Question 14: Policy WP5 'Waste transfer stations, materials recycling facilities, ELV facilities and WEEE recovery facilities

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Comment

Initial Consultation document

Representation ID: 92106

Received: 10/08/2018

Respondent: Broadland District Council

Representation Summary:

WP4, WP5, WP7 etc. - a number of policies refer back to WP3 stating that proposals 'may be acceptable on land within the identified uses in', the Policy would be more effective as 'will not be acceptable outside of land identified in'.

Full text:

General point - it is not necessary or desirable for policies to cross-reference to general policy MW2. There is a danger that if you just refer to MW2 this implies that other policies are not relevant, and other policies (e.g. MW 3 and MW4) that might be equally applicable across a range of specific development types may be overlooked .

MW1 - Presumption in favour of sustainable development. This largely duplicates policy contained in the NPPF. As such it is not necessary and conflicts with plan-making guidelines about duplication. It is suggested that it is deleted, and perhaps reworded into appropriate supporting explanatory text.

MW4 - Climate change mitigation and adaption. The wording of this policy is a little unspecific, through the use of "should" and "minimise" and "endeavour", and potentially conflicts with other regimes such as Building Regulations. It is suggested that it is made clear at the beginning of the policy that measures will be encouraged, or expected, to go beyond normal "national" standards if at all feasible, but that this is not a requirement.

MW6 - Agricultural soils. The policy should seek to guide development to the lowest grade of land available, and not lump 3b, 4 and 5 together.

WP2 - Spatial Strategy for waste management facilities. The meaning of the first sentence is unclear. It is unlikely that anywhere will be within five miles of more than one urban area or main town, and the reference to "at least one" implies that encouragement is being given to serving more than one area which could put the focus on a mid-point that poorly serves all areas.

WP3 - Land uses potentially suitable for waste management facilities
The list of potentially suitable land uses, 'within or adjacent to agriculture and forestry buildings' would appear to open up a wide range of sites to possible consideration, although it is understood that sites would need to meet the requirements of the general policies too. Permitted Development also opens up the scope for new build agricultural buildings, with relatively little input from the local planning authority. Consequently, it is suggested that clause d) be caveated 'appropriately located' and 'in established use'.

WP4, WP5, WP7 etc. - a number of policies refer back to WP3 stating that proposals 'may be acceptable on land within the identified uses in', the Policy would be more effective as 'will not be acceptable outside of land identified in'.

WP7 - Household Waste Recycling Centres. The reference to an "appropriate level of developer contributions from new developments will be sought" goes beyond the remit of the Minerals and Waste Local Plan by seeking to be applied to non - mineral or waste development. As such it would make the plan fail the test of legal soundness. Such a policy might be appropriately located within the local Plan of a local planning authority such as a District Council. An example is policy CSU4 in BDC's Development Management DPD 2015.
It would also be difficult to 'retro-fit' new Household Waste Recycling Centres into identified growth locations, if it was not a requirement when those locations were identified. Consideration could be given to allocating sites in the Minerals and Waste Local Plan which have good access to the growth locations.

WP15 - Whitlingham Water Recycling Centre. The majority of this policy is not worded as policy for land use and development, and would appear to be requests, for example Anglian Water being strongly encouraged to develop a long-term vision, and suggestions for the local liaison group and working relationships. Reference to these matters could perhaps be included in the supporting text with, possibly, the policy requiring the demonstration of how any improvement proposals fit into a long-term vision eg 'Any proposals for the improvement of WWRC must to be accompanied by a longer-term vision, produced in collaboration with ...' as this would likely be a consideration in the determination of any proposals.
As regards the Local Liaison Group, it might be worthwhile inviting other nearby Parish Councils in addition to the ones listed (eg Postwick and Thorpe St Andrew).

WP16 - Design of Waste Management facilities. This overlaps with MW2 and MW3. Therefore, this policy might be better placed in the General Policies part of the Plan, and used to cover waste and minerals proposals.

Comment

Initial Consultation document

Representation ID: 92519

Received: 13/08/2018

Respondent: South Norfolk District Council

Representation Summary:

WP4, WP5, WP7 etc. - a number of policies refer back to WP3 stating that proposals 'may be acceptable on land within the identified uses in', the Policy could be more effective as 'will not be acceptable outside of land identified in'.

Full text:

Thank you for your recent consultation on the above document, South Norfolk Council has the following comments to make.

General comments regarding the format of the policies:
Several policies concerning particular development types refer back to 'General' Policy MW2; whilst the reason for this is understood, there are a number of other general policies (e.g. MW3 and MW4) that might be equally applicable across a range of development types, but may get overlooked when development specific policies just refer back to MW2. As the policies in the plan should be read as a whole, is it necessary to have the references back to the general Development Management policies?
In a number of places policies are worded as aspirations, rather than requirements, consideration should be given to moving such wording to the supporting text, or strengthening the wording in the policy itself.

Comments on specific policies:

MW6 - would be more effective if it set out a hierarchy that sought development on the lowest grade of agricultural land first.

WP2 - it is not entirely clear what the first part of this policy is seeking to achieve; if it is seeking sustainable locations within easy reach of centres of population (particularly those that the proposed facilities are serving), the text may need to be expanded to better reflect this.

WP3 - in the list of potentially suitable land uses, 'within or adjacent to agriculture and forestry buildings' would appear to open up a wide range of sites to possible consideration, although it is understood that sites would need to meet the requirements of the general policies too. Permitted Development also opens up the scope for new build agricultural buildings, with relatively little input from the local planning authority. Consequently, could clause d) be caveated 'appropriately located' and 'in established use'?

WP4, WP5, WP7 etc. - a number of policies refer back to WP3 stating that proposals 'may be acceptable on land within the identified uses in', the Policy could be more effective as 'will not be acceptable outside of land identified in'.

WP7 - Concerned that this may not be legally sound, in that it goes beyond the remit of the Minerals and Waste Local Plan by seeking developer contributions. It would also be difficult to 'retro-fit' new Household Waste Recycling Centres into identified growth locations, if it was not a requirement when those locations were identified. Consideration could be given to allocating sites in the Minerals and Waste Local Plan which have good access to the growth locations.

WP15 - elements of this policy would appear to be requests rather than requirements, for example could 'strong encouragement' to Anglian Water be included in the supporting text, and the policy be reworded to say, 'Any proposals for the improvement of WWRC must to be accompanied by a longer-term vision, produced in collaboration with ...'

WP16 - This seems to overlap with MW2 and MW3; therefore, would this policy be better placed in the General Policies part of the Plan, and used to cover waste and minerals proposals?

Comments on Proposed Minerals Extraction Sites:

MIN25 at Haddiscoe - the site is very close to the nearest dwelling and the village generally, it would seem to be quite a significant site in terms of volume of material to be extracted, number of lorry movements etc. (we note there is a balance to be struck between length of extraction time and daily vehicle movements, to address concerns raised by the previous refusal of permission). Is there any scope to reduce the extent of the site, moving the boundary away from nearby dwellings and/or phasing the extraction as part of any mitigation? This, along with the impact on the Grade I Listed church and the visual impact of the proposed bunding, was a concern that South Norfolk Council raised in respect of the previous application on this site. In addition, the landscape assessment refers to mature screen planting, it would be useful if retention of this was picked up in the Initial Conclusion.

MIN 212 at Mundham - The relationship between the site and the processing plant seems to be quite poor, although it is acknowledged that the number of movements are relatively small and this is an existing route. The proposal includes increased bunding to screen the minerals workings, but doesn't indicate if that would be acceptable in terms of the landscape character type within which the site is located.

I hope you find the above comments useful.

Comment

Initial Consultation document

Representation ID: 93043

Received: 31/08/2018

Respondent: Norfolk County Council - Waste Disposal Authority

Representation Summary:

Our comments concerning this policy are along similar lines to those in question 12 albeit for slightly different reasons in some cases.

Whereas the consideration of the size of the facility in terms of its throughput capacity gave rise to our comments in question 12, here it is the specialist nature of the activities proposed when considering reprocessing of ELVs and WEEE in particular that would lead us to caution against the policy unintentionally constraining the development of these facilities should they be proposed.

As respects the development of MRFs, again, if they are particularly large in scale then we would reiterate our comments from question 12.

When considering waste transfer stations however, these issues are of less concern because transfer stations, by their nature, ought to be located close to where concentrations of households are found.

Full text:

Minerals and Waste Local Plan Review - Consultation response from the Waste Disposal Authority

Introduction
This consultation response is an internal response by Officers of the County Council in its capacity as the Waste Disposal Authority (WDA) for Norfolk. It has therefore focussed exclusively on policies relating specifically to waste management and there are no comments on those elements of the review relating to Minerals.

Waste Management specific policies

Policy WP1 - Waste Management capacity to be provided

Question 10a
There is little to pick between the Norfolk SHMA and ONS projections in numerical terms and both can be argued to be realistic. However, the SHMA takes a reasonable and realistic view of the local picture on household growth. It appears the more appropriate tool in terms of the principles on which it is established and its projections seem sensible and realistic.

The general approach of linking waste growth to growth in households is the most appropriate. The LACW figures from 2007/08 onwards as set out in the Waste Management capacity assessment look across the whole of Norfolk and show both increases and decreases between years. This highlights the inherent difficulty and uncertainty in attempting to establish an appropriate waste growth pattern using historical waste data that contains year on year fluctuations.

Some limited analysis by the WDA has shown that waste per household levels tend to remain relatively static over longer periods of time even if they can be subject to short term fluctuations. It is reasonable to assume that it is the number of households that is fundamentally driving longer term trends in levels of waste. On that basis, using household growth is an appropriate principle.

Question 10b
The WDA is less well placed to comment on forecasting commercial and industrial waste because it does not have the statutory responsibility for dealing with it or to compile data on it.

Question 11
We do not have any specific drafting to put forward as an alternative but would comment as follows.

The consideration of proximity to urban settlements is, on the face of it, in the combined interests of the WDA and Norfolk's WCAs. In theory, this should reduce transportation costs for the WDA and increase the efficiency of collection rounds for the WCA. However, where waste treatment facilities operate at a more industrial scale (higher than 75,000 being an example given in the consultation document), waste will often travel from considerably further afield and be drawn from a far wider area than the immediate locality.

We would therefore caution against the policy creating an unintended constraint on the development of waste treatment capacity at a larger scale. In general, sourcing a site that is available and suitable for a larger waste facility is more difficult than for smaller facilities and the WDA would want to see that there remains sufficient flexibility in this policy to ensure that the waste management industry has a wide enough range of options when considering sites suitable for such a facility.

Question 11a
On the basis of the above comments, whilst understanding the additional complications it may present from a policy point of view, a principle as set out in alternative options 2 or 3 would reduce the risk of this policy placing undue restrictions on the location of industrial scale facilities.

As respects the provision of Recycling Centres, some of the WDA's facilities are located near Key Service Centres. However, where new facilities have been developed in recent years, the tendency has been to seek sites closer to centres of population.

Question 12
Whilst we would broadly agree with the general thrust of the policy, the WDA see no reason why a site that was formerly a landfill site could only be considered suitable for a waste management facility on a temporary basis (unless this is specifically referring to facilities built directly on the waste burial area). Nationally, there are examples of waste management facilities being developed on a site formerly operated as a landfill site, adjacent to closed landfill cells. The long standing association of the site with a waste management use has been advantageous in a number of ways and has proved a good fit with the broader site continuing to be in use as a waste management site but having changed to a cleaner, more modern method of waste management.

Question 12a
We would agree that the experience of having allocated 29 sites previously, having had none of them developed whilst permissions have been granted on other sites does point away from an approach of allocating sites and towards criteria based policies.

Question 13
On the basis that it does not fall to the WDA to commission services for these sorts of wastes beyond the small amounts collected at our recycling centres (for which existing offtake capacity is used) the WDA is not best placed to offer a useful comment on this question.

Question 14
Our comments concerning this policy are along similar lines to those in question 12 albeit for slightly different reasons in some cases.

Whereas the consideration of the size of the facility in terms of its throughput capacity gave rise to our comments in question 12, here it is the specialist nature of the activities proposed when considering reprocessing of ELVs and WEEE in particular that would lead us to caution against the policy unintentionally constraining the development of these facilities should they be proposed.

As respects the development of MRFs, again, if they are particularly large in scale then we would reiterate our comments from question 12 above.

When considering waste transfer stations however, these issues are of less concern because transfer stations, by their nature, ought to be located close to where concentrations of households are found.

Question 15
We would broadly agree with the proposed policy and have no further comments to make.

Question 16
Policy WP7 offers appropriate additional flexibility to that offered by WP3.

Question 17
We would broadly agree with the proposed policy and have no further comments to make.

Question 18
We would broadly agree with the proposed policy and have no further comments to make.

Question 19
The County Council in its capacity as the WDA, has a policy for the commissioning of residual waste treatment services that precludes the development of facilities in Norfolk that use incineration to treat residual waste in that the County Council as WDA is responsible for.

Our comments here are made in clear recognition that the function of the County Council as a planning authority is separate from its function as a WDA and given in a manner that is neutral about waste treatment technology.

There are few comments to make other than those already made in relation to policy WP3 in the response to question 11 earlier.

We agree that the facilities should only be treating residual waste.

We would agree that any proposed thermal treatment process should recover energy as a minimum and preferably heat also. Incineration without energy recovery would only be appropriate for small scale operations such as pet crematoria or clinical waste incineration, both of which we assume are outside of the scope of this policy.

Question 20
Since the WDA do not routinely commission services for this sort of waste we are not best placed to offer comments.

Question 21
We agree with the proposed policy wording.

Question 22
The wording of the policy is pragmatic and appropriate.

Question 23 & 24
No comments.

Question 25
No further comments

Question 26
No further comments

Further comments on the Waste Management capacity assessment
P6 states that the WDA "maintains detailed records of the amounts of Local Authority Collected Waste that is collected by the Waste Collection Authorities (District, Borough and City Councils)."

This is correct in itself but it would be more accurate to reflect that the records include waste collected by the WDA (at its HWRCs and through the third party recycling credits payments). A simple re-wording would deal with this and it could read: "...maintains detailed records of the amounts of Local Authority Collected Waste collected by the Waste Collection Authorities (District, Borough and City Councils) and by Waste Disposal Authority (the County Council)."