Initial Consultation document
WASTE MANAGEMENT SPECIFIC POLICIES
National Planning Policy for Waste
National Planning Policy for Waste requires that Waste Planning Authorities should identify sufficient opportunities to meet the identified needs for their area for the management of waste streams.
A significant element of the planning policy context for waste is the Waste Hierarchy. The intention is that, in making decisions about waste management, greater weight should be attributed to those waste management methods that are at the top of the hierarchy. In order of preference the waste hierarchy is:
In terms of planning this has meant a change from planning for new temporary landfill sites in former quarries and instead the emphasis is now on permanent fixed facilities in employment areas or other suitable sites. This Plan is mainly concerned with recycling, other recovery and disposal because these are the stages of the waste hierarchy where waste management facilities are required.
The other key element of National Planning Policy for Waste is the principal of self-sufficiency in waste management capacity. This is the concept of providing enough waste management capacity to handle the forecast amount of waste arising in Norfolk. Therefore the County Council aims to plan for sufficient capacity to manage an amount of waste equal to that arising in Norfolk, whilst acknowledging that waste is transported between different areas of the Country. It is recognised that there may be certain waste streams for which the complexity of the waste management process, and/or the volumes of waste in each area so low that it would be unviable for a full range of waste management facilities to exist in every area.
Article 16 of the Waste Framework Directive recognises this; 'The principles of proximity and self-sufficiency shall not mean that each Member State has to possess the full range of final recovery facilities within that Member State.'
Discussions with other Waste Planning Authorities take place as part of the Duty to Cooperate, to ensure adequate capacity exist both inside and outside Norfolk to manage such waste.
Waste is classified into different types depending on the nature and source of the material; these are referred to as waste streams. The different waste streams that arise within Norfolk are defined in the glossary and are:
- Local Authority Collected Waste (LACW)
- Commercial and Industrial waste (C&I)
- Construction, Demolition and Excavation waste (CD&E)
- Hazardous waste
- Radioactive waste
- Wastewater (sewage)
- Agricultural waste
Waste reduction and prevention
The Norfolk Waste Partnership is an organisation which promotes waste reduction and prevention, members include all eight local authorities in Norfolk. The partnership has four strategic objectives:
- Reduce the amount of waste generated per household
- Increase the availability of waste reduction, reuse, repair and recycling activities
- Ensure residents and businesses understand the importance of waste as a resource and the range of opportunities for waste reduction, repair, reuse and recycling
- Reduce the overall system cost of dealing with Norfolk's household waste.
The targets set out in the Waste Management Plan for England (2013) are key drivers for the partnership. Norfolk does not have a Joint Waste Management Strategy which covers the whole of the Plan period, the existing document has an end date of 2020. The requirement for Waste Disposal Authorities to produce such strategies was removed by Defra in 2010.
The recycling rate for Norfolk's household waste in 2016/17 was 46.7%, compared to a household waste recycling rate for England of 44.9%. There is a target within the Waste Management Plan for England for 50% of household waste to be recycled by 2020. All local authority areas in Norfolk that collect waste from households made improvements in their recycling rates for 2016/17 compared with those in 2015/2016. However, there are disparities between individual authority's recycling rates, with the highest recycling rate in Norfolk being 50.9% and the lowest 33.3%. National household waste recycling rates for England have remained steady over the last five years at just below 45%.
Initiatives to reduce waste, and improve recycling are largely outside the scope of this Plan, these being aligned with the aims of the Waste Collection and Waste Disposal Authorities through their membership of the Norfolk Waste Partnership. The Plan will provide an approach that ensures suitable areas for sustainable waste management facilities are identified and that there is a flexible approach to waste technologies so that innovation within the market is encouraged, while still providing appropriate safeguards.
Existing Waste Management Capacity
Norfolk currently has a wide range of waste management facilities, which manage both waste arising within Norfolk and some types of waste arising in other Waste Planning Authority areas. These facilities include composting, recycling, household waste recycling centres, anaerobic digestion, transfer stations and treatment facilities. Assessment of the maximum recorded throughputs for a range of waste management sites in Norfolk has indicated that approximately 2.25mt of capacity per annum exists for the treatment and processing of waste.
Waste management was previously dominated by landfill as a final destination for residual waste, but there has been a significant shift away from this situation over the last few years. Nationally, the majority of residual waste is now either consumed directly in Energy from Waste plants (usually incinerators) which produce electricity and/or heat as part of the process; or processed into Refuse Derived Fuel (RDF), and then transported to Energy from Waste plants. There has been rapid growth in RDF exports to such plants on continental Europe and beyond over the last few years. These plants generally have lower fees for accepting waste than was the case for landfill sites; this has led to the closure of landfill sites. In Norfolk, at the current time, there are no operational non-hazardous landfill sites, although there are two mothballed sites which still contain significant voidspace of over 5 million cubic metres. While, Norfolk does not have any final treatment or recovery facilities for residual LACW or Commercial & Industrial waste, there are a number of facilities which provide treatment and processing (for example, into RDF) before it is transported to such facilities.
Inert waste recycling takes place using mobile plant at construction sites as well as waste management facilities. It is recognised nationally that figures for inert waste recycling are less robust than for other waste streams, as there is no requirement for data to be provided for mobile plant operating under exemptions from the Environment Agency. Many inert waste recycling facilities operate at mineral workings as part of the wider commercial undertaking and the processed waste is sold as a recycled aggregate. Inert material unsuitable for reuse as a result of recycling is often used in the restoration of mineral workings.
Norfolk contains a number of specialised facilities which deal with hazardous waste, mainly florescent tubes, waste electronic and electrical equipment and end-of-live vehicles. These sites receive waste from a wide area, including nationally for some sites, due to the nature of the waste stream. The facilities in Norfolk manage a greater quantity of waste than arises within the county.
Existing waste movements
The waste management industry is market driven, and as such operators seek to find the most efficient way of managing waste. The disposal of waste is expensive, and therefore separation of waste for which a recycling or reprocessing market exists is a widely accepted business model. As waste is separated into more and more homogenous streams, so the technology and processing complexity required generally increases, with final reprocessing often requiring a large scale industrial plant. As transport is a cost to business, a commercial operator will not move waste further than is necessary to make a given return. Waste from Norfolk travels nationally and internationally to appropriate waste management facilities, and Norfolk waste management sites receive some wastes from other areas nationally.
13. Waste management capacity to be provided
In order to plan for future waste arisings, national planning policy guidance states that growth projections should be produced. The Environment Agency's Waste Data Interrogator includes data on Household, Industrial and Commercial, Inert, and Hazardous waste streams. Growth projections have therefore been produced for the following waste streams:
Local Authority Collected Waste (LACW): The data on arisings is considered to be robust and national guidance suggests that forecasts for population growth and household formation should be used as a basis for the waste arisings forecasts. Population and household projections are produced by the Office for National Statistics. Local Planning Authorities often use these projections as a basis for producing Strategic Housing Market Assessments which often augment these projections by taking into account local factors. Norfolk County Council has produced a LACW forecast for this Plan using a growth scenario where the current arisings of waste per household are multiplied by the household projections contained in Norfolk's Strategic Housing Market Assessments. This growth scenario forecasts an annualised growth rate of just under 1%. Therefore LAWC is forecast to grow in line with a growth in households.
Commercial and Industrial waste: Forecasting future arisings for Commercial and Industrial waste is recognised as being less robust due to the lack of data on quantities of waste arising. However, the Environment Agency's Waste Data Interrogator contains data on the quantities of household, industrial and commercial (HIC) waste received at waste management facilities with an Environmental Permit. Therefore the arisings of C&I waste have been calculated by taking the arisings of Household, Commercial and Industrial Waste in the Waste Data Interrogator and subtracting the quantity of Local Authority Collected Waste arisings from the total. Therefore all remaining HIC waste has, for the purpose of this Plan, been considered to be C&I waste (although it is recognised that it will also include some Construction & Demolition and agricultural waste).
Defra carried out a number of surveys to estimate C&I waste arisings (the last of these was in 2009). We have taken the business sectors used in the Defra Survey; and equated these to the GVA (Gross Value Added) growth forecasts for certain business sectors within the East of England Economic Forecasting Model (EEFM), to produce a growth forecast for C&I waste for the Plan period of an annual growth rate of just over 1.5%. Therefore C&I waste is forecast to grow in line with economic growth.
Inert waste: National guidance advises that Waste Planning Authorities should start from the basis that net arisings of construction and demolition waste will remain constant over time as there is likely to be a reduced evidence base on which forward projections can be based for C&D waste. Therefore this plan has taken the inert waste arisings in Norfolk from the Environment Agency's Waste Data Interrogator 2016 and assumed that the arisings will remain constant in each year of the Plan period. Any C&D waste arisings that are not inert will already be included within the figures for Commercial and Industrial waste arisings and forecasts for this waste stream over the Plan period, which assume an increase in waste arisings.
Hazardous waste: National guidance states that data returns for hazardous waste should be considered robust due to the need for facilities dealing with this waste to have an Environmental Permit and therefore submit waste returns to the Environment Agency. National guidance states that time series data should be used to forecast quantities of hazardous waste for the Plan period. Analysis of the Environment Agency's Waste Data Interrogator data shows that hazardous waste in Norfolk has been declining since 2009. The time series has been taken with 2009 as a base year because data prior to that does not reflect the current regulatory environment with regard to regulations on Waste Electrical and Electronic Equipment and End-of-Life Vehicles, and it is considered that the current decline in hazardous waste arisings is likely to continue through the Plan period. Using the time series data on hazardous waste arisings in Norfolk since 2009 quantities of hazardous waste are forecast to reduce (from arisings of 64,845 tonnes in 2016) by an average of 6.6% a year throughout the Plan period.
The waste forecasts do not take into account potential improvements in waste reduction and prevention. Analysis of the way the waste management industry in Norfolk operates indicates that existing sites are likely to modify the methods they use in order to adapt to such changes rather than large numbers of operators entering or leaving the market.
Using the growth forecasts above, total waste arisings for Norfolk of LACW, C&I, inert and hazardous waste will increase from just under 2.976mt per annum in 2016 to approximately 3.431mt per annum in 2036.
The maximum existing waste capacity of operational sites in Norfolk is calculated to be 2.25 million tonnes per annum. This is based on the maximum recorded throughputs at sites between 2012 and 2016; and these may not represent absolute maximums, with many sites having higher maximum volumes set out in their Environmental Permits. However, in addition to the 2.25 million tonnes per annum capacity at existing facilities, Norfolk also has a number of mineral extraction sites that will be restored using imported inert material and it is considered that these sites will meet the capacity requirements for the inert waste arisings that are unsuitable for recycling, over the Plan period. Norfolk also has two non-hazardous landfill sites that are not currently receiving waste but have a remaining void capacity of 5.09 million cubic metres.
Further detail on waste management capacity, movements, arisings and forecasts is provided in a separate Waste Management Capacity Assessment report.
The following policy indicates the levels of waste management development that is expected over the Plan period to 2036. These figures are not limits, but are indicative.
Planning for net self-sufficiency in waste management recognises that there will be some cross-boundary movement of waste, as it is sometimes more sustainable to take waste to a facility out of Norfolk where the source of waste arisings is close to an administrative boundary. Therefore, the premise is to provide for the equivalent of waste forecast to arise within Norfolk, irrespective of where it actually arises.
Policy WP1: waste management capacity to be provided
The strategy for waste management is to provide, through the policies for specific waste management facility types, for sufficient waste management capacity to meet the expected arisings of Local Authority Collected Waste (LACW), commercial & industrial waste (C&I), and inert waste. Appropriate handling, transfer and management capacity will also be provided for hazardous waste, while recognising that due to the quantities of such waste it is unlikely to be feasible for Norfolk to have a full range of facilities, and that Norfolk may have certain specialist facilities which receive waste from other Waste Planning Authorities.
Provision will be made to manage the quantities of waste set out in Appendix 9. New facilities or changes to existing facilities which help to achieve the targets for recycling, composting, reuse and recovery set out in the Waste Management Plan for England (2013) will be encouraged.
During the plan period, there is a need to ensure that capacity exists to manage at least the following quantities of waste. Sufficient capacity currently exists to meet the growth forecast.
Question 10: Policy WP1 'waste management capacity to be provided' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
Local Authority Collected Waste: The growth forecast in Policy WP1 for LACW is based on a household projection produced for the Norfolk Strategic Housing Market Assessments which takes into account some additional local factors in relation to the formation of small households. This results in a growth rate of just under 1% per annum. An alternative is to base the household growth projection figure purely on past household growth (from 1998/99-2015/16), which would result in a growth rate of over 1.5% per annum. The projection based on past household growth was not used because it results from a change in the age structure of the Norfolk population (the 'baby boom' generation reaching retirement age) and changes in society which resulted in an increase in the rate of formation of small households. It is considered that these pressures would be unlikely to continue at the past rate and that the growth forecast in the Norfolk SHMAs is more realistic.
The Office of National Statistics projection for household growth is lower than the growth projection in the Norfolk SHMAs, at 0.88% per annum, and would result in a lower LACW arisings over the Plan period. The ONS projection does not take into account local factors, in relation to the formation of small households. However, an alternative option would be to forecast LACW growth over the Plan period at 0.88% per annum (in accordance with the ONS) instead of 0.97% per annum (in accordance with the Norfolk SHMAs).
Question 10a: Do you consider that an alternative growth scenario should be used for forecasting LACW growth?
Commercial and Industrial Waste: The forecast in Policy WP1 for Commercial and Industrial (C&I) waste is based on growth of 1.5% per annum, in accordance with economic growth in the East of England Forecasting Model (EEFM). This is based on growth estimates of Gross Value Added (GVA) for selected business sectors, to approximate with those sectors used by the previous Defra C&I waste survey. However, the latest Defra estimate of C&I economic growth for England is slightly lower, at 1.4% per annum. Therefore, an alternative option would be to forecast C&I waste growth over the Plan period at 1.4% per annum instead of 1.5% per annum.
Question 10b: Do you consider that an alternative growth rate should be used for forecasting C&I waste growth?
14. Spatial Strategy for waste management facilities
The Key Diagram and Policy WP2, set out the spatial strategy for the location of new waste management facilities within Norfolk. The following factors have been considered in the spatial strategy for waste management facilities:
- in the past temporary sites for the disposal of waste by landfill followed minerals extraction, whereas waste is increasingly being managed at permanent facilities that are located with suitable highways access in proximity to centres of population and sources of waste;
- the Norfolk Route Hierarchy provides a recognised hierarchy of roads. HGVs should take the shortest practicable route (avoiding inappropriate junctions and travel through settlements where possible) to access the strategic highway network at the earliest appropriate point;
- significant areas of the County are within the statutory landscape designations of the Norfolk & Suffolk Broads, and the Norfolk Coast Area of Outstanding Natural Beauty;
- significant areas of the County are within the statutory ecological designations of Ramsar, Special Protection Areas, Special Areas of Conservation and Sites of Special Scientific Interest;
- the production of waste is likely to be concentrated in the county's larger settlements; these settlements will also be the locations of greatest housing and employment growth in Norfolk during the Plan period.
The settlement hierarchy is defined by the Local Planning Authorities in Norfolk. The urban areas and main towns are as follows:
Urban Areas: Norwich, King's Lynn (including West Lynn), Thetford, Attleborough, Great Yarmouth and Gorleston-on-Sea
The Norwich urban area includes the built up parts of the urban fringe parishes of Colney, Costessey, Cringleford, Trowse, Thorpe St Andrew, Sprowston, Old Catton, Hellesdon, Drayton and Taverham.
Main Towns: Aylsham, Cromer, Dereham, Diss, Downham Market, Fakenham, Harleston, Holt, Hunstanton, North Walsham, Swaffham, Watton, Wymondham
The landscape designations of the Norfolk Coast AONB and the Broads Authority Executive Area are shown on the Key Diagram and the Policies Map along with the national and international ecological designations of Ramsar sites, SPAs, SACs and SSSIs. Some of these landscape and ecological designations occur in proximity to Norfolk's urban areas and main towns.
Policy WP2: Spatial Strategy for waste management facilities
New or enhanced waste management facilities should be located within five miles of at least one of Norfolk's urban areas or main towns (detailed the supporting text) and be accessible via appropriate transport infrastructure.
However, due to their characteristics, the following types of facilities will be acceptable in locations more distant from the urban areas or main towns, if they are close to the source of the waste, or the destination of the recovered waste material, and are in compliance with the landuses in Policy W3 and the development management criteria set out in Policy MW2:
- agricultural waste treatment facilities
- windrow (open-air) composting facilities
- community composting facilities
- small scale local facilities (including "bring" sites for the collection of recyclables).
Water recycling centres and pumping stations can normally only be located on or adjacent to watercourses, so they will normally only be acceptable in such locations.
Question 11: Policy WP2 'spatial strategy for waste management facilities' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
- Policy WP2 states that waste management facilities should be located within five miles of at least one of Norfolk's urban areas or main towns. An alternative option would be to also include settlements in a lower tier of the settlement hierarchy within the policy criteria. Settlements in the next tier in the settlement hierarchy are usually described as Key Service Centres. Including Key Service Centres within the policy would increase the number of potential locations for waste management facilities. However, it is considered that the policy already provides for sufficient locations and that it is not necessary to also include Key Services Centres.
- Another alternative option would be to increase the distance at which waste management facilities could be located from urban areas or main towns, from 5 miles to 10 miles. Increasing the distance to 10 miles would increase the number of potential locations for waste management facilities. However, it is considered that the policy already provides for sufficient locations and that it is not necessary to increase the distance.
- Policy WP2 currently treats virtually all waste management facilities the same, regardless of scale. An alternative option would be to have different locational criteria depending on the throughput of a site. For example sites over 75,000 tonnes would need to be within 10 miles of an urban area, whist smaller facilities would need to be within 10 miles of an urban area or a main town. It is considered that this could complicate the implementation of the policy, but it is a potential alternative.
Question 11a: Do you consider that Policy WP2 should be amended in line with any of the alternative options?
15. Land uses potentially suitable for waste management facilities
Modern waste management facilities can require purpose designed buildings and structures which, in most instances, are suited to industrial areas. Most types of enclosed waste facilities, regardless of the technology used or waste type being processed, have similar locational requirements due to their potential to impact on local amenity and the environmental. Such facilities are therefore directed towards specific suitable locations where these impacts can be more easily accommodated. Opportunities for integrated waste management will be encouraged, where various waste management operations can be co-located to reduce transport requirements and assist improved levels of waste recovery close to the source of the waste.
Waste management facilities that deal with waste in the open air can give rise to specific impacts such as noise and dust which can influence where such development should take place. Open air waste operations include aggregate recycling facilities and open windrow composting.
Aggregate recycling facilities are often temporary and are likely to be best located on mineral extraction sites or close to the source of waste, to minimise transport distances. Policy WP4 specifically applies to aggregate recycling facilities.
Open windrow composting facilities are likely to be suitable in more rural locations due to their similarity to other agricultural developments (e.g. farms). They can produce odours because of the biodegrading process and therefore, rural, less populated locations are more appropriate for these facilities. Any particular requirements for minimising adverse effects on residential amenity and rural character will be expected to be demonstrated through a planning application. Policy WP8 specifically applies to composting facilities.
Policy WP3: Land uses potentially suitable for waste management facilities
Waste management facilities (other than landfill sites and water recycling centres) will be acceptable only on the following types of land:
- land in existing waste management use;
- land in existing general industrial use (B2 use class) or in existing storage or distribution use (B8 use class) (excluding open air composting);
- land allocated for B2 and B8 uses in a local plan or development plan document (excluding open air composting);
- within or adjacent to agricultural and forestry buildings;
- previously-developed (brownfield) land (excluding open air composting);
- former airfields (open air composting only);
- water recycling centres (composting and anaerobic digestion only);
Proposals for waste management facilities at existing mineral workings and landfill sites may be considered acceptable on a temporary basis. Any temporary planning permission will be restricted to the cessation date for the mineral operation or landfill activities on site.
Proposals must also comply with the development management criteria set out in Policy MW2.
Question 12: Policy WP3 'land uses potentially suitable for waste management facilities' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
The National Planning Policy for Waste states that "Waste Planning Authorities should identify, in their Local Plans, sites and/or areas for new and enhanced waste management facilities in appropriate locations."
The Waste Site Specific Allocations DPD was adopted in 2013 and allocated 29 sites for waste management facilities. However, as none of the allocated sites for waste management have been delivered since the adoption of the Waste SSA, whilst unallocated sites have been approved, we consider that it is more appropriate for the M&WLPR to contain criteria based policies to determine planning applications for waste management facilities instead of allocating specific sites. Policy WP3 identifies suitable land use types for the location of waste management facilities, whilst further details are provided in the following policies that would apply to particular types of waste management facilities. Appendix 3 of this document lists all of the sites allocated in the Waste SSA and how the policies in this M&WLPR would apply to them.
However, an alternative option would be to continue to allocate specific sites for waste management facilities. A 'call for sites' would be required to enable specific sites to be proposed and the sites would then need to be assessed for their suitability in planning terms.
Question 12a: Do you consider that specific sites should be allocated for waste management facilities as well as criteria based policies?
16. Recycling or transfer of inert and construction, demolition and excavation waste
The recycling of construction, demolition and excavation waste makes a significant contribution to meeting aggregates demand and to reduce pressure on land won and marine dredged sources of aggregate. Therefore, the recycling of these wastes provides a sustainable source of aggregates. Potential environmental and amenity impacts from the recycling of inert and CD&E wastes include noise and dust.
Policy WP4: Recycling or transfer of inert and construction, demolition and excavation waste
Proposals for recycling or transfer of inert and construction, demolition and excavation waste may be acceptable on land within the uses identified within Policy WP3.
At mineral sites, planning permission will be limited to the life of the mineral operation.
Proposals for such facilities at landfill sites may be considered acceptable on a temporary basis whilst landfilling and restoration is taking place on site.
On land suitable for general industrial use (B2 use class) or storage & distribution use (B8 use class), activities shall take place within purpose-designed facilities.
Proposals must also comply with the development management criteria set out in Policy MW2.
Question 13: Policy WP4 'Recycling or transfer of inert and construction, demolition and excavation waste' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
17. Waste transfer stations, materials recycling facilities, end of life vehicle facilities and waste electrical and electronic equipment recovery facilities
The main function of a waste transfer station is to facilitate the efficient transportation of waste by sorting loads from small collection vehicles such as skip lorries and reloading onto much larger lorries including articulated lorries for onward transportation. Waste transfer stations sort mixed waste to separate out the recyclable materials as well as bulking up waste into larger loads for onward transportation to recycling, recovery or disposal facilities.
Materials recycling facilities are where recyclable wastes are separated into their different types for onward transportation to recyclers (such as paper/card, glass, metal and plastic). The remaining waste, called residual waste, is either sent to landfill or a treatment facility for recovery.
End of life vehicle facilities remove potential pollutants from vehicles, remove the usable parts and send the scrap items off to recyclers.
Waste electronic and electrical equipment (WEEE) recovery facilities carry out the disassembly of WEEE and the separated parts and materials can then be either reused, recycled, recovered or disposed of at other waste management facilities. The exact treatment of WEEE can vary significantly according to the category of the waste and the technology that is used. As the treatment of WEEE is a specialised activity, often receiving waste from a large area, other facilities carry out the storage and transfer of WEEE before onward transportation to a treatment facility.
Policy WP5: Waste transfer stations, materials recycling facilities, end of life vehicle facilities and waste electrical and electronic equipment recovery facilities
Waste transfer stations, material recycling facilities, end of life vehicle facilities and waste electrical and electronic equipment recovery facilities may be acceptable within purpose designed or suitably adapted facilities on land within the uses identified within Policy WP3.
Proposals must also comply with the development management criteria set out in Policy MW2.
Question 14: Policy WP5 'Waste transfer stations, materials recycling facilities, end of life vehicle facilities and waste electrical and electronic equipment recovery facilities' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
18. Transfer, storage, processing and treatment of hazardous waste
There are many different types of hazardous waste and five main categories of hazardous waste are:
- Construction and demolition waste, including asbestos, contaminated soils and treated wood
- Oily wastes, batteries and accumulators, and end-of-life-vehicles
- Chemical processing wastes and marine wastes
- Waste water treatment and water industry wastes
- Waste electrical and electronic equipment, including televisions and florescent tubes.
Applications for facilities for the transfer, storage and treatment of waste electronic electrical and electronic equipment (WEEE) and end-of-life vehicles (ELV) will be determined in accordance with Policy WP5. Applications for other types of hazardous waste management facilities will be determined in accordance with Policy WP6 below.
Hazardous wastes usually require specialised treatment and disposal facilities, and given the relatively small quantities of waste produced (compared to other waste streams), the catchment area of such facilities is often wider than a single county. Hazardous waste therefore travels considerable distances to specialised facilities across the Country.
Policy WP6: Transfer, storage, processing and treatment of hazardous waste
Facilities for the transfer, storage, processing and treatment of hazardous waste may be acceptable within purpose designed or suitably adapted facilities on land:
- in existing general industrial use (B2), in storage and distribution use (B8), or
- identified for B2 or B8 uses in a local plan or development plan document, or
- on brownfield land, or
- integrated within an establishment producing much of the waste that will be dealt with.
Facilities for the transfer and short-term storage of hazardous waste will also be acceptable on existing waste management sites identified as having potential for non-hazardous waste transfer where hazardous waste will only represent up to 5% of waste managed on site.
Proposals must also comply with the development management criteria set out in Policy MW2.
Question 15: Policy WP6 'Transfer, storage, processing and treatment of hazardous waste' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
19. Household Waste Recycling Centres
The County Council has a statutory duty, as Waste Disposal Authority, to provide Household Waste Recycling Centres (HWRCs) for householders within Norfolk to dispose of their waste. There are 20 HWRCs in the county in 2017.
A number of the HWRCs can at times suffer from constraints such as size restrictions and peak-time queues. Modern sites offer an improved recycling service, and the County Council would wish to consider the potential for upgrading more of its current sites, or construct new replacements sites, to these higher standards when opportunities emerge.
Significant housing and employment growth is planned for Norfolk over the next twenty years. In the light of future housing growth and the desire to improve some existing sites, the County Council will continually be reviewing the current distribution, adequacy and number of HWRCs in the county. Improvements to existing sites and/or new sites may be required as the major housing growth planned for Norfolk is delivered.
It is important to note that the upgrading of current HWRC sites and the construction of new sites is dependent on both the County Council finding suitable sites and securing necessary finance to purchase or lease the land, and to construct/improve the site. However, as relatively little capital funding is currently available for major HWRC improvement works, all potential opportunities to secure suitable sites and/or section 106 planning gain through the planning system will be explored.
Although most potential HWRC improvements or new HWRC locations will be consistent with Policy WP3, there may be cases where there is a demand for a HWRC in a certain area, but no suitable sites are available. In these cases, Policy WP7 will allow an appropriate proposal to be determined positively.
Policy WP7: Household Waste Recycling Centres
Household waste recycling centres may be acceptable within purpose designed or suitably adapted facilities on land within the land uses identified within Policy WP3.
Where it can be demonstrated that no suitable sites consistent with Policy WP3 are available within the area to be served by the household waste recycling centre, household waste recycling centres may be acceptable on other sites provided these are consistent with the development management criteria set out in Policy MW2 and are accessible to the public.
Where justifiable, an appropriate level of developer contributions from new developments will be sought towards the provision of improvements to the Household Waste Recycling Centre network. This will normally be in the form of financial contributions, but in certain locations - particularly the major growth locations identified in adopted Local Plans – suitable sites for new Household Waste Recycling Centres could be requested.
Question 16: Policy WP7 'Household Waste Recycling Centres' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
Composting is a natural process that involves the breakdown of organic material in the presence of air (aerobically). It creates a product that can be applied to land to improve soil structure and enrich the nutrient content of soil. Potential environmental and amenity impacts from composting include bio-aerosols, odour and dust.
Open-air composting involves green waste (vegetation) which is shredded and placed outdoors in elongated heaps, which are kept at specific moisture and oxygen levels. The windrows are turned and re-mixed on a regular basis to maintain their aerobic state, until the active composting period is finished and the final product is ready. This form of composting can require a large site.
In-vessel composting facilities promote aerobic degradation of organic waste including green waste and/or food waste within either an enclosed building or other form of containment that have forced air pumped into and extracted out of them and then discharged to the atmosphere via bio-filters that remove odours. The main advantage of this system over open-air composting is that it can take food waste, including meat, because the required temperature can be reached and maintained so that harmful bacteria can be neutralised. In-vessel composting often also requires some form of outdoor maturation.
Policy WP8: Composting
Composting facilities may be acceptable on land within the uses identified in Policy WP3.
Proposals for open air composting or in-vessel composting will not be approved unless they are accompanied by a site-specific risk assessment which shows that bio-aerosol levels can be maintained throughout the life of the operations, at appropriate levels at dwellings or workplaces within 250m of a facility. Appropriate schemes for the management of odours and dust will also be required.
Proposals must also comply with the development management criteria in Policy MW2.
Question 17: Policy WP8 'composting' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
21. Anaerobic digestion
Anaerobic digestion facilities promote anaerobic degradation of organic wastes such as animal wastes, energy crops, and vegetable tailings. Anaerobic digestion is an enclosed process and can operate at a range of scales (from the very small to the very large). The process involves introducing the feedstock into a tank of bacteria rich slurry. This process produces methane gas that is normally used to drive a diesel generator and export the electricity to the grid. The organic waste is converted into a nutrient rich digestate (which can be used as a fertiliser if produced from source segregated biodegradable waste). The main advantage of anaerobic digestion over composting is the electrical power is produced.
Policy WP9: Anaerobic digestion
Anaerobic digestion facilities may be acceptable on land:
- within the uses identified in Policy WP3; or
- integrated with water recycling centres
Proposals must also comply with the development management criteria in Policy MW2.
Question 18: Policy WP9 'Anaerobic digestion' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
22. Residual waste treatment facilities
Residual waste is the waste that is not re-used, recycled or composted. There are various types of residual waste treatment facilities, which range in size from very big to very small. Residual waste treatment facilities fall into two main categories:
- Thermal treatment – involving some form of combustion of the waste
- Mechanical Biological Treatment (MBT) – where the waste is stabilised through some form of biological treatment after, and/or before, mechanical separation of the non-organic material.
Within these broad categories there is a wide range of residual waste treatment technologies, which Policy WP10 would apply to:
Direct Energy from Waste in which the waste is combusted and used to generate electricity and also potentially to supply a Combined Heat and Power (CHP) Scheme.
Advanced Thermal Treatment including gasification and pyrolysis, in which the waste is charred in low or zero levels of oxygen and the resulting gases are recovered for combustion to generate electricity or CHP.
Refuse Derived Fuel (RDF) and Solid Recovered Fuel (SRF) is produced from the waste, sometimes as part of an MBT process, and then used as a fuel at another facility to generate electricity or CHP.
Autoclave/Mechanical Heat Treatment in which the waste is subjected to heat and steam to break down the organic fibres and aid separation of the recyclable/combustible material.
Mechanical and Biological Treatment (MBT) in which the recyclable and/or readily combustible waste is separated from the remaining organic/lower grade waste. The remaining waste is then either stabilised by in-vessel composting or anaerobic digestion. The composting or AD process has the effect of significantly reducing the volume of the waste and reducing the biodegradable potential of the residue. The residue is either landfilled or processed further to make a refuse derived fuel.
Policy WP10: Residual waste treatment facilities
Residual waste treatment facilities may be acceptable where the proposed facility is:
- on land within the land-uses set out in Policy WP3, and;
- the proposals meet the development management criteria set out in Policy MW2.
The treatment of waste that could practicably be recycled or composted will not be acceptable. Conditions will be placed on planning permissions to ensure that only residual source-separated or pre-sorted waste is treated. Facilities that include thermal treatment of waste must provide for the recovery of energy and, where practicable, heat; and the use of combined heat and power will be encouraged.
Question 19: Policy WP10 'Residual waste treatment facilities' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
23. Disposal of inert waste by landfill
Many inert wastes can be reused or recycled. Although landfill is the least preferred option within the waste hierarchy, there may be a need for the disposal of inert material to landfill if no other waste management method is practicable. In particular, inert waste can be used to enable the restoration of former mineral workings to a satisfactory landform and afteruse. This may be considered a recovery operation rather than a disposal operation if the Environment Agency considers that the proposal meets one of two recovery tests: Is there a statutory obligation to undertake the work (i.e. has a regulator imposed a legal requirement for the restoration of a site to be completed in accordance with an approved restoration plan), or would it be financially viable for the scheme to be completed using non-waste materials (i.e. the waste is being used as a substitute for non-waste materials)?
In 2017 Norfolk had two inert waste landfill sites. One site is at Cantley and is only for the disposal of waste soils from the sugar beet processing factory; the site is not currently receiving waste as the waste soils are being recycled instead. The other inert landfill site is located at Blackborough End. In addition to these two inert landfill sites, there are a number of mineral extraction sites in Norfolk that are being restored with inert waste.
Any proposals for additional inert waste landfill voidspace would be determined in accordance with Policy WP11 below.
Policy WP11: Disposal of inert waste by landfill
Additional void space for the disposal of inert waste may be acceptable where:
- the importation of inert waste is required for restoration of a former mineral extraction void;
- there is no acceptable alternative form of waste management further up the waste hierarchy that can be made available to meet the need; and
- the proposals comply with the development management criteria set out in Policy MW2, and;
- the proposals demonstrate that, on restoration, there will be improvements to biodiversity, landscape, and/or amenity.
The landfilling of inert waste that could practicably be recycled will not be acceptable. Conditions will be placed on planning permissions to ensure that only pre-sorted wastes are landfilled.
Question 20: Policy WP11 'Disposal of inert waste by landfill' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
24. Non-hazardous and hazardous waste landfill
Landfill sites are facilities where waste is disposed of mainly below ground level. Modern landfill practice requires a significant degree of engineering in order to contain the waste, control emissions and minimise potential environmental effects. The primary by-products of landfilling, where biodegradable materials are disposed of, are landfill gas and leachate (a liquor resulting from water passing through the waste mass) and much landfill engineering is geared towards dealing with these substances. As such, landfill sites require containment lining systems and abstraction systems for both landfill gas and leachate.
Norfolk does not have any hazardous waste landfill capacity. In 2017 Norfolk had an estimated 5.09 million cubic metres of void capacity for non-hazardous waste landfill which was in two sites located in west Norfolk. However, neither of these landfill sites were receiving waste in 2017. Feltwell landfill site has been inactive since 2012 and Blackborough End landfill site has been inactive since April 2016. Feltwell landfill site is currently required to be restored by 2041 and Blackborough End landfill site is required to be restored by the end of 2026.
Most of Norfolk has unsuitable geology for the location of new non-hazardous or hazardous waste landfill sites; these are areas of Major Aquifers and Minor Aquifers that have high vulnerability and intermediate vulnerability. In particular, new non-hazardous or hazardous waste landfill sites would not be suitable within groundwater Source Protection Zones 1 and 2. The land west of the River Ouse is an area of Norfolk that is not an aquifer, however, this area is at high risk of flooding and therefore would also not be a suitable location for a new non-hazardous or hazardous waste landfill site.
Any proposals for additional non-hazardous or hazardous waste landfill voidspace would be determined in accordance with Policy WP12 below.
Policy WP12: Non-hazardous and hazardous waste landfill
Additional landfill void space for the disposal of non-hazardous waste or hazardous waste may be acceptable if:
- it could be designed, built, operated and restored without unacceptable risk to groundwater quality and air quality;
- it would accept only pre-treated wastes (except where pre-treatment is not feasible or necessary, e.g. for asbestos);
- it would not prejudice the movement of waste up the waste hierarchy by providing excessive landfill capacity;
- the proposals comply with the development management criteria set out in Policy MW2; and
- the proposals demonstrate that, on restoration, there will be improvements to biodiversity, landscape, and/or amenity.
The landfilling of waste that could practicably be recycled, composted or recovered will not be acceptable. Conditions will be placed on planning permissions to ensure that only residual source-separated or pre-sorted waste is landfilled. Proposals for landfill gas energy recovery will be required.
25. Landfill Mining and Reclamation
Historically the options for waste management were limited to what would be called 'final disposal' today with little or no recycling or reuse of materials. Over time, uncontrolled landfilling has been phased out, and more stringent regulatory requirements were imposed to ensure the environment and human health were effectively managed. Landfill is now recognised as the least preferred form of waste management through the waste hierarchy and legislative drivers such as the incrementally increasing landfill tax are acting to reduce the viability of landfilling as a means of managing waste. However, Norfolk has a legacy associated with historic mining operations, with approximately 300 historic landfills of various types located across Norfolk.
As resources become scarcer, the value in previously disposed wastes is being increasingly recognised. With the notion of the circular economy gaining momentum, attention is turning towards the potential resource and energy value that could be recovered through extracting material from historic landfills, through a process known as Landfill Mining and Reclamation.
At present, landfill mining schemes are little more than trials, as it is not yet considered to be cost effective at a significant scale. In 2012, Zero Waste Scotland, commissioned Ricardo-AEA to undertake a Scoping Study 'Feasibility and Viability of Landfill Mining and Reclamation in Scotland'. This identified more barriers than drivers to this process at present, although this may change towards the latter parts of this Plan period. In order for this Minerals and Waste Local Plan to be able to respond to any technological advancement in landfill mining, there is a requirement to set out a policy stance.
Landfill mining and reclamation may be required in Norfolk for reasons not linked to purely economic concerns. Examples could include where the historic landfill site suffers from poor engineering, or if it is currently the cause of significant pollution, environmental or health impacts which justifies its reopening.
However, the mining or excavation of waste has the potential to given rise to significant environmental issues. In the case of putrescible waste, this could potentially result in the rapid increase of leachate, landfill gas and odours. Therefore, any proposal will need to demonstrate mitigation of any impact on the local environment and amenity in accordance with other policies in this Plan. Further, landfills are normally a temporary use of land which is subsequently returned to its former, or an alternative use, such as agriculture or biodiversity and the excavation of landfilled waste may disturb previously restored sites or delay the final restoration of sites. Therefore, there are only certain circumstances where it is considered that landfill mining or excavation is justified.
Policy WP13: Landfill Mining and Reclamation
Proposals for the mining or excavation of landfill sites will be permitted where:
- The site (without intervention) is demonstrated to pose a significant risk to human health or safety, and/or;
- The site (without intervention) is demonstrated to pose a significant risk to the environment or;
- Removal of the waste is required to facilitate a major infrastructure project and it is demonstrated that there are no other locations which are suitable for the infrastructure;
- The waste is demonstrated to be suitable for recovery and/or the waste will be captured for fuel/energy as part of the mining operation; and
- The proposals include detailed information upon how the types of waste deposited within the landfill are to be managed; and
- The proposals comply with the development management criteria set out in Policy MW2.
Proposals will be considered in terms of their impact on the restored use, and whether there would be an unacceptable impact on any development which has taken place since the closure of the old landfill.
Question 22: Policy WP13 'Landfill mining and reclamation' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
26. Water Recycling Centres
Water Recycling Centres treat waste water and sewage; they are a vital part of community infrastructure and are necessary to protect human health and water quality. Existing Water Recycling Centres will be safeguarded through the application of Policy WP17.
With increasing populations and water quality standards there is continuing investment being made into waste water treatment. Although changes to permitted development rights have sought to remove the need for planning applications for very small developments there are still applications that will need to be determined.
Policy WP14: Water Recycling Centres
New or extended Water Recycling Centres may be acceptable where such proposals aim to:
- treat a greater quantity of wastewater; and/or
- improve the quality of discharged water; and/or
- reduce the environmental impact of operation.
The applicant will be required to demonstrate that the proposal can be located without giving rise to unacceptable environmental impacts. Proposals must also comply with the development management criteria set out in Policy MW2.
Question 23: Policy WP14 'Water Recycling Centres' - Do you agree or disagree with the proposed policy W11? Do you have any comments or suggestions for alternative policy wording?
27. Whitlingham Water Recycling Centre
Whitlingham Water Recycling Centre, located to the south of Norwich (in South Norfolk District) is the largest such plant in Norfolk. It handles sewage from Norwich and the surrounding rural area and also takes in sewage waste (such as sludge cake and liquors) for treatment from a wider area (including from outside Norfolk). Whitlingham WRC is therefore a vital piece of infrastructure for the implementation of the growth planned in the Norwich Policy Area. Based on Anglian Water's landholdings, there is room for Whitlingham WRC to expand to meet any increased future needs for both water quality improvements and volumetric (capacity) increases.
However, whilst future development on the site will be necessary to better treat waste waters, there is the potential for the site to cause amenity impacts to local residents, particularly from HGV movements, noise and odour. The site's location close to the Broads also raises landscape and flood risk concerns. Recent years have seen a series of developments on the site, some of which have been permitted development, and others requiring planning permission. In the absence of a longer-term masterplan or vision for the future development of the site it is not easy to assess the significance of individual proposals or the cumulative impact of a number of separate, but linked, proposals.
It is acknowledged that Anglian Water's strategic budget is set by OFWAT through the Asset Management Planning (AMP) process in five-yearly tranches, with the current period (AMP 6) running from 2015 to 2020. But the company does not know how much money it will have to spend on improvements during the remaining of the plan period to 2036 which will fall within AMP 7, AMP 8 and AMP 9. There is no public information as to how much money will be spent at Whitlingham.
It is proposed that the existing Whitlingham Local Liaison Group, which debates ongoing operational matters and allows Anglian Water to discuss its future plans for the site, should be expanded, with meetings taking place on a regular basis (perhaps quarterly or six-monthly).
Anglian Water is encouraged to discuss and agree a longer-term masterplan/ vision/ implementation strategy for the site with the local authorities of the Greater Norwich Growth Board and the Environment Agency so that the strategic importance and cumulative impact of individual development proposals at Whitlingham WRC can be most effectively understood and assessed.
The policy sets out the considerations for future development of the site, with the aim of minimising the impact on nearby dwellings and the Broads area whilst recognising the strategic significance of Whitlingham WRC for housing and employment growth in the Norwich Policy Area.
Policy WP15: Whitlingham Water Recycling Centre
Whitlingham Water Recycling Centre is one of Anglian Water's strategic works of particular significance for Norfolk in general, and the Greater Norwich area in particular (with a wider sub-regional role also recognised). Future improvements, whether to increase the physical capacity or to increase the treatment standard of waste waters, will be vital to successful delivery of the planned growth in Greater Norwich and as such are supported in principle.
However, future improvements will need to be planned carefully to minimise adverse environmental and amenity impacts, particularly on the Broads area and nearby residents.
Anglian Water is strongly encouraged to develop and agree a longer-term vision for Whitlingham WRC in collaboration with the constituent authorities of the Greater Norwich Development Board and the Environment Agency.
Anglian Water is strongly encouraged to invite the following parties to the Local Liaison Group: Kirby Bedon Parish Council, Trowse Parish Council, local residents, Anglian Water, the Environment Agency, Norfolk County Council, South Norfolk Council and the Broads Authority. The Local Liaison Group should continue to meet regularly to discuss operational issues and planned site improvements.
The County Council will work closely with Anglian Water, the Environment Agency, South Norfolk Council and the Broads Authority to ensure that development proposals at Whitlingham WRC will:
- Minimise the effect on the amenity of local residents, with particular emphasis on noise and odour;
- Route all HGV movements to and from the site via the C202 Kirby Road and the A146 Loddon Road, with the routing of HGV movements to be controlled through planning conditions or Section 106 Legal Agreement as appropriate;
- Not affect adversely the landscape setting of the Broads by insensitively locating and/or designing equipment or buildings on the site; and
- In line with the requirements of the NPPF and National Planning Practice Guidance, choose preferentially locations within Flood Zone 1, and where locations in Flood Zone 2 or 3 are proposed, adequate measures to control pollution and manage sewage during flooding events are put in place, to be controlled by either a Section 106 Legal Agreement or planning condition(s) as appropriate.
Question 24: Policy WP15 'Whitlingham Water Recycling Centre' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
28. Design of waste management facilities
The National Planning Policy Framework states that "good design is a key aspect of sustainable development, is indivisible from good planning, and should contribute positively to making places better for people". Waste management facilities are often permanent development and therefore their design is just as important as the design of any other development type.
The layout and design of waste management facilities can help to reduce potential impacts, create positive impacts with regard to the public perception of such activities, improve safety and security, as well as increasing operational and/or energy efficiency.
Strategic site layout can also allow for greater opportunities to incorporate elements of visual interest, reflect local identity in the design or provide for effective buffers. Visual design elements of such developments can either seek to facilitate integration into the surrounding landscape or townscape, or create visual interest and highlight innovation.
This policy sets out the criteria for the consideration of the design of waste management facilities.
Policy WP16: Design of waste management facilities
Waste management facilities will be considered favourably where they incorporate:
- designs of an appropriate scale, density, massing, height and materials;
- safe and convenient access for all potential users;
- schemes for the retention of existing and provision of new landscape features;
- measures which will protect, preserve and where practicable enhance the natural, built, and historic environment including the setting of heritage assets; and
- comply with Policy MW4 (climate change adaption and mitigation)
Question 25: Policy WP16 'Design of waste management facilities' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?
29. Safeguarding waste management facilities
The safeguarding of waste management facilities is necessary to protect them from other forms of development which might either directly or indirectly impact upon the waste management facility. Therefore, applications for new development in proximity to existing safeguarded waste management facilities or water recycling centres should take into account any potential conflicts. Local Planning Authorities are therefore requested to consult the Waste Planning Authority if a proposed development is within the consultation area of a safeguarded facility. The safeguarded waste management facilities and water recycling centres will be identified on the Policies Map and are listed in Appendices 7 and 8.
Decisions on whether a proposed development would prevent or prejudice the continued use of a safeguarded facility, and would therefore raise an objection from the Waste Planning Authority, will be made on a case by case basis. Each decision will take into account the particular use of the safeguarded site, the nature of the proposed development, their compatibility and, where appropriate, any mitigation which could address any adverse impacts.
Policy WP17: Safeguarding waste management facilities
The County Council will safeguard existing and permitted waste management facilities, within the following categories:
- Waste management facilities with a permitted input of over 20,000 tonnes per annum;
- Key water recycling centres (listed in Appendix 8);
- Waste water pumping stations;
Consultation areas are delineated on the Policies Map and extend to 250 metres from each safeguarded waste management facility, and 400 metres from each safeguarded water recycling centre. The Waste Planning Authority should be consulted on all development proposals within these consultation areas, except for the excluded development types set out in Appendix 4.
Development proposals within the defined consultation areas around safeguarded facilities should demonstrate that they would not prevent or prejudice the use of those facilities. The County Council will oppose development proposals which would prevent or prejudice the use of safeguarded facilities for those purposes unless suitable alternative provision is made.
In addition, any development proposed within 50 metres of a pumping station (as identified through the planning application) will be subject to consultation with the relevant waste water management company by the planning authority responsible for determining the application.
Question 26: Policy WP17 'Safeguarding waste management facilities' - Do you agree or disagree with the proposed policy? Do you have any comments or suggestions for alternative policy wording?