 5.79 should also be amended to reflect the amendment to Policy W9.

If you require any clarification of the above comments please do not hesitate to contact me.

Yours Sincerely

Laura Burton Principal Planner

Planning Services Room 271, County Hall Northampton NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 e. [email protected]

Rutland County Council

From: Mark Chant

Sent: 23 July 2013 15:58

To: '[email protected]'

Cc: Shari Macdonald; Laura Burton

Subject:Confirmation of Duty to Co-operate

David

This is to confirm that Northamptonshire County Council considers, insofar as matters relating to us as a planning authority, that the Duty to Co-operate has been met in respect of the Rutland Site

Allocations and Policies DPD.

regards

Mark. Warwickshire County Council

Northamptonshire County Council

Tony Lyons Please ask for: Planning Services Tel: 01604 366014 Principal Planning Officer Our ref: WCCW/Publication Planning and Development Your ref: PO Box 43 Date: 8 August 2012 Shire Hall Warwick CV34 4SX

Dear Tony

Warwickshire County Council: Waste Core Strategy Publication Consultation

Thank you for you letter with your comments in relation to hazardous waste and low level radioactive waste.

We accept that hazardous waste and low level radioactive waste does not necessarily require a separate policy in the plan, but at present we cannot see how these waste types would actually be dealt with using your current policies. Until it can be demonstrated how your existing policies deal with both hazardous waste and low level radioactive waste we will not be in a position to change our representation to the plan.

If you require any further clarification please contact either myself or Mark Chant, Head of Planning Services on 01604 366831

Yours Sincerely

Laura Burton Principal Planner

Planning Policy Guildhall Road Block County Hall Northampton, NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. 01604 366065 e. [email protected] From: [email protected] [mailto:[email protected]] Sent: 07 December 2012 12:41 To: Mark Chant Cc: Laura Burton Subject: RE: Examination of the Core Strategy of the Warwickshire Waste Local Plan

Dear Mr Chant

Thank you for your speedy response. I have forwarded your comments to the Inspector.

Many thanks. regards Bee Yew-Booth Programme Officer Tel no : 01926 418071 [email protected]

From: Mark Chant To: "'[email protected]'" Cc: Laura Burton Date: 07/12/2012 09:29 Subject: RE: Examination of the Core Strategy of the Warwickshire Waste Local Plan

Dear Ms Yew-Booth

Thank you for your email.

The Council notes that the Inspector has picked up on the issues we have raised on hazardous and radioactive waste and considers there is limited additional information it can add to the debate.

One of the reasons why the Council has resisted making detailed wording changes is because it is difficult to suggest where this should go and what it should say without it involving a redrafting of a number of policies. However the Council notes the questions posed by the Inspector in the Matters and Issues for Examination ( questions 77 and 79) and would support amendments to Policy CS1 and Policies CS5-7 as implied in the questions.

Failing that we note a potential alternative approach that the Council would support: the submission plan at para 8.15 states that ‘if new proposals for hazardous waste treatment are submitted, they will be judged on their merits when assessed against all relevant development plan policies, and taking into account national policy and guidance and other relevant material considerations’; this statement could be expanded to include reference to low level radioactive waste and changed into policy. regards Mark.

Mark Chant I Head of Planning Services I 01604 366831 I Planning Services, Northamptonshire County Council, County Hall, Guildhall Road, Northampton NN1 1DN

From: [email protected][mailto:[email protected]] Sent: 06 December 2012 13:11 To: Planning Subject: Examination of the Core Strategy of the Warwickshire Waste Local Plan

Dear Ms Burton

Please find attached the following two documents produced by the Inspector;

 Matters and Issues for Examination,  Main Modifications, Recommendations to the Core Strategy of the Warwickshire Waste Local Plan.

You may wish to comment upon the soundness of the Plan’s policies with regard to hazardous waste and radioactive waste and to attempt to reach a common position with the Council, possibly by way of a Statement of Common Ground.

Participants are urged to read the Guidance Notes below, this can also be found from the examination website www.warwickshire.gov.uk/wasteplanexamination

All statements should be received by myself no later than midday on Monday 31st December 2012.

If you have any queries please do not hesitate to contact me.

Regards Bee Yew-Booth Programme Officer Tel no : 01926 418071 [email protected]

West Berkshire Council

1) The information that you have provided seems correct. In relation to the 2.04 tonnes of waste received at the MRF in Berkshire that is not codeable, this waste should not be assigned to Northamptonshire and should be left as just being imported from the East Midlands. We have no further information as our figures are taken from the same sources.

2) The SIMS group site in Daventry is currently operating under County Council planning permissions, and has been the subject of a Breach of Condition Notice issued by the County Council. The operator is understood to be close to achieving compliance with this notice, and whilst reducing the operating capacity of the site, would not prevent the continued use of the site for WEEE recycling.

3) Whether or not these sites continue to accept waste over your plan period will be down to the commercial arrangements of these facilities. Northamptonshire are aiming for self sufficiency in terms of treating waste but do accept that waste will travel to Northamptonshire from other counties.

4) Waste that is imported into the county is included in figures even if it is non codeable. With improvements in reporting the amount of non codeable results has been decreasing.

5) Northamptonshire County Council accepts that cross boundary movements will take place due to the commercial nature of the waste industry. Northamptonshire County Council do implement catchment areas on new waste sites inline with the adopted MWDF which is being carried forward into the Local Plan which is currently at examination. Details on catchment areas can be found at paragraph 5.104 onwards in the Minerals and Waste Local Plan: Submission document.

6) The current adopted Minerals and Waste Development Framework has a number of allocated sites for both waste and minerals development. Permitted and operational sites are covered by safeguarding policy CS11 in the adopted MWDF.

7) We note that in relation to waste matters a number of authorities have chosen to go down the route the West Berkshire have of going through the waste interrogator and sending all authorities lists of facilities in their area and asking whether this is likely to continue. This tends to neglect the strategy/policy angle and really only asks planning authorities about commercial arrangements they usually have no control over. 5th March 2014

West London Boroughs Response from Northamptonshire County Council to a request for information from West London Boroughs. 14 February 2014

Duty to Co-operate – hazardous waste movements from West London boroughs

1) Waste data in relation to hazardous waste should be taken from hazardous waste interrogator rather than the waste interrogator. The data from the hazardous waste interrogator gives a total of 2797.62 tonnes instead of 6895 tonnes.

2) Both sites are currently operational. ESS Recycling is currently operated under B2 from the District.

3) We are unsure of the current status of the ESS recycling but can confirm that the East Northants Resource Management Facility has permission to operate until the end of 2026.

4) Paragraph 5.91 of the Minerals and Waste Plan: Submission document published in November 2013 and currently under going examination, recognises that the East Northants Resource Management Facility has a national significance and therefore has a national catchment area.

5) No further comments on hazardous waste.

Duty to Co-operate – waste movements from West London boroughs

1) The information that you have provided seems correct.

2) Monoworld is operating on a site permitted for B2 use under a District permission. The site is currently in breach of this permission (the current operations are probably classed as B8), but we are lead to believe the operator is altering operations at the site and they we be converting to a B2- ‘type’ operation in the Spring. Accordingly Monoworld has not yet been subject of planning enforcement action by the County Council. The SIMS group site in Daventry is currently operating under County Council planning permissions, and has been the subject of a Breach of Condition Notice issued by the County Council. The operator is understood to be close to achieving compliance with this notice, and whilst reducing the operating capacity of the site, would not prevent the continued use of the site for WEEE recycling.

3) Sims Group currently has the breach of condition notice served on it which will impact the capacity and cause a likely reduction. The East Northants Resource Management Facility currently has an end date of 2026.

4) The plan (para 2.35 of the Minerals and Waste Local Plan: Submission document published in November 2013) states that London should endeavour to take responsibility for its own waste – this is in line with communities taking more responsibility for their own waste and moving waste up the hierarchy which is supported by national policy. It should also be noted that under the former regional planning system it was only authorities in the East and South East Regions that were expected to take a proportion of London’s waste i.e not Northamptonshire in the East Midlands. Northamptonshire County Council do implement catchment areas on new waste sites. Details on catchment areas can be found at paragraph 5.104 onwards in the Minerals and Waste Local Plan: Submission document. 5) No further comments West Sussex County Council

Northamptonshire County Council

Strategic Planning Please ask for: Planning Services Tel: 01604 366014 West Sussex County Council Our ref: WSussex_DTC County Hall Your ref: Chichester Date: 7 September 2012 West Sussex PO19 1RH

Dear Michael Elkington

Duty to Co-Operate: Waste movements from West Sussex

Thank you for you letter dated 6th September 2012. Northamptonshire County Council has the following comments to make in response to the questions you raised.

Question A) Yes

Question B) Facility only has permission to 2016 although application to the National Infrastructure Directorate for extension to 2026 has been made – determination in mid 2013.

Question C) No

Question D) No

If you require any clarification of the above comments please do not hesitate to contact me.

Yours Sincerely

Laura Burton Principal Planner

Planning Policy Guildhall Road Block County Hall Northampton, NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. 01604 366065 e. [email protected]

Northamptonshire County Council

Strategic Planning (WLP) Please ask for: Planning Services Tel: 01604 366014 West Sussex County Council Our ref: WSC PS Waste County Hall Your ref: Chichester Date: 22 November 2012 West Sussex PO19 1RH

Dear Sir/Madam

West Sussex Waste Local Plan Proposed Submission Draft (Regulation 19)

Thank you for consulting the county council on the above. As a waste planning authority we have comments in relation to hazardous waste.

Both the hazardous waste and low level radioactive waste policies appear at first glance to meet what Northamptonshire County Council would consider to be a requirement to have policies on which proposals for such development can be determined. However both policies are drafted in such a way as to effectively preclude such development being granted planning permission.

Policy W7-Hazardous and Low Level Radioactive Waste This policy only relates to proposals that will make a substantial contribution to the management of waste produced in the plan area. It should include criteria on which proposals for waste produced outside of the plan area should be determined.

If you require any clarification of the above comments please do not hesitate to contact me

Yours sincerely

Laura Burton Principal Planner

Planning Policy Guildhall Road Block County Hall Northampton, NN1 1DN w. www.northamptonshire.gov.uk t. 01604 366014 f. 01604 366065 e. [email protected] From: Mark Chant Sent: 20 March 2013 17:37 To: '[email protected]' Subject: West Sussex WLP: haz and low level radioactive wastes

Alethea

For some reason I managed to send this before I had the chance to fully read it through and to make a conclusion! However, nothing more to add really. I can’t point to any guidance on the need for criteria in national policy or guidance, but I don’t think that let’s you off the hook! I will have a look through our correspondence with the Warwickshire Core Strategy Programme Officer as I think this may give pointers. regards

Mark.

From: Mark Chant Sent: 20 March 2013 17:04 To: '[email protected]' Subject: RE: West Sussex WLP: haz and low level radioactive wastes

Alethea

Our view is that Policy W7 when read in conjunction with Policy W8 and in relation to (a) (i) of this Policy, Policy W1 (b) is written in such a way as to preclude the granting of such sites, but that Waste Plans should have policies that more clearly, and proactively, set out the criteria on which any proposals for hazardous or radioactive waste disposal are determined.

There is a long standing issue in respect of hazardous waste facilities in London and the wider south east, with the only properly engineered facility being in Northamptonshire, and the case for a more proactive policy in Waste Plans in the wider south-east to address this is considered necessary. There are considerable doubts about the long term (post 2026) future of the Northamptonshire facility because of land ownership constraints, and remember your plan goes five years beyond that date.

Radioactive waste is a more recent issue and the hazardous waste facility in Northamptonshire is now allowed to take radioactive waste. It is the only such facility in the south, midlands and east of the Pennines. Bearing in mind 2026, which looks like the likely end of the Northamptonshire site, is the date when radioactive disposal is expected to accelerate.

Reliance on a site(s) elsewhere for hazardous waste/radioactive waste disposal does appear to be actually the default position of the plan even if it is not actually stated- the nature of the relevant policies implies this.

It is therefore our view that a more proactive policy for hazardous and radioactive waste disposal is required. We consider an Inspector would also concur with this view. It may also be that Cumbria have also commented in similar vein to our representation.

For information the policy on radioactive waste disposal we consulted on in our partial review is: Policy 21: Development criteria for radioactive waste disposal Proposals for the disposal of radioactive waste must demonstrate that: * the proposal is best placed to serve the wider communities need (i.e. national), * it is in general conformity with the principles of sustainable waste management including the waste hierarchy and proximity principle, in doing so identify the intended catchment area for the waste to be disposed and demonstrate how the proposal supports sustainable transport movements, * there is a clearly established need for the facility, and where applicable the requirement for a specialist facility, * disposal forms the last available management option, * any potentially adverse impacts can be mitigated to an acceptable level, and * it will not prejudice the existing use where the proposal is for co-location on a committed site. Cumbria CC have come back to us with an alternative policy wording (see attachment). By the way we never turn up in person at public hearing sessions even if no agreement on representations is reached! regards

Mark.

From: [email protected] [mailto:[email protected]] Sent: 18 March 2013 10:54 To: Mark Chant Subject: West Sussex WLP: haz and low level radioactive wastes Morning Mark,

Further to our discussion at the conference last week I would like to take the opportunity to discuss the representation submitted by Northamptonshire in respect of the West Sussex Waste Local Plan.

The text of your representation set out the following (to save you looking it up): ''Thank you for consulting the County Council on the above. As a waste planning authority we have comments in relation to hazardous waste. Both the hazardous waste and low level radioactive waste policies appear at first glance to meet what Northamptonshire County Council would consider to be a requirement to have policies on which proposals for such development can be determined. However both policies are drafted in such a way as to effectively preclude such development being granted planning permission. Policy W7-Hazardous and Low Level Radioactive Waste. This policy only relates to proposals that will make a substantial contribution to the management of waste produced in the plan area. It should include criteria on which proposals for waste produced outside of the plan area should be determined. If you require any clarification of the above comments please do not hesitate to contact me''

The West Sussex WLP contains Policy W7 which refers to both Hazardous and Low Level Radioactive Wastes, in terms of treatment and disposal processes. The criteria under Policy W8 (non inert waste disposal) will also be used to assess proposals for disposal of these wastes. Whilst it is not the intention of West Sussex to preclude the granting of planning permission for any type of waste treatment/disposal land use, the Plan adopts a proportional approach to the identification of strategic waste sites. The amounts of hazardous and low level radioactive waste arising in the Plan area is very small and these wastes are currently being appropriately handled at sites both within the Plan area and further afield. The Plan includes policies to enable further facilities to be developed if and when required whilst also reflecting the fact that such facilities are likely to be scaled at a regional level. In line with the aspiration to achieve net-self sufficiency, the wording at the end of W7 aims to ensure that where a new facility is required it is able to handle a large proportion of the hazardous/low level radioactive waste arising in West Sussex. If some of the inputs to such a new facility are imported from outside the Plan area there is no indication that this will be an issue at the planning application stage.

It is not clear from the representation whether you consider the Plan to be unsound on the basis that it excludes 'criteria on which proposals for waste outside of the Plan area should be determined'. If this is the case, I would really appreciate signposting towards the relevant national policy or guidance which includes reference to the need to include such an approach.

The Plan will be submitted on (or around) 27 March 2013. I hope we are able to move towards a mutual understanding of our respective positions on this issue over the coming weeks, through appropriate dialogue, and perhaps we will be able to put this issue to rest prior to the hearings in July.

Many Thanks

Alethea

Alethea Evans | Senior Minerals and Waste Planner, West Sussex County Council | Location: Northleigh, County

Hall, Chichester, PO19 1QT

Internal: 77549 | External: 01243 777549 | E-mail: [email protected]

Minutes of Meetings Meeting between officers from Bedfordshire, Northants, Milton Keynes and Buckinghamshire – Thursday 26th April 2012

Attendees:

Roy Romans, MW Team Leader Central Bedfordshire Council (CBC) Lester Hannington, Principal MW Officer – policy CBC Susan Marsh, Principal MW Officer – policy and DM CBC Tom Podd, senior policy planning officer Milton Keynes Council Laura Jones, planning officer, Northamptonshire CC

Apologies:

Graham Lydiard, Buckinghamshire CC

Purpose of Meeting

SEM said that the meeting had partly been set up because of the Duty to Co- operate set out in the Localism Act and now the NPPF. However, CBC were thinking of setting up such meetings even before then as they were conscious that whilst they fully participate with authorities in what was the East of England Region (both the Waste Technical Advisory Body and the Aggregates Working Party) they are on the edge of that region and abutting both the SE Region and Midlands. It would be helpful to share information to mutual benefit.

How minerals and waste Is dealt with at the different authorities

Bedfordshire

RR said that a shared service had been provided for the last 3 years. This was for Development Management (DM) between CBC and Bedford Borough Council and for M&W policy with Luton Borough Council as well.

LH said that we had been working on the M&W LDF since 2009. The original intention had been to produce 4 separate plans – separate minerals and waste core strategies and site allocations documents. However, in 2009 it was decided to merge these together and to produce a single document.

The production of a single Plan reduced costs and the amount of consultation etc. The councils also have to go through the committee processes of the 3 councils and this was a significant issue even with one plan and would have been extremely difficult with 4.

CBC, who operate the shared service, have both policy and DM M&W officers. However, increasingly, officers are gaining experience of both aspects. This provides for both flexible working and will allow officers to gain experience and assist their careers.

Milton Keynes

TP said he was responsible for waste policy and Fiona ? was responsible for minerals policy. They also have a more general policy role.

Any M&W applications were dealt with by the general DM team. There are 8 in the team.

No dedicated M&W team. There had been discussions with BucksCC about officers there undertaking M&W work on MKs behalf but this did not progress.

Northants

NCC is about to start a partial review of their M&W DPDs.

NCC undertake M&W policy work for Rutland council.

Separate policy and DM teams.

Mark Chant is Head of Planning Services Phil Watson is Head of DM Shari MacDonald is head of policy

Update on progress on MW Plans

CBC/BBC/Luton – about to undertake a focused change consultation on changes following consultation on soundness and as a result of the NPPF. This is scheduled early June. Submission is anticipated in August.

There will be a change to the text on radioactive waste. Published research has shown that there is only 3.5kg of such waste arsing in the Bedfordshire area each year. No sites have been put forward for managing such waste. The MPAs are not justified in putting forward a site on the basis of such small amounts of waste. Should an application be received it will be dealt on the basis of national Policy. (RR suggested forwarding the link to the paper to NCC)

NCC – DPDs adopted in 2011. About to undertake a partial review.

Kings Cliffe – proposed extension of time for landfill of Low Level radioactive waste until 2026 – just accepted for Examination by the Major Infrastructure Unit.

The review of the DPDs will cover the SA/waste forecasts and minerals to get more accurate and realistic figures (due to demise of RSS). No intention to review individual sites. Likely to be lower figures and sites identified will ‘last longer’ . Plan period to be extended from 2026 to 2031.

Milton Keynes – has an adopted Waste DPD up to 2026. Thinking about a review. Working on an Issues and Options paper for minerals. Minerals Local Plan was adopted in 2006. The landbank remaining is not adequate and need more sites.

NCC has no enforcement/ monitoring officer. Have been advertising for one and have had 7 applicants. Three to be interviewed.

Waste Date/monitoring

Difficult to obtain reliable data. EA data is at a regional level as used to feed into the national and European level. This may improve as the EA collect information electronically.

LH – it would be useful to know what MW sites there are in MK and NCC – the information is needed to plan new facilities and to ensure that they are not too close together. i.e to take note of other facilities close to boundary of Plan area. LH will contact authorities separately on this.

Bucks CC have now determined the Calvert EfW application.

Minerals Issues

RR There is the OFT investigation into local aggregates supply. Lafarge and Tarmac are potentially merging making a very large company. There is perceived, by some, to be a too cosy relationship between the MPAs and mineral companies on the AWPs. Information was provided to the recent Office of Fair Trading study by the independent marketing company BDS - they did not contact AWPs. They say that there may be difficulties for smaller minerals companies getting into the market as extensions to sites are allowed. LPAs may be contacted as part of this investigation.

Any Other Business

LH We need to agree what the outputs are going to be from the joint meetings. i.e. exchange of information and discussion on specific issues between authorities.

Other authorities will need to do this as well. It will be important when plans are reviewed.

It was agreed that meetings should be arranged about every 3 months initially but that they could be postponed if there was inadequate business to discuss . It was agreed that the Central Beds offices at Chicksands provided a central location to meet rather than rotate venues . Next meeting would be arranged for the end of July/early August.

Northamptonshire County Council Minerals and Waste Development Planning Update report

3 September 2012

MWDF Partial Review

Our Partial Review will bring together what are currently four separate DPDs (Core Strategy, Waste site-specific, Minerals site-specific and DC policies) into one combined plan and extend the plan period to 2031. We have consulted on the scope of the Review of the MWDF. This included what we propose to update and our initial considerations on this. The consultation on the document ‘MWDF Partial Review: Consultation on the Way Forward’ ended at 5pm on 23 August 2012. At the same time we invited comments on our Local Aggregates Assessment and a Local Assessment of Waste Management Needs, as well as on a new Statement of Community Involvement.

Responses to the ‘Way Forward’ consultation

In total we had 28 responses from respondents. The largest number of responses received (mostly from the Minerals Industry and other Councils) was in relation to our proposal to reduce our aggregate apportionment by using the ten year sales figures. Most of these responses objected to the decrease in apportionment and all those that objected requested that further discussions should take place over this figure at the RAWP (scheduled for September).

The issue of LLW divided the respondents. Northamptonshire’s aim of seeking to make best use of the available capacity at the East Midlands Resource Management Facility and treating LLW at locations nearer to its source was supported and objected to in equal measure. Most of the other representations generally either fully supported the proposed approach or generally agreed with it but suggested further matters or wording that an amended policy could include.

Moving forward

We are now working on putting together a draft plan which we are aiming to take to Cabinet in November 2012. This document will be accompanied by the required Sustainability Appraisal Environment Report (although this is not required to go to Cabinet). We plan to consult on this Draft Minerals and Waste Local Plan (MWLP) and associated documents no later than mid January 2013.

Duty to Co-operate

We are continuing to make representations on other authority’s plans at key stages. These representations are generally around hazardous waste and low level radioactive waste. Cumbria County Council is also following a similar approach.

However as we have commenced the Partial Review the boot is now on the other foot and we will be required to show compliance with the Duty to Co-operate. As part of the consultation on the Partial Review we have written to all county minerals and waste planning authorities, and a significant number of unitary authorities and national parks. We notified them of the Review, its context and pointed them towards those issues that they may have views on. We basically asked: are our approaches making assumptions that could impact on their area that they are currently not proposing to plan for? This initial contact is intended to start the process of engagement. Note of meeting held with Northamptonshire County Council, 7th August 2012

Present: Mark Chant (MC) Northamptonshire County Council Laura Burton (LB) Northamptonshire County Council Sally Gill (SG) Nottinghamshire County Council Suzanne Moody (SM) Nottinghamshire County Council Sarah Watson (SW) Nottingham City Council

Waste policy issues

SG and SM outlined current progress with the Waste Core Strategy and that officers were in the process of preparing a schedule of proposed changes in response to representations and to reflect publication of the NPPF. Further to Northamptonshire’s representations on hazardous and radioactive waste, MC explained that due to Northamptonshire’s position, having the only general hazardous waste landfill serving the East Midlands and East of England, they are keen to see that other WPAs take account of this within their own local plans. Whilst understanding Nottinghamshire’s difficulty in terms of geological suitability for hazardous waste disposal, Northamptonshire nevertheless feel it is appropriate for the Waste Core Strategy to set out its approach to hazardous waste disposal. SG and SM acknowledged this and suggested that it might be possible to draft appropriate wording changes to Policy WCS4, and its supporting text, in order to show how any proposal for hazardous waste would be considered. However, this would need to make clear the likely physical constraints and therefore very limited circumstances in which any proposal might come forward.

SM also highlighted that significant quantities of hazardous waste are imported to facilities within Nottinghamshire and Nottingham for treatment and it is considered that this helps to offset the reliance on other areas for disposal capacity. The Waste Core Strategy would therefore continue to make provision for this treatment capacity in line with the strategic objective to manage the equivalent of the amount of waste arising within the plan area. This is already referred to in the supporting text but it was agreed that this relationship would be further highlighted within the text and a related change would be suggested to the Policy WCS6 supporting text to clarify that this policy applies to treatment facilities for all types of waste, including hazardous. SM agreed to prepare draft wording and send this through to Northamptonshire in advance for comment.

Although it was agreed that detailed geological surveys were unnecessary for this Waste Core Strategy, it was noted that more detailed geological assessment would be necessary for the subsequent site-specific policies if there was an identified need for dedicated hazardous waste disposal capacity within Nottinghamshire.

In terms of specific hazardous waste disposal capacity within Northamptonshire, MC and LB outlined that the King’s Cliffe site has planning permission until 2013 and is approved to accept low level radioactive waste as well as general hazardous waste. Northamptonshire are currently dealing with three planning applications to extend the time period for the hazardous landfill area, the low level radioactive waste cell and the soil treatment facility to 2016. The operator has also applied to the National Infrastructure Commission for further clay extraction on another part of the site for the purpose of hazardous and low level radioactive waste disposal until 2026. This includes an undertaking form the operator that if it is clear that the site will not be filled by 2026 then operations will cease and the site will be restored. However MC also highlighted that there is a possibility the operator could then purchase adjoining land to create additional void space but this is uncertain.

Northamptonshire’s development management policies consider facility catchment areas on a national, regional, sub-regional and local basis.

Minerals policy issues

MC explained that they are currently carrying out a partial review of their Minerals and Waste Development Framework and are therefore in the process of contacting other minerals and waste planning authorities. Following publication of the NPPF they had originally been concerned that a 10 year average for sand and gravel would be too low but the market has declined significantly and they are now looking at a 10 year sales average after all. MC commented that Northants seemed unlikely to be a key player for sand and gravel in future as there was little industry interest. However some is exported to Bedfordshire. For crushed rock they are likely to stick with the regional review figures rather than a 10 year average as the market here has greater potential.

Minerals and Waste Planning

Duty to Co-operate Meeting between Oxfordshire County Council and Northamptonshire County Council and Milton Keynes Council

24 July 2013, 2.00pm at County Hall, Northampton

AGENDA

1. Introductions

2. Current positions on and programmes for minerals and waste plans in Oxfordshire, Northamptonshire and Milton Keynes (minerals only)

3. Local Aggregate Assessments a) Oxfordshire – draft LAA June 2013 (attached) b) Northamptonshire – LAA January 2013 c) Milton Keynes – LAA Draft Methodology May 2013

4. Specific cross boundary issues on aggregate supply

5. Potential future issues for minerals planning in the three authorities

6. Waste movements between Oxfordshire and Northamptonshire (attached) – current movements and prospect of / potential for continuation to 2030; and any site related issues

7. Options and policy for future waste management and cross boundary issues arising; including Northamptonshire CC’s representation on the Oxfordshire Minerals and Waste Core Strategy (Policy W8)

8. Potential future issues for waste planning in the two authorities

9. Need / scope for joint-working arrangements and future meetings

10. Any other issues

PHD 18.07 2013 West Northamptonshire Joint Planning Unit Duty to Co-operate Meeting - Notes Thursday, 27 September 2012

Location: Holding Room, Guildhall Time From & To: 9.45am to 11.25am

Meeting To discuss the duty to co-operate in relation to the West Northamptonshire Objective: Joint Core Strategy including co-operation to date, the forthcoming Examination into the Joint Core Strategy and future co-operation arrangements.

Attend: David Atkinson [DA] West Northants Joint Planning Unit Claire Berry [CB] West Northants Joint Planning Unit Dave Hemmett DH] West Northants Joint Planning Unit Faye Tew [FT] West Northants Joint Planning Unit Richard Wood [RW] Daventry District Council Paul Lewin [PL] Northampton Borough Council Laura Davidson [LD] Northamptonshire County Council Andy D’Arcy [AD] South Northamptonshire Council Julie King [JK] Cherwell District Council Sarah Fisher [SF] Rugby Borough Council Tony Perks [TP] Stratford upon Avon District Council Bob Wilson [BW] Milton Keynes Council Andrew Longley [AL] North Northamptonshire Joint Planning Unit Simon James [SJ] North Northamptonshire Joint Planning Unit Simon Richardson [SR] Kettering Borough Council Sue Bateman [SB] Borough Council of Wellingborough Lesley Aspinall [LA] Harborough District Council

Apologies: Amanda Jacobs [AJ] Oxfordshire County Council Andy Kirkham [AK] Aylesbury Vale District Council Lonek Wojtulewicz [LJ] Leicestershire County Council Jasbir Kaur [JB] Warwickshire County Council

Distribute: To all

Item Discussion Notes Actions

1. Introductions

1.1 DA welcomed all to the meeting and introductions were given around the table. 1.2 DA explained the format of the meeting.

2. Purpose of the Meeting

2.1 It was noted that the national context, including the National Planning Policy Framework, the 2011 Localism Act and all associated Regulations including the statutory Duty to Co-operate requiring close working with neighbouring Councils and prescribed bodies, needs to be adhered to in the preparation of the West Northamptonshire Joint Core Strategy.

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2.2 DA explained that the purpose of this meeting is to discuss the effectiveness of the co-operation undertaken regarding the West Northamptonshire Joint Core Strategy to date and to discuss the forthcoming public examination of the Joint Core Strategy. 2.3 Future arrangements for co-operation will also be considered, including those that relate to the other plans now under preparation in West Northamptonshire in addition to the JCS, so we can continue to operate in the most advantageous and co-operative way for us all. All other Plans currently under preparation to which this approach will apply are set out in the West Northamptonshire Local Development Scheme, June 2012.

3. WNJPU Work Programme Update

3.1 A copy of the West Northamptonshire Local Development Scheme Timetable was distributed for information. 3.2 CB explained that the West Northamptonshire Joint Strategic Planning Committee was established in 2008 through statutory instrument. The Joint Committee is made up of elected Councillors from Daventry District, Northampton Borough, South Northamptonshire and Northamptonshire County Councils and observers from West Northamptonshire Development Corporation, the Borough Council of Wellingborough and a Northampton Labour Councillor, to oversee plan making in West Northamptonshire. 3.3 The primary focus of the Committee work has been the preparation of the Joint Core Strategy for West Northamptonshire. 3.4 In 2007, an Issues and Options Discussion Paper was produced. Further evidence work was undertaken and in 2009, the Emergent Joint Core Strategy was produced and went out to public consultation. 3.5 A huge response was received to the ECS public consultation. With significant opposition to the scale of development and the location of some of the preferred growth options. 3.6 In 2011, the Pre Submission Joint Core Strategy was produced. This included revised housing numbers due to the deliverability of the RSS housing numbers in the Plan Period (up to 2026). 3.7 Following on from the public consultation on the Pre-Submission JCS, Significant and Minor Proposed Changes were prepared. These Proposed Changes were subject to public consultation for six weeks, which closed yesterday (26 September 2012). 3.8 CB noted that as the consultation had only closed yesterday, today’s meeting would not include any reflection of the comments received from the Proposed Changes consultation. 3.9 It is planned that the examination of the JCS will take place in Spring 2013. Adoption of the final plan is scheduled for Autumn 2013.

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FINAL NOTES - APPROVED West Northamptonshire Joint Planning Unit Duty to Co-operate Meeting - Notes Thursday, 27 September 2012

3.10 Alongside the JCS, the WNJPU are working with the Partner Councils of Daventry District, Northampton Borough and South Northamptonshire on a number of the other Local Plan documents that are set out in the West Northamptonshire Local Development Scheme, June 2012. 3.11 Preparation of the separate locality specific Settlement and Countryside Local Plans for Daventry and South Northamptonshire has started. Preparation of the Northampton Related Development Area Local Plan is also now underway. 3.12 The WNJPU are also assisting the three Partner Councils with the preparation of their CIL Charging Schedules and the associated viability assessment to support this work is underway. 3.13 CB noted that it is the intention of the WNJPU to prepare a compliance statement on the Duty to Co-operate for the JCS Examination Inspector.

4. Co-operation to Date

4.1 CB gave a presentation regarding co-operation to date. 4.2 It was noted that there were cross boundary issues regarding Minerals and Waste. There were also cross boundary issues identified regarding the movement of aggregates. 4.3 AL queried the timescale of the JCS. If the RSS is still in place, it is still the intention to submit in December 2012? DA responded that the WNJPU are keeping a close eye on the current Milton Keynes examination, as they are having similar issues. There has been lots of debate at the Milton Keynes examination. It was noted that it is understood that practical solutions are being sought and entertained by the Inspector. The report on this is now awaited. 4.4 BW informed the group that the Inspector had made it clear that the Milton Keynes Core Strategy housing numbers were an issue. BW explained that a robust case had been put forward making it clear that the scale of housing stated in the RSS could not be delivered. BW updated the meeting on the expected next stages of the MK CS process. 4.5 DH explained the housing provision in the WNJCS to the meeting, noting that there is a dichotomy between the RSS housing numbers and a realistic/ deliverable plan. 4.6 JK enquired how the WNJPU envisaged the co-operation between the neighbouring authorities would be presented to the Inspector. CB explained that duty to co-operate compliance statements were now commonplace and that she envisaged producing such a statement that will include maps showing the neighbouring authorities to West Northamptonshire, summarising the key issues and explaining how those issues have been addressed in the JCS. 4.7 SJ stated that the Evidence Base played a key role in demonstrating co-operation, including regarding retail and transport.

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FINAL NOTES - APPROVED West Northamptonshire Joint Planning Unit Duty to Co-operate Meeting - Notes Thursday, 27 September 2012

5. Future Co-operation Arrangements

5.1 BW mentioned that the SEMLEP Planners Meeting had discussed BW sharing evidence collection. BW agreed to circulate Milton Keynes’ work on this. 5.2 CB asked if people preferred to carry on with the current levels and types of communication, e.g. telephone calls, emails and occasional meetings. What sort of relationship do people wish to have? 5.3 RW suggested that multi-purpose meetings could be held once or twice a year, especially including the NNJPU to cover the other Local Plans set out in the West Northamptonshire LDS. 5.4 AL suggested that it was a good idea to update people by phone. We need to ensure that contact details are up to date. 5.5 JK suggested that due to logistics and time management, it would be best to contact people, as needed, for more focused discussions. JK stated that this meeting had provided a good opportunity to meet people from neighbouring authorities. 5.6 CB stated that the WNJPU would put a contact list together and CB circulate to all. 5.7 PL asked what the long term plan was for working together with neighbouring authorities once the JCS has been adopted. Could work be done to complement each other? Once the RSS has gone and now we have the NPPF, how do we co-ordinate working together? 5.8 BW stated that once the RSS eventually disappears, SEMLEP (which includes Milton Keynes Council) are likely to look to make their main focus of attention infrastructure rather than housing numbers. BW suggested that work should carry on in the SEMLEP area, including the sharing of information and agreeing what issues to concentrate on. 5.9 PL stated that Northampton is a growth area and is keen to create its own identity. The geography of the country is changing. 5.10 TP stated that evidence gathering is a good idea. We need to look at who can provide this information. Growth can be shared across certain areas if that is agreed to be a good idea. DH noted that a lot of areas, especially rural ones, will not want to promote growth. DA noted that the New Homes Bonus will attract growth. 5.11 CB stated that we are still at the early stages and are still trying to identify issues and the way forward. 5.12 TP stated that if evidence was procured as a region, whatever that “region” is, it was a good way to promote joined-up working. 5.13 CB noted that there are already a variety of existing identified geographies that indicate a range of issues requiring co-operation e.g. housing market areas, travel to work areas and retail catchments areas. Obviously these may change over time but they provide a useful starting point. 5.14 DH stated that there will always be external factors that have an impact, including the retention of Business Rates. If the job numbers change then so do the housing numbers. The longer term consequences need to be looked at. Gaps need to be filled. J:\JPU\21 Duty to Co-Operate\Duty to Co-operate Meeting\12 09 27 FINAL Duty to Cooperate Meeting Notes.doc 4

FINAL NOTES - APPROVED West Northamptonshire Joint Planning Unit Duty to Co-operate Meeting - Notes Thursday, 27 September 2012

5.15 AL stated that the LEPs have a purely economic focus and are not focused on planning matters in the traditional sense. We need to look at how we can work with the LEPs to help us to deliver planning. 5.16 CB noted that LEPs and LNPs are likely to have an influential role but this is currently heavily constrained by resources. 5.17 DH suggested it would be beneficial to look at the Infrastructure Funding Gap together. Could funding from the LEPs be available for this? This needs to be looked into as the opportunity is there. 5.18 BW informed the group that Milton Keynes Council are trying to persuade SEMLEP that bigger infrastructure is needed rather than small fixes. There is a big gap in funding. This gap cannot be completely covered but can be reduced until the economy is healthier.

6. Summary of Actions

6.1 CB explained that we need to explore the collection of evidence that we all have. There is an opportunity to explore filling the regional need for sub-national planning. 6.2 DA noted that there is the opportunity to explore the sharing of specialist information and planning resources and the need to explore which districts want to develop/grow. There is the need to develop working relationships with the LEPs, ensuring that economic reality is maintained. 6.3 BW agreed to keep the group up to date with progress on the Milton BW Keynes Examination process. 6.4 A list of contacts for this group will be circulated with the notes. FT 6.5 CB suggested that we carry on with how we have been communicating and co-operating to date as everyone seems content with this approach. Meetings will only then take place as and when required to discuss detailed issues. DA suggested that it would be useful to meet at least once a year. 6.6 TP stated that it would be helpful if the meetings were more topic driven. 6.7 AL stated that there is a need to look at the needs of other areas. A map could be produced to show progress on local plans in other areas. CB informed the group that WNJPU had done some CB research that could be used to prepare this information and that this would be circulated to this group. 6.8 LA informed the group that Harborough District Council were looking at reviewing the housing allocations in their Core Strategy. 6.9 JK suggested it was useful to see a wider picture of the housing/job numbers forecast and population figures.

7. Any Other Business

7.1 There was no other business. 7.2 DA closed the meeting and thanked everyone for attending.

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FINAL NOTES - APPROVED West Northamptonshire Joint Planning Unit Duty to Co-operate Meeting - Notes Thursday, 27 September 2012

Summary of Agreed Actions 5.1 Circulate information from SEMLEP Planners Forum regarding BW sharing collection of evidence, Milton Keynes Council’s work on this, the evidence that Milton Keynes have and what is still needed. 5.6 & Put a contact list from this meeting together and circulate to all. CB/FT 6.4 6.3 Keep the group up to date with progress on the Milton Keynes BW Examination process. 6.7 Produce a map to show progress on local plans in other areas CB and circulate to this group.

Definition of Acronyms JCS Joint Core Strategy WNJPU West Northamptonshire Joint Planning Unit ECS Emergent Core Strategy RSS Regional Spatial Strategy CIL Community Infrastructure Levy MKCS Milton Keynes Core Strategy WNJCS West Northamptonshire Joint Core Strategy SEMLEP South East Midlands Local Enterprise Partnership NNJPU North Northants Joint Planning Unit LDS Local Development Scheme NPPF National Planning Policy Framework LEP Local Enterprise Partnership LNP Local Nature Partnership

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FINAL NOTES - APPROVED East Midlands Strategic Waste Advisory Group Meeting (EMSWAG) Minutes /Actions from meeting held on 20th February 2013 - held at Nottinghamshire County Council, County Hall, Committee Room B

Present:

1. Rob Murfin (RM) Derbyshire County Council (Chair) 2. Bryn Walters (BW) Derbyshire County Council (Technical Lead) 3. Jim Davies (JD) Environment Agency 4. Martyn Hands (MH) Environment Agency (Anglian Region) 5. Laura Burton (LB) Northamptonshire County Council 6. Laura Davidson (LD) Northamptonshire County Council 7. Richard Leonard (RL) Lincolnshire County Council 8. Phil Larter (PL) Leicestershire County Council 9. Paul Statham (PS) Leicester City Council 10. Suzanne Osbourne-James (SOJ) Nottinghamshire County Council 11. Lisa Bell (LBe) Nottinghamshire County Council

1 Introductions / Apologies:

1.1 Apologies received from Neil Richmond (Peak District National Park), Shari MacDonald & Mark Chant (both Northamptonshire County Council)

2 Organisational matters:

2.1 No one offered any objection to RM as EMSWAG Chair. Previous chair Alan Freeman (Lincolnshire CC) had to step down from the role due to ill health. As the group has not met for some time no previous meeting minutes were circulated.

2.2 RM suggested BW as SWAG Technical Lead, this was unanimously supported.

2.3 BW & SOJ agreed to take meeting minutes /actions

3. Minutes of last meeting and matters arising:

3.1 No previous minutes available. No matters arising not covered elsewhere on agenda.

4. Review of Group /Role of EMSWAG:

4.1 The group discussed the circulated documents (the role of EMSWAG & the EMSWAG/ Duty to Cooperate proposed protocol) at some length

4.2 It was broadly agreed that the “Role of EMSWAG” document was a fair reflection of the role of the group. RM pointed to the first bullet point which details NPPF & the Localism Act as particularly pertinent.

1 4.3 BW introduced the EMSWAG Duty to Cooperate Proposed Protocol paper. This is along consistent lines with that drafted by the West Midlands RTAB group, due to be discussed at their next meeting on 12th March 2013. The EA Regionally within the Midlands operates across both West & East & so it was identified that a consistent approach of this type would be particularly helpful for them. MH also reminded the group that he represents the EA’s Anglian Region (which takes in areas such as Lincolnshire and Northamptonshire)

4.4 On the elements of the protocol it was agreed that it was proportionate for the group to meet around 3 times a year. BW to circulate dates. All members have been asked to look at meeting venue options. It was agreed that Nottingham / Leicester is a sensible option. As well as the core group of SWAG members it was suggested by LB that there should also be a wider all-encompassing list of contacts to include the Waste Industry, FoE, WRAP etc. This wider list could form the basis of an extra meeting once a year to enable networking and issue sharing etc. Members agreed to send suggested contacts for this list through to BW.

4.5 PL agreed that Leicestershire would be able to host a SWAG web page on their website. It was agreed that only final, validated documents would be added to this page. The minutes of meetings will only be added once they have been approved as an accurate record of a meeting. This will happen at the subsequent meeting.

4.6 BW suggested that there may need to be a “working documents” page hosted somewhere whereby WPA’s can add and comment on relevant work of the group. This could help to cut down the need for formal meetings whilst also helping to foster the Duty to Cooperate spirit. It was suggested that a Google Group may be able to provide this. BW to look into it before the next meeting

4.7 In terms of future reporting SOJ confirmed that Nottinghamshire and Derbyshire are considering a “live” web based system in the future rather than an AMR. There needs to be agreement on what will be reported as significant new Waste Management Capacity. A standard report format for all WPA’s was suggested

5 Data National Approach

5.1 RM raised the issue of work that he has been doing with the EA nationally on Waste Data & the format of data that WPA’s use. This is to potentially help with the issue of the reliability of waste data and the applicability of the interrogator tool. The argument is that the interrogator was not really designed with cross border waste movements in mind and that the EA needs to be consistent at the National level by providing an agreed and minimum level of reporting along the lines of the former Strategic Waste Management Assessment approach. It was agreed that RM should go back to the EA at a National level to agree a process for the consistent delivery of waste data. Concerns were also raised that currently WPA’s do not necessarily have the capacity, resources or expertise to make use of the existing EA interrogator. The EA confirmed that they would continue to support training for WPA’s on the use of the Waste Data Interrogator and confirmed that take up of previous training sessions had been “patchy” It was suggested that there needs to be a consensus on how to run queries in order to ensure results that are generated are comparable. Derbyshire and Nottinghamshire have agreed to share their methodology used to analyse their respective cross border waste movements

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5.2 It was agreed that it would be beneficial for SWAG and the EA to agree a common methodology so that all WPA’s use data consistently and for local EA areas to support WPAs by validating the basic use of data. This is already happening at an individual level but could be rolled out across all areas. If WPA’s produce data reports to a common template/methodology this will assist the EA in validating

6 EA Update

6.1 In the absence of Martin Everett due to illness BW read out a transcript of an update e-mail sent. No comments raised. Nothing further to add from any EA attendee.

7 AOB

7.1 There was a discussion over the need to improve engagement with LEPs as they do not seem to be generally aware of a planning role. BW suggested that they could be included in a “global” correspondence list of key group stakeholders. All SWAG members agreed to send any key LEP contacts to BW to include in the list. RM agreed that he would raise the engagement issue with D2N2.

7.2 RM proposed that there should be a standing AOB item with regards to “flavour of the month” issues. A key one is a recent resurgence of golf course applications with significant inert waste disposal volumes especially in relation to disposal of construction and demolition waste from tram extension works in Nottinghamshire. This is only likely to increase with large construction projects such as the A453 widening between M1 J24 & Nottingham as well as HS2. Districts often seem unaware of consequences and content of the letter on this from the Chief Planning Officer. There is a lack of legitimate inert disposal applications coming forward as material is being ‘diverted’ to other potentially unauthorised sites. This is likely to mean that the annual C&D disposal figures reported are artificially low

7.3 The number of waste applications that are not being recognised and referred to WPA’s highlights the importance of close cooperation and intelligence sharing amongst the group

8 Date of Next Meeting

8.1 As agreed earlier there will be two further scheduled meetings of the group in the 2013 calendar year with the potential for a wider stakeholder meeting in addition. BW will circulate the two dates and organise venues

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(Circulation date: 27th February 2013)

4 A G E N D A

EAST MIDLANDS STRATEGIC WASTE ADVISORY GROUP MEETING (EMSWAG)

Monday 17th June 2013 14:15 – 15:15 Park Inn Radisson, Mansfield Road, Nottingham, NG5 2BT.

1. Welcome and Introductions – Chair (Rob Murfin)

2. Review & agreement of minutes of previous meeting – 20/02/13 3. Waste Planning Duty to Cooperate arrangements – EA, EMSWAG and WPA commitments 4. Schedule of meetings and reporting arrangements – EMSWAG 5. Any other Business 6. Date of next Meeting

DRAFT East Midlands Aggregates Working Party

MINUTES

11 a.m. Tuesday 11th September 2012

Leicestershire County Council, Glenfield, Leicester

Present:

Lonek Wojtulewicz (Chairman) Leicestershire County Council Nigel Hunt Leicestershire County Council Phil Watson Northamptonshire County Council Mark Chant Northamptonshire County Council Rob Murfin Derbyshire County Council Michelle Spence Derbyshire County Council David Bent Peak District National Park Authority Sally Gill Nottinghamshire County Council Steven Osborne-James Nottinghamshire County Council Richard Leonard Lincolnshire County Council Ken Hobden Mineral Products Association (MPA) Mark Page MPA/Hanson UK Tim Deal MPA/Lafarge Kirsten Hannaford-Hill MPA/Cemex Neil Beards MPA/Tarmac Nigel Weedon British Aggregates Association (BAA)/Longcliffe Jim Davies Environment Agency

1. Apologies/Introductions

Apologies were received from: Keith Bird, MPA/Hanson UK; Mark Plummer, CLG. Introductions were made around the table.

2. Minutes of the last meeting

The minutes of the last meeting held on 8th October 2010, which had been circulated prior to the meeting, were agreed.

3. Matters arising

None.

4. EMAWP Surveys and Reports

Annual Report 2010

The final draft was circulated in May 2012.

2011 Survey

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Returns were complete for Leicestershire/Rutland, Northamptonshire and Nottinghamshire. Derbyshire were still awaiting some returns.

Funding for technical secretaries of Aggregate Working Parties is in the process of being sorted out by CLG. In the meantime, as a fall-back arrangement, Leicestershire have agreed to carry out this role.

5. National Planning Policy Framework and Local Aggregate Assessments

LW introduced the paper that had been circulated on the role of AWPs in the context of NPPF and LAAs.

KH pointed out that the condensing of national guidance in the NPPF has left some gaps to be filled. The intention is that the NPPF be supported by guidance. He understood that guidance is sitting on a Minister’s desk waiting to be signed off. If this is not forthcoming soon, KH suggested that MPA/POS produce its own guidance. RM suggested that a memorandum of understanding could be drawn up indicating how arrangements would work. MS indicated that authorities appear to be doing slightly different things, based on what was said at the recent workshop held by Essex CC.

KH/LW considered that a meeting of the National Coordinating Group should be held to discuss and agree arrangements. ACTION: LW to contact CLG requesting that a NCG meeting be arranged.

MP asked whether local authorities are sufficiently resourced to carry out LAAs on an annual basis. LW indicated that LAAs are being prepared so far to support the preparation of MLPs. He did not consider that annual reviews should be too onerous.

MC indicated that some authorities may wish to push on with their reviews. The NPPF pushes strongly for the 10-year average approach. The Inspector’s recent report on the Buckinghamshire MLP indicated that the LAA could be prepared after the MLP.

KH considered that there should be an annual LAA which would be used as a basis for plan making. The LAA should be put to the AWP for review. This will mean more work for AWPs, who will have a duty to indicate whether they are reasonable, endorsing them or otherwise.

RM felt that it was important that the AWP ensures that everyone plays their fair share.

MS indicated that ‘other local circumstances’ was an important consideration in LAAs, especially where there are growth pressures.

KH indicated that the industry’s objective is to ensure ‘steady and adequate supply’. He did not feel that the AWP’s consideration of LAAs needs to be too precise or scientific. The AWP should have regard to broad indications related to resource availability, changes to production capacity, growth areas and major new infrastructure projects.

RM considered that the Duty to Co-operate issue also needs to be looked at. DCC have had meetings with Yorkshire and Humberside. This needs to be done in a structured way, taking account of the large geographical distances that are often involved. The AWP is the vehicle to deal with such issues on a strategic basis.

PW pointed out that there is an issue with the timescales to undertake such work so that it feeds into individual plan reviews.

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MC considered that Duty to Co-operate is more of a problem if an authority deliberately chooses to under-provide. It should not be such an issue if adequate provision is made.

LW pointed out that the duty lies with the local authority concerned, but that the AWP can help facilitate the matter.

RM considered that local authorities should inform their Members of the updated ‘terms of reference’ for the AWP in due course and obtain their agreement to the proposed arrangements. ACTION: LW to review role of AWP (para.6 of circulated paper) in light of discussions with a view to feeding into consideration of future arrangements by NCG.

KH raised the issue of data confidentiality. Data to inform the preparation of LAAs/MLPs will be required from the minerals industry. Existing procedures regarding use of data collected for AM surveys have been drawn up in order to defend against Freedom of Information requests. The use of this data may not be compatible with data necessary to prepare LAA and ensure soundness of plans. MPA are still looking at the situation. He advised that planning authorities should approach operators regarding the use of data for plan-making. A lot of information is already in the public domain however in the form of information supporting planning applications.

There is concern by the industry that their position is untenable, particularly bearing in mind the current investigation from the Competition Commission and the view that has been expressed that sharing data is anti-competitive,.

6. Competition Commission Investigation

The Competition Commission is carrying out an investigation into the aggregates, cement and ready-mix concrete market.

A revised administrative timetable has recently been published. This indicates further hearings with main parties in December 2012; notification of provisional findings in March/April 2013; and publication of report in December 2013.

KH said MPA and individual operating companies have met with the Competition Commission. None of the Mineral Planning Authorities in the East Midlands have been approached so far.

In the light of the ongoing investigation, KH stressed the importance of the AWP remaining as a technical advisory body.

7. Research

NH mentioned that the 4 projects referred to at the meeting had produced final reports in March/April 2011, namely:

“An evidence based approach to predicting the future supply of aggregate resources in England” by BGS/Capita Symonds/Green Balance.

“Distributing Bulk Aggregates to Future Markets” by Buchannan and Partners with Green Balance.

“Barriers to Underground Mining of Aggregates – an Overview” by Lester Hicks

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“Proposed Toolkit for Developing Aggregate Apportionment Options” by Land Use Consultants in associaition with Green Balance and BGS.

No recent research contracts have been let.

8. MPA Updates

LW suggested that an update of the DPD Key Milestones table be produced, including information on the anticipated production of Local Aggregate Assessments. ACTION: NH to circulate table for MPAs to complete.

Northants: A consultation on the Way Forward for the Partial Review of the Northamptonshire Minerals and Waste Development Framework has been carried out. The review will include rolling forward the plan period to 2031. The consultation includes a draft Local Aggregate Assessment. It is intended to take a draft plan to Cabinet in November and consult on it next year.

MC indicated that he would like some indication from the AWP that the LAA satisfactory. In particular, whether using a 10-year average is a reasonable way forward for Northamptonshire. In response to the consultation exercise, Leicestershire and Lincolnshire had both indicated that the LAA should take into account advice from the AWP. ACTION: LW/NH to consider how AWP should consider responding to LAAs.

Nottinghamshire: Consultation on Issues and Options for the Minerals Local Plan took place earlier in the year. Preferred Options currently being drawn. Consultation on preferred approach anticipated in March 2013. LAA is being drafted – will circulated when complete.

PDNP: LDF Core Strategy (including minerals) was adopted in October 2011.

Derbyshire: Consultation on preferred options anticipated later this year/early next. Joint LAA being prepared with Derby City and Peak Park.

Lincolnshire: Draft Core Strategy and Development Management Policies document being drafted. Consultation anticipated early 2013. Given the growth agenda with the County, looking to meet the sub-regional apportionment agreed for 2005-2020 rather than use the 10-year sales average. An examination of recent housing completions compared to future projections suggests that sand and gravel provision should be at least 10% higher than the 10-year average.

Leicestershire: Minerals Core Strategy and DC Policies adopted in October 2009. Intend to commence review of policies next year. LAA has not yet been prepared.

Rutland: Minerals Core Strategy and DC Policies adopted in October 2010.

9. Industry Updates

NW reported that BAA’s challenge to the aggregates levy is continuing.

NB reported that completion of the Tarmac/Lafarge Joint Venture was ongoing. A remedies package was in the process of being implemented. The JV was likely to happen towards the end of this year.

10. Date of Next Meeting

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LW indicated that this would be dependent on the situation with the NCG and on how it is decided deal with LAAs.

11. Any Other Business

JD advised members that they could contact him if they need any assist from the Environment Agency.

5 DRAFT East Midlands Aggregates Working Party

MINUTES

Monday 4th February 2013

Nottinghamshire County Council, County Hall, West Bridgford

Present:

Lonek Wojtulewicz (Chairman) Leicestershire County Council Nigel Hunt Leicestershire County Council Michelle Spence Derbyshire County Council Richard Stansfield Derbyshire County Council Richard Leonard Lincolnshire County Council Phil Watson Northamptonshire County Council Mark Chant Northamptonshire County Council Sally Gill Nottinghamshire County Council Lisa Bell Nottinghamshire County Council Steve Osborne-James Nottinghamshire County Council David Bent Peak District National Park Authority Ken Hobden Mineral Products Association (MPA) Colin D’Oyley MPA/Breedon Aggregates Kirsten Hannaford-Hill MPA/Cemex Mark Page MPA/Hanson Tim Deal MPA/Lafarge Tarmac Neil Beards MPA/Lafarge Tarmac Nigel Weedon British Aggregate Association (BAA) /Longcliffe

1. Apologies and Introductions

Apologies were received from Keith Bird, MPA/Hanson; Jim Davies, Environment Agency. Introductions were made around the table.

2. Minutes of the last meeting

The minutes of the last meeting held on 11th September 2012, which had been circulated prior to the meeting, were agreed.

3. Matters arising

None.

4. EMAWP Secretary

LW reported that CLG are in the process of appointing secretaries for all the AWPs. As yet there is no indication who will be the EMAWP secretary, but it is understood that a decision is imminent.

5. National Planning Policy Framework and Local Aggregate Assessments

NCG

No minutes are available yet for the meeting held on 30th November 2012 – these are expected from CLG soon. KH reported that, whilst there was some interesting discussion at the meeting, it was more about the role of NCG than AWPs. The meeting was not well attended by AWP Chairmen. CLG are awaiting confirmation of AWP secretaries before setting a date for the next NCG meeting.

CLG Guidance on MASS

This guidance has been published since the last EMAWP meeting.

Nottinghamshire LAA

NH reported that the following AWP members had indicated that they were in agreement with the draft AWP response to Nottinghamshire’s LAA: Leicestershire; Lincolnshire; Tarmac; and Lafarge. However, 2 disagreed (Northamptonshire and Peak Park) hence the need to discuss the matter further at the meeting.

MC felt that the response was overly critical of the use of the 10 year average. Given the state of the housing market, he questioned the need to provide for more than this. DB agreed and queried how long the current economic situation is likely to last.

KH emphasised that ‘adequate’ provision needs to be made. Taking the lead from the NPPF, he felt that the 10-year average should be the starting point. The AWP then need to discuss whether provision should be higher or lower. The 10 year average should be used unless there is good evidence to indicate otherwise. A higher LAA figure does not mean that more has to be produced – this will depend on actual demand. DB pointed out however that this may mean allocating some sites unnecessarily.

CD pointed out that LAAs will be subject to annual review, but NB did not consider that the plan review process was working particularly well. Where the plan period is quite long, the plan may be out of step with provision unless it is subject to regular review. He felt that plans need to ensure that they have some flexibility. LB pointed out that the Nottinghamshire plan would be subject to an ongoing monitoring regime and that a full or partial review could be undertaken if figures changed.

MC considered that the AWP should be considering the strategic position, but wondered how the AWP can deal with this as it needs to look at the overall supply picture in the region. Discussion at the recent East of England AWP concluded that this is difficult to do. LW acknowledged that this first round of LAAs would be messy, but that in the future it should be possible to look at all the LAAs in the region at about the same time.

KH queried what happens if all AWP members are not in agreement. Options are to report the consensus only, or report the differences (and then leave it to PINS or NCG to sort out later).

LW pointed out that where areas are striving for housing growth, this may have been less than past housing achievements. If local planning authorities are planning for such growth, MPAs need to ensure that their MLPs make provision for an adequate supply. He felt that the decision to dismiss housing growth in the Notts LAA was not explained sufficiently.

SOJ felt that there is insufficient evidence to justify a specific figure above the 10 year average. LB pointed out that not many Local Plans within the County had been progressed to adoption yet making it difficult to identify a figure for future housing provision. Any figure that is used needs to be justified based on evidence; it is not possible to just pluck a % increase figure out of the air.

NB felt that there should be sufficient flexibility for the authority to make its own judgement and that it would be better to over than under provide. CD felt that authorities should only deviate from using the 10 year average in exceptional circumstances. KH agreed that authorities need evidence to deviate from the 10 year average; and that the greater the deviation, the greater the evidence required.

MC pointed out that the 2009 apportionment figure is still a material consideration, although this is based on previous growth expectations. LW noted that the 10 year average and RSS figures are similar for Notts but that the 2009 figure was higher. SOJ pointed out that there has always been a mismatch between the apportionment and sales within Notts. In response to a question from LW, AWP members indicated that they did not have confidence in using the 2009 figures. Comments regarding the 2009 apportionment figure could therefore be removed from the AWP response to Notts.

CD considered it was important that production capacity be addressed to ensure that units are not being lost to deliver supply. LB indicated that this would be addressed as part of the preparation of the MLP.

KH felt that the situation regarding the landbank is also a consideration. The level of proposed provision will be less critical if the landbank is high.

LB stated that they needed to agree the LAA as soon as possible in order to enable them to go out for consultation on a draft plan in September. They propose to amend the text to explain certain issues further but do not propose to change the proposed apportionment figures. They could add a section to cover monitoring/review, which would indicate mitigation measures should circumstances change (such as new housing figures). The development of HS2 is also to be recognised in the revised LAA.

In conclusion, it was agreed that use of the 10 year average was acceptable as the basis for determining future provision within Nottinghamshire unless strong evidence emerged to suggest otherwise. In this respect, whilst there are issues regarding future housing growth, it would be acceptable to address this through appropriate monitoring and provisions for plan review. ACTION: NH to redraft response to Nottinghamshire LAA and send it out to AWP members for agreement.

CD felt that the AWP should ensure that all LAAs include certain basic data. MC pointed out that they had used the format adopted in the first LAA (Hampshire), whose approach was endorsed by CLG.

Northamptonshire LAA

MC introduced the Northamptonshire LAA. This has been produced to support the LP review, which is currently out for consultation until 17th March. It is proposed to use the 10 year average for sand and gravel as there was no evidence to suggest a deviation from this. It was not felt that the 10 year average gives enough flexibility regarding crushed rock so that it is proposed to retain the figure in the RSS.

NB pointed out a mathematical error in the calculation of the 10 year average which would mean a reduction in the figure to be used.

NH referred to a statement in the draft plan which suggested that any shortfall between the apportionment and growth would be met by imports. He was concerned that this would put pressure on Leicestershire to meet such shortfalls. MC commented that the plan needs to be deliverable and that he had doubts as to whether a higher sand and gravel figure would be deliverable. He agreed to look again at the statement together with the calculation of the 10 year average. ACTION: comments on Northamptonshire LAA to be forwarded to NH by end of February with a view to the AWP secretary preparing a draft response for AWP members’ comments.

Progress with other LAAs

Derbyshire is preparing a LAA jointly with Peak District NPA. Draft LAA will be out for consultation in February.

Lincolnshire proposes to publish its LAA in March to support consultation on its draft Plan.

Leicestershire is preparing a LAA jointly with Rutland. The draft should be available shortly. Unlike other LAAs in the region, it will focus on monitoring of the authorities’ adopted plans, but will flag up the intention to commence a review of the Leicestershire Minerals Plan.

6. Surveys

2011 Survey

Derbyshire has just finalised their returns.

ACTION: Collated returns and associated information to be forwarded from MPAs to EMAWP Secretary (once appointed) in order for 2011 Annual Report to be produced.

2012 Survey

ACTION: MPAs to send out survey forms to operators a.s.a.p.

7. Competition Commission Investigation

KH reported that MPA have submitted information to the Competition Commission. CC is issuing working papers on various matters.

8. Research

Nothing to report.

9. MPA updates

ACTION: NH to circulate updated DPD Key Milestones table with the minutes.

10. Industry updates

The Lafarge Tarmac JV was completed on 7th January. Certain sites have been divested. Integration of the two companies is still evolving. MQP is still operating as normal until Hanson decide whether to exercise their option to take control of Tarmac’s interest.

11. Any Other Business

KH reported that this year's annual RTPI/MPA conference will be held on 22nd May at Edgbaston. The conference will look at what the initiatives proposed by the Government to streamline the planning and associated permitting systems will mean for minerals planning and considers the implications of these changes for those who are charged with securing the supply of minerals to society.

12. Date of Next Meeting

To be held at the end of April.

ACTION: EMAWP Secretary to canvass dates for meeting at end of April.