Waste Management Capacity Assessment 2017

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Comment

Background documents

Representation ID: 94679

Received: 25/10/2019

Respondent: Norfolk County Council - Waste Disposal Authority

Representation:

Summary:
- The Capacity Assessment remains a robust basis for the development of the Local Plan.
- There are a few comments on movements in the local and national waste markets.
- Current volatility in refuse derived fuel export markets illustrates how quickly local operations can change from pre-treatment to transfer.
- Although the capacity assessment would naturally state there is more capacity than is truly available, it is not a cause for concern given how applications are determined.
- Though some reductions in LACW levels are observed, the WDA predicts a general upward trend.

We have reviewed the Waste Management Capacity Assessment and consider that, as respects how it addresses Local Authority Collected Waste (LACW); it remains an appropriate and robust basis for the development of the Local Plan.

Accordingly, we have a few general comments below given in the context of the movements observed in waste volumes and in the local and national waste market at the time of writing. These comments may provide additional context but they do not fundamentally call into question any part of the Waste Management Capacity Assessment.

Table 3 on page 10 refers to "transfer" facilities and a larger amount of waste served by "transfer/treatment" facilities. Defining facilities in this way is appropriate in general given that these facilities often perform waste pre-treatment, treatment and waste transfer operations.

However, the current volatility in the market for the export of refuse derived fuel (RDF) is illustrative of how quickly sites can change their operations from pre-treatment to transfer. At the time of writing there is anecdotal evidence, nationally and locally; of RDF production operations resorting to considerable use of contingency operations such as transferring untreated waste for UK based Energy from Waste treatment or landfill. In addition, there is anecdotal evidence of RDF production facilities being mothballed and the sites they were using reverting almost entirely to their previous function as a transfer station. This point does not undermine the assessment of existing permitted capacity undertaken - we understand that this is based on what is permitted rather than what is operating at any given point in time.

What is relevant to the determination of any future applications for waste treatment operations however, is that the capacity assessment will naturally have the potential to overstate the treatment capacity that is practically and commercially available in Norfolk. In line with our comments at 2.4 above, this is not considered by the Waste Disposal Authority to be a cause for concern. We would not consider that this would be likely to obstruct the development of waste treatment infrastructure given that there are other considerations that would carry weight in the determination of any application.

Paragraph 2.3 on page 10 of the document deals with landfill capacity. Without commenting on the plans for specific sites mentioned or the commercial plans of their operators, it is worth noting that the volatility in the market for RDF export at the time of writing is leading to an increase in the use of landfill for the disposal of waste in the UK.

Paragraph 3.3 refers to waste travelling from Norfolk to Wisbech for RDF processing. The annual tonnage at the time of writing is more in the region of 33,000. However, as mentioned previously, the RDF market is volatile at the time of writing and there could be substantial reliance on contingency disposal to landfill. Moreover, this contract ceases in 2021 so this waste movement may or may not cease after then.

Section 4 of the document deals with projections of waste arisings. The Waste Disposal Authority can only comment with any authority on projections relating to Local Authority Collected waste (LACW). Having reviewed the projections, it is the view of the Waste Disposal Authority that they remain robust projections based upon sound logic. In line with the requirement to avoid "spurious precision", the short-term effects of economic downturns are recognised. The Waste Disposal Authority would agree that the general trajectory for the amount of LACW is upward whilst the potential for short term downward shocks linked to economic cycles remains.

Note that the final line of the 3rd paragraph of page 6 of the document appears to contain a minor error, in referring to "...sites over 2000tpa" when it is assumed that this should read "...sites over 20,000tpa".

Full text:

We have reviewed the Waste Management Capacity Assessment and consider that, as respects how it addresses Local Authority Collected Waste (LACW); it remains an appropriate and robust basis for the development of the Local Plan.

Accordingly, we have a few general comments below given in the context of the movements observed in waste volumes and in the local and national waste market at the time of writing. These comments may provide additional context but they do not fundamentally call into question any part of the Waste Management Capacity Assessment.

Table 3 on page 10 refers to "transfer" facilities and a larger amount of waste served by "transfer/treatment" facilities. Defining facilities in this way is appropriate in general given that these facilities often perform waste pre-treatment, treatment and waste transfer operations.

However, the current volatility in the market for the export of refuse derived fuel (RDF) is illustrative of how quickly sites can change their operations from pre-treatment to transfer. At the time of writing there is anecdotal evidence, nationally and locally; of RDF production operations resorting to considerable use of contingency operations such as transferring untreated waste for UK based Energy from Waste treatment or landfill. In addition, there is anecdotal evidence of RDF production facilities being mothballed and the sites they were using reverting almost entirely to their previous function as a transfer station. This point does not undermine the assessment of existing permitted capacity undertaken - we understand that this is based on what is permitted rather than what is operating at any given point in time.

What is relevant to the determination of any future applications for waste treatment operations however, is that the capacity assessment will naturally have the potential to overstate the treatment capacity that is practically and commercially available in Norfolk. In line with our comments at 2.4 above, this is not considered by the Waste Disposal Authority to be a cause for concern. We would not consider that this would be likely to obstruct the development of waste treatment infrastructure given that there are other considerations that would carry weight in the determination of any application.

Paragraph 2.3 on page 10 of the document deals with landfill capacity. Without commenting on the plans for specific sites mentioned or the commercial plans of their operators, it is worth noting that the volatility in the market for RDF export at the time of writing is leading to an increase in the use of landfill for the disposal of waste in the UK.

Paragraph 3.3 refers to waste travelling from Norfolk to Wisbech for RDF processing. The annual tonnage at the time of writing is more in the region of 33,000. However, as mentioned previously, the RDF market is volatile at the time of writing and there could be substantial reliance on contingency disposal to landfill. Moreover, this contract ceases in 2021 so this waste movement may or may not cease after then.

Section 4 of the document deals with projections of waste arisings. The Waste Disposal Authority can only comment with any authority on projections relating to Local Authority Collected waste (LACW). Having reviewed the projections, it is the view of the Waste Disposal Authority that they remain robust projections based upon sound logic. In line with the requirement to avoid "spurious precision", the short-term effects of economic downturns are recognised. The Waste Disposal Authority would agree that the general trajectory for the amount of LACW is upward whilst the potential for short term downward shocks linked to economic cycles remains.

Note that the final line of the 3rd paragraph of page 6 of the document appears to contain a minor error, in referring to "...sites over 2000tpa" when it is assumed that this should read "...sites over 20,000tpa".