2.0 NEED FOR THE DEVELOPMENT & CONSIDERATION OF ALTERNATIVES

2.0 NEED FOR THE DEVELOPMENT & CONSIDERATION OF ALTERNATIVES 2.1 This chapter outlines how the need for this proposed development has been established, where planning policy supports it, the alternative methods of provision to meet this identified need have been considered, and how the final design was determined GENERAL NEED FOR THE DEVELOPMENT 2.2 There is a recognised need at international, national, regional and local level that waste generated by both commercial and municipal uses should be dealt with in the most sustainable way possible. 2.3 The Climate Change Convention and its Kyoto Protocol (December 1997) set a legally binding targets for industrialised countries to reduce collective emissions of six greenhouse gases compared to 1990 baseline levels by 5.2% between 2008 and 2012. National limitations range from 8% reductions for the European Union (EU) to 0% for Russia, and permitted increases for Australia and Iceland. Carbon Dioxide (CO2) has the biggest impact of the six greenhouse gases, and therefore reduction strategies for this gas are particularly important. 2.4 Part of reduction strategies often include minimising the generation of wastes and improving methods for its disposal, particularly relevant are strategies that include the recovery of energy from waste which mean that pressure for CO2 producing energy generation (i.e. natural gas and coal) is minimised. 2.5 At the European level the European Union (EU) Waste Framework Directive establishes the principle of member states obligation to: Handle waste that does not have a negative impact on the environment or human health; The requirement to apply the waste hierarchy in accordance with the polluter pays principle; and Costs of disposing of waste should be borne by the producer or holder of that waste. 2.6 At a national level Planning Policy 10: Planning for Sustainable Waste Management sets out the goals for achieving this succinctly in its first section: The overall objective of Government policy on waste, as set out in the strategy for sustainable development, is to protect human health and the environment by producing less waste and by using it as a resource wherever possible. By more sustainable waste Page 8

management, moving the management of waste up the waste hierarchy of prevention, preparing for reuse, recycling, other recovery, and disposing only as a last resort, the Government aims to break the link between economic growth and the environmental impact of waste. This means a step-change in the way waste is handled and significant new investment in waste management facilities. The planning system is pivotal to the adequate and timely provision of the new facilities that will be needed. 2.7 Therefore it is clear that new modern waste facilities that utilise recycling, reuse or recovery as opposed to disposal are needed to fulfil the objective of producing less waste and utilising the waste that is unavoidably produced as a valued resource. 2.8 Development such as that envisaged for this site is acutely needed in BANES in particular because although steps have been taken to reduce the volume of waste that is produced within the authorities boundaries it still disposes of a significant volume of waste each year to landfill, some of which is transported outside of the authorities boundaries which is even more unsustainable as a long term waste strategy. Specific Need identified in Planning Policy 2.9 In 2011 a Joint Waste Core Strategy (JWCS) was adopted by the constituent authorities of the West of England sub-region. This included BANES, Bristol, North Somerset and South Gloucestershire Councils. 2.10 In preparing this document the constituent authorities and their advisors undertook a thorough analysis of the waste streams that were generated within the sub-region and how these should be dealt with as part of the plan period which was designed to run until 2026. This Strategy applied the principles of the waste hierarchy of prevention; reuse; recycling; recovery; and disposal. 2.11 The JWCS was subject to sustainability appraisal as an integral part of its production and this looked at, among other things, the overall strategy put forward and the specific sites advocated for allocation as waste sites to meet the identified needs for waste disposal and recovery. 2.12 Specifically relevant to the proposed development is the fact that the JWCS identified a need to provide residual waste treatment facilities to recover resources from waste. The JWCS assessed the minimum capacity requirements to deal with such waste and determined that sites to deliver a minimum capacity of 800,000 tonnes per annum (tpa) were required and Page 9

further identified that delivering this was central to the achievement of JWCS policy and objectives (Para 6.8.4 of the JWCS). 2.13 The JWCS further analysed the need for each of the constituent authorities and as part of policy 5: Residual Waste Treatment Facilities Locations. This policy defines an indicative requirement of 150,000 tpa of residual waste treatment capacity for an area identified as Zone C, which broadly corresponds with the administrative area of BANES. 2.14 In order to deliver the capacity requirements identified the JWCS allocates sites suitable for the development for residual waste treatment facilities. The whole of the site currently occupied by the two semi detached cottages and the WRB operation is allocated as part of Policy 5 of the JWCS referred to as: Former Fuller s Earth Works, Fosseway. CONSIDERATION OF ALTERNATIVES 2.15 The EIA Directive 85/337/EEC as amended by 97/11/EC2 (and associated Regulations) requires that an ES should provide: An outline of the main alternatives studied by the developer and an indication of the main reasons for his choice, taking into account the environmental effects. 2.16 As we have set out the JWCS has already studied the alternatives of differing spatial strategies and alternative sites for delivering residual waste and general waste capacity to meet the assessed requirements until 2026. This process included sustainability appraisal of alternatives including specific sites. 2.17 In relation to the delivery of sufficient residual waste capacity for Zone C, namely 150,000 tpa, the JWCS identifies two sites, namely the existing WRB Site and a site at Broadmead Lane, Keynsham. In order to deliver the required waste treatment capacity it is anticipated that both sites will be required. 2.18 Therefore the assessment of alternatives should focus on the options available for delivering the required treatment capacity on the application site and not at alternative spatial options, because no such option exists due to the lack of other allocated site s within Zone C. 2.19 The main alternatives are described, for the purposes of this report, as those that will meet the identified capacity requirements of the JWCS whilst also potentially meeting operational objectives. Page 10

2.20 Accordingly in developing the proposals the Applicant has considered alternative uses for the site, different layouts and different waste technologies. These are summarised below. The no-development option; Alternative site uses; Alternative waste technologies; and Design alternatives. The no-development option 2.21 As we have set out above, there is a strong international and national desire to minimise the impact of waste on the environment. Integral to this is the application of the waste hierarchy, a key component of which involves the recovery of resources from waste, whether it be energy, minerals or any other valued material. 2.22 The JWCS has applied these principles and assessed the need for residual waste and other waste treatment facilities in the joint strategy area, which includes BANES. After robust assessment a minimum capacity target for residual waste treatment facilities has been set and potential sites to accommodate this have been sustainability tested. As part of this process the application site has been selected in order to meet this minimum capacity requirement. 2.23 Commercial demand for residual waste treatment facilities exists and therefore the 'no development option' is not a realistic alternative as it would mean that the JWCS fails to meet its targets in the most sustainable way it identifies, waste would continue to be disposed of in an unsustainable way (i.e. landfill) and important resources such as energy would not be extracted from waste thereby increasing the demand for energy from other sources, some of which are not as sustainable. 2.24 In summary a no-development option would miss the opportunity of the site contributing to greener energy, reduction of waste to landfill, and sustainable development in a local and regional context. Accordingly this option has been discounted as it is not sustainable or environmentally responsible. Page 11

Alternative Site Uses 2.25 Over the last few years the applicant has looked at alternative design options for the site which we will go on to discuss. As part of this process alternative site uses were considered. 2.26 As part of the pre-application discussions undertaken with BANES the potential to collocate non residual waste uses with residual waste facilities was discussed and BANES confirmed this would be acceptable if synergies could be demonstrated and such uses could be accommodated not at the expenses of residual waste capacity. 2.27 In light of these discussions, a proposal to collocate a Household Waste Recycling Centre (HWRC) on the site was considered because a significant proportion of the material collected at such sites would be suitable for further processing into a valued material. 2.28 After putting this option to the council the HWRC proposal was discounted because: The council considered that adding this resulted in too intense a development for the site which may result in adverse visual impact; BANES s waste department were considering other locations for the HWRC to replace their existing Midland Road facility and the provision of a HWRC on the application site would be unlikely to occur without the council s waste management department s support; Concerns were raised regarding its location relative to serving the needs of residents located in the northern part of Bath and how this could make travel to the site difficult for such residents; and As the residual waste proposals developed it was apparent that outdoor storage capacity would be needed and the logical place for this was in the area which was at that time considered for the HWRC. 2.29 No other alternative uses were considered in detail as synergies between residual waste and other suitable waste uses (composting for example) could be identified. Alternative waste technologies 2.30 As set out in the JWCS (see para 6.9.1) the expectations of its policy relating to residual waste facilities is not technology specific. This refers to the recovery of energy from waste and not the sorting and processing of waste. Page 12

2.31 Each site that was allocated in the JWCS was subject to appraisal and the results of this were set out in Revised Detailed Site Assessment Report v3 (September 2009). This assessment concluded that the analysis undertaken at that stage had not been able to conclude that thermal treatment facilities would not have a significant effect on nearby European habitat sites (SSSI s, SAC s and RAMSARs). Accordingly incineration technologies were discounted at this stage, although it was concluded that such uses may be possible in the future after further analysis of this issue had been undertaken. Therefore, as AD technology had been identified as an alternative option for residual waste disposal and recovery it was decided to discount incineration technologies at this time. 2.32 Open Windrow composting would dispose of green waste but does not recover any energy from that process, therefore it would be questioned whether such a use complies with the sites allocation for residual waste facilities. Therefore this option was discounted. 2.33 In-vessel composting requires air to be passed through the system and therefore generates significantly more odour than the Anaerobic Digestion (AD) processes. It also requires additional energy inputs such as additional heating/cooling to maintain the optimum temperature or to blow additional oxygen through the compost. The AD process generates enough heat and power both to maintain itself and to export surplus electricity and heat. The production of energy and a nutrient rich fertiliser for crop spreading via the AD process is considered to be of much greater benefit to the area and environment in general than compost which would be provided via in-vessel composting. 2.34 In relation to the Materials Recovery Facility (MRF) this is considered to be operationally essential if the site is to be developed for a residual waste treatment plant, otherwise segregated waste streams could only be accepted at the site which would mean sorting and processing of waste would have to occur off site. This would be an unsustainable approach to waste management as waste would have to be transported form source to a processing MRF and then onto the application site, if the application site includes a MRF then only one journey is required and synergies between the various processes proposed can occur. Design alternatives 2.35 Although the scale and general layout of the development is driven by operational factors which limit the alternatives in this regard a number of design alternatives were considered which primarily included: Page 13

The reuse of the existing buildings located on the allocation site; The accommodation of a HWRC on the site; Providing more buildings for internal storage; and Not setting main buildings and structures into the existing ground level. 2.36 In respect to the first option this was discounted because the existing buildings are primarily historic (some dating from pre-1910) and their size and internal layouts do not lend themselves to reuse as a modern MRF or AD Plant because such uses require large open and level internal spaces, none of which are provided by the existing buildings that are located on site. 2.37 Furthermore, these buildings are currently used for waste processing already and their use as such fulfils a key role in delivering sufficient waste processing capacity for the Bath area. Therefore, the reuse of the existing buildings was discounted and this part of the allocation site was excluded from the application because it is not required to deliver modern residual waste processing capacity. 2.38 With reference to alternative 2 the design that accommodated a HWRC was discounted for the reasons already set out. 2.39 Alternative 3 included more built development on the existing site, namely two storage buildings on the site s northern and north-western boundaries. This was discussed with representatives of BANES s and the internal consultant team and it was thought that the provision of large scale buildings in these locations may not be appropriate in light of the policy requirement to minimise the impact of development on the Green Belt. It was also identified that outside rather than internal storage would be suitable to meet operational need and the removal of the HWRC provided an area suitable for outside storage. 2.40 In respect to alternative 4 the first drafts of plans for the site assumed that buildings and structures would be place do the site at existing ground level. After review it was decided to set the buildings into the ground where operationally possible to minimise landscape impact and this has now been done as part of the finalised proposals. This has been incorporated into the preferred option. Page 14

THE PREFERRED OPTION/CONCLUSION 2.41 It has been identified that the proposed development of the site for residual waste processing facilities is clearly needed in a wide context. This has been recognised at a regional level an accordingly the application site has been allocated for such a use in the JWCS which plans for waste management until 2026. 2.42 The JWCS was underpinned by the collection of a robust evidence base and sustainability appraisal, which included the assessment of all of the sites proposed for allocation. This included the application site which is needed to fulfil the aims of the JWCS. 2.43 No development or alternative site options should therefore be discounted swiftly because the sustainability analysis of these has already been undertaken as part of the JWCS. 2.44 The proposed use of the site which combines a MRF with both an AD plant and Refuse Derived Fuel (RDF) line will assist greatly in meeting both the JWCS and national targets for recovering resources from waste. The current development mix proposed for the site allows waste to be transported in the most sustainable way and synergies between processes can further enhance the value that that site adds to the waste accepted and the energy and resources it extracts from this waste. 2.45 Alternative site uses and designs have been explored as discussed but it is considered that the current proposals represent the optimal use of the application site. 2.46 Therefore the preferred option for the application site represents the most sustainable use of the site and will minimise the use of non-renewable resources. REFERENCES West of England Joint Waste Core Strategy (March 2011) (JWCS) Page 15