Essex County Council / Southend Borough Council

Transcription

1 Essex County Council / Southend Borough Council Review of deliverability constraints associated with the use of industrial estates for waste management facilities Study Report Version: Final (5.1) 17 October 2014

2 Contents Section Page No. Executive Summary 1 Glossary Introduction Purpose and Scope of Study Methodology Findings Conclusions Analysis of Approaches Recommendations Afterword.. 34 Appendices: 1 Methodology for selecting the sample of industrial estates Waste Industry Questionnaire Findings from Waste Industry Survey Industrial Property Management Industry Questionnaire Findings from Property Management Industry Survey Notes of Stakeholder Workshop Findings from the quantitative assessment examining the main determinants for economic viability/feasibility of waste management facilities.. 88 Assessments associated with the preparation of this report have involved an element of professional judgement. The conclusions presented rely upon information provided by third parties which have been used in good faith. While due care and diligence has been exercised in the research and production of this report, BPP Consulting LLP excludes to the fullest extent lawfully permitted, all liability for any loss or damage however arising from reliance on its contents.

3 With the economic recovery, the price of employment land is increasing and availability is increasingly constrained. This is especially so in parts of the study area with good access to the M25. Some waste management development can offer relatively stable returns to landowners over long periods of time but in general it is a land use which currently struggles to compete with other uses of employment land due to its low value (rate of return per hectare), initial capital investment and the perception that it is a bad neighbour activity. The use of generic development management policies and Areas of Search within the WLP to guide the development of waste management facilities on employment land will improve the deliverability of future waste management capacity, particularly where these are applied in combination with specific site allocations. The deliverability of the WLP would be greatly improved through the allocation of further strategic sites (at least 0.65 hectares in size), in addition to those allocated in the Preferred Approach, which are able to accommodate a range of waste management uses. It is likely that suitable sites would be found within shortlisted employment land. The deliverability of waste management capacity can be expected to improve as the number of allocations increases. Key Recommendations: 1. To ensure maximum deliverability of additional waste capacity on employment land, the development of the WLP should seek to: a. Continue to identify specific allocations of industrial land, no less than 0.65ha in size, with good accessibility to waste arisings, able to accommodate a range of waste management uses. b. Include Areas of Search encompassing the potential areas of employment land identified in the ELR. c. Include general policy identifying industrial land as broadly suitable for waste management uses subject to meeting development management criteria intended to ensure sustainable development. 2. The negative perception of waste management could be improved with the development of a Design Guide Supplementary Planning Document (SPD) setting out the authorities expectations with regard to a good standard of design and operations. It would assist the WLP process if this were done in parallel with the development of the WLP, or at least the WLP included a clear commitment to prepare such an SPD. 3. The importance of waste management to a high performing local economy should be emphasised in discussions with stakeholders, such as the Local Enterprise Partnership, during the preparation of the WLP. 4. District Councils to review whether sufficient employment land has been allocated in their Local Plans to supply all sector needs. They should also entertain, and certainly not rule out, the possibility of waste management Page 2 of 102

4 capacity being developed on employment land. This is particularly so in the case of high end low impact uses such as those which deal with single material streams. In designating employment land in local plans the LPAs should consult with Essex County Council at the earliest possible opportunity with a view to establishing the suitability of locations for waste management uses which may be compatible with other employment uses. Page 3 of 102

5 Glossary Contract for difference: This is a new system being introduced by the Government to replace Renewable Obligation Certificates (ROCs- see below). Under the Contract for difference' Feed In Tariff, government offer top-up payments for renewable power if the wholesale price of energy falls below a certain threshold. EfW: An Energy from Waste facility is a waste management facility that uses waste to generate energy or a fuel thereby capturing the energy value in the waste. When directly combusted the heat energy can be used for direct heating and/or to drive turbines to generate electricity. Alternatively, a combustible fuel, such as methane or syngas, can be produced. ELR: Employment Land Review. The report prepared by Essex County Council which assessed the suitability of employment land in Essex and Southend on Sea for locating waste management uses. The title of the report is Review of employment land for waste management facilities dated September Employment land: Land allocated by local planning authorities for industrial and commercial use i.e. land that gives rise to employment. Gate fees: Fees charged to accept material at a waste management facility. Generally expressed as /tonne. Green Belt: Areas of land around large metropolitan areas designated to prevent urban 'sprawl' and merging of urban areas by keeping land permanently open. The essential characteristics of Green Belts are their openness and their permanence. The Government attaches great importance to the preservation of Green Belts. HGVs: Heavy Goods Vehicles these are vehicles with a combined (vehicle and payload) weight exceeding 3.5 tonnes. Industrial Land: For the purposes of this study industrial land is taken to mean land identified as potentially suitable for the development of waste management uses within the ELR (see above). ktpa: Waste management capacity measured as thousands of tonnes per annum. Merchant facilities: Waste management facilities primarily developed to manage non-municipal waste. Such facilities are developed using private finance rather than relying on long term public sector contracts. R1 requirements: Annex II of the revised Waste Framework Directive sets out a list of waste management operations that can be classed as recovery. One of these is the use of waste principally as a fuel or other means to generate energy referenced as R1. The Annex includes an energy efficiency threshold, which incineration plants dedicated to treating local authority collected waste must achieve, or surpass, in order to qualify as a recovery operation. ROCs: Renewable Obligation Certificates. Certificates issued to operators of electricity generating stations that have been accredited as producing power from renewable sources for the eligible renewable electricity they generate. To be superseded by 'Contract for Difference' (see above). Site: Site is considered to relate to a specific plot of land, more likely within an area of employment land, rather than the entire area of employment land itself. WLP Area: This is the area covered by the Replacement Essex and Southendon-Sea Waste Local Plan i.e. Essex and Southend-on-Sea. Page 4 of 102

6 1 Introduction 1.1 Essex County Council (ECC) and Southend-on-Sea Borough Council (SBC) (hereinafter referred to as the 'authorities') are producing a Replacement Essex and Southend-on-Sea Waste Local Plan (WLP also referred to as the Plan ) as required by the Planning and Compulsory Purchase Act (2004). The WLP will replace the existing Essex and Southend WLP (adopted 2001) and covers the administrative areas of both ECC and SBC. 1.2 The WLP will set out the authorities vision, objectives, strategy and policies (and how they will be delivered and implemented) with respect to waste related issues and development over the plan period 2015 to In doing so the WLP will indicate how much additional waste management capacity is needed in the area and where this capacity should be provided, in accordance with the overarching aim of achieving sustainable development. 1.3 The existing and emerging district council Local Plans, as well as the unitary council of Southend on Sea s Local Plan include employment land allocations and it is considered that these might provide opportunities for the location and development of future waste management capacity. 1.4 In due course the WLP will be tested for soundness in accordance with the National Planning Policy Framework (NPPF). One of the tests of soundness is concerned with the effectiveness of the Plan, the measure being that the Plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities 1. Effectiveness is also captured by the NPPF requirement that Local Plans should be aspirational but realistic. It is important therefore, for the authorities to demonstrate that the ways in which the WLP proposes waste will be managed are reasonably likely to happen. It is equally important for the authorities to ensure that the policies in the WLP do not undermine the aspirations and plans of the district councils for the development of industrial locations. 1.5 This study tests the validity of the hypothesis that, in future, waste management capacity may reasonably be expected to be developed on industrial areas. Industrial areas are defined as being within those areas of employment land allocated in existing and emerging district council Local Plans, as well as the unitary council of Southend on Sea s Local Plan. The report should be read alongside the Councils Review of employment land for waste management facilities. The identification of such land for a waste management use is in accordance with current national planning policy concerning waste management 2. More information about the purpose and scope of this study is included in Section 4 below. 1 NPPF, Para "Paragraph 4 of National Planning for Waste, October 2014." Page 5 of 102

7 2 Purpose and Scope of Study 2.1 The last key stage in the preparation of the Waste Local Plan was the publication and consultation on a Preferred Approach in November The Preferred Approach identifies site-specific proposals for strategic 4 waste management facilities, drawing on the sites that came forward through a Call for Sites exercise undertaken in October-December As well as identifying specific locations for strategic facilities, the Preferred Approach (Preferred Approaches 6 to 11) considers how proposals will be considered which come forward for development on land that is not allocated or is not on an existing safeguarded site. In such cases development is guided to various types of land, reflecting those specified in paragraphs 20 and 21 of the former planning policy on waste, PPS10 5. For the purposes of this study, it is important to note that the Preferred Approaches (6 to 10 6 ) include the following types of land within the categories considered suitable: within existing industrial estates used for general industry (B2), storage and distribution (B8) or land allocated as such in an adopted local plan or LDF document ; and. within those employment areas (existing or allocated) not categorised by Use Class B2 or B8; 2.3 This is included in the general location criteria for the following types of use: Recycling and Recovery Facilities Materials Recycling/ Recovery Facilities and Waste Transfer Stations Inert Waste Recycling Facilities Metal Recycling and Vehicle Dismantling Facilities In-vessel Composting Facilities Clinical waste treatment facilities Mechanical Biological Treatment, Autoclaving and Anaerobic Digestion Facilities Energy from Waste, Pyrolysis and Gasification Facilities 3 "The Preferred Approach document, supporting evidence and earlier Issues and Options stage (December 2010) are available to view on the ECC website: Policy/Pages/RWLP-documents-and-supporting-evidence.aspx" 4 "The Preferred Approach considers what constitutes a strategic waste facility at paragraph This states that generally facilities with a throughput greater than 50,000 tpa are considered strategic. Table 8 of this document provides a more detailed analysis." 5 "Note that updated national planning policy on waste includes a similar expectation." 6 "Open Windrow Composting is covered by Preferred Approach 11 that does not include industrial and employment land as being potentially suitable." Page 6 of 102

8 2.4 The Preferred Approach justified the general identification of industrial estates as being suitable for most types of development, on the basis that national planning policy extant at that time (PPS10) stated that WPAs should consider industrial sites as possibly suitable for waste management uses. It should be noted that recently updated national planning policy for waste 7 includes a similar expectation in paragraph The district councils within Essex are also preparing their own Local Plans to guide other forms of development including that associated with employment. These plans include policies allocating land as specifically suitable for the development of employment uses. However it should be noted that Government guidance to planning authorities on the implementation of the waste hierarchy 8 recognises that such authorities also have a role in furthering sustainable waste management. In particular this includes the following: While such authorities may not have the planning functions in respect of the preparation of Local Plans covering waste, or dealing directly with waste planning applications, they must have regard to national planning policy for waste and are expected to help deliver the Waste Hierarchy. This might include: working constructively with waste planning authorities to identify and protect those sites needed for waste management facilities. Local planning authorities should consider the need for waste management alongside other spatial planning objectives Earlier Government guidance 9 on this matter suggested that: when undertaking Employment Land Reviews, it is important to consider the full range of employment opportunities, including appropriate waste management proposals, before releasing sites for non-employment uses, such as housing. 2.6 Following consultation on the Preferred Approach and to inform the next stage of WLP preparation, a report entitled Review of employment land for waste management facilities has been prepared by ECC and SBC. Drafts have been subject to discussion and review with each Essex district council in line with the Duty to Cooperate plan making requirements " " 8 "Planning Practice Guidance for waste "" 9 "Guidance for local planning authorities on implementing planning requirements of the European Union Waste Framework Directive (2008/98/EC), DCLG, December uthorites_on_implementing_planning_requirments_of_the_european_union_waste_framework_directive EC_.pdf" 10 In summary, the Duty to Cooperate requires planning authorities to cooperate when planning for strategic matters (including waste management) which cross administrative boundaries. Page 7 of 102

9 2.7 The assessment of employment land across the county and Southend-on-Sea involved the application of the WLP s emerging development management criteria and so establishes the extent to which these criteria (and hence the WLP) will allow the location and development of additional waste management capacity in suitable locations within the WLP area sufficient to meet all of Essex and Southend s requirements over the plan period (i.e. to 2032). The assessment included three stages as follows: All Local Plan designated employment land/industrial estates (initially 240) were identified in the WLP area. From the initial 240 estates/sites, a shortlist was prepared through a desktop exercise that identified the presence of key constraints which would inhibit waste management development. The key constraints considered were: o Site size, o proximity to Natura 2000 sites, o flooding, o proximity to sensitive land uses, o access. Finally, each of the shortlisted areas were assessed for their suitability for waste management development against specific criteria, including: o Availability (at that time); o land use policy; o individual unit size; o compatibility with adjoining land uses, 2.8 Based on the criteria applied, the review of employment land revealed that there appears to be scope (both availability and suitability) within existing industrial estates to locate a range of waste management facilities. The locations identified are considered to offer opportunities for development that would be in line with the emerging development policies of the WLP. The industrial locations have been identified to demonstrate the deliverability of emerging WLP policy in terms of providing for the development of additional waste management capacity on employment land in Essex and Southend-on-Sea. 2.9 In order to ensure that the WLP addressed NPPF requirements regarding deliverability and viability (see below), the ELR highlighted that further analysis was needed to inform approaches in the WLP. This was with the intention of identifying deliverable opportunities for the development of waste management capacity by, for example, the allocation of sites forming part or all of the shortlisted employment areas The NPPF does not include specific waste policies. However, other policies in the Framework are relevant to the content of the WLP. In particular, when testing soundness, the examination Inspector will consider whether the WLP has been positively prepared. In testing this aspect the Inspector will look to see that the waste management requirements identified by the WLP can be met and this will include an assessment of the deliverability of development on land identified in the WLP as suitable for waste management. This study is intended to provide evidence related to the deliverability of waste management facilities on industrial estates in particular. Page 8 of 102

10 2.11 It is worth noting that in preparing an evidence base, paragraph 160 of the NPPF advises that: Local planning authorities should have a clear understanding of business needs within the economic markets operating in and across their area. To achieve this, they should..work closely with the business community to understand their changing needs and identify and address barriers to investment, including a lack of housing, infrastructure or viability Furthermore the NPPF includes the following on Ensuring viability and deliverability 173. Pursuing sustainable development requires careful attention to viability and costs in plan-making and decision-taking. Plans should be deliverable. Therefore, the sites and the scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened Local planning authorities should set out their policy on local standards in the Local Plan.In order to be appropriate, the cumulative impact of these standards and policies should not put implementation of the plan at serious risk, and should facilitate development throughout the economic cycle In addition, paragraph 18 of the former national planning policy on waste management (PPS10) noted the following: waste planning authorities should: avoid unrealistic assumptions on the prospects, for the development of waste management facilities, or of particular sites or areas, having regard in particular to any ownership constraint which cannot be readily freed, other than through the use of compulsory purchase powers Therefore in order to demonstrate that the WLP is deliverable, (as required by the NPPF) this study assesses whether it is reasonable to expect that waste management development will come forward at suitable locations shortlisted in the ELR. This also takes into account the impact of the WLP s development management criteria This study therefore forms part of the evidence base of the emerging WLP. It further informs the in-principle policy approach promoting waste related developments on employment land that are deliverable and viable for a range of waste management facilities. The study presents qualitative and quantitative information to provide an understanding of the practical and deliverability constraints associated with the use of industrial estates for a range of waste management facilities. Ultimately, this study considers ways in which any reliance of the WLP on industrial land for the development of required waste management capacity might be supported. Page 9 of 102

11 3 Methodology 3.1 This study has involved several distinct activities which all make a contribution to assessing the deliverability of waste management facilities on industrial land in Essex and Southend-on-Sea. These activities are as follows: - Sample survey of waste management industry - Sample survey of industrial property management industry - Stakeholder Workshop - Assessment of the main determinants for economic viability/feasibility of waste management facilities via separate research. 3.2 A description of each of the activities is set out below. Further details are set out in the appendices as follows: Appendix 1: Methodology for selecting the sample of industrial states Appendix 2: Waste Management Industry Questionnaire Appendix 3: Findings from Waste Management Industry Survey Appendix 4: Industrial Property Management Industry Questionnaire Appendix 5: Findings from Property Management Industry Survey Appendix 6: Notes of Stakeholder Workshop Appendix 7: Findings from the quantitative assessment examining the main determinants for economic viability/feasibility of waste management facilities 3.3 It should be noted that a meeting with the District Councils also took place at which the concept of holding the stakeholder workshop was considered. Survey of sample of waste management industry representatives 3.4 The survey of a number of representatives of the waste management industry focussed on the following three factors considered to affect the deliverability of waste management facilities on industrial estates: Operational, Setting and Economic. 3.5 Each of these is considered in turn as follows: Operational 3.6 Operational factors are those which affect the ease with which a waste management facility can function on a daily basis in particular how easily materials can be received, stored, processed and removed. Certain types of facility produce outputs such as power, heat and biogas and the ease with which these outputs can be utilised/distributed is also an operational factor. The presence of utilities needed for the facility to function in the form of power and water is also a factor. As the locations being examined are all existing, developed, industrial locations it was assumed that necessary power and water would already be available. Page 10 of 102

12 Setting 3.7 Setting factors include those, which if present, may require specific measures to ensure that they are not harmed by the operations of a waste management facility. For example if a site is adjacent to a habitat that has a protected status it may be necessary to implement mitigation measures to reduce the risk of operations harming that habitat. Such factors include the presence of dwellings whose inhabitants might also be adversely affected if no mitigation is in place. In extreme cases it may be that no level of mitigation reduces the risk to an acceptable level and so operations cannot take place in that location (essentially making that location undeliverable for such development as conceived at the time). Economic 3.8 Economic factors are those factors which would affect the viability of developing a waste management facility in an industrial location. Economic factors include the cost of leasing or purchasing a site and fiscal measures (incentives and penalties) affecting the management of waste. This report examines the main determinants for economic viability/feasibility of waste management facilities. 3.9 The deliverability of different types and sizes of waste management facility will be affected by the above factors in different ways. So for a certain type of facility the presence, absence or presence in excess of certain factors may make it difficult or impossible for a facility of a particular type to be developed in a particular location. It may however be possible to develop a facility of a different type Ultimately it is for the waste management industry to decide to develop a facility or not and so, in understanding deliverability, it is important to establish industry views of how these factors might affect the prospects of development of different types of waste management facility on industrial locations in Essex and Southend-on-Sea in particular. The approach taken to obtaining these views and the findings are set out in the following sections Representatives of the waste management industry were contacted to obtain their views on how deliverability of waste management facilities is affected by certain factors. The representatives were chosen on the basis that they had knowledge of developing waste management facilities, and an interest in doing so within the study area. The survey results were recorded on an anonymous basis to assure confidentiality and maximise cooperation. As part of this exercise, where possible, views were sought on the suitability and deliverability of sites on a sample of types of industrial locations which may be found in Essex and Southend on Sea Views were obtained through the completion of a survey questionnaire (included in Appendix 2). The questionnaire included schematic diagrams intended to illustrate each of the types of industrial location which made up the representative sample of locations. Respondents were specifically asked to consider the deliverability of waste management facilities in those locations. Initially s were sent to 26 sector representatives based on a listing of consultees contacted in previous stages of consultation. This included the 11 The process of selecting the representative sample of locations is described in Appendix 1 Page 11 of 102

13 questionnaire and a request to discuss its contents by telephone. A total of eleven telephone interviews took place, with the representatives ranging from smaller local companies to those operating on a national basis. While the majority (80%) of respondents had a local interest a few of those from the larger companies did not currently have operations in the WLP Area but had substantial experience of developing waste management capacity using a variety of technologies, mostly in industrial locations A breakdown of the experience of the representatives spoken to or the companies they represent, in terms of developing different types of facility in different types of location, is provided in Table 1 below: Table 1 - Experience of waste management industry representatives surveyed Facility type Type of location (no. of respondents) Industrial estate/area 12 Urban (builtup) Area 13 Rural Area 14 - Transfer & bulking Recycling - MRF Composting - open or in vessel Construction and demolition (C&D) processing - Treatment inc MBT and AD Treatment energy from waste including ATT This shows that the respondents covered experience of developing all types of waste management operations in the full range of settings and in particular that which is the focus of this study i.e. employment land. Survey of a sample of industrial property management industry representatives 3.15 Industrial property management companies were also surveyed for their views on the viability of locating waste management facilities on industrial estates. As some of these companies might be unfamiliar with waste management a list of the key characteristics of different waste management facilities was drawn up and included with the questionnaire The industrial property management companies contacted were taken from a listing of companies that had previously been contacted during earlier WLP consultation exercises. This information was supplemented with an Internet search for contact names associated with the management of land shortlisted in the ELR Initial contact was made by ing a questionnaire and introductory letter and this was followed up with a phone call. The questionnaire is included as 12 An 13 An area of land that has been specifically developed for use by light and heavy industry. area of land located within or on the edge of the built up area of a town or city but is not located in an industrial estate/area. 14 An area of land that is away from main settlements; mainly surrounded by open, undeveloped greenfield land including on the edge of small settlements e.g. villages." Page 12 of 102

14 Appendix 4. Key questions were as follows: a. How are waste management facilities/uses perceived by other tenants on an industrial estate? b. What is the approximate cost of the sale and lease of industrial land in Essex? c. Is there a broad understanding of the sale and rental costs of industrial land and the turnover of occupiers on these industrial estates? d. What are the preferences for site owners relating to development and use i.e. bespoke or generic buildings, short or long term lease arrangements? industrial property management companies were contacted and, of these, nine agreed to participate in the survey. The main findings from the survey are included in Appendix While some representatives had clear views on specific areas others had a much wider perspective and were able to provide views which related to the entire area. The consistency of views expressed in responses between representatives suggests that a sufficiently large sample had been surveyed. 15 Stakeholder Workshop 3.20 During the study period it was decided that it would be useful to hold a workshop for stakeholders to inform the study. Representatives from the following stakeholders were invited: Waste Management Industry Industrial Property Management Industry District Council Planning Authorities The Environment Agency - as permitting body and statutory consultee on planning applications 3.21 The initial aim of engaging these stakeholders in discussion was to provide an opportunity for all parties to clarify, and consider, each other s positions with regard to the potential development of waste management facilities in industrial locations. This was with a view to achieving some consensus on the need for local waste management facilities, and how they might be accommodated in such locations. Other aims of the workshop were to achieve the following: A. A better understanding of the nature and possible impacts of modern waste management activities; and, B. To identify and clarify potentially problematic issues that might affect site deliverability; 3.22 The workshop was also intended to provide a forum to further cooperation between the District Councils and the authorities, building on a roundtable session involving the District Councils that took place earlier in the project The 20 respondents to the telephone interview process, as well as others who had been contacted but not completed the survey, were invited to attend along 15 "During the survey it became apparent that the companies contacted initially did not have an interest in Southend on Sea and so respondents from that area were deliberately sought and interviewed." Page 13 of 102

15 with representatives of all District Councils in Essex together with a representative of the Environment Agency. Representatives from all three stakeholder groups attended: seven from the waste management industry; three from the property management industry; two from local authority. This allowed for three mixed facilitated discussion groups to be established with representatives expressing a range of views and testing each other s perspectives The workshop involved a combination of presentations and group discussion and feedback. Following a brief Q&A session the discussion groups were invited to consider a number of questions as follows: Question 1: Site availability had been ranked in the telephone interview process as the most important determinant in developing a site. a. But what determines site availability? b. Is it solely down to landowner willingness? c. If so how might ECC and SoS engage with landowners most effectively to secure support for use of industrial estates identified in the Plan? Question 2: The price of land was identified in the telephone survey as secondary to land availability but is also an important factor. Some respondents said that it could be prohibitive to development on industrial sites. a. How do the economics of waste management influence the decision to develop a site on an industrial estate? b. In particular what return is generally being sought on investment? c. What are the main barriers to gaining the required investment? d. How might they be overcome? Question 3: The term "Industrial estate" is generic for a wide range of areas allocated for employment type development. a. Is there a need for the emerging WLP policy to distinguish between types of estate so that prospective developers are directed towards sites on the 'most appropriate' industrial land? b. If so how might such a distinction be framed in policy? c. Is there a role for policy to encourage the migration of long established sites to 'more appropriate' ones? 3.25 A summary of the responses is provided in Appendix 6. Quantitative assessment examining the main determinants for economic viability/feasibility of waste management facilities Work was undertaken with a view to establishing the maximum price the waste management industry would be prepared to pay for land in Essex and Southend on Sea. This determines the ability of waste management uses to effectively compete for sites on industrial estates in the area and in turn helps ensure that approaches put forward in the WLP are deliverable Completion of this task requires understanding of the following two elements: a. The price or cost of land on industrial estates in Essex and Southend of Sea. b. The sensitivity of different types of waste management development, in terms of their viability, to rents and land prices. Page 14 of 102

16 3.28 The information required was obtained from the survey of the waste management industry and property management industry as outlined above and through a literature survey Furthermore, validation of the approach and findings was obtained from selected experts from the sector via a review of Appendix 7. 4 Findings 4.1 The raw findings from each of these four main evidence gathering activities are presented within the appendices as follows: - Survey of waste management industry Appendix 3 - Survey of industrial property management industry Appendix 5 - Stakeholder Workshop Appendix 6 - Assessment of the main determinants for economic viability/feasibility of waste management facilities Appendix This section presents the findings as responses to the following key questions which need to be understood for an assessment of deliverability of waste facilities on industrial estates to be made. 1. What are the key barriers to the development of waste management facilities on industrial land in Essex and Southend on Sea and how do they affect the development of additional waste management capacity? 2. Are these barriers likely to change over the period of the WLP i.e. to How might local planning policy facilitate the development of additional waste management capacity on industrial land? Answers to these questions, derived from the findings are set out below: 1. What are the key barriers to the development of waste management facilities on industrial land in Essex and Southend on Sea and how do they affect the development of additional waste management capacity? Availability of land 4.3 The only absolute showstopper was identified as availability of land. Availability was found to have two elements associated with it as follows: - the presence of unoccupied plots of land - willingness of landowners to release land for waste management 4.4 The survey and workshop revealed that landowners were often wary of allowing waste management development on their land or, in some cases, were fundamentally opposed to it. However it seems that the position of landowners is affected by two factors: - The price that a waste management company is prepared to pay to occupy and operate on a piece of land; and Page 15 of 102

17 - the perception that the proposed waste management facility will in some way devalue the land - either by direct damage or by deterring higher value users on adjacent and nearby plots While landowners initial reactions may be negative towards an approach for a waste management use, it does seem that this initial position can be modified if the right terms are offered over a sufficiently long period to make it a worthwhile commitment. This shift in position may be assisted by specific companies, and the industry generally, being able to satisfy concerns, by education, that what is proposed will not cause the feared adverse impacts. This could be in the form of assurances of environmental permits being in place, quality management systems and external verification. 'Showcasing' existing facilities operating elsewhere without causing any adverse impacts may also help change perceptions. Regulatory authorities also have a role to play by implementing and enforcing appropriate standards of operation across the sector. This may include the development and implementation of a Supplementary Planning Document (SPD) concerning design standards for waste management facilities and waste management at sites more generally. Proximity to residential areas 4.6 The close proximity of industrial land to residential areas was most frequently noted as an issue that requires careful consideration and was seen as a potential barrier to waste management development in particular locations. This was especially so for waste management facilities processing putrescible wastes, such as in-vessel composting and anaerobic digestion. It should be noted that under Environment Agency permitting rules, intended to limit possible exposure to bioaerosols, the location of such facilities proximate to areas of human occupation may be restricted. In cases of larger size industrial estates, that may have residential areas proximate to a particular boundary, it might still be possible to develop a plot within the estate at sufficient distance from that residential area to reduce the risk of potential impacts to an acceptable level. It should be noted that the ELR already screened out land where a significant portion (e.g., 50% or more) fell within either 100m or 250m of sensitive properties (housing, hospitals and schools), however such a criteria does not completely eliminate the possibility of proposals coming forward on employment land proximate to residential areas. Impacts will also be managed through appropriate and relevant development management policy criteria to be applied when determining individual planning applications. 4.7 Other elements of waste management uses which make them less compatible on land in close proximity to residential areas were the possible need for 24 hour operations and access to the site by HGVs. Limitation of hours of operation below a 24 hour (3 shift) regime may compromise the viability of an operation requiring substantial up front investment and may in some cases be prohibitive e.g. EfW plant requires continuous operations to maintain operational efficiency and avoid costs and delays associated with frequent start up. Such 24-hour operations tend to be associated with higher capital cost facilities which may require good quality access to the strategic highway network, which is more commonly associated with larger/modern industrial estates and distribution centres situated on the outskirts of settlements and utilising the strategic road network. So, although a lack of a good access to a site was not considered to be a showstopper, in Page 16 of 102

18 general it was noted that if the access was through a residential area then this could be problematic. Size of sites 4.8 It was noted all the locations were potentially quite large (the smallest size category considered in the representative samples of industrial locations was less than three hectares and the ELR screened out land less than 0.5 hectares). Most respondents considered that open composting could not be located in such locations and one respondent felt that an EfW facility would need a plot of at least 3 hectares thus ruling out some of the smaller locations shortlisted in the ELR. However it should be noted that an EfW plant recently built in Exeter has been accommodated on a site of only 1 hectare in size. 4.9 Findings of a literature review set out in Table 1 of Appendix 4 indicate that the minimum site size for a facility of some sort is 0.65 hectares. i.e. any site of this size or larger could theoretically accommodate a waste processing facility with a significant capacity. Costs of land 4.10 Waste management is not a use of land that is particularly profitable and so the waste management industry can struggle to compete with other users especially in high demand locations. This is particularly the case for sites in prime locations due to connectivity where it is considered that certain players in the sector can only realistically compete for sites of 1 hectare or less. However the cost of land appears to play a variable role in determining viability and overall viability depends on the particular type of facility being developed and business model applied. Not surprisingly, land price can be a significant factor for activities with low profit margins Table 1 below sets out the findings with regard to land prices in Essex and Southend on Sea and illustrates the range of prices which might be expected regardless of type of use. Table 1: Indicative Employment Land Price ranges 16 Low High Purchase Price/hectare < 1 million 2.5 million Rental cost (open)/hectare 100, ,000 Rental cost (building)/sq ft Applying the values obtained to minimum facility footprint data suggests that to secure a site of minimum size required to process at least 40,000 tonnes 17 of biodegradable waste would cost: 1. Between 400,000 and 1 million to purchase; or 2. Between 43,000 and 183,000 per annum in rent. 16 "Derived from survey respondents" 17 "See Table A3-2 in Appendix 4" Page 17 of 102

19 4.13 A developer with a project with large up front capital expenditure is more likely to be sensitive to land costs as an element in set up cost. Therefore the development of technologies that entail large capital outlay will be more sensitive to land costs if they exceed a certain threshold. Or, put another way, where land costs are high it is less likely that technologies that entail large capital outlay will be developed unless they either have long-term security or offer a particularly high level of profitability. Profitability may in turn be dictated by the availability of competing capacity either locally or within an acceptable driving distance There will also be an absolute threshold of land cost above which technologies of any sort are unlikely to be viable. That is where the waste management industry will be unable to compete. One industry expert indicated that as a rule of thumb 5/tonne 18 cost of land was considered to be a threshold although it might be exceeded in the case of purchase where the land can be viewed as an asset As one would expect, land prices are affected by the availability of unoccupied plots so locations with smaller industrial areas tend to be more expensive. The survey of industrial property industry established that land prices and rental rates were highly variable across the county with costs generally rising as connectivity to main urban areas, (and sources of waste), improves The survey did not result in specific estates being identified as particularly expensive, although it was noted that, as a rule of thumb, the more accessible the land is to London and the M25 the more expensive it tends to be. Perception of Waste Management 4.17 The perception that all waste management activity is likely to have significant adverse impacts means that landowners are not actively seeking to locate such uses on their land and would prefer to host other uses. This generally puts the waste management industry at a disadvantage when competing for the use of land. 2. Are these barriers likely to change over the period of the WLP i.e. to 2032? 4.18 The principal barriers identified above are: (i) (ii) the terms offered and the possible negative impact on land value In the case of the former this is very much dependant on how competitive waste management uses will be as compared with other potential tenants. This will depend on market conditions both within the waste management sector (and the potential long term returns envisaged) and the state of the economy more generally. Economic recovery can be expected to result in increased demand for industrial land as new businesses develop and others expand such an increased demand will push property prices up if supply remains limited. This finding seems to be consistent with that in the ELR, the executive summary of which includes the following: 18 "Gareth"Philips"SITA"Estates"Manager" Page 18 of 102

20 The review found that the amount, size and location of employment land/industrial estates varies considerably across the study area. The recent economic downturn has had an effect on the number of units being let and the length of tenancy in most industrial estates However an economic recovery is also likely to lead to increased quantities of waste requiring management. The other factor that might improve the competitiveness of the waste management industry, as the economy recovers, are increases in the demand for materials and energy. Generally speaking, increasing material and energy prices will improve the incomes of waste management companies making the development of additional facilities more attractive and in turn meaning that the industry may be willing to pay more for land In the case of waste management facilities having a negative impact on land values, the expectation is that the quality and performance of waste management facilities will continue to improve partly through regulatory pressure and partly through operators being more conscious of their own public image and its importance in maintaining their licence to operate. As more facilities become operational which do not impact on their surroundings in a manner that matches common perceptions, it should become easier for the industry to convince landowners that their activity will not negatively affect the value of industrial land In addition the operating model of the sector is changing with an increase emphasis on logistics, moving towards smaller satellite facilities where materials can be separated for bulking for onward transport to larger more remote facilities. This allows for the possibility of a reduced land demand on better connected (and hence more expensive) sites with the larger facilities sited on cheaper land. 3. How might local planning policy facilitate the development of this capacity on industrial land? 4.23 The lack of suitable allocated employment land was highlighted as an issue with one representative of the property management industry noting, Chelmsford is full! The allocation of further employment land in local policy was therefore seen as crucial The imposition of additional controls intended to address the specific environmental impacts of waste management facilities and seek high quality development was thought to make the development of such facilities a more expensive venture than for other types of employment use. Additional expenditure on such mitigation could therefore make the waste management industry even less competitive than other uses (Also the additional investment has a longer pay back period and so the developer may be more committed to a longer lease period). On this basis it is important that local planning policy, or other environmental regulations, do not result in additional unnecessary costs associated with the development and operation of a waste management facility in particular and look to a consistent approach of promoting high quality development on employment land regardless of its end use. Page 19 of 102

21 4.25 In order to help waste management companies compete in the property market in particular locations, planning policy identifying allocations of land exclusively for waste management uses would be particularly supportive. 4. Other key findings 4.26 None of the characteristics associated with the representative samples of industrial land (represented by schematic drawings as set out in Appendix 1) would automatically rule out development in those locations i.e. it was considered that some form of waste management could be successfully developed in any of the locations considered Management of waste is increasingly involving the separation of different materials to realise, and increase, their value. This activity frequently involves the separation of dry, non-putrescible materials and can take place within a warehouse-type (B2 or B8) building with external yard storage and parking area typically of the kind found on industrial estates One representative of the waste management industry noted that in some areas, waste planning authorities had placed restrictions on where waste may be sourced. It is thought that this is to counter those concerns about particular waste development leading to an area becoming a dumping ground for waste arising in neighbouring areas (this point is partly linked to the negative perceptions associated with waste management facilities and more importantly the lack of positive perception of benefits such facilities may bring such as cheap or stable priced heat). Such catchment area restrictions can hinder the operation of the market, stifling competition and potentially making the development of a facility unviable. This may be of particular relevance if the viability of developing a facility on certain industrial estates is more marginal than other locations proposed The findings of the surveys and the workshop suggest that additional waste management capacity may be developed on industrial land subject to the following: - Land being available - Proposed waste uses being compatible with the character (including existing or planned use) of the industrial land on which the proposed use may be situated. In particular the need for sites to be appropriately located, offering unhindered vehicle movement and accommodating structures with a suitable roof height for associated vehicles and plant For related planning policy to be effective (deliverable) both of these factors need to be taken into account. Therefore it seems sensible to consider the following planning policy approaches: - clearly define industrial land in relation to the different types of waste use that may be accommodated taking account of the fact some types of waste management use may be less suitable for some locations than others. - set out the circumstances under which industrial land may be developed for waste management use. - Page 20 of 102

22 4.31 The use of the term industrial land in policy may not be helpful as the types of land, which fall within this generic category, vary widely. This is revealed by the ECC draft Review of Employment Land in which the type of land considered suitable varies considerably; from being isolated plots in rural areas to being surrounded by development in urban areas. If the term industrial land is used then it will be necessary to have clear development management policies to ensure that certain uses do not come forward in unsuitable locations, e.g. composting on land on an industrial estate that is proximate to residential areas. 5 Conclusions Suitability of shortlisted employment land 1. The ELR process appears to have been effective in identifying industrial land with characteristics that would not rule out, and may offer, opportunities for the development of additional waste management capacity. 2. While not all types of waste management use will be deliverable in all of the short-listed industrial locations, the findings of this study suggest that some form of waste management is deliverable on most if not all of the shortlisted locations. Therefore, the general conclusion is that, it is not only possible, but also foreseeable, that additional capacity, that will contribute to the overarching aim of achieving sustainable waste management, can, and most likely will, be developed on some industrial locations in Essex and Southendon-Sea. 3. The process and criteria applied in shortlisting employment land for waste management uses has resulted in a wide range of locations being identified which could host a range of waste management facilities. There appear to be no other spatial factors, not already considered by the ELR, which would affect their deliverability and might subsequently result in their elimination. Quantitative assessment and economics 4. Any quantitative assessment of viability will be relative and time bounded i.e. the price of land varies, as does the profitability of waste management facilities so any conclusions drawn will only present a present day snapshot. The assessment undertaken indicates that certain types of facility are likely to be more sensitive to land prices than others. Therefore price may be acting as a 'screening' tool to limiting the range of facilities that might be brought forward in certain locations. If the intention of the WLP is to maintain flexibility then a range of sites including those located on land likely to be of lower costs e.g. due to their location, need to be included. Also were the value of waste management activity in general or specific activities to rise substantially then it may enable access to more expensive locations that may currently be seen as cost prohibitive over a certain size. This is where opportunities for facilities that supply heat or power might yield more beneficial returns than might otherwise be expected if judged by gate fee alone. 5. The current affordability of employment land in Essex and Southend on Sea varies according to location and to the type of waste management capacity to be developed. The ELR did not include land value as a deliverability criterion. While such a criterion could be applied in a manner whereby land with a value above a certain /hectare threshold was eliminated, this is not recommended, Page 21 of 102

23 as over the WLP period, market conditions are very likely to change such that land currently considered unaffordable (and therefore undeliverable) may become affordable either due to reducing land values and/or rising waste management industry revenues as added value opportunities associated with waste management emerge. Or simply a shift in operating model with the sector adapting to land supply constraints as described earlier. Therefore applying such a price threshold criterion would make the WLP unduly inflexible. 6. The economic recovery is resulting in increasing competition for land and waste management companies are struggling to compete with other uses especially in industrial locations nearer to the M Identification of industrial land within policy 7. It would not be sufficient to include policy by itself, which suggests that, in principle, waste management activities may be located on industrial land as there are very wide variations in scale and type of activity represented by the term waste management activities as well as the very wide variations in characteristics associated with land which may be defined as industrial. Indeed, it seems that, by itself, such a policy would be meaningless at best and misleading at worst. 8. Further to the point above, the identification of industrial land within policy as generally suitable (as per the 2011 Preferred Approach) would not assist with the waste management industry s ability to compete with other employment uses in the property market. Whereas, allocating specific sites within employment land could be beneficial if it meant that only the waste management industry could compete for that land as, due to the absence of demand from other users, the price might then come down. However, were a very limited number of sites to be allocated, then the value of these sites might become inflated as different waste management companies seek to compete for them. 9. Following on from the point above, any site allocated on employment land should be at least 0.65 hectares in size to ensure that a facility able to make a significant contribution to meeting the need for additional capacity could be made. Furthermore a site of such a size is more likely to require substantial investment and the developer will therefore be seeking to either purchase the land or secure a lease of at least years. Such a long term proposition should also be more attractive to landowners and could mitigate against adverse positions taken due to negative perceptions of waste activity. Development management 10. The proximity of residential areas and other sensitive uses to potential locations is most likely to constrain some types of waste management use than others. In particular, very careful consideration should be given to the development of those uses, which may result in odours being released, in 19 "Near to the M25 is taken to mean that the M25 can be reached within 20 minutes journey time" Page 22 of 102

24 close proximity to residential properties or where sensitive access routes prevent 24 hour working were it to be needed. 11. This study does not identify the need for specific adjustments to the development management criteria, identified in the 2011 Preferred Approach, to enhance the deliverability of waste management facilities in industrial areas, without removing the protection of surroundings and communities. Industry views 12. There is a widely held perception that waste management is generally a bad neighbour activity to be located away from other development. This perception is shared by a significant part of the property management industry and, given the current state of understanding and limited experience of the modernised waste management sector, may reduce the appetite of owners and agents to seek out and promote the development of waste management capacity compared to other potential uses. 13. There is also a widely held view across both the property management and waste management sectors that there is not enough allocated employment land. However it is not possible to say whether this is actually the case without undertaking a review of industrial estate vacancies, development and turn over. Relevance of industry sample size 14. Despite the apparent small sample size of businesses in both sectors surveyed it is considered that this was proportionate in light of the fact that the messages received were relatively consistent. Had widely varying views been elicited from the companies surveyed then it would have been reasonable to extend the sample size but this was not the case. 6 Analysis of Possible Approaches 6.1 The conclusions suggest that generic policies, which state that industrial land might be suitable for waste management, are insufficient in improving deliverability. Instead the conclusions suggest that specific areas, or allocations should be included. This can be done in a number of ways as follows: 1. Allocate areas of search on established industrial land as 'in-principle locations' for the development of a range of waste management facilities. Applications for development within areas of search would be dealt with in the same way as proposals for waste related development on allocated sites, by using criteria based policies in the WLP. Proposals for any type of technology and waste stream would be considered, though whether permission would be granted would depend on the compatibility of the proposal with surrounding area (site setting) and the constraints of the particular site. Each location identified as suitable in the Councils assessment of employment land should be specifically identified as an Area of Search suitable for accommodating unspecified waste management uses. Page 23 of 102

25 2. Allocate additional sites, of at least 0.65 hectares, on industrial land for the specific development of waste management capacity 20. Allocated sites are identified plots of land within the WLP that are essentially identified for waste development. The tests of suitability for proposals for other non-waste uses on such land would therefore be much more stringent than those for waste uses. 3. Allocate areas of employment land as being suitable for specific types of waste management uses. For example certain 'higher end' waste management uses such as WEEE de-manufacture may be compatible with business park type locations while others involving open processing e.g. crushing of hardcore may not. 4. Establish a Local Development Order that specifies waste uses amongst those permitted within a particular area. A Local Development Order grants planning permission for the type of development specified in the Order, and by doing so, removes the need for a planning application to be made. Local Development Orders are very flexible in that they can: Apply to a specific site, sites, or wider geographical area; Grant planning permission for a certain type or types of development; and Grant planning permission outright or subject to conditions. They do not remove the need to obtain consent under any other relevant regimes. Enterprise Zone status is conditional upon putting in place a genuinely simplified approach to planning. Local Development Orders are the most likely planning mechanism to simplify planning controls in Enterprise Zones. Developers may still be required to demonstrate compliance with an LDO, and detailed conditions may still be imposed which require ongoing and prior approval. 6.2 Combinations of options may be considered. It should be noted that a sequential approach has been adopted in other Plans which usually seek development on allocated sites first, followed by land within Areas of Search and, finally, elsewhere in accordance with generic polices. However before adopting such an approach it is worth considering the Inspector s very recent report 21 on the Hertfordshire County Council Waste Site Allocations Local Plan that ruled against such an sequential approach (in paragraphs 32 to 34): 32. The site selection process is the subject of a number of key concerns. First and foremost is a concern regarding the sequential approach. In this regard, 61 Employment Land Areas of Search (ELAS) have been identified across the county. These tend to be industrial areas or trading estates the majority of which are allocated or designated for employment or similar purposes in the development plans of the constituent district-level authorities within the county. 20 These sites may or may not be those set out in the 2011 Preferred Approach for allocation. 21 " Page 24 of 102

26 33. Notwithstanding some detailed criticisms about the inclusion or extent of some of the Employment Land Areas of Search, I find that in principle they are suitable locations for the development of waste management facilities. Their selection reflects the Government view that waste planning authorities should consider industrial estates when identifying sites and areas suitable for new or enhanced waste management facilities Given the suitability in principle of the Employment Land Areas of Search for the development of waste management facilities, it does not make sense that waste development at these locations should only be permitted if it cannot be located on one of the 16 allocated sites. 6.3 A SWOT analysis of the approaches listed above is included in the table below which is intended to inform decisions made about the Preferred Approach. 22 Planning Policy Statement 10: Planning for Sustainable Waste Management, Para 20 Page 25 of 102

27 Strengths Weaknesses 1. Allocate areas of search which incorporate employment land Possibly more acceptable to District Councils than site allocations by being nonspecific and leaving the market to decide. Provides flexibility and accounts for the fact that different plots of land, within an area of employment land will become available at different times. Guides waste industry to land which, in principle is suitable for waste management development. Other uses may compete for land within areas of search and so may out price waste industry. Areas of search are areas where waste uses could be developed in-principle subject to further detailed assessment at the time of application 2. Allocate additional sites (min 0.65ha) on employment land Only the waste management industry could compete for that land which may make land more affordable due to the absence of demand from other users. Certainty that the WLP has allowed for the development of additional capacity that is required in future. Capacity relating to footprint of allocation can be banked. For consistency, sites would need to be identified, albeit within focussed areas, and assessed using the same methodology as that used to identify the strategic site allocations in the 2011 Preferred Approach - time and resources required for detailed assessment, including SA, to 3. Allocate different types of industrial land for specific types of waste management uses Makes it easier for low impact waste uses to be developed in more prestigious locations. Landowners may be more amenable to allocation of lower impact waste uses; Less resistance from Districts with more prestigious estates identified as suitable only for lower impact facilities. Facilitates development of facilities to meet increasing demand for low impact, single material, processing facilities e.g. WEEE recycling, plastics baling. Site selection process is more complex. Lack of flexibility for the employment sites, which may lead to vacant sites. Landowner may not be promoting the site for waste uses, or indeed wish to 4. Establish an LDO Provide a degree of certainty by establishing the principle of development and setting parameters. Potential developers see LDOs as positive statements of intent LDOs generally speed up the process of development. Loss of income from planning applications. Loss of public scrutiny and detailed assessment of the planning merits of the proposed waste use. Perception of loss of Planning Authority control. This may be Page 26 of 102

28 1. Allocate areas of search which incorporate employment land Likely to require more additional supporting information/ evidence at application stage. 2. Allocate additional sites (min 0.65ha) on employment land identify and assess sites. Lack of flexibility for the employment sites, which may lead to vacant sites. Landowner may not be promoting the site for waste uses, or indeed wish to develop their site for this purpose. Therefore difficult to prove deliverability in line with the NPPF. 3. Allocate different types of industrial land for specific types of waste management uses develop their site for this purpose. Therefore difficult to prove deliverability in line with the NPPF. 4. Establish an LDO a particularly sensitive matter when the use in question is perceived to be high impact. Waste management is generally a sui-generis use outside of the use class order with many variables on the nature and impact of operations difficult to define controls within an LDO. As a sui-generis use detailed applications (not outline) are required in any event and info required to properly assess impacts and hence appropriate conditions. Opportunities Identify sufficient spread of employment land area so search to ensure flexibility and enhance deliverability Development of a Waste Facilities Design Guide SPD to help allay fears concerning impact of facilities. Ideally prepare in parallel with the WLP to show commitment. A development brief for waste uses on a particular area of land could set out how development should take place including the particular issues needed to be taken into consideration. Development of a Waste Facilities Design Guide SPD to help allay fears concerning Development of a Waste Facilities Design Guide SPD to help allay fears concerning impact of facilities. Ideally prepare in parallel with the WLP to show commitment. May be more appropriate to include low impact waste uses as suitable, along with other employment uses, in LDOs developed for specific areas of employment land in conjunction with the Districts. This would be a strong demonstration of compliance with Duty to Cooperate. Page 27 of 102

29 1. Allocate areas of search which incorporate employment land 2. Allocate additional sites (min 0.65ha) on employment land impact of facilities. Ideally prepare in parallel with the Waste Local Plan to show commitment. 3. Allocate different types of industrial land for specific types of waste management uses 4. Establish an LDO Further investigation to assess use of LDOs and development of waste management capacity could be undertaken. Threats Open to accusation of general 'blight'. Employment land identified is too expensive for the waste industry. Circumstances e.g. landowner intentions, change such that an allocation (s) is no longer deliverable. District Council and community opposition likely due to specific 'blight'. Avoid allocating land solely near expensive areas which may make development unviable. Availability of time and resources to select sites and manage objections. A "ransom site" situation Could be overly complex, prescriptive and inflexible. Time and resources required for detailed assessment, including SA, to identify and assess sites. Circumstances e.g. landowner intentions, change such that an allocation (s) is no longer deliverable. District Council and community opposition likely due to specific 'blight'. Avoid allocating land solely near expensive areas which Development of a Waste Facilities Design Guide SPD to help allay fears concerning impact of facilities. Ideally prepare in parallel with the WLP to show commitment. Hard to see how LDOs could be developed for complex, high impact, waste uses would be time consuming and development is still not guaranteed. Page 28 of 102

30 1. Allocate areas of search which incorporate employment land 2. Allocate additional sites (min 0.65ha) on employment land develops within the industry/between the industry and the landowner. This can be overcome by identifying a sufficient number of sites to provide flexibility and options. 3. Allocate different types of industrial land for specific types of waste management uses may make development unviable. Availability of time and resources to select sites and manage objections. 4. Establish an LDO A "ransom site" situation develops within the industry/between the industry and the landowner. This can be overcome by identifying a sufficient number of sites to provide flexibility and options. The above analysis shows that all the options considered have strengths and weaknesses. However, clearly the best approach, in terms of securing maximum deliverability of additional waste capacity, would for the WLP to include a variety of these options. Page 29 of 102

31 7 Recommendations The following recommendations flow from the conclusions and review of possible approaches set out in the sections above. The recommendations have been split into three sections according to whether they are general or specifically related to waste planning policy or local planning policy. 7.1 General Recognise the management of waste as an important factor in the achievement of sustainable economic growth within Essex and Southend on Sea. Such recognition to be included in the WLP, local plans and the South East LEP s Strategic Economic Plan. Discuss the findings and recommendations of this study with the district council local planning authorities of Essex (LPAs) with a view to agreeing a memorandum of understanding on how suitable land uses on designated employment land across Essex are planned for in a manner which takes account of the requirements for waste management within the County. This might be achieved by an appropriate update to the ECC and Essex Planning Officers Society guidance notes 23 on development involving county matters. Such a discussion would be informed by the following: a. Information concerning the importance of effective waste management to the growing economy of Essex and Southend on Sea (see recommendation 1 above); b. Government guidance to planning authorities on the implementation of the waste hierarchy; c. Information concerning modern waste management practices. 7.2 For waste planning policy: To ensure maximum deliverability of additional waste capacity on employment land, the development of the WLP should seek to: o o o Continue the identification of specific allocations of industrial land, no less than 0.65ha in size, with good accessibility to waste arisings, able to accommodate a range of waste management uses. Include Areas of Search encompassing the potential areas of employment land identified in the ELR. Include general policy identifying industrial land as broadly suitable for waste management uses subject to meeting development management criteria intended to ensure sustainable development. For the purposes of ensuring the WLP s flexibility, and deliverability, it is recommended that careful consideration is given before including a policy that would result in a sequential approach to the granting of permission, whereby 23 Development involving County Matters Guidance Note, June 2013! Page 30 of 102

32 development on allocated sites is preferred over that on land within Areas of Search. Furthermore it is possible that, during the life of the Plan, a site that was ruled out as undeliverable due the landowner s attitude to waste management at the time becomes deliverable due to a change of heart. It is important, therefore, that the policies of the Plan are flexible enough to allow for such development to come forward. The WLP should avoid allocating land for waste management development solely in close proximity to the M25. Survey findings suggest that the industry may struggle more to compete for land nearer the M25 and so if the WLP were to allocate land only in this area it may fail the deliverability test. Consider developing a matrix listing different categories of industrial location and the types of facility which might suitable in that location. An example of how this might work is set out below. Business Park Light Industrial Estate Materials Recycling/ Recovery Facilities and Waste Transfer Stations Heavy Industrial Estate MRF for pre sorted materials? Y Y MRF for general waste (putrescible) N Y Y MRF for CDEW (skip waste) N Y Y Inert Waste Recycling Facilities CDEW processing inc crushing and N N Y shredding Metal Recycling and Vehicle Dismantling Facilities WEEE Demanufacturing (ATF) Y Y Y Vehicle Dismantling (ATF) Y Y Y Vehicle Destruction (Shredder) N N Y Other Recovery In-vessel Composting Facilities N? Y (IVC)/ Anaerobic Digestion (AD) Open windrow composting N N? EfW: Small scale selected materials Y Y Y such as wood only EfW: Large scale general waste N Y Y Mechanical Biological Treatment N Y Y Advanced Thermal Treatment inc. N Y Y Autoclaving, Pyrolysis and Gasification Clinical waste treatment facilities N Y Y Such a matrix would only be regarded as providing a guide as in certain circumstances, certain uses may be suited to locations which differ from those set out above. In particular, facilities may need to be in keeping with their surroundings in order for them to be acceptable. For example, in an areas of low rise development a 10 metre building ridge height may be seen as a maximum suggesting that facilities requiring larger stacks would not be Page 31 of 102

33 acceptable. N.B. A similar approach is included in the Northants Locations for Waste Development DPD. 24 Develop a Design Standards Supplementary Planning Document, ideally in parallel with the WLP, to demonstrate the authorities 'commitment to ensuring that waste management development will be of good quality. If it is not practical to develop this alongside the WLP then include a commitment in the WLP to prepare such an SPD. This might be extended to include designing for waste management in all development that might be developed as cross District - County guidance by the Essex Planning Officers Association. Such a guide should not result in requirements for the standard of waste facilities being greater than those for non-waste facilities. Policy, which would enable the inclusion of conditions on planning permissions restricting the area from which waste managed at a facility may be sourced, should only be considered in exceptional circumstances due to the possible impact on the deliverability of additional waste management capacity. In commenting on the local plans of the district councils the WPAs should seek the allocation of employment land that could be utilised for the development of waste management capacity. This would be in accordance with DCLG guidance set out in paragraph 2.5 above. 7.3 For other Local Plan policy: In designating employment land in local plans the LPAs should consult with Essex County Council at the earliest possible opportunity with a view to establishing the suitability of locations for waste management uses which may be compatible with other employment uses. Allocation of employment land should take into account the need for land associated with the development of waste management capacity (in consultation with ECC). In other words, waste management should not be ruled out from development on employment land or ignored as a matter to be dealt with by the WPA. Local planning policy should clearly indicate where waste management uses might be acceptable on designated employment land (subject to compliance with other planning policies (including those in the WLP)). An example of this type of policy has been included in the Brighton & Hove City Council draft City Plan (with emphasis added): Protection of the following primary industrial estates and business parks for business, manufacturing and warehouse (B1, B2 and B8) use: 24 See Para Documents/110416%20D%20LWD%20adopted%20new%20covers.pdf! Page 32 of 102

34 {List of industrial estates included} The council will support proposals for the upgrade and refurbishment of these estates and premises so that they meet modern standards required by business, are more resource efficient and improve the environment or townscape of the site or premise. Sui generis uses, including waste management facilities, appropriate in nature to an industrial estate location will also be acceptable, provided that they generate employment which is quantitatively and qualitatively comparable to uses within B1- B2, B8 Use Classes; do not harm the continuation of existing uses within those Classes and comply with other City Plan policies, and for waste management facilities the Waste and Minerals Plan. In relation to the above, the following statement in the recent Government Technical Consultation on Planning (DCLG July 2014) should be noted: 2.95 Waste management facilities may fall under more than one Use Class or be sui generis, depending on the type of operation carried out and the type of facilities required. Facilities for bulking up waste for onward movement (such as waste transfer stations) or for the recycling of waste (such as material recovery facilities) may fall under general industry (B2) or storage/distribution (B8) and so are able to benefit from existing permitted development rights. Page 33 of 102

35 Afterword Although this report recommends that the Plan seek to allocate sites on employment land, the evidence suggests that it is quite possible that any attempt to do so will have varying degrees of success. Clearly landowners who consider that they are more likely to obtain a greater return for their land by developing it for uses other than waste management may not wish to offer their land for allocation. It is also noted that during the course of this report s preparation, a call for sites exercise has been undertaken which has resulted in no new sites coming forward on employment land despite an extensive process of notification. However, in light of the fact that a plan with additional allocated sites within it will provide a more certain future for the development of additional waste management capacity it is considered premature to rule out this approach. In the event that a thorough exercise of identifying sites for inclusion in the Plan proves to be unsuccessful then a reappraisal of the Plan s approach can be undertaken at that time, however in light of the number (around 50) and distribution of estates identified as suitable within the ELR, it seems unlikely that such an attempt would be completely fruitless. In identifying sites it will be important to have in mind what type of facility will be considered suitable as not all uses may be suited to a particular location, especially those managing waste which is likely to give rise to odours. A particular conundrum is the fact that more expensive areas are less likely to be willing to offer land for the development of waste management facilities and inclusion of such land would make the Plan undeliverable, however it is within these areas that the waste industry needs greater support from the Plan (in the form of site allocations) that would allow it to be compete with other uses. Attempts to include Areas of Search in the WLP which encompass employment land may meet with less resistance as such an approach does not rule out other forms of development within those areas. Clearly they would not provide the Plan with the same certainly but should be seen as another tool in the toolbox that is worth employing as they provide greater certainty than generic policies. Page 34 of 102

36 8 Appendices Appendix 1: Appendix 2: Appendix 3: Appendix 4: Appendix 5: Appendix 6: Appendix 7: Methodology for selecting the sample of industrial states Waste Industry Questionnaire Findings from Waste Industry Survey Industrial Property Management Industry Questionnaire Findings from Property Management Industry Survey Notes of Stakeholder Workshop Findings from the quantitative assessment examining the main determinants for economic viability/feasibility of waste management facilities N.B. The title of the substantive appendices are shown highlighted in green like this, to distinguish between those and appendices within appendices. Page 35 of 102

37 Appendix 1 Methodology for selecting the sample of industrial states To test the deliverability of waste management development on short-listed industrial locations in Essex and Southend-on-Sea a sample of locations short-listed in the Employment Land Review (ELR) was chosen for further examination. Selection of sample estates involved analysis of the presence or absence of key spatial features at all the initial shortlisted estates. Estates which, taken together, have a good range and mix of features were then chosen as those which best represent all the estates. To be properly representative it was considered necessary to choose 15 different locations (just over a quarter of the total no. of short-listed areas). It was considered that selection of the sample estates in this manner would mean that conclusions reached from a further analysis of the deliverability of these estates would be broadly applicable to all the shortlisted areas identified as potentially suitable in the draft ELR. An initial sort of the areas based on size was undertaken as it was felt this was an important factor in choosing a representative sample. This revealed that the size of areas ranged between 0.74 and 128 hectares with the majority of sites falling within a range of 3 to 50 hectares. Five size categories were chosen to represent the different sizes of area. The range is shown in Table A1.1 below. It was considered important to test the deliverability of areas at the extremes of the range, and so very small (< 3 hectares) and very large (>50 hectares) size categories (as well as small, medium and large were also used. The key features and the way in which they were analysed are described below. Size Size of the area was included, as this will affect the likelihood that a suitable site will be available for development with larger areas having a greater likelihood. Presence of waste management facility Whether a location had a waste management facility already within it was considered an important selection criteria as this indicates that such areas already offered deliverable opportunities. Proximity to main urban areas Proximity to main urban areas was assessed on whether the locations were within; adjacent or within 1km; over 1 km away. This was included as it was considered that some operators might consider that proximity to the main sources of waste was a factor in the deliverability of a site. The main urban areas were taken to be those formed by the settlements of Chelmsford, Colchester, Southend-on-Sea, Basildon and Harlow. Proximity to the Green Belt Proximity to the Green Belt was considered, as, due to policies to protect its openness, it is possible, but certainly not inevitable, that the development of a waste management use might conflict with this aim. For areas within, or less than 1 km away from, the Green Belt it was therefore noted as a constraint. It should be noted Page 36 of 102

38 that for some areas no mention was made of the Green Belt in their descriptions in the draft ELR and so it was assumed that the Green Belt was greater than 1 km away. Opportunity of Heat Use The extent of the opportunity for the use of heat generated by certain types of waste management facilities was also considered important, especially in light of government emphasis, in the new national planning policy on waste, being placed on the need for such heat to be utilised. The East of England renewable and low-carbon energy capacity study was used in assessing whether a location presents a greater or lesser opportunity for the use of heat. Figure 23 of this study 25 shows those areas where there might be district heating opportunities. These areas relate closely to the main urban areas. Access to the strategic highway network Areas were recorded as having good or limited access to the strategic highway network, which was taken to mean that the main A roads and motorways in or near Essex were within easy reach. This was considered important as operators may wish to develop sites that deal with waste from a wider area and make it possible to transport materials produced by various waste management processes to other facilities which may be some distance away using large articulated vehicles via motorways and dual carriageways. Access to sites The actual suitability of access on to the areas is reported in the ELR that shows that this is quite variable. This was therefore included to ensure areas with varying suitability of access were included in the sample. Operators may take this into account when deciding on the deliverability of a site, as sites with poor access may require expensive improvements to make them operate effectively. Proximity to Railways and Waterways These criteria were included to take account of opportunities for sustainable transport and national objectives intended to encourage transport by modes other than road. However it is noted that the 2011 Preferred Approach is luke warm on the prospects and desire for such transport modes where it states the following in paragraph 2.7: there are limitations with alternative transport modes as the rail network is also under pressure and is generally used for transporting material greater distances primarily to import waste (which is something that the WDD is aiming to move away from). The rail network has less potential to handle movements of waste within the Plan area. Transporting waste by water, for example down the Thames out of London has been an alternative to road transport, but this approach has no regard to the need for the facility in that locality. Water transport is generally also more appropriate for transporting waste over longer distances, contrary to the principle of treating and managing waste close to its source in order to reduce transport distances. In any event, a review of the information available in the ELR only revealed a single location (Temple Fields) proximate to a sustainable transport hub. 25! Page 37 of 102

39 Proximity to residential areas Developing a facility proximate to residential areas is likely to require greater investment in mitigation, to the extent where development in some locations may become unviable. Inclusion ensures that any difference in deliverability between sample employment areas proximate to residential areas and those further away can be ascertained. This assessment is supported by work previously undertaken to establish whether an area is proximate to a sensitive land use (taken to be that which involves the housing and care of communities). Proximity to SINC or Local Wildlife Sites This was considered as some additional mitigation may be required before, during and after development of a waste management facility. This will have cost implications and could affect project viability. Proximity to site of historical interest This criterion was included as the proximity of such sites may constrain the development of land. Based on the information in the ELR very few areas were found to be close to such sites. Features not considered Various features were not considered as these had been used in the original shortlisting and so would either be present or absent from all of the areas. Features not considered included the following: Proximity to a Natura 2000 site Presence of a flood zone Availability of land was not considered as this will change over time and particularly over the period of the plan. Availability is linked to turnover of businesses to be tested as part of the survey of industrial property management companies. In addition the size of units or plots of land on an estate was not considered, as it may be that units and plots can be combined where they are currently considered to be too small. Table A1.1 below shows the results of the analysis of the information presented in the ELR. Table A1.1: Results of ELR Analysis Key Features Analysis (sub-category) No. of areas Opportunity/constr aint Size Very small (< 3 hectare) 4 Constraint? Small (3 to 7 hectares) 10 Constraint? Medium (7 to 16 hectares) 18 Opportunity? Large (16 to 50 hectares) 14 Opportunity? Very large (> 50 hectares) 9 Opportunity? Presence of waste Waste use present 23 Opportunity management facility No waste use present 22 Neutral Proximity to main urban areas Within 1 Opportunity Page 38 of 102

40 Proximity to Green Belt Opportunity for Heat Use Access to the strategic highway network Adjacent or within 1 km 34 Opportunity away > 1km away 20 Opportunity Within 15 Constraint Adjacent or within 1 km 13 Constraint away > 1km away 28 Neutral More 12 Opportunity Some 30 Opportunity Less 13 Neutral Good 17 Opportunity Limited 38 Constraint Access to site Good 43 Opportunity Poor 12 Constraint Proximity to < 250m 50 Constraint residential areas > 250m 5 Neutral Proximity to SINC Within 3 Constraint Adjacent or within 1 km 28 Constraint away Proximity to site of Within 2 Constraint historic interest Adjacent or within 1 km away 6 Constraint Table A1.2 below shows the distribution of the sample areas by district compared the total number of areas as well as the areas initially shortlisted in the draft ELR. Table A1.2: Distribution of Industrial Estates by District Found to be Initially Suitable District Sample Total no. of industrial estates Shortlisted areas Basildon Braintree Brentwood Castle Point Chelmsford Colchester Epping Forest Harlow Maldon Rochford Southend on Sea Tendring Uttlesford Page 39 of 102

41 Locations were roughly split between those with fewer locational constraints and more locational opportunities and those with more constraints and fewer opportunities. To account for those areas with a relatively even mix of constraints and opportunities, a third mixed category was created. To ensure a representative selection of areas, five locations were chosen (representing an area from within each of the size bands) from within each of these three categories. Table A1.3 shows the proposed sample areas. Page 40 of 102

42 Table A1.3: Sample Areas Type Proposed Industrial Estate Wrt criteria Size Potentially positive criteria Potential constraints Name Ref. No. Borough Mainly Very Positive Small Beyond 250m from residential areas within a 'Special Landscape Area' Generic Industrial Estate Away from sensitive land uses Good access to strategic highway network Good site access within the Green Belt Mainly Positive Small Proximate to main urban areas within 250m of residential area Industrial Location Good access to strategic highway network Good site access Proximate to railway Mainly Positive Medium Beyond 250m from residential areas Proximate to SINC or (Local Wildlife Sites) Existing waste use Good access to strategic highway network Good site access Mainly Positive Large Proximate to main urban areas within 250m of residential area Mainly Positive Existing waste use Good access to strategic highway network Good site access Very Large Beyond 250m from residential areas Proximate to local wildlife sites Proximate to main urban areas Good access to strategic highway network Good site access within or adjacent to Green Belt South Woodham Ferrers Industrial Estate Ch/4 Chelmsford City Essex Regiment Way Ch/2 Chelmsford City Cranes Farm Ba/4 Basildon Pinnacles and Roydonbury Industrial Estates Har/1 Harlow Page 41 of 102

43 More constraints Very Small Existing waste use Limited access to strategic highway network Beyond 250m from residential areas Poor site access Proximate to SINC or (Local Wildlife Sites) More constraints Small Good site access within 250m of residential area within or adjacent to Green Belt Limited access to strategic highway network Proximate to SINC or (Local Wildlife Sites) More constraints Medium within 250m of residential area within or adjacent to Green Belt Limited access to strategic highway network Poor site access Proximate to SINC or (Local Wildlife Sites) More constraints Large Existing waste use within 250m of residential area Proximate to SINC or (Local Wildlife Proximate to main urban areas Sites) Good access to strategic highway network Poor site access More constraints 11 Mixed Very Large Good access to strategic highway network Good site access within 250m of residential area within or adjacent to Green Belt Area of flood storage Proximate to SINC or (Local Wildlife Sites) Very Small Proximate to main urban areas within 250m of residential area Existing waste use Proximate to SINC or (Local Wildlife Basketworks Site Co/1 Colchester Generic Industrial Estate - - Horizon Business Park Bre/2 Brentwood Freebournes/Swan Vale Industrial Estate Bra/4 Braintree Ford Research & Technical Centre Ba/6 Basildon Hoblongs Ind Est Ut/3 Uttlesford Page 42 of 102

44 Good access to strategic highway network Sites) Good site access 12 Mixed Small Existing waste use within 250m of residential area Morses Lane Industrial Estate Te/3 Tendering Good site access Limited access to strategic highway network 13 Mixed Medium Proximate to main urban areas within 250m of residential area Childerditch Industrial Park Bre/1 Brentwood 14 Mixed Large 15 Mixed Very Large Existing waste use Good access to strategic highway network Good site access part of estate away from residential areas Proximate to main urban areas Existing waste use Good access to strategic highway network within or adjacent to Green Belt within 250m of residential area within or adjacent to Green Belt Wickford Business Centre Ba/7 Basildon Good site access Good access to strategic highway network within or adjacent to Green Belt Temple Fields Har/2 Harlow Proximity to main urban areas Existing waste use Proximate to rail freight sidings Proximity to site of historic interest within 250m of residential area Proximate to SINC or (Local Wildlife Sites) Page 43 of 102

45 Appendix 2 Waste Industry Survey Questionnaire Essex County Council and Southend-on- Sea Borough Council Deliverability of Industrial Locations Project Waste Management Industry Survey, April 2014 Survey Questions (N.B. You do not need to fill this in yourself please [email protected] with a time that is convenient for you to go through this on the telephone) Name: Company: Position: Contact Details ( and telephone number): Please respond to questions based on your own experience and knowledge. We are aware that in some cases you may not be able to offer full responses to every question. Introduction 1. To provide us with an idea of the extent of your experience with developing sites please indicate the types of facility your company operates and the type of location where these facilities are situated (see below): Facility type Broad facility type - Transfer / Recovery - Recycling Industrial estate/area 26 Type of location Urban (built-up) Area 27 Rural Area An area of land that has been specifically developed for use by light and heavy industry. 27 An area of land located within or on the edge of the built up area of a town or city but is not located in an industrial estate/area. 28 An area of land that is away from main settlements; mainly surrounded by open, undeveloped greenfield land including on the edge of small settlements e.g. villages.! facilities FINAL v Page 44 of 102

46 Facility type - Composting - Construction and demolition (C&D) - Treatment - Treatment energy from waste Specific Facilities - Materials recycling/recovery facilities and waste transfer stations - Inert waste recycling facilities - Metal recycling and vehicle dismantling facilities - In-vessel composting facilities - Open windrow composting facilities - Clinical waste treatment facilities - Mechanical biological treatment, autoclaving and anaerobic digestion facilities - Energy from waste, pyrolysis and gasification facilities. Industrial estate/area 26 Type of location Urban (built-up) Area 27 Rural Area 28 Site characteristics 2. This question is about understanding what is important to you when selecting a site. In your experience, how important are the considerations listed in the table below in choosing a site in an industrial location? Please apply a score of 1 to 4 as follows: 1 = The most important factor (within each of the categories i.e. please only score one of the considerations within each category as a 1 ) 2 = An important consideration which would affect decision to develop site 3 = A minor consideration (easily dealt with through design) 4 = Not a consideration at all. Considerations Commercial Considerations Availability of site Score (1 to 4) Comments Available sources of waste (i.e. waste producers) are within easy access Price of land Security of tenure Operational Considerations Proximity to main highway network (A roads and motorways) facilities FINAL v Page 45 of 102

47 Considerations Ease of access to the site (taking into account e.g. any congestion and condition of access roads) Proximity to existing waste management operations Score (1 to 4) Comments Proximity to destinations for outputs from the facility e.g. hardcore for crushing, digestate, compost, recyclate. Added Value Opportunities Ability to co-locate with other waste uses Proximity to possible heat users Proximity to a railhead Proximity to a navigable waterway Possible Development Constraints Proximity to residential areas Proximity to other land uses Proximity to protected habitat Proximity to Green Belt Covenants or restrictions on the land Any other considerations? Please list and score below 3. Appendix 1 includes various types of industrial location of varying sizes and with varying constraints and opportunities. Taking their constraints and opportunities into account, as well as your answers to the question above, which site or sites do you think would be the most easy to develop and where might it not be possible to develop a waste management facility? 4. This question is specifically about economic viability. (a) In your experience, what aspects of a site s location will make development of a waste management facility more or less economically viable? (b) In your experience would this change for different types of waste management facility (see table of uses in question 1) (if at all)? Yes/No. If yes please explain. 5. Are there key barriers to the operations of your waste facility/business? Please consider in terms of: The characteristics of a site s location facilities FINAL v Page 46 of 102

48 The current and future economics of waste management e.g. price paid for recyclate, landfill tax Different waste uses 6. In your experience are any of the waste uses listed in the table in Question 1 not well suited to development in an industrial location? If so which ones and why? Area of land 7. What is the minimum size (area in hectares) of land below which you consider development of a waste management facility would not be economically and/or technically viable? Based on your experience is there an optimum area of land needed for the development of a particular type of waste management facility? (Please see list of types below). Facility type Broad facility type - Transfer - Recycling - Composting - Construction and demolition (C&D) - Treatment - Treatment energy from waste Specific Facilities - Materials recycling/recovery facilities and waste transfer stations - Inert waste recycling facilities - Metal recycling and vehicle dismantling facilities - In-vessel composting facilities - Open windrow composting facilities - Clinical waste treatment facilities - Mechanical biological treatment, autoclaving and anaerobic digestion facilities - Energy from waste, pyrolysis and gasification facilities. Suggested Optimum Area (hectares) Minimum Area (hectares) Comments Other financial considerations 8. How do you decide whether to lease or purchase land and/or premises to operate your waste operation? Does it matter? If leasehold is acceptable is there a minimum lease period? 9. Do you have any other information that you are willing to share about the financial considerations you took into account when developing a waste facility? This could facilities FINAL v Page 47 of 102

49 include operational costs e.g. costs of materials, landfill tax as well as costs of developing a facility (N.B. We guarantee not to disclose this to third parties or make direct reference to it in any published reports.) General considerations 10. In your experience have the local Councils created barriers to development of waste facilities? Yes/No If yes how do you think they might be able to remove them? Also, is there any way you think the Councils could help facilitate development of this nature? 11. Would you be prepared to take part in a Council run workshop intended to discuss the issues concerning the development of waste facilities on industrial estates? Appendix 1 (of waste management questionnaire) Schematics of the representative sample industrial locations being considered The following descriptions and schematic diagrams represent the main different types of industrial location in Essex and Southend-on-Sea. They are intended to represent the following key features: - Size - Potential constraints to development e.g. proximity to residential areas - Potential opportunities e.g. good road connections, access to a site These schematic diagrams have been prepared to inform a survey of waste industry and industrial property management professionals concerning the deliverability of industrial locations for waste management facilities. A total of 15 different types of location have been identified as providing a representative sample of industrial locations which might be suitable for waste management development. The 15 locations have been split into the following three categories: - Category A predominantly positive features with few constraints - Category B a reasonably balanced mix of opportunities and constraints - Category C more constrained with fewer positive features Within each category five different size of industrial location are considered as follows: 1. Very small: Less than 3 hectares 2. Small: Between 3 and 7 hectares 3. Medium: Between 7 and 16 hectares 4. Large: Between 17 and 50 hectares 5. Very large: More than 50 hectares To assist visualisation a full sized football pitch has an area of just over 1 hectare. facilities FINAL v Page 48 of 102