Replacement Waste Local Plan Preferred Approach

Replacement Waste Local Plan – Preferred Approach

WIVENHOE TOWN COUNCIL feel very strongly that whilst there has been a lot of information made available in respect of the Replacement Waste Local Plan – Preferred Approach, that information is complex, and the documents very difficult to understand or negotiate. Accordingly, we feel very strongly that we the Councillors, and the people of Wivenhoe should have been briefed, and an effort made to allay local fears by sharing knowledge.

Whilst we are broadly in support of what is proposed for the whole county, recognising as we do that we have to take a responsible approach to waste disposal, we do not feel that Wivenhoe is a suitable location. Our position has to be that we will resist any proposal unless we fully understand them, sufficient detail is provided for all the stakeholders to understand any proposal and its implications, and if the people of Wivenhoe direct us to accept them.

PROPOSED VISION

By 2032, Essex and Southend-on-Sea will have achieved net self-sufficiency in our waste management, where practicable. Households, businesses, the public sector and voluntary organisations within the Plan area will be taking responsibility for waste reduction, re-use and recycling. Where waste is subsequently created, all opportunities to recover the value from waste will be explored in order to minimise the amount of waste sent to landfill in accordance with the notion of the ‘circular economy’ and the potential for waste to act as a resource. The Plan will provide sufficient waste management infrastructure in Essex and Southend-on-Sea to meet the existing and forecasted amount of waste expected to arise over the Plan period. The forecast includes allowance for an annually decreasing proportion of London’s waste exports to the Plan Area, as informed by the London Plan 2015, which states that Greater London will be working towards managing the equivalent of 100% of waste arising in London inside their Plan area by 2026. Waste management facilities will be located, designed and operated to minimise potential adverse impacts on the general amenity of local communities, the natural environment, the landscape and the townscape of Essex and Southend-on-Sea. Opportunities to enhance such features will be supported. The Plan will offer a degree of flexibility whilst still maintaining a Plan-led approach to the delivery of waste management facilities, which is sympathetic to the Waste Hierarchy. The co-location of complementary waste facilities and non-waste developments (e.g. housing and employment) will be encouraged, where appropriate, to facilitate synergies and efficiencies in waste management and transport, whilst recognising the potential risks of cumulative impacts.

Wivenhoe Town Council agree in principle to the vision that is set out, but have deep reservation with regard to the detail of the plan, and object strongly to undefined commercial or industrial use of the proposed site.

PROPOSED STRATEGIC OBJECTIVES

SO1. To work with partner organisations, including District, Borough and City Councils, the Waste Disposal Authorities, Waste Collection Authorities, the Environment Agency, the waste industry, the business sector and voluntary organisations to promote and maximise waste prevention measures amongst all waste producers, both from the business sector as well as consumers.

SO2. To support an increase in the proportion as well as the quantity of waste that is re-used, recycled and recovered within the Plan area to meet local targets for recycling and recovery.

SO3. To safeguard and encourage opportunities to enhance existing strategic waste infrastructure at sites that serve the Plan area.

SO4. To achieve and thereafter continue to deliver net self-sufficiency in waste management by 2032, where practicable, with an associated reduction in the amount of waste from London that is disposed of in the Plan area as set out in the London Plan 2015.

SO5. To make provision for suitable site allocations to meet the predicted need for new waste management facilities, and ensure flexibility through the inclusion of Areas of Search and criteria-led locational policies.

SO6. To support the reduction of greenhouse gas emissions, primarily by moving waste up the hierarchy to minimise the need for landfill, and by minimising waste transport by locating new waste facilities in proximity to key growth centres.

SO7. To maximise opportunities for sustainable economic growth through the co-location of waste facilities within non-waste development and by encouraging the use of waste as a resource, including assessing its potential as a source of heat and energy.

SO8. To ensure waste facilities, and their proposed locations, are sustainably designed, constructed and well operated to reduce potential adverse effects on human health, amenity and the environment, in line with national standards and regulations.

SO1 – WIVENHOE TOWN COUNCIL is in agreement in principle, but has concerns regarding the degree of control that will be applied to partner organisations to maintain the agree status quo.

SO2 – Agreed

SO3 – Agreed with reservations

SO4 – Agreed

SO5 – Agreed, but with reservations as to how the sites are selected.

SO6 – Agreed, but with reservations regarding the use of transport and the associated pollution taking the place of greenhouse gas emissions.

SO7 – Disagree, WIVENHOE TOWN COUNCIL do not want to see potential waste sites turned into ever-larger commercial sites to the detriment of the locale.

SO8 – Agreed

OVERALL SPATIAL STRATEGY

The waste planning authorities are planning on the basis of net self-sufficiency, where practicable, in their waste management by 2032. New waste development should be principally directed towards the key urban centres of Basildon, Chelmsford, Colchester, Harlow and Southend-on-Sea. This approach reflects the location of the main population centres and where growth and employment is concentrated in the Plan area. This ensures that the majority of waste arising is managed and treated close to its source. There is a recognised need to ensure that other settlements are also adequately served whilst being sympathetic to the infrastructure and amenity constraints in such localities. The Waste Planning Authorities will continue to rely on a network of strategic waste management facilities to manage Local Authority Collected Waste arising in the Plan area. Primarily this is based on the strategic Integrated Waste Management Facility at Tovi EcoPark (formerly known as Courtauld Road) in Basildon, but also includes a supporting network of six Local Authority Collected Waste transfer stations located across the Plan area. All the proposed preferred sites within this Plan have been allocated and safeguarded as they are required to meet the forecasted increase in the capacity gap within each waste stream up to 2032. Key strategic sites which fulfil a recognised and ongoing need in the Plan area will continue to be safeguarded following development of the facility. If additional sites are needed beyond the preferred site allocations, and in order to offer a degree of flexibility within the Plan, Areas of Search have been designated around suitable industrial estates where waste management facilities could be supported in principle. These Areas of Search are further supported by locational criteria by which the broad suitability of a land type to accommodate a waste facility is set out. Opportunities to co-locate facilities on existing waste management sites will be supported where appropriate. Opportunities to support sustainable waste practises, including the use of waste a resource will be supported through close working with Local Planning Authorities in the Plan area.

WIVENHOE TOWN COUNCIL disagree with the configuration shown above – we are extremely concerned that there is a high degree of waste management concentrated in the North East corner of the county around Wivenhoe and Brightlingsea.

NEED FOR WASTE MANAGEMENT FACILITIES

In order to meet the future needs of the Plan area, the WPAs will support proposals on allocated sites (subject to them meeting other policies within the RWLP) to meet the shortfall capacity of:

• Up to 309,000 tonnes per annum of biological treatment for non-hazardous organic waste; Up to 1.27 million tonnes per annum for the recovery of inert waste;
• Up to 256,000 cubic metres per annum for the disposal of inert waste to landfill, (if the 1.27 million tonnes per annum of inert waste recovery cannot be identified through allocations);
• Up to 50,000 tonnes per annum for the disposal of stable non-reactive hazardous waste.

Proposals on unallocated sites to deliver capacity over and above this shortfall will be permitted where it can be demonstrated that there is a need, consistent with the principle of net self-sufficiency where practicable, and the site accords with all remaining policies within the Plan when it is adopted.

WIVENHOE TOWN COUNCIL are not in a position to comment as we do not have access to the figures used to derive, and we do not have the resources to analyse what information that is available to us.
We are further concerned that “proposals on unallocated sites to deliver capacity over and above this shortfall will be permitted” will simply be used a mechanism to permit expansion, controlled or otherwise, beyond the original proposals.

SAFEGUARDING AND WASTE CONSULTATION ZONES

To safeguard the following sites:

A. Strategic Sites Essential for the Delivery of the RWLP

Strategic sites (as defined in Table 3 'Proposed Strategic Waste Facilities') will be safeguarded for their particular waste management use, in accordance with the life of the planning permission of the associated facility. Following the expiration of planning permission, if the site is considered particularly desirable for waste management, the site will remain safeguarded for another future waste use upon cessation of its current use. The Annual Monitoring Report will be used to monitor the situation and could trigger a Plan review.

These provisions include those sites with planning permission but which are not currently developed or operational, unless circumstance dictates otherwise. Such circumstance could be a desire to re-locate a facility for which an alternative site has been found.

B. Non-Strategic Site Allocations Made in the RWLP

All site allocations within this RWLP are to be safeguarded until the proposed facility is operational unless the potential operator and annual monitoring confirm such sites are no longer required. Safeguarding provisions will also be removed once the proposed facility is confirmed to the Waste Planning Authorities as operational unless the facility meets the threshold for that facility type as set out in Table 3.

C. Waste Transfer Stations Essential for Delivery of the Joint Municipal Waste Management Strategy

The network of Local Authority Collected Waste facilities comprising the Integrated Waste Management Facility at Tovi EcoPark, Basildon and supporting transfer stations are to be safeguarded for the life of the planning permission or unless it can be demonstrated that they are no longer required for the delivery of the Joint Municipal Waste Management Strategy. As part of the annual monitoring process, the safeguarding of these sites will be re-assessed to determine if they are still necessary in terms of meeting the strategy or whether a more suitable site has become available.

D. Waste Consultation Zones

Where planning applications for uses other than waste management activities (excluding those defined Appendix DD) are proposed within a 250m consultation zone of the safeguarded sites, the relevant Local Planning Authority will be required to consult the Waste Planning Authority on the planning application. The application will need to demonstrate that the proposal would not prevent or unreasonably restrict the use of the safeguarded site for waste management purposes. In consultation with the relevant Local Planning Authority, this distance of 250m may be expanded or reduced depending on the specific nature of the site.

E. Monitoring

An indicator will be added to the monitoring framework to ensure that any changes to safeguarding provisions made due to the expiration of planning permission, the delivery of a non-strategic facility or the closure of a strategic facility are reported annually.

WIVENHOE TOWN COUNCIL recognises and acknowledges the need to identify the facilities for waste disposal, and to safeguard sites, however, in a smaller community such as ours, the site and the exclusion zone will absorb a considerable amount of land that constitutes local amenities. This should not be considered a proposal to reduce safety zones, they are essential, but rather, it serves to illustrate the considerable impact such a site will have on us and our environs.

Early, honest and open communication with local communities is an absolutely essential requirement where any development is proposed.

STRATEGIC SITE ALLOCATIONS: LOCAL AUTHORITY COLLECTED WASTE (LACW)

To allocate the sites considered essential for ongoing operations associated with the management of LACW. This would ensure their continued contribution, and if needed re-configuration or intensification, throughout the Plan period, subject to compliance with other policies in the Plan.

The preferred sites to be allocated are set out in the Site Assessment & Allocations Report, which supports this Revised Preferred Approach Document and describes the site assessment process.

Not Applicable to WIVENHOE TOWN COUNCIL

STRATEGIC SITE ALLOCATIONS: BIOLOGICAL TREATMENT

To allocate sites considered suitable for the development of built waste management facilities for the biological treatment of waste to meet the identified shortfall in biological treatment capacity.

The preferred sites to be allocated are set out in the Site Assessment & Methodology Report, which supports this Revised Preferred Approach Document.

In addition, proposals for new biological treatment facilities which come forward on non-allocated sites would have to demonstrate their compliance with the relevant locational criteria. It will also have to be shown why they are more suitable than the allocated sites (with reference to the same site assessment criteria and method used for selecting the allocated sites, as set out in the Site Assessment & Methodology Report).

We recognise and acknowledge the need to allocate sites for biological treatment to address the current shortfall, however, the proposed site in the gravel pit in Wivenhoe has a considerable number of issues associated with it including:

• Proximity to;
• Schools
• Leisure facilities including cricket club, fishing lake, walking areas, residential areas
• The latter concern is especially sensitive as the Wivenhoe Neighbourhood Plan identifies the area as one that is suitable for the suggested expansion of the town. A 250m exclusion zone will render a large part of that area unusable, and in any case, it is un-likely that residents will want to live in close proximity to such a plant
• A large increase in vehicular traffic and all the issues that that brings with it
• Risk of any runoff being conducted into the town via the “Town Drain” or various other water courses some of which are underground and only manifest themselves as springs, and subsequent run-off into the Colne and on to affect Oyster beds and various wild life areas
• Noise and Light pollution from what amounts to a small industrial plant
• And with it, disruption to the local ecosystem
• The risks inherent in the handling of the biological waste before it is processed including smells and other unpleasant effects noted at other plants.
• The risks inherent in the handling the output from the plant which we understand to be methane, compost and CO2. It is far from clear exactly what will be produced, and what will be done with it, or what impact that is likely to have on the community

It is our (WIVENHOE TOWN COUNCIL) contention that this proposal should be withdrawn given the inherent difficulties, and its considerable negative impact on the community.

STRATEGIC SITE ALLOCATIONS: INERT WASTE RECYCLING

To allocate sites considered suitable for the recycling of inert waste which contribute to meeting the identified shortfall in inert recycling capacity, once sufficient allocations have been made to meet the forecasted need for biological treatment.