Chapter 12 - WASTE
12.1 INTRODUCTION
12.1.1 'Waste', for the purposes of this chapter is defined as those previously used materials for which the Borough and other bodies have a statutory management responsibility. This chapter is concerned with land-use, and not the Borough's own waste management strategy which is separate.
12.1.2 As a waste planning authority (WPA) Brent has responsibility for waste land-use planning. This involves determining applications for change of use to or development of waste management facilities. The Borough has a statutory requirement to include waste policies as part of its Unitary Development Plan.
12.1.3 The Borough may need to deal with applications for planning permission dealing with waste which fall outside the Borough's responsibilities for collection and disposal of 'controlled' waste. Examples could include private waste transfer and recycling facilities for construction waste and incinerators for other forms of waste (such as sewage sludge).
12.2 BACKGROUND
12.2.1 'Sustainable Waste Management' is the key objective of all current national policies on waste. This concept improves on the old idea of 'waste disposal' in that waste is never truly disposed of; even landfill requires continued management. Given the sustainability focus of the UDP, on meeting the needs of future generations in ways which are both economic and enhance the quality of life, it is clear that current waste management practices are unsustainable even in the short term, are increasingly uneconomic and are detracting from the quality of life. One key aspect of Sustainable Waste Management, therefore is to treat waste as a resource.
12.2.2 As over 70% of the Borough’s waste is non-household (e.g. industrial / commercial / construction / demolition waste), the problem is much larger than just the Borough's own waste-management responsibilities. The Borough also has to deal with private sector applications for dealing with these forms of waste. Given the poor location and design of many existing facilities and the need for new facilities to deal with waste more sustainably, the key issue is therefore that of land - how Brent can best and fairly contribute to dealing with London's waste and to ensure that enough land is available in the right places.
• The Key Problem: space available for London's waste is running out, and time is running very short. Alternatives all have land use requirements.
12.2.3 The nearly seven million people of London generate over seventeen million tonnes of waste a year, a quarter (4.4 million) of which is collected by Local Authorities, and the volume of waste is slightly rising (Source: The Mayor’s Municipal Waste Management Strategy, 2003). 76% of London’s, and 97.5% of Brent's waste goes to landfill; in Brent's case all in Bedfordshire and Buckinghamshire (93 / 94 data).
12.2.4 The London and South East Regional Planning Conference (SERPLAN) forecast in 1997 that all then available landfill capacity would be exhausted within 15 years, and this assumes optimistic levels of increase for waste reduction and recycling. This is due to a decline in the number of new waste disposal sites from minerals working, the filling up of old sites, stricter standards and higher costs for landfill, and a resistance to 'landraising' (like landfill only a banked up new area is created). Current contracts for landfill are reaching their end and the economics which made landfill the cheapest option have completely changed; landfill is taxed and the tax is anticipated to double, and alternatives receive tax credits (such as recycling credits and Non-Fossil Fuel Obligation for incinerators with energy recovery).
12.2.5 This year (2004), Brent is likely to send in the region of 110,000 tonnes of household waste to landfill, incurring a landfill tax bill of approximately £4,620,000. The above figure relates to the waste that Brent controls directly as a waste collection authority - there is further waste from Parks, Highways and Housing that is handled by contractors and which is paid for indirectly. Thus, the true costs of the landfill tax are higher. Clearly, as landfill tax, rises so other options for waste management become more attractive in cost terms. Recycling rates for Brent are published annually as Best Value Performance Indicators.
12.2.6 It is necessary that there is a radical change of direction in waste management. The previous system of a dustbin per household collected once a week is increasingly outmoded. Bins are not sufficient by themselves to cope with waste - leading to flytipping, the need for expensive street sweeping, park clearance etc.
12.3 STRATEGIC Context
12.3.1 There are three key, but simple, considerations that are relevant, however, and these are reflected in all of the strategic policy documents below; otherwise when a planning application for a waste management facility is received the considerations that apply are mostly the same as those that apply to most other industrial premises - an incinerator, for example, is just 'a factory which produces energy'.
12.3.2 Best Practicable Environmental Option (BPEO). In considering the best option for dealing with each type of waste the goal is to use the best practicable environmental option for waste management. For example landfill will not be the BPEO for most types of waste. This applies both to consideration of processes in applications for integrated pollution control (which under the principle of 'non-duplication' above are not material planning considerations) and to consideration of choice of disposal methods and to locations of management facilities.
12.3.3 It is important to use the principle in the context of each type of waste and each area. In some circumstances, for example, landfill will still be the BPEO for some types of waste. The other two principles derive directly from BPEO.
12.3.4 The Waste Management Hierarchy. The different waste management options can be ranked in a hierarchy that gives some idea of the relative sustainability of each. The hierarchy proposed below by the Mayor’s Municipal Waste Management Strategy is an elaboration of the national one, to reflect London's unique needs:
12.3.5 The Government in Waste Strategy 2000 for England and Wales (DEFRA, 2000) state that;
“The concept of the waste hierarchy suggests that the most effective environmental solution may often be to reduce the generation of waste. However, where further reduction is not practicable, products and materials can sometimes be used again, either for the same or a different purpose. Failing that, value should be recovered from waste through recycling or composting, or through energy recovery. Only if none of the above offer an appropriate solution should waste be incinerated without energy recovery, or disposed to landfill.” (paragraph 5.2).
12.3.6 The Proximity Principle. The proximity principle promotes the concept that any waste which is created, should aim to be disposed of, or otherwise managed, in close proximity to the point that it is generated. There are four main reasons for this:
(i) it encourages all those who create waste to take more responsibility by requiring them to consider carefully the effects of managing the waste they create;
(ii) it is more likely to accord with the principles of sustainable development by avoiding environmental damage which could be caused by transporting waste over long distances;
(iii) it may assist the local economy; and
(iv) overall costs should be lower.
12.3.7 Deriving from the proximity principle is that of regional self-sufficiency. This is that each regional planning area should deal with all the waste generated within its area. Government policy is that each region should plan to achieve this over a period of at least 10 years. With the shortage of landfill space in the South-East outside London the principle has recently been extended so that no untreated waste from London goes to landfill outside it afterwards. The principle needs to be applied flexibly where it conflicts with BPEO. For example a nearby facility in another region may be more proximate and sometimes transporting difficult to dispose of waste to specialist facilities in another region may be the BPEO.
12.3.8 Of relevance is the EC Waste Framework Directive (91/156/EEC, as amended). Its key directives are to ensure that waste is recovered or disposed of without endangering human health, causing a nuisance through noise, or harming places of special interest; and that an integrated and adequate network of waste management facilities is provided and it embodies the proximity principle, BPEO and the waste hierarchy. Planning decisions made after 1/5/94 must implement the aims of the directive. It ensures that landfills must be sealed against leachate (polluted water leaking); a factor which has added significantly to landfill costs.
12.3.9 The Government's Waste Strategy 2000, states the government's key aim of sustainable waste management, which is to cut down on the amount of waste we produce. It aims to substantially increase recycling and composting. Where it does not make sense to recycle waste, consideration should be given to using it as a fuel. Local authorities must make realistic assessments of likely future requirements for the number, type and siting of waste treatment facilities in their area in the light of this waste strategy. As required, the Mayor of London has produced a Municipal Waste Strategy; Rethinking Rubbish in London (September 2003). The Strategy includes proposals and policies for the recovery, treatment and disposal of London's municipal waste; “The Mayor’s Vision for Waste in London is that by 2020, municipal waste should no longer compromise London’s future as a sustainable city.” (page xiii). The following policy objectives are set out:
1. London will aim to exceed the recycling and composting targets for household waste set by the Government. These are currently, as set out in Waste Strategy 2000;
• To recycle or compost at least 25 per cent of household waste by 2005;
• To recycle or compost at least 30 per cent of household waste by 2010; and
• To recycle or compost at least 33 per cent of household waste by 2015. (Policy 1).
2. London will aim to meet the recovery targets for municipal waste set by the Government, by prioritising reduction, recycling and composting. The Mayor will insist that waste authorities consider options to maximise the reduction, reuse, recycling and composting of municipal waste from all sources before considering the recovery of materials and energy from the residual waste. The targets are currently, as set out in Waste Strategy 2000 ;
• To recover value from 40 per cent of municipal waste by 2005;
• To recover value from 45 per cent of municipal waste by 2010; and
• To recover value from 67 per cent of municipal waste by 2015. (Policy 2).
3. The Mayor aspires to higher targets for recycling and composting and considers they can be achieved in the longer term. (Policy 3).
12.3.10 The DETR consultation document Limiting Landfill (October 1999) lists options for meeting the targets of the EC landfill directive for reducing the amount of bio-degradable waste going to landfill.
12.3.11 Regional Planning Guidance for the South East (RPG9), March 2001, states that a critical issue for waste planning policies for the region is to ensure that there is adequate provision for the re-use, recovery and disposal of waste, taking account of the potential for waste minimisation. It states that "It is unlikely that London will achieve self-sufficiency in the short term and disposal to landfill sites outside the capital will therefore continue to play an important role. However, the Mayor’s strategies will be required to take account of Government policy and EU legislation and to make provision for the necessary waste management and disposal facilities to meet London’s future needs for municipal and other waste streams so that there is a progressive reduction in the amount of untreated wastes exported to ROSE (Rest Of South East) for disposal as alternative waste management facilities are established in London." (paragraph. 10.15).
12.3.12 Strategic Guidance for London Planning Authorities (RPG3), May 1996, sets out government policy for London, to which Boroughs must have regard in preparing their development plans. It recommends that planning authorities "...should already be investigating and planning alternative methods of waste management." (paragraph 9.10). The guidance lays particular stress on encouraging household recycling, as it is minimal in parts of London. It states that Boroughs will need to consider the siting and design of collection points for household wastes, the need for recycling and incineration / energy recovery plant (including combined heat and power) in their areas, and for waste transfer / bulk reducing stations.
12.3.13 It states "Disposal methods should reflect an acceptable balance locally and for London as a whole, paying regard to economics, land use and the environment, the effects on potential for development in the area and the use of different modes of transport for the movement of wastes and residues." (paragraph 9.11) and urges Boroughs to co-operate and work collectively.
12.3.14 It states that, where appropriate, UDPs should identify areas of search and / or specific sites for developments for the above forms of waste and to demonstrate that mutually acceptable and workable arrangements for waste transfer and disposal exist between originating and receiving authorities (paragraph 9.13). Whether or not sites have been identified Boroughs should set out criteria-based policies against which proposals for waste management facilities can be considered (paragraph 9.14). It sets down a presumption in favour of the movement of significant amounts of waste by rail or water (paragraph 9.15).
12.3.15 On local facilities, it states "...Boroughs should not attempt to prohibit developments from their areas but should work with local communities to ensure that amenity is safeguarded." (paragraph 9.16). UDPs should have locational policies for licensed civic amenity and collection / recycling points which minimise both nuisance and travel to them.
12.3.16 PPG10 Planning and Waste Management (1999). The objectives of the planning system are set out as:
• To provide a framework which enables adequate provision to be made for waste management facilities to meet the needs of society for the re-use, recovery and disposal of waste, taking account of the potential for waste minimisation and the particular needs of special waste;
• To help meet the needs of business and encourage competitiveness;
• To encourage sensitive waste management practices in order to preserve or enhance the overall quality of the environment and to minimise risks to human health;
• To have regard to the need to protect areas of designated landscape and nature conservation value from inappropriate development;
• To minimise adverse environmental impact arising from the handling, processing, transport and disposal of waste;
• To consider what new facilities may be needed, in the light of wastes forecast to arise; and
• To ensure that the opportunities for incorporating re-use / recycling in new developments are properly considered. (paragraph. 5).
12.3.17 It states that the planning system should not unnecessarily inhibit market trends in waste management, and that other land-use policies and objectives should not prevent an adequate network of facilities being established whilst carefully considering the siting of waste facilities in relation to existing and, where possible, potential surrounding land-uses (paragraph. 29).
12.3.18 Appraisal of policy options is central to PPG10 It states:
"...WPAs (Waste Planning Authorities) should appraise the policy options in terms of the social, environmental and economic effects in order to demonstrate:
a) all practicable options have been assessed; and
b) the selected policies represent the best balance of social, environmental and economic costs and benefits, after full consideration of the BPEO and the principles of sustainable development." (paragraph. 28).
12.3.19 It states "Plans should identify existing waste management sites with capacity for the future and, where practicable, new or extended sites sufficient to make adequate future provision of waste management facilities.” (Paragraph.33).
12.3.20 The Mayor’s Draft London Plan (DLP), (June 2002), contains policies providing the stear for waste planning across London. Policy 4A.1 Waste Strategy and targets makes a partnership approach commitment to minimise the level of waste generated, increase reuse and recycling and composting of waste and reduce landfill disposal. The Policy requires that Boroughs ensure that land resources are available to implement the Mayor's municipal waste management strategy, Waste Strategy 2000, the Landfill directive and other EU directives on waste. This Policy also makes a presumption against any increase in mass burn incineration capacity.
12.3.21 DLP Policy 4A.2 Spatial policies for waste management sets out what Boroughs ought to address, in reviewing UDPs, in order to support the Mayor’s Municipal Waste Management Strategy, the proximity principle and the need to plan for all waste streams. The policy also states that the Mayor will also produce Supplementary Planning Guidance on planning for waste to promote the co-ordination of Boroughs’ waste policies. He also intends to press for powers to prepare a London-wide Waste Local Plan. The Mayor is committed to working with the South East England and East England regional authorities to co-ordinate the strategic waste management across the three regions.
12.4 POLICY OBJECTIVES
1. To pursue a "recycling-intensive" option as opposed to an "incineration-intensive" one. This should not completely rule out the role of incineration with energy recovery as a fall back option if recycling and reduction targets unavoidably cannot be met.
2. To reduce the amount of waste arising in Brent by 20% from 1995 levels by 2015, and to increase the proportion of waste recycled to 40% by 2005.
3. To ensure that sufficient land is allocated for a variety of waste management facilities and options;
4. To minimise transport associated with waste;
5. To ensure that the best practical environmental option is used in managing waste; and
6. To minimise the environmental impact of waste management processes.
12.5 BOROUGH STRATEGY
12.5.1 Brent's strategy follows this national and regional framework seeking to implement a "recycling-intensive" option as opposed to an "incineration-intensive" one. This should not completely rule out the role of incineration with energy recovery as a fall back option if recycling and reduction targets unavoidably cannot be met. This will require a spatial framework for the location of different types of waste industries, hence 'Waste Management / Manufacturing' Areas are proposed.
POLICIES AND PROPOSALS
12.6 KEY PRINCIPLES OF SUSTAINABLE WASTE MANAGEMENT
12.6.1 In considering every application for waste management uses, the aim is to use the best practical environmental option (BPEO) in choosing the best method of waste management. For example, landfill will not be the best practical environmental option for most types of waste. This applies both to consideration of processes in applications for integrated pollution control (which under the legal principle of 'non-duplication' are not material planning considerations) and to consideration of choice of waste management methods and consequently to locations of waste management facilities (which are).
12.6.2 The different waste management options can be ranked in a hierarchy that gives some idea of the relative sustainability of each. The waste hierarchy proposed by the Mayor’s Municipal Waste Management Strategy, which is based upon the national one, is considered appropriate for Brent as discussed at paragraph 12.3.4.
12.6.3 Whilst the waste management hierarchy represents the overall priorities for waste, it will not remain true for all types where it conflicts with BPEO. For example, incineration may well be the only option for some forms of waste (such as clinical and sewage sludge, which cannot be dumped at sea from 1998), whilst disposal is still the only practical option for some forms of hazardous waste. The hierarchy provides a checklist: can the waste be reduced? can it be re-used? can it be recycled?; and helps us find the best place in the hierarchy for each type of waste.
W1 THE WASTE MANAGEMENT HIERARCHY
A planning application for a waste management facility will be assessed against whether it utilises the best practical environmental option (BPEO). An application which conflicts with this will not be permitted.
In assessing applications, regard will be had to whether it contributes towards the overall management of waste in the following order of declining priority:
(1) Waste minimisation;
(2) Re-use;
(3) Recycling and / or composting;
(4) Energy recovery;
(5) Disposal (including non-energy recovery treatment and landfill).
12.6.4 The proximity principle promotes the concept that any waste which is created, should aim to be disposed of, or otherwise managed, in close proximity to the point that it is generated. The policy will be applied flexibly where it conflicts with BPEO. To satisfy the principle of regional self-sufficiency (see paragraph. 12.6.2) may require provision for the management of a proportion of waste from outside the borough.
W2 THE PROXIMITY PRINCIPLE
Waste management facilities, should be of a scale and catchment area to minimise the environmental impact of the transport of waste through dealing with it as close as possible to its source.
Development should not prejudice the ability to group together complementary waste management facilities on suitable sites.
12.6.5 This policy covers all waste-management / manufacturing
facilities, including: materials reclamation facilities, recycling, waste transfer and bulk reduction, construction / demolition waste recycling and storage, composting, anaerobic digestion and
incineration. In addition to planning requirements, many waste activities will also require a waste management license from the Environment Agency which would establish further environmental criteria.
12.6.6 Problems of odour can often be lessened through 'negative pressure' buildings and air-filtration systems. Good design, even good functional design, can and has been applied to 'shed' developments. There is no reason why enclosed waste facilities cannot be important pieces of architecture in their own right - in a similar way to Victorian water facilities.
12.6.7 The acceptable distance of a proposal from the London Distributor Road network (under criterion b) will depend upon the scale of the plant and the uses along the link. Overall the Council wishes to see as short a link as possible.
W3 NEW WASTE MANAGEMENT / MANUFACTURING PROPOSALS -
ENVIRONMENTAL AND ACCESS CRITERIA
The following criteria will be used to assess proposals for a waste-management / manufacturing facility:
(a) Ground conditions should be suitable for the facility;
(b) The development should have acceptable means of access. Where a proposal would generate significant HGV movements then it should have a short, safe and direct link onto the London Distributor Road Network and be within close proximity to the Strategic Road Network. Where proposals deal with large volumes of waste (>20,000 tonnes) there will be a presumption in favour of rail or water transhipment minimising road use;
(c) The proposal should be designed and operated to minimise its environmental impact. It should not give rise to significant visual, odour, dust and pollution, noise, water quality and overall impact - having regard to regeneration proposals in the area and adjoining land-uses (see policies EP1, EP3, EP4, EP9 & EP10), unless these can and will be satisfactorily mitigated; and
(d) For proposals requiring environmental assessment, there should be a need for the development.
12.7 DEVELOPMENT AFFECTING WASTE MANAGEMENT FACILITIES
12.7.1 The purpose of designating waste management / manufacturing areas is to ensure that sufficient land is allocated in Brent for a variety of waste management facilities and options. Currently a number of waste management facilities are poorly located and sites do not have sufficient spare capacity to be able to adapt to meet the demands of the Mayor’s Municipal Waste Management Strategy. This will require a 'clustering' of complementary waste management and manufacturing uses, e.g. secondary-materials recycling industries benefit from being located next to depots / materials reclamation facilities, transfer stations etc.
12.7.2 Flexibility will be the key to planning for these sites. Preferred options may change through time. Some options may require space for large scale sustainable waste management facilities - and as such they may not be suitable in the first instance for multiple small facilities. There would be a strong incentive to ensure that buildings in such areas are, where possible, flexibly designed. Sites need to be safeguarded until the choices between certain options becomes clearer. Potential space for small scale incineration may also need to be provided in case reduction / recycling targets are unavoidably not met. The need for weighbridges is another requirement.
12.7.3 Despite Brent having one of the highest levels of industrial land in North West London suitable sites are difficult to come by. This is because such sites have strict locational requirements in terms of their need for large sites and good road and rail access. Such sites can potentially generate up to ten times more HGV traffic than an industrial development of the same size. Such locational requirements are also relevant to the designation of employment areas; - but are even stricter for waste uses - very close road access to the strategic road network, and preferably to rail, is desirable to minimise the environmental impact of traffic. Regeneration of older employment areas means that they are less and less seen as 'industrial estates' in the old sense of places where 'bad-neighbour' use can be located - rather they are seen as clean and modern places for business investment. However treating waste as a resource means that manufacturing industries based on the recycling of secondary materials could lead to considerable growth in manufacturing in London. Waste minimisation clubs such as the PREMIER scheme in Park Royal have also proven that industry dealing with its own waste is good business. The key is to ensure that 'waste management and manufacturing' areas are situated in the right locations within employment areas and are designed and managed with sufficient environmental controls that the problems with existing sites are avoided.
12.7.4 Areas have been chosen which meet the objectives of policies W3 (New Waste Management / Manufacturing Proposals - Environmental and Access Criteria) & W2 (the Proximity Principle). No site is ideal given the severe land pressures that the Borough is facing. Household and non-household waste have quite different locational requirements in terms of the application of the 'proximity principle' and the economics of collection.
12.7.5 The Park Royal Partnership has commissioned a waste study for Park Royal. This looked at current and future waste management and planning issues in Park Royal with the aim of stimulating regeneration by developing links to modern recycling based manufacturing activities. This found that there were clear market opportunities in Park Royal.
W4 WASTE MANAGEMENT / MANUFACTURING AREAS
The following sites are safeguarded as Waste Management / Manufacturing Areas, unless the non-viability, in the medium term, for this, is conclusively demonstrated. Such development will be directed to these areas, unless policy W5 permits
facilities outside them:
1. Charringtons Yard / Neasden Goods Yard (subject to Policy WEM31); and
2. Alperton (part of the former depot and adjoining land).
12.7.6 As well as a need to identify land for new waste management / manufacturing facilities there is also a need to safeguard existing facilities. So as to ensure that sufficient sites are available.
12.7.7 The following policy sets down criteria for consideration of proposals outside waste management and manufacturing areas. Generally these will be small-scale local facilities.
W5 SAFEGUARDING OF WASTE FACILITIES
(A) Lawful waste management facilities within waste management / manufacturing areas will be safeguarded for waste management / manufacturing use - especially where sites have existing or potential rail access - unless an alternative acceptable site is secured (policies W2 and W3) and changes in waste management mean that the site is no longer required for acceptable waste management purposes.
(B) Lawful waste management facilities outside waste management / manufacturing areas will be safeguarded only where they comply, or where they can be upgraded to comply, with policy W3 (New Waste Management / Manufacturing Proposals - Environmental and Access Criteria).
W6 PROPOSALS FOR WASTE MANAGEMENT FACILITIES OUTSIDE WASTE MANAGEMENT / MANUFACTURING AREAS
(I) A planning application for a small (less than 0.3Ha) household waste collection, recycling and composting facility, or for a local area commercial, construction, demolition waste facility (see policy W7) or timber station, or an extension to such a facility, will be permitted on employment sites outside Waste Management and Manufacturing Areas, and subject to policy W3.
(II) Outside waste management and manufacturing areas, waste management / manufacturing facilities, other than those described in (I) above, or the extension, intensification or continuation of an existing such facility, will only be permitted where:
(a) the proposal complies with the waste management hierarchy (policy W1) and policy W3 (environmental and access considerations);
(b) a suitable site within a waste management / manufacturing area, or in Park Royal in the wider Park Royal area in adjoining Boroughs, is not available, and the proposal does not create an excessive concentration of waste management facilities in any one locality;
(c) a local shortage of such facilities exists (policy W2) and potential alternative sites are less suitable when judged against policy W3 (environmental and access criteria); and
(d) the site lies within a Strategic or Borough Employment Area (policy EMP8).
12.8 REDUCTION, RE-USE & RECYCLING
12.8.1 The pursuit of a 'recycling-intensive' option does not automatically save energy and resources - this will depend on the type and distribution of facilities. Large amounts of energy can be expended during the recycling process, for example, where special car journeys have to be made to recycling sites, or where re-processing is energy intensive or where materials have to be transported long distances. The long term aim must be for provision to be made for doorstep collection of separated waste, which would cut out unnecessary journeys and increase the proportion of waste recycled. Brent has set itself a target of increasing the percentage of households served by the kerbside recyclable materials collection scheme to 76% of all suitable properties by 2003 / 2004 and to decrease the number of green box complaints to 18000 by 2003 / 2004.
12.8.2 The Council's own recycling activity has previously been focused at the Council's Civic Amenity site (at First Way, Wembley), which has banks for: cardboard, scrap metal, textiles, books, shoes, foil, paper, glass, mixed cans and a waste engine oil reclamation tank, and through Bring-Bank collection schemes. There are a number of "Bring Bank" schemes operating throughout the Borough covering a range of materials.
12.8.3 Where 'Bring' recycling facilities are used, the government's target was for these to be 'easily accessible' to 80% of households by the year 2000 (within 1/2 mile, or 2 miles where the recycling facility is located with other frequently used facilities, e.g. supermarkets). 100% of Brent’s households are within 1 mile of a recycling site.
W7 LOCAL RECYCLING POINTS AND FACILITIES
Recycling points should be located in convenient and prominent, but not in obtrusive locations, or locations which would be harmful to residential amenity. They should be located at places attracting significant numbers of the public - such as supermarket forecourts and public car parks - and deal with the types of waste originating at the site / in the area.
Large retail proposals should also facilitate and / or incorporate proposals for the overall reduction and recycling of waste.
12.9 CONSTRUCTION / DEMOLITION / COMMERCIAL WASTE
12.9.1. The policy below covers all such facilities including scrap metal yards / car breakers etc.
12.9.2 Brent has, on the whole, a comparable number of waste transfer facilities to many other London Boroughs. This number is understandable considering waste facilities often deal with industrial commercial waste and / or require an industrial location and that Brent is strategically important in terms of its supply of industrial land and premises. However Brent does have some of the largest such facilities and one of the highest concentrations of construction / demolition / commercial facilities in London. These facilities are operating in inappropriate locations (conflicting with regeneration proposals such as for the Wembley area) and their lawful use status means that modern environmental controls cannot be applied. In terms of other waste recycling facilities Brent is definitely underprovided. It is also particularly difficult to apply the 'proximity principle' to such developments as they may take contracts or waste from wide areas and a wide variety of sources.
12.9.3 With the increasing cost of aggregates (due to the decline in number of workings) and the cost of the landfill tax, the construction waste industry in particular can only increase. Construction / demolition waste recycled as aggregates reduces the need for minerals extraction with its associated environmental costs. The Government target in Minerals Planning Guidance Note 6 (MPG6, Guidelines for aggregates provision in England, 1994) is for 13% of all aggregates to come from recycling by 2006. On-site crushing and recycling may be possible, particularly on larger sites. Although MPG6 states that such sites should be 4-6 Ha min (to gain the highest grade product from separation and to maximise its aggregate displacement potential), pressure in Brent will be for much smaller sites.
12.9.4 Future strategy must be based on moving towards smaller covered facilities serving local catchment areas; information submitted with planning applications will be essential in assessing whether this is proposed. There are not the very large scale sites in Brent available to meet the requirements of MPG6. For operations that involve the stockpiling of material, the Institute of Demolition Engineers recommends a minimum site size of 1 ha. The DETR report ‘Controlling the Environmental Effects of Recycled and Secondary Aggregates Production: Good Practice Guidance’ finds that the minimum size of site will also depend on the range of activities proposed, and only 'stand-alone' or 'interim' facilities need to be as large as set out in MPG6. Brent has a proliferation of smaller open sites causing significant nuisance and harm to amenity. These sites cannot be practically, or desirably, extended to the size required by MPG6, and they enjoy lawful use rights. The issue then is how to improve them. The Environment Agency has been refusing applications to alter or extend licenses for such facilities in Brent unless they are covered over. A developer should include a supporting feasibility study and proposed license restrictions with their applications in support of an application. More importantly, however, there will be a need, especially for major developments, to re-use / recycle waste on site as construction material or aggregates - but not to simply raise the level of the site which is the equivalent of an unauthorised landfill site. Such a move could contribute in a major way to the reduction in lorry traffic in London.
12.9.5 The Borough also has a particular concentration of waste hauliers operating from within residential areas. These all will require licensing and often will require planning permission - the Courts have determined that whether or not the vehicle is parked on the street is not material, what matters is whether the property is used as a 'base'. Brent will work with the Environment Agency on more effective enforcement of firms causing a nuisance.
W8 CONSTRUCTION / DEMOLITION / COMMERCIAL WASTE
(A) All commercial and industrial facilities should have adequate on-site facilities for the storage, recycling and handling of waste arisings.
(B) Planning applications for storage / recycling / transfer facilities dealing with construction / demolition / commercial waste should assist a move away from large open sites, and 'skip-based' sites with large catchment areas, towards smaller, covered, facilities where waste generated within the locality is processed and re-used within the locality.
Sites should preferably be in a Strategic Employment Area (policy EMP5). Waste haulage uses will not be permitted in residential areas.
The granting of permission will be subject to the applicant entering into a planning obligation to I) ensure that vehicles are covered, control mud, use appropriate routes and II) to limit the catchment area, where appropriate. Conditions will be used to restrict the height and amount of any open storage.
(C) Construction / demolition waste facilities, aggregate handling facilities and concrete transfer stations should have acceptable road access and preferably rail or water access, and have an acceptable noise and dust impact, be integrated with recycling facilities and be compatible with surrounding land uses.
12.10 CONSTRUCTION / MOVEMENT OF SPOIL
12.10.1 The number and scale of development sites in the Wembley area and of the major estates in particular, means that demolition / construction could have a negative impact on local residents unless carefully controlled.
W9 CONSTRUCTION / MOVEMENT OF SPOIL
For large redevelopment sites (>1Ha), details of methods for minimising / processing construction waste, and construction method statements to minimise nuisance to residents, will be required as part of the application, with a presumption in favour of rail or water movement where re-use is not possible. Recycling should be to as high a grade of recycled product as possible to minimise primary aggregate use.
12.11 INCINERATION
12.11.1 The Borough's planning policies for waste are based upon the adoption of a 'recycling-intensive' approach. However even here incineration has a residual role. The economies of scale in relation to incinerators mean that a large facility serving several Boroughs may be promoted. However there is a tension between this and the minimisation of road transport (the 'proximity principle'). Such facilities would cover less than 2Ha of land and could fulfil a longer term role in a recycling-based strategy if recycling / reduction targets are unavoidably not met. Smaller scale facilities also make distribution of heat easier and it might be possible to expand capacity gradually. The policy below sets down the additional criteria to be met as well as policies W1-W3, and W4 / W5.
12.11.2 Overall, in a recycling-based strategy, incineration capacity should only be promoted for waste not economically and / or sustainably capable of being recycled or for residual waste. The recent government document 'Less Waste More Value' states that ‘energy recovery should not be undertaken without first consideration being given to the possibilities of composting and material recycling' (paragraph 3.3.5).
12.11.3 Waste to energy incinerators should not consume the bulk of waste from their catchment areas but allow recycling to grow. This is why applicants will need to demonstrate how proposals will contribute towards a recycling-based strategy. For example recycling facilities can be incorporated on-site in order to separate out recyclable waste. There is currently a debate about whether incineration is the BPEO for separated paper waste. It is important to understand however that this is compatible with a 'recycling intensive' option as this requires separation and small scale incineration for residual waste anyway. Prioritising recycling is reflected in the government document 'Less Waste More Value' which states: "Local authorities considering energy from waste will...want to guard against over-reliance on this option...In particular, they will need to ensure that the use of energy from waste plants does not direct waste from recycling and composting" (page 72).
12.11.4 Policy EP4 sets down in detail those circumstances when pollution can be a material consideration. Any incinerator proposal would be one of the few waste management facilities in the Borough likely to require Integrated Pollution Control consent from the Environment Agency. It is best practice for such applications to be submitted at the same time as planning permission is applied for and a copy sent to the local planning authority. Without such information, Brent may use its powers under the applications regulations to consider the proposal invalid. Incinerator proposals will almost certainly require an Environmental Assessment to be submitted with the application (see policy EP1).
12.11.5 The advent of air-quality management will have a particular bearing on the assessment of pollution impacts (policy EP3). Although new models of incinerator seem to have largely solved the problems that dogged previous types (e.g. dioxins), concern remains about possible cumulative and other impacts of Nox (nitrogen oxide) and PM10s (particulates).
W10 INCINERATORS
Waste incinerator proposals will be assessed against the following criteria:
(a) The proposed scale, location, phasing and waste category to be incinerated should not hinder London and Brent's proposals to radically increase waste reduction, re-use and recycling;
(b) Any potential pollution from the development should comply with policy EP4, and policy EP3 on air-quality management; particular attention should be paid to particulate dust pollution and odour;
(c) The application should be accompanied by full environmental information (including where required a formal environmental assessment) looking at its individual and cumulative impacts together with other existing and proposed facilities (policy EP1);
(d) The catchment area of the plant should be limited so as to comply with the proximity principle (policy W2) and have an acceptable transport impact (policy TRN1);
(e) The proposal should be integrated with on site or adjoining recycling and material reclamation facilities;
(f) The proposal should incorporate energy recovery - preferably incorporating district heating proposals; and
(g) Given their size and visual prominence particular attention should be paid to the quality of design and its skyline impact (policy BE10).
12.12 WASTE DISPOSAL
12.12.1 Waste transfer stations serve a crucial intermediate role between collection vehicles and large scale waste management facilities. The distance between the two is often too great for an economic run by a collection vehicle. Sometimes commercial and construction waste is transferred to a hardstanding before final transfer to a bulk carrier. Bulk reduction (usually of household waste) reduces the environmental impact of transport to final waste management, and storage on site is rarely more than 24-36 hours. With proposals for London taking a more proactive role in the management of its own waste the need for a number of existing major bulk transfer stations may be reduced although some of these sites may be suitable for other waste management uses.
W11 WASTE TRANSFER FACILITIES / WASTE TO LANDFILL
A waste transfer station / bulk reduction facility handling putrescible waste, will not be permitted unless the operations are fully enclosed within a building, and where odour can be controlled, and subject to policy W3 (environmental and access criteria).
Planning applications will be refused which would prejudice a shift over the plan period towards the final transport of household waste residuals to landfill by rail or water modes - with transport by road being a fallback option in emergencies only.
12.13 AGGREGATES
12.13.1 Strategic Guidance (RPG3) requires UDPs to address minerals issues and to provide for depots, with a presumption in favour of movement by rail or water, and the recycling of waste materials. The 'proximity principle' also applies to trans-shipment locations. It identifies the need for a transfer facility in North or West London to accept aggregates from the East Midlands. Brent would need to be satisfied that any site put forward was the best within this broad area and that suitable alternative sites had been fully compared within the environmental assessment (see policy W2).
12.13.2 New aggregates recycling / transfer facilities will be judged against policy W8. Particular attention should be paid to dust suppression - water supplies should be adequate for dust suppression or temporary pipework should be provided. By virtue of their large water consumption greywater recycling facilities should be provided (policy EP11).
W12 AGGREGATE EXTRACTION
An application for minerals extraction will be judged against their environmental & traffic impact (policy W3) and the potential for contributing towards the London minerals landbank. Secondary aggregates usage will need to be fully explored before primary aggregates extraction is considered.
