East Sussex County Council and Brighton & Hove City Council Waste and Minerals Development Framework Residual Waste from London Study: Draft Report
October 2009
Residual Waste from London Study: Draft Report
Revision Schedule
Rev Date Details Prepared by Reviewed by Approved by
01 02/10/08 Draft 01 AW/MN/JB/RJ/AG AW/MN AW
02 05/10/09 Draft 02 AW/MN/JB/RJ/AG AW/MN AW
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Residual Waste from London Study
Table of Contents
1 Introduction ...... 1 1.1 Background ...... 1 1.2 Structure of This Document ...... 2 2 Regional Policy Review...... 3 3 An Understanding of the Expectations of Key Organisations...... 13 4 The Situation in Counties Neighbouring East Sussex and Brighton & Hove ...... 31 4.1 Introduction...... 31 4.2 Existing and future land disposal capacity ...... 32 4.3 Environment Agency RGN3 Landfill Location ...... 37 4.4 Spatial Relationship Analysis (SRA) ...... 38 4.5 The Situation in Counties Neighbouring East Sussex and Brighton & Hove: Summarising Comments...... 47 5 Land Disposal Capacity in the Strategy Area ...... 48 5.1 Introduction...... 48 5.2 Assessment of ESCC/B&H potential land disposal capacity ...... 49 5.3 Ashdown Brickworks...... 52 5.4 Generic potential land-raising capacity ...... 53 5.5 Land disposal capacity gap analysis...... 54 5.6 Accessibility assessment of potential land disposal sites...... 57 5.7 Industry and associated interested party observations...... 63 5.8 Summary and Conclusions...... 65 6 A critique of the Apportionment Methodology Using Sustainability Appraisal Techniques ...... 67 6.1 Methodology...... 67 6.2 Appraisal ...... 70
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6.3 Summary of sustainability appraisal findings...... 80 6.4 Assessment of the original SA methodology and conclusions...... 81 7 Conclusions...... 85 7.1 Introduction...... 85 7.2 Policy Context...... 85 7.3 Concluding Assessment ...... 85
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1 Introduction
1.1 Background
1.1.1 Policy W3 of the South East Plan 1 requires that waste planning authorities (WPA) in the South East make provision for land disposal capacity for 19.4 million tonnes of waste from London over the period 2006-2025. Policy W3 includes an apportionment of the total amount of London’s waste to the individual South East WPA areas, but notes that the apportionment figures are to be treated as a benchmark to be tested in the preparation of development plan documents. South East Plan Policy W4 requires that WPAs plan for net self-sufficiency in waste management and that, “where appropriate and consistently with Policy W3, capacity should also be provided for: i. waste from London….”
1.1.2 The apportionment tonnage figures set out in Policy W3 are based on an apportionment methodology that was prepared for the South East Regional Assembly and tested at examination in public.
1.1.3 The apportionment methodology is based on the principle that the burden of providing capacity for land disposal of London’s waste should be shared in the South East in accordance with sustainability and practical factors, rather than as has happened historically, on the basis of where capacity exists and the market dictates waste will travel.
1.1.4 The apportionment methodology works on the basis of each WPA area being assessed for its suitability to accommodate land disposal, on the basis of a range of criteria, namely: void space availability; geological suitability; proximity to London; sustainable transport; contracts and patterns of movement and other land use/environmental factors.
1.1.5 The methodology examined the effect of applying different relative weightings to the different criteria. Full details of the apportionment methodology are available in the Jacobs Babtie report Towards a Methodology for the Apportionment of London’s Exported Waste – Final Report (2005).
1.1.6 Apportionment figures allocated to East Sussex and Brighton and Hove in the South East Plan are:
• 2006-2015 1.06 million tonnes
• 2016–2025 0.59 million tonnes.
1 The South East Plan. Regional Spatial Strategy for the South East of England. May 2009. CLG/GOSE.
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1.1.7 The purpose of the studies that are considered in this report is to examine the availability of land disposal capacity to deal with waste from London in the Core Strategy area and the practical implementation of the apportionment methodology, in terms of the way that the waste industry operates now and in the future and the practicalities of waste transportation.
1.1.8 The scope of the study was divided into five discrete tasks as listed below.
• Task 1. Review and understand expectations of regional policy.
• Task 2. Examine expectations of key bodies.
• Task 3. Examine neighbouring counties’ situations.
• Task 4. Examine land disposal capacity in the Core Strategy area.
• Task 5. A critique of the apportionment methodology using sustainability appraisal techniques.
1.2 Structure of This Document
1.2.1 This report is divided into sections that record the methodologies and findings of the separate elements of the study. Section 7 draws together the findings to conclude on the implications of the South East Plan apportionment policy and methodology for East Sussex and Brighton & Hove.
Section 2 Regional Policy Review
Section 3 An Understanding of the Position of Key Organisations
Section 4 The Situation in Counties Neighbouring East Sussex and Brighton & Hove
Section 5 Land Disposal Capacity in the Strategy Area
Section 6 A Critique of the Apportionment Methodology Using Sustainability Appraisal Techniques
Section 7 Conclusions
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2 Regional Policy Review
2.1.1 In order to fully understand the context to the study, a full examination of the relevant documentation was undertaken, including:
• RPG9 – Waste and Minerals (June 2006)
• A Clear Vision for the South East – The South East Plan Core Document (March 2006) (Section D6)
• The Panel Report on the Regional Spatial Strategy for South East of England (August 2007)
• The Secretary of State’s Proposed Changes (July 2008)
• The South East Plan (May 2009)
• Relevant key submissions to the RSS examination in public and the Hampshire Minerals and Waste Development Framework Public Examination Topic Paper1 – London’s Waste
The findings of this examination are documented below.
Regional Planning Guidance for the South East (RPG9) – Waste and Minerals (June 2006)
2.1.2 RPG9 Waste and Minerals was, until May 2009, the adopted Regional Spatial Strategy for waste management. Policy W3 required waste authorities to plan for an equivalent of the amount of waste arising and requiring management within the Region’s boundaries, plus some waste from London, usually limited to landfill.
2.1.3 Policy W4 of RPG9 provided some additional information on the requirement to deal with waste from London, stating that Waste Planning Authorities should plan for net self sufficiency based on the equivalent of the amount of waste arising within their boundaries, plus waste from London where consistent with Policy W3. RPG9 did not contain a numeric apportionment of waste from London to the counties in the South East.
2.1.4 Before adoption, the Waste and Minerals policies were subject to public examination and the Panel Report 2 recommended that further work be done to develop a numerical apportionment of London’s waste to landfill in the South East. The Panel recommended that the apportionment be based on a number of specific criteria, namely:
2 RGP9 – Review of Waste and Minerals, Examination in Public Panel Report, December 2004
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i. Surplus of void space over and above that required to meet the sub-region’s own needs at 2015; ii. Suitability of geology and/or engineering and other land use/environmental factors; iii. Proximity to London; iv. Ability to use sustainable transport modes; v. The availability of and potential for alternative recovery methods.
A Clear Vision for the South East – The South East Plan Core Document (March 2006) (Section D6)
2.1.5 Work to update regional policy for waste and minerals began before work on the development of the South East Plan. Draft strategies were the subject of an Examination in Public (EiP) in November 2004. In June 2006, the Secretary of State issued alterations to RPG9 (as above) for Waste and Minerals. The policies were rolled forward into the draft South East Plan with only minor amendments.
2.1.6 A study to develop a methodology for the apportionment of London’s waste was commissioned by SEERA and the report of the study 3 was published in July 2005. The apportionment methodology was based on weighted criteria, summarised below:
• surplus void space: 25%
• geology/groundwater suitability and other environmental constraints: 37.5%
• proximity to London: 25%
• sustainable transport: 12.5%
2.1.7 Consequently the Draft South East Plan Waste Policies included a new policy W3, which incorporated a numerical apportionment of the amount of waste forecast to be needed to be exported from London.
Table taken from Policy W3 (Draft South East Plan)
Recommended 2006-2015 2016-2025 Total million Apportionment million tonnes million tonnes tonnes %2
Berkshire unitaries 8.5 1.4 0.9 2.2 Buckinghamshire 16.8 2.7 1.7 4.4 East Sussex 8.4 1.4 0.8 2.2
3 Towards a Methodology for Apportionment of London's Exported Waste, Jacobs Babtie for SEERA, July 2005
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Recommended 2006-2015 2016-2025 Total million Apportionment million tonnes million tonnes tonnes %2
Hampshire 8.4 1.4 0.8 2.2 Kent and Medway 12.2 2.0 1.2 3.2 Milton Keynes 10.1 1.6 1.0 2.7 Oxfordshire 17.0 2.7 1.7 4.4 Surrey 8.4 1.4 0.8 2.2 West Sussex 10.1 1.6 1.0 2.6 SE Total 100.0 16.2 10.0 26.2
1 Estimated imports of MSW and C&I in 2005 is 1.76 million tonnes, as set out in RPG9 as amended
2 From ‘Towards a Methodology for Apportionment of London’s Exported Waste’ Jacobs Babtie report, July 2005 p.20
The Panel Report on the Regional Spatial Strategy for South East of England (August 2007)
2.1.8 The draft South East Plan was subject to public examination in 2006/2007. The testing of waste policies in the draft Plan was very limited, given that a partial alteration of RPG9 on this topic had been so recently adopted in June 2006. The most controversial issue was where (rather than how much) provision should be made for London's waste exports.
2.1.9 Several local authorities argued strongly for a reduction in their apportionment level because of the particular circumstances of their area. Those authority areas towards the periphery of the South East region argued, amongst other things, that:
• their transport systems were inadequate to accommodate waste movements from London,
• there was inadequate capacity to accommodate London’s waste;
• for commercial reasons waste would not travel from London to landfill in those areas, and
• it was not practical to introduce an apportionment immediately due to the long lead-in times required for planning for new landfill capacity.
2.1.10 Further details of the principal objections to the apportionment methodology are summarised in Tables 2.1 and 2.2 , at the end of Section 2.
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2.1.11 In the Panel Report, the Inspectors noted the idea of a ripple effect, as expressed by Cory 4, namely that additional capacity provided in these outer areas may in reality accommodate material generated in adjacent inner authority areas, leaving further capacity for the inner authority areas to accept waste from London.
2.1.12 A further point of objection related to deferring the apportionment to allow for the inherently long lead-in times required for planning for new landfill capacity. Waste authorities who supported the deferment option considered it important to take stock of the latest data on London waste landfilled in the South East which was due to be released by the EA during the later stages of the EiP 5.
2.1.13 On this basis there were two main options open to the Inspectors:
• accept a single apportionment (either that in the draft Plan or one of the options put forward in the additional studies undertaken); or
• accept some form of deferment of the apportionment
2.1.14 In making their choice, the Inspectors considered that the final apportionment should fulfil the following criteria.
• Spread the burden to the extent consistent with sustainability considerations
• Be sufficiently challenging in order to influence a direction of travel for the future
• Be transparent and objective, but recognising that it will never be possible to satisfy all parties
• Be deliverable
2.1.15 The Inspectors favoured retaining a single apportionment, for the reasons summarised below.
• A single set of percentages provides a clearer message of the intended direction of travel.
• A single set of figures starting at 2006 has more chance of influencing development plan provisions (which is the stated intention of the policy), so that the testing process can start in this Waste Development Framework (WDF) round.
• There is more opportunity to influence industry planning the earlier the apportionment starts, bearing in mind the long lead times for new sites or major extensions to become operational.
4 Letter from Cory Environmental to Panel Secretary dated 25 th Jan 2007 re Proposed Apportionment of London’s Waste: Comments on additional SEERA Submission on Apportionment Options
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2.1.16 Following the public examination, and taking account of some alterations to the apportionment criteria that were considered and tested at the examination, the Inspectors made the following recommendation in relation to Policy W3:
• Use a single apportionment to allocate London waste exports to WPAs in Policy W3, and use the percentage sub-division between WPAs that results from the sensitivity test of the distribution model which does not include Green Belt as an environmental constraint.
The Secretary of State’s Proposed Changes (July 2008)
2.1.17 Following the Panel Report in August 2007, the Secretary of State published her proposed changes to the South East Plan in July 2008. In relation to Policy W3, the Secretary of State proposed changes to the apportionment of London’s exported waste, as summarised in the tabulated extract from draft Policy W3 below.
2.1.18 The main changes resulted from an acceptance by the Secretary of State of the position adopted by Hampshire, following advice received from SEERA, and the implications of the Hampshire Minerals and Waste Core Strategy.
Policy W3 – Regional Self-sufficiency
2006-2015 2016-2025 Apportionment Million Apportionment Million %2 tonnes %2 tonnes
Berkshire unitaries 9.3 1.12 8.6 0.63 Buckinghamshire 17.6 2.12 16.2 1.18 East Sussex, 8.8 1.06 8.1 0.59 Brighton and Hove Hampshire, Portsmouth, Southampton and 0 0 7.8 0.57 New Forest National Park
Kent and Medway 13.1 1.58 12.1 0.88 Milton Keynes 10.8 1.30 10 0.73 Oxfordshire 18.7 2.26 17.2 1.26 Surrey 11.5 1.39 10.6 0.77 West Sussex 10.2 1.23 9.4 0.69
5 Landfill Report, compiled by the EA from data submitted by licensed landfill site operators on waste arisings from London, February 2007
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2006-2015 2016-2025 Apportionment Million Apportionment Million %2 tonnes %2 tonnes
SE Total 100 12.1 1 100 7.3 3
1 Estimated imports of MSW and C&I from London in 2006 is 1.21 million tonnes (Source: Environment Agency note for Inter Regional Waste Forum, March 2008)
2 From ‘Towards a Methodology for Apportionment of London’s Exported Waste’, Alternative Apportionment Options: Revision for EiP, page 15, option 2f, Jacobs Babtie report, January 2007. For 2006-2015 these have been amended based on advice from SEERA to reflect the Hampshire M&W Core Strategy
3 reduced to reflect Policy W5 diversion targets
The South East Plan. Regional Spatial Strategy for the South East of England. (May 2009).
2.1.19 The apportionment figures in Policy W3 are unchanged from the Secretary of State’s proposed changes (July 2008). However, an addition to the policy text notes that the apportionment figures are a benchmark against which the South East WPAs should test strategy options for inclusion in development plan documents. The policy notes that “ WPAs should use more recent data where this is available in order to assess and plan for capacity .”
Hampshire Minerals and Waste Development Framework Public Examination - Topic Paper 1 – London’s Waste
2.1.20 The Topic Paper identifies the reasons why Policy S3 of Hampshire’s Core Strategy makes no provision for the landfilling of London’s waste and justifies this approach in the context of Policies W3 and W4 of Regional Planning Guidance 9 (RPG9). It argues that the Strategy is in conformity with Policies W3 and W4 of RPG9 because:
• “Hampshire’s approach does not necessarily mean that RPG9 targets will not be delivered as other actors are also involved;
• It is not ‘appropriate’ for Hampshire to provide for the landfilling of London’s waste because:
• Hampshire has insufficient suitable non-hazard landfill opportunities, in the right locations; • accepting untreated waste from London, in the period to 2016, conflicts with the Strategy and places Hampshire’s businesses at a commercial disadvantage; • London’s requirements are unreasonable and unambitious.”
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Hampshire Minerals and Waste Development Framework Public Examination
2.1.21 The Inspector’s report on the Hampshire Minerals and Waste Core Strategy 6 noted that at the time of the examination, the South East Plan was not adopted and the draft London’s waste apportionment figures held little weight.
2.1.22 However, the inspector found that there were serious doubts about the practicality, deliverability and commercial reality of dealing with the apportionment, in the context of a lack of available sites in Hampshire, a shortfall in capacity provision for Hampshire’s own needs and only very small amounts of waste going to landfill in Hampshire from London.
2.1.23 The inspector also commented that a dogmatic approach in pursuing the apportionment figures in these circumstances was likely to result in uncertainty regarding the deliverability of landfill capacity in the region and the implications of Hampshire not meeting apportionment figures in the short term was not significant for the Regional Spatial Strategy.
6 Report on the Examination into the Hampshire Minerals and Waste Core Strategy Development Plan Document. (May 2007). The Planning Inspectorate.
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Table 2.1. Relevant key submissions to the RSS examination in Public Respondent Main points raised
Sub-regional apportionment of London’s waste to East Sussex/Brighton & Hove in Policy W3 is not appropriate given commercial reality, environmental constraints and transport considerations.
Introduction of the apportionment policy in 2006 whilst existing contracts are in place would result in over-provision.
East Sussex County Council The quality of the evidence base should be improved. Brighton & Hove City Council The methodology doesn’t take account of real constraints on the ground, including the lack of potential void-space, environmental constraints and the constrained nature of the road network in East Sussex.
The assumptions used to model the criteria are too simplistic.
The apportionment is flawed because it is not realistic and deliverable, it doesn’t reflect the current situation (the starting point) and it does not deliver sustainability outcomes.
Realism and Delivery Waste won’t travel by road from London to Hampshire and Hampshire won’t be able to provide enough landfill to meet its own needs.
Reflecting the Current Situation It is not realistic to impose apportionment from 2006 as it will take time for actual provision of capacity to be planned and developed. Hampshire County Council Delivering Sustainability Rail-linked void capacity considered to be the primary sustainability driver and the methodology doesn’t allow for an option which prioritises the use of such capacity to be considered.
In addition to the above points, the methodology, and by implication the apportionment, is fundamentally flawed. • The approach relating to distance from London is flawed and is not sophisticated enough. It should use the distance to the main ‘commercially viable’ landfill opportunities. • The methodology takes no account of geological differences in landfill potential. • The balance of weightings is not appropriate. • The criteria do not reflect those proposed by the December 2004 Panel Report. The preferred option should be one that takes account of proximity and environmental constraints. Any model which Kent County Council over-emphasises available landfill void should be discarded. While supporting the principle of maintaining current patterns of movement during the period 2006-2015, Kent County
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Respondent Main points raised
Council doubts the effectiveness of attempting to assign an apportionment during this period. In respect of C&I waste movements there must remain considerable doubt as to the accuracy of the stated figures. The method for the apportionment of London’s waste is unfair and inappropriate for three reasons: 1. It is not compatible with the aim of providing management capacity for a declining amount of waste from London • It fails to recognise the inertia which is inherent in the system (time required to move away from current spatial provision situation) • WPAs facing major shortages of landfill capacity are still being asked to play a significant part in providing capacity for London’s exported waste (practicality and deliverability) Waste Recycling Group Ltd 2. It is not appropriate to plan for the provision of landfill capacity for London’s exported waste based on projections based on a declining rate equal to that applied to the landfill for South East’s own waste • Inadequate provision is being made for landfill capacity to meet London’s planned exports of waste and this situation will be exacerbated in the event of the slippage in the development of new recycling recovery capacity within the capital. 3. It is not appropriate to plan for the provision of landfill capacity for London’s exported waste on the premise that after 2016 new provision will be limited to that needed for the disposal of ‘residues’ only.
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Table 2.2 Main Themes of Objection Considered at EiP Theme EiP Panel Response
The Panel found the modelling approach well founded and transparent, but Realism and deliverability. Waste won’t travel by road beyond sites close supported that concept of the figures being tested at the WDF stage. to London (practical and economic issues). Areas such as East Sussex and Hampshire don’t have sufficient capacity, due to environmental and The Panel advocated the ‘ripple effect’ as a counter to arguments about geological constraints, to dispose of their own waste. waste not travelling to areas towards the periphery of the South East Region. Response favoured a single apportionment, as this approach provides a Deferment. It will take time to move from the current geographical clear policy message, with greater chance of influencing policy (plan pattern of the disposal of London’s waste to a pattern driven by the provision) and industry planning, more quickly. Also the Panel noted that it apportionment methodology. It is not appropriate to apply the would be difficult to set a base date for a current pattern of disposal, as apportionment from 2006. this would be very sensitive to a few major contracts. “The (modelling) work looked comprehensively at a range of relevant Methodology robustness. The apportionment methodology itself, i.e. the criteria, which largely corresponded with those recommended by the last criteria and the way they are modelled, and the evidence base, is not EiP.” The Panel found the modelling approach “well founded and robust. transparent”. Delivering necessary capacity. The policy will result in under-provision Not directly addressed. The report notes that the principle of the amount for the amount of capacity for London’s waste this is required, and will of London’s waste to be apportioned was not an area for discussion at the make it more difficult to secure planning permission for new capacity in EiP. areas where such capacity is more readily available and environmentally and commercially deliverable.
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3 An Understanding of the Expectations of Key Organisations
3.1.1 Interviews with various key organisations, such as local government, waste disposal authorities, waste management operators and industry bodies took place, in order to gather evidence of how they individually see the policy of apportioning London’s waste into the South East working in practice. It was important to take notice of the current situation, and any changes to this that may take place in the future regarding the exportation of waste from London to landfill.
3.1.2 Views on whether there would be a ‘ripple effect’ were also considered significant, the ‘ripple effect’ being the theory that while East Sussex may not take waste directly from London, it may instead take an equivalent amount from immediate neighbouring counties closer to London (i.e. Kent, Surrey, West Sussex), which in turn would actually have received waste directly from London.
3.1.3 The organisations contacted in the course of this study are shown below;
• Greater London Authority (GLA) • London Councils • Local Authority Recycling Advisory Committee (LARAC) • London Waste and Recycling Board • Chartered Institution of Wastes Management (CIWM) • Environmental Services Association (ESA) • Waste Recycling Group • Cory Environmental Services • Western Riverside Waste Authority • West London Waste Authority • South London Waste Partnership • London Borough of Bexley • London Borough of Bromley • Biffa Waste Services • Viridor Waste Management • South East England Regional Assembly (SEERA) • The Environment Agency (EA) • The Government Office for the South East (GOSE) • Veolia Environmental Services
3.1.4 Scott Wilson did not receive responses from The London Boroughs of Bromley and Bexley, and from Cory Environmental Services. CIWM, ESA and LARAC undertook to consult their members, but no response was received. However, it is not considered crucial that these remaining responses be obtained prior to the completion of this element of work, particularly those organisations whose members have been approached directly, where ‘high’ level
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responses were identified as being ‘useful’, but not ‘essential’. The range of responses received is such that it is possible to accurately determine the ‘majority’ view, which would in any event be used to realistically inform the report of which this activity forms a part.
3.1.5 The main views expressed in the course of these interviews are summarised below.
3.1.6 The majority of waste arising within London is exported out of the region, with, in addition to road-borne exports which form the ‘norm’, large amounts of MSW travelling by rail to landfills in Oxfordshire and Buckinghamshire and by barge to landfill in Essex. In addition, the majority of C&I waste is moved by road to the majority of counties surrounding the Capital.
3.1.7 Waste, predominantly MSW, from West London (covering the Boroughs of Richmond, Hounslow, Ealing, Brent, Harrow and Hillingdon) is exported by rail to landfills managed by WRG in Oxfordshire (Sutton Courtenay) and Buckinghamshire (Calvert and Bletchley). Capacity at these landfills is defined as ‘abundant’ and will last for more than 20 years. The rail link makes the movement of waste to these regions economical and competitive.
3.1.8 Waste, predominantly MSW, from Western Riverside (covering Boroughs of Lambeth, Wandsworth, Hammersmith and Fulham and Kensington and Chelsea) is transported by barge via the Thames to a landfill site in Essex (Mucking) managed by Cory Environmental Services. This landfill site is due to close at the end of 2010. However, the Belvedere EfW facility, again managed by Cory, will be accepting the Authorities’ waste from January 2012 onwards. Cory also has other landfills in Essex and Kent.
3.1.9 Waste, predominantly MSW, from the Boroughs of Kingston, Sutton, Merton and Croydon (which together make up the South London Waste Partnership) is managed within the boundaries of the authority grouping. Residual waste is landfilled in Sutton, at Beddington, which is managed by Viridor and has a ‘significant’ remaining capacity.
3.1.10 Responses from the Waste Authorities of Bromley and Bexley have not yet been received. However, from the other opinions sought it seems likely that they will be relatively ‘self sufficient’ in management of residual waste.
3.1.11 Therefore, it may be surmised that a large amount of residual waste requiring landfill from the Southern Boroughs of London is unlikely and therefore improbable that it would find final disposal in East Sussex. This is provided treatment facilities for diversion come on-line in the future as planned.
3.1.12 The main drivers for the movement of waste are the actual availability of landfill void space and fuel costs. Non-inert landfill capacity is scarce, not to say virtually non-existent, in London and the use of more economical methods of transport than road-borne, e.g. rail and waterways, has the potential to make facilities that are further away in other regions very attractive.
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3.1.13 The general opinion expressed by those who were contacted was that waste from London would not travel directly to East Sussex. The main driver for the exportation of waste is the availability of long-term landfill void space which, in practice, is not readily obtainable in East Sussex and Brighton and Hove. A scenario in which waste may theoretical be moved to East Sussex and Brighton and Hove would be if there is/was to be a rail link. Nevertheless, efficient non road-borne transportation infrastructure is unlikely to be developed where there is a lack of existing landfill void space. Planning issues could also prevent the development of a hypothetical ‘rail link’ in the absence of proven receiving landfill capacities.
3.1.14 The ‘ripple effect’ was thought by those questioned to be improbable due to the lack of available landfill void space in East Sussex and Brighton and Hove. Generally, as waste is exported due to the availability of landfill void space in the exporting authority, assumed exports into a County which could not manage its own waste would not be considered appropriate. Currently, waste exported from London to landfills in Oxfordshire and Buckinghamshire is considered most likely to remain in these Counties, as there is ample void space for exports and their own waste.
3.1.15 One view expressed by those who responded was that the ‘ripple effect’ could happen if new waste infrastructure in London is delayed, and the movement of London’s waste to other Counties further out may take place in this scenario. However it was considered that this would most likely be a short term measure, only until the new infrastructure became available. Even so, this would have to follow the underlying principle that the movement of movement of waste would only take place to a recipient County with available landfill void capacity.
3.1.16 Of note, is that subsequent to the conversation with London Councils in September 2008, the London Council’s Transport and Environment Committee released a position statement, Borough Priorities for the Review of the Mayor’s Municipal Waste Management Strategy (MMWMS) 7 in December 2008. The Officer responsible for this work was consulted by Scott Wilson previously for this report. This document outlines the differences in approach, content and focus that the Office of the Mayor would like to see in the revised strategy.
3.1.17 Concerning waste growth, the document states in paragraph 13:
‘London Councils would like the revision of the waste strategy to look closely at the waste growth trajectory and review the GLA’s assumptions in the light of more up to date data which suggests that the total amount of municipal waste produced by London seems to be on a downward trend 8. London Councils wants to see a strategy that moves London further towards a reduction in the amount of waste generated for collection and management. This has an obvious impact on apportionment, land requirements and numbers of facilities to be provided’.
3.1.18 For the purposes of this report, the above statement is taken to mean that while the London Councils view the principle of apportionment appropriate, they wish to have access to a more
7http://www.londoncouncils.gov.uk/London%20Councils/081029SummaryandBackgroundFINAL.pdf
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current data-set before making strategic decisions. This is considered applicable for this report, as again, valid data-sets are required in order to determine appropriate land disposal capacity allocations. Further views on this issue can be found in Appendix 1, paragraphs 39 – 40, of the London Councils’ position statement document.
3.1.19 Concerning regional self sufficiency, facilities and land-take, the Position Statement document states, in paragraph 14:
‘PPS10 requires regional planning bodies to “enable waste to be disposed of in one of the nearest appropriate locations”. However, the London Plan places undue and restrictive emphasis on regional self sufficiency. London Councils would like to see a more explicit tilting of the balance towards ‘proximity’, particularly where the movement of waste and materials can draw on rail and river use’.
3.1.19 Again, for the purposes of this report, the above statement is taken to mean that the London Councils wish to see greater emphasis placed on the realistic cross-regional movement of waste to nearby receiving Councils rather than those more distant, where realistic transfer is unlikely. Further views on this issue can be found in Appendix 1, paragraphs 41 – 49, of the Councils’ Position Statement document.
3.1.20 It is intended that further evidence on the specific plans of the London Boroughs, including details of emerging development plans, will be sought and included in a revision to this study and report.
3.1.21 More recently, the Mayor of London has published a new report on plans for a Greener London 9 The report sets out a programme of environmental policy to be rolled out in a number of policy documents and strategies. A key element of the programme is “Turning London’s waste into an opportunity” (Section 3.3), which notes that London should manage as much of its own waste as practicable within London and should aspire that zero waste goes to landfill outside London. It also places a priority on ceasing the practice of landfilling unsorted waste outside the capital. However, the programme document acknowledges that there will continue to be a need to plan for the transition from current practices of landfilling London’s waste outside London with the regions surrounding London, and that London’s landfill capacity will run out in 2025.
3.1.22 Further, in October 2009, the Mayor of London published the draft replacement London Plan 10 , which includes revised waste management policies. The draft plan includes proposals to work towards zero waste to landfill by 2031 and to reduce the proportion of waste exported from the capital over time, but short term targets for recycling and composting of municipal solid waste and commercial and industrial waste remain broadly the same as those in the adopted plan.
8 GLA Economics research published in July 2008 9 Leading to a Greener London. An environment programme for the capital. July 2009. Mayor of London. 10 The London Plan. Spatial Development Strategy for Greater London. Consultation draft replacement plan. (GLA) October 2009.
Draft Report 16 October 2009
Residual Waste from London Study
London Waste Disposal Authority / Partnership SEERA London Councils
South London Waste Western Riverside Waste West London Waste Question Partnership Authority Authority
1. Do you have existing Yes, with Viridor Yes, with Cory Yes, with WRG for residual n/a or future contracts for Environmental Services and raw MSW (mainly disposal of waste to residual). landfill? 2. Where are the Waste is landfilled within Waste is sent outside of WRG have the contracts for n/a disposal locations? the Authority at Viridor's Authority to Mucking landfill most of the Authorities waste landfill site at Beddington site in Essex by barge. which is landfilled outside of Road in Sutton. An Mucking Landfill is due to the Authority. Waste is moved extension of the landfill close at the end of 2010. In via a rail link in Hendon to has been granted till 2023 the future residual waste will Sutton Courtenay in and a AD plant is being be sent by barge to be Oxfordshire and Calvert and constructed on the site. processed at Cory's Bletchley in Buckinghamshire. Belvedere EfW plant (in the Waste used to be moved to Borough of Bexley) which Brogborough in Bedfordshire becomes operational in Jan but since this closed the waste 2011. Cory are also building goes to Bletchley. Landfill a MRF in the Authority capacity for Calvert is (Wansdworth) which is due expected to last for several to open in 2011, residuals decades. The Authority did from the MRF will go to have plans to build a treatment Belvedere MRF. facility within the Authority however it is possible they may use facilities outside of the planning authority. 3. Do you know how far Waste travels short Waste travels by barge Waste travels from Brent the waste would distances circa. 10 - 20 down the Thames to Cross to Oxfordshire and normally travel? What miles within the boundary Mucking Landfill in Essex. Berkshire. The Authority is in are the drivers for this? of the Partnership. The drivers for this are less the unique position that waste environmental impacts, is able to travel by rail which lesser travel time and makes the movement of waste loading infrastructure at the outside the Authority landfill site. Traditionally economical and competitive. barge movements have The main driver for this is cost been more expensive. By the use of barges the Authority has saved 100,000 lorry movements. 4. Does the waste travel No, by road No by barge (see above) Yes (see above) by rail?
Draft Report 17 October 2009
Residual Waste from London Study
London Waste Disposal Authority / Partnership SEERA London Councils
South London Waste Western Riverside Waste West London Waste Question Partnership Authority Authority
5. Are there any No No. Mucking landfill will No, landfill capacity is conflicts between the close at the end of 2010 and abundant. There are 20+ remaining operational Belvedere EfW will take years left at both sites. life of existing/future waste from Jan 2011. If landfill sites and the there are delays with the likely minimum contract EfW, the waste will be duration for managed via Cory's other hypothetical deliveries landfill sites. of waste? 6. Will progressive It is possible but they No. The Authority has No diversion of MSW away have just put 19 years guaranteed capacity from landfill, resulting in disposal in place. available at Belvedere EfW. reducing residual However there is no fixed tonnages affect the prices or tonnages. attractiveness of possible contracts for London's waste? 7. Can these contracts Yes Yes as landfill and EfW Yes, WRG will accept any allow for continued services will be offered by tonnage. tonnage commitment Cory Environmental. even on a reducing tonnage basis? 8. How will possible Landfill tonnage would Cory are able to landfill WRG will take any waste that problems in delivering remain higher but the waste if there is any delay in results from delays in diversion targets have contract allows for that. the EfW coming on-line. treatment facilities becoming any impact on the above operational. WRG are aware matter? E.g. a delay in that it will take them longer to new facilities becoming fill their landfill sites and would available. therefore be interested in any waste they can competitively process. 9. Will any new / Yes No as the Mucking landfill Yes, although it is unlikely that n/a proposed treatment site is due to close at the treatment plants will be in their plants in your Authority end of 2010. Authority. The landfill void free up more landfill space would be in Oxfordshire void space? and Buckinghamshire.
Draft Report 18 October 2009
Residual Waste from London Study
London Waste Disposal Authority / Partnership SEERA London Councils
South London Waste Western Riverside Waste West London Waste Question Partnership Authority Authority
10. Will residuals from Yes Residuals from the MRF will Unsure at this stage n/a any new treatment go to the Belvedere EfW. plants in your Authority The APC residues from the be landfilled or used as EfW will go to hazardous RDF? landfill and the IBA will be recycled. 11. Do you envisage Yes Yes by using the Belvedere London Waste Authorities are n/a that your Authority will EfW plant in Bexley. not so much driven by LATS be 'self sufficient' in the but by the Mayor's Plan. The disposal of waste in the obligation for 'self sufficiency' future? states that 85% of London's waste must be dealt with in London. In their opinion the driver will change. Borders in this context are a nonsense. In the National Waste Strategy regional 'self sufficiency' has been removed, however it is part of the London Plan. In their opinion the London Plan should / will be revised to make it softer. 12. Do you think waste No No No. Theoretically it could be n/a from your Authority / possible if a rail link was contracts would be provided, but in practice this disposed of to landfill in would never happen. Planning East Sussex? Can you for a rail link is unlikely to be envisage a scenario given and landfill capacity when this would be the would be an issue. case?
Draft Report 19 October 2009
Residual Waste from London Study
London Waste Disposal Authority / Partnership SEERA London Councils
South London Waste Western Riverside Waste West London Waste Question Partnership Authority Authority
13. Do you have any Possibly This will undoubtedly West and North London do not The 'ripple effect' will probably expectation of a 'ripple happen to some degree. cause ‘ripple effect’. Whatever not happen as if a neighbouring effect' caused by the With new infrastructure not waste is delivered into county could not deal with it's apportionment policy? coming on line fast enough Oxfordshire and own waste, it is unlikely to take and landfill capacity Buckinghamshire stays in that waste from London. The dwindling, movement of region as there is ample situation would not be sensible. waste to other Counties capacity at the landfill sites. further out from London may Displacement could happen if take place. This would be a there was no drive to move short term measure only to away from landfill but the tide over till new direction is to divert away from infrastructure to divert waste landfill so this will not be the from landfill becomes case. The South London operational. Waste Partnership it seems will be treating most of their waste in their own Planning Authority, therefore there will not be much residual waste available to cause a ‘ripple effect’. 14. Does your Not sure This entry is from research No answer given . n/a organisation or your not from interviewee. Cory contractors have any has a landfill in Severn Oaks sites in Kent, Surrey or in Kent (Greatness). Cory West Sussex to have put in planning facilitate the 'ripple permission to restore effect'? Laybrook Brickworks Quarry in Thakenham, West Sussex. 15. Do you have any n/a n/a n/a n/a contractual commitments on in- county sites across East Sussex which would otherwise restrict ‘open market’ availability and/or ability to allocate to London?
Draft Report 20 October 2009
Residual Waste from London Study
London Waste Disposal Authority / Partnership SEERA London Councils
South London Waste Western Riverside Waste West London Waste Question Partnership Authority Authority
16. Is likely/actual n/a n/a n/a n/a contract price a possible filter between you choosing between London and ‘local’ MSW contracts, either existing or future contracts? 17. Will the n/a n/a n/a n/a presence/absence of London waste (whether contracted, ‘obliged’, or market driven) have any material impact on your decision or not to develop a new or extend an existing landfill site or associated facility? 18. Does your company n/a n/a n/a Any non compliance with the London Councils did submit pay any attention or RSS must be based on views/representations on the place any importance evidence and not just on methodology used to apportion on the management of political grounds. For example, London’s waste between the London’s waste on the Hampshire had a clear London Authorities. This was to basis of the evidence base for the Core ensure the assumptions and apportionment exercise, Strategy, whereas Milton methodology was robust. For and has it lobbied for Keynes was less clear. example, there was an issue any changes to SEERA will work with Waste with the weighting for rail original/revised Planning Authorities during the transport versus waterways. apportionment activity? preparation of the Core The comments were taken on Strategy to agree the evidence board with the second round of base before EiP. The Core the apportionment exercise for Strategy will need to the revised London Plan. In demonstrate which targets it October 2008 London Councils can actually meet, or how far Transport and Environment towards them it can get. E.g. Committee published a Position there may be evidence to Statement on the Borough demonstrate that national Priorities for the Review of the targets in the National Waste Mayor's Municipal Waste Strategy 2007 could be Management Strategy which achieved, but not quite reach highlights their position on
Draft Report 21 October 2009
Residual Waste from London Study
London Waste Disposal Authority / Partnership SEERA London Councils
South London Waste Western Riverside Waste West London Waste Question Partnership Authority Authority
the higher regional targets. waste growth and regional self Any non-compliance will need sufficiency, facilities and land to be evidence based. There is take amongst other aspects. also the wider issue that http://www.londoncouncils.gov. industry and costs to them will uk/London%20Councils/081029 be the key drivers in where SummaryandBackgroundFINAL London's waste is taken to be .pdf treated / disposed of, irrespective of local policy and allocations in the WMDF.
Draft Report 22 October 2009
Residual Waste from London Study
Waste Management Operators
Question Biffa Viridor Veolia WRG
1. Do you have existing or future Biffa does have contracts for Yes with the South London Waste Veolia has various contracts to Yes with the West London Waste contracts for disposal of waste to London's waste, especially C&I Partnership. handle waste from London. Authority and the North London landfill? waste. Waste Authority. 2. Where are the disposal For disposal it goes to Redhill When Beddingham (Lewes, E. Sussex) Regarding London waste, it is Waste from London is moved from locations? (Surrey), Westmill closes (estimated in March / April 2009), taken to transfer stations and then WRGs rail transfer station in Brent (Hertfordshire), Colnbrook the two nearest non-inert landfills will be exported by roads to sites such as Cross, Hendon. Waste is moved to (Berkshire) or one in Essex. Small Dole (W. Sussex) which is also Pitsea (Essex), Gerrards Cross landfill sites in Sutton Courtenay owned by Viridor. Viridor applied to and Springfield Farm which are (Oxfordshire) and Calvert and WSCC for planning permission (went to both in Buckinghamshire (off the Bletchley (Bucks). C&I waste from April Committee) for an extension of time M40) and SELCHP (South East London is also disposed of to and height at Small Dole. Should Viridor London Combined Heat and Bletchley and travels by road up not be able to fill Small Dole by 2010 Power energy recovery facility). the M1. C&I waste is also with waste from just W. Sussex then we Veolia has merchant facilities delivered to Stewartby (Bucks). may look to export waste from E. Sussex elsewhere but not currently in East There are decades of landfill / Brighton and Hove. (The site already Sussex / Brighton and Hove.. capacity available at Calvert and takes some C&I waste from the Sutton Courtenay landfill sites. Worthing / Brighton area.) Beddington (Croydon) is a large disposal site and has a remaining life of a few years. There is a MBT onsite and permission for an AD on the site. Viridor also has 400,000 tonne capacity EfW about to open at Colnbrook Integrated Waste Management Park (near Heathrow) in conjunction with Grundon. Colnbrook was developed on the basis of contracts for various London Authorities, MSW and C&I (i.e. not purely on the basis of an MSW contract).
Draft Report 23 October 2009
Residual Waste from London Study
Waste Management Operators
Question Biffa Viridor Veolia WRG
3. Do you know how far the waste Commercial viability enforces The distance that the waste will travel is Waste will travel distances once it See above would normally travel? What are the proximity principle. mostly cost related, there's no is on lorries. In principle it could the drivers for this? standardised 'sphere of influence' for a feasibly come to East Sussex if treatment facility or disposal site. The there is void space available and increasing cost of diesel is having an the gate price is right although impact but this varies month to month currently it does not. depending on prices. Waste will travel great distances though for the right price of management / disposal. Cost is also influenced by nearby competitor gate fees, so for Beddingham that means Lidsey (W. Sussex,),Brookhurst Wood (W. Sussex, Biffa), Redhill (Surrey, Biffa), Pebsham (E. Sussex, Biffa) and also potential for Freshfield Lane Brickworks (in W. Sussex).
4. Does the waste travel by rail? No. In terms of feasibility of rail / In terms of Beddingham, distance Yes and by road (C&I waste) - see water movement of waste, the travelled is probably from Brighton in the above. only cost is getting it onto rail / West, from Eastbourne in the East / water, then it is easy to transport North. long distances. So if East Sussex has a rail served landfill site then there is a risk of London sending waste to it. A Biffa site in Lincolnshire has a rail link and Brookhurst Wood (Horsham, West Sussex) has an adjoining railway. Periodically people lobby to connect Brookhurst Wood to the railway to reduce lorry movements. If it were connected then it would be likely to import London's waste .
Draft Report 24 October 2009
Residual Waste from London Study
Waste Management Operators
Question Biffa Viridor Veolia WRG
5. Are there any conflicts Redhill (Surrey) has capacity Current estimated fill date for No there is plenty of landfill between the remaining until 2030 so it is unlikely that Beddingham is March/April 2009.. capacity in Sutton Courtenay in operational life of existing/future Brookhurst Wood will take Regarding the extension to Beddingham Oxfordshire and Calvert and landfill sites and the likely London waste. identified in the Waste Local Plan, the Bletchley in Buckinghamshire. minimum contract duration for EA is likely to have significant concerns hypothetical deliveries of waste? in terms of drainage and also location in the potential South Downs National Park. Viridor has not ruled it out but neither have they submitted any applications. If there was any extension it would only be piecemeal, nothing significant. The permission for Beddingham says it should mainly take E. Sussex / Brighton and Hove waste but there are single figure percentages of imports currently for outside of the plan area.
6. Will progressive diversion of In terms of whether it is possible No, London's contracts will MSW away from landfill, resulting to take London waste, the continue to be attractive. Some in reducing residual tonnages market has been a bit distorted contracts end in 2011 and are affect the attractiveness of by the recent change in the EA short term. It is unlikely that the possible contracts for London's permitting regime. People London region will be 'self waste? wanted to fill up landfill sites sufficient' so there will be some quickly before the new residual waste which requires permitting scheme came in so landfilling. It is difficult to predict they reduced their gate prices the amount of waste that will be for C&I. It can work both ways available. The reducing amount of however. London waste will probably result in WRG taking waste from further afield. 7. Can these contracts allow for Yes. continued tonnage commitment even on a reducing tonnage basis?
Draft Report 25 October 2009
Residual Waste from London Study
Waste Management Operators
Question Biffa Viridor Veolia WRG
8. How will possible problems in WRG will be able to landfill waste delivering diversion targets have that results from delays in new any impact on the above matter? treatment facilities coming on-line. E.g. a delay in new facilities This will obviously come at a cost becoming available. to the Authority. 9. Will any new / proposed n/a treatment plants in your Authority free up more landfill void space? 10. Will residuals from any new n/a treatment plants in your Authority be landfilled or used as RDF?
11. Do you envisage that your In the future they are likely to need n/a Authority will be 'self sufficient' in either merchant facilities or the disposal of waste in the combined facilities linked to the future? MSW contract but to also handle C&I waste because of synergies of those waste streams, which offer economies of scale and extra security for the investment but they are often not popular publicly or politically. For C&I price is very important in determining how it is dealt with but Veolia also prefer to deal with waste close to source so that is also a key factor. In order to move C&I waste management up the hierarchy and away from landfill there needs to be economic 'sticks' which just aren't there yet. Landfill tax goes some way towards it.
The Core Strategy can encourage a shift by avoiding over provision of land disposal but that alone won't be enough, there needs to be strong economic reasons to force the change because otherwise while there is still landfill
Draft Report 26 October 2009
Residual Waste from London Study
Waste Management Operators
Question Biffa Viridor Veolia WRG
(within the plan area or elsewhere) then C&I waste will always find the cheapest option. If the Core Strategy restricts landfill without enabling provision of treatment capacity for C&I then it is likely that the waste would just be transported out of the county to landfill elsewhere, increasing waste miles. RPG9 / RSS is the upper end of what is achievable. The targets in the MSW contract were reasonable at the time but there is now scope to achieve more as evidenced by the fact that rates achieved are already ahead of the predictions. A limiting factor though is that the districts do their own thing, compared to something like Project Integra (Hampshire) where there is integration. 12. Do you think waste from your The role that Viridor see East Sussex In principle waste could feasibly It is possible if there were Authority / contracts would be playing in taking London's waste is all come to East Sussex if there is treatment facilities in East Sussex. disposed of to landfill in East related to the larger question of the void space available and the gate However, there is no spare Sussex? Can you envisage a future objectives of Viridor as a whole, price is right although currently it capacity so this is unlikely to scenario when this would be the they wouldn't view Viridors role in East does not. happen. Waste is only exported case? Sussex in isolation. No Viridor sites in where capacity is available. the plan area currently take London's waste, but Beddington (Croydon) does. Hypothetically if Viridor had a site in the plan area and were seeking permission there would be two different approaches to convince the Inspector. You could either plan to fill it up as quickly as possible or you could husband the void on the basis of potential future gate prices that could be achieved. The preference would depend on the site and the waste operator. With all sites in East and West Sussex, there is so many
Draft Report 27 October 2009
Residual Waste from London Study
Waste Management Operators
Question Biffa Viridor Veolia WRG
constraints that for gaining permission there must be a really clear demonstration of need. Potentially the need for London's waste would also be a factor in addition to local need.
13. Do you have any expectation The idea of the ripple effect isn't In terms of London waste, it's . This could be a possibility. Waste of a 'ripple effect' caused by the very convincing. The waste is understandable the case Hampshire will follow the proximity principle apportionment policy? already going to Surrey. It's not made in the Core Strategy that waste so any waste on the borders of the volumes of waste that would wouldn't travel all that way, however Counties would travel over if the suddenly be new to the market, what about the ripple effect and that facility was closer. This will be so why would patterns suddenly Hampshire could take some of Surrey's driven by fuel costs and the change and generate a ripple waste instead for example. availability of void space, however. when it doesn't currently. In addition there is an increasing capacity being developed in London so exports are more likely to decrease. It seems more of an academic argument than a reflection of reality. There may be a very tiny ripple but it would be hard to quantify.
14. Does your organisation or In terms of current capacity This entry is from research not your contractors have any sites within East Sussex / Brighton from interviewee. WRG have an in Kent, Surrey or West Sussex to and Hove, there is a current EfW and transfer and recycling facilitate the 'ripple effect'? application in for a small plant at Allington in Kent. extension at Pebsham. Pebsham only takes local waste from the plan area because of it's location and it doesn't import. Even if ESCC / B&H planned capacity for London's waste it is unlikely to come.
Draft Report 28 October 2009
Residual Waste from London Study
Waste Management Operators
Question Biffa Viridor Veolia WRG
15. Do you have any contractual No commitments on in-county sites across East Sussex which would otherwise restrict ‘open market’ availability and/or ability to allocate to London? 16. Is likely/actual contract price London waste will always be a possible filter between you attractive to WRG due to the choosing between London and landfill void they have available ‘local’ MSW contracts, either and the rail infrastructure they existing or future contracts? have. This would not affect WRG taking local contracts as there is room for both. 17. Will the presence/absence of It is possible that if an operator Yes it will. It is necessary to London waste (whether was tendering for an MSW understand the dynamics of waste contracted, ‘obliged’, or market contract in London then they in London. In order to develop a driven) have any material impact may transport outside of London site it is important to have on your decision or not to for disposal but if it were Biffa guaranteed waste coming in. An develop a new or extend an tendering then they would important scenario to consider is existing landfill site or associated develop the facilities to treat it in the economies of scale which can facility? London rather than develop sites be had by the Shire Counties in outside of London, although they managing waste from London. may use existing sites outside of London. Commercially, it doesn't make sense to build facilities further away than you need to, it costs money to haul waste so commercial viability enforces the proximity principle.
Draft Report 29 October 2009
Residual Waste from London Study
Waste Management Operators
Question Biffa Viridor Veolia WRG
18. Does your company pay any Viridor were involved in the EiP on the Yes, they have submitted attention or place any importance South East Plan and gave evidence. No representations regarding the on the management of London’s major concerns with the approach. apportionment methodology in the waste on the basis of the Viridor are just looking for more certainty South East plan. This is on-going. apportionment exercise, and has to work with and trying to reduce doubt, WRG would like to know if this it lobbied for any changes to therefore looking for a strong policy study will be published and original/revised apportionment framework to work with so in the available and would like to be activity? absence of local policy in Sussex then informed when this happens. looking to regional.
Draft Report 30 October 2009
Residual Waste from London Study
4 The Situation in Counties Neighbouring East Sussex and Brighton & Hove
4.1 Introduction
4.1.1 The issue of finding capacity for the final disposal of waste from London, largely in the South East and Eastern Regions, is being addressed in waste development plan documents. The concepts of ‘net self sufficiency’ and ‘equivalent amounts of waste’ in the South East Plan suggest a degree of flexibility in waste movements across Waste Planning Authority boundaries.
4.1.2 This section of the report examines if it is feasible for East Sussex and Brighton and Hove to accept waste for disposal from neighbouring authorities in lieu of waste direct from London. For economic reasons, waste from London may only travel to County areas immediately neighbouring London, or to sites directly accessible from the motorway network or those which are directly linked by rail. At the South East Plan examination, the concept of a ‘ripple effect’ was considered, whereby waste from London to be landfilled would be disposed of primarily in areas neighbouring London and this waste would displace some of the waste produced in these neighbouring areas into landfills in adjacent authorities, further away from London. In accordance with this ‘ripple effect’, authorities that are not direct neighbours to London would indirectly accept London’s waste.
4.1.3 In considering whether the RSS apportionment figures can be met in the Strategy area, the real potential for East Sussex and Brighton and Hove to receive the equivalent of its London’s waste apportionment from neighbouring County areas must be examined, rather than a theoretical concept based on numerical modelling. The focus of this element of the study was whether the transportation of waste to landfill in East Sussex from neighbouring counties, in accordance with the ripple effect, is both feasible and sustainable, when compared to the continuation of in-county disposal.
4.1.4 The methodology adopted to test feasibility involved the establishment of an overview of the existing permitted land disposal capacity in the counties surrounding East Sussex (West Sussex, Surrey and Kent). This information was sourced from an examination of the latest versions of the relevant waste local plans and development frameworks, and from published SERTAB data. Spatial analysis and sustainability appraisal techniques were used to question whether the ‘ripple effect’ is likely to be a means by which East Sussex and Brighton and Hove could realistically take waste from neighbouring authorities in lieu of waste from London. Spatial Relationship Analysis using GIS mapping and an SA-based comparative assessment of the disposal scenarios were undertaken. The methodology and findings are described in the following sections.
Draft Report 31 October 2008 Residual Waste from London Study
4.1.5 The principle assumption underlying the Spatial Relationship Analysis exercise is that landfill capacity in the Strategy area and the neighbouring areas (Kent, Surrey and West Sussex) is likely to be restricted in the foreseeable future to existing sites with significant remaining capacity and sites that are allocated in development plans. Therefore, using existing and allocated landfill sites as point destinations for land disposal, a comparative assessment can be undertaken of the transport distances and sustainability issues arising if waste generated in Kent, Surrey and West Sussex were required to be diverted to land disposal in East Sussex due to the apportionment policy being implemented in accordance with the ripple effect.
4.2 Existing and future land disposal capacity
4.2.1 Waste Planning Authorities are in the process of preparing Waste Development Frameworks, which will replace their Waste Local Plans. The Waste Development Frameworks will set out the approach to managing waste and will allocate sites for waste management facilities. These waste management facilities will include landfill sites in the authority area where a need is established. The current and future site allocations for East Sussex and its neighbouring authorities have been examined and from this the locations of existing and future allocated landfill sites has been collected.
4.2.2 Where development plans do not give a complete picture of existing and future allocated landfill capacity, other sources of information have been used. These have included:
• Annual Monitoring Reports– these are produced every year by the County Councils. The most up to date are for the period 2007/2008. • Golder Associates (2004) Waste Management Capacity in the South East – A report to SEERA 11
4.2.3 Capacity estimates for each of the Counties taken from the SEERA Capacity Assessment have been included in this chapter. The capacity estimates in this assessment are based on sites that have planning permission (whether or not they were operational or licensed/permitted).
East Sussex
4.2.4 The Waste Local Plan for East Sussex and Brighton and Hove was adopted in February 2006. The Waste Local Plan identifies two sites in Policy WLP10: Site-Specific Allocations for Waste Disposal to Land. The two sites are Beddingham Landfill Site and Ashdown Brickworks, Bexhill.
4.2.5 The Waste Local Plan identifies sites existing at the time of the plan (February 2006) as Beddingham and Pebsham. The Beddingham landfill site closed in 2009 and any proposal for further capacity at Beddingham is unlikely to receive support from statutory environmental
11 Golder Associated and MEL Research Ltd (2004) Waste Management Capacity in the South East Region – A Report to SEERA
Draft Report 32 October 2008 Residual Waste from London Study
bodies. The Pebsham site also closed in 2009. However, planning permission was granted for a small amount of further capacity.
4.2.6 Other potential specific future sites under the Waste and Minerals Core Strategy 12 (WMCS) and Waste Sites DPD have not yet been identified.
Table 1 - East Sussex Existing and Allocated Landfill Sites and Site Capacity Type Capacity (if stated) Status (if Site stated) Existing Authorised Landfills 13 Beddingham Landfill Site Non-inert Total anticipated landfill void in April 2001 was Site closed in and inert 1,700,000 cubic meters 2009 Capacity estimated to last until 2009 Pebsham Landfill Site Non-inert Remaining capacity estimated at 1,113,000 Existing cubic meters in April 2001. At current rates of filling it was anticipated that the site will be completed in 2008. However, planning permission was recently granted to enable the disposal of non-inert waste in the Northern Quadrant 14 (an additional 490,000m 3) . Allocated Capacity 15 Ashdown Brickworks, Bexhill Non- Potential capacity is under consideration as Allocated in hazardous part of the WMCS preparation process. Policy Potential Future Allocated Capacity 16 Not yet identified in detail. Ashdown Brickworks and other areas of Identified in search are identified in the WMCS (Appendix emerging 5, Map 4) policy
4.2.7 East Sussex County Council and Brighton and Hove City Council have produced a series of Information Papers to support the formation of the Minerals and Waste Development Framework (MWDF). Estimates of existing landfill capacity have been made. Capacity was assumed to exist where there was a high degree of certainty that the capacity would be developed at a particular site. This included planned capacity, which had not yet been commissioned. This information represents the most up to date available data and is summarised in Table 2.
Table 2 - East Sussex and Brighton and Hove Estimated Existing Landfill Capacity Data Source Type Capacity
12 East Sussex and Brighton & Hove Waste and Minerals Core Strategy – Preferred Strategy (Draft for ESCC Cabinet) September 2009. 13 East Sussex and Brighton and Hove Waste Local Plan (2006) Chapter 4: Existing Waste Management in the Plan Area 14 East Sussex County Council (2008) Planning Committee 10 th September 2008 Planning Committee Minutes http://www.eastsussex.gov.uk/NR/rdonlyres/4AC57B83-FD01-4E5C-AD38-80ED5F689CCE/17999/MinsP10Sept2008.pdf [accessed 12.09.08] 15 East Sussex and Brighton and Hove Waste Local Plan 2006 http://wastelocalplanescc.brighton- hove.gov.uk/index.cfm?request=b1146164 [accessed 12.09.08] 16 Information not yet available. East Sussex and Brighton and Hove Waste Core Strategy and Waste Sites DPD have not yet reached Preferred Options stage.
Draft Report 33 October 2008 Residual Waste from London Study
Data Source Type Capacity
Non- MWDF Information Paper 1 17 489,000 tonnes per annum hazardous
West Sussex
4.2.8 The Existing Allocated Landfill capacity for West Sussex is detailed in the 2004 West Sussex Waste Local Plan 2001 – 2016 Revised Deposit Draft. Future Allocated Capacity for the County is set out in the Strategic Waste Site Allocations Development Plan Document (DPD), which is currently at the Preferred Options stage. It is possible that there may be changes to the sites selected between now and the adoption of the Strategic Waste Site Allocations DPD (anticipated Winter 2010). However for the time being the document gives us the best indication of the probable locations of future allocated sites.
Table 3 - West Sussex Existing and Allocated Landfill Sites and Site Capacity (non-inert and non- hazardous landfill only) Type Capacity (if stated) Status (if Site stated) Allocated Capacity 18 Claypit north of Graylands, Non-inert Not stated Not stated Warnham Laybrook Brickworks, Thakeham Non-inert Not stated Not stated Lidsey Landfill Non-inert Not stated Not stated Small Dole - Horton Landfill site Non-inert Not stated Not stated Warnham - Brookhurst Wood Non-inert Not stated Not stated Landfill Site Potential Future Allocated Capacity 19 Sites with provisional allocation Brookhurst Wood extension Non-inert Potential capacity of up to1.4mt Proposed extension to existing landfill Langhurstwood Quarry Non-inert Potential capacity of up to 1.2mt to 2021 but New landfill not likely to become available in the short- term; Long-term capacity could be considerably greater. Laybrook Brickworks Non-inert Potential capacity of up to 2.4mt to 2021 New landfill (based on discussions with potential operator) subject to landfilling commencing in 2010. Long-term capacity could be considerably greater
17 East Sussex County Council and Brighton and Hove City Council (2008) Waste and Minerals Core Strategy and Minerals Sites Development Plan Documents. Information Paper 1 – The Future Need for Waste Management http://www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste/downloadpapers.htm [accessed Sept. 09] 18 West Sussex Waste Local Plan 2001 - 2016 (2004) Revised Deposit Draft http://www.westsussex.gov.uk/ccm/cms- service/stream/asset/?asset_id=2845414 [accessed 12.09.08] 19 West Sussex Strategic Waste Allocations DPD Preferred Option (2007) http://www.westsussex.gov.uk/yourcouncil/ppri/mwdf/wastesites_prefoption.pdf [accessed 12.09.08]
Draft Report 34 October 2008 Residual Waste from London Study
Type Capacity (if stated) Status (if Site stated)
Sites without provisional allocation Rudgewick Brickworks Non-inert Potential capacity of 1.0mt (total capacity New landfill uncertain; figure is a suggestion of maximum capacity likely to be available in period up to 2021) Freshfield Lane Brickworks Non-inert 1.2mt New landfill West Hoathly Brickworks, Non-inert Potential capacity of 1.0mt (total capacity New landfill Sharpthorne uncertain; figure is a suggestion of maximum capacity likely to be available in period up to 2021).
4.2.9 Estimates of the total remaining permitted landfill capacity for non-inert wastes in West Sussex are stated in the Annual Monitoring report. The March 2007 estimate includes the capacity provided by the extension of the Lidsey Landfill site. Further information on existing non-inert landfill capacity in West Sussex is provided in the West Sussex Minerals and Waste Development Framework Background Paper 2: Waste Arisings and Waste Management Capacity (Version 1, July 2008). Table 4 summarises the data from these sources.
Table 4 - West Sussex Estimated Remaining Permitted Landfill Capacity Data Source Type Capacity
MWCS Background Paper 2 20 Non-inert 3.2mt (March 2008) Annual Monitoring Report 21 Non-Inert 3.2mt (March 2008) SEERA Capacity Assessment Report Non- 3,546,000 cubic meters (at the start of 2004) 22 hazardous
Surrey
4.2.10 The Surrey Waste Plan was adopted in May 2008 and identifies existing allocated capacity.
Table 5 - Surrey Existing and Allocated Landfill Capacity (non-inert and non-hazardous landfill only) Type Capacity (if stated) Status (if
stated) Allocated Capacity Albury Sandpit, Shere Rd, Albury Non-inert Not stated Not stated Seale Lodge Sandpit, Seale, Nr Non-inert Not stated Not stated Farnham Clockhouse Landfill, Horsham Rd, Non-inert Not stated Not stated Capel Patteson Court Landfill, Cormongers Non-inert Not stated Not stated
20 West Sussex Minerals and Waste Development Framework Background Paper 2: Waste Arisings and Waste Management Capacity (Version 1, July 2008) 21 West Sussex (2008) Annual Monitoring Report 2007/08 22 Golder Associated and MEL Research Ltd (2004) Waste Management Capacity in the South East Region – A Report to SEERA
Draft Report 35 October 2008 Residual Waste from London Study
Type Capacity (if stated) Status (if
stated)
Lane, Nutfield Princess Royal South, Guildford Non-inert Not stated Not stated Road, Runfold Potential Future Allocated Capacity
4.2.11 The 2007/08 Surrey Annual Monitoring Report estimated that there was 10,709,088 cubic metres (10.46mt) of permitted non-inert landfill capacity remaining in the County at the end of 2007.
Table 6- Surrey Estimated Total Landfill Capacity Data Source Type Capacity
Annual Monitoring Report 2007/08 23 Non- Hazardous 10,709,088 cubic metres SEERA Capacity Assessment Non-hazardous 15,600,000 cubic meters (at the start Report 24 of 2004)
Kent
4.2.12 Information on existing permitted landfill capacity is given in the Kent Annual Monitoring Report. Information on future allocated capacity is not yet available.
Table 7 - Kent Existing and Allocated Landfill Capacity (non-inert and non-hazardous landfill only) Type Capacity (if stated) Status (if
stated) Existing Permitted Capacity 25 Shelford Landfill Site Non Not stated Hazardous Greatness Quarry Non Not stated Hazardous Total Non Hazardous = 5,474,500 Potential Future Allocated Capacity 26
23 Reported in Minerals and Waste Planning in Surrey Annual Monitoring Report 2007/2008 (2007) http://www.surreycc.gov.uk/sccwebsite/sccwspublications.nsf/591f7dda55aad72a80256c670041a50d/ae0278736f9710d080257 54000561045/$FILE/Chptr%204%20Waste.pdf [accessed Sept 2009] 24 Golder Associated and MEL Research Ltd (2004) Waste Management Capacity in the South East Region – A Report to SEERA 25 Kent County Council (2007) Minerals and Waste Annual Monitoring Report 2007/08 http://www.kent.gov.uk/NR/rdonlyres/618A7EEA-C096-4CEE-B031-2C2807A943E3/0/kentamr08.pdf [accessed Sept. 2009] 26 Information not yet available. Kent County Council Core Waste Strategy and Waste Sites DPD are anticipated to be adopted in 2009
Draft Report 36 October 2008 Residual Waste from London Study
4.2.13 The SEERA Capacity Assessment includes Medway. The Waste Development Framework when prepared will exclude the Medway area.
Table 8 - Kent Estimated Total Landfill Capacity (including Medway) Data Source Type Capacity
SEERA Capacity Assessment Non-hazardous 6,990,000 cubic meters (at the start Report 27 of 2004)
4.3 Environment Agency RGN3 Landfill Location
4.3.1 In order to assess the likely potential of future landfill capacity in the counties neighbouring East Sussex and Brighton & Hove, it was proposed that any identified future landfill allocations in emerging development plan documents be mapped and their locations assessed against the Environment Agency Regulatory Guidance Note 3 28 (RGN3). Such an exercise would identify any future allocated sites that fail to comply with the Guidance and enable a more accurate assessment of potential future capacity for disposal of non-inert waste.
4.3.2 RGN3 states the following modifications to the Policy and Practice for the Protection of Groundwater adopted by the Environment Agency as follows:
• The Agency will object to an landfill proposal which is in groundwater Source Protection Zone 1;
• For all other proposed landfill site locations, a risk assessment must be conducted based on the nature and quantity of the wastes, and the natural setting and properties of the location. Where this risk assessment demonstrates that active long-term site management is essential to prevent long-term groundwater pollution, the Agency will object to sites:
• below the water table in any strata where the groundwater provides an important contribution to river flow or other sensitive surface waters;
• on or in a Major Aquifer;
• within Source Protection Zones II or III.
4.3.3 It was not possible to undertake this exercise given that so few of the Counties had progressed their MWDF to the stage were future allocated sites has been identified. RGN3 does not apply to existing landfills for the purposes of Schedule 4, paragraph 1 of the Landfill Regulations i.e. those which were already in operation on 15 June 2002 or had not been brought into operation by that date, but the relevant authorisation (Licence or permit) was granted before that date.
27 Golder Associated and MEL Research Ltd (2004) Waste Management Capacity in the South East Region – A Report to SEERA 28 Environment Agency. Landfill Directive Regulatory Guidance Note 3 (Version 4.0, December 2002). Groundwater Protection: Locational Aspects Of Landfills In Planning Consultation Responses & Permitting Decisions.
Draft Report 37 October 2008 Residual Waste from London Study
The Guidance Note will apply to any extensions to existing sites that are new areas (i.e. not already licensed or permitted on 15 June 2002).
4.4 Spatial Relationship Analysis (SRA)
4.4.1 A spatial relationship analysis (SRA) was undertaken, to compare travel distances from major settlements to landfills within the counties neighbouring East Sussex and Brighton & Hove, with distances from the same major settlements to landfills in East Sussex and Brighton & Hove. At the time of the assessment, the Beddingham site in East Sussex was still operational and the results of this assessment are retained in this report as they are indicative of the presence of an alternative land disposal site in the central/west part of the core strategy area, which would be broadly similar to the proposed land disposal areas of search for land disposal, illustrated in the preferred strategy consultation document.
4.4.2 A SRA was undertaken for the following scenarios:
• Scenario 1 - Disposal of waste in the nearest landfill in counties neighbouring East Sussex and Brighton & Hove;
• Scenario 2 - Disposal of waste in the nearest landfill in East Sussex; and
• Scenario 3 - Disposal of waste in the nearest landfill in East Sussex (situation following the closure of Beddingham Landfill).
4.4.3 The distance from the largest three settlements in each Waste Planning Authority area to the nearest landfill was calculated on the basis of distance by road. It was assumed that waste would be travelling by road from the main settlement to the landfill and that rail would not be used. In calculating travel distance by road it was assumed that waste would travel preferentially along the strategic road network.
4.4.4 The locations of the existing landfill sites and allocated future sites in Figures 1, 2 and 3 were identified from the examination of waste plans and MWDF. A ‘reality check’ was undertaken on this information to ensure that sites identified as existing were still operational and accepting waste. Existing sites were checked using the Environment Agency’s website, using the ‘what’s in your back yard’ function. Their operational status was then verified using its EDM (electronic data management) system, underwritten by industry knowledge. This was then cross- correlated with LPA returns data in order to determine what is considered to be a definitive list of operational landfill sites, receiving non-hazardous waste during the years 2006 and 2007. These three, cross-linked, actions are believed to have delivered a validated data-set for use in this study.
4.4.5 The results of the SRA set out by-scenario below.
Draft Report 38 October 2008 Residual Waste from London Study
Scenario 1 - Disposal of Waste in the Nearest Landfill
4.4.6 A SRA was undertaken between the locations of the main settlements in the Counties neighbouring East Sussex and Brighton & Hove, in relation to the non-inert and non-hazardous landfills in the four Counties. The model allowed for waste to travel to another neighbouring County if this is where the closest landfill was located.
4.4.7 For roughly half of the settlements there are landfills located in close proximity. For example Bexhill, Hastings, Gravesend, Guildford, Reigate, Bognor Regis, Chichester and Horsham are all within 10km from the nearest landfill.
4.4.8 The SRA of the disposal of waste in the nearest landfill revealed that if travel distance by road were the only factor governing the location of waste disposal, all waste would be disposed of, in the County of generation. None of the waste generated by settlements in the Counties would be taken across the border to be disposed of in neighbouring Counties.
4.4.9 Figure 1 shows the results of the SRA for Scenario 1.
Scenario 2 - Disposal of Waste in the Nearest Landfill in East Sussex
4.4.10 When the Spatial Relationship Analysis for Scenario 1 is compared against that undertaken for Scenario 2, the distances travelled by waste is much greater. For example for Gravesend, under Scenario 1 the distance travelled by waste to the nearest in-county landfill is 6km. Under Scenario 2 this increases to 83km. In total under Scenario 1 total road kilometres travelled are 259. Under Scenario 2 this increases to 1,129.
4.4.11 The Spatial Analysis reveals that the two landfills located in East Sussex are geographically distant from the main settlements in the neighbouring authorities. The two landfills are located close to the coast in the south of the County. This reflects the location of the main population centres in the County. The main settlements and areas of waste generation in Kent are located to the Northern half of the County (Gravesend, Maidstone, Canterbury and Margate) and Centrally (Ashford). In West Sussex, Worthing is closer to the nearest landfill in East Sussex than the main settlements in Kent are to the nearest landfills in East Sussex. However it is still roughly twice as far for waste to travel from Worthing to the nearest landfill in East Sussex than to the nearest landfill within West Sussex itself.
4.4.12 Figure 2 shows the results of the SRA for Scenario 2.
Draft Report 39 October 2008 Residual Waste from London Study
Scenario 3 - Disposal of Waste in the Nearest Landfill in East Sussex (situation following the closure of Beddingham Landfill)
4.4.13 Until 2009, East Sussex had two landfill sites, Beddingham and Pebsham. Beddingham closed in 2009, leaving Pebsham as the only existing site. Ashdown Brickworks is allocated in the Waste Local Plan as potential future landfill capacity. Scenario 3 examined the situation following the closure of Beddingham and assumed that Ashdown Brickworks was an operating site, where waste travelled from each neighbouring county settlement to the nearest landfill in East Sussex, either Pebsham or Ashdown Brickworks. In considering this scenario, the potential land disposal areas of search identified in the WMCS Preferred Strategy document were also acknowledged. These areas of search are situated more centrally within the core strategy area than Ashdown Brickworks. However, it was considered that the difference in the travel distance to these areas, when compared to Ashdown Brickworks, would not have a significant effect on the outcome of the Scenario 3 model.
4.4.14 Figure 3 shows the results of the SRA for Scenario 3.
4.4.15 The distances travelled by waste were the greatest under scenario 3. Table 9 provides a summary of the total distances travelled under each Scenario. The total waste travelled was calculated by summing the road distances travelled by waste from each of the neighbouring county settlements to the nearest landfill site.
Table 9 - Summary of Distances Travelled by Waste under Each Scenario Scenarios Total Waste Travelled (km)
Scenario 1 259 Scenario 2 1,129 Scenario 3 1,426
Draft Report 40 October 2008 Residual Waste from London Study
Figures 1 - 3
Draft Report 41 October 2008 THIS DRAWING MAY BE USED ONLY FOR THE PURPOSE INTENDED AND ONLY WRITTEN DIMENSIONS SHALL BE USED
NOTES Nearest Landfill to Major Town/City Landfill Sites Existing Site NORTH SEA New Allocated Capacity Major Towns and Cities (in each County) Motorways A roads Brighton and Hove 10 GRAVESEND East Sussex
MARGATE Kent Surrey West Sussex
Landfill Sites CAMBERLEY WOKING 1 Albury Sandpit 11 9 2 Patteson Court 3 Princess Royal South MAIDSTONE CANTERBURY 4 Claypit north of Graylands 5 Laybrook Brickworks 6 Lidsey SURREY 2 REIGATE 7 Horton GUILDFORD 8 Brookhurst Wood 1 9 Shelford 10 Bakers Hole 3 11 Greatness Quarry 12 Beddingham
d ASHFORD
x 13 Pebsham m . 14 Ashdown Brickworks s e t i
s Copyright
l l i
f This map is reproduced from Ordnance Survey d
n CRAWLEY material with the permission of Ordnance Survey a l on behalf of the Controller of Her Majesty's s 4 u Stationary Office. o d r a
z 8 © Crown copyright a
h HORSHAM - n
o Unauthorised reproduction infringes Crown n copyright and may lead to prosecution or d
n KENT civil proceedings. a
t r e
n 2008 i - n o n
d n a
s 5 t n
e EAST SUSSEX m e
l WEST SUSSEX t t e s
r o j 7 Revision Details By Date Suffix a Check m
n Drawing Status e 14 13 e HASTINGS w
t DRAFT e b 12 BEXHILL s Job Title i
s BRIGHTON AND HOVE
y CHICHESTER l a
n 6
A WORTHING BRIGHTON AND HOVE East Sussex CC WMDF p i h s BOGNOR REGIS London's Residual Waste n o
i SEAFORD t Distance by Road to the Nearest Landfill a l e
R EASTBOURNE
l Drawing Title a i t EAST SUSSEX SURREY a
p Spatial Relationship Analysis S \ Bexhill - 5km Camberley - 17km s between major settlements D
X Eastbourne - 22km Guildford - 9km M
\ and non-inert and e t Hastings - 6km Reigate - 6km s
a non-hazardous landfill sites
W Seaford - 11km Woking - 15km
_ Scale at A3 l
a ENGLISH CHANNEL 1:500,000 u d i Drawn Approved s
e KENT WEST SUSSEX DH RJ R
_ Stage 1 check Stage 2 check Originated Date n Ashford - 27km Bognor Regis - 6km o d n
o Canterbury - 5km Chichester - 8km
L Scott Wilson 8 _
0 Scott House 5 0 Gravesend - 6km Crawley - 13km Alençon Link, Basingstoke 3 2
6 Hampshire, RG21 7PP r 1 e Telephone (01256) 310200
2 Maidstone - 28km Horsham - 8km b
1 Fax (01256) 310201 o t
D www.scottwilson.com c \
: Margate - 25km Worthing - 18km O K
t : Drawing Number Rev s h t 1
a : p e t e l
a Brighton & Hove - 24km i FIGURE 1 D F THIS DRAWING MAY BE USED ONLY FOR THE PURPOSE INTENDED AND ONLY WRITTEN DIMENSIONS SHALL BE USED
NOTES Nearest landfill in East Sussex to Major Town/City Landfill Sites Existing Site NORTH SEA New Allocated Capacity Major Towns and Cities (in each County) Motorways A roads Brighton and Hove GRAVESEND East Sussex 10 MARGATE MARGATE Kent Surrey West Sussex
Landfill Sites CAMBERLEY WOKING 9 1 Albury Sandpit CANTERBURY 2 Patteson Court 3 Princess Royal South 11 MAIDSTONE 4 Claypit north of Graylands 5 Laybrook Brickworks 6 Lidsey REIGATE 7 Horton d
x GUILDFORD 8 Brookhurst Wood m
. 2
x 9 Shelford e
s 10 Bakers Hole s u 1 SURREY S 3 11 Greatness Quarry
t
s 12 Beddingham a KENT ASHFORD E
13 Pebsham n i 14 Ashdown Brickworks s e t i
s Copyright
l l i
f This map is reproduced from Ordnance Survey d
n CRAWLEY material with the permission of Ordnance Survey a l on behalf of the Controller of Her Majesty's s
u Stationary Office. o 8 d 4 r a
z © Crown copyright a
h HORSHAM - n
o Unauthorised reproduction infringes Crown n copyright and may lead to prosecution or d
n civil proceedings. a
t r e
n 2008 i - n o n
d n a
s t n e 5 m
e EAST SUSSEX l t
t WEST SUSSEX e s
r o j Revision Details By Date Suffix a Check m
7 n Drawing Status e 14 e w
t DRAFT
e BRIGHTON AND HOVE HASTINGS b 13 s 12 Job Title i BEXHILL s
y CHICHESTER l a n A 6 East Sussex CC WMDF p
i BRIGHTON AND HOVE
h Distance by Road to the Nearest s London's Residual Waste n WORTHING o i t EASTBOURNE Landfill in East Sussex a l BOGNOR REGIS e
R SEAFORD
l Drawing Title a i t EAST SUSSEX SURREY a
p Spatial Relationship Analysis S \ Bexhill - 5km Camberley - 122km s between major settlements and D
X Eastbourne - 22km Guildford - 100km M
\ non-inert and non-hazardous e t Hastings - 6km Reigate - 68km s
a landfill sites in East Sussex
W Seaford - 11km Woking - 105km
_ Scale at A3 l
a ENGLISH CHANNEL 1:500,000 u d i Drawn Approved s
e KENT WEST SUSSEX DH RJ R
_ Stage 1 check Stage 2 check Originated Date n Ashford - 56km Bognor Regis - 64km o d n
o Canterbury - 80km Chichester - 70km
L Scott Wilson 8 _
0 Scott House 5 0 Gravesend - 83km Crawley - 50km Alençon Link, Basingstoke 3 2
6 Hampshire, RG21 7PP r 1 e Telephone (01256) 310200
2 Maidstone - 63km Horsham - 51km b
1 Fax (01256) 310201 o t
D www.scottwilson.com c \
: Margate - 110km Worthing - 39km O K
t : Drawing Number Rev s h t 1
a : p e t e l
a Brighton & Hove - 24km i FIGURE 2 D F THIS DRAWING MAY BE USED ONLY FOR THE PURPOSE INTENDED AND ONLY WRITTEN DIMENSIONS SHALL BE USED
NOTES Nearest landfill in East Sussex to Major Town/City Landfill Sites Existing Site NORTH SEA New Allocated Capacity Major Towns and Cities (in each County) Motorways A roads
d Brighton and Hove x
m GRAVESEND . l l i
f East Sussex d n
a 10 MARGATE MARGATE L Kent n o t g n i Surrey d d e B
f West Sussex o
e r u s o l CAMBERLEY c Landfill Sites e WOKING 9 h t CANTERBURY 1 Albury Sandpit g n
i 2 Patteson Court
w MAIDSTONE
o 11 3 Princess Royal South l l o
f 4 Claypit north of Graylands
n
o 5 Laybrook Brickworks i t
a 6 Lidsey u REIGATE t i GUILDFORD s 7 Horton
-
2
x 8 Brookhurst Wood e
s 9 Shelford s u 1 SURREY S 3 10 Bakers Hole
t
s 11 Greatness Quarry a KENT ASHFORD E
12 Pebsham n i 13 Ashdown Brickworks s e t i
s Copyright
l l i
f This map is reproduced from Ordnance Survey d
n CRAWLEY material with the permission of Ordnance Survey a l on behalf of the Controller of Her Majesty's s
u Stationary Office. o 8 d 4 r a
z © Crown copyright a
h HORSHAM - n
o Unauthorised reproduction infringes Crown n copyright and may lead to prosecution or d
n civil proceedings. a
t r e
n 2008 i - n o n
d n a
s t n e 5 m
e EAST SUSSEX l t
t WEST SUSSEX e s
r o j Revision Details By Date Suffix a Check m
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w 13
t DRAFT
e HASTINGS b
s 12 Job Title i
s BEXHILL
y CHICHESTER l a n A 6 East Sussex CC WMDF p
i BRIGHTON AND HOVE h s Distance by Road to the Nearest London's Residual Waste n WORTHING o i t EASTBOURNE Landfill in East Sussex - Situation in mid 2009 a l BOGNOR REGIS Drawing Title e
R SEAFORD
l Spatial Relationship Analysis a i t SURREY a EAST SUSSEX between major settlements and p S \ Camberley - 148km non-inert and non-hazardous
s Bexhill - 5km D
X Eastbourne - 22km Guildford - 128km landfill sites in East Sussex M \
e - situation following the closure t Reigate - 98km
s Hastings - 6km
a of Beddington Landfill W Seaford - 33km Woking - 124km _ Scale at A3 l
a ENGLISH CHANNEL 1:500,000 u d i Drawn Approved s e KENT WEST SUSSEX DH RJ R
_ Stage 1 check Stage 2 check Originated Date n Bognor Regis - 93km
o Ashford - 56km d n
o Canterbury - 80km Chichester - 99km
L Scott Wilson 8 _
0 Scott House 5 0 Crawley - 79km Alençon Link, Basingstoke
3 Gravesend - 83km 2
6 Hampshire, RG21 7PP r 1 e Telephone (01256) 310200
2 Horsham - 80km b Maidstone - 63km
1 Fax (01256) 310201 o t
D www.scottwilson.com c \ : Margate - 110km Worthing - 69km O K
t : Drawing Number Rev s h t 1
a : p e t e l a i Brighton & Hove - 50km FIGURE 3 D F Residual Waste from London Study
Sustainability Appraisal-Based Comparative Assessment of Disposal Options
4.4.16 A SA based comparative assessment of Scenario 1 and 3 was undertaken. Scenario 2 was not assessed as it was considered not to be less representative of the likely short-medium term scenario following the closure of the Beddingham site in 2009.
4.4.17 The intention of the assessment was to appraise the likely sustainability impacts of the scenarios, i.e. the impact of the implementation of the apportionment policy in accordance with the ripple effect. The assessment drew upon the SA methodology to examine the effects of the scenarios in an objective fashion.
4.4.18 The appraisal of the options was undertaken on basis of the situation portrayed by the SRA described in Section 4.4. Figures 1 and 3 were used to identify the nearest landfill under each of the Scenarios for each major settlement.
4.4.19 The assessment drew upon baseline data contained in the Sustainability Appraisal Reports prepared to support the development of the MWDF for each of the four Counties (East Sussex, Kent, Surrey and West Sussex). Due to the Counties being at different stages, which respect to producing their MWDF there was not the same amount of information available for each County.
4.4.20 The SEA Regulations require the assessment of the likely significant environmental effects of the plan or programme on issues such as:
• Air • Biodiversity (including flora and fauna) • Climate • Cultural heritage • Human health • Landscape • Material assets • Population • Soil • Water • And the interrelationship between the above factors
4.4.21 The SA process extends the assessment process to include of likely significant social and economic effects of the topics listed above to include social and economic factors such as the economy and employment, transport, crime and safety, health and education.
4.4.22 For the appraisal of the two waste disposal options, the effects on the following environmental, economic and social issues were considered.
Draft Report 42 October 2008 Residual Waste from London Study
• Population • Health • Employment and Economy • Transport • Crime and Safety • Housing • Cultural Heritage • Climate • Air • Soil • Biodiversity • Landscape • Waste
4.4.23 From the common list of issues considered by SA/SEA it is possible to identify those against which the scenarios are likely to have significant effects. The main factor distinguishing between the scenarios was the distanced travelled. Consequently it was possible to identify transport, climate, air and health as the main issues affected by the implementation of the scenarios and the assessment focused on these issues.
4.4.24 The assessment did not consider the other issues listed above, as no effects against these issues were anticipated. It was not intended that the assessment should examine the wider effects of landfilling in one location rather than another or that it should examine the effects of landfilling as a means of waste disposal against other waste management options.
Current Conditions
4.4.25 To enable the effects of the two options on the main assessment issues to be determined, baseline data was collated, to build up an understanding of the current conditions in each of the Counties. The baseline data was collated from SA reports that were produced by each of the County Councils during the preparation of their respective MWDFs. The baseline information collated focused on the four identified issues only. To maintain focus, for the climate issue baseline data centred on addressing the causes of climate change, rather than including those aspects of the environment which may be affected by it. Similarly, health data focused on aspects which could be influenced by air quality and road traffic effects only.
4.4.26 Baseline data was taken from the following sources:
• East Sussex County Council and Brighton and Hove City Council (2007) East Sussex and Brighton and Hove Waste and Minerals Core Strategy and Minerals Site Development Plan Document Sustainability Appraisal Scoping Report
• West Sussex County Council (2007) West Sussex Minerals and Waste Core Strategy DPD – Draft Sustainability Appraisal Report
Draft Report 43 October 2008 Residual Waste from London Study
• Kent County Council (2005) SEA/SA of Kent Minerals and Waste Development Framework, Joint Municipal Waste Management Strategy and the Local Transport Plan for Kent Scoping Report
• Surrey County Council (2006) Surrey Waste Plan Sustainability Appraisal
4.4.27 The Baseline Information is contained within Appendix 1 .
Appraisal Matrices
4.4.28 The effects of the scenarios on Transport, Climate, Air and Health only were considered. As a scoping stage had not been undertaken there were no SA Objectives. To address this, common sustainability objectives under each topic were taken into account. Under each of the issues identified the following sustainability aims were taken into account:
Transport
• Reduce the need to travel • Promote the use of sustainable transport modes • Reduce congestion
Climate
• Reduce CO 2 emissions from the transport sector
Air
• Maintain and improve air quality • Prevent exceedences in air quality objectives
Health
• Reduce illness and mortality from respiratory diseases • Reduce disturbance from noise • Reduce the number and severity of road accidents
Draft Report 44 October 2008 Residual Waste from London Study
4.4.29 The symbols used in the appraisal matrices are as follows:
Symbol Meaning
The Preferred Option is likely to have a significant beneficial effect on the SA / SEA Objective
The Preferred Option is likely to have a beneficial effect on the SA / () SEA Objective but the effect is not likely to be significant
The Preferred Option is likely to have an adverse effect on the SA /
() SEA Objective but the effect is not likely to be significant
The Preferred Option is likely to have a significant adverse effect on the SA / SEA Objective
The Preferred Option is likely to have no effect on the SA / SEA ~ Objective
The effect of the Preferred Option on the SA / SEA Objective is ? unclear
4.4.30 When undertaking the SA-based comparative assessment, it was assumed that Scenario 1 ‘Disposal of waste in the nearest landfill to the settlement’ reflected the current situation.
4.4.31 Due to the high-level nature of the assessment and the relative absence of information about the landfill sites, it was assumed that Scenario 1 (disposal to land in the nearest appropriate site) represented the business as usual situation. Under Scenario 1, no effects (positive or negative) are anticipated as the scenario maintains the current situation. Consequently, the assessment of Scenario 3 was undertaken as a comparative assessment against the Scenario 1 baseline. The results of the assessment are summarised in the table below.
Transport Climate Air Health ST MT LT ST MT LT ST MT LT ST MT LT Scenario 1 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Scenario 3 () () ()
Findings of the SA-based Comparative Assessment
Transport
4.4.32 Scenario 3 will result in the long distance transport of waste. Current conditions in terms of the level of road traffic in the four Counties are poor and are anticipated to worsen. In the South East estimated traffic flows for all motor vehicles (millions of vehicle kms) increased from
Draft Report 45 October 2008 Residual Waste from London Study
82,062 to 86,402 between 2000 – 2004 29 . Under Scenario 3 waste transport will contribute to high and growing levels of road traffic in each of the four Counties. It is anticipated that there will be significant adverse effect on transport associated with this.
Climate
4.4.33 Scenario 3 will result in the long distance transport of waste. Under scenario 1 (the assumed current situation) the total waste distance travelled is 259km. Under scenario 3 it is 1,426km. This represents an increased of 1,167 km in waste distance travelled.
4.4.34 Under Scenario 3 CO2 emissions from transport are likely to increase in all four of the Counties as a consequence of the long distance transport of waste. Despite UK targets to reduce CO2 emissions, emissions from the transport sector have continued to rise. In 2003 UK emissions from transport were 8% higher than 1990 levels despite UK targets to reduce emission by 20% by 200830.
4.4.35 Given the magnitude of increase in road distance travelled and the current poor level of performance in reducing emissions from the transport sector despite targets to do so, it is anticipated that the long distance transport of waste associated with Scenario 3 will have a significant adverse effect on Climate.
4.4.36 Under Scenario 3, long-term impacts are anticipated given that once released, CO2 emissions will continue to have an impact even if emissions decline in the longer term.
Air
4.4.37 East Sussex and Brighton & Hove has three Air Quality Management Areas (AQMA) 31 . One of these is in Brighton City Centre, one in Bexhill Road in Hastings, and one in central Lewes. It is unlikely that lorries carrying waste would pass through the centre of Brighton and Lewes if it were possible to avoid this.
4.4.38 Under Scenario 3 it is likely that there will be a significant adverse effect on Air Quality. Under this scenario Lorries carrying waste will be travelling from the East and West to access Pebsham Landfill Site and will be using Bexhill Road as the access road to the landfill site.
29 East Sussex County Council and Brighton and Hove City Council (2007) East Sussex and Brighton and Hove Waste and Minerals Core Strategy and Minerals Site Development Plan Document Sustainability Appraisal Scoping Report 30 West Sussex County Council (2007) West Sussex Minerals and Waste Core Strategy DPD – Draft Sustainability Appraisal Report 31 East Sussex County Council and Brighton and Hove City Council (2007) East Sussex and Brighton and Hove Waste and Minerals Core Strategy and Minerals Site Development Plan Document Sustainability Appraisal Scoping Report
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Health
4.4.39 A significant adverse effect on air quality has been identified under Scenario 3 due to the likely impact on the AQMA at Bexhill. There may be an adverse effect on health as a consequence of worsening air quality in this area. This effect is likely to be minor only as the area affected will be relatively small. It is likely that health impacts will be felt in the short, medium and long term. Poor air quality has a variety of impacts on human health, which are felt over a range of timescales.
4.4.40 The baseline for road accidents which has been collated from the Counties MWDF SA/SEA reports is not sufficiently detailed to be able to examine the likely situation under the scenarios with respect to road traffic accidents.
4.5 The Situation in Counties Neighbouring East Sussex and Brighton & Hove: Summarising Comments
4.5.1 This element of the study aimed to examine the implications of implementing the apportionment policy, taking account of land disposal capacity in the counties neighbouring the Strategy area and examining the transport implications of the ‘ripple effect’, both in terms of travel distance an a wider sustainability appraisal approach.
4.5.2 The Spatial Relationship Analysis exercise demonstrated that the ripple effect scenario would result in significantly increased waste miles, in the order of six times the number of miles travelled by waste HGVs.
4.5.3 Applying sustainability appraisal principles to the analysis of the effects of different scenarios demonstrates that the ripple effect scenario would be likely to result in significant adverse effects on a range of sustainability indicators, including transport, climate, air and health, when compared to a continuation of the current land disposal situation of disposal in-county at the nearest suitable site.
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5 Land Disposal Capacity in the Strategy Area
5.1 Introduction
5.1.1 The spatial relationship between potential land disposal capacity in the Strategy area and potential/actual sources of waste for final disposal is a key consideration in the light of national policy and the importance of using the nearest appropriate installations. The potential to provide land disposal capacity in locations that are truly accessible to waste travelling from London, or indeed neighbouring authority areas, is an important part of the consideration of the feasibility of the apportionment policy.
5.1.2 In assessing the realistic disposal capacity in the Strategy area, together with its potential ability to be used for the disposal of London’s waste, we have considered a number of linked assessments, and have:
• Undertaken a broad assessment of actual and potential future landfill capacity in East Sussex (ESCC) and Brighton and Hove (B&H), based on a consideration of the potential capacity of sites allocated in the Waste Local Plan and the typical capacity of potential generic land-raising sites in the Plan area;
• Examined the accessibility in broad terms of shortlisted land disposal sites by assessing proximity to the strategic highway network and the suitability of the access route to the site, taking account of issues such as impact on communities etc;
• Considered the land disposal capacity gap assessment undertaken by ERM on ESCC/B&H’s behalf, on the basis of the above times/volumes, with and without London’s apportionment tonnage; and then
• Undertaken a travel validation study, based on typical industry views on development feasibility/penalties and cost of residual waste transportation to assess whether any capacity so released would elastically be attractive either for direct delivery of London’s waste, or by the development of what is referred to as a ‘ripple effect’, whereby London’s waste, when disposed of closest to the City, progressively displaces further and further southwards, towards ESCC/B&H sites, which are closest to the Channel.
This approach provides evidence to determine the overall feasibility of identified sites and generic land-raising sites realistically being able to meet out-of-county demand.
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5.2 Assessment of ESCC/B&H potential land disposal capacity
Background
5.2.1 The operational attractiveness of a landfill/landraise site can generally be defined on the basis of its development and operational costs vs. its potential to earn income against which to recoup these costs.
5.2.2 The industry typically uses such a simple screening method as a ‘first-pass’ assessment methodology when considering new/replacement sites, having firstly assessed the likelihood of the success at the authorisations stage.
5.2.3 Broadly, operational costs remain relatively constant irrespective of the size of a site, although they are an absolute function of the rate of inputs, i.e. the higher the rate, the higher actual costs, but the lower the unit cost. Cost changes of this nature are ‘gapped’, in that they are driven by the amount of mobile plant required in order to manage the waste as it is received. The introduction of an additional item of plant therefore carries a penalty unless its capacity to manage waste is substantially utilised.
5.2.4 For this reason, sites with annual inputs of less than 100,000 tonnes tend to represent a level below which main-stream operators typically consider unviable. Similarly, inputs, and therefore nominal capacities, can be artificially constrained in order to match plant capacities.
5.2.5 Development costs can broadly be classified into two elements; fixed, i.e. infrastructure costs such as the access road, fencing, weighbridge and associated accommodation, together with screening elements; and variable, i.e. engineering costs directly associated with the release of voidspace, such as any void creation costs (excavation/shaping), basal/side lining, and surface capping and restoration.
5.2.6 Broadly speaking, fixed costs tend to not to be directly influenced by the size of a site, more by its anticipated level of inputs – and once expended, they are generally recouped as soon as is practicable. This tends to infer that once a site has been developed and operations commenced, interruptions to operational continuity are not usually welcomed.
5.2.7 Operational periods of less than 5 years are also typically considered too short for cost effective cost-recovery – subject to site size/capacity.
5.2.8 The combination of the above two matters typically leads main-stream industry players to consider sites with less than 1 million cubic metres of voidspace, operated for more than 5 years, as non-viable, although local circumstances can over-ride this.
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5.2.9 Likewise, variable costs are not directly influenced by the absolute size of a site, more by its relative engineering sensitivity and depth:area ratio.
5.2.10 The use by the Environment Agency of RGN3 (see Section 4.4) and the Landfill Directive has tended to reduce the impact of a site’s sensitivity, as minimum engineering standards are now required across all sites, which acts as an industry ‘leveller’. However, the ability to use in-situ clay in engineering operations will deliver a lower cost-base for a site in comparison to one where such material would otherwise have to be imported.
5.2.11 The depth:area ratio of a landfill site is typically the key financial driver, as, since lining and capping costs are typically fixed on a per square metre basis (although there are minor variations reflecting the amount procured at any one time), maximising the depth of placed waste is crucial if such costs are to be recouped at an acceptable rate.
5.2.12 The deeper the site the better, within reason, if a cost-effective transfer of the price of engineering the basal, side and upper surfaces of the landfill is to be made into a ‘saleable’ per cubic metre. Industry norms sit within a range of >25m to <10m, with a ‘typical’ minimum waste depth being not less than 7.5m.
5.2.13 The above constraints all tend to mitigate against land-raise operations from a commercial basis, as they tend to be shallower (thinner waste deposit depth) and of greater physical area – they are therefore less likely to be developed than mineral workings. However, this approach may be set aside if landraise proves to be the only development option, although more recent industry responses are driven by pre-processing closer to source, with only the disposal of residual materials then to landfill.
5.2.14 However, conversely there is evidence that land-raise is on occasions considered more suited to disposal of waste to land by the Environment Agency, as placing waste largely above ground avoids engineering and post-closure issues associated with the development of, say, deeper mineral workings, particularly those within hard strata, such as ease of liner construction, access to pollution management systems and differential settlement. Planning authorities across a number of regions tend to view the use of non-mineral sites almost as sites of ‘last resort’, as they more frequently than not result in the loss of non-brownfield land – typically contrary to land-use policies. Further background information on land disposal options is provided in the Waste and Minerals Core Strategy Information Paper 5 – Residual Waste Disposal.
5.2.15 The allocated sites and generic land-raising sites identified in Table 5.1 were assessed on two parallel, yet different, bases. Ashdown Brickworks was assessed as a specifically allocated site, in that it is considered as a specific opportunity, while two generic sizes of land-raising site were considered as ‘typical’ potential examples of land-raise opportunities, acknowledging that actual sites will be subject to a number of constraints which may mitigate against its effective release and the timing of that release. It is acknowledged that the draft WMCS identifies a number of potential areas of search for land-raising. However, the consideration of potential capacity that could be offered by these areas was not sufficiently advanced for inclusion in this
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study. Therefore, in the absence of capacity information for specific potential land-raising areas, an estimate was made of typical land-raising capacity for sites that might be representative of generic land-raise sites in the core strategy area. In due course, once further assessment of preferred areas or sites for land-raising in the core strategy has been completed, capacity assessment of such sites can be used to inform a further iteration of this report.
5.2.16 Each allocated site was assessed against the development constraints noted in the Waste Local Plan, in order to demonstrate how these might affect capacity in practice. Undertaking a more extensive, risk-based, assessment of the benefits and dis-benefits of landraising as compared to mineral working based landfill developments, would strengthen the Council’s position in undertaking this allocation assessment review, in that it could be used to benchmark the above observations.
5.2.17 Similarly, undertaking a real-time assessment of the likely release of voidspace at Ashdown Brickworks, in conjunction with the owners, in order to begin to accurately quantify the amount and timing of voidspace release, would also help underwrite the Councils position in relation to sustaining any allocation of landraise capacity.
5.2.18 Based on a consideration of the adopted Waste Local Plan and associated background studies, assessments of potential capacity were made of each site in the ‘existing’, ‘allocated’ and ‘generic potential land-raising’ categories, as is detailed below.
Table 5.1 Sites considered in this assessment, together with their original derivation EXISTING SITES ESTI. CAPAPCITY (mcm) Status Pebsham Existing 0.40 Planning permission September 08 permission 0.49 Assumed released 09/10
ALLOCATED SITES ESTI. CAPAPCITY (mcm) Status Beddingham Zero WLP Policy 10. Site closed and application for additional capacity not expected and unlikely to receive support from statutory environmental bodies. Ashdown Brickworks Existing assessed at 1.5 WLP Policy 10 See also below for future releases Unlikely to be released prior to early 2012 Ashdown Brickworks Maximum future assessed at 2.5 WLP Policy 10
2nd tranche 1.25 Assumed not released before 2022 3rd tranche 1.25 Assumed not released before 2032
GENERIC POTENTIAL LAND- ESTI. CAPAPCITY (mcm) Status RAISING Large land-raising site 2.0 – 3.0 WLP Policy 21 Assumed 2.5 assumed as realistic released 2012/13 Small land-raising site 1.0-2.0 WLP Policy 21. Release
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1.5 realistic assumed by 2016/17
Note – Black text as per ESCC/B&H information; Blue text as per this study’s interpretation and assumption
5.3 Ashdown Brickworks
Comment
5.3.1 Ashdown Brickworks is an operating brick production facility, and unless Ibstock Brick, as operator, is able/willing to consider early closure and/or sterilisation, the meaningful release of any landfill capacity can only be realised if both operations can be balanced. This position is likely to be further complicated in view of a third-party interest, which could constrain any potential release.
5.3.2 Any proposed development is considered unlikely to fail an RGN3 screening, by the very nature of the site’s geology.
5.3.3 Based on a working knowledge of the principles of the extraction of raw materials for brick manufacture, it is considered unlikely that the site can be developed in its entirety, as a single operation, if inputs of more than 100,000 tonnes/cubic metres per annum are to be considered. This is primarily as a result of the working methods used (typically blending during extraction), the method of extraction (typically ‘campaign’ extraction, once per year), the maximum output of the works (nominally approx. 40 million bricks/year, but significantly less at the time of writing) and the need to retain large areas for raw material stocking (typically substantial).
5.3.4 On the basis of a preliminary assessment, which takes account of information in the Waste Local Plan, it is considered that a substantial restructuring of raw material extraction methods would be necessary to realise an initial tranche of not less than 1.5 million cubic metres capacity. This activity would realise a stockpile of greater than 1 million cubic metres of clay, plus almost the same of over- and inter-burden, predominantly sand. It is also considered that it would be virtually certain that there would then of necessity be a break, perhaps of 10 years or so, before the next ‘tranche’ of airspace, say a further 1 million cubic metres or so, could be released by a repeat activity, again leading to the establishment of significant stockpiles.
5.3.5 Key issues are the necessary mass of the stockpiles, together with the fact that, in order to release each subsequent ‘tranche’, all stocked material would need to be removed off-site, either as bricks (the brick-shale), as permitted, or ‘other’ product (the sand), for which no permission currently exists. This would most probably result in a stop-start release of airspace, which could potentially compromise the development/operation of the facility as a landfill site. The potential capacity of Ashdown Brickworks is further constrained by environmental and amenity issues noted in the Waste Local Plan, including road access, ecological issues and impacts on residential properties.
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Voidspace assessment
5.3.6 Voidspace assessment is difficult in the absence of detailed operational drawings, particularly in terms of land release patterns, as these will heavily constrain landfill capacities.
5.3.7 An initial assessment, based on releasing not more than 85% of the 32.6Ha overall site area, using the quoted maximum potential release of 4 million cubic metres, would equate to an average waste depth of a little under 14.5m. This is considered realistic, and would realise a waste depth of up to some 25m or so, a release of voidspace of this depth is considered well within industry norms.
5.3.8 A staged release of up to 4 million cubic metres of voidspace is considered a realistic assessment, subject to the need to overcome the constraints identified in the Waste Local Plan and only spread over a total period of some 30-40 years or so, in order to protect brickshale reserves. An initial release of not less than 1.5 million cubic metres would be unlikely to be followed by a subsequent release within 10-15 years or so, and, although the potential to release a substantial proportion of the remaining capacity at this time cannot be ruled out, as in Table 5.1 above, a staged release has been assumed as a conservative basis.
5.4 Generic potential land-raising capacity
5.4.1 Using ‘typical’ industry guidelines, and a consideration of background work undertaken to inform the preparation of the Waste Local Plan, a provisional and high-level assessment was made of the likely typical capacity of generic land-raising sites in the core strategy area. It was assumed that the precise nature/extent of any release could logically be designed around 1- years’ needs, thereby providing for the progressive removal of land from, and return to, agricultural use.
5.4.2 A generic ‘large’ land-raising site could have a nominal footprint of 70% of a 70Ha site, the remainder being retained for screening and other operational issues, suggesting a nominal landraise area of 50Ha. This ‘loss’ of area is considered not untypical for the industry, and is a reflection of a typical need for land for screening or other amelioration areas.
5.4.3 Typically for the topography of areas of the core strategy area that could be geologically suitable for land-raising, a 50Ha footprint would infer an average waste depth of between 4 and 8 metres across the whole site. At 4 metres this is considered outside industry norms, and at 8 metres it is close to being so.
5.4.4 An average notional capacity for a ‘large’ land-raising site was therefore assumed to be 2.5 million cubic metres, on the basis that this ought to represent a conservative voidspace release.
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5.4.5 A generic ‘small’ land-raising site was assumed to extend to some 35Ha. For this area, the release of 1.7 million cubic metres of voidspace, based on the 70% availability filter referred to above, effectively releases an average waste depth of 7m or so – just less than the effective minimum referred to above. Although this average waste depth would be on the borderline of that acceptable to the industry, an average notional capacity of a ‘small’ land-raising site of 1.5 million cubic metres, reflecting a reduced area release (within increased depth) was assumed to be deliverable for the purposes of the capacity gap review.
5.5 Land disposal capacity gap analysis
Background and Inputs
5.5.1 Table 5.2 illustrates the contribution that potential land disposal capacity identified in Section 5.2 – 5.4 might make towards meeting the land disposal capacity gap identified in the WMCS preferred strategy, which is between 3.2-3.7 million tonnes over the plan period. The apportionment of London’s waste allocated to East Sussex and Brighton & Hove in South East Plan Policy W3 is 1.65mt between 2006 and 2025.
5.5.2 Table 5.2 illustrates how the assumed contribution of Ashdown Brickworks and generic land- raising sites might contribute to meeting the estimated land disposal capacity gap. The different scenarios take account of the exclusion or inclusion of London’s waste and the estimated minimum and maximum contribution from Ashdown Brickworks. In order to make a comparative illustration, each scenario assumes a fixed capacity contribution from generic large and small land-raising sites. An interpretation of the capacity gap scenarios is provided below.
Scenario 1 assumes only East Sussex and Brighton & Hove waste is planned for and the minimum contribution from Ashdown Brickworks. Under this scenario, 1.95mt of capacity would be required from land-raising, which could be delivered by one large land-raising site.
Scenario 2 assumes only East Sussex and Brighton & Hove waste is planned for and the maximum contribution from Ashdown Brickworks. Under this scenario, no land-raising capacity would be required.
Scenario 3 assumes East Sussex and Brighton & Hove waste plus the London’s waste apportionment is planned for and the minimum contribution from Ashdown Brickworks. Under this scenario, 3.6mt of land-raising capacity would be required, and one large land- raising site plus and additional smaller site would be required to meet the capacity gap.
Scenario 4 assumes East Sussex and Brighton & Hove waste plus the London’s waste apportionment is planned for and the maximum contribution from Ashdown Brickworks. Under this scenario, 1.1mt of land-raising capacity would be required and therefore only one small land-raising site would be required.
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Table 5.2. Contribution of potential capacity to meeting the capacity gap
Capacity East Sussex and Brighton & Hove East Sussex and Brighton & Hove + Contribution waste only: London’s waste Apportionment Capacity gap = 3.45*mt Capacity gap = 5.10**mt Scenario 1 Scenario 2 Scenario 3 Scenario 4 Ashdown 1.5mt 4mt 1.5mt 4mt Brickworks Large land- 2.5mt Not required 2.5mt Not required raising site (2.5mt) Small land- Not required Not required 1.5mt 1.5mt raising site (1.5mt)
Notes.
*3.45mt is median cumulative land disposal capacity requirement estimate, taken from Table CS2, WMCS preferred strategy document (October 2009).
** 5.10mt is median cumulative land disposal capacity requirement estimate, taken from Table CS2, WMCS preferred strategy document (October 2009)), plus London’s waste apportionment (1.65mt) taken from South East Plan, Policy W3.
5.5.3 When assessing potential demand against potential voidspace release, a number of assumptions become crucial, namely:
• The basis for the commencement of the assessment, i.e. the ‘base year’;
• Annual consumption predictions - in this case the WMCS Preferred Strategy data, Table 7 and CS2 - is used to determine the overall capacity gap estimate for the life of the WMCS.;
• Whether out-of-county demand is included, or not – in this case London’s waste has been both included and excluded, to demonstrate the impact of accepting it;
• Likely voidspace release amounts and nominal dates; and
• A conversion rate, if applicable, between tonnes and cubic metres – in this case a 1:1 ratio is used, based on industry experience.
5.5.4 In modelling future demand, and therefore any capacity gap, a further release of 490,000 cubic metres is allocated for 2010, nominally split between 2009/10 and 2010/11, identified as the recent extension at Pebsham in Table 5.1. To this is also added:
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• Ashdown Brickworks – assumed release of not less than 1,500,000 cubic metres in 2012, together with an additional 1,250,000 cubic metres in 2022 and 2032 – subject to confirmation; • One large land-raising site – assumed release of 2,500,000 cubic metres in 2013/14; and • One small land-raising site – assumed release of 1,500,000 cubic metres in 2016/17.
5.5.5 In reality, the precise order in which the above releases occur is not absolutely relevant, only that there is a release of a suitable amount at suitable intervals as allows engineering prior to use.
5.5.6 It is noted in the adopted Waste Local Plan that the availability of capacity at Ashdown Brickworks is limited by site access constraints and other issues. The Waste Local Plan refers specifically to the implementation of the Bexhill-Hastings link road and the ‘County Ave’ link to the proposed access road. It is understood that the Bexhill-Hastings link road is unlikely to be operational before 2012 and there are no committed plans for the implementation of the ‘County Ave’ link. Further, the engineering considerations outlined in Section 5.3 indicate that there is considerable doubt as to whether the full potential capacity of Ashdown Brickworks could be released within the period covered by the core strategy. These considerations would not appear to justify a strategy of reliance on capacity being provided by Ashdown Brickworks alone.
5.5.7 Consequently, if planning for East Sussex and Brighton & Hove waste only, of the scenarios presented in Table 5.2, Scenario 1 might be considered the most likely, requiring as a minimum Ashdown Brickworks plus one large land-raising site. If the WMCS had to plan for provision for the SEP apportionment of London’s waste, in addition to East Sussex and Brighton & Hove waste, Scenario 3 might be considered the most likely of those presented in Table 5.2, involving a requirement for the equivalent of at least one large land-raising site plus an additional small land-raising site.
5.5.8 In summary, the provisional capacity gap analysis described above indicates that planning for the apportionment of London’s waste in East Sussex and Brighton & Hove would be likely to involve the need for an additional land-raising site to that required for the management of East Sussex and Brighton & Hove alone. Additionally, the timing of any release of capacity remains crucial if long-term out-of-county disposal is to be avoided. Further assessment of the implications of the timing of capacity availability in the light of operational and environmental constraints is recommended to provide clarification on the capacity gap issue.
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5.6 Accessibility assessment of potential land disposal sites
Transport Assessment
Context
5.6.1 When considering how far waste might travel under what circumstances, it is important to note that it is more often than not travel time that is the more important function than the distance travelled. The reasons for this are based around maximising the number of collection/disposal trips per working day, rather than the absolute distance travelled, as for the most part, fuel costs represent a single element of operating an HGV.
5.6.2 Travel-time input assumptions used in this assessment are based around:
• nominal HGV speeds of not more than 60mph on dual-carriageway A-roads and motorways, 40mph on single carriageway A-roads/good quality B-roads and 20mph elsewhere;
• travel preferences using the quickest, rather than the shortest, routes; and
• point-to-point transfer, i.e. from a central loading point at the source to a single disposal point, i.e. a single landfill to which all waste is delivered
Travel-times between London and Counties to the South
5.6.3 This assessment looks at nominal travel times for HGVs between:
• initial ‘production’ centres and the closest non-London landfill sites, as derived from 2006 REGIS and RATS databases, as produced by the Environment Agency, using nominal West London boroughs (Hillingdon transfer station, as used for rail-borne waste sent to Oxfordshire); nominal South London boroughs, as typified by LB Sutton; and nominal South-East London boroughs, as typified by LB Bexley;
• landfill sites closest to the southern extent of the capital, i.e. Surrey and Kent;
• landfill sites slightly further a-field still, in the north of East and West Sussex; and
• landfill sites closest to the Channel, i.e. those furthest from the capital.
5.6.4 Figure 4, below, illustrates that these filters confirm travel times to be:
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• generally less than 30 minutes, and always less than 45 minutes, between individual borough sources and the closest landfill sites to the south of the capital;
• in excess of 40 minutes between first-line sites to the south of the capital and those ‘immediately’ to the south; and
• generally in excess of 60 minutes to those most distant from the capital
5.6.5 Once loaded for transfer, i.e. collection from a single point, such as a transfer station, and delivery to a second single point, such as a landfill site, industry experience suggests that the maximum vehicle travel time acceptable is around 60 minutes.
5.6.6 The above therefore suggests that while transfer delivery by road from the southern-most London boroughs to those landfill sites closest to the capital will, and indeed, is happening, onward travel becomes increasingly unlikely the further south the process requires waste to travel.
5.6.7 This means that it is unwise to derive a strategy that relies on waste from London being disposed of directly into East Sussex.
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Figure 4
Draft Report 59 October 2008 travel times by road - London and East Sussex
0 mi 10 20 30 40 Copyright © 1988-2005 Microsoft Corp. and/or its suppliers. All rights reserved. http://www.microsoft.com/autoroute/ © 1993-2004 NAVTEQ and its suppliers. All rights reserved. Residual Waste from London Study
Ripple-effect Travel Times by Road
5.6.8 This assessment looks at nominal travel times for HGVs between:
• those centres of population from which waste might be deposited in landfills closest to London; and
• those centre of population more removed from the capital, to which waste could be displaced were capacity at those receiving waste from London to be protected.
5.6.9 Figure 5, illustrates that these filters confirm travel times to be:
• generally less than 30 minutes, and always less than 45 minutes, between individual source towns and the closest landfill sites to the south of the capital;
• rarely less than 30 minutes, and frequently in excess of 40 minutes, between individual source towns and those first-line sites further to the south of the capital; and
• generally in excess of 40 minutes, and possibly in excess of 60 minutes, to those sites closest to the Channel in East Sussex to which more distant displacement ultimately determines
Key displacements used to judge the system are:
Town Current Disposal Travel time Possible Travel time Location alternative disposal location(s) East Grinstead Brookhurst Wood 30 mins Redhill 30 mins Beddingham 30 mins Pebsham 75 mins Crawley/Horsham Brookhurst Wood <10 mins Horton 30 mins Beddingham 30 mins Royal Tunbridge Bakers Wood 30 mins Redhill 40 mins Wells Beddingham 40 mins Pebsham 50 mins Maidstone Bakers Hole 30 mins Canterbury 40 mins Pebsham 65 mins Lewes Beddingham <10 mins Pebsham 30 mins Brighton Beddingham 20 mins Lidsey 40 mins
5.6.10 Once loaded for ‘normal’ delivery, i.e. collection from single or multiple points, such as a household or business, with delivery to either a transfer station or landfill, industry experience suggests that the maximum travel time acceptable is around:
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• 30 minutes for what might be considered as single-trip vehicles, e.g. RCVs and skip- motors; and
• possibly as much as 45 minutes for commercial, ‘mobile compaction’, vehicles.
5.6.11 The above therefore suggests that while displacement from towns in Surrey and northern Kent either further into West Sussex or southern Kent (respectively) is theoretically possible, displacement thereafter from either county into East Sussex is extremely unlikely. Further, displacement from East Sussex into West Sussex or Kent would, under normal circumstances, be almost impracticable, if assessed purely on the above travel-time basis. However, on the basis of there being no alternative land disposal capacity in East Sussex, as is essentially the case at present, on a ‘needs must’ basis such displacement must already be happening.
5.6.12 This means that it is unwise to derive a strategy that relies on waste being displaced from Surrey and Kent into East Sussex for land disposal. Likewise, it is similarly unwise to assume that waste displaced from within East Sussex will, on a long-term, basis, travel to either West Sussex or Kent for final disposal to land, unless some form of transfer/bulking arrangement is established to off-set cost penalties.
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Figure 5
Draft Report 62 October 2008 ripple theory travel times by road
0 mi 10 20 30 40 Copyright © 1988-2005 Microsoft Corp. and/or its suppliers. All rights reserved. http://www.microsoft.com/autoroute/ © 1993-2004 NAVTEQ and its suppliers. All rights reserved. Residual Waste from London Study
5.6.13 Of additional relevance to a ‘ripple effect’ theory is the ability/attitude of collection organisations to vary their disposal points. Commercial collection companies have the ability to do this, subject to contractual arrangements and commitment, relatively easily. Local authority collection organisations, which are frequently contracted-out (i.e. operated under contract by a private sector company), are less flexible, in that they are frequently unable to tip out-of-county without attracting additional travelling costs – which have to be paid by the disposal authority.
5.6.14 This tends to restrict out-of-county disposal, unless it is specifically provided for in the relevant contracts, and therefore hampers any ‘ripple’ enactment.
5.7 Industry and associated interested party observations
Background
5.7.1 Controlled contact has been made with 4 groups across the waste industry, as is reported in Section 2:
• Producers – i.e. London boroughs;
• Strategists – i.e. EA, SEERA, ESCC/B&H;
• Managers – i.e. private sector waste management companies; and
• Trade/other interested bodies – i.e. ESA, LGA, ESA, etc.
all of whom were questioned on the principles and practices associated with the apportionment of London’s residual waste for disposal across the South East region, and specifically into East Sussex.
5.7.2 Contact took the form of:
• Face-to-face discussions;
• Telephone discussions; or
• An exchange of emails,
all to a common format, but with questions skewed to reflect the different interests of each group.
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Output
5.7.3 Details of individual contact and comment are held under a commitment of confidentiality, but can be summarised as below.
• Producers – do not see a future need for a significant reliance on disposal capacity in East Sussex and Brighton and Hove, as incoming treatment capacity is anticipated to reduce residual waste to below that used in the prediction process that led to the apportionment tonnages, and could therefore expect to continue to use current routes;
• Strategists – see importance in retaining the apportionment principle, and were generally not prepared to offer comment so as to countermand this;
• Managers – generally see the apportionment exercise as flawed, depending on where the assets of those commenting are located (as recognised in submissions to the EIP process), but nevertheless cannot envisage London’s residual waste travelling by road to East Sussex because of the distances and times involved, nor by rail to ‘small’ sites, i.e. those without major available capacity, as are available elsewhere and therefore currently receive London’s waste; and
• Trade/other bodies – comment by and large was as per the strategists, although ESA advises support in principle, subject to recognition of EPI comments by it members,
5.7.4 No-one who responded to the questionnaire could envisage a ‘ripple-effect’ working in practice, unless there was a significant delay in delivery of waste management infrastructure across London.
5.7.5 On the basis of the above analysis, it is clear that, while apportionment is accepted as a principle, as reflected in a number of EIP submissions it is considered that:
• Waste will not travel directly by road to East Sussex, and, in the absence of current rail links or of sites perceived to be sufficiently large (and therefore long-term), by rail – conversely, the delivery of large-scale infrastructure could not be envisaged in the absence of substantial landfill reserves with which to underwrite it;
• The principle of a ‘ripple effect’ remains just a principle – and no-one truly envisages it becoming a functional reality; and
• Apportioned tonnages ought to reflect the fact that realistic releases of post-mineral extraction, RGN3-compliant, airspace are likely to be restricted to those authorities with appropriate extraction history and geology, primarily Oxfordshire, Bedfordshire and Buckinghamshire.
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5.8 Summary and Conclusions
5.8.1 It is possible to summarise the above assessments reported in Section 5 as follows.
• There is insufficient potential mineral-excavation based voidspace available in East Sussex to begin to satisfy landfill demand.
• No specific allocations of land-raising sites were made in the Waste Local Plan. Some broad areas of search for land-raising are identified in the emerging WMCS, but there is no reliable estimate of potential land-raising capacity. Notional ‘large’ and ‘small’ scale land- raising capacity in the WMCS area was estimated to be 2.5 and 1.5 million tonnes respectively.
• Capacity gap modelling suggests that:
• in the absence of London’s apportionment, sufficient land disposal capacity might be realised through a single large land-raise site, in addition to Ashdown Brickworks, but;
• if London’s apportionment is included, at least two further land-raise sites in addition to Ashdown Brickworks will be required.
• The transport assessment indicates that;
• direct delivery from London to East Sussex is unlikely ever be a realistic possibility, for reasons of travel time and an absence of long-term recipient land disposal sites; while
• any theoretical ‘ripple-effect’ is equally unlikely to develop, for the same reasons, unless on a short-term, ‘needs must’ basis.
• 1 to 1 discussions with interested industry parties suggests that;
• not only do few of them anticipate there being any need for London’s residual waste to be considered for landfill disposal in East Sussex;
• the majority cannot see a ‘ripple effect’ developing; while
• possible producers across the southern and western portions of the capital itself believe that predicted residual tonnages are significantly overstated in the first instance.
5.8.2 As a result of the above, it may be concluded that:
• landfill voidspace is sufficiently scarce in ESCC/B&H as to warrant against the principle of accepting any of London’s waste;
• landfill voidspace may not even be available for apportionment in the first place; and
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• even if it were allocated, it would almost certainly not be considered suitable for delivery by road, whether by direct or displacement (ripple-effect) delivery.
5.8.3 In the absence of rail-transport, again rendered unrealistic in the absence of long-term land disposal capacity, these conclusions strongly indicate against East Sussex and Brighton & Hove accepting an apportionment of waste from London ever being a practicable scenario.
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6 A critique of the Apportionment Methodology Using Sustainability Appraisal Techniques
6.1 Methodology
6.1.1 Using the original SA Framework and matrices (derived from the Draft South East Plan SA) a revised appraisal of the four options put forward for the apportionment methodology was undertaken, taking into account baseline data obtained from existing documents, data collation and web-based sources. The same regional SA framework was used for the re-appraisal to allow direct comparison. The refined sub-options for Option 4 (apportionment based on capacity evaluation together with other environmental, social and economic factors) were not re-appraised in light of the lack of sensitivity of the weightings identified by objectors to the methodology.
6.1.2 In undertaking the re-appraisal, an assessment of the original appraisal methodology was undertaken and any obvious shortcomings were identified. An evaluation was carried out to determine how robust the original appraisal and conclusions reached were.
6.1.3 Following a re-appraisal of the four options, each option was assessed in light of its potential implications for East Sussex, given the constraints identified in the County. This provides an assessment of the implementation of each of the Options in the local context and highlights potential issues for East Sussex of the implementation of the different Options.
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SA FRAMEWORK Objective SA Objective Sub-objective Number To reduce the risk of flooding and the resulting 2.1 Prevent all inappropriate development in the flood plain 2 detriment to public well- 2.4 Ensure that development does not increase flood risk to being, the economy and others the environment To improve the health and well-being of the 3 population and reduce inequalities in health To improve efficiency in land use through the re- use of previously developed land and 10.5 Ensure that the historic urban environment and the 10 existing buildings, distinctiveness/character of urban areas in protected as part of including re-use of urban renaissance materials from buildings, and encourage urban renaissance 11.1 Promote more sustainable transport patterns in all areas, particularly those of poor air quality (e.g. AQMAs) including public transport, walking, cycling To reduce air pollution 11 and ensure air quality 11.2 Ensure the national air quality strategy objectives are not continues to improve breached 11.3 Address the air quality impacts arising from specific development activities (e.g. airports, energy generation, etc) To address the causes of climate change through reducing emissions of 12 greenhouse gases and ensure that the South East is prepared for its impacts 13.1 Protect, enhance and restore the region’s (international, national and local) designated areas To conserve and enhance 13 the region’s biodiversity 13.2 Protect, enhance and restore the region’s priority habitats and species, and ensure the delivery of regional biodiversity targets To protect, enhance and 14.1 Protect, enhance and restore the region’s natural make accessible for environmental assets (e.g. the Green Belt, parks and green 14 enjoyment the regions’ spaces, common land, woodland and forests, National Parks, countryside and historic AONBs, ESAs etc) environment 14.2 Protect, enhance and restore the region’s cultural and
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SA FRAMEWORK Objective SA Objective Sub-objective Number heritage assets (e.g. Heritage Coasts, World Heritage Sites, SAMs, Listed Buildings, Historic Parks and Gardens, Conservation Areas, Registered Battlefields, etc) To reduce road congestion and pollution 15.1 Promote more sustainable transport patterns in all areas, 15 levels by improving travel particularly those with high congestion choice and reducing the need for travel by car/lorry 17.1 Promote sustainable waste management practices in all To reduce waste sectors and at all levels through implementation of the waste generation and disposal hierarchy and the provision of a range of appropriate waste 17 and achieve the management facilities, implementation of the proximity principle sustainable management of waste 17.3 Support implementation of the proximity principle and self- sufficiency
To maintain and improve to water quality of the region’s rivers and coasts 18 and to achieve sustainable water resources management To sustain economic growth and 21 competitiveness across the region
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6.2 Appraisal
6.2.1 The four Options appraised are outlined below:
• Option 1 - No Apportionment Option : This option represents a scenario where there is no waste accepted for disposal in the South East England Region from London. This would mean cessation of any existing contracts for London’s waste exports to the region and WPAs would not have to plan for London’s waste in their WDFs.
• Option 2 - Apportionment Based on Capacity Option : This option represents basing the apportionment solely on availability of landfill void space. This would mean only WPAs with surplus void over and above their own needs during the RSS period would be allocated an apportionment for London’s waste requiring disposal in South East England, irrespective of environmental and other constraints.
• Option 3 - Apportionment Based on Historic Trends Option : Historically, Buckinghamshire, Oxfordshire and Surrey were the main destinations for London’s waste landfilled in the South East region. This option seeks to continue this trend and would see the apportionment split between the WPAs that have historically landfilled London’s waste.
• Option 4 - Apportionment Based on capacity evaluation together with other environmental, social and economic factors : This option is based on a set of criteria including availability of surplus suitable void space, geological suitability, ground water protection, proximity to London and the potential for use of sustainable transport modes. It also takes into account environmental constraints such as nature conservation designations, landscape designations, flood risk areas and built up areas. This option also looks at any existing long term contracts that are committed for disposal in the region and whether any of these are rail based. This options forms the basis of the South East Plan Policy W3 for the apportionment of London’s waste to landfill in the South East.
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6.2.2 The symbols used in the appraisal matrices are similar to those used in the original appraisal:
Symbol Meaning
The Preferred Option is likely to have a significant beneficial effect on the SA / SEA Objective The Preferred Option is likely to have a beneficial effect on () the SA / SEA Objective but the effect is not likely to be significant The Preferred Option is likely to have an adverse effect on the () SA / SEA Objective but the effect is not likely to be significant
The Preferred Option is likely to have a significant adverse effect on the SA / SEA Objective
The Preferred Option is likely to have no effect on the SA / ~ SEA Objective
The effect of the Preferred Option on the SA / SEA Objective is ? unclear
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Option 1 - No Apportionment Option (No imports from London) Objective SA Objective Score Comments Number To reduce the risk of flooding and the resulting detriment to 2 ~ Having no imports from London will have no effect on flooding public well-being, the economy and the environment To improve the health and well-being of the population and Localised improvements to well-being for those close to (potential) 3 () reduce inequalities in health landfill sites To improve efficiency in land use through the re-use of There would be the potential for PDL to be utilised for other uses, as previously developed land and existing buildings, including re- 10 ? opposed to landfill, but this would be dependent upon the suitability use of materials from buildings, and encourage urban of individual sites and therefore the effect is unknown at this level renaissance Potential for reduced pollution – directly through lower To reduce air pollution and ensure air quality continues to concentrations of greenhouse gases associated with landfill e.g. 11 improve methane; indirectly through fewer transport movements associated with transporting waste from London Potential for reduced emissions through lower concentrations of To address the causes of climate change through reducing greenhouse gases associated with landfill e.g. methane and fewer 12 emissions of greenhouse gases and ensure that the South transport movements associated with transporting waste from East is prepared for its impacts London Any potential effects are likely to be indirect and minor and therefore 13 To conserve and enhance the region’s biodiversity ~ considered insignificant The requirement for fewer landfill sites to accommodate waste from To protect, enhance and make accessible for enjoyment the 14 () London will likely be positive for the countryside and maintain its regions’ countryside and historic environment accessibility and character To reduce road congestion and pollution levels by improving The need for travel by lorry will be reduced as waste will not be 15 travel choice and reducing the need for travel by car/lorry transported from London to the South East Will reduce waste disposal in the South East through not To reduce waste generation and disposal and achieve the 17 () accommodating waste from London and will encourage sustainable sustainable management of waste management of waste at source 18 To maintain and improve to water quality of the region’s rivers ~ No effects likely
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Option 1 - No Apportionment Option (No imports from London) Objective SA Objective Score Comments Number and coasts and to achieve sustainable water resources management The effect on the economy of not accommodating London’s waste is unclear – there is the potential for adverse effects on the waste To sustain economic growth and competitiveness across the 21 ? industry but such effects are unknown. There is also the potential for region the growth of other land uses on land that would have been utilised for landfill, but again the effect is unknown.
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Option 2 - Apportionment Based on Capacity Option (assume Buckinghamshire (incl. Milton Keynes), Surrey, Oxfordshire, Berkshire [according to Jacobs apportionment methodology report, 2005]) Objective SA Objective Score Comments Number Would be dependent upon the location of current/potential landfill To reduce the risk of flooding and the resulting detriment to sites. The Environment Agency flood risk maps show that some 2 ? public well-being, the economy and the environment areas of Oxfordshire are at greater risk of flooding than Surrey, Berkshire and Buckinghamshire. Concentrating apportionment in areas with capacity will likely reduce To improve the health and well-being of the population and 3 () well-being of the local population through increased traffic reduce inequalities in health movements and associated noise and pollution To improve efficiency in land use through the re-use of previously developed land and existing buildings, including re- Utilising existing landfill sites will make efficient use of land and 10 use of materials from buildings, and encourage urban negate the requirement for additional sites renaissance It is unlikely that this option would result in any significant effects when compared with the existing situation as there are existing rail- based contracts for the transportation of residual waste from London To reduce air pollution and ensure air quality continues to 11 ~ in Buckinghamshire and Oxfordshire, which reduces the effect of improve transport-based emissions and their effect on air quality. The counties with most existing capacity are also broadly better linked to London via the motorway network than those with less capacity. To address the causes of climate change through reducing It is unlikely that this option would result in any significant effects 12 emissions of greenhouse gases and ensure that the South ~ when compared with the existing situation. East is prepared for its impacts There is the potential for minor positive effects as utilising existing capacity at existing sites would benefit biodiversity through negating 13 To conserve and enhance the region’s biodiversity () the need for additional sites and therefore negating the potential adverse effects this might have on biodiversity. Utilising existing capacity at existing landfill sites will negate the need 14 To protect, enhance and make accessible for enjoyment the for additional sites and therefore protect the countryside from
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Option 2 - Apportionment Based on Capacity Option (assume Buckinghamshire (incl. Milton Keynes), Surrey, Oxfordshire, Berkshire [according to Jacobs apportionment methodology report, 2005]) Objective SA Objective Score Comments Number regions’ countryside and historic environment additional development It is unlikely that this option would result in any significant effects To reduce road congestion and pollution levels by improving when compared with the existing situation as there are existing rail- 15 ~ travel choice and reducing the need for travel by car/lorry based contracts for the transportation of residual waste from London in Buckinghamshire and Oxfordshire. It is not appropriate to utilise this objective as it relates to waste To reduce waste generation and disposal and achieve the generation and disposal in general and therefore it cannot be 17 ~ sustainable management of waste translated well for options relating to issues relating to the actual management and disposal of waste. Existing landfill sites are licensed by the Environment Agency and To maintain and improve to water quality of the region’s rivers water quality issues addressed through such licensing. The 18 and coasts and to achieve sustainable water resources ~ utilisation of existing capacity is therefore unlikely to affect water management quality. To sustain economic growth and competitiveness across the Economic growth for the waste industry and associated industries 21 () region will be supported in areas with landfill capacity
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Option 3 - Apportionment Based on Historic Trends Option (assume Buckinghamshire, Oxfordshire and Surrey) Objective SA Objective Score Comments Number Would be dependent upon the location of current/potential landfill To reduce the risk of flooding and the resulting detriment to sites. The Environment Agency flood risk maps show that some 2 ? public well-being, the economy and the environment areas of Oxfordshire are at greater risk of flooding than Surrey and Buckinghamshire. Concentrating apportionment in areas that have historically To improve the health and well-being of the population and accommodated waste from London will likely reduce well-being of 3 () reduce inequalities in health the local population through increased traffic movements and associated noise and pollution Utilising existing landfill sites will make efficient use of land. To improve efficiency in land use through the re-use of However, distributing apportionment based on historic trends does previously developed land and existing buildings, including re- 10 ? not consider whether there is the necessary capacity to use of materials from buildings, and encourage urban accommodate additional waste and therefore new sites could be renaissance required. It is unlikely that this option would result in any significant effects when compared with the existing situation as there are existing rail- To reduce air pollution and ensure air quality continues to 11 ~ based contracts for the transportation of residual waste from London improve in Buckinghamshire and Oxfordshire, which reduces the effect of transport-based emissions and their effect on air quality. To address the causes of climate change through reducing It is unlikely that this option would result in any significant effects 12 emissions of greenhouse gases and ensure that the South ~ when compared with the existing situation. East is prepared for its impacts The effects are unclear as there is the potential for both positive and negative effects on biodiversity – concentrating the accommodation of waste in areas currently utilised for such could benefit biodiversity 13 To conserve and enhance the region’s biodiversity ? through negating the need for additional sites elsewhere and therefore negating the potential adverse effects this might have on biodiversity. However, there is the potential for adverse effects if accommodating additional waste in these areas would ‘tip the
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Option 3 - Apportionment Based on Historic Trends Option (assume Buckinghamshire, Oxfordshire and Surrey) Objective SA Objective Score Comments Number balance’ and cause cumulative detrimental effects where such effects are currently minimal. Apportionment based on historic trends takes no account of the capacity of such areas to accommodate additional waste and To protect, enhance and make accessible for enjoyment the therefore it is unclear as to whether additional landfill sites would be 14 ? regions’ countryside and historic environment required to accommodate this waste. The effects on the countryside are therefore unclear and would be dependent upon the capacity of these areas and the potential requirement for additional landfill sites. It is unlikely that this option would result in any significant effects To reduce road congestion and pollution levels by improving when compared with the existing situation as there are existing rail- 15 ~ travel choice and reducing the need for travel by car/lorry based contracts for the transportation of residual waste from London in Buckinghamshire and Oxfordshire. It is not appropriate to utilise this objective as it relates to waste To reduce waste generation and disposal and achieve the generation and disposal in general and therefore it cannot be 17 ~ sustainable management of waste translated well for options relating to issues relating to the actual management and disposal of waste. To maintain and improve to water quality of the region’s rivers Existing/potential landfill sites are licensed by the Environment 18 and coasts and to achieve sustainable water resources ~ Agency and water quality issues are addressed through such management licensing. To sustain economic growth and competitiveness across the Economic growth for the waste industry and associated industries 21 () region will be supported in these areas
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Option 4 - Apportionment Based on capacity evaluation together with other environmental, social and economic factors (availability of void space, geological suitability, ground water protection, proximity to London, potential for use of sustainable transport modes, nature conservation and landscape designations, flood risk) Objective SA Objective Score Comments Number To reduce the risk of flooding and the resulting detriment to Flood risk will be taken into consideration when determining 2 public well-being, the economy and the environment apportionment To improve the health and well-being of the population and Effects unclear as it will be dependent upon the distribution of the 3 ? reduce inequalities in health apportionment To improve efficiency in land use through the re-use of previously developed land and existing buildings, including re- Effects unclear as it will be dependent upon the location of sites, as 10 ? use of materials from buildings, and encourage urban opposed to the level of apportionment renaissance Potential for reduction in air pollution if counties in close proximity to London were allocated a higher apportionment than outlying To reduce air pollution and ensure air quality continues to 11 () counties. However, proximity is only one factor to be considered and improve therefore any benefits could be considered to be minor in light of the factoring of other issues To address the causes of climate change through reducing Transporting waste to outlying counties in the South East will 12 emissions of greenhouse gases and ensure that the South () increase transport-related emissions; however, the consideration of East is prepared for its impacts proximity and sustainable transport could reduce this effect. The effects are unclear as there is the potential for both positive and negative effects on biodiversity – considering nature conservation designations in determining apportionment will benefit biodiversity. Conversely, the potential for additional transport movements would likely increase transport-related emissions, which have the potential 13 To conserve and enhance the region’s biodiversity ? to adversely affect both habitats and species through increased deposition of pollutants. Also, there is the potential for adverse effects if accommodating additional waste in an area would ‘tip the balance’ and cause cumulative detrimental effects where such effects are currently minimal.
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Option 4 - Apportionment Based on capacity evaluation together with other environmental, social and economic factors (availability of void space, geological suitability, ground water protection, proximity to London, potential for use of sustainable transport modes, nature conservation and landscape designations, flood risk) Objective SA Objective Score Comments Number Potential benefits in terms of protecting the countryside as landscape designations would be considered. However, areas of countryside To protect, enhance and make accessible for enjoyment the not covered by landscape designations would not be considered; 14 () regions’ countryside and historic environment landscape is only one factor to be considered, therefore any benefits could be considered to be minor in light of the factoring of other issues. The effects of transportation are unclear. Transporting London’s waste across the South East will likely contribute to increased congestion and increase the need to travel by lorry. However, such effects will be dependent upon the proximity to London and could be To reduce road congestion and pollution levels by improving 15 ? reduced if areas closer to London are utilised. Such effects could travel choice and reducing the need for travel by car/lorry also be reduced if sustainable transport modes are utilised. Given that proximity and sustainable transport are only two factors to be considered the effects will be dependent upon the distribution of apportionment. It is not appropriate to utilise this objective as it relates to waste To reduce waste generation and disposal and achieve the generation and disposal in general and therefore it cannot be 17 ~ sustainable management of waste translated well for options relating to issues relating to the actual management and disposal of waste. To maintain and improve to water quality of the region’s rivers Existing/potential landfill sites are licensed by the Environment 18 and coasts and to achieve sustainable water resources ~ Agency and water quality issues are addressed through such management licensing. The economics of waste disposal largely dictates the viable locations for such activities, based on the cost of transport. The potential for To sustain economic growth and competitiveness across the 21 () the requirement for additional landfill sites in areas that do not have region an economically viable waste industry at the current time could result in reduced viability within the industry.
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6.3 Summary of sustainability appraisal findings
6.3.1 The appraisal for Option 1 indicates that, overall, the option is likely to result in positive effects.
6.3.2 The tests of soundness outlined in PPS12 state that alternatives should be ‘reasonable’ and that there is no point in inventing alternatives if they are not realistic. In the context of national waste planning policy, it is very unlikely that the South East Region would stop taking an apportionment of the residual waste from London. It could therefore be argued that Option 1 is not a ‘reasonable’ option and should not therefore be included in the Appraisal.
6.3.3 Additionally, cross boundary impacts were considered in the original SA. Given that the SA was focussed on the likely effects in the South East region, and that no scoping (baseline information assembly) was undertaken for areas outside the South East, it is considered inappropriate to draw SA conclusions on cross-boundary issues.
6.3.4 Of the three apportionment options, option 2, based on land disposal capacity performs best in sustainability appraisal terms. This is largely a due to the fact that the option would direct land disposal to suitable former mineral void capacity, some of which is linked to London by rail, and avoid the potential impacts associated with developing new capacity at green field sites at locations further afield.
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6.4 Assessment of the original SA methodology and conclusions
6.4.1 An assessment of the original Sustainability Appraisal and its conclusions raises fundamental questions in relation to the robustness of the appraisal and therefore the validity of the conclusions reached. There are various aspects of the original SA that appear to be inherently flawed and this casts doubt on the conclusions reached.
Baseline data
6.4.2 The SA does not appear to take account of baseline information relating to the sustainability objectives, which results in an appraisal that does not consider the implications of implementing the different options at the county/local level at which the effects will be felt.
Options
6.4.3 The details provided for each of the different Options are inconsistent and for Option 2 do not provide enough relevant information for the Option to be appraised. The assumptions made for each of the Options are not clearly set out and the lack of clarity and consistency raises questions as to the validity of the Appraisal.
6.4.4 The appraisal for Option 1 takes account of the potential effects on other regions of accommodating waste from London. However, the purpose of the SA is to appraise the effects of the different Options on the South East region and therefore such consideration of effects elsewhere is not appropriate and skews the results of the appraisal.
Comparison of Options
6.4.5 The appraisals of Options 2 & 3 make mention of the fact that that the Option gives no consideration to environmental constraints. However, this does not necessarily mean that the options are inherently negative for the environment as this would be dependent upon the implementation of the options in relation to the baseline situation (issues relating to the baseline data are discussed above). The fact that the appraisal of these options mentions the consideration of environmental constraints suggests that they are being compared with Option 4, the option that was taken forward for the methodology for the apportionment of London’s waste. However, the other appraisals do not appear to be comparative to each other and this raises questions as to the objectivity of the appraisal methodology.
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Implications for East Sussex
6.4.6 The SA for the apportionment methodology looks at four different alternatives and their effects on the sustainability objectives for the South East region. A further alternative might be that the apportionment for the region is calculated without the inclusion of East Sussex. Whilst it would be inappropriate to use the SA methodology to consider this option without testing the various other alternatives possible through the exclusion of other counties, or combinations of counties, the impact on the SA objectives in East Sussex and Brighton & Hove under each option can be separately considered, as set out below.
Option 1 - No Apportionment Option
6.4.7 There would be no effect on East Sussex if this option was taken forward as the county does not currently accommodate waste from London.
Option 2 - Apportionment Based on Capacity Option
6.4.8 There would be no effect on East Sussex if this option was taken forward as the county does not have surplus capacity to accommodate waste from London – the data from the Environment Agency indicates that East Sussex currently has limited capacity to accommodate its own waste.
Option 3 - Apportionment Based on Historic Trends Option
6.4.9 There would be no effect on East Sussex if this option was taken forward as the county has not historically accommodated waste from London.
Option 4 - Apportionment Based on capacity evaluation together with other environmental, social and economic factors
6.4.10 There would likely be significant adverse effects on East Sussex and Brighton & Hove if this option was taken forward:
• Flood risk – areas around Lewes, Eastbourne and Rye are particularly at risk from flooding and any additional landfill sites would need to be located away from these areas.
• Land use efficiency – There very unlikely to be sufficient and suitable previously developed land available to accommodate all of the capacity requirements of the apportionment policy. It is almost certain that if the Strategy area were to accommodate its apportioned amount of waste, new Greenfield landraising sites would have to be developed.
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• Air pollution – transport-related air pollution is an issue in some parts of East Sussex and two Air Quality Management Areas have been declared in central Lewes and coastal Hastings. The Hastings area AQMA is very likely to be adversely affected due to the location of the main land disposal capacity in the Strategy area. Further, additional transport in the county as a result of additional waste being transported from London could lead to additional air quality issues in other areas of the county, particularly due to the poor quality and congested nature of the strategic road network in the Strategy area.
• Biodiversity – East Sussex contains many different habitats and there are several areas within the county that are designated for their nature conservation importance. Any requirement for additional landfill sites would need to take biodiversity and the environment into consideration as part of the requirements of the NERC Act 2006. Further, the requirement to develop Greenfield sites indicates a degree of biodiversity impact that would not occur if existing capacity outside the Strategy area were to be used.
• Countryside and historic environment – A large proportion of East Sussex is subject to national landscape/countryside designations (AONB, National Park) and contains several historic settlements (Lewes, Hastings). Accommodating additional waste from London would require additional landfill capacity and such designations would need to be taken into consideration when determining suitable locations for this. Given the extent of AONB designations, it is likely to be difficult to find locations for land-raising which do not adversely impact on AONB of National Park.
• Road congestion and reducing the need to travel – The road network in East Sussex is such that it consists of primary A-roads and local rural roads; there are no motorways in the county. The major routes suffer with congestion and road transport is anticipated to increase in the future. Additional landfill requirements in the county to accommodate waste from London will likely exacerbate existing congestion issues on the primary road network. In terms of rail transport, there are no rail depots to handle freight within the county.
• Sustainable waste management – Disposing of waste at locations that are not consistent with the principle of disposal at the nearest appropriate location, as established in PPS10, inherently works against achieving sustainable waste management.
• Water quality - The geology of East Sussex is such that there only very limited areas that are suitable geologically for land disposal. Realistically, potential areas for landfill in East Sussex are restricted to the central area of the county, between the South Downs and High Weald AONBs. These areas are not generally well served by the strategic road network and are not close to either the main population centres or main access points of the Strategy area.
• Economic growth – The existing geography of the disposal of London’s waste is largely driven by economic considerations and the location of suitable void capacity. The apportionment policy works against economically viable options by artificially directing waste across longer distances that would otherwise be economically viable. It can be concluded that the apportionment policy would have a negative impact on the viability of the waste industry, which would in turn be passed on to consumers, i.e. businesses and the public.
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7 Conclusions
7.1 Introduction
7.1.1 This concluding section uses the evidence accumulated in Sections 2-6 of this report to consider whether it is appropriate for East Sussex and Brighton & Hove to plan for the apportionment allocation of London’s waste set out in the South East Plan.
7.2 Policy Context
7.2.1 Policy W3 of the South East Plan deals with regional self sufficiency and requires that waste planning authorities plan for capacity for London’s exported waste to landfill, in accordance with apportionment figures tabulated in the Policy. The policy states that the apportionment figures “ should be used as a benchmark for the production and testing of development plan documents, but WPAs should use more recent data where this is available in order to assess and plan for capacity .”
7.2.2 Policy W4 of the South East Plan breaks down the regional self sufficiency concept of Policy W3 into delivery though net sub-regional self sufficiency. In terms of a requirement to manage a proportion of London’s waste, the policy states that “where appropriate ” (and in line with Policy W3) waste planning authorities should plan for capacity for waste from London.
7.2.3 The wording of South East Plan policies W3 and W4 explicitly allows each waste planning authority to test the appropriateness of meeting the apportionment of land disposal capacity for London’s Waste. The testing of regional policy should be carried out in the light of more detailed, locally based evidence. Such evidence is gathered together in this report and the findings of the testing process are summarised in the remaining parts of this section.
7.3 Concluding Assessment
7.3.1 This concluding section draws from the relevant themes of objection to the apportionment concept and methodology that were examined at the RSS EiP. These themes are identified in Table 2.2 of this report, which is reproduced below.
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Table 2.2 Main Themes of Objection Considered at EiP Theme EiP Panel Response
The Panel found the modelling approach well founded and Realism and deliverability. Waste won’t travel by road transparent, but supported that concept of the figures beyond sites close to London (practical and being tested at the WDF stage. economic issues). Areas such as East Sussex and
Hampshire don’t have sufficient capacity , due to The Panel advocated the ‘ripple effect’ as a counter to environmental and geological constraints, to dispose of arguments about waste not travelling to areas towards the their own waste. periphery of the South East Region. Response favoured a single apportionment, as this Deferment. It will take time to move from the current approach provides a clear policy message, with greater geographical pattern of the disposal of London’s waste chance of influencing policy (plan provision) and to a pattern driven by the apportionment methodology. industry planning, more quickly. Also the Panel noted It is not appropriate to apply the apportionment from that it would be difficult to set a base date for a current 2006. pattern of disposal, as this would be very sensitive to a few major contracts. “The (modelling) work looked comprehensively at a Methodology robustness. The apportionment range of relevant criteria, which largely corresponded methodology itself, i.e. the criteria and the way they are with those recommended by the last EiP.” The Panel modelled, and the evidence base, is not robust. found the modelling approach “well founded and transparent”. Delivering necessary capacity. The policy will result in Not directly addressed. The report notes that the under-provision for the amount of capacity for London’s principle of the amount of London’s waste to be waste where this is required, and will make it more apportioned was not an area for discussion at the EiP. difficult to secure planning permission for new capacity in areas where such capacity is more readily available and environmentally and commercially deliverable.
7.3.2 The main relevant theme of objection is that of ‘realism and deliverability’, i.e. a combination of practicality, environmental impact and economics. The ‘deferment’ theme is not relevant to the East Sussex and Brighton & Hove WDF Core Strategy, given the programme to adoption. The ‘methodology robustness’ theme relates largely to differing views about the level of detail of the baseline data used and the weighting applied to the various criteria. The EiP Panel report considered the modelling approach well founded and transparent. The robustness of the assumptions underlying the model is best considered as part of an assessment of the ‘realism and deliverability’ theme.
7.3.3 The main points of objection under the final theme of ‘delivering the necessary capacity’ are not directly relevant to the appropriateness of providing capacity for London’s Waste in East Sussex and Brighton & Hove. However, the conclusions below do support the arguments put forward at the South East Plan EiP that attempting to artificially force waste to disposal in unsuitable areas will exacerbate rather than improve the land disposal capacity problems in the South East.
7.3.4 This report presents the findings of a number of studies, which were undertaken with the objective of examining land disposal capacity availability and the practical implementation of the apportionment methodology in East Sussex and Brighton & Hove. The studies included an assessment of:
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• the position of key delivery organisations (Section 3);
• the land disposal situation in neighbouring counties (Section 4);
• land disposal capacity in the Core Strategy area (Section 5); and
• a SA-based critique of the apportionment methodology (Section 6).
7.3.5 The findings of these studies demonstrate that it is not appropriate for East Sussex and Brighton & Hove to plan for land disposal of London’s waste in accordance with the South East Plan , because the apportionment methodology does not take account of the key realism and deliverability issues of practicality, environmental impact and economics. In short:
• on the basis of current infrastructure, there is considered no real prospect of waste for land disposal travelling from London to East Sussex and Brighton & Hove;
• there is considerable uncertainty whether sufficient land disposal capacity could be developed in East Sussex and Brighton and Hove to take waste from outside this area; and
• the ‘ripple effect’ is not sustainable and won’t work in practice
7.3.6 The following sub-sections sections draw together the findings of the various studies described in this report, to address these themes and take account of the main challenges to the RSS apportionment methodology that were considered at the RSS and Hampshire Core Strategy public examinations, and of the Panel and Inspector’s conclusions respectively.
Waste Won’t Travel From London
7.3.7 The apportionment methodology used various assumptions to model criteria (contracts and patterns of movement, sustainable transportation and proximity to London) which sought to consider the implications of waste transportation as a driver for an appropriate apportionment. However, the assumptions did not take account of the practical, economic and environmental constraints that will restrict the transportation of waste directly from London to East Sussex and Brighton & Hove for land disposal.
7.3.8 Section 3 of this report examined the views of the key organisations that would be involved in delivering the apportionment policy. The prevailing view was that the main driver for the exportation of waste was availability, or otherwise, of landfill (land disposal) void space. The waste management industry in particular considered that it was very unlikely that new capacity would be developed in East Sussex and Brighton & Hove specifically to take waste from London; any new capacity developed most likely being earmarked for local arisings in the face of existing and short-term future capacity demands. The commercial focus of the waste industry in relation to land disposal of London’s waste would most likely be on sites close to
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London, where disposal to available capacity is more cost-effective, and the ‘proximity principle’ more sustainable. Further, there was a general view that although, in theory, waste might travel from London by rail, in the absence of readily available capacity, the industry would most likely not seek to invest in rail-linked sites in East Sussex and Brighton & Hove specifically to take London’s waste, relying instead on ‘local’ arisings for its business.
7.3.9 Additionally there was emerging evidence, derived from industry comment, that, as diversion capacity is developed, there will be increasingly limited amounts of waste requiring export to land disposal from the southern London boroughs in the period to 2026. Recent policy programmes produced by the Mayor of London also suggest that the amount of waste that might be required to be landfilled outside London in the future could be less, and the capacity requirements could decline more quickly, than envisaged during the preparation of the South East Plan.
7.3.10 Section 5 of this report considers land disposal capacity in the Strategy area and the accessibility, in terms of travel time from London, of potential capacity in East Sussex and Brighton & Hove. It concludes that, on the basis of excessive travel times and distances (in which fuel and people costs figure large), the movement of waste from London to East Sussex and Brighton & Hove by road is unlikely to occur and is not a practical scenario on which to base Regional strategy.
The Ripple Effect Won’t Work and is Not Sustainable
7.3.11 Policy W4 of the South East Plan introduces the concept of each waste planning authority planning for net self sufficiency, plus (where appropriate), an amount of waste from London, in order to plan for overall regional self sufficiency. This concept takes into account the possibility that, rather than taking waste to land disposal direct from London, areas like East Sussex and Brighton & Hove that are relatively remote from London in the South East Regional context, might accept an equivalent amount to their London apportionment from waste planning authority areas with which they share a boundary, i.e. West Sussex, Kent and Surrey. In turn, these areas adjacent to London would accept an equivalent additional amount of London’s waste. This concept has become known as the ‘ripple effect’. The RSS EiP Panel Report endorsed the veracity of this principle to rebut the arguments presented to the EiP that waste would not travel from London to the relatively remote waste planning authority areas, including East Sussex and Brighton & Hove.
7.3.12 The apportionment methodology is not explicitly based on the ripple effect, but the discussions at the RSS EiP referred to the potential for this effect to overcome concerns about whether waste will travel from London to the outlying areas of the South East Region. Sections 3, 4 and 5 of this report specifically examined whether it is realistic to rely on the occurrence of the ripple effect to effectively deliver regional policy.
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7.3.13 Section 3 of this report examined the view of the key waste production and service delivery organisations, including major waste management companies, who are involved in the movement of both MSW and non-MSW waste streams. The prevailing view was that the ripple effect would not work, for a combination of practical and economic reasons. These were principally because of the lack of available or potentially available land disposal capacity in East Sussex and Brighton & Hove, and the reluctance of the industry to base a development strategy on transporting waste over extended distances and journey times. This view indicates that it is unlikely that contractors would develop new land disposal capacity in East Sussex and Brighton & Hove to manage waste from neighbouring waste planning authority areas, particularly when there is insufficient capacity for in-county waste in the first place and greater capacity in the neighbouring authority areas.
7.3.14 Section 4 of this report sought to examine, more closely than was possible using the apportionment methodology, the situation in the waste planning authority areas neighbouring East Sussex and Brighton & Hove, specifically to generate some data for quantitative analysis of the potential for the ripple effect to be put into practice.
7.3.15 The study demonstrated that should the ripple effect be implemented, the mileage of waste movements could be up to approximately six times that associated with a scenario that saw waste disposed in the closest available installation (mirroring broadly the current situation). This indicates that the ripple effect scenario is, both in principle contrary to national waste planning policy (PPS10), which requires waste to be disposed of in one of the nearest appropriate installations, and in practice unlikely to meet industry activity and financial criteria.
7.3.16 In sustainability terms, the study also demonstrates that the ripple effect scenario would be likely to result in significant adverse effects on a range of sustainability indicators which have been developed by East Sussex and Brighton & Hove to evaluate the sustainability of its development plans.
7.3.17 Section 5 of this report considers the potential land disposal capacity in the Strategy area, and concludes that there is a significant capacity gap of around 3.1 million tonnes that would have to be found from land-raise schemes, just to manage the area’s own waste. This gap increases to around 4.75 million tonnes of land-raise capacity if the London’s waste apportionment is accounted for. In the absence of alternative mineral working based capacity, this can only be realised through the release of one or more landraise developments. Given the extreme difficulty in promoting the development of landraising sites, these figures underline the fact that there is no readily available land disposal capacity in East Sussex and Brighton & Hove and therefore the industry is considered very unlikely to seek to develop sites in East Sussex and Brighton & Hove that could solely or partially receive waste from outside the County.
7.3.18 Section 5 also examines the implications of travel times from centres of arisings in the waste planning authority areas neighbouring East Sussex and Brighton & Hove to the land disposal site in East Sussex and Brighton & Hove. The analysis shows that displacement of waste into East Sussex and Brighton & Hove is extremely unlikely to happen, as economically viable
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journey times are, based on first-hand industry knowledge, more likely than not to be exceeded for such journeys.
There is Insufficient Realistic Capacity for Waste from Outside East Sussex and Brighton & Hove
7.3.19 The RSS apportionment methodology uses generalised void availability and simplistic geological and environmental constraints as criteria to help to determine suitability for accommodating waste to land disposal. However, these criteria are modelled in a crude way, such that the modelling does not take account of the specific local geological/hydrogeological constraints and environmental constraints affecting East Sussex and Brighton & Hove. It is the role of the Waste and Minerals Core Strategy to consider more detailed evidence on potential land disposal capacity and to use this evidence to test the RSS apportionment policy.
7.3.20 As described above, Section 5 of this report examines potential land disposal capacity in the Strategy area. The land disposal capacity of sites with existing permitted capacity, sites that are allocated in the Waste Local Plan and other sites considered to have potential capacity was examined.
7.3.21 The evidence presented in Section 5 shows that there are no further suitable minerals voids remaining in East Sussex and Brighton & Hove that would offer significant additional void capacity to that permitted or allocated. Consequently the additional capacity required for London’s waste would have to be released via land raising sites, activities which themselves have specific environmental issues, primarily associated with visual impact, and the amount of land-take required. The study reported in Section 5 shows that waste produced in the WMCS area might be accommodated in a single large land-raising site, but accommodating the apportionment of London’s waste would require two or more land-raising sites.
7.3.22 Geological constraints in East Sussex and Brighton & Hove place major restrictions on the areas where landraising might be acceptable. The potential for the development of landraising sites in these areas was examined in detail during the preparation of the East Sussex and Brighton & Hove Waste Local Plan. At that time, a proposal to allocate a specific landraise site in the Plan was rejected by the County Council. Instead, a generic policy (East Sussex and Brighton and Hove Waste Local Plan Policy WLP21) was proposed that allowed potential landraise sites to come forward. A final policy was adopted, following the WLP Inspector’s recommendations that the policy be strengthened such that landraise is only to be used for the disposal of waste arising in the Plan area, and then only in extremely limited circumstances, whereby strict locational criteria have been met and all other options for the disposal of waste have been thoroughly examined and exhausted.
7.3.23 The physical circumstances of the Plan area have not changed in the intervening period. More recent work on identifying potential sites for land disposal capacity has been undertaken by the Councils during the preparation of the Waste and Minerals Core Strategy preferred strategy
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document. This work has re-confirmed that opportunities for new land-raising capacity in the core strategy area, that would be acceptable in environmental, social and economic terms, are extremely limited. It is therefore not considered appropriate in these circumstances for East Sussex and Brighton and Hove to plan for the land disposal of any amount of waste from London, in addition to its own requirement.
7.3.24 Section 6 of this report reviews the sustainability appraisal of the original apportionment methodology. The review finds that the apportionment option based on South East Plan Policy W3 scores poorly in relation to potential environmental impacts and apportionment based on land disposal capacity would be likely to be more sustainable. This analysis helps to demonstrate the crude nature of the apportionment methodology and that it does not consider fully the deliverability constraints of the range of environmental impacts that would be generated by landraising waste from London in East Sussex and Brighton & Hove.
Concluding Comments
7.3.25 This section draws together contemporary data from the findings of a number of studies, to demonstrate through a thorough process of gathering testing evidence at the local WMDF Core Strategy level, that it is not appropriate for East Sussex and Brighton & Hove to meet the apportionment of land disposal of London’s waste, as set out in South East Plan Policy W3.
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Appendix 1 - Baseline Data for Sustainability Appraisal-Based Comparative Assessment of Disposal Options (Report Section 4.5)
East Sussex and Brighton and Hove
Transport
1.1.1 Continued growth in traffic flow is identified as a probable future trend. This will impact upon air quality and CO 2 emissions as well as traffic congestion.
Indicator B&H East Sussex South East UK Area Trend/Comparison Issues/Constraints Data Source
Freight handled Shoreham Newhaven No data found for No data The amount of freight per annum - 2000 - 1.8 2000 - 0.6 all ports in the handled at Ports 2001 - 1.8 2001 - 1.0 South Shoreham decreased in (million tonnes) 2002 - 1.8 2002 - 0.9 East 2003 by 0.1m. 2003 - 1.7 2003 - 0.9 The amount of freight 2004 - 1.7 2004 - 0.9 handled at Newhaven increased from 0.6m to 0.9m between 2000 and 2004
Estimated traffic 2000 - 1,351 2000 - 4,029 2000 - 82,063 2000 - 402,890 Estimated traffic flows for Situation flows for all 2005 - 1,441 2005 - 4,373 2005 - 86,402 2005 - 429,705 all vehicles at every unfavourable. motor administrative vehicles (million have increased since vehicle kms) 2000. No administrative level has experienced a decrease in any year from 2000 to 2005.
Draft Report 1 September 2008
Climate
Area Indicator B&H East Sussex South East UK Issues/Constraints Data Source Trend/Comparison
Carbon dioxide 2003 - 5.5 2003 - 7 2003 - 8.8 2003 - 9.1 Data is not There is a need for Netcen, Defra: emissions by 2004 - 5.2 2004 - 6.4 2004 - 8.6 2004 - 9.1 comparable between trend based Local and end (England) 2003 and 2004 due to data to assess regional estimates user -Total revised whether CO2 of emissions per methodology emissions are carbon emissions capita East Sussex and increasing/decreasin 'electricity user' (tonnes) Brighton & g and to basis' Hove have compare with http://www.defra.g comparatively low national targets ov.uk/en CO2 emissions per for cutting CO2 vironment/statistic capita emissions. (This s/globat compared with the applies to all CO2 mos/galocalghg.ht South East emission m and England indicators)
Air
1.1.2 Air quality is identified as an indicator, which is performing poorly
Area Issues/Constrain Indicator B&H East Sussex South East UK Trend/Compariso Data Source ts n Air Quality In 2005 Brighton In 2004 Hastings N/A N/A Situation http://www.hasting Management and Hove City Borough Council unfavourable. Air s.gov.uk Areas Council have declared an Air quality in these /airquality/airqualit declared an Air Quality areas is poor ymanag Quality Management Area and is detrimental ement.aspx, Management Area related to to peoples http://www.brighto (AQMA) related to exceedences of health. nhove. exceedences of the 24-hour gov.uk/downloads/ the annual objective for PM bh average 10 in Bexhill Road cc/airquality/Detail
Draft Report 2 September 2008 Area Issues/Constrain Indicator B&H East Sussex South East UK Trend/Compariso Data Source ts n objective for Lewes District edAsses nitrogen dioxide Council declared sment2004report. (NO2). an Air pdf, The area of the Quality http://www.lewes.g AQMA Management Area ov.uk/e encompasses (AQMA) on the nvironment/824.as Lewes Rd, Upper 30th June 2005. p Lewes Rd, The AQMA was Preston declared Circus and Grand due to the Parade area. modelled exceedence of the annual average air quality objective for nitrogen dioxide (NO2 of 40 µg/m3 in 2005). The area of the AQMA will focus on the Station Rd, Fisher St, West St area of Lewes
Health
Area Indicator B&H East Sussex South East UK Issues/Constraints Data Source Trend/Comparison
Average life 2000 - 74.6 2000 - 76.5 2000 - 76.9 2000 - 75.6 Average life Situation ONS expectancy - 2001 - 74.9 2001 - 76.8 2001 - 77.2 2001 - 75.9 expectancies have unfavourable in Males 2002 - 75.1 2002 - 77.2 2002 - 77.4 2002 - 76.1 increased over the Hastings and B&H. 2003 - 75.7 2003 - 77.3 2003 - 77.7 2003 - 76.5 time period. Hastings (England and (2003 - 75.2) and Wales) Brighton & Hove (2003 - 75.7) are the only
Draft Report 3 September 2008 Area Indicator B&H East Sussex South East UK Issues/Constraints Data Source Trend/Comparison
areas that do not exceed the national average.
Average life 2000 - 80.5 2000 - 81.6 2000 - 81.3 2000 - 80.3 Average life Situation favourable ONS expectancy - 2001 - 81 2001 - 81.6 2001 - 81.5 2001 - 80.6 expectancy for in every females 2002 - 80.9 2002 - 81.7 2002 - 81.6 2002 - 80.7 females in East district except 2003 - 81.2 2003 - 81.7 2003 - 81.8 2003 - 80.8 Sussex has Hastings. (England and remained stable at a Hastings (2003 - Wales) level higher 79.7) is the than the national only area that does average. not exceed the national average.
Age 2003 - 101 2003 - 89 2003 - 92 2003 - 99 All districts in East Situation favourable ONS standardised 2004 - 93 2004 - 91 2004 - 92 2004 - 99 Sussex in B&H and mortality ratio except Hastings have every district except a Hastings. mortality rate below the national average.
Draft Report 4 September 2008 West Sussex
Transport
1.1.3 The main transport corridors are the South Coast rail and A27/A259 road corridor, and the Crawley/Brighton rail and A23 road corridor. Secondary corridors are the Arun Valley rail corridor and the A24 road corridor, which link the north east of the County with the coast.
Indicator and relevant data Current condition (2006) Comparators/targets Likely future trend Source set
Modal split- applies to all Average length of vehicle Traffic reduction in West Uncertain West Sussex LTP 2000 journeys irrespective of modal trip: Sussex targets of: http://www.westsussex.gov.uk/y split 3km in urban areas 2.5% by 2006 our 13km in rural areas. 5% by 2010 council/ppri/ltp/pdfs/traffic_redu No modal split is available. 12.5% by 2016 ctio n.pdf
Commuting mode 1991-2001: No targets identified. Uncertain West Sussex LTP 2000 Train= 0.2% change http://www.westsussex.gov.uk/c Bus= -0.1% change ont Car/Taxi= 0.1% change ent/category.jsp?categoryID=7 Motorcycle= -0.4% change 5561 Cycle= -1.4% change Foot= -1.0 change Other= -0.9% change Home= 3.5% change
Road traffic growth 2000/02 +1.5% pa LTP target to limit growth to Forecast growth levels from Sustainable Development by 2006 +9% pa 10% pa by 2011 and to reduce 2000 levels, based on www.sustainabledevelopment. growth by 50% by proposed development: gov.uk/sustainable/quality99 2016. 9% growth by 2006 WSCC LTP 2000 (section 5) & 16% growth by 2011 2002/3 progress report
Average car use Car kilometres traveled No target identified. Insufficient data Sustainable Development (kilometres/year/capita) increased by 17% between http://www.sustainabledevelop 1990 and 2003 ment. gov.uk/performance/8 .htm
Climate
Draft Report 5 September 2008
Greenhouse Gas Emissions UK is not yet on track to meet UK target by 2008 reduce The advantages of Climate Change: The UK from transport 2008 target after CO2 emissions by 12.5% of 1990 increased fuel efficiency are Programme emissions increased in 2004 levels - reduce CO2 likely to be outweighed http://www.defra.gov.uk/environ from 2003. by 20% [UK]. if the use of the cars and the ment/climate By 2050, reduce need to travel are not change/cm4913/pdf/section1.p greenhouse gas emissions also addressed. In 2003, df from activities within SE emissions from transport http://www.sustainabledevelop region by 60%. were 8% higher than 1990 ment. levels. gov.uk/performance/2 .htm
Air
Indicator and relevant data Current condition (2006) Comparators/targets Likely future trend Source set
NOx/NO2 levels 17.2ppb (1999) down from UK target: Catalytic converters on petrol DEFRA 21 ppb (1998) NOx emissions should be cars and reductions in http://www.defra.gov.uk/enviro below 1181 tonnes by 2010. emissions from large nme West Sussex target of combustion plants helped nt/statistics/airqual/aqnitrogen. 40ppb/year (2001-2010) reduce levels in the 1990s. htm
Well below 2010 target, though a number of local problems exist.
Particulate (PM10) levels No local data identified West Sussex target of UK emissions of PM10 fell DEFRA 40ppb/year (2001-2010) by 58 per cent between 1980 http://www.defra.gov.uk/enviro and 2003. Emissions from road nment/statisti transport increased by 27 cs/airqual/kf/aqkf21.htm per cent between 1980 - 1988 Sussex Air Quality but by 2003 had fallen to 26 http://www.sussexair. per cent below net/local_areas.html the 1980 level. Change in PM10 threshold in 2010 will bring much of West Sussex to near legal threshold.
Number of moderate or poor No local data identified UK number of days of Weather can cause Sustainable Development air quality days moderate or higher air pollution significant variation from year http://www.sustainabledevelop
Draft Report 6 September 2008 Indicator and relevant data Current condition (2006) Comparators/targets Likely future trend Source set
per site 2004: to year making it difficult to ment. Rural = 42, Urban = 22 predict. gov.uk/performance/6 2003 1.htm R = 61, U = 50 DEFRA, Annually 2002 http://www.defra.gov.uk/enviro R =30, U =20 nme nt/statistics/airqual/kf/aqkf02.ht m
Existence of air quality No management areas None identified. Currently several hotspots WSCC Transport Strategic and management programme currently designated which may require AQMA Environmental Policy (Ian in the future. Evans) Sussex Air Quality http://www.sussexair. net/local_areas.htm
Health
Indicator and Current relevant data condition Comparators/targets Likely future trend Issues identified Source set (2006)
General level 2001 UK: 69% in good health Insufficient data 2001 Census of health 70% in Good (2001) http://www.westsussex.gov.uk/cont health ent/community-andliving/ 22% in fairly population-and-censusdata/ good health census-of-population- 2001.jsp?sectionNumber=6 Draft South East Plan policy S2
Life 2000/02 2001 national average Life expectancy is in the Sustainable Development expectancy M = 77.2 yrs healthy life expectancy: South East is steadily http://www.sustainabledevelopment. F = 81.5 yrs men = 67 year increasing. gov.uk/indicators/regional/2003 women = 68.8 years /h06.htm http://www.sustainabledevelopment. gov.uk/performance/50.htm SEERA http://www.southeastra. gov.uk/our_work/planning/sus_d ev/irf_2004/irf_data_trends_final.pdf
Draft Report 7 September 2008 Indicator and Current relevant data condition Comparators/targets Likely future trend Issues identified Source set (2006)
Mortality rate 1999-2001 1999-2001 Mortality is likely to 2001 census 91/100,000 Region = 93/100,000 continue decreasing SEERA population UK = 100/100,000 http://www.southeastra. gov.uk/our_work/planning/sus_d ev/irf_2004/irf_data_trends_final.pd f
Draft Report 8 September 2008
Appendix 1 - Baseline Data for Sustainability Appraisal-Based Comparative Assessment of Disposal Options (Report Section 4.5)
East Sussex and Brighton and Hove
Transport
1.1.1 Continued growth in traffic flow is identified as a probable future trend. This will impact upon air quality and CO 2 emissions as well as traffic congestion.
Indicator B&H East Sussex South East UK Area Trend/Comparison Issues/Constraints Data Source
Freight handled Shoreham Newhaven No data found for No data The amount of freight per annum - 2000 - 1.8 2000 - 0.6 all ports in the handled at Ports 2001 - 1.8 2001 - 1.0 South Shoreham decreased in (million tonnes) 2002 - 1.8 2002 - 0.9 East 2003 by 0.1m. 2003 - 1.7 2003 - 0.9 The amount of freight 2004 - 1.7 2004 - 0.9 handled at Newhaven increased from 0.6m to 0.9m between 2000 and 2004
Estimated traffic 2000 - 1,351 2000 - 4,029 2000 - 82,063 2000 - 402,890 Estimated traffic flows for Situation flows for all 2005 - 1,441 2005 - 4,373 2005 - 86,402 2005 - 429,705 all vehicles at every unfavourable. motor administrative vehicles (million have increased since vehicle kms) 2000. No administrative level has experienced a decrease in any year from 2000 to 2005.
Draft Report 1 September 2008 Surrey Transport
Key Issues
1.1.4 Surrey has very high levels of traffic compared to the national average. Urban areas and major routes experience congestion that is severe at times.
Climate
1.1.5 Surrey’s contribution to the UK emissions from energy production and waste treatment and disposal are low, however emissions from road transport are disproportionately high.
Air Key Issues
1.1.6 The air quality standard for nitrogen dioxide (NO2) is exceeded in some areas of the county, and the standard for nitrogen oxides (NOx) is exceeded across large areas.
Health Key Issues
1.1.7 Surrey’s people are healthier than average compared with the South East region and the rest of the country, although there are pockets of health deprivation.
Draft Report 9 September 2008 Kent Transport
Sustainability Problems
1.1.8 Over the last 3 years, road traffic in Kent has grown by 2.6%:
• • Motorway +3% • • Inter urban routes +11.5% • • Urban areas +0.6% • • Rural areas +5%
1.1.9 This compares with an average increase of 1.43% for the UK over the same time period.
1.1.10 The proportion of people traveling to work by car has risen from 63% to 64.6% since the 1991 census.
Climate Sustainability Problems
1.1.11 None identified.
Air Sustainability Problems
1.1.12 In 2003, air quality was poor on 78 days in rural areas and 49 days in urban areas: this was 44% increase in rural areas in the last two years and a 133% increase in urban areas.
1.1.13 PM10 levels were moderate or poor for 11 days in 2003; ozone for 71 days. The National Air Quality Strategy is for these to be no more than, respectively, 35 times and 10 days per year by end 2005.
Health Sustainability Problems
Draft Report 10 September 2008 1.1.14 The life expectancy of Kent’s residents is comparable to that of the rest of the South East and UK.
1.1.15 Continued decline in the number of people killed or seriously injured on roads in the County. However, road traffic in Kent is increasing.
Draft Report 11 September 2008