12. Scale and distribution for land disposal facilities
Issue W6 - The need for an appropriate distribution of land disposal facilities for residual waste: options for strategic locations for land disposal facilities.
Summary of the issue
12.1 Landfill capacity in East Sussex and Brighton & Hove is running out. There is an immediate and continuing need for significant disposal capacity, for waste generated in East Sussex and Brighton and Hove, in the absence of new facilities to divert waste from landfill. There will also be an on-going requirement to dispose of residues from recycling and reprocessing facilities that can't be recovered.
12.2 The Core Strategy must consider where new land disposal capacity should be located, taking account of where the waste that needs to be disposed of is generated, and the specific local environmental, social and economic impacts of land disposal at particular locations.
12.3 Decisions about where new land disposal capacity should be located will be influenced by the amount of waste that is forecast to require disposal and the potential capacity of sites or areas that could be suitable, i.e. how many land disposal sites will be needed and where should they be.
12.4 As described in the Context section and under Issue W2 of this preferred strategy, there is currently no landfill capacity for non-inert (biodegradable) wastes(51). Permission exists for some landfill at Pebsham but is dependent on other authorisations which have not yet been secured. If implemented this would provide overall capacity for approximately only one year's total non-inert land disposal requirements. There are significant geological and environmental constraints to finding suitable new sites for final disposal in East Sussex and Brighton & Hove and there are very few potentially suitable old mineral quarries that could be restored by landfilling with waste.
12.5 Broadly speaking, there are two options for types of potentially suitable land disposal sites; landfill and landraise. Traditionally, disposal to land has involved the restoration of old mineral quarries by landfilling with waste. Such locations would need to have suitable geological conditions, acceptable standard of access for HGVs, and lack of other environmental constraints. There are very few such locations in East Sussex and Brighton & Hove. Opportunities for landfilling are restricted to existing mineral sites, and the location of these sites is not necessarily compatible with the main areas of waste arisings in East Sussex and Brighton & Hove, and the locations of such sites may not be compatible with modern environmental protection policy and may therefore not be suitable for land disposal, which can have different impacts to minerals extraction.
12.6 Landraising is an alternative solution that involves depositing waste above existing land levels using engineered containment methods. Because this method is not restricted to pre-existing quarries, decisions on the location of landraising sites can take greater account of proximity to the main areas of waste arisings and the local environmental suitability of potentially acceptable sites or areas.
What can the Core Strategy do about this?
12.7 The Core Strategy can identify sites, and, broad areas of search within East Sussex and Brighton & Hove that can provide suitable capacity for land disposal and guide the content of a Waste Sites document.
12.8 Broad areas of search could be restricted to existing mineral extraction sites or could include areas that are potentially suitable site locations for landraising. The selection of a preferred option will be influenced by the amount of capacity required and the suitability of existing mineral extraction sites or landraising locations.
12.9 The Core Strategy can also take account of the factors established in regional and national planning policy that determine the suitability of sites or areas for land disposal. These factors, summarised below, include environmental, social and economic constraints and the geographical relationship between a site and where the majority of waste for disposal to land is generated.
12.10 Factors affecting the identification of strategic locations of Land Disposal Sites:
- Environmental Constraints
- Impact on water resources including surface watercourses (rivers, streams etc.), groundwater and reservoirs;
- Areas at risk of flooding;
- Unstable areas of land;
- Impact on designated landscapes, particularly those of national importance (AONB, National Park, Heritage Coasts);
- Impact on areas which are important for nature conservation including Special Protection Areas, Special Areas of Conservation, RAMSAR Sites, Sites of Special Scientific Interest, National Nature Reserves;
- Impact on areas which include particular historic environments and built heritage. These include World Heritage Sites, Scheduled Ancient Monuments, Conservation Areas, Listed Buildings, Registered Historic Battlefields, Ancient Woodland and Registered Parks and Gardens.
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Presence of mineral void or existing disposal site
- The restoration of a worked mineral quarry, or the extension of existing disposal sites, can offer particular opportunities.
- Proximity to waste arisings, i.e. urban areas
- PPS10 states that planning authorities should prepare planning strategies that provide a framework in which communities take more responsibility for their own waste, and enable sufficient and timely provision of waste management facilities to meet the needs of their communities. Proximity to waste arisings, or major facilities that produce residual waste for disposal, is therefore a key locational principle.
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Proximity to transport networks
- This improves road safety, and reducesnuisance, impact on local amenity, and reduces costs of providing infrastructure, as well as operating costs.
- Proximity to Communities
- Sites in or near communities can have adverse environmental impacts, such as road congestion, nuisance and impacts on amenity from noise, litter, odour etc, if these impacts are not managed effectively.
- There can be local economic/employment benefits.
- Affordability - viability factors also need to be considered in selecting locations for land disposal facilities. These include:
- Economies of scale;
- Costs of transporting waste (affected by proximity to waste arisings and transport infrastructure);
- Site development costs - these will be affected by whether additional infrastructure is needed to access the site, as well as land costs.
What are the options?
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Issue W6 – The need for an appropriate distribution of land disposal facilities for residual waste: options for strategic locations for land disposal facilities. |
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W6a. Identify and allocate Land Disposal Sites which are located avoiding:
This option considers strategic locations for land disposal sites that are:
W6b. Identify and allocate Land Disposal Sites located at existing disposal sites, or at minerals voids. This option considers all existing land disposal sites (for inert, as well as non-inert waste) and voids created by mineral workings (i.e. quarries) and is not constrained by consideration of environmental designations or proximity to communities. W6c. Identify and allocate Land Disposal Sites located at existing disposal sites, or at minerals voids, avoiding:
This option considers all existing land disposal sites (for inert, as well as non-inert waste) and quarries that are:
Certain strategic locations for Land Disposal Sites, or sites within these locations, may be preferred due to their proximity to waste arisings. The following options are intended to reflect this: W6d. Allocation locations for Land Disposal Sites proximate to waste arisings in preference to those which are greater distances from areas of waste arisings. W6e. To account for the possible importation of residual waste for Land Disposal, allocate locations for Land Disposal Sites proximate to the borders of the Plan Area in preference to those which are greater distances from the borders. W6f: Export of waste for disposal elsewhere. This option would propose that waste is exported for disposal to land facilities outside the Plan area. |
12.11 The Site Identification study(52) sets out further details about these options and includes the accompanying maps which illustrate how the options translate spatially.
Preferred Option Selection
Preferred option - The preferred option is a combination of W6a, c and d
Reasons - Options for the spatial location / distribution of land disposal facilities and the relative merits of prioritising existing land disposal sites and mineral voids, or allowing land disposal (landraising) on greenfield sites, have been considered. Spatial relationships between such sites and areas of arisings have also been evaluated. National policy would indicate prioritisation of mineral voids, in preference to developing landraising facilities on greenfield sites. The assessment also indicates a preference for sites that are closer to areas where waste arises.
The Waste Local Plan currently allocates Ashdown Brickworks as potentially suitable for Landfill. Ashdown Brickworks offers a substantial mineral void close to one of the major urban areas of waste arisings in East Sussex and Brighton & Hove. Notwithstanding this, it is clear that the development of the Ashdown Brickworks site for landfill would involve the need to overcome a number of environmental and operational constraints. Further, the potential capacity of Ashdown Brickworks would need to be established in more detail than at present to demonstrate soundness of the Core Strategy. In timing terms, this site is also unlikely to fulfil all the necessary requirements. Therefore primary areas of search have been identified that might offer opportunities for the development of a landraise site within them (see Plan 4). This will be investigated further.
Regarding London’s waste, the report on London’s Waste (53) concludes that waste is not likely totravel from London or the surrounding areas and there is no spare land disposal capacity in East Sussex and Brighton & Hove.
Spatially, if London’s waste were to be transported to East Sussex and Brighton & Hove it would have to go to sites with good
access to the main road network. The areas close to London are generally in the AONB and therefore unlikely to offer suitable
opportunities for the development of Land Disposal facilities.
Sites further afield into East Sussex and Brighton & Hove would probably be uneconomic to cater for London's waste and waste would most likely have to traverse the AONB to reach them.
Given the constraints on capacity, the timing to bring forward sites, and their poor proximity to London, it is not considered appropriate for East Sussex and Brighton & Hove to provide for the landfill provision for waste from London as per policy W4 of the South East Plan which would negate the need to meet the specific provision identified in policy W3 of the South East Plan.
Spatial Policy
Policy CS6
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CS6 The need for an appropriate distribution of land disposal facilities for residual waste in suitable locations
Subject to further study and consultation on the Preferred Strategy, development to meet the need for capacity for the land disposal of non-hazardous non-inert waste would be permitted at either alternative suitable mineral voids or locations that could accommodate landraising facilities.
Suitable locations would need to demonstrate that they are acceptable in terms of other policy considerations and should meet all of the following criteria.
- They are within the brownfield/mineral sites or greenfield/primary areas of search identified on Plan 4.
- There is no unacceptable impact on the environment or communities.
- There is good access to the main areas of waste arisings. (Only waste generated in East Sussex and Brighton & Hove will influence the location of land disposal facilities.)
- Recovery of energy from landfill gas is maximised.
- There is a comprehensive scheme of restoration and aftercare which makes a positive contribution to the local landscape character.
- Where appropriate, temporary on-site facilities are included for the recovery of waste which can be managed further up the waste hierarchy