Question 18: Policy WP9 'anaerobic digestion'

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Initial Consultation document

Representation ID: 93047

Received: 31/08/2018

Respondent: Norfolk County Council - Waste Disposal Authority

Representation Summary:

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

Full text:

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

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)."