Report: Offline Representations. jwcs...1.2 Waste arising s figures queried -Request submission doc...

The West of England Partnership – Joint Waste Core Strategy Preferred Options consultation

Offline Representations

15 January to 12 March 2009

Report: Offline Representations Schedule of Consultation Representations submitted offline prepared and considered by The West of England Partnership and ERM May 2009 Contents Introduction……………………………………………………………………………………………………………………………………….2 Representations……………………………………………………………………………………………………………………….…………3

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Introduction: This report is a brief summary of the issues contained in the offline responses (representations) and supporting documentation received during the consultation on the Preferred Options of the Joint Waste Core Strategy and some late representations made after the 12th March deadline. In the instance that the representation answers a specific question this has been included in the report “Representations by Question”. In the case of most of the 31 offline responses summarised here the supporting information has not specifically addressed a consultation question and has therefore not been captured in the Representations by Question Report.

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Name Representation Comment

267 E58 Indigo Planning

Indigo Planning Limited (“Indigo”) act on behalf of The Prudential Assurance Company Ltd who have significant land ownership interests in South Gloucestershire Council’s administrative area. This is both as part of a tripartite ownership (with JT Baylis and Capital Shopping Centres) as well as land within their sole ownership. This ownership includes the Morrisons Distribution Depot at Lysander Road, Cribbs Causeway (“the site”), which has been identified in the above Core Strategy. Prudential object to the inclusion of this site in the Core Strategy. Seek removal of site at Cribbs Causeway from JWCS- (Deliverability and Authority Ownership Issues). One of the tests of ‘soundness’ set out at-para 4.24 PPS 12 “clear mechanism for implementation”…this is not the case as the site is unavailable. It is considered that the introduction of a waste management facility within the vicinity of the complex would be detrimental to the economic value of the area, given that it has the potential to degrade investment confidence, which in turn would be damaging to the local and regional

ERM has reassessed the former Safeways Depot site at Cribbs Causeway in conjunction with the surrounding land. The whole of this area has the potential to be remodelled in line with South Gloucestershire Council’s vision for a more sustainable community at Cribbs Causeway which is better linked to the surrounding residential areas. The deliverability issues identified by the landowner and potential impact on the strategic road network, in particular, are recognised. In these circumstances that land at Cribbs Causeway will not be included in the Joint Waste Core Strategy as a possible site for a strategic waste management facility. Noted This work has been completed and will be included within the evidence base. Noted. Impact on recreational uses is most appropriately

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economy. Furthermore, a waste management facility would undoubtedly be considered as an unneighbourly use to the extensive residential population (existing and proposed) in the Cribbs Causeway area. In this respect, it is considered to comprise inappropriate development for the site. Proximity to residential query Financial viability of these sites should be included in the JWCS

considered under a development management policy. Locating sites close to urban areas (the main source of waste arisings) is a national, regional and local policy objective. Noted

206 E56 CSJ Planning

1.3 Questioning background evidence was not made available –absence of SFRA questionable soundness. 1.2 Waste arising s figures queried -Request submission doc evidence base to include a map of where waste currently arises and where waste is currently managed. 1.4 Request for sites proposed to be accompanied by comprehensive Ecological Assessments- evidence to be made available as part of the next consultation stage prior to the submission DPD. 1.5 Expectation that the ERM critical review of the evidence base will be made available to the public. 1.7 Waste Capacity breakdown may affect the need for the total amount of facilities and where they are to be located. This information should be published prior to the consultation submission DPD.

This work has been completed and will be included within the evidence base. Noted. Noted. This work has been completed and will be included within the evidence base. The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009 This work has been completed and will be included within the evidence base. The West of England Partnership will be providing a progress

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1.9 To meet capacity consideration of technologies will need to be made and reported in the submission DPD as required by para 18 of PPS10. 1.10 In the absence of (above) information Publication of the Preferred Options may be considered premature and risks being unsound. 2.2 The DPD should ensure flexibility to allow alternative sites and new technologies to come forward. 2.3 The DPD should allow new non-allocated site to come forward within the overall framework. 2.3 Dleiverability questioned- unlikely that all of the 18 sites will come forward, strategy needs to identify more sites than are needed. 2.4 Diamonite Industrial Estate Fishponds has just benefited from planning permission from office development and given its location close to residential properties it is unlikely to be suitable for a number of waste proposals and some types of waste activity. Recommended that the allocation of this site is reviewed. 2.5 Assessing the deliverability of sites should not just consider ‘suitability’ but also its availability and whether it is achievable in terms of both planning and commercial considerations.

update, including additions to the evidence base, in June 2009 This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. This work has been completed and will be included within the evidence base. The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009 Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. Noted. Noted. Noted Noted.

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2.8 The submission document needs to provide a better set of policies concerning development on allocated sites ad clarify that non-allocated sites may also be suitable and supported subject to certain criteria. 3.2 The Preferred Options Doc does not detail how the phasing of composting (and other facilities) is intended to be delivered. The Preferred Options document highlights capacity gaps for 2010,2013 ad 2020 but does not provide any detail on how /where these will be phased. The Issues and options Doc provided more certainty regarding no if facilities needed and their phasing whilst the preferred options document at Table 4 simply outline the capacity needed at 2010 and 2020 with no details of phasing within these periods. This should be rectified in the submission DPD. 3.4/3.5There is a current and immediate need for waste management facilities, which is not adequately addressed in the preferred options document…the Councils should continue to support proposals fir such facilities that come forward on suitable sites prior to the adoption of the strategy. To address existing needs on behalf on new Earth solutions, we put forward six sites …we would like all of these site to be considered in the development of the submission DPD. (Brittania Zinc, Avonmouth; Cabot Park, Avonmouth; Albert Road, St Pillips; Stowey Quarry, Bishop Sutton; Brockley Wood, North Somerset; Heneage Farm, S.Glos).

Noted. Noted. The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009 Noted.

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4.1 The figures used in the Preferred options are misleading and it is unclear how Jacobs have interpreted the figures in the Draft /revised Regional Spatial strategy as the two sets of figures do not tally. 4.4 The Eunomia Report submitted on behalf of New Earth Solutions, as part of the Issues and Options consultation identified that composting capacity in the sub-region is underestimated. It is not apparent that this information as been considered. This has resulted in the identification of a lower level of composting capacity than required. 4.6 Despite the statement at para 6.22 of the preferred options that the capacity targets have not been challenged these were challenge at the previous stage of consultation and should be considered again in drafting the DPD.

5.2 There does not appear to have been an assessment of where waste currently arises and where it is likely to arise in particular given the proposed housing figures for the West of England Sub-Region and proposed Urban Extensions. 5.8 It is recommended that a implementation policy is developed in the submission DPD, as without such a policy, implementation will be difficult. 6.1 The strategy us currently unclear on the size of sites and facilities required to address the identified capacity needs. Whilst it is noted that the DPD will only identify sites

Noted. This work has been completed and will be included within the evidence base. Noted. This work has been completed and will be included within the evidence base. Noted. Noted. Noted Noted

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for strategic facilities, the Preferred Options document does not provide clear guidance on the strategy for delivering smaller, non-allocated sites, and the way in which such sites could help deliver identified waste management capacity. 7.3 With inadequate detail regarding the timing of provision and phasing, if this lack of detail is continued into the submission DPD the strategy is in serious danger of not delivering facilities as quickly as needed. 8.1 The Preferred options Document is virtually silent on the public consultation responses received to date and how they have informed the document. This should be remedied prior to the consultation on the submission DPD. 9.1 The /preferred options document does not provide a detailed fall back strategy or outline the proposed solutions if the strategy fails to deliver the required sites. In relation to ‘environmental protection’ page 16 the planning requirement is to mitigate any losses. The word ‘compensation should be deleted as this word is unspecific and would tend to be considered as a financial payment. ‘Groundwater Protection Zones should moved from the ‘inappropriate for development’ list to the ‘may be appropriate’ list, as appropriate uses could be acceptable subject to suitable mitigation. The document does not explain or justify why it is only

Noted Noted The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009 Noted General areas have been identified when it is not appropriate to be site specific i.e. high turnover or when it is not possible to identify a discrete site. Noted Noted

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suitable for recovery sites to be located at NW bristol, elsewhere in Bristol, Weston, Keynsham and Yate. Other suitable sites should not be discounted, especially given the immediate need for facilities. This policy should be reworded in the DPD. We feel that this option (A) is the least sustainable as it is not flexible enough to cater waste demands, likely changes to technology and provision over the next decade. This option (B) is too reliant on sites in small areas and is not flexible enough to cater the possibility that there may not be suitable sites in the catchments. Option B is considered to be less sustainable than Option C. Option C is our preferred option. It provides for more flexibility, although we feel that there needs to be greater flexibility over the location of sites and the boundaries of the 5 sub-areas.

Noted General areas have been identified when it is not appropriate to be site specific i.e. high turnover or when it is not possible to identify a discrete site. Noted Noted Noted

271 E65 GOSW

Broadly speaking the document is fit for purpose as a Preferred options report, but given my comments below there may be the need for further limited informal consultation on additional elements of the strategy to ensure the requirements of the Development Plan Regulations and the four authorities SCIs have been met before publication. Pg 10 provides a cross ref to the relevance of the respective Sustainable Communities Strategies for each UA. Do all

Noted The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009

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sustainable Community Strategies address the waste issues in the same way or does each authority have different priorities? As this is a Joint Core strategy, would it be more useful if this section clearly explained any differences in these priorities and how this affects the production of the Joint Waste core Strategy? This might equally apply to similar strategies such as each authority’s Climate Change Strategy. The Vision for the document is clear and concise and relates to a clear set of aims. However to aid deliverability it would be helpful if these aims were directly linked to monitoring indicators. The Spatial portrait of the area should also attempt to highlight the main waste arising/waste handling characteristics of the area in spatial terms. What will need to be articulated far more clearly in the publication document is the spatial strategy for the location of waste treatment sites. It is clear from the Preferred option document where some of these sites will be located but it is hard t understand the rationale behind this. …The document at the moment has not got a clear strategic direction. This lack of overarching strategy has a further effect. Clearly in order to meet anticipated levels of waste arisings that are set out in the RSS, a significant level of waste will need to be handled and treated in non strategic sites.

Noted Noted Noted This work has been completed and will be included within the evidence base. Noted This work has been completed and will be included within the evidence base. The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009 Noted This work has been completed and will be included within the evidence base. The West of England Partnership will be providing a progress

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Whilst these individual sites are not strategic in themselves the joint Waste Core Strategy should be setting a clear strategic direction for their location. I suggest this is done by setting out a clear spatial strategy and developing criteria based policy for the location of both strategic and non strategic waste treatment and handling sites. The identification of the list of broad suitable locations would flow from this policy but could also provide a development plan context for the assessment of applications prior to the development of these DPDs by the four authorities. Furthermore such a policy could also be used to assess the acceptability of unanticipated strategic sites, such as may come forward as part of the proposed urban extensions. Related to this the JWCS is far from clear on what constitutes a Strategic waste site. A clearer articulation of the rationale would be useful. Is setting a purely numeric level sufficiently flexible given the possibility of new technology and changes to the waste stream? There is no policy to ensure that essential facilities for the handling of waste such as suitable wharves, railheads and similar facilities are safeguarded for future use. Clearly there are difficulties in finding additional landfill facilities in the sub region and it would not be reasonable to expect the JWCS to find opportunities that do not exist. However there needs to be clear evidence that all opportunities have been investigated, and that there is a

update, including additions to the evidence base, in June 2009 Noted This work has been completed and will be included within the evidence base. The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009 Noted This work has been completed and will be included within the evidence base. The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009 Noted Noted This work has been completed and will be included within the evidence base.

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clear and deliverable strategy for handling and treating this waste outside the authority boundary. PPS12 is explicit on the need for a delivery plan to support the publication and submission of any core strategy. There is very little in the preferred options document to suggest how the delivery strategy is to be developed. There are clear aims for the strategy but it is far from clear how these aims will e implemented – who is going to provide the plant and undertake necessary treatment? A clear monitoring mechanism that feeds into the four authorities Annual Monitoring report would also need to be developed.

Noted

256 E51 Environment Agency

The Agency must advise that further consideration is required in respect of composting facilities. Statement 6.31 should make it clear that small scale composting sites need to be carefully chosen as they also have the potential for odour and amenity problems. Accordingly the Agency request clarification regarding the following issues: Will there be adequate land available for spreading compost ? If not, what other markets will there be for compost? Will the policy direct compost production to PAS 100 specifications? Will the policy consider suitable markets for the final recovery of the compost? The JWCS is not technology specific, however the policies in the preferred options document are. In particular there are specific policies on the technology used for treating organic waste, namely IVC or open windrow composting.

Noted. Noted

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Concentrating on composting facilities restricts the use of other technologies. Would it be better to have a more open policy on the treatment of green food and waste that would be suitable for technologies providing the Best Available Technology? Site Waste Management plans are ideal tools fro reducing the waste produced and increasing the waste recovered and recycled from construction sites. As a planning document is there scope to include Site Waste Management plans as a strong policy that can be disseminated down through the four member Unitary Authorities to incorporate at the local level? Is Table 8 an accurate representation of the available landfill space in the West of England? The figures for Hazardous Waste do not appear to be correct. Further consideration needs to be given to the policies on hazardous waste. The Agency would recommend that the policy regarding the minimisation of hazardous waste should e far stronger… in order reduce the reliance on hazardous waste landfills in other areas. It is quite clear that the potential recovery sites have been screened for flood risk, but it is not clear that the SFRAs have been referred to more widely for example the Sustainability Appraisal (SA) suggests that Options A-C need cross checking with the SFRAs. The Agency would therefore welcome clarification regarding this point.

Noted Noted This work has been completed and will be included within the evidence base. Noted This work has been completed and will be included within the evidence base. Noted This work has been completed and will be included within the evidence base. Potential water pollution risks are most appropriately considered under a development management policy. All site allocations will be subject to flood risk assessments.

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Inert Waste recycling facilities- these are classed in PPS25 table D2 as ‘Less Vulnerable’ development subject to the sequential Test detailed in PPS 25. They are not appropriate in principle flood zone 3b. All potential sites need sequential testing against the relevant SFRA map outputs. Non-inert recycling facilities – the document only proposes to retain existing facilities at this stage. These existing sites could be assessed for flood risk, with any opportunity for flood risk reduction pursued where and when appropriate e.g. site layout changes, redevelopment etc, The Spatial options A-C for Waste recovery facilities need to be sequentially tested against relevant Council’ SFRA or a Joint west of England Waste SFRA document, complied form the existing Councils SFRA’s. In support of the preferred option C, this in effect spreads the susceptibility to flooding across the West of England, giving more resilience in the event of some sites being temporarily affected by flooding- others can remain operational. There are likely to be larger sustainability drivers for siting in accordance with option C, that outweigh the flood risk issue in any case. From a groundwater protection perspective , the identified landfill search areas are appropriate and in accordance with Environment Agency Landfill Directive Regulatory Guidance note 3 (Version 4.0, December 2002). The selected methodology is slightly conservative because some of the areas that could potentially be used for the

Noted This work has been completed and will be included within the evidence base. Potential water pollution risks are most appropriately considered under a development management policy. All site allocations will be subject to flood risk assessments. Noted Potential water pollution risks are most appropriately considered under a development management policy. All site allocations will be subject to flood risk assessments. Noted This work has been completed and will be included within the evidence base. Noted Potential water pollution risks are most appropriately considered under a development management policy. All site allocations will be subject to flood risk assessments. Noted

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location of landfills were excluded. However, the Agency welcomes the adoption pf this precautionary approach. Conversely, some of the identified landfill search areas may be unsuitable, although they are located on non-aquifers. Areas identified that may not be suitable: Sites below the water table in any strata where groundwater provides an important contribution to river flow or other sensitive surface waters, this may apply to non aquifers. This should be taken into account in the site specific assessment. Some of the identified landfill search areas are narrow stretches of land between aquifers. Such locations may be unsuitable due to the proximity of the receptor. Areas that could have potentially been included, but were omitted in the strategy: Major Aquifers and source Protection Zones III where a substantial natural low permeability zone overlies an aquifer, subject to risk assessment. Minor aquifers outside Source protection zones subject to risk assessment. With regard to inert waste, the above Guidance note provide inert waste landfills can be considered as potentially suitable for any locations subject to site specific risk assessment, except within Source Protection Zone 1. From an ecological perspective the Agency would advise that potential strategic sites within the Avonmouth area must consider the adjacent Severn Estuary and the value of local ditch and rhyme networks, which provide a valuable habitat

Noted Noted Noted Noted Noted

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for inter alia water voles. 173 E16 Highways

Agency

The key message from the Highways Agency is the requirement for the Strategic Partnership to demonstrate that the preferred option for waste management are sound in terms of traffic modelling specifically in relation to the impact on the Strategy road Network (SRN). The Agency supports the consideration of co-locating facilities together with complimentary activities. The Agency welcomes the objectives of the sub region to deal with waste within its own administrative boundaries as this will reduce the need to transport waste to areas outside of the sub region. It is acknowledged that the JWCS will only identify sites for the delivery of strategic facilities, whilst individual authorities will have the responsibility f To identify sites for other facilities through their respective site allocation DPD’s. the agency reserves the right to comment upon these as they pass trough their respective LDF processes. The Agency supports a sequential approach to site selection, seeking to locate sites within on the edge or in close proximity to SSCTs as defined by the emerging RSS. The Agency agrees that advantage should be taken within such schemes to introduce new technologies and facilities that can serve the local populations and create more

Noted. Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted Noted PPS10 makes no reference to the proximity principle. Instead, the key planning objectives refer to enabling communities to take more responsibility for their own waste and to enable waste to be disposed of in one of the nearest appropriate installations. Noted Noted PPS10 makes no reference to the proximity principle. Instead, the key planning objectives refer to enabling communities to take more responsibility for their own waste and to enable waste to be disposed of in one of the nearest appropriate installations. Noted

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sustainable patterns of development, which reduces the requirement to transport to wider locations The Agency would like to be consulted upon the location of such facilities during the embryonic stages of potential urban extension schemes. The Agency supports policy for recycling and composting but would still need to be satisfied that any additional facilities would not have an adverse impact on the Strategic Road Network, particularly at rural locations. It is advised in par 6.34 that the sites may be suitable subject to further assessment. The agency would like to be consulted in association with further technical assessments of these sites especially where there is a potential impact on the SRN. Sites 1 & 2 at Welton Sewage works and Broadmead Lane Keynsham are well positioned to serve the south east of the region if preferred Options B or C were to be pursued. Sites 3,4,5,6,7,8 and 12 at Avonmouth have the potential to impact upon the M4, M5 , M49 Motorways and that part of the A4 that forms part of the SRN. Any proposed schemes in these locations would need to be supported by a robust evidence base and the Agency would need to be satisfied that there would not be any unacceptable impacts on the SRN. Site 9, Fishponds, are well located to serve north-east

Noted Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted Noted Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted

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Bristol if access issues can be overcome. The Agency would need to be satisfied that there were no unacceptable impacts on the M32. Site 10, Hartcliffe Way, positioned well to serve South Bristol, the agency would like to see the potential for transport of waste via sustainable modes of transport (i.e. rail) explored. Site 11, St Phillips Mars, this site is well positioned to serve Bristol City Centre. The Agency would encourage investigations into the use if the nearby railway to transfer waste and therefore reduce the potential impacts on the city centre road network. Sites 13, 14 and 15 Weston super Mare, these sites are well located to serve the south of the region. The Agency would need to be satisfied that there would e no unacceptable impacts on the M5 in particular Junction 21 which has significant capacity issues ant peak times. Site 16 Filton Railway Triangle, this site is well located to serve north Bristol. The agency would need to be satisfied that there would be no adverse impacts on the M32 and M5. Site 17 Land at Crooks Marsh, Hallen, the Agency would need to be satisfied that there are no adverse impacts on the M5 and the M49. A robust evidence base would be required that takes into account the potential development at severnside, which is subject to extant ICI planning consents form 1957 and 1958 which permits Use Class B2

Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy.

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an 8 development on a substantial area of land. Proposals for a large distribution centre have recently been outlined by Santon developments close to Crooks Marsh Site 18 Cribbs Causeway former Safeway Depot, The Agency would need to be satisfied that there were no unacceptable impacts on the M5 in particular Junction 17/18. Option A Scenario 1- Whilst the location of a major facility within proximity to the largest urban population (Bristol) is an approach that is supported by the Agency, there are concerns that the large catchment areas that each facility served would create significantly longer vehicle journeys in conjunction with the operation. Option A Scenario 2- The Agency is concerned that the largest population in the area i.e. Bristol would not be served by a bespoke facility and that this scenario would therefore require trips originating in Bristol to travel to Keynsham or Weston. Option B-The Agency supports this approach for identifying sites and the locational spread adopted to deliver Option B. However, the Agency would need to be satisfied that the capacity of each facility was commensurate to the population it served, so as to make optimum use of each facility. The Agency is concerned that the proximity to the primary route network is a positive indicator, which the Agency would like to expand upon whilst it is acknowledged

Noted Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted Noted Noted Development of the spatial options has considered traffic and transport routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. PPS10 makes no reference to the proximity principle. Instead, the key planning objectives refer to enabling communities to take more responsibility for their own waste and to enable waste to be

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that sites need to be accessible there is still the need to ensure that there is no adverse impact on the function and capacity of the strategic Road Network. Option C- The Agency supports the promotion of Option C as the preferred option for the location of strategic recovery facilities, as this approach makes provision for facilities commensurate in capacity to the catchments that they are to serve. Option C would also allow for a greater number of potential sites to be considered and requires fewer overall sites than Option B. An application of any proposed facility would need to be supported by a full Transport assessment ad the Agency reserves the right to comment upon further technical work as it comes forward. Landfill-If the exporting of such waste is a requirement then the Agency would support the approach outlined in paragraph 6.59 for non-inert waste that sees waste transferred by rail. Para 6.6 The Agency would like to be consulted at an early stage regarding the suitability of potential sites identified for landfill operations in the West of England. Para 6.80 The Agency would like to see hazardous waste exported out of the region transported by train to reduce the impact on the SRN.

disposed of in one of the nearest appropriate installations. Noted Noted Noted Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted Noted Noted Policy of the Joint Waste Core Strategy should apply to hazardous waste in addition to other waste streams. Additional consideration is required for those sites situated in an identified

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The Agency reiterates that sites should be assessed using the sequential approach to site selection as it is important that new waste management facilities are located within central and highly accessible locations, which do not encourage additional trips along the strategic Road Network (although the Agency recognise that due to the ‘bad neighbour’ nature of operations that this may not be practicable in predominantly residential areas.

flood zone. Noted Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy.

273 E67 RegenSW

I write to express RegenSW concerns that the West of England’s current site options for waste-to energy facilities (listed in Table 5 of the Preferred options document) are not sufficiently integrated with other energy plans or optimally sized for the most efficient recovery of heat form waste stream. The ‘vision’ set out in the consultation does not identify recycled material or energy as a resource and the ‘aim’ addresses the carbon footprint in terms of reducing a plant’s impact rather than by maximising its energy recovery. It is vital that west and energy planning policies are ‘joined up’ and that these facilities are seen as energy infrastructure (as opposed to just waste treatment facilities) and integrated into local authorities wider energy planning remit (as developed under PPS1 and PPS12) as part of the process of ensuring the optimum development of these long term energy facilities. It is critical that facilities are correctly sited to maximise the use of input fuel. The choice of thermal technology should be guided by energy recovery efficiency. Pyrolysis and gasification can

Noted The Joint Waste Core Strategy will acknowledge and support of generating heat and electricity through waste management processes. Noted Noted

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have advantages over traditional incineration. Thermal waste to energy facilities such as those proposed for the west of England, should be sited adjacent to suitable heat loads and be integrated with local authorities broader energy infrastructure planning. The size of plants should be tailored to the size of available heat loads. This may mean that a number of smaller planets are more appropriate than fewer larger plants. The benefits of reduced carbon emissions (including shorter transport distances, greater diversity (which lowers operational risk) and low local impact need to be included. These benefits counter a simplistic view of the economies of scale which can be attributed to larger installations. The integration of waste to energy with heat loads should not be reserved for new development, if there are opportunities to supply heat to existing local industry or developments. In summary we urge that: Waste to energy facilities are fully integrated with local authorities broader energy planning All proposed sites are optimally sited and sized for CHP All options are evaluated to ensure the most efficient application of the fuel stream in CHP facilities.

Noted Noted PPS10 makes no reference to the proximity principle. Instead, the key planning objectives refer to enabling communities to take more responsibility for their own waste and to enable waste to be disposed of in one of the nearest appropriate installations. Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted Noted The Joint Waste Core Strategy will acknowledge and support of generating heat and electricity through waste management processes. This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments.

290 E74 The Coal Under the heading ‘Other locations where development may Noted

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Authority be inappropriate ‘ The Coal Authority considers that ‘Areas of Ground instability’ should be added to the list of conditions which may make the area unsuitable for waste development. N To comply with guidance set out in PPG14 relating to unstable land. Whilst The Coal Authority has no preference in relation to any particular spatial option, it should be noted that some options can raise the possibility of sites being chosen within areas where mining legacy and ground stability issues may be present. In Option A no issues are present in option b sites in North East Bristol and Yate could potentially raise the possibility of mining/legacy ground stability. In Option C the same comment would apply in relation to Yate. Land stability and mining legacy is not a complete constraint on the new development, rather it can be argued that because mining legacy matters have been addressed the new development as safe, stable and sustainable.

Noted Noted

187 E24 National Grid

The following potential strategic waste management sites which have been identified in the Preferred options document are located within the vicinity of National Grid’s gas and electricity transmission assets: Site 03 Sevalco Plant, Severn Road, Avonmouth Site 12 Land Norh of Severn Road Avonomouth Site 17 Land at crooks Marsh, Hallen National Grid own and operate Seabank 400kV substation which is located within Seabank power Station site. The above sites are located within the vicinity of Sebank substation. While National Grid does not object to future

Noted Noted

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redevelopment in this area, we would like to take this opportunity to highlight that substations are vital to the efficient operation of our electricity transmission network for switching circuits or transforming voltage. The sites are therefore ‘Operational Land’ and there may need to be further essential utility development at the site in future. In addition one of the National Grid’s high voltage overhead power lines which is routed via Seabank substation passes through Site 17 Land at Crooks Marsh, and within close proximity to sites 3 and 12. National grid does not object to the proposals outlined, however the following points should be taken into consideration: National Grid does not own the land over which the overhead lines cross, and it obtains the right form individual landowners to place our equipment on their land. We advise developers and planning authorities to take into account the location and nature of existing electricity transmission equipment when planning a development. Gas-The three sites mentioned above are also located within close proximity to national grids’ 1499 high pressure gas transmission pipeline which runs form Seabank power station. Local authorities have a statutory duty to consider applications for development in the vicinity of high pressure (above 7 bar) pipelines and to advise the developer on whether the development should be allowed on safety

Noted Noted Noted

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grounds on rules provided by HSE. I n order to enable local authorities to discharge this duty and also to ensure that National Grid’s pipelines are protected from uncontrolled development in the vicinity of the pipeline please see following guidance: http://www.nationalgrid.com/NR/rdonlyres/50ACAC0A-ED26-41A7-91FA-83163A98270F/23790/TSPSSW22_J537_Rev0807.pdf

Noted

208 E34 Bristol Civic Society

Facts which became clear at the meeting 1. The consultation was limited to the disposal of WoEs

black bag waste, which excluded the disposal of domestic food and recyclable waste , commercial waste and the construction waste.

2. The Preferred option was chosen by consultants whose report was neither disclosed no summarised.

3. The Consultants brief and the relevant evidence base was not summarised although it may be accessible on a WoE website.

We do not know: The percentage that local authority waste represents to the total. The industry’s capacity to absor the additional waste that all local authorities will divert to it from landfill over the next few years. Market survey of recycled and recovered waste. We do not know: The proportions of the content of the waste disposal industries supply stream.

Noted Waste development policies will generally follow the waste hierarchy and aim to reduce the amount of waste going to landfill. This work has been completed and will be included within the evidence base. The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009 Noted This work has been completed and will be included within the evidence base. This work has been completed and will be included within the evidence base. Noted This work has been completed and will be included within the

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The nature and quantity if materials recycled. The proportion of materials converted into energy The proportion of inert final residue. Will the unreliable end market for recycled materials influence the choice of the waste industry’s disposal processes? We do not know the merits of the advantages and disadvantages of the various methods to compost organic waste….what level of odour do these systems create? Option B where there are the most sites will create least waste transport. This is an over simplification because there are other relevant factors: Did the Woe consultant consider rail transhipment? Will the same facilities be available at all sites? Will the waste disposal contractor e free to import waste from other areas if the economies of scale at a large facility make that an attractive commercial opportunity. The Woe black bag waste stream may give the opportunity to consolidate their existing operation. This possibility could be the factor that determines both the viability and level of a tender. Will waste disposal contractors have the opportunity to tender for all WoE waste to include resident sorted and amenity sites waste? The plan makes proposals for a 20 yr period. During that time there will be significant changes: To waste flows,

evidence base. Whilst policy should encourage new markets, direct control over market for recycled materials is beyond the remit of this Plan. Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. Amenity and health impacts will be assessed as part of the planning application process. In addition, all plant are required to operate to certain legal standards and will be subject to monitoring from the Environment Agency. Further, PPS10 advises that modern plant should not cause health effects. This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. PPS10 makes no reference to the proximity principle. Instead, the key planning objectives refer to enabling communities to take more responsibility for their own waste and to enable waste to be disposed of in one of the nearest appropriate installations. This work has been completed and will be included within the evidence base. Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific

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To waste recycling and recovery processes; To the markets for recycled and recovered materials. None of the options consider: How its waste disposal facilities can adapt to the anticipated changes: The relationship of the Woe local authorities and the waste disposal contractors. It is probable that market forces will cause the waste disposal industry to consolidate. It is important to consider how the Joint Waste policy will give rise to possible adverse incentives. In principle we prefer a policy that maximises the number of waste disposal facilities. The WoE authorities own existing sites. If any are shut it will be difficult t reopen them. This principle must also acknowledged that noise and nuisance that the site causes to local residents the site is an important factor. More sites will make it easier to adapt waste disposal facilities to future changes for waste flow, waste process and changes in the market for recovered materials. More sites make it easier to achieve alternative waste disposal supply sources. We would be interested to review this response in the light of the response from the Woe consultation event to which the waste disposal industry was invited.

treatments. Noted Noted Noted Noted Noted Noted The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009

193 E54 Individual I strongly prefer Option B. This enables recovery to be Noted

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close to waste arisings. The SA and ERM reports have identified Option A and B as finely balanced. The SA and the ERM reports did not cover the environmental issues of individual technologies only in so far as transport movements. Hence it is somewhat objective to put option C ahead of B. Economies of scale for an incinerator are different to a pyrolysis plant. Other benefits such as local heat cannot be easily used if the output is concentrated in Avonmouth. It is better to have waste recovery nearer waste arisings and for communities to have greater responsibility for their waste. More sites means more potential for use of the surplus heat. If an incinerator was built at Avonmouth, most of the heat would be lost and they are not as energy efficient. The urban extensions should have their own waste recovery sites. A study not included in the study of sites is the ‘dumps’ section of Hengrove park. The site is approx 9 ha. It is an ideal location for a waste park with other businesses. It is adjacent to the proposed new hospital and council leisure centre. All the waste recovery technologies produce heat and it is more economical for the heat to be used by large users such as hospital, leisure centres etc. The site became an SNCI about 5/6 years ago but it does not preclude its use as a waste park. The ‘dumps’ site is better located than the Hartcliffe depot

This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. The Joint Waste Core Strategy will acknowledge and support of generating heat and electricity through waste management processes. Noted Noted Noted

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which is in a valley and across a stream. The ‘dumps’ site should be considered. It has its own access from a roundabout, it is hidden from the road due to high mounds and accessible being on the inner ring road. It is not clear if the 11,000 extra homes in South Bristol have been included in the waste calculations. South Bristol will be more densely populated and hence option C will indicate 60k tons seems inadequate.

Noted Noted This work has been completed and will be included within the evidence base.

221 E70 Cllr Claire Young

I strongly agree that we should maximise recycling and am concerned that facilities requiring minimum input streams act as a disincentive to recycling. Para 6.8 I strongly support the ‘proximity principle’ the need to minimise the transport of waste, but I feel there has been some confusion surrounding this for local residents which may affect the consultation responses, based on my experience of attending the Chipping Sodbury drop in event with local people. I do not think the document makes it sufficiently clear that waste will not necessarily be processed in the nearest site. One of the officers at the event explained that if Option B or C was preferred, the local authorities might have a contract with just one of the sites for municipal waste, with the other sites dealing exclusively with commercial waste. Also different sites might have different technologies better suited to some waste streams than others. It appeared that up to that point at least some of the residentshad been assessing the

Noted Noted Development of the spatial options has considered traffic and transport routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy.

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prospect of a facility in Yate based on the assumption that it would deal only with local municipal waste, with all the implication that has for road traffic. I think the document could make a stronger case for CHP facilities in the new developments and explain better how these would relate to the sites identified in the later options. Could they replace the need for some of the capacity elsewhere or are the amounts involved not significant enough to do that? On the basis of the proximity principle I would favour smaller sites dispersed around the area, and this was a preference expressed by the majority at the issues and Options stage. However, I do not believe there is sufficient information provided to judge how any efficiencies of scale with the larger plants balance against the greater travelling distances for waste. For Yate, no site has been identified, only 2 areas in which to search. This not only makes it difficult to make informed comments on the possible Yate facility, it also raises concerns about deliverability. The expectation in the document is that Yate would be delivered in the early part of the timescale (2010-2012\0 but this appears unrealistic without a site identified. A number of residents have expressed concern to me that the document does to identify technologies. They point out that the impact on the local area (in terms of air quality,

Noted The Joint Waste Core Strategy will acknowledge and support of generating heat and electricity through waste management processes. Noted Development of the spatial options has considered traffic and transport routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. General areas have been identified when it is not appropriate to be site specific i.e. high turnover or when it is not possible to identify a discrete site. This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. Pollution impacts are project specific and will be dealt with

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noise visual impact, effect on local highways and so on) depends in part on the type of technology. Para 6.46, acknowledges that the method used for identifying sites might not fully reflect waste arisings within north west bristol as this includes a highly industrialised area at Avonmouth. Has the Waste output of industry been mapped to see if it differs significantly form that predicted by population? While overall the WoE must deal with its own waste within its boundaries they may be cases where waste travels to facilities just outside the boundaries and other waste from just outside travels inwards. When looking at sites relatively close to the edge of the region, such as Midsomer Norton in option B, it would be useful to know if the neighbouring authority plans to put a similar facility just the other side of the boundary. If it did it might make sense to relocate the West of England one.

through the planning application process. The JWCS will provide guidance through a development control policy.. The Habitat Regulations Assessment has addressed potential impacts on international wildlife sites in assessing and selecting the sites to be identified in the JWCS. Impacts on other wildlife is a development control matter and therefore forms part of the planning application process. This work has been completed and will be included within the evidence base. Noted This work has been completed and will be included within the evidence base.

257 E52 Individual Firstly I have to say I found your consultation document very unfriendly. These are of course complex issues but the document rather jumps in at the deep end and uses technical terms without really introducing them. Explain what is being done with the waste now, and where it is done. Only then get into the ‘what might we do about it’ and what is being considered, with a clear explanation of the limits of the current planning exercise. A very important point that is not raised in the options is

Noted Noted Noted

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Flexibility. The baseline figure is 160,000 tonnes pa but that must be subject to a good deal of uncertainty. We need a system that can adapt economically to potentially quite sudden variations. More small units must be inherently more flexible in this respect than one or two very large ones. Getting energy from waste is clearly very desirable but I don’t see how the debate can be divorced from the technology, and indeed the location. Traditional incinerators, digesters producing electricity form methane plus low grade heat and high heat produces like pyrolysis have quite different economics depending where they are and how the heat can be sued. Is the 160,000 tonnes an input figure or net figure? How much output will there be? Isn’t this likely to be classed as hazardous? Where will it go? I can only comment on the site proposed locally in Fishponds the ‘Diamonite Site’ though as I understand it this site covers all the land between lode causeway and Filwood Rd and even included the Riverwood Packaging site which is still an active factory. I am very surprised this site survived the appraisal process and ended up on the final list. The filtering was meant to exclude sites accessed through residential areas. Both ends of the site have current planning permissions for office, or office and warehouse, developments and as I say the Riverwood factory is still very much operational even if

This work has been completed and will be included within the evidence base. Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. This work has been completed and will be included within the evidence base. Policy of the Joint Waste Core Strategy should apply to hazardous waste in addition to other waste streams. Additional considerations is required for those sites situated in an identified flood zone. Noted. General areas have been identified when it is not appropriate to be site specific i.e. high turnover or when it is not possible to identify a discrete site. Locating sites close to urban areas (the main source of waste arisings) is a national, regional and local policy objective. Noted

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some floor area is out of use. The existing road network is extremely congested, especially at school arrival and departure times when Goodneston Rd is frequently locked by the current school and lorry traffic. The obvious unsuitability of the site has already raised considerable opposition. After announcing the site selection in our local Hillfields Focus newsletter I have had a response greater than any previous issue, with over fifty people troubling to mail or hand deliver notes to me opposing this use of the site.

Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted

255 E50 Pelorus on behalf of SITA

Response to Q11 (continued). Specifically SITA would draw attention to the absence of: Strategic Flood Risk Assessment and subsequent Sequential Test against allocated sites required by ‘Planning Policy Statement 25 (PPS25): Development and Flood Risk. Habitats Regulation Assessment (HRA) Required by regulation 48 of the Habitats Regulations 1994. The absence of the SFRA and HRA has the cumulative impact of undermining the credibility of other fundamental components of the required evidence base, specifically the ‘Sustainability Appraisal’ (SA) required by the Planning and compulsory Purchase Act 2004.

Noted This work has been completed and will be included within the evidence base. This work has been completed and will be included within the evidence base.

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In Table 1.1 of the SA ERM schedule the ‘Main issues for sustainable development in the West of England’ both Biodiversity and Flood risk are identified as key issues. Without the findings of the SFRA and HRA to advise on these key issues ERM will therefore have been unable to complete a robust and credible SA. Until the finding of a SFRA and HRA are made available to ERM for incorporation into the SA then it cannot be considered robust and credible enough to constitute the required element of the evidence base. The Joint Waste Core Strategy Preferred options document itself is factually inaccurate when discussing the required evidence base. Indeed the document comes dangerously close to misrepresenting the process of preparation. The ‘Evidence Base’ scheduled on page 4 of the document states that some information is in preparation, but sites the ‘Habitats Regulations Assessment’ as constituting a component of this evidence base. It is considered highly misleading to reference this document at this stage, even under the caveat that some information is in preparation. As the document does not yet exist it cannot constitute part of the evidence base used in preparing the JWCS. There is n o mention in this schedule of the SFRA, which must form a component of the evidence base. Para 6.37 then states:

This work has been completed and will be included within the evidence base. Noted Noted This work has been completed and will be included within the evidence base.

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‘These conclusions, supplemented by the Habitats Directive Assessment and Strategic Flood Risk Assessments, will enable the West of England Authorities to identify the preferred option and the sites necessary to deliver it.’ This constitutes a major factual inaccuracy. The Preferred Options cannot be ‘supplemented’ by two documents which do not exist this clearly misrepresent the evidence base used in preparing the JWCS. SITA consider it essential that the West of England reconsider their Preferred Options for Spatial Strategy and Site allocations once they can be supported by a complete evidence base. Currently the WoEP is exposing itself to a clear risk that when the JWCS is subject to public examination, the Inspector will have no option but to find the document unsound. SITA UK therefore consider it essential that an additional round of consultation is held on the JWCS once the complete evidence base has been considered and incorporated into existing documentation, and the result of this additional consultation considered prior to releasing the document for public examination. Supporting documentation This representation is made in relation to the site identified by ERM as SG39 and described as ‘South of Severnside Works’. This site was not brought forward to the short list of

Noted The consultation was undertaken in accordance with the requirements of the Statements of Community Involvement (SCI’s) of the 4 unitary authorities and legislative requirements. Noted This work has been completed and will be included within the evidence base. Noted The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009 As a result of this representation, ERM have carried out a full Habitats Regulation Assessment and a detailed re-assessment of

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‘Potential Strategic Waste Management sites for Recovery Facilities’ within the Joint Waste Core Strategy Development Plan Document (JWCS) Preferred Options by the West of England Partnership (WoEP) for consultation. Consultation with WoEP cites the conclusions reached by ERM regarding the site as the sole reason for this exclusion. The sole reason for the exclusion given by ERM is as follows; There is the potential for pollutants to enter the estuary via the drain on site. ERM concludes that any waste related development in this location is likely to have a significant effect on the identified European sites. ERM concludes that it is not appropriate to consider this site for development of a strategic waste management facility. This conclusion is drawn primarily on the basis of the site’s proximity to and water borne links with the Severn Estuary Ramsar. Further Habitat Regulation Assessment work would be required if promoting thermal treatment facilities. Furthermore, Site SG39 is low lying and has drains and streams running through it. It lies entirely within identified flood zone 3 The objective of this document is to provide a clear and credible evidence base to support the inclusion of site SG39 in the allocated site shortlist for the Avonmouth area and to demonstrate clearly that the sole concern raised by ERM in relation to the site is both surmountable and unfounded against a robust evidence base.

the site and now recommend that it is allocated for the development of a strategic waste management facility.

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a robust and credible evidence base has been constructed comprising the following key features; ▪ Show that the rhine environment is a consistent baseline and not unique to the site ▪ Demonstrate that the site is supported by key strategic planning policy objectives ▪ Highlight the unique strength of a quantifiable rail link ▪ Demonstrate that a robust SUDS drainage strategy can prevent the risk of pollutants from entering the rhine environment ▪ Prove that a SUDS drainage strategy will have no adverse effect on the velocity of the rhine ▪ Show that the rhine is not at risk of ‘out of bank’ flooding during a 1 in 100 year flood event ▪ Make requisite allowances for climate change ▪ Demonstrate that the combination of drainage and hydrology will have, at worst, a de minimis effect on the European Site In preparing this evidence base SITA UK have commissioned a number of specialist consultants to undertake robust reporting. Conclusions drawn are done so comparatively between reports to understand the ‘in combination’ impact of each aspect. The final conclusion drawn by Ecology Solutions, the specialist ecologists appointed by SITAUK, having considered the proposed drainage solution and hydrology report, states that; ‘It is concluded that the emerging development proposals

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associated with site SG39 ‘South of Severnside Works’ would not give rise to any adverse effects to the Severn Estuary through hydrological impacts, or at worse any effects would be de minimis’ In excluding the site, ERM did not conduct an impact assessment of sufficient detail to reach an accurate conclusion on potential impact on the European site, and no such report has been prepared for comparative sites. It is concluded that the sole concern raised by ERM relating to potential ‘significant impact’ on the European site has been disproved by robust and credible assessment and reporting and that the allocation of site SG39 ‘South of Severnside Works’ should therefore be reconsidered in light of this evidence base. In assessing the deliverability of the site for a potential Recovery Facility the following points should be considered; ▪ The site is under the ownership of SITA UK. ▪ SITA have expressed their intention to bring forward an application for an Energy from Waste facility with Combined Heat and Power offtake on the site. ▪ The allocation of the site would ensure that there was a demonstrable deliverability for the Spatial Options requirements within the area. ▪ A planning application is intended to be brought forward and the site developed within an expedient time frame. Further to the specific study of Red Rhine it should be noted

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that this link with the estuary is not unique to site SG39. Any site within the Severnside / Avonmouth area will be have water borne links to the estuary via the network of drains and rhines insipient to the area. In relation to the location of a large scale recovery facility required by the spatial options (400,000 tonnes per annum Energy from Waste facility) this corridor at Severnside has been promoted as the preferred location. Whilst we entirely support ERM in their intention to protect the links with the Severn estuary from contamination, the rhine network needs to be considered in its entirety. It could be argued that any site proximate to a rhine which eventually outfalls into the estuary has water borne links with said estuary. ERM’s report short lists several sites with rhines either proximate to or adjacent site boundaries whilst failing to shortlist the site ‘South of Severnside works’ on the basis of its water borne links with the estuary. There is severe disparity in this argument. Only specific and quantifiable environmental risks should exclude a site from being considered as a suitable location for waste facilities at this stage in the process. If sites are excluded based on ‘potential’ risk then it would be hard to justify bringing any site forward within Severnside. Due to the complexity of the issue and the preference for detailed consultation with Natural England, The

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Environment Agency and the Internal Drainage Board to support any hydrology and drainage solution, it is recommended that no site should be excluded due to ‘potential’ impact, but rather the correct vehicle of a robust Environmental Impact Assessment should be used to assess ‘actual’ impact at the planning development control stage. Rhines within or proximate to sites should not be considered as an exception, but should rather be considered as a consistent consideration applied to any site within the area. Excluding a site based soley on the proximity of a rhine is not a consistent approach. It sets a dangerous precedent against which the majority of sites within the area could be challenged. If water borne links with the estuary are indeed a reason to exclude sites at the allocations stage then all sites currently allocated in Severnside / Avonmouth would need to be reviewed. It is therefore concluded that the exclusion of the site ‘South of Severnside Works’ due to the proximity of a rhine, and its subsequent water borne links with the Severn Estuary, is not consistent with the allocation procedure and the site’s omission from the allocated site short list should be reviewed in line with comparable circumstances on other short listed sites. A number of detailed reports have been undertaken. They provide a robust and credible evidence base which disprove

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ERM’s conclusion. These reports are included in full in the Appendices of this document. These reports are as follows; ‘Drainage Strategy for Proposed EfW Development’ Richard Jackson PLC ‘Hydrological Assessment’ Millard Consulting ‘Hydrological Impact on the Severn Estuary’ Ecology Solutions Hydrology Assessment-The report concludes that when the proposed surface water discharge via drainage on site is assessed in combination with the existing velocities within Red Rhine, taking into account 1 in 100 year flood information and climate change, there is a de minimis impact upon velocities within the rhine and subsequently the RAMSAR site. This conclusion supports the drainage design and use of attenuation features to prevent pollutants entering the rhine by demonstrating that this drainage design will not result in any detrimental impact to the velocities within the rhine. Ecology Assessment-It is concluded that the emerging development proposals associated with site SG39 ‘South of Severnside Works’ would not give rise to any adverse effects to the Severn Estuary through hydrological impacts, or at worse any effects would be de minimis. In direct response to ERM’s concern over a ‘significant impact’ on the European site it is considered that ERM have not undertaken a study of sufficient detail and scope to assess the likely significant effects of a plan or project

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associated with the site, as would be required even at the first sieving stage of Regulation 48 of the Habitats Regulations. It is understood that no comparative case has been constructed for sites recommended for allocation in the Joint Waste Core Strategy by ERM and that site SG39 ‘South of Severnside Works’ is unique in demonstrating acceptable planning and design in relation to water borne links with the Severn Estuary. We would strongly recommend that site SG39 ‘South of Severnside Works’ is allocated in the Joint Waste Core Strategy as a potential site for waste management development. The site complies strongly with the criteria of national and local planning policy. The site possesses the unique feature of a quantifiable rail link which will serve to lower the carbon impact of the site and mitigate concerns over traffic generation. The site is deliverable and the intent to develop is quantified. Concerns regarding the environmental impact of the site have been disproved by credible assessment and reporting. The site uniquely benefits from robust reporting into the potential hydrological impacts on the Severn Estuary SAC /

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SPA / RAMSAR Site and the findings that there would be, at worst, a de minimis impact.

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E69 Baker Associates on behalf of LandTrust

LandTrust is the controlling landowner promoting the development of the South West Bristol Urban Extension, known as Ashton Park. LandTrust supports the overall waste strategy put forward by the West of England which promotes waste minimisation and recycling, whilst recognising the role recovery has in dealing with the residual municipal and commercial waste once efforts have been made to re-use and recycle waste. The Waste Core Strategy (WCS) Preferred Options report does not specify the time period the WCS covers. The vision suggests that the WCS goes to 2026, however, para 6.2 (table 2) sets out the indicative annual waste management capacity targets for 2020 only. This is the capacity that the rest of the WCS appears to address and therefore, potentially the plan falls short of making provision to 2026. If the WCS is only making provision in relation to capacity targets in 2020, this is inconsistent with the requirement for the time horizon of core strategies to be at least 15 years from the date of adoption (PPS12, para 4.13). The WCS Preferred Options report gives preference to brownfield and urban land (aim number 7). Such a sequential approach does not form part of PPS10, nor should it prejudice the strategy and the consideration of specific sites in the WCS.

Noted Noted Noted Noted

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Potentially, this aim leads to the urban extensions treated as inferior locations when they perform very well against proper sustainability criteria such as energy efficiency, renewable energy use, and reducing greenhouse gas emissions as locations for recovery, particularly CHP facilities. The effects of this aim have been particularly significant in the site assessment process for the WCS, which has effectively discounted the urban extensions from the site assessment process because they are currently in the greenbelt or on greenfield land In terms of recovery facilities, we support the preference for a large network of smaller localised facilities across the plan area because of the way this approach is more likely to accommodate suitable smaller combined heat and power schemes in generating energy close to where it can be used. On this basis, we object to Option A. although Option B is said to be more difficult to deliver because of political, resource, economies of scale and site availability issues. However, given the political resistance to a large scale recovery facility at Avonmouth, Option C appears to be experiencing delivery issues. We support the general approach of Option B in that it lends itself to supporting smaller localised facilities across the plan area. However, we object to the site identification process (referred to in para 6.34) that has lead to the identification of

Noted Noted Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. Noted Noted This work has been completed and will be included within the

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potential sites for strategic recovery facilities in Table 5 of the WCS Preferred Options report. We also object to the sites considered suitable to deliver Options B and C (table 7 and Table 8) because the spatial options presented are based on an incomplete evidence base. Urban extensions have a particular advantage in that energy recovery schemes are more likely to be viable because the expensive infrastructure associated with CHP can be planned comprehensively as part of the wider development and be introduced at the same time as other infrastructure required for a new development, thereby sharing the costs. Retrofitting infrastructure for energy recovery in existing urban areas could render CHP schemes unviable in many places. Page 15 of the WCS Preferred Options report says that the urban extensions proposed in the South West RSS will become priority areas of search for CHP schemes. However, this does not follow in what is set out in tables 5, 7 and 8 or on the spatial options maps presented. The ‘Site Selection Methodology’ report (SLR May 2007) shows that the South West Bristol Urban Extension (SWBUE) was put forward for consideration and given a reference number NS28. However, despite a comment alongside NS28 that ‘urban extensions would be dealt with separately’ (page 31), the SWBUE site is not taken any further in this report / shortlisted for further consideration, nor is it dealt with in the subsequent ‘Detailed Site

evidence base. Noted Noted The Joint Waste Core Strategy will acknowledge and support of generating heat and electricity through waste management processes. Noted

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Assessment’ report (ERM, Oct 2007). It appears that there is a flaw in the methodology for the site assessment process whereby green belt and greenfield sites have been discounted (page 2 of the Site Selection Methodology). However, this ignores the emerging RSS which will remove the urban extensions from the green belt and promotes their development, creating newly urbanised areas. LandTrust object to the way the evidence has been collected – that is – discounting greenfield / green belt sites early on in the site identification process which has been used to inform the spatial options. This is a fundamental oversight of the WCS because CHP schemes in these locations could form a very deliverable and sustainable option for accommodating a strategic waste treatment facility, at the same time as recovering heat and energy for use in the new urban areas. This gap in the evidence base needs addressing and the urban extensions need to considered as part of the spatial options appraisal of identified sites. LandTrust believe that those locations where it is possible to achieve CHP should be part of the spatial options presented, and therefore, the urban extensions should form areas of search that are mapped and referred to as potential sites (such as in tables 5, 7 and 8) in the proposed submission draft of the WCS. The proposals at Ashton Park are very advanced and a planning application for the development including a CHP scheme will be submitted in the summer 2009.

Noted Noted

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The proposals for the development of land at South West Bristol (Ashton Park) are well advanced to begin to address both the landfill diversion targets and the regional renewable energy targets as soon as 2012. On this basis, land at South West Bristol should take the form of a strategic allocation in the proposed submission draft of the WCS. The draft RSS sets a renewable electricity target for the former Avon area of 35-52MWe of installed capacity by 2010. Roughly 50% of the installed capacity of a gasification CHP facility would count towards this target. A gasification facility at Ashton Park would make a significant contribution of about 2.5-3MWe towards this target The draft RSS also sets a target of 100MWth of installed renewable heat capacity for the region by 2010 and 500MWth by 2020. Again, the renewable heat from CHP at Ashton Park would make a significant contribution to this, in the region of 5-10MWth. The local Climate Change Strategies for Bristol and South Gloucestershire Council include cutting greenhouse gas emissions, reducing waste and encouraging renewable energy development (including energy from waste).


34 X1 Kerry McCarthy MP/Wholesale Fruit Centre

I have been contacted by Richard Laurence, the Secretary of the Bristol Wholesale Fruit Centre regarding the Joint Waste Core Strategy. The Centre is understandably very concerned by the

Noted Amenity and health impacts will be assessed as part of the

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proposal to convert the neighbouring transport depot in Albert Rd into a Waste transfer site. Mr Laurence does not feel it is appropriate to sort household and clinical waste next to an open air fruit and vegetable market . Indeed on a previous visit to the Centre I was surprised by the proximity of the existing waste transfer sites so appreciate Mr Laurence’s concern about the impact of another development. They question the possible contamination and the effect on air quality from pollutants and dust, highlighting that misting systems can be ineffective. The Centre also enquires about what risk assessments have been conducted with regard to both employees’ health and the additional traffic, with the potentially dangerous narrow entrance being used by large lorries. I understand there are approximately 500 people employed on the Centres site, and Mr Laurence emphasizes that their produce is used ti supply schools and NHS facilities. I would be grateful if you could review this proposal and the impact on the Centre and reply to me as soon as possible.

planning application process. In addition, all plant are required to operate to certain legal standards and will be subject to monitoring from the Environment Agency. Further, PPS10 advises that modern plant should not cause health effects. Pollution impacts are project specific and will be dealt with through the planning application process. The JWCS will provide guidance through a development control policy. Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted Amenity and health impacts will be assessed as part of the planning application process. In addition, all plant are required to operate to certain legal standards and will be subject to monitoring from the Environment Agency. Further, PPS10 advises that modern plant should not cause health effects. Noted Noted

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Amenity and health impacts will be assessed as part of the planning application process. In addition, all plant are required to operate to certain legal standards and will be subject to monitoring from the Environment Agency. Further, PPS10 advises that modern plant should not cause health effects. Noted Noted Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments.

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Noted Amenity and health impacts will be assessed as part of the planning application process. In addition, all plant are required to operate to certain legal standards and will be subject to monitoring from the Environment Agency. Further, PPS10 advises that modern plant should not cause health effects. Noted This work has been completed and will be included within the evidence base. Noted Noted A range of plant sizes will be required and should be provided appropriate opportunities in the plan

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Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy.

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Noted

149 E5 Individual Whilst this is perhaps the normal approach of the planning process it seems to me very difficult for anybody to comment on a preferred solution when the facts of the options are nonexistent. What sort of facility would be sited in the proposed areas designated in Options A, B or C? If for example Option C is put forward as a solution and the facility is a compost solution in Yate. How much extra traffic would be generated? If this type of facility was expected to generate large volumes of traffic would the plans include provisions for improving the local transport infrastructure? The answer to these questions would help me judge as a resident in the local area if I consider Yate to be a suitable

Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. Development of the spatial options has considered traffic and transport routes at the plan making level. More detailed issues

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option. If for example Option C is put forward as a solution and the facility is a mechanical solution in Yate. How much extra traffic would be generated? If this type of facility was expected to generate large volumes of traffic would the plans include provisions for improving the local transport infrastructure? Would this type of facility generate extra noise heard by local residents? If extra noise is a possible issue how far away from local residential property would this facility be? Again answer to these questions would be the only way to give a useful response to the question put forward to resident at this stage of the planning process. If any of these technologies are to be used in the areas designated what are the impacts on the natural environment such as water causes and wild life. Have these sites been investigated prior to selection to see if any impact is unacceptable? Has anybody investigated the possible impact of the technology to enable the previous question to be answered? I have noticed that one of the Sites, namely Kingsweston Lane, Avonmouth is already designated as a Travellers Site is it really wise to close this site when Spatial Planning departments are following a government directive and under pressure to find extra sites for Travellers and Gypsies? My question for this site is: Has an alternative site been agreed for the travellers as part of this proposal?

are more appropriately considered on receipt of a planning application or under development control policy. This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. Development of the spatial options has considered traffic and transport routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Pollution impacts are project specific and will be dealt with through the planning application process. The JWCS will provide guidance through a development control policy. The Habitat Regulations Assessment has addressed potential impacts on international wildlife sites in assessing and selecting the sites to be identified in the JWCS. Impacts on other wildlife is a development control matter and therefore forms part of the planning application process. This work has been completed and will be included within the evidence base.

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I do believe that it is necessary to find out information about the issue before you can suggest a solution. How can you identify a suitable site without first knowing the site requirements born from investigating the impact of a particular facility or technology?

Noted Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments.

118 E1 Individual In that proposal, it defines ‘small’ open windrow facilities as ‘500 tonnes at any one time.’ I can only presume this tonnage arises by taking the current Exempt level for green waste composting of 1,000 cu metres and using a conversion rate of 0.5. This is somewhat out of date. Recently DEFRA have published a consultation paper, which recognises the problems caused by these Exemptions and has proposed drastic changes. We know that the EA considers open windrow composting to be a higher risk waste operations because instead of phasing the changes in over a 3 year period the consultation document proposes that ‘operators of some higher risk simple exemptions (current para 12 on composting) will need to apply for an environmental permit or stop carrying out the activity’ on or before 1st October

Noted Noted Noted The Habitat Regulations Assessment has addressed potential impacts on international wildlife sites in assessing and selecting the sites to be identified in the JWCS. Impacts on other wildlife is a development control matter and therefore forms part of the planning application process.

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2009 [para 3.10.9 p34]. 5.76 The proposed exemption has been split into two quantity limits; i. 40 tonnes on site at any one time for organizations composting their own waste on site for use on that site; or ii. 25 tonnes on site at any one time for organizations importing the waste and/or exporting the resulting compost. This move will mean that community composting groups will more comfortably fit within the rules of the exemption in the latter category. Please note: in part the current legislation has caused problems because the 1,000 cu metre limit refers specifically to the amount of ‘composting material’ on-site at any one time and material that was not shredded was not legally defined as compost even though it had been sat in green bins and begun the composting process for up to two weeks before being collected. Our understanding is the proposed legislation, in line with the new permits, takes account of the total amount of material on-site, which further restricts the quantities. In the meantime it seems ludicrous for a draft policy to propose that Local Authorities adopt a high risk form of composting (open windrows) at levels which the EA themselves no longer support without much more rigorous risk assessments and monitoring required under the permitting system.

Noted Noted Noted

204 E33 Strategic Not all Waste streams can be treated and will require Noted

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Land Partnerships

disposal to landfill. This needs to be taken into account when assessing future landfill capacity. Larger recycling and composting facilities including recycled aggregate processing facilities should be located in conjunction with landfill facilities to minimize distances traveled and provide economies of scale. The concept of waste resource parks (para 3.8 Preferred Options) should be more strongly promoted. We would support Option C in terms of flexibility/choice which will assist deliverability and reduction in waste transportation. The policies for the requirement for provision of new non-inert landfill capacity are supported. The continued export of waste from the West of England is not sustainable. There should be an acknowledgement of the need for sufficient lead times to enable new facilities to be brought forward. Due to the established lack of ‘void’ capacity in West of England it should be acknowledged that land raise is an appropriate option. Provision should be made within policy and capacity assessment to allow for circumstances where alternative facilities do not come forward. In these circumstances additional landfill capacity may need to be allocated to provide a robust disposal strategy until facilities can be brought forward. As such a ‘sensitivity analysis’ needs to be undertaken to establish what the effect in tonnage/landfill

Noted PPS10 makes no reference to the proximity principle. Instead, the key planning objectives refer to enabling communities to take more responsibility for their own waste and to enable waste to be disposed of in one of the nearest appropriate installations. Noted Noted Noted This work has been completed and will be included within the evidence base.

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capacity terms would be and to assess the impact of a delay in new treatment/technology facilities coming forward. A criteria based policy approach is supported in order to provide flexibility in assessing suitable landfill locations rather than specific Areas of Search. In terms of the assessment work undertaken by ERM to identify Areas of Search this is very much on an overarching macro –scale. In reality impacts will be site location specific and their effect will be dependent on the type and reason for the constraint or designation. As such the ‘buffer’ zones unecessarially exclude large parts of the West of England. The assessment does not justify or explain the constraints used and appears to exclude other key criteria: Geology- The Major Aquifer and SPZ 1,2,3 criteria reflect this to some extent but a further assessment of geological suitability should be incorporated into a criteria based approach. It is acknowledged that one of the aims is to reduce waste transport distances and this should be adopted as one of the key criteria for landfill assessment. Disposal should occur as close as possible to the point of arising. Suitability of the road network should be considered as a criteria. Green Belt- In terms of location of landfill facilities Green Belt should not be considered a constraint (para 6.8 Preferred options Document). The purposes of Green belt designation are not directed towards constraining this type

Noted General areas have been identified when it is not appropriate to be site specific i.e. high turnover or when it is not possible to identify a discrete site. Noted PPS10 makes no reference to the proximity principle. Instead, the key planning objectives refer to enabling communities to take more responsibility for their own waste and to enable waste to be disposed of in one of the nearest appropriate installations. Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues are more appropriately considered on receipt of a planning application or under development control policy. Noted

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of development and landfill sites can be very successfully restored back to woodland/agricultural/amenity uses compatible with that environment. Use of Green Belt as a constraint effectively conflicts with the objective of allocating facilities as close as possible to the point of waste arisings ie population centres and effectively means that waste transportation distances are potentially increased by having to ‘jump’ the Green Belt to reach a landfill disposal point.

292 E76 Dynamic Storage Ltd

I have noted the local press report re the possibility of this district being considered as a waste recycling centre. We own the freehold of this 5.87 acre site currently used for storage and distribution. If the consortium are interested in discussing the future of this site perhaps you will let me know in due course. (Site layout provided illustrating proximity to the new S.Glos Council offices currently under construction).

This representation relates to Dynamic Storage Ltd’s site on Stover Industrial Estate, Yate. This site is in strategic Area A and therefore it is recognised, in principle, that they are appropriate locations for waste management facilities.

64 E44 WP2 Ltd/Minerals Waste Planning

Proposals to provide for facilities for recycling this waste are specifically limited in the plan to existing (but apparently not former) mineral sites, former or existing waste sites (type unspecified) or brownfield or industrial sites in urban or rural locations… the reasoning behind the use of such sites could be usefully clarified in the plan. It does not automatically follow that recycling is more acceptable in land use terms at all of these locations than at others. These sites will have their own limitations and constraints to development that were not previously considered or where an intensification or prolongation of a use over the plan period by a recycling use would not be acceptable. For instance a mineral working may have a

Noted Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments.

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restoration requirement as might a landfill site. Whilst the preference will always be to use such wastes constructively on site where they arise this may not always be possible for a variety of commercial, practical and ‘environmental’ reasons such that other suitable sites where they can be recycled into other useful products will inevitably still be required. However, it is more appropriate for Councils to make adequate provision for recycling facilities to meet an aspiration for a greater amount of recycling. Urban areas are likely to be the principal source of C&D wastes but a network of recycling facilities should be provided to minimize transport mileage and accord with the proximity principle. PPS10 indicates that priority should be given to the re use of previously developed land and states that the concept of co location should be considered in the identification of sites. However, it may not always be possible or desirable for the reasons outlined above to locate these facilities in mineral workings or at waste sites and commercial and industrial waste transfer stations that do not have dedicated plant or space In appropriate circumstances it may therefore be desirable for inert recycling facilities to be located on greenfield sites, especially where their use would accord with the proximity principle; the site is on a primary route and where

Noted PPS10 makes no reference to the proximity principle. Instead, the key planning objectives refer to enabling communities to take more responsibility for their own waste and to enable waste to be disposed of in one of the nearest appropriate installations. Noted Noted PPS10 makes no reference to the proximity principle. Instead,

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amenity/environmental constraints are minimal and it is suggested that this flexibility is properly provided for in the plan. It is also desirable to have a network of both small and larger scale facilities forflexibility. Option A- Too much reliance on only two sites that would not minimise haulage distances. A site(s) at Weston super Mare (thermal treatment) is supported because the town is too far from other possible sites to the north and there are planned development opportunities for DHS/CHP Option B- Again this option is supported in as much as a facility is required at Weston s Mare. Eight sites will spread the environmental load across the Partnership area and concentrating sites in Bristol where most arisings will occur will also maximise the potential for new and retrofit DHS/CHP from thermal facilities. However, this option would not benefit as much from economies of scale and is perhaps too intricate, with catchment areas that are too small for this option to be effectively achieved. Option C- Also supported because of the inclusion of a site(s) at Weston super Mare as set out above in Option A and the better spatial coverage of the Partnership area. However, the capacity of this facility should be increased to allow for the liklihood that arisings from Somerset as well as from Clevedon would be treated; a facility of between 150,000 tpa and 175,000 tpa is therefore considered to be

the key planning objectives refer to enabling communities to take more responsibility for their own waste and to enable waste to be disposed of in one of the nearest appropriate installations. Noted Noted Noted Noted

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more appropriate for Weston. The recovery of energy from waste by thermal treatment is strongly supported. using ‘recyclable’ wastes for energy production may be of greater potential value to society in the longer term. It is necessary for the capacities which are based on a recovery target of 800,000tpa to have sufficient flexibility to treat a greater amount in the event that recycling targets are not achieved. This possibility is alluded to in the two scenarios for Option C. There are concerns about both aspects of the approach taken in the report; these are the non inclusion of other potential sites, the deliverability of the sites that are identified and the deliverability of the level of recovery for the sites identified in the preferred option. It is disappointing that whilst the location of sites is identified and the area (ha) of each site is listed, there are no plans showing the site locations/boundaries other than the diagrammatic representations on the plans that accompany the options. If the plan is to be site specific then these should be shown. The criteria used in the identification of the sites in Table 5 are not specifically listed in the report though on page 15 general principles and approaches are shown. What is the relationship between these general principles and the sites in Table 5?…… this process should be more transparent as

Noted Noted General areas have been identified when it is not appropriate to be site specific i.e. high turnover or when it is not possible to identify a discrete site. This work has been completed and will be included within the evidence base.

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Table 5 includes anomalies such as site 16; although included in the Table this site does not meet the general criteria of being on a primary route and indeed is excluded because of this reason from Option A. The sites that are listed in Table 5 are, however, annotated with comments on particular issues but whilst some are statements of fact others are of a more subjective nature and have not been uniformly applied. It is not clear also why in the consideration of design it is stated that at some sites i.e Nos 1 and 13 stacks should be avoided. These are surely detailed and not strategic matters that should more properly be considered in the development plan documents that will be prepared by the individual Unitary Authorities and in the consideration of individual planning applications. A site specific approach to the strategy will conform to guidance on waste planning and is supported because of the important steer it will provide but whilst the preferred options report indicates that an ERM/SLR study identified the 18 Potential Strategic Waste Management Sites for Recovery Facilities in Table 5, these sites have been identified without a Strategic Flood Risk assessment or Habitats Directive Assessment. It is therefore not unreasonable to conclude that once completed the studies may identify the unsuitability of some of the sites in Table 5 which in turn may warrant a revision of the spatial options. One omitted site is an existing waste transfer and recycling

This work has been completed and will be included within the evidence base. Noted Noted This work has been completed and will be included within the evidence base.

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facility at Warne Road in Weston - s – Mare. This site, which is currently operated by Towens Waste Management, is an established waste transfer and recycling site within a general industrial area which has good access to the primary route network. The submission of a request for a Scoping Opinion from North Somerset Council in 2008 indicates the intention of WP2 to develop part of the site as a recovery (thermal treatment) facility. This site has the potential and deliverability of the other sites identified in North Somerset and its inclusion in the plan as a preferred option site is therefore requested. A spatial distribution of facilities to reflect the location of waste arisings is desirable and recovery facilities at a site(s) in the general area of Weston s Mare is strongly supported.... It is not clear, however, as to how the preferred option or any other option would be achieved in the event of a planning application being approved for a facility at one of the sites whose operating capacity would not meet or might exceed the tonnage identified for the site in the plan or if only a part of the waste management spatial jigsaw actually comes to fruition over the period to 2026. Whilst the plan should identify sites(s) for waste management facilities as required by PPS10 the allocation of operating tonnages to them may serve to militate against the realization of the intricate and equitable pattern that Option 3 seeks to achieve. It is understood that ‘deliverability’ has been used as a selection criterion but only some of the sites in Table 5 are

Noted Noted Noted

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identified as being deliverable and that only short and medium term deliverability may have been assessed. Can it be assumed that sites not identified in the Table as deliverable are therefore not deliverable at all or are not deliverable in the short or medium term only? The factors that might have been considered in defining whether a site is deliverable or not are not presumably will have included the commercial aspirations and development programmes of site owners where known/disclosed? However, the political dimension is a relevant consideration; for instance it is understood that B&NES does not endorse the use of thermal treatment at its sites thereby restricting the range of recovery facilities that might be developed at locations in B&NES. Additionally some sites are already identified for other uses that may be potentially be more attractive to developers than a waste recovery use. If, for whatever reason, the sites shown in the preferred options do not come forward for development as a waste recovery site or are not deliverable within the timeframe of the plan what contingency measures are proposed to deal with the tonnage of waste that is intended to be managed locally through recovery facilities? The fact that different options for essentially the same potential sites propose different throughputs suggests that at the sub regional level some sites or general areas, as some are called, may be able to take in an amount of waste that is


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different (smaller or larger) from that shown in the preferred option thus affecting the overall recovery ‘target’ and spatial pattern of operation.

296 L5 Individual I am the secretary of the PTA in one of the schools that could be affected by your Joint Waste Core Strategy. I felt very strongly that this has not been publicised, and so decide to outline your proposals to parents through a school PTA newsletter. The PTA offered to receive any comments- Enclosed are the comments we received. As a local resident and parent of three young children I strongly oppose the proposal to site a waste disposal facility (incinerator) in a primarily thriving residential area. This contradicts your description of the area as a 'primarily industrial and warehousing' this I believe is a blatant misrepresentation of an area which has a vibrant diverse community made up of families, students, working households and older residents. The issues and concerns such as facility brings to bear on this community are primarily heath and safety. Smoke, gas, ash and heavy metals from incinerators can contain harmful dioxins which are a cause of cancer and therefore detrimental to the health and well being of all in the fishponds area. The increased traffic of comprising of heavy lorries bringing waste to the incinerator, on routes where many infants and primary school children walk to school is not acceptable. ...the quality of life for all fishponds residents as a whole will be reduced from pollutants and foul smelling elements

Waste development policies will generally follow the waste hierarchy and aim to reduce the amount of waste going to landfill. This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. Locating sites close to urban areas (the main source of waste arisings) is a national, regional and local policy objective. Noted Amenity and health impacts will be assessed as part of the planning application process. In addition, all plant are required to operate to certain legal standards and will be subject to monitoring from the Environment Agency. Further, PPS10 advises that modern plant should not cause health effects. Congestion in the area is noted and the site is being considered

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emanating from the site. Why not site the incinerator in wealthy areas of Bristol such as Clifton, Redland or Sneyd Park? Your proposal outlines the limits is 60,000 tonnes per annum of waste to be processed; my understanding is this site will be run by a private company who are looking to maximise profit therefore this figure will no doubt increase during the duration of the contract thus further increasing risks to health and safety to the local community. Irrespective of the benefits of turning waste into energy the location of the proposed site is completely unacceptable given the proximity of the site to residential areas. I firmly believe that there are other solutions to waste management problems in the region and the increased levels of recycling are required before burning of waste. I would like to take this opportunity to comment on how poorly this proposal has been communicated. I believe you had communicated you proposals via local newspapers which I do not purchase; it would have been far more appropriate to communicate such an important local issue to the residents directly through mail rather than chance of finding out about this proposal through irregular sources. I intend to write to my local MP and any other pressure group that will help aid our community t ward off such a wanted crass scheme as this.

further. Noted The Habitat Regulations Assessment has addressed potential impacts on international wildlife sites in assessing and selecting the sites to be identified in the JWCS. Impacts on other wildlife is a development control matter and therefore forms part of the planning application process. Locating sites close to urban areas (the main source of waste arisings) is a national, regional and local policy objective. This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. Waste development policies will generally follow the waste hierarchy and aim to reduce the amount of waste going to landfill. The consultation was undertaken in accordance with the requirements of the Statements of Community Involvement (SCI’s) of the 4 unitary authorities and legislative requirements.

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I believe putting a waste facility so close to 2 school , 2 pre schools and a residential home and food outlets would not only be a risk factor as there are already lots of traffic but it would drive people away from shopping. I can't understand why a waste facility ca not be locate in a less residential area. Consideration needs to focus on potential impact and any health risks from omission/ pollutants. The fishponds site is large in comparison to other possibilities so what other development is being considered?

Noted Amenity and health impacts will be assessed as part of the planning application process. In addition, all plant are required to operate to certain legal standards and will be subject to monitoring from the Environment Agency. Further, PPS10 advises that modern plant should not cause health effects. Congestion in the area is noted and the site is being considered further. Noted. Impact on recreational uses is most appropriately considered under a development control policy. Locating sites close to urban areas (the main source of waste arisings) is a national, regional and local policy objective. Amenity and health impacts will be assessed as part of the planning application process. In addition, all plant are required to operate to certain legal standards and will be subject to monitoring from the Environment Agency. Further, PPS10 advises that modern plant should not cause health effects. General areas have been identified when it is not appropriate to be site specific i.e. high turnover or when it is not possible to identify a discrete site.

287 L4 Individual RE: Proposed incinerator at Goodneston Road Noted

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Firstly the incineration of waste is not without hazard...If it is absolutely necessary should this be done in a highly populated area surrounded by primary schools. Secondly the local road infrastructure is barely able to cope and regularly snarls up with just one large lorry getting blocked by parked cars or narrow roads leading to grid lock. A private company will no doubt be tendering for increased levels of capacity in order to maximise profits. The site may have been designated industrial and warehousing status in the past but it is disingenuous to argue that waste incineration with all its hazards comes under the same category.

This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. Noted Noted Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments.

274 E68 Persimmon Homes Special Projects

Persimmon Homes own land which includes part of Site 14, land adjacent to Site 13 and also part of Site NS17 assessed in the detailed Site Assessment document by ERM. In totality that land comprises Weston Airfield. This is within Area of Search C identified in Policy HMA1 of the Emerging RSS as an area of search for 9000 dwellings. Policy in HMA1 seeks to secure concerted employment led regeneration, whilst safeguarding the integrity of environmental and habitat designations. Persimmon Special Projects (PSP) are working to implement that Policy by promoting planning applications for employment

Noted Noted

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development on land comprising of Site NS17 and Site 14. It is therefore important that the assessment of sites for waste recovery facilities and the preparation of the Joint Waste Core Strategy DPD (JWCS) properly take in to account these wider planning considerations. Our principle concerns are: 1.To identify our land interest in our adjacent to the sites identified in Weston-super-Mare. 2. To register our concern that the inter-relationship between the JWCS DPD, the North Somerset Core Strategy and he Weston Regeneration Area DPD need to be properly considered, in particular in relation to the proposals for the Weston Regeneration area and the identification of a site for a waste recovery facility. 3. To identify a wish for active involvement in the preparation of the JWCS DPD before it is submitted in relation to potential sites at Weston super Mare and our emerging proposals. 4. To object to the lack of detail in the JWCS DPD, which prevents a proper assessment of the impact of the proposed sites in Weston-Super-Mare on our land. Our main objection is to the lack of detail in the document, which has implications for its soundness and we comment further on this below. Paragraph 6.34 says the sites identified in Table 5 “are considered to be appropriate for development of a strategic waste management facility, which includes a range of technologies” and “subject to further assessment these sites may be suitable locations.”

Noted Noted Noted Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. This work has been completed and will be included within the evidence base.

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In general terms we do not think it is appropriate to consider locations for sites until the specific impacts of those sites can be assessed, particularly given the wide range of different technologies and processes which could be employed. Firstly, until the technology is known it is not clear how the potential capacity of the site can be given with any certainty. Secondly, we note in the case of Weston-Super-Mare the capacity required to be met ranges from 100,000 tonnes per annum in Options B and C, to 400,000 tonnes per annum in Option A Scenario 2. The impacts, including environmental and traffic, of these two scenarios will be considerably different. As neither the technology to be used nor the type of facility to be provided is known, the detailed impacts on the Weston Airfield Master Plan cannot be assessed. What the Master Plan does show is that the adjoining uses to both Sites 13 and 14 will be residential and the impacts need to be assessed accordingly. In particular, what impacts would the proposed facility have on noise and vibration, ground and air pollution and smells and odours? What is the impact on flood and traffic and how do these relate to the wider Weston Airfield and Weston Regeneration proposals? The employment led Policy for Weston-Super-Mare is substantially in response to traffic impacts on Junction 21 and the A370 and how do these proposed locations affect this? It is not clear how the consequences of providing recovery facilities will be assessed in both planning and

Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. Pollution impacts are project specific and will be dealt with through the planning application process. The JWCS will provide guidance through a development control policy. Development of the spatial options has considered traffic and transports routes at the plan making level. More detailed issues

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environmental terms within the formal planning process. If these issues are not to be dealt with in this DPD, then it should say so and set out how and where they will be dealt with. We consider this is a fundamental omission in the JCWS DPD and the relationship between this and other documents is addressed further in the section on soundness below. Emerging RSS Policy W2 sets out a sequential approach to the identification of sites and contains criteria for considering new sites, which include use of established and proposed industrial sites. Whilst Sites 13 and 14 at Weston-Super-Mare are existing employment sites, our view is that the future planning context for those sites needs to inform whether or not they are suitable locations for recovery facilities. We consider there are five issues of soundness which need to be addressed. Firstly, the lack of detail of the nature of the facilities at the proposed sites and the inability to assess the impact of those sites render the JWCS DPD unsound, as it fails to set out a robust and credible evidence base. Therefore it fails the “Justified” test of soundness in Paragraph 5.2 of PPS12. Secondly, we note that Paragraph 6.51 of the JWCS DPD says further assessment of the identified shortlisted sites was carried out to assess their availability and long term deliverability. PSP have not been made aware of any proposals to identify land it owns in

are more appropriately considered on receipt of a planning application or under development control policy. Noted This work has been completed and will be included within the evidence base. Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments.

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Weston-Super-Mare for a waste recovery facility. In the light of its emerging proposals to bring forward the land as part of the Weston Regeneration Area and in view of the lack of detail the proposals for the land in the JWCS DPD, PSP consider its land would not be available for a waste recovery facility and for the same reasons it would object to proposals for sites on adjoining land. Therefore the JWCS DPD also fails the “Effective” soundness test in Paragraph 5.2 of PPS12 in relation to the proposals at Weston-Super-Mare, as they are not deliverable. a more general soundness point which needs to be considered. That is whether the overall approach is sound of preparing separate DPD’s for the JWCS and Weston Regeneration Area if they are potentially in conflict or have overlapping or inter-related proposals, such as the potential for heat and energy generation or conflicting environmental impacts. Those issues should be addressed in the North Somerset Core Strategy. in respect of the Sustainability Appraisal in Paragraph 7.2.1 that a number of data gaps were identified and that further assessments are being carried out for biodiversity and flood risks. It is clearly important that the evidence base is completed before the DPD is submitted, if it is to be considered sound. one further comment on the Sustainability Appraisal in respect of soundness. We note in Section 2.3, which deals with the relationship of the JWCS with other Policy

Noted Noted The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009

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Documents, it does not refer to the North Somerset Core Strategy or the Weston Regeneration DPD. There is a brief mention in Section 7, Implementation, to other plans and programmes and 7.1.1 refers to Unitary Authorities needing to work in partnership. None of this deals with the internal conflicts between one Authority’s plans and there is no evidence that this issue has been addressed. ERM have only considered the site and its surroundings in their current conditions. we consider that the site should be assessed in relation to emerging proposals for the Weston Regeneration Area and reference should be made to that and to the emerging PSP Master Plan. It is also necessary to point out that this paragraph and our comments on it would apply equally to Sites NS17 and NS18. Finally in relation to Site NS11 we note that the impact of helicopters flying from the Helicopter Museum on any proposed facility has been completely ignored. In the absence of proper details to enable a full assessment to be carried out, PSP object to Policy 3 and the section of the JWCS DPD relating to Recovery.

Noted Noted Modern waste facilities should minimise the risk of bird strike through design. This is an issue most appropriately considered under development control policy. Noted

179 E21 Saltford Saltford Parish Council is generally content with the Noted

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Parish Council

proposed waste policies but has serious concerns about the analysis leading up to the selection of a preferred option for siting of recovery plants, in particular - a. The consultation document states that, in earlier consultation, a considerable majority of the public and stakeholders were in favour of a large network of smaller localised facilities dispersed across the area. This is not reflected in the present study – or reasoned against. b. Whilst the document provides estimates of the future total waste management requirement it does not give a breakdown of where, geographically, the waste is being generated. In the absence of this information it is difficult to form a view on where facilities are best sited to minimise transport distances c. Although the Evidence Base includes a spatial appraisal and analysis of sustainability issues for the various sites and Options, it is of concern that no attention seems to have been paid to the actual cost of the project. A decision will need to be based on all relevant factors, including a 'through life' financial appraisal showing the comparative costs of the Options and sites within them. d. Related to Broadmead Lane, Keynsham, it is noted that the various Evidence Reports highlight the problems of this location with regard to access, flooding and impact on the A4, which is already at or above capacity. Mention is made of a 2003 estimate of £3M to widen the bridge but no


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updated figure (for 2010?) is provided. Whilst widening of the bridge resolves the problem of access to the A4 (at a price), overloading of the A4 is likely to increase with future development and, if global warming is to be believed, the site and access road will be flooded deeper and more frequently in years to come. All of which makes the case for selection of this site very questionable. NB Concerns have also been expressed over a rumour that a second access is to be provided from the Keynsham/Willsbridge road via Avon Mill Lane. e. On the basis that Bath will be a major generator of rubbish, it would seem sensible to site a recovery facility as close to the city as possible; the Evidence Base (SLR Consulting – Site Selection Methodology – May 2007 – Stage 2 Appraisal) includes a statement concerning a site on the Lower Bristol Road, 'Short List – No Constraint Identified'. No further mention has been found of this site, which is disappointing as it would seem an ideal location to meet the future needs of the area (and might link in to the expansion proposed for the south west of the city).

Noted

272 E66 GVA Grimley on behalf of Del Piero Ltd

We have reviewed the consultation document on behalf of our client Del Piero Ltd (owners of the former Barrow Hospital site) which is allocated as a major development site within the Green Belt in the adopted North Somerset Replacement Local Plan and has the benefit of an outline planning permission for comprehensive redevelopment. The site also forms part of the south west Bristol urban extension area identified for 10,500 new homes in the Regional Spatial Strategy (RSS). Our client is currently

Noted

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working with Land Trust Development on a planning application for this urban expansion, known locally as Ashton Park, which is programmed for submission in late summer 2009. Within this context of major future development, our client is generally supportive of the sustainable principles promoted throughout the document. This focus on locating facilities on industrial/brownfield land is not consistent with the RSS approach of accommodating Bristol’s future growth on Greenfield land in south west Bristol. As part of a sustainable urban extension being masterplanned for Ashton Park, it is proposed that a new waste-to-energy facility adjacent to the A370 is delivered. Whilst the objective of this is primarily to serve the new development, it is intended this should have a wider remit. Furthermore, it would be delivered in advance of the comprehensive development coming forward in totality and therefore will need to be made available to support other local urban areas and adjacent developments. Paragraph 7.3 of the document advises that, “It will also need to enable the integration of waste management facilities within the identified areas of future development, such as the proposed urban extension, and ensure that the waste planning implications of new development are properly taken into account”. This echoes our client’s aspirations to see a waste-to-energy facility brought forward as part of the Ashton Park proposals to support surrounding

Noted Noted Noted

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development. We have included a site plan which illustrates the preferred/emerging location for this facility which will have direct and dedicated access off the A370. In terms of the spatial strategy for the recovery centres, our client supports the preferred option (Option C) as this will facilitate the delivery of the required strategic waste management infrastructure. It provides more opportunities for the commercial sector, requires fewer sites than Option B and captures other benefits derived from economies of scale.

Noted

40 E62 Wrington Parish Council

Wrington Parish Council supports the Vision and Aims of the Joint Waste Core Strategy and in particular to locate development in accordance with land use priorities, giving preference to brownfield land and urban land. We would support the quoted general locations for waste development and the lists of inappropriate and other locations where waste development may be inappropriate. We would support the need to reduce the distance waste is transported. We would also support the link between generation of energy production to use. This is would be easier to provide within new medium to large scale developments. Preferred Options’ identify where but not what – the what is important because of the impact it has on local communities.

Noted Noted Noted This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments.

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On-site management should be considered for all new medium/large scale developments. The focus should be on using industrial sites already equipped with a surface access infrastructure for heavy goods vehicles used in transporting waste. We note - ‘the increased housing numbers through the Regional Spatial Strategy will not affect levels of waste to be planned for’ – it will be essential for the planning of any new development to incorporate waste reduction and waste management. In the race to achieve short-term Landfill Allowance Trading Scheme (LATS) targets we should not procure facilities at inappropriate sites or enter into agreements for inappropriate treatment of waste. Identification of the sources of waste in the West of England, illustrate well that the concentration of effort needs to be with businesses. This has not been the case in the past. Residents, whose contribution to the total amount of waste is minimal in comparison, will again be asked to live with the impacts of waste disposal and treatment. Much more construction waste should be recycled into new and redevelopment and not to landfill. Paras 4.3 & 4.8 These points show a conflict – with 4.3 showing significant waste imported into the West of England

Noted Waste development policies will generally follow the waste hierarchy and aim to reduce the amount of waste going to landfill. Noted Noted Waste development policies will generally follow the waste hierarchy and aim to reduce the amount of waste going to landfill.

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and 4.8 identifying how we must address continuing export of waste. The West of England should not be penalised for dealing with others waste. Support Site Waste Management Plans and the use of Waste Audits to promote the reduction of waste in new development. Green Belt sites including Green Belt sites around urban areas should not be used in preference to industrial/brownfield land. Facilities that are fully enclosed may be acceptable on industrial/brownfield land within urban areas. Rural areas should not be considered for normal/large scale composting facilities requiring excessive and unnecessary journeys of waste from the urban areas of population. Whilst we appreciate the need for cross boundary provision within West of England, locations for waste treatment should be relevant to the local population otherwise waste will not be dealt with close to its point of origin and unnecessary transport movements will have a detrimental impact on communities and increased emissions.

Noted Noted Noted Noted PPS10 encourages community responsibility. Further policies of the plan should not discourage this.

184 E23 KELAGUmwelttechnik

In a first step we allow us to present enclosed our few on future waste management. It is nothing else than our proposal of a sustainable technical solution in waste treatment designed for the West of England, and some kind of help to understand our technology.

Noted

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Maybe this could be a way in approaching local stakeholders for future cooperation or partnership who might be interested in our EfW technology. (Brochure provided)

308 Late email1

Individual I would like to raise questions regarding the proposed Option C which includes a site in St Phillips Marsh. As a resident of Summer Hill I am concerned about the impact any further waste/recycling activities in the area of St Phillips Marsh just across the river from Bath Road, we are in a residential area and have already been adversely effected by the noise from the recycling centres on Albert road. Indeed we have had to make several complaints of noise infringements to stop early morning activity within the curfew times. My concerns centre around the following factors which are defined as assessment criteria for choosing potential sites:: minimise noise/vibration - we are already effected by noise from the current recycling centres especially early mornings minimise odour - increased waste management activity will increase odour which will undoubtedly spread up over the Totterdown residential area minimise nuisance e.g. vermin, pests, litter - there is already a problem with litter this can only increase with increase waste activity, lighting pollution - from evening and early morning activity minimise damage to air quality - concern over increased odour and other emissions that will spread over the residential area

Noted Pollution impacts are project specific and will be dealt with through the planning application process. The JWCS will provide guidance through a development control policy. Pollution impacts are project specific and will be dealt with through the planning application process. The JWCS will provide guidance through a development control policy. Amenity and health impacts will be assessed as part of the planning application process. In addition, all plant are required to

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prevent adverse visual impacts - large waste facilities so close to residential areas will not improve the view and over all ambience of the area There are a number of suitable sites that do not border residential areas so closely and should be considered more seriously than sites in St Phillips Marsh that are overlooked by Summer Hill and the other residential streets this side of Totterdown. if there will be further consultation as I would like to be actively involved.

operate to certain legal standards and will be subject to monitoring from the Environment Agency. Further, PPS10 advises that modern plant should not cause health effects. Noted The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009

302 Late 1

Individual Will there be an independent assessment of the health impact on the local population? Will there be compensation if there is a drop in house prices as a result of the facility?

Amenity and health impacts will be assessed as part of the planning application process. In addition, all plant are required to operate to certain legal standards and will be subject to monitoring from the Environment Agency. Further, PPS10 advises that modern plant should not cause health effects. House prices are not a planning matter.

303 Late 2

Individual I object to the 400,000 tonne mass burn incinerator at Avonmouth I reject options A and C I am in favour of Option B I understand it is particularly important for local views to be stated as government minister Ed Bradshaw, would establish a mass burn incinerator if he could.

This Plan is technology neutral and is therefore not expressing any preference or bias towards / away from any specific treatments. Noted Noted Noted

304 Late Individual We agree in principle with the treatment of waste from Noted

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3 within our catchment area, but not treatment of imported waste. Aggregate reprocessing would produce unacceptable noise levels at the three sites listed potentially for Weston-Super-Mare. We would not wish to have additional waste transportation from outside North Somerset. We would prefer option C, since the one site selected would be processing 100,000 tonnes not 400,000 tonnes pa as the Option A.

Pollution impacts are project specific and will be dealt with through the planning application process. The JWCS will provide guidance through a development control policy. Noted Noted

305 Late 4

Equality and Human Rights Commission

Unfortunately we do not had the resources to respond to consultations unless they concern matters which are directly related to the work of EHRC.

Noted

307 Late6

English Heritage

The Vision and aims set out in the document are most worthy of our support and in particular the commitment to the 3Rs. Our concerns rest however, in about how it is proposed to assess (and in terms of the Sustainability Appraisal score) the potential impact which waste management facilities might have upon historic assets lying some way from the sites of these proposed developments. We are concerned that a waste facility, especially in the recovery of waste materials, may be in order of large scale development with an impact far greater than the current document suggests.

Noted A range of plant sizes will be required and should be provided appropriate opportunities in the plan Noted

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We are therefore pleased to see that one aim is to include reference to the need to safeguard the environmental assets of the Plan area and to protect the quality of life of the communities of the four Authorities. Under “Inappropriate Waste Locations” we note the World Heritage sites are not mentioned. Clearly this is a significant omission given the presence of the major World Heritage Site (WHS) of Bath within the plan area. Whilst there may not be any direct proposal for a waste management facility close to the WHS, the whole of Bath is a working town that will require a significant level of waste disposal. Is there a need to have a special policy relating to Bath that ensures the appropriate level of protection is provided for this asset of international importance whilst recognising its needs as a living community? A significant adverse impact should be scored for any proposed site that would have an adverse impact upon the site or setting of a WHS, Listed Building, Scheduled Monument, Conservation Area or Historic Park and Garden and, in the case of the latter, any proposal that would detract from important views of a Registered Landscape. In terms of the specific Options A, B and C under the Recovery section, the details are too general for us to be able to comment in detail on any historic assets that may be affected by these options. We would therefore simply reserve our views on this part of the plan until more details are available of the site that may go forward into the DPD.


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With Option C however, we would raise concern at this stage over the potential siting of a facility within central Bristol.

252 E47 South West Regional Assembly

We clearly welcome the short and concise format of the document, and the maps depicting the options for delivering waste management facilities. We also welcome that reference is made to the RSS across the document. We support the vision and aims of the Core Strategy as they are consistent with the approach to waste management in the draft revised RSS and the Regional Waste Strategy. We also support that the Joint Waste Core Strategy (JWCS) addresses climate change issues as far as they are waste related or where there are potentials to harness energy from waste. Page 15 and 16 of the Core Strategy contain criteria which at face value are consistent with RSS Policy W2. We particularly welcome the integrated approach to delivering i.e. CHP facilities at the urban extensions proposed in the RSS. It would be beneficial however to subsume guidance for the location of all types of facilities in one upfront criteria-based policy. Broad locations for recovery and landfill already identified could flow from this under separate policies. Also, it appears that the urgency to deliver additional composting facilities in Bristol and South Gloucestershire requires stronger policy steer from the JWCS in order to address capacity issues


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Para. 6.13 asserts that the JWCS could make a contribution to waste minimisation through promoting the reduction of waste in development. We would encourage you to do so and specify regional policy W4 in respect to waste audits to be used in the West of England. Draft revised RSS Policy W1 contains capacity allocations for Municipal Waste and Commercial and Industrial Waste for the Former Avon County. We note that the Core Strategy (Table 1) contains aggregated numbers for both waste streams. The table below highlights the differences between the (aggregated) RSS allocations and the Core Strategy provision numbers (in t/annum), the latter being lower that the RSS provision numbers. This of course results in different capacity gaps for i.e. recycling and composting in Table 3.

We generally acknowledge however that the evidence behind the draft revised RSS figures is relatively old, as the numbers were derived from the Regional Waste Strategy published in 2003. The Secretary of State however proposed that the indicative capacity allocations should now form part of regional policy. The RPB believes that the allocations should provide a general direction of travel to divert waste away from landfill, aiming to achieve a target of

Noted Noted This work has been completed and will be included within the evidence base. Noted

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20% of waste being landfilled by 2020. Recycling capacity remains lower than required by the RSS between 2010 and 2013 but is higher for 2020. There are currently no recovery facilities in the West of England. The Core Strategy will not be formally adopted before 2011. It seems therefore difficult to meet the (aggregated) 2010 target in the RSS for recovery, which is for 370,000-390,000t, or even the lower target taken forward in the Core Strategy (260,000t). The Partnership has undertaken a site selection exercise which is very useful, and this will assist in delivering key waste recovery facilities. Option C for recovery is generally supported as it takes into account the weighting of waste arisings in the sub-region and the results of the Sustainability Appraisal. It also performs well against RSS Policy W2 requirements, and the thrust behind the policy to concentrate facilities in and around the major urban areas. It is however unclear if industry has suggested those sites and as to whether there are real chances for delivery. What happens for instance if no proposals come forward over the next couple of years for developing facilities at those particular sites? We do not know if recovery facility proposals are already in the pipeline which would help to achieve recovery targets in the JWCS. However, should proposals for recovery facilities

Noted Noted Noted

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in line with RSS and JWCS policies come forward now, those applications should be considered favourably provided they perform well against other legal requirements. Again, it would be beneficial to have a criteria-based policy in place to test proposals. The JWCS, under para. 6.25, leaves it to the four unitary authorities to identify sites in their site allocation documents over the plan period to deliver the targets. Some of those facilities will be required within 2010 which is in 9-21 months time (i.e. composting sites in Bristol and South Gloucestershire), even before adoption of the JWCS, which is scheduled for 2011. If those facilities cannot be delivered by 2010, this could potentially result in a need to transport biodegradable waste further afield for treatment. When looking at the Local Development Schemes for Bristol and South Gloucestershire, it appears that (draft) site allocation DPDs will not come forward before 2011 the earliest. Whilst we agree that the Core Strategy should not go into unnecessary detail, the provision for additional composting sites deserves stronger policy steer in the JWCS, preferably as part of an overarching strategic policy. Planning applications for composting facilities could be tested against policy criteria prior to the adoption of site allocation DPDs. This would aid in the timely delivery of the JWCS.

Noted Noted Noted

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Hence any shortfall would need to be met in neighbouring authorities. We understand that the Partnership has commissioned consultants to look in more detail at landfill capacity issues and we welcome that additional information will be available at submission stage of the Core Strategy. Sites for key recovery facilities and Areas of Search for landfill sites, consistent with those criteria, should be identified in more detailed policies.

This work has been completed and will be included within the evidence base. The West of England Partnership will be providing a progress update, including additions to the evidence base, in June 2009 Noted

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