Preferred Options consultation document
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Preferred Options consultation document
1. Introduction
Representation ID: 94667
Received: 25/10/2019
Respondent: Norfolk County Council - Waste Disposal Authority
This consultation response is an internal response by Officers of the County Council in its capacity as the Waste Disposal Authority for Norfolk. It has therefore focussed exclusively on policies relating specifically to waste management. There are no comments on those elements of the review relating to Minerals.
As the WDA for Norfolk, the County Council has a statutory duty under section 51 of the Environmental Protection Act 1990 to arrange:
a) for the disposal of controlled waste collected in its area by the waste collection authorities
b) for places to be provided where persons resident in its area may deposit their household waste.
The County Council in its capacity as the WDA, has a policy for the commissioning of residual waste treatment services that precludes the use of facilities in Norfolk that incinerate residual waste that the County Council as WDA is responsible for. However, 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 are therefore given in a manner that is neutral about waste treatment technology.
No comment is offered on the planning or sustainability implications of specific sites because it is considered that these are matters on which the WDA would remain neutral.
This consultation response is an internal response by Officers of the County Council in its capacity as the Waste Disposal Authority for Norfolk. It has therefore focussed exclusively on policies relating specifically to waste management. There are no comments on those elements of the review relating to Minerals.
As the WDA for Norfolk, the County Council has a statutory duty under section 51 of the Environmental Protection Act 1990 to arrange:
a) for the disposal of controlled waste collected in its area by the waste collection authorities
b) for places to be provided where persons resident in its area may deposit their household waste.
The County Council in its capacity as the WDA, has a policy for the commissioning of residual waste treatment services that precludes the use of facilities in Norfolk that incinerate residual waste that the County Council as WDA is responsible for. However, 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 are therefore given in a manner that is neutral about waste treatment technology.
No comment is offered on the planning or sustainability implications of specific sites because it is considered that these are matters on which the WDA would remain neutral.
Comment
Preferred Options consultation document
1. Introduction
Representation ID: 94672
Received: 25/10/2019
Respondent: Norfolk County Council - Waste Disposal Authority
The Waste Disposal Authority submitted comments during the pre-consultation phase of the development of the Local plan in relation to the general policies and waste specific policies. We are contented that our comments were taken into account at that stage in the development of the policies now presented in the Preferred Options document and will not repeat them in this response.
Nevertheless, we have reviewed the policies contained in the Preferred Options document and their associated Sustainability Appraisals and have very few further comments to add to those already given during the pre-consultation phase.
1.12 of the Preferred Options document recognises that there is currently sufficient permitted capacity in Norfolk to cover the forecast growth in waste arisings to 2036. However, there is a distinction between capacity that is permitted and that which is realistically commercially available to the serve the needs of the Waste Disposal Authority.
In terms of residual waste for which the Waste Disposal Authority is responsible, it is necessary to export much of this outside of Norfolk following either receipt at a transfer station or some degree of pre-treatment and there is currently sufficient permitted capacity for this. The Waste Disposal Authority would not wish the perception that there is sufficient capacity in general to undermine any specific case made for the need for local residual waste treatment capacity.
However, the Waste Disposal Authority does not believe that the Preferred Options document creates such a difficulty. Paragraph 1.12 clearly recognises the contract driven nature of the waste management industry and that any planning application would be assessed against the M&WLPR criteria-based policies.
The Waste Disposal Authority submitted comments during the pre-consultation phase of the development of the Local plan in relation to the general policies and waste specific policies. We are contented that our comments were taken into account at that stage in the development of the policies now presented in the Preferred Options document and will not repeat them in this response.
Nevertheless, we have reviewed the policies contained in the Preferred Options document and their associated Sustainability Appraisals and have very few further comments to add to those already given during the pre-consultation phase.
1.12 of the Preferred Options document recognises that there is currently sufficient permitted capacity in Norfolk to cover the forecast growth in waste arisings to 2036. However, there is a distinction between capacity that is permitted and that which is realistically commercially available to the serve the needs of the Waste Disposal Authority.
In terms of residual waste for which the Waste Disposal Authority is responsible, it is necessary to export much of this outside of Norfolk following either receipt at a transfer station or some degree of pre-treatment and there is currently sufficient permitted capacity for this. The Waste Disposal Authority would not wish the perception that there is sufficient capacity in general to undermine any specific case made for the need for local residual waste treatment capacity.
However, the Waste Disposal Authority does not believe that the Preferred Options document creates such a difficulty. Paragraph 1.12 clearly recognises the contract driven nature of the waste management industry and that any planning application would be assessed against the M&WLPR criteria-based policies.
Comment
Preferred Options consultation document
W1. Waste management capacity to be provided
Representation ID: 94674
Received: 25/10/2019
Respondent: Norfolk County Council - Waste Disposal Authority
WO. 13 above recognises the growth in recent years of pre-treatment of residual waste to generate refuse derived fuel (RDF) for export to combined heat and power plants in mainland Europe and that this has led to the closure of landfill sites that still possess significant consented void space. At the time of writing, the economics have proved more challenging for the RDF export market with lower capacity availability, rising gate fees and less favourable foreign exchange rates. An associated increase in landfill disposal in the UK has been observed. It is therefore reasonable to speculate that currently mothballed landfills in Norfolk could be reopened.
The Waste Disposal Authority recognises that policy WP10 is a planning policy against which any application for any kind of residual waste facility would be objectively assessed. As such, it is recognised that the development of this policy is entirely independent from the development of the Waste Disposal Authority's waste management policies.
WO. 13 above recognises the growth in recent years of pre-treatment of residual waste to generate refuse derived fuel (RDF) for export to combined heat and power plants in mainland Europe and that this has led to the closure of landfill sites that still possess significant consented void space. At the time of writing, the economics have proved more challenging for the RDF export market with lower capacity availability, rising gate fees and less favourable foreign exchange rates. An associated increase in landfill disposal in the UK has been observed. It is therefore reasonable to speculate that currently mothballed landfills in Norfolk could be reopened.
The Waste Disposal Authority recognises that policy WP10 is a planning policy against which any application for any kind of residual waste facility would be objectively assessed. As such, it is recognised that the development of this policy is entirely independent from the development of the Waste Disposal Authority's waste management policies.
Comment
Preferred Options consultation document
Appendix 3 - Existing Waste Site Specific Allocations Policies
Representation ID: 94675
Received: 25/10/2019
Respondent: Norfolk County Council - Waste Disposal Authority
The Waste Disposal Authority notes that Appendix 3 deletes the existing waste site specific policies with a view to determining planning applications on those sites in accordance with criteria-based policies. Although the Waste Disposal Authority has no comment on any specific sites, we can confirm that we have no objection to this general approach.
The Waste Disposal Authority notes that Appendix 3 deletes the existing waste site specific policies with a view to determining planning applications on those sites in accordance with criteria-based policies. Although the Waste Disposal Authority has no comment on any specific sites, we can confirm that we have no objection to this general approach.
Comment
Preferred Options consultation document
Appendix 9 - Forecast Waste Arisings
Representation ID: 94676
Received: 25/10/2019
Respondent: Norfolk County Council - Waste Disposal Authority
Appendix 9 summarises the forecast waste arisings which are covered in more detail in the Waste Management Capacity Assessment. Our comments on the Waste Management Capacity Assessment are made at that part of the consultation.
Appendix 9 summarises the forecast waste arisings which are covered in more detail in the Waste Management Capacity Assessment. Our comments on the Waste Management Capacity Assessment are made at that part of the consultation.
Comment
Preferred Options consultation document
Appendix 10 - Proposed waste management sites
Representation ID: 94677
Received: 25/10/2019
Respondent: Norfolk County Council - Waste Disposal Authority
Appendix 10 details specific sites that have been submitted for allocation. Although the Waste Disposal Authority has a generalised interest in the provision and maintenance of local waste management capacity, it does not wish to comment on specific sites.
Appendix 10 details specific sites that have been submitted for allocation. Although the Waste Disposal Authority has a generalised interest in the provision and maintenance of local waste management capacity, it does not wish to comment on specific sites.
