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CONTENTS Executive Summary 1. Introduction 2. The context and concept for a strategic BPEO assessment 3. Identification of the BPEO 4. Conclusions APPENDIX A – Waste Planning Policy Review Adams Hendry Excavated Material and Waste Management Strategy : Volume 2 Best Practicable Environmental Option 1 2 3 4 14 25 27

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Page 1: CONTENTS74f85f59f39b887b696f-ab656259048fb93837ecc0ecbcf0c557.r23.cf3.rackcdn.… · 2015-01-27 · to identify the BPEO for the management of waste that is practicable in foreseeable

CONTENTS

Executive Summary

1. Introduction

2. The context and concept for a strategic BPEO assessment

3. Identification of the BPEO

4. Conclusions

APPENDIX A – Waste Planning Policy Review

Adams Hendry Excavated Material and Waste Management Strategy : Volume 2 Best Practicable Environmental Option 1

2

3

4

14

25

27

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Adams Hendry Excavated Material and Waste Management Strategy : Volume 2 Best Practicable Environmental Option 2

SUMMARY

Crossrail will use the Best Practicable EnvironmentalOption (BPEO) to deal with surplus material (excavatedmaterials, construction and demolition waste) arisingduring construction of the project. The BPEO isdefined as “the outcome of a systematic andconsultative decision making procedure whichemphasises the protection and conservation of theenvironment across land, air and water. The BPEOprocedure establishes, for a given set of objectives, theoption that provides the most benefits or the leastdamage to the environment as a whole, at acceptablecost, in the long term as well as the short term.” (RCEP1988)1

The Government’s Waste Strategy (DETR 2000)2

identifies three considerations that are important inidentifying the BPEO in a particular case.

l The Waste Hierarchy, from waste reduction as the most preferred option, through re-use and recovery,to disposal as the last resort.

l The Proximity Principle, which encourages the useof facilities for waste disposal that are as close to the place of origin as possible, to reduce the environmental impacts that arise from transportingthe waste.

l Self-sufficiency, ie the view that most waste shouldbe treated or disposed of within the region in whichit is produced.

The BPEO appraisal of the Crossrail project concludesthat an integrated strategy for managing wasterepresents the best way of dealing with the surplusmaterials. The strategy will involve waste minimisation,beneficial use of waste (including restoration of landfillsites) and, as a last resort, landfill. The results of theBPEO are discussed below. The strategy is consistentwith the requirements of the London Plan (GLA 2004)and with other relevant planning policy.

1 Royal Commission on Environmental Pollution (1988) best Practicable Environmental Option, Twelfth Report2 DETR (2000) Waste Strategy 2000 for England and Wales. Parts 1 and 2 Cm 4693

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1 INTRODUCTION

1.1 This Report summarises the strategicassessment of the Best Practical Environmental Option(BPEO) for dealing with the waste that will arise duringthe construction of Crossrail, largely as a result oftunnelling. The Report comprises Volume 2 of theStrategic Technical Report (STR) dealing with surplusmaterials3. The assessment has been undertaken byAdams Hendry Consulting Ltd.

1.2 Crossrail construction will generate substantialvolumes of surplus material (excavated material,construction and demolition waste) in a denselydeveloped area. Tunnelling waste will be movedrapidly and continuously away from works sites, andthere are very few opportunities to use the surplusmaterial, which will largely be London Clay, elsewhereas part of the Crossrail project.

1.3 The Report begins by defining the BPEOconcept for the purpose of the assessment, explaininghow it has been applied to the Crossrail projectfollowing government guidance on strategic planningfor sustainable waste management.

1.4 Crossrail surplus material will not be producedfor some years and spatial plans for the surroundingarea include proposals for significant physical changein that period, for example in the Isle of Dogs andThames Gateway. Were London to host the 2012Olympics, further regeneration opportunities mightemerge. This means that there is inevitably someuncertainty about the precise land use and social andenvironmental context that will apply at the time thatCrossrail will be generating waste. There is also timeto continue to refine the potential for beneficial use andit is likely that practical opportunities that are notcurrently known will emerge.

1.5 However, it would not be prudent to planCrossrail on the basis that future opportunities forbeneficial use will become available. It is necessaryto identify the BPEO for the management of waste thatis practicable in foreseeable circumstances,acknowledging that opportunities to use the wastecreated for beneficial purposes will continue to bevigorously pursued.

1.6 Waste Strategy 2000 recommends a LifeCycle Assessment (LCA)4 approach to suchassessments. These build in environmental, social andeconomic costs of the various options. TheEnvironment Agency tool WISARD5 is recognised as ameans of carrying out LCA, but it has limitations,particularly lack of flexibility.

1.7 In these circumstances, it is consideredappropriate to use a qualitative approach to define theBPEO, rather a model such as WISARD.

1.8 A qualitative approach is more flexible andpragmatic and can better reflect the particularcircumstances in which the waste material will begenerated, the nature of the material itself, and thetimescales over which it will be produced.

1.9 The Report sets out:

l the background to the concept of BPEO and the need to apply strategic principles

l guidance and the appropriate methodologyl objectives and indicators to be applied to this

Projectl the outcomes of the BPEO Assessment for the

Project.

Adams Hendry Excavated Material and Waste Management Strategy : Volume 2 Best Practicable Environmental Option 3

3 Excavated Materials and Waste Management Strategy4 Can provide a basis for making strategic decisions on the ways in which

wastes in a given set of circumstances can be most effectively managed, in line with principles of BPEO, the waste hierarchy and the proximity principle

5 Environment Agency tool for carrying out Life Cycle Assessment

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2 THE CONTEXT AND CONCEPT FOR ASTRATEGIC BPEO ASSESSMENT

2.1 The context of the Crossrail proposals and thescale of the surplus materials is such that it spans alarge geographical area and a number of regions. It isnecessary to consider European, national and localpolicies by way of context. Appendix A sets out thelocal planning context along the route of the project ingreater detail and determines where the proposals:

l accord with policyl are potentially contrary to policyl are neutral to policy

Matters relating to European and National policycontext are dealt with in the main Report.

European Context

2.2 The European and national policy context forwaste management is of key importance. TheEuropean Union has adopted a number of Directivesaimed at waste reduction and dealing with waste in amore sustainable manner.

2.3 The Waste Framework Directive (1975,amended 1991)6 has largely been implemented in theUK through part II of the EPA 19907 and the WasteManagement Licensing Regulations 1994.8 TheFramework Directive notes the importance of:

“ensuring that waste is recovered or disposed ofwithout danger to human health and without usingprocesses which could harm the environment, and, inparticular, withoutl risk to water, air, soil, plants or animals;l causing noise or odour pollution;l adversely affecting the countryside or places of

special interest;establishing an integrated and adequate network ofwaste disposal installations, taking account of the bestavailable technology and techniques”

2.4 “The Community Strategy for WasteManagement” (1989 updated 1996)9 sets out ahierarchy for the management of waste. The emphasisof the hierarchy is waste minimisation, followed by

recovery of value and finally, disposal as a last resort.These were reflected in the amendment to the WasteFramework Directive. The strategy contains nomeasures to improve performance in waste reductionbut introduces the concept of targets. Producerresponsibility10 is a major theme of the strategy and isof vital importance in the Crossrail project given thequantities of material involved and the potentialimpacts arising from materials handling.

2.5 The 1999 Landfill Directive (99/31/EC)11

requires Member States to draw up strategies for areduction in the quantity of “bio-degradable municipalsolid waste” disposed of to landfill. The UK has toreduce the quantity of such material being landfilled to35% of the 1995 figure by 2020.

UK Waste Strategy

2.6 In May 2000, the government publishedWaste Strategy 2000 (the Waste Strategy) which setsout a vision for sustainable waste management inEngland and Wales to 2020. The Waste Strategyprovides an overview of waste policy and sets targetsfor recycling and recovery of value from householdwaste.

2.7 The Waste Strategy sets a target to reduce thequantity of industrial and commercial waste landfilledto 85% of 1998 levels. The strategy states that inmeeting this target focus must be on recovering valueand reducing environmental impact. These targetscoincide with the aims of a number of otherGovernment Policy documents including itssustainable development strategy.

2.8 At present landfill still remains the principalmethod of dealing with waste and it is estimated thatnearly 60% of waste produced by industry, commerceand households is landfilled.

2.9 Together with guidance to local authorities onthe siting of facilities, the Waste Strategy implementsfor England and Wales the requirements of theFramework Directive and requires member states todraw up strategies for dealing with waste diverted fromlandfill.

Adams Hendry Excavated Material and Waste Management Strategy : Volume 2 Best Practicable Environmental Option 4

6 75/442/EEC Framework directive on waste, amended by 91/156/EEC7 Environmental Protection Act 1990 (UK)8 Waste Management Licensing Regulations 1994 (SI No 1056) (UK)9 Community Strategy for Waste Management 1989, amended 1996 (EC)

10 Where producers and others involved in the production of waste take

greater responsibility for management11 Council Directive 99/31/EC of 26 April 1999 on the landfill of waste

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2.10 The Waste Strategy emphasises the need to“make good decisions” and in doing so accepts thatthe right way to treat a particular waste stream cannotbe determined simply. The objective is to choose theBPEO in each case.

2.11 The Strategy encourages an integratedapproach to waste management.

The London Plan – February 200412 – Planning forwaste

2.12 In order to meet the national policy aim ofregional self-sufficiency, the Mayor has set thefollowing targets (as contained in Policy 4A.113 ) for allwaste generated in London to be managed withinLondon:-

75% (16 million tonnes) by 201080% (19 million tonnes) by 201585% (22.5 million tonnes) by 2020

2.13 As well as the London Plan the Mayor is alsorequired by law to produce other strategies for Londonincluding the Municipal Waste Management Strategy(see paragraph 2.20) 14, published in September 2003:

2.14 Policy 4A.215 sets out guidelines for councilsto shape Unitary Development Plan (UDP) policies inrelation to waste. The policy asserts the ProximityPrinciple for all waste streams. It also seeks to ensurethat the BPEO is applied to all disposal solutions, andsupports treatment facilities to recover value fromresidual waste. Where waste cannot be dealt withlocally, UDPs should promote waste facilities that haveaccess to river or rail transport.

2.15 London currently produces 17 million tonnesof waste every year and this is forecast to rise to 26.5million tonnes in 202016. Table 1 shows the divisionbetween the various types of waste by totals producedand disposal method.17

2.16 Table 1 highlights that the quantity of surplusmaterial arising from Crossrail is equivalent to over 12months of construction and demolition waste for thewhole of London in 2001. Table 1 also indicates that81% of construction and demolition waste wasrecycled. As at 2001 London managed 60% of its ownwaste, taking account of total waste arisings.

2.17 The London Plan recognises the importanceof collaborative working between the LondonBoroughs. Work is ongoing with the South EastEngland regional authorities and East of Englandregional authorities to co-ordinate strategic wastemanagement across the three regions and, inparticular, to reduce London’s dependence on landfilldisposal in these regions. The London Plan recognisesthe need to become more self-sufficient in its treatmentof waste and that planning for waste in Londondepends on accurate data and forecasts.

2.18 While these are laudable objectives theimplications of a development such as Crossrail arevast and the arisings are not accounted for in theoverall figures. Taking into account previous arisingsand quantities of waste dealt with in London it is clearthat the volumes of material arising cannot beaccommodated wholly within the existing infrastructureor within the confines of London. The implications ofthe arisings are such that existing waste managementcapacity will be used up potentially resulting in greaterdisturbance from material arising elsewhere beingforced to travel greater distances.

Adams Hendry Excavated Material and Waste Management Strategy : Volume 2 Best Practicable Environmental Option 5

12 Mayor of London, February 2004 The London Plan – Spatial

Development Strategy for Greater London GLA13 Ibid page 15614 Mayor of London, September 2003 Re-thinking Rubbish in London –

Municipal waste management strategy GLA

15 Ibid page 15716 Enviros 2003 Technical Assessment for Waste Management in London17 Page 158 The London Plan

Sources of Waste

Municipal solid wasteCommercial /industrialConstruction /demolitionSpecial waste

Million tonnesper annum4.46.46.10.4

% Disposed atlandfill7350266

% Recycled

833817

% Other

0151726

% Incinerated

19201

Source: London Plan - February 2004

Table 1 Total waste produced and disposal method, London 2001

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2.19 Although the Plan does not specificallymention policies relating to the transport of waste, itdoes highlight the importance of using the RiverThames for transportation (Policy 4C.14), and thesafeguarding of wharves for freight related purposes(Policy 4C.15). Consideration of the transportation ofthe surplus material arising from the Crossrail projectand the resultant environmental implications have ahigh priority in the development of a materials handlingstrategy.

2.20 Crossrail has considered the strategy formaterials handling as an important part of the projectdevelopment and this has allowed the implications ofmaterials handling to be assessed and properjudgements to be taken regarding how and where thematerials will be handled so as to minimise policycontravention, impacts on existing infrastructure andmaximise benefits through development of a strategyfounded on the principles of the waste hierarchy andbeneficial use.

Rethinking Rubbish in LondonThe Mayor’s Municipal Waste ManagementStrategy

2.21 The Mayor’s Strategy only deals withmunicipal waste and sets out a framework foralternative means of dealing with waste in the capital.Although the waste arising as part of the CrossrailProject is not municipal waste, the underlyingsustainability principles are relevant.

2.22 London produces around 17 million tonnes ofwaste per year of which 4.4 million tonnes is collectedby Councils, mostly from households and somebusinesses. If waste continues to grow at its currentrate, there will be twice as much to deal with by 2020.

2.23 The vast majority of London’s waste iscurrently disposed of by landfilling. In 2001/02 landfillaccounted for 73% of municipal waste. Only 8% ofLondon’s waste is put to good uses through recyclingschemes or composting.

2.24 At present, London’s capacity for dealing withmunicipal and other waste is small with only a thirdbeing dealt with within the City. Exporting waste isheavily relied upon for disposal. London currentlyexports by rail to Bedfordshire and Buckinghamshire,by barge along the River Thames to Essex and by road

to sites in Bedfordshire, Buckinghamshire,Cambridgeshire, east London, Essex, Oxfordshire andWest Sussex.

Transport of waste

2.25 2.75 million tonnes of London’s municipalwaste is already transported outside the capital fordisposal. Approximately 27% is transported by barge,27% by rail and the rest by road. Currently on average,2,500 tonnes of municipal waste are loaded ontobarges and tugged to Essex. One barge carriesapproximately 300 tonnes of waste.

2.26 The overall transport objective containedwithin the Strategy for Municipal Waste is to reduce theamount of environmentally damaging emissions fromtransport. The Mayor is committed, in line with theprinciples of BPEO, to minimise the environmentalimpact of the transportation of waste and recyclablesin London (Policy 40). Policy 88 states that the Mayorwill encourage the use of sustainable modes oftransport, particularly rail, river and canal. Wherematerial cannot be managed locally, wharves and railwaste transfer stations that are, or can be made viablefor the movement of recyclables or residual wasteshould be made viable through the London Plan.Furthermore, as stated in Policy 91, the Mayor willencourage waste authorities to minimise theenvironmental impact of waste transportation, byappropriate vehicle specifications, routeing andoperating practices.

Landfill

2.27 The general thrust of the plan is to reduce theamount of waste being sent to landfill in line with theLandfill Directive.

2.28 In general, the policy towards landfill in theStrategy is to reduce the amount of London’s wastebeing exported, however the Mayor recognises thatthere will still be a role for landfill in the disposal ofresidual waste resulting from recycling, composting,pre-treatment and recovery where landfill representsthe BPEO.

2.29 Although the materials arising from Crossrailare predominantly inert in nature, the volumes andtimescale over which they arise are such that theseobjectives are relevant in terms of considering the bestmethod of handling. In particular the transportationobjectives will have a bearing.

Adams Hendry Excavated Material and Waste Management Strategy : Volume 2 Best Practicable Environmental Option 6

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STRATEGIC WASTE MANAGEMENT18

ASSESSMENT 2000: LONDON

2.30 This document was produced by theEnvironment Agency and sets out a largely factualsummary of the types of waste generated in Londonand their means of disposal in the late 1990s. Thepurpose of the information is to inform the productionof regional and local waste management strategiesand for the purposes of this BPEO assessmentprovides additional background information in relationto the main types of material arising from the projectand historical means of handling such arisings from theLondon area.

2.31 The majority of London’s waste (80%) wassent to licensed sites in neighbouring regions fordisposal or recovery. At that time London had only 2landfill sites licensed to take biodegradable household,industrial and commercial waste. London had a totalof 309 licensed waste management facilities acceptingwaste during 1998-99. (See Table 2).

Table 2 : Waste Management Facilities in London1998-99

Source: Strategic Waste Assessment 2000: London (EA)

2.32 During the 12-month period (1998-1999)London produced 7.09m tonnes of industrial andcommercial waste. London produced just over 6% ofinert /construction and demolition wastes and

contaminated general waste produced in England(Table 3).

2.33 Waste management options used for industrialand commercial wastes were predominately landfill(50%) and recycling (33%).

2.34 84% of London’s total industrial andcommercial waste was exported outside of the Londonarea for disposal or recovery. The export of wastebetween areas of London was common e.g. betweennorth and south London areas, though the mainmovement of waste was to disposal and handlingfacilities outside the Greater London area.

2.35 Approximately 12m tonnes of waste washandled at waste management facilities in London in1998/99 with only about 2.5m tonnes (21% ofLondon’s waste) being finally dealt with in the Londonregion. The balance was exported for furtherprocessing or final disposal. Approximately 50% ofthis was inert/ waste.

2.36 ‘Open gate’19 landfill sites include siteslicensed to accept special waste, household, industrialand commercial waste and inert/C&D waste. Morethan 80% of waste disposed to landfill in London wasin the East London sub-region, where 2m tonnes ofwaste were deposited – divided between municipal(25%), industrial (40%) and commercial waste (35%).West London had the only other significant landfill input(16% of total) and was almost entirely inert/C&D waste.While it is not proposed to use such facilities the figuresshow where most of the waste has historically beendealt with (Table 4).

2.37 The EA undertook a survey in 1998/99 toidentify the capacity remaining at existing landfill sitesin London. This was produced to help assess ‘need’within the planning process. Table 5 below showsamount of available space within existing licensedlandfill sites in 1998/99.

Adams Hendry Excavated Material and Waste Management Strategy : Volume 2 Best Practicable Environmental Option 7

Waste Management Facilities in London

Active landfill sites

Landfills accepting only inert

Landfills accepting household, industrial and

commercial waste

Transfer stations (inc civic amenity sites)

Treatment including composting stations

Total

Number

34

32

2

199

76

343

Waste Type

Inert/ C&DContaminatedgeneral

Industry (000 tonnes)104154

Commerce(000 tonnes)48114

Total(000 tonnes)152268

% England &Wales6.46.7

Source: Strategic Waste Assessment 2000: London (EA)

Table 3 : Quantities of Inert, Construction and Demolition (C&D) and Contaminated Waste Arising

18 Environment Agency, Strategic Waste Management Assessment 2000 :

London

19 Those sites not bound by specific contracts

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2.38 London had almost 21m cubic metres ofremaining landfill voidspace at the time of the survey.The majority of the capacity was specifically identifiedas for household and commercial and industrial waste.

2.39 Five of the seven sub-regions within Londonhad no landfill capacity for biodegradable waste andcapacity for other wastes was limited (Table 6).

2.40 The statistics within the Strategic Assessmentserve to show current pressures and constraints withinthe London area. The impact of the material arisingfrom Crossrail has the potential to increase the burdenon an already inadequate supply of facilities. Thisrequires consideration as part of the overall strategicBPEO assessment.

Adams Hendry Excavated Material and Waste Management Strategy : Volume 2 Best Practicable Environmental Option 8

Waste deposited in open-gate landfills:

Western Riverside*

East London

West London

North London

South London

South East London

Central London

Total

Inert/C&D

(000 tonnes)

0

829

335

0

1

32

0

1,197

Table 4 : Inert /C&D Waste Deposited in OpenGate Landfills

Table 5: Remaining Capacity at Licensed Landfills in London on 1/4/99 (000’s cubic metres)

Source: Strategic Waste Assessment 2000: London (EA)* Seven sub regions within London

Source: Strategic Waste Assessment 2000: London (EA)

Disposal capacity in open-

gate landfills:

Western Riverside

East London

West London

North London

South London

South East London

Central London

Total

Disposal capacity in

restricted-user landfills:

Western Riverside

East London

West London

North London

South London

South East London

Central London

Total

Non bio-

degradable

0

1,720

2,229

0

0

0

0

3,949

0

0

0

0

0

0

0

0

Household,

industrial and

commercial

0

10,900

170

0

4,233

0

0

15,303

0

0

0

0

0

1,100

0

1,100

Co-disposal

(all wastes)

0

358

0

0

0

0

0

358

0

0

0

0

0

0

0

0

Total

0

12,978

2,399

0

4,233

0

0

19,610

0

0

0

0

0

1,100

0

1,100

% England

and Wales

2.5%

0.1%

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South East England Regional Assembly –Proposed Alterations to regional Planningguidance, South East – Regional WasteManagement Strategy “No Time to Waste” (March2004)

2.41 While London has its own planning frameworkand lies outside the south east planning area, thecontent of the waste management strategy isconsidered important given the fact that much ofLondon’s waste is exported to the region for disposal.The overarching policy objectives of No Time To Wastereflect those iterated in the UK Waste Strategyguidance ‘Waste Strategy 2000’. In summary they areas follows:

l waste minimisationl reuse/Recyclingl protection of the environment

2.42 No Time to Waste highlights the wastehierarchy with the least desired disposal option beingto landfill. The emphasis is firmly placed on diversionfrom landfill and recycling and composting.

2.43 Policy guidance therefore reflects this switchaway from landfilling and the plan highlights the needfor policies which reflect increased waste minimisation;recycling/composting; recovery/diversion from landfill;and last of all, landfill. Other principles such as self-sufficiency (dealing with waste locally to its production)are also key considerations. Initiatives such as marketdevelopment can also contribute to the reuse/recycleelements. The strategy also incorporates a positivepolicy for inter-regional co-operation.

2.44 Transport is also a crucially important issue,given the volumes of traffic that waste managementgenerates. The proximity principle and the principlesset out in the Regional Transport Strategy are key tomanaging transport impacts.

2.45 The Strategy contains 20 policies relating towaste management. Policy W1 seeks a reduction inthe growth of all waste. Policy W2 emphasises theneed for development plans to require design andconstruction which minimises waste production andassociated impacts through the re-use of constructionand demolition materials. Best practice in design andconstruction for waste minimisation and recyclingshould be employed.

2.46 Policy W3 sets out the Strategy’s approach tolandfill and states that waste authorities and wastemanagement companies should ensure that enoughcapacity is available for waste arisings in the region’sboundaries. Provision for London’s exports should belimited to landfill within the provisions of the LandfillDirective targets (for reducing waste delivered tolandfill). Provision for recovery and processing capacityfor London’s waste should only be made where thereis a proven need, with demonstrable benefits to theregion including improving the viability of recovery andreprocessing activity within the region, and where thisis consistent with the proximity principle.

2.47 Policy W4 asserts the requirement to meetwaste needs within Waste Planning Authorityboundaries. A degree of flexibility should be applied inrelation to waste movements and the proximityprinciple in identifying the BPEO. Capacity should beprovided for waste from London.

2.48 Policy W14 highlights the Strategy’s aim ofhigh quality restoration of landfills. The excavatedmaterial from the project could be used in order tofacilitate this, on a number of sites.

2.49 The overall vision of the Strategy is to reducethe amount of waste going to landfill. A number ofStrategy Principles are advocated in order to facilitatethis vision. Those relevant to Crossrail, are thepromotion of regional net self-sufficiency andminimising the transport and associated environmentaleffects from the movement of waste.

Western Riverside

East London

West London

North London

South London

South East London

Central London

Total

Remaining Capacity (years)

0.0

4.6

>25

0.0

>25

0.0

0.0

10.6 yrs20

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Table 6 : Remaining Landfill Capacity at 1/4/99

Source: Strategic Waste Assessment 2000: London (EA)

20 the average proportion of void required for engineering work in site construction, daily cover, and capping to comply with government recommended practice has been calculated and deducted in order to give a more accurate impression of potential remaining landfill life. The method of calculation of life expectancy used here is somewhat theoretical as it compares residual waste capacity with biodegradable inputs at an average placed density of 0.83 per m3 and does not take into account circumstances surrounding individual sites which will have an influence at a local level. It does, however, provide a goodgeneral indication of maximum remaining life in each sub-region, and one which has the advantage of being comparable between regions and sub-regions.

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2.50 The Regional waste management strategyPanel Report was published on 6th January 2005. TheSecretary of State will consider the Report and intendsto publish his proposed changes to Regional PlanningGuidance Note 9: Regional Planning Guidance forSouth East during March 2005. The key principlescontained in policies, and many of the targets andpolicies are supported and unchanged by the Panel.

2.51 As well as the strategic planning context thereare also a number of other policy and relateddocuments which are relevant in assessing the mostappropriate strategy for dealing with the waste arisingfrom the project. This is set out in tabular form atAppendix A.

THE CONCEPT OF BPEO

2.52 The process of identifying the appropriatemeans of dealing with waste materials arising in aparticular situation is informed by the identification ofBPEO.

2.53 The BPEO was first outlined in the 5th Reportof the Royal Commission on Environmental Pollution(RCEP)21 in 1976 as an extension to the conceptknown as “Best Practicable Means”.

2.54 The BPEO was further defined, and mostcommonly referred to in the 12th Report of the RoyalCommission on Environmental Pollution (RCEP)22 as:

“The outcome of a systematic and consultativedecision making procedure which emphasises theprotection and conservation of the environment acrossland, air and water. The BPEO procedure establishes,for a given set of objectives, the option that providesthe most benefits or the least damage to theenvironment as a whole, at acceptable costs, in thelong term as well as the short term.”

2.55 The BPEO is further refined through WasteStrategy 2000 which identifies three considerationsthat are important when identifying BPEO in aparticular case:

l the Waste Hierarchyl the Proximity Principlel self sufficiency

2.56 Planning Policy Guidance Note 1023 providesthe current planning policy guidance and states thatthe Government wishes to see future wastemanagement decisions based on the followingprinciples. A Draft Planning Policy Statement 10 hasbeen issued for consultation (see paragraph 2.77).

The waste hierarchy

2.57 The waste hierarchy is the name given to thefavoured hierarchy of options, where reuse of wastematerials is considered the best option and the leastdesirable option is landfill and should be considered asa last resort.

2.58 The waste hierarchy is a conceptualframework that acts as a guide to the wastemanagement options which should be consideredwhen assessing the BPEO. The hierarchy sets out a“preferred” order of options for dealing with waste.The Waste Strategy 2000, Part 2 (page 29) identifiesthe hierarchy as:

l reductionl reusel recovery – recycling, composting or energy

recoveredl disposal, only if none of the above offer an

appropriate solution

2.59 In the prelude to Waste Strategy 2000, MakingWaste Work (1995)24 it states:

“…it would clearly be over-simplistic to rely solely onsuch a generalised objective [as increasing theproportion of waste managed by options towards thetop of the waste hierarchy]. The waste hierarchy willnot always indicate the most sustainable wastemanagement option for particular waste streams, andwaste producers will want to recover or dispose oftheir waste in the most cost-effective way. Thereforethe BPEO for each waste stream will vary according tocircumstances.”

2.60 Waste Strategy 2000, Part 2 states:

“To make rational decisions on waste management, weneed to consider a number of subsidiary objectives.

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21 Royal Commission on Environmental Pollution (1976) Air Pollution Control

: An Integrated Approach - Fifth Report22 Royal Commission on Environmental Pollution (1988) Best Practicable

Environmental Option - Twelfth Report

23 PPG 10 (1999) Planning and Waste Management, paragraph 624DoE, Making Waste Work, 1995

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These might include social, economic, environmental,landuse, and resources use impacts, each of which willhave its own set of criteria.”

2.61 In terms of future waste management options,there are measures that can be adopted to complywith all parts of the hierarchy. However the impact ofthese options on the overall quantities of waste willvary considerably. The most effective solution is tobuild waste reduction/ minimisation into the schemedesign. However, in certain parts of the project (e.g.tunnel excavation) material will be generated constantlyover a 24 hour period. This reduces the prospect ofbeing able to reduce/minimise the surplus materialgenerated. This aside, there are limiting factors inparticular the tunnels have to be a set size toaccommodate the trains. Waste reduction initiatives,as a single waste management option, will not providea sustainable, long-term solution.

2.62 Below waste minimisation / avoidance, in thehierarchy of options, lies waste re-use. The issuesrelating to re-use, for the Crossrail project, areconsumer and generator led and are heavily reliant onthe availability of projects at a particular time, though aproportion of the material will be re-used forlandscaping purposes. While a significant proportion ofsurplus material is capable of re-use, a proportion ofthe materials excavated during the tunnelling andconstruction works will have been contaminated byprevious activities or events along the line of the route.These materials will require particular attention inhandling . Once again as a single waste managementoption this will not be an effective way of dealing withall of the waste generated.

2.63 The third tier of the hierarchy is often referredto as recovery. This term relates to the recovery ofvalue from waste through recycling and other methodsof processing the waste, including methods such ascomposting. The nature of the waste arising is suchthat it will not be suitable for such processing. TheGovernment has set statutory targets for municipalwaste but there are no defined targets for the type ofwaste generated by the proposals.

2.64 The final means of dealing with waste, in termsof the hierarchy is landfilling.

2.65 As a result of the Landfill Directive which cameinto force on 16th July 2001, the Government iscommitted to reducing the amount of waste going to

landfill. The Directive requires that waste is divertedaway from landfill, up the hierarchy towards moresustainable forms of waste management. As well asintroducing stricter regulatory controls, the Directiverequires the amount of bio-degradable waste going tolandfill to be reduced, in stages over the next twodecades, to 35% of the 1995 total by 2020.

2.66 The United Kingdom has not managed tomeet the interim deadlines and as a result landfillcapacity for bio-degradable waste is still required. Inaddition the landfill capacity needs to be husbanded toensure that there is sufficient capacity for the long termto deal with this type of waste. Crossrail is committedto ensuring that the strategy for dealing with materialsarising from the project does not, in so far as ispracticable, compromise the objectives of Europeanand Government policy.

2.67 The thrust of Government Policy remains thediscouragement of inefficient use of landfill, howeverthis can only be achieved if the planning systemdelivers the necessary waste management facilities.

The proximity principle

2.68 The proximity principle is a furtherconsideration. This principle encourages the provisionof waste disposal facilities as close to the place oforigin as possible, to reduce the environmental impactsthat arise from transporting waste.

2.69 The proximity principle is described in WasteStrategy 2000 as having two important functions.Firstly it is a tool for planning authorities andbusinesses when considering the requirements for,and location of, waste management facilities andregional self-sufficiency. Secondly it helps raiseawareness in local areas that waste produced is aproblem which must be dealt with, in so far as ispracticable, close to where it arises.

2.70 The Waste Strategy suggests that theenvironmental impact or cost of transporting waste toa distant facility for reprocessing, outweighs the benefitof recovering the waste. However, there is clearly abalance that needs to be struck and local factors needto be taken into account.

2.71 Crossrail is the largest infrastructure project inthe UK and as such some of the resultant implications

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need to be considered in a unique way. The projectspans Greater London, a developed area providing onthe one hand unique opportunities for re-use ofmaterials in other major projects such as ThamesGateway and on the other hand limited opportunitiesfor the deposit of materials due to the lack of landfillsites within the Greater London Area.

2.72 Application of a rigid interpretation of“proximity” is unlikely to prove sustainable and has noregard to quantities of waste generated or locationalfactors. Furthermore when considering projects suchas Crossrail it is unlikely that one administrative areawould be able to provide the capacity for such arisings.While the London Plan sets out strategic policies toprovide sufficient capacity to manage 75% of wastearising within London by 2010.The capacity isrecognised by surrounding authorities and in policyterms there is provision for accommodating aproportion of waste arising from within the Londonarea.

2.73 The proximity principle can make the linkbetween the waste hierarchy and BPEO.

2.74 Self sufficiency is the final consideration whendetermining the BPEO in a given situation. Wasteplanning authorities and the waste industry should aimfor regional self-sufficiency in managing waste.

2.75 As well as these, consideration also needs tobe given to:

l international obligationsl the national policy frameworkl national and regional policies, and l local planning policies and environmental, social

and economic factors.

2.76 Although self-sufficiency is an objective it isrecognised that this is rarely possible, as administrativeboundaries do not necessarily reflect practicalconsiderations relating to waste arisings and transferfrom place of origin.

Consultation on Planning Policy Statement 10 25

2.77 A consultation paper on Planning forSustainable Waste Management (PPS10) waspublished in December 2004. The consultation paperforms part of a wider package of reform of wasteplanning and the objective of the Draft PPS is toprovide a clear statement of Government PlanningPolicy on sustainable waste management.

2.78 The PPS also coincides with the publication ofa series of consultation papers produced by DEFRA26,27.

2.79 In revising the guidance DEFRA has reviewedthe decision-making principles set out in WasteStrategy 2000. In particular the changes seek toaddress the decision-making processes fordetermining the Best Practicable Environmental Option(BPEO) for waste management facilities. TheGuidance addresses some of the deficiencies arisingas result of applying the BPEO concept to decisions onwaste management. As part of the review thegovernment has examined the role of BPEO which it isstated28 “encapsulates the following importantprinciples:

l in taking decisions forward there should be consideration of alternative options in a systematicway

l engagement of the community and key stakeholders should be an important and integral part of the decision making process

l the environmental impacts for possible options should be assessed looking at both long and shortterm

l decisions should seek the best environmental outcome taking account of what is feasible and what is an acceptable cost.”

2.80 It is acknowledged that these principlesremain valid. The aim is to move towards the BPEO asa “concept” being superseded by the SustainabilityAppraisal and Strategic Environmental Assessmentprocesses.

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25 Consultation on Planning Policy Statement 10:Planning for Sustainable

Waste Management, ODPM, December 200426 Consultation Paper 1 – Changes to Waste Management Decision

Making Principles in Waste Strategy 2000, DEFRA, December 2004

27 Consultation Paper 2 - Consultation on Draft Guidance on Municipal

Waste Management Strategies, DEFRA, December 200428 Ibid , paragraph 5

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2.81 The proposed revised text for Waste Strategy2000 re-affirms the Government’s belief that the mosteffective waste management decisions can be takenby adopting an integrated approach to wastemanagement and states that those planning themanagement of significant quantities of various wasteshould avoid over-reliance on a single wastemanagement option. In line with current advice, anyintegrated waste management system must makeallowance for the precautionary principle29.

Application and interpretation of the BPEO

2.82 As well as Government advice the conceptand application of the BPEO has been tested throughthe planning inquiry system and through the courts.the BPEO was deemed a material planningconsideration in 199730 and recent high profileplanning cases have emphasised the role of the BPEOin decision-making.

2.83 Case law has determined, that while theBPEO is most often applied as strategic tool,assessment of site specific BPEO is consideredappropriate for site-specific proposals. Bearing inmind the indicators set out in Table 7, these are moreappropriately dealt with at a site-specific level and alsowithin the context of environmental impactassessment.

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29 This means where action is taken to tackle suspected causes of

environmental damage without waiting for unequivocable scientific

evidence.

30 R v Bolton Metropolitan Borough Council ex parte Kirkman (1998) Env

LR 560

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3 IDENTIFICATION OF BPEO

3.1 It is clear that Government is moving towardsa clearer and more robust method of option selection.However the current strategy and advice on WasteStrategy 2000 sets out a step-by-step approach toidentifying waste management options.

Step 1: Set the overall goals for making the wastemanagement decision, define subsidiary objectivesand the criteria against which the performance ofdifferent options will be measured

Step 2: Identify all viable options

Step 3: Assess the performance of these optionsagainst the criteria

Step 4: Value performance

Step 5: Balance the different objectives or criteriaagainst one another

Step 6: Evaluate and rank the different options

Step 7: Analyse how sensitive the results are tovariations in the assumptions made or data used.

3.2 Work on BPEO has been further refined and isset out in Strategic Planning for Sustainable WasteManagement31. Further guidance is also available inScotland and Ireland and is being developed throughemerging policies.

3.3 The Guidance highlights the advantages inadopting a methodology that is:

l comprehensivel flexible l iterativel transparent

3.4 Most often the concept of BPEO is applied toregional strategies rather than specific proposalshowever the concept can be adapted to provide aframework for sustainable waste managementdecisions. Given the scale of the Crossrail project thisis paramount.

3.5 The Guidance provides advice on methods ofappraising strategic waste planning options. A varietyof methods can be used to appraise the performanceof the options against the objectives and indicators setout in Table 2. They fall into three types:

l use of quantitative assessment toolsl use of generic datal use of professional judgement

3.6 Waste Strategy 2000 recommends a LifeCycle Assessment approach, which builds inenvironmental, social and economic costs of thevarious options. The Environment Agency hasdeveloped a software tool (WISARD) for assessing therelative merits of the various options in a quantitativeway but it is recognised that the tool has limitations interms of lack of flexibility.

3.7 The limitations of quantitative assessmenttools have been explored at the outset of the strategicassessment. There is limited generic data relating tothe waste handling relating to the Crossrail project anda number of uncertainties which would affect thereliability of the outcome from a quantitativeassessment.

3.8 The guidance indicates that the use ofprofessional judgement is appropriate and states thatthis can vary from a simple qualitative ranking throughto more detailed research.

3.9 This approach is backed up by planning caselaw. In the appeal against refusal of planningpermission for an integrated waste managementfacility in Kidderminster32, the Inspector noted that“there is no set approach to be followed in making aBPEO assessment and there is no requirement to useWISARD software”.

3.10 The use of performance ranking is a valuableindication of the relative performance of each option.The guidance suggests that this should beaccompanied by a “weighting” arrangement as not allof the indicators will be of equal importance.

3.11 Having used these techniques it is thenpossible to identify the preferred option based on arobust series of decisions taken through the step bystep process.

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31 Strategic Planning for Sustainable Waste Management, Land Use

Consultants and ERM

32 Appeal Ref: APP/E1855/A/01/1070998 (2002) Appeal decision British

Sugar Site, Stourport Road, Kidderminster

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3.12 Once the preferred option has been identifiedit is advised that a thorough examination of thesensitivity of the results is undertaken. This will allowsome option refinement if necessary. Clearly in thecontext of Crossrail there are a considerable number ofuncertainties which need to be considered.

3.13 The recent guidance33 recommends the use of aquantitative tool but also recognises that appraisalmethods may also include use of generic data on theperformance of options and /or the use of professionaljudgement to assess the performance of options.

3.14 The ultimate choice of appraisal method willdepend on a number of factors, however, it is clear thatwhere generic data are not available it is appropriate tomake an expert judgement.

3.15 Taking this on board the following stagedBPEO assessment process has been applied to thewaste arising from the Crossrail project.

Stage 1: Establish the waste baseline figures

Stage 2: Define the local decision criteria

Stage 3: Define initial set of waste management options

Stage 4: Appraise options

Stage 5: Review and refine the preferred options

Stage 6: Choose the BPEO

Stage 1: Establish the waste baseline figures

3.16 An assessment of the surplus material arisingfrom the Crossrail project has been undertaken inrelation to each aspect of the development. This hasconcluded that approximately 8 million cubic metres ofpredominantly inert excavated materials will beproduced. In addition a proportion of the waste will beconstruction and demolition waste and there is also asmall proportion of contaminated materials.

Stage 2: Define the local decision criteria

3.17 The Crossrail project spans a number of localauthorities across London and beyond. Each LocalAuthority is covered by a suite of planning policiescomprising the overall Development Plan. A number oflocal plans contain policies relating to waste. Alongwith the European, national and regional wasteplanning policy framework these policies will providethe framework for local decision-making. Furtherdetails of the policy framework are set out in Section 2and Appendix A.

3.18 The guidance for strategic waste managementoptions34 sets out a list of recommended objectivesand indicators for option appraisal. These are set outin Table 7 below.

Stage 3 & 4: Define initial set of wastemanagement options and appraise the options

3.19 As part of the BPEO assessment, Stage 3provides for the definition of an initial set of wastemanagement options. For the purposes of theCrossrail Project an initial set of options can beidentified as:

l “do nothing” i.e. let market forces dictate how /where the waste will go at the time it arises

l maximise reductionl maximise reusel maximise recycling / recoveryl landfill the arisings

3.20 The guidance35 is clear that the initial list isnot intended to be prescriptive.

3.21 The Guidance states that the initial definition ofthe strategic options forms the starting point fordeveloping a shortlist of preferred options for detailedappraisal. It is recognised that in practice, strategicwaste planning solutions will comprise a combinationof the options, because the best option will varyaccording to the type of waste, its source andcomposition, and the viability of alternative methods,both generically and in the local context. The guidancegoes on to suggest that each strategic waste planning

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33 Land Use Consultants and ERM (2002) Strategic Planning for Sustainable

Waste Management: Guidance on Option Development and Appraisal34 Land Use Consultants and ERM (2002) Strategic Planning for Sustainable

Waste Management: Guidance on Option Development and Appraisal

35 Land Use Consultants and ERM (2002) Strategic Planning for Sustainable

Waste Management: Guidance on Option Development and Appraisal

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option should cover all stages in waste management,including:

l collection and transfer of wastel recoveryl disposal

3.22 To assist in identifying an appropriate range ofoptions a review has been undertaken of key policyand legislation. Options should include:

l the simplest “do minimum” solution l the most ambitious “do maximum” solution that

moves as much waste as possible up the waste hierarchy

3.23 The assessment looks at waste managementoptions against a set of criteria, based round theguidance in Waste Strategy 2000, and through asimple matrix approach (paragraph 3.36) assesses thecomponents of the hierarchy against the criteria.

3.24 The criteria identified in the Strategic Guidancehave been assessed in qualitative manner, the resultsof which are summarised in the matrix as a result of anassessment of their relative performance against thefollowing:

l environmentall economicl social

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Environmental Objectives1. To ensure prudent use of land and other resources

2. To reduce green house gas emissions3. To minimise adverse impacts on air quality andpublic health

4. To conserve landscapes and townscapes5. To protect local amenity6. To minimise adverse effects on water quality

Socio-economic objectives7. To minimise local transport impacts (congestion,severance, fear and intimidation, physical damage)8. To provide employment opportunities9. To provide opportunities for public involvement andeducation

Operational Objectives10. To minimise costs of waste management

11. To ensure reliability of delivery

Waste Management Policy Objectives12. To conform with waste policy

Indicatorsl Depletion of resources, such as wood, water,

fuels and oresl Landtakel Greenhouse gases emittedl Emissions which are injurious to public healthl Emissions contributing to air acidificationl Emissions contributing to depletion of the ozone

layerl Extent of odour problemsl Extent of dust problemsl Extent of visual and landscape impactsl Extent of noise, litter and vermin problemsl Emissions contributing to eutrophicationl Extent of water pollution

l Total waste kilometres (by mode)l Transport along roads other than motorwayl Number of jobs likely to be createdl Extent of opportunities for public involvement and

education (concerning sustainable waste management practices)

l Costs of collection, management and disposal, including material and energy revenues

l Likelihood of implementation within required timescale, taking account of maturity of technology, necessary level of public participation, and the need for planning (taking account of scale of development and likely perceived adverse impacts)

l Percentage recovery Percentage recycled

Table 7:Recommended Objectives and Indicators

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l practicability of the option; and l fit with policy

3.25 The environmental criteria are further brokendown into key categories upon which wastemanagement solutions are likely to impact. Generalenvironmental factors such as impact on air, land andwater are included, the impact on climate change,impact on local amenities, impact on non-renewableresources and finally the risk of accidents isconsidered.

3.26 Economic criteria are built into the matrix toreflect the need to consider economic factors whendetermining the overall BPEO. In assessing the impactof the various options, cost, financeability/affordabilityand impact on local economy are considered.

3.27 Social factors also have a bearing on thechoice of waste management options. These includethe wider social benefits associated with the overallproject in terms of accessibility. There is also theresultant employment arising. Public acceptability isalso a factor that requires consideration.

3.28 As well as the other criteria, practicability isalso an important consideration. The options need tobe regarded in terms of flexibility to deal with the largequantities of waste arising. Further considerations arepractical deliverability of the chosen option, technicalfeasibility and making best use of existing facilities andexpertise.

3.29 Finally, each option is considered against fitwith policy at European, national and local policylevels.

3.30 Waste minimisation is omitted from the list ofobjectives as it is considered that it should be inherentto waste management options. In respect of theCrossrail proposals waste minimisation is a factor ofthe scheme design.

3.31 There are also a number of “site specific”objectives which do not appear in the list. This ispredominantly due to the fact that the impact ofstrategic waste planning options cannot be assessedwithout prior knowledge of the nature and sensitivity ofthe site specific issues relating to materials handling.

3.32 The summary table (Table 9) demonstratesthat waste reduction and re-use are both desirableoptions and should remain as part of the “option

package” however as single or combined solutionsthey are unlikely to be successful given the volumes ofmaterial and the timescales over which the material willarise. Given the project timescales and volume ofmaterial likely to be generated, it is not possible toassign the materials to readily identifiable projects.Waste minimisation is built into the project design butthe scheme tunnels are a requisite size toaccommodate operation of the trains which reducesthe scope for further waste reduction. Neither optionon its own is likely to provide sufficient capacity or besufficiently flexible to deal with such quantities ofarisings. A process of identifying projects andinitiatives to use some of the surplus material, hasbegun and while no specific projects are currentlyidentified, knowledge of the London area anddevelopment plans for the future indicate that asignificant quantity of material is likely to be diverted forsuch uses.

3.33 Government policy suggests that landfill is theleast desirable option. Landfill gives rise to a range ofemissions and impacts on local communities. Landfill,per se, is not a flexible option and continuing,increasing reliance on landfill is contrary to policy.However, some of the surplus material arising from theCrossrail project would be put to “beneficial” use aspart of achieving the wider restoration objectivesassociated with the landfills. This has the benefit ofensuring that landfill void is husbanded for future useand for the types of waste which have to be disposedof in this way.

3.34 Recycling and recovery sit in between optionsat the top and bottom of the hierarchy. While certainprocesses lead to environmental disbenefits, recyclingand recovery and “beneficial use” largely fit with policyand are practicable solutions. There are likely to bedisbenefits associated with the transportation ofmaterials by road to any “re-use” schemes,necessitating the use of strategic routes, however thiswould also be the case for landfill unless it there arealternative transportation options. This is also true ofother options.

3.35 Table 8 sets out the application of theoverarching objectives from Waste Strategy 2000 tothe Crossrail project and looks at the overallperformance of the various options.

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ENVIRONMENTAL CRITERIA

1. Air, land and waterMost waste management options can lead to impacts on air quality and public health particularly if the waste is to beprocessed. The nature of the waste arisings from the project are such that they are predominantly inert and can be directedfor beneficial use in site restoration at landfills. The material can largely be accommodated within the parameters of existingconsents at existing facilities thereby minimising the impacts arising from the creation of new sites or intensifying the use.

As part of the assessment process, guidance suggests that it is appropriate to consider the impact of waste managementoptions on water quality, air and land. Key questions to be asked relate to the potential for pollution arising from disposalof the material. As most of the material is inert in nature the potential for pollution arising from the disposal of material isminimal. However a small proportion of the material is likely to be contaminated. The direct disposal of contaminated wasteto landfill is the least preferred option. Co-disposal (i.e.the placement of such material in landfill in conjunction with inert ornon-hazardous putrescible waste) has been banned under the Landfill Regulations 2002. These regulations are strictlyapplied by the EA and as such there is minimal prospect of additional pollution as the material will be controlled anddeposited in appropriately licensed facilities. Furthermore there are stringent controls placed on operators who are requiredto have carrier’s licences to transport such waste. As part of the project development consideration has been given to theappropriate means of dealing with such waste. The effect of the tightening legislation is a reduction in the number of facilitiesavailable to take the material and as a result the strategy for such material arising from Crossrail is based on:

l Maximising the opportunity for on-site remediation and re-usel Maximise the opportunity for off-site remediation and re-use (where the above is not practicable)l Secure suitable outlets for disposal where neither of the above is practicable.

Reuse of the materials may give rise issues of pollution if the contaminated materials are not properly separated. Howeverthe management of the construction elements and the associated codes of practice are such that this is unlikely. Thelandfilling of the materials may give rise to issues of environmental impact, however these types of impact are largelyassociated with bio-degradable wastes.

2. Global climate changeClimate change is predicted to occur as a result of emissions of gases. The principal source of greenhouse gas emissionsis from fossil fuel combustion (i.e. through transportation of waste) and also from waste decomposition. Any option forwaste management will result in the production of gases and as part of the assessment process consideration should begiven to whether the option will, inter alia, lead to an increase or decrease in fossil fuels used and what will the effect onemissions of greenhouse gases be.

The main sources of these gases arises from vehicles used to collect and transport waste.

With the exception of waste minimisation at source, all of the options have the potential to contribute to the greenhouseeffect, principally through the need to transport the material away from the construction project.

3. Local amenityWaste management options have varying potential to impact upon local amenity by virtue of noise, dust, traffic etc. Theimpact on local amenity will arise both at arising and disposal. Temporary storage of materials may give rise to impact aswill eventual disposal. It is not anticipated that any new sites will be used for disposal, and in line with the overall strategythe project objectives are concentrating on the utilisation of existing landfill sites (where necessary) and so far as ispracticable to work within the existing and permitted operational parameters.

The traffic and transportation impacts of the proposals have been assessed and the removal and handling of surplusmaterial is based around the need to comply with sustainable transportation objectives, therefore maximising the use of trainand barge. It is inevitable due to the location of some of the construction sites that a proportion of material will need to beremoved by road however where possible movements are restricted to materials handling sites for onward transportationby train and barge. Furthermore the strategy presented in the Environmental Statement for material handling addresses theimpacts arising from the disposal of all materials to landfill. The availability of landfills has been assessed and a strategy canbe applied which ensures that vehicle movements do not exceed those already granted planning permission. This willensure that additional environmental impacts, as a result of traffic, do not occur.

It is not anticipated that any option will impact significantly on local amenity.

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Table 8: Performance of Options against the Criteria

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4. Natural heritageThe options available for the material arising from Crossrail relate to either beneficial re-use or disposal at landfill sites foruse in site restoration. Potential beneficial use projects include such things as flood defence works and bunding exercisesassociated with major development projects. These will be carefully controlled and part of a masterplan for the individualdevelopments. Bearing in mind the quantities of waste arising there may be impacts during the construction phases butoverall the benefits in the long term will outweigh any disbenefits associated with short term impacts.

It is not anticipated that any option will impact significantly on natural heritage. A landfill appraisal has been undertaken andwhere it is necessary to transport materials out of London for use on landfill sites it is concluded that it is possible to work,for the most part, within existing operational conditions and planning conditions. Many of the sites lie within or adjacent toareas of natural heritage importance but the proposals will not give rise to additional operational impacts.

5. Cultural heritageThe waste management options are unlikely to involve new infrastructure or development. Where landfill of the waste isnecessary this will take place at existing facilities and so far as is practicable within current operational parameters. It is notenvisaged that the options will impact on cultural heritage.

6. Non-renewable resource useA key environmental objective is the prudent use of land and resources. Landtake will not necessarily be an issueassociated with the surplus material although a need has been identified for temporary storage areas for the surplusmaterial. The materials would be suitable for either beneficial use associated with major development projects, and as suchalready included within the landtake areas identified e.g use in bunding or landform creation. Otherwise the material wouldbe used in restoration associated with existing landfills. This will ensure that the waste is appropriately used and that thelandfill voids are husbanded and protected for waste that cannot be re-directed to other waste management options i.e.residues from other processes.

The prudent use of finite resources also falls under this objective and is key to sustainable development. Non-renewableresources should be used efficiently. An option involving re-use and recovery of materials should result in reduction ofconsumption of primary resources.

The strategy for dealing with the waste arising from the project is predicated on the principle of re-use and where wasteneeds to be transported using barge and rail transport where this is feasible While this will not totally eliminate theproduction of greenhouse gases it is more sustainable than all the material travelling by HGVs.

Waste minimisation through design and re-use close to source will assist in minimising the use of non-renewable resources,in particular fossil fuels associated with transportation. Landfilling may involve transportation of the materials some distancefrom where they arise.

7. Risk of accidentsGuidance suggests that it is appropriate to assess the risk associated with the various waste management options. Thisshould include the risk of accidents to people and the safety of any technologies applied. Given the nature of material arisingit is unlikely that the treatment / management will give rise to significant risk. There are risks associated with haulingsignificant quantities of material but these are not considered to be unacceptably high.

There are no benefits or disbenefits between the options in terms of risk of accidents other than those associated withtransportation.

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ECONOMIC OBJECTIVES

8. CostFrom an economic perspective, guidance suggests that a key objective is to satisfy waste management objectives at leastoverall cost to society. Assessment of costs is a complex process and difficult to determine precisely. In terms of wastemanagement the costs of disposal are wholly dependent on the method and distance of haulage, need for double handlingand final destination. Landfilling of waste attracts Landfill Tax. The type of material to be excavated for the tunnelling workis predominantly London Clay and indications are such that the material can be put to beneficial uses, including siterestoration and as such will not attract the payment of Landfill Tax. A key objective of waste management is adherence tothe proximity principle i.e. dealing with waste as close as possible to where it arises. This forms a key element of the overallwaste management strategy and assists in reducing the costs.

Overall there is a large proportion of surplus material and the costs of dealing with it are to a great extent uncertain at thisstage.

Landfilling of the surplus material will attract greater costs than the other options.

9. Financeability /AffordabilityGuidance is clear that there needs to be sufficient funding available for any waste management option to be successfullyimplemented. Crossrail is a publicly funded project and the costs of dealing with the surplus materials arising from thedevelopment will be an important factor in determining the overall strategy for dealing with the surplus material.

Landfilling of the surplus material will attract greater costs than the other options given the implications of the Landfill Tax.Material directed for use in site restoration will be exempt from such tax payments.

10. Impact on local economyWaste management options can impact both positively and negatively on employment. There is no doubt that overall theCrossrail project will impact beneficially on employment opportunities both temporarily and permanently by virtue ofconstruction and in the longer term by improving accessibility.

Both re-use projects and landfilling will lead to benefits to the local economy in terms of job creation.

SOCIAL OBJECTIVES

11. EmploymentEmployment opportunities will arise through construction activities, haulage of material and dealing with the materials at itsfinal destination. The waste will arise over a 5 year period and will have a positive impact on the employment in the wasterelated sectors.

Both re-use projects and landfilling will lead to benefits to the local economy in terms of job creation.

12. Making producers responsibleA key aim of government policy is the encouragement of producer responsibility. The waste management options includemaximising re-use of the material for beneficial uses and ensuring that material is transported in sustainable way.

Landfilling performs the least well under this indicator, unless the material is directed for use in site restoration.

13. Public acceptabilityIssues relating to public acceptability are usually associated with the need to provide new facilities and are also importantwhen introducing systems for dealing with household waste, which require public participation. It is not anticipated thatthere will be any particular issues relating to public acceptability arising from the means of dealing with the excavatedmaterials.

While landfilling can attract public opposition, it is proposed to use existing sites with planning permission. It is not proposedto undertake significant activities outside current operating requirements. Use of materials in site restoration and otherbeneficial use projects are likely to attract public support.

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14. Skills baseIt is unlikely that any particular skills gaps will be identified when considering the options.

There is no perceived difference between how the options perform.

15. Social implicationsWaste management options can have social implications. This is particularly relevant to schemes which require publicinvolvement. Issues such as social exclusion / deprivation are key issues to consider. Additional impacts could be perceivedto arise at the any landfills used to take surplus materials, however it is anticipated that activities will take place withinexisting planning parameters. As a result it is not expected that there will be any additional impact.

It is proposed to store materials temporarily on Mile End Park and this will result in temporary impact.

The social implications arising from the waste management options for the Crossrail project will be difficult to determinewholly until the final destination for the material is identified, however as the material is likely to go to existing sites within theexisting permissions there are unlikely to be any social implications arising.

PRACTICABILITY

16. FlexibilityIt is important that the final choice of option (s) is sufficiently flexible to cope with change. When assessing the ability of thestrategy to deliver a solution capable of responding to changes e.g. in the levels of arisings it is important to build in sufficientflexibility. A solution based wholly on landfill is dependent on the availability of suitable voidspace.

No option on its own can provide the level of flexibility needed to cope with such quantities of material over the constructionperiod.

17. Making the best use of existing facilities and expertiseThe development of new infrastructure to deal with waste can be very costly. It is considered important to make good useof existing resources and disposal capacity as discarding these will be a waste of already committed resources. Newfacilities will be created for rail access at Pitsea, however they will make the site more sustainable for subsequent wastes.

Re-use and use of the material for site restoration at landfill sites both perform well under this indicator.

18. Practical deliverabilityAlthough a waste management option may seem, on the face of it, to perform very well (such as all re-use /recovery) it maynot be possible to implement the system due to simple practical constraints. This is particularly true when considering theCrossrail project. There are unlikely to be sufficient projects which can take the huge quantities of material within the settimescale of arisings. It is therefore important to be realistic at this stage about the practical deliverability.

There are issues relating to the practical deliverability of solutions for dealing with the material. Given the timescales thereare no existing contracts for dealing with the waste and no specific projects identified for beneficial use. Practically landfilldoes perform well as there is sufficient identified capacity for the material with the construction period timescale.

19. Technical feasibilityAs there are no complex waste management technologies anticipated, there are no likely problems associated withtechnical feasibility.

There are no obvious benefits between the options as all are technically feasible.

FIT WITH POLICY

20. Compliance with European PolicyIt is important that waste management options do not conflict with policy.An assessment of the proposals against all levels of policy has been carried out and is set out in Section 2 and AppendixA. Overall, with the exception of landfill the various options perform well when considered against European PolicyObjectives. Landfill is the least desirable option.

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3.36 Table 9 present a summary of the options appraisal exercise following a qualitative assessment of theimpact on particular criteria. In the table a benefit is indicated by 4 . A disbenefit is indicated by 8.

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21. Compliance with National PolicyAn assessment of the options against national policy indicates that overall, with the exception of landfill the various optionsperform well.

22. Compliance with Local PolicyThe local planning policy implications of the options are addressed in Appendix A. For the most part the options andproposals perform well when considered against the policy objectives. However, a key objective of the London Plan is futureself-sufficiency in terms of waste management. The volumes of material and the timescale over which it will arise meansthat a proportion of the material is likely to be dealt with outside the London area. This is likely to be that material used forsite restoration / engineering at landfill sites. While this is contrary to the self-sufficiency objectives in the Plan it does notcompromise landfill objectives elsewhere as the material will be used for beneficial purposes.

Criteria

Environmental

Air, Land, WaterGlobal Climate ChangeLocal AmenityNatural HeritageCultural HeritageNon- renewable resource useRisk of accidents

Economic

CostFinanceability / affordabilityImpact on local economy

Social

Employment Making producers responsiblePublic acceptabilitySkills baseSocial implications

Practicability

FlexibilityMaking the best use of existing facilities and expertisePractical deliverability Technical feasibility

Fit with Policy

Compliance with European PolicyCompliance with national PolicyCompliance with local Policy

Waste Management Option As single solutionReduce

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reuse

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Recycling/recovery

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Table 9 – Summary Assessment of Relative Performance Waste Management Options

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3.37 Overall, as a single solution none of theoptions on their own can deliver a strategy for dealingwith the surplus material which is robust and complieswholly with the key criteria. This is largely due to thequantities of material involved and capacity of otherprojects and existing infrastructure to deal with thematerials.

Stage 5: Review and refine the preferred options

3.38 The broad structure for the overall strategy fordealing with the surplus material is based on anassumption that all the waste will be landfilled. This islargely as a result of lack of storage within the schemearea and the fact that the material will arise from thetunnel construction on a 24-hour basis. This ispredominantly to ensure that in the event the lessreliable alternatives cannot be secured, then there issufficient, available capacity to deal with the waste.This is a fundamental component of the Strategy.

3.39 At regional level the Regional strategy and theLondon Plan endorse the principles of BPEO, regionalself-sufficiency, the proximity principle and the wastehierarchy but there is a general understanding thatauthorities should apply the hierarchy flexibly. Overallthe general aim should be the progressive movementof waste management up the hierarchy and an overallreduction in the reliance on landfill.

Stage 6: Choose the BPEO and sensitivity testing

3.40 The final step of the process relates tochoosing the BPEO.

3.41 It is clear from the summary table andperformance matrices that the BPEO for dealing withthe excavated materials will comprise an integratedapproach, which involves:

l waste reduction through scheme designl maximising re-usel beneficial re-use of material l use of materials in site restorationl minimising landfill

3.42 The exact proportion and contribution of eachelement remains to a large degree uncertain, howeverto ensure that there is a destination for the surplusmaterial, a study of landfill and void capacity hasrevealed sufficient available capacity in the unlikelyevent that all of the material needs to be dealt with inthis way.

3.43 Guidance recognises that the identification ofBPEO is not a precise science. There are a number ofuncertainties inherent in the process. However, use ofa defined methodology does ensure that the process istransparent.

3.44 In terms of Waste Strategy 2000 decisionmakers need to consider the implications of the wastehierarchy. While the hierarchy is a conceptualframework it provides a guide for the wastemanagement options and the weight which should begiven to each option. The performance matrix (Table 9)shows that options towards the top of the hierarchy areall desirable however as a single solution deliverabilityand flexibility is likely to be a key issue.

3.45 Landfilling of waste falls at the bottom of thehierarchy and is the least preferred method of wastemanagement. However it is necessary to draw adistinction between “landfilling” of voidspaces and useof material for site restoration. The majority of theexcavated materials arising from the Crossrail projectare suitable for capping material and use in siterestoration. It is essential that landfill void ishusbanded appropriately and that material which canbe put to beneficial use is dealt with accordingly. Thisis wholly in accordance with the waste hierarchy.

3.46 It is clear that some of the surplus material andconstruction and demolition waste arising from theproject will be contaminated. The BPEO for this typeof waste is remediation. The preferred option isremediation on site followed by offsite remediation withremaining contaminated material sent to landfill.

3.47 The proximity principle was considered indetail in the BPEO and subsidiary studies. In particularthe proximity principle was applied to the selection oflandfill sites. Waste Strategy 2000 suggests that theproximity principle can make the link between thewaste hierarchy and the BPEO. Where the BPEO istowards the lower end of the hierarchy this can be asa result of impacts/costs to distant re-processors.

3.48 Given the scale of the project, it is recognisedthat a number of means of waste transfer arepotentially available and desirable:

l transport by roadl transport by raill transport by bargel direct removall interim disposal sitesl waste transfer

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3.49 Alternatives to road transport are considered apriority given the volume of material arising from theProject. Rail and barge were considered the preferredtransport options, both of which are sustainable andconform with the extant planning policies across thescheme, in particular the transportation objectives setout in the London Plan.

3.50 In terms of the proximity principle andapplication to Crossrail there are three key factorswhich will have a bearing on how the proximityprinciple is ultimately applied:

l location of existing landfill capacity within the Greater London Area

l location of other facilitiesl accessibility by means other than public highway.

3.51 A final important strand in the determination ofthe BPEO is regional self-sufficiency. It is unlikely to bepossible to deal with all the surplus material within theGreater London area given the volume of materialwhich will be generated. There are a number of majordevelopment schemes which may require suchmaterial for beneficial use. There is limited landfillcapacity available in the Greater London Area.

3.52 Having identified that a combination of optionsis likely to be the BPEO, guidance suggests that it isappropriate to analyse the sensitivity of the results ofthe assessment. The guidance suggests that the useof some simple questions to ensure decision makers tobe satisfied with the robustness of the outcomes.

3.53 A common question applied is “Will the BPEOchange over time?” The ultimate BPEO is unlikely tochange over time, however the nature of thecomponent parts may change as developmentprojects involving beneficial use come on stream. Assuch projects are identified it is considered that agreater proportion of material will be put to beneficialuse in accordance with the waste management policy.

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4 CONCLUSIONS

4.1 This assessment has shown that no singlewaste management solution is likely to represent thebest practicable environmental option for dealing withthe surplus material arising from the project.

4.2 The BPEO will comprise a number ofcomponent parts involving waste minimisation, re-useand landfilling.

4.3 Over time the BPEO will remain the same,however the percentage contribution of each option islikely to change as material is re-directed for beneficialuse as and when such projects are identified.

4.4 The approach to the BPEO will remain aniterative process, however from the assessment ofBPEO it is possible to derive a strategy based on ahierarchy of options:

l waste minimisationl beneficial usel landfill as a last resort

4.5 Crossrail will use a disposal hierarchy toidentify the most appropriate destination for surplusmaterial and construction and demolition waste, asfollows. The project will:

l minimise generation of surplus material wherepossible

l re-use and recycle surplus material where possiblewithin the Crossrail project;

l re-use and recycle surplus material through environmental beneficial use (eg at registered exempt sites or as landfill restoration cover); and

l dispose of surplus material at licensed landfill sites.

4.6 The Crossrail project will re-use as much of thesurplus material as practicable within the project areaand on or near to the sites where it will be generated.

4.7 The project will also seek to provide excavatedmaterials for re-use on development projects that willbe constructed at the same time as Crossrail. The

project will undertake a review of appropriatedevelopment projects prior to Crossrail constructionand will set out a framework for the re-use of suchmaterials within the identified developments.

4.8 Construction and demolition waste willsimilarly be re-used, where practicable. Crossrail willidentify sites in the London area that can accept thiswaste for recycling. Any contaminated materials thatcan be re-used will be remediated prior to re-use.

4.9 Any materials or waste that cannot be re-usedeconomically will be disposed of at appropriatelylicensed landfill sites with sufficient capacity. Thedisposal sites have been selected using criteriaincluding proximity to Crossrail worksites andtransportation methods available for delivery ofmaterials to the disposal site (with preference given tosites accessible by rail and barge rather than lorry).Crossrail will also re-use excavated materials at landfillsites where the material could be used for siterestoration or engineering.

4.10 Surplus material that is contaminated and thatcannot be remediated and re-used will be disposed ofat sites licensed to accept hazardous waste.Contaminated materials may require treatment prior todisposal to appropriately licensed facilities. Thisrepresents a small proportion of the overall total ofsurplus materials. A precise assessment cannot bemade until the project is approved and intrusiveinvestigations are carried out. Contaminated materialswill be handled and transported separately touncontaminated materials, as appropriate.

4.11 Suitable landfill sites have been identified in asystematic way and the approach is set out in Volume1 and Volume 3 of the STR36.

4.12 The preferred means of transporting surplusmaterial is transportation by rail and barge, to reducethe number of lorries transporting excavated materialson the public road network. Approximately 30% ofsurplus material will be transported by rail. Surplusmaterial arising from constructing the tunnels willpredominantly be removed by rail.

4.13 Rail heads will be set up to enable the transferof the excavated material onto freight trains at

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36 Excavated Material and Waste Management Strategy (Volume 1) /

Appraisal of Landfill Sites (Volume 3)

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appropriate sites and approximately 15% of thesurplus material could be removed by barge.

4.14 Surplus material will be transported by roadwhere rail or barge transport is not practicable.Materials generated from the construction of most ofthe shafts and stations within central London will beremoved by road. Construction and demolition wastesgenerated at sites will also be removed by road.

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APPENDIX A

Waste Planning Policy Review

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Adams Hendry Excavated Materials and Waste Management Strategy : Volume 2 - Appendix A

APPENDIX A : Waste Planning Policy Review

Policy No.

Paras. 4.37and 4.42

Para. 9.3

PolicyWLP24PolicyWLP25PolicyWLP26Para. 10.13

Para 10.15

Paras. 40 -44

Paras. 48 -50

Paras. 75 -78

Policy Thrust

Inert Waste

Existing Recycling ofInert WasteRecycling of InertWasteDisposal of Inert Wasteby Land FillControls on theDisposal of Inert WasteTransport and Access

Buffer Zones BetweenWaste ManagementSites and SurroundingProperty

Current waste deposits

Waste ManagementFacilities inBuckinghamshireVoid Capacity

Comments

SEE BODY OF REPORT

SEE BODY OF REPORT

SEE BODY OF REPORT

SEE BODY OF REPORT

The strategy for inert waste is to maximise recyclingfollowed by disposal of the remainder in mineral workingsfor restoration. Assessments show there is likely to besome void space (2.9m cubic metres) suitable for thedisposal of inert waste in the Plan period.In 1993/94 18% of inert waste in Berkshire was recycled.This was put to lower grade use within the aggregates market.This Policy outlines that temporary inert waste and skip-recycling facilities would be permitted.The use of landfill for the disposal of inert waste will onlybe appropriate where this is required for restoration. The disposal of inert waste to landfill will be restricted tothat which remains after the recycling processes. Access to proposed waste sites which will generate largevolumes of traffic needs to via the primary road network,to avoid disturbance to the surroundings area. Sites notaccessed by the primary road network will be refused.A 100m buffer zone between inert waste landfill sites andthe nearest settlement and 150m between inert wasterecycling sites and the nearest landfill site.

Buckinghamshire produces around 1.5m tonnes of wasteper year, of which 1.2m tonnes are disposed of within theCounty. However there is around 2.5m tonnes of waste intotal disposed of within the County each year, takingaccount of imported waste. 42% of this is Type A waste,which includes inert materials e.g. construction anddemolition waste, soil, brick and rubble, accounting for1,059,258 tonnes of waste annually 1990-94.Landfill is the principle means of waste disposal, 99% ofcontrolled waste is disposed of at the 19 licensed landfillsites without pre-treatment.Around 16m tonnes of waste will need to be disposed ofduring the plan period, requiring 14.57 cubic metre of voidspace

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EUROPEAN WASTE POLICYGUIDANCE

NATIONAL PLANNING POLICYGUIDANCE

REGIONAL PLANNING POLICYGUIDANCE

STRATEGIC PLANNING POLICY

Buckinghamshire Waste Local Plan 1996-2006 (adopted 1997)

Waste Local Plan for Berkshire (adopted 1998) (Windsor and Maidenhead & Slough)

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Adams Hendry Excavated Materials and Waste Management Strategy : Volume 2 - Appendix A

Policy No.

Para. 89

Policy WLP1

Policy WLP4

Policy WLP6

PolicyWLP11

PolicyWLP19

Policy 10

Paras. 3.1.1– 3.1.4

Policy 11

Policy Thrust

Suitability of VoidSpace

Landfill Voids

Disposal of WasteOutside the County

Landraising

Recycling Facilities forInert Materials

Transport Links toWaste Facilities

Overarching WasteManagement: Principles

Overarching WasteManagement:Principles

Imported Wastes

Comments

13.67m cubic metres of void space have been identifiedas suitable for inert (type A) material, which exceeds thepredicted 5.88m cubic metres required.The County Council will support proposals for depositswithin voids created by mineral extraction, subject toconditions being met.Where waste cannot be deposited in the County, transferfacilities will be promoted and where appropriate recyclingof inert materials. Landraising with inert materials will only be acceptablewhere there is no alternative and is not of detriment to theenvironment.Recycling facilities for inert materials includingconstruction and demolition waste will be promoted onsites allocated for industrial purposes.The Council will give preference to waste managementfacilities which utilise rail or water transport, where theseare proved not be practical access should be via thestrategic highway network.

Promote and encourage measures to reduce overallwaste levels. Council Plan for self-sufficiency by 2016, byrequiring the County’s waste to be managed in theCounty with also a declining imported waste for London.

Degree of flexibility in relations to waste movements andsupport the proximity principle in determining the BPEO.Support the waste hierarchy.In Buckinghamshire in 2000/01 around 2.3m tonnes ofwaste were managed, of which around 45% (1.03mtonnes) was construction and demolition waste, of whicharound one third was recycled.

The Plan aims to increase the recycling of waste andreduce levels of landfill. A report produced in June 2004identifies that there is a waste management capacity of2.52m tonnes in 2004 in Buckinghamshire, with a 1.46mtonnes being non-inert landfill and 0.53m tonnes beinginert landfill.In order to prudently manage existing void space andreduce levels of landfill, Buckinghamshire will only plan fora declining amount of imported waste, and will resistproposals that would perpetuate existing landfill sites orcreate new ones, excepted in exceptional circumstances.

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Buckinghamshire Waste Local Plan 1996-2006 (adopted March 1997)

Buckinghamshire Minerals and Waste Local Plan 2004-2016: Second Deposit Draft (2004)

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Adams Hendry Excavated Materials and Waste Management Strategy : Volume 2 - Appendix A

Policy No.

Paras. 3.2.1– 3.2.4

Policy 18

Paras. 3.9.1– 3.9.5

Policy 21

Policy 29

Paras. 4.7.1– 4.7.2

Paras. 3.1-3.17

Policy W3C

Para. 3.35

Policy Thrust

Landfill andLandraising

Landfill andLandraising

Inert Waste and InertWaste Recycling

Proximity Principle andSustainable Transport

Transport of Waste

Waste Hierarchy

Need for WasteDevelopment

Landfill Provision

Comments

Buckinghamshire has one of the largest landfill voids inthe south east, and is well placed with good rail links toaccommodate imported waste from London and Bristol.As London has little landfill capacity and is not self-sufficient in waste management Buckinghamshire willcontinue to take imported waste from London – largelylandfill material and restoration material that cannot berecovered or recycled within London.This Policy outlines that the Council will continue toprovide for a continuing but declining landfill capacities.Permission will not be granted for any land raising.There is a total of 23,763,000 cubic metres landfillcapacity in Buckinghamshire in 2004. Landfill currentlyaccounts for 80% of the County’s total annual wastemanagement capacity. Beyond 2016 there is unlikely tobe sufficient landfill capacity to in full the County’s wasteand that imported from London. If increased recovery isachieved there will be sufficient landfill capacity.Support is given to proposals for permanent or temporaryfacilities for recycling inert wastes. County Council will notnormally grant permission for landfill or other land disposalof inert wastes except for restoration/ environmentalpurposes.All waste management proposals will need todemonstrate consideration of minimum adverse transportimpact. Proposals need to comply with the proximityprinciple. Where practical, use of rail, waterways,conveyors or pipeline will be preferred over roadtransport. Where road transport is only possible it needsto be demonstrated that the road network is suitable.Rail, canal and conveyors are identified as moreenvironmentally acceptable than road and that wasteneeds to be disposed of as close to waste arisings aspossible.

The Plan endorses the principles of the waste hierarchywhen considering waste management – with landfill beingat the bottom of the hierarchy and as such the leastdesirable disposal method.Proposals for significant waste management developmentwill only be permitted for schemes above 25,000 tonnesper annum where there is a demonstrated need for wastearising in Essex and Southend.Satisfactory provision needs to be made of securing someof the proposed void space for waste arising in Essex andSouthend, in accordance with proximity principle andregional advice. Void space identified for non-inert wasteshould be reserved for that purpose.

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Buckinghamshire Minerals and Waste Local Plan 2004-2016: Second Deposit Draft (2004)

The Essex and Southend Waste Local Plan (adopted 2001)

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Adams Hendry Excavated Materials and Waste Management Strategy : Volume 2 - Appendix A

Policy No.

Paras. 7.16-7.23

Para. 9.1 andPolicy W9A

Para. 9.6 andPolicy W9B

9.10-9.17

Para 1.24and PolicyW1Para. 5.2.4

4A.1

Policy Thrust

Inert Waste Recycling

Landfill

Landfill

Inert Waste Sites

Landfill

Spoil Material

Waste Strategic Policyand Targets

Comments

A range of materials currently disposed of at landfill couldbe reused/recycled as substitutes for primary aggregates.The reuse/recycling of construction/demolition wasteeither on site or elsewhere will be promoted.The requirement for void space has been arrived at afterfull allowance has been made to reduce initial wastearising. Landfill on preferred sites is only acceptable wherethere is a requirement to restore a site which cannot bemet without fill. Only where fill is required for restoration islandfill acceptable.Landraising is unacceptable when it doesn’t meet thecriteria. However it would become acceptable if it wasgenuinely required to meet restoration – this wouldnormally be achieved with inert material.Total void space available at the end of 1996, and all isassumed to be available before 2010 is 2.15 mcm(permitted) on inert sites, 1.55 mcm on non-inert sites,with a further potential for 5.02 mcm on inert sites and1.40 mcm on non-inert sites, giving a total of 10.12 mcm.

Landfill has a continuing but diminishing role to play inwaste disposal and will be considered as the lastalternative – support is given to the waste hierarchy.Large construction projects generate significant levels ofinert rocks and soils. Where appropriate the materialshould be reused on site or adjacent to it duringrestoration. Where it is not possible for reuse on site oradjacent to the site, the high value of the material forrestoration should be recognised – and used for thispurpose.

London should aim for regional self-sufficiency and aim for75% of waste by 2010, 80% by 2015 and 85% by 2020to be treated/disposed of within the region.

Mayor will promote waste minimisation and the re-use,recycling and composting of waste and reduction oflandfill disposal. Emphasis placed upon increasing use ofnew and emerging technologies in preference toincineration and a declining reliance on landfill.

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The Essex and Southend Waste Local Plan (adopted 2001)

Kent Waste Local Plan (adopted 1998)

The London Plan (adopted 2004)

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Adams Hendry Excavated Materials and Waste Management Strategy : Volume 2 - Appendix A

Policy No.

4A.2

Paragraphs4.5-4.10

Policy 4C.14and Policy4C.15

Policy Thrust

Spatial Policies forWaste Management

Planning for Wastesupporting text

Freight Uses on theBlue Ribbon Networkand SafeguardedWharves on the BlueRibbon Network

Comments

This policy considers the thrust of UDP policies inimplementing the Mayor’s Waste Management Strategy,proximity principle and need to plan for all waste streams. l Safeguard existing waste management sitesl Identify site for new facilities e.g. recycling demolition

wastel Support developments supporting manufacturing

related to recycled wastel Where waste cannot be dealt with locally promote

facilities with good rail/river accessl Forecast in UDPs the total amount of waste to be

imported/exported

Boroughs should co-ordinate to identify sites for wastedisposal.London currently produces 17m tonnes of waste per yearin total. It is estimated that London currently manages60% of its own waste, taking account of total wastearisings. In 2001, 6.1m tonnes are construction/demolitionwaste were produced, of which 2% were disposed of atlandfill, 81% recycled and 17% were disposed of by othermeans.

It is an aim of the plan to promote the efficient use ofwaste, reduction in amounts generated and to promoteincreased recycling. There will be a generalencouragement for new facilities, including inert wasterecycling plants and composting etc.

The management of waste will be through the proximityprinciple, however where movement is required priorityshould be given to those where movement by rail or riveris possible.It should be the overall aim to reduce landfill and phase itout when new waste management facilities aredeveloped. This is especially necessary as theneighbouring regions are looking towards self-sufficiency,which will limit the ability to landfill London’s waste. Although the Plan does not specifically mention thetransport of waste, it does highlight the importance ofusing the River Thames for transportation (Policy 4C.14),and the safeguarding of wharves for freight relatedpurposes (Policy 4C.15).

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The London Plan (adopted 2004)

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Adams Hendry Excavated Materials and Waste Management Strategy : Volume 2 - Appendix A

Policy No.

Para. 29.1and 29.4

Policy G32

Policy G30

PolicyWAS1A

Policy 1.2andsupportingtext

Policy 2.10andsupportingtext

Policy TR25

Para. 2.1

Para. 1.77

Policy SD9and SD12and paras.1.80-1.81

Policy Thrust

Waste

Waste re-use andrecycling

Waste Strategy

Waste minimisation/recycling

EnvironmentalResources and Waste

Waste Minimisationand Management

Movement of Goodson Waterways

Strategic Policy Aims

Waste Management

Development andConstruction Waste

Comments

Waste must be dealt with efficiently, to reduce theenvironmental impact associated with its transfer,processing, storage and disposal. No sites have beenidentified as suitable for new landfill facilities within theBorough.The Council will encourage the re-use of materials, therecovery of resources from waste and the re-use andrecycling of building materials.

Waste management development proposals will beconsidered with the national sustainable developmentcontext and the principle of BPEO, waste hierarchy andproximity principle.It is the Council’s aim to minimise the overall generation ofwaste within the Borough and to increase the overall levelof recycling.

The Council will promote a pattern and form ofdevelopment which minimises waste. The councilsupport the ending of London’s outflow of waste fordisposal by landfill by 2010, through waste reduction,reuse and recycling, and the most sustainable transportmodes for the movement of waste.This Policy seeks to promote the efficient use and reuseof materials in order to minimise the generation wastegenerally, through more efficient sites, greater recyclingand reuse of materials.

The Policy also promotes the transport of waste by canaland railway in order to protect the environment, withsidings, jetties and wharves protected for this purpose.

In relation to building and demolition materials, theCouncil will promote their re-use rather than disposal.

This Policy encourages finding suitable sites for wastemovement.

It is an overall aim of the plan to reduce the volume ofwaste.The Council promotes the waste management hierarchyand aims for waste minimisation, with the aim of regionalself-sufficiency. The Plan promotes the re-use and recycling ofconstruction waste on site, with noise, dust and transportimpacts minimised.

The Plan also identifies that London supplies very little of itaggregates for the construction industry and a need forgreater recycling of waste. Also, there is a desirability toretain existing rail depots for the transport of aggregatesover long distances to minimise road traffic.

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LOCAL PLANNING POLICY

Barking and Dagenham Unitary Development Plan (adopted 1996)

Bexley Council Unitary Development Plan (adopted 2004)

Ealing Unitary Development Plan: The New Plan for the Environment (adopted 2004)

Camden Unitary Development Plan (adopted 2000)

Camden Unitary Development Plan: Revised Deposit Draft (2004)

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Policy No.

PolicySTRA35

Para. 9.160and 9.190

Para. 9.171

Paras,9.172-9.175and PolicyENV11

Para. 9.160

Policy SE4

Para. 5.29and PolicyE13

Para. 4.115Policy EN19Aand Para.4.121

Policy Thrust

Waste Managementand Recycling

Construction Waste

Waste Collection andTransfer

Future WasteManagement

Construction Waste

Waste Disposal

Waste HierarchyRecycling ofDemolition Waste

Comments

This Policy promotes the reduction of waste, the reuseand recycling of materials, the recovery of energy andmaterials from waste, and its eventual treatment anddisposal by the best practicable environmental means.The Plan acknowledges that there is a significant amountof construction waste in the Borough. The Plan promotesthe re-use and recycling of waste where possible.This paragraph acknowledges that there are no sites forlandfill or incineration within the Borough and no sitesproviding plant for the recycling of construction anddemolition waste. This Policy promotes the waste hierarchy, to reduce thelevel of landfill and promote re-use, recycling, compostingetc as more preferable options.

The Plan acknowledges that there is a significant amountof construction waste in the Borough. The Plan promotesthe re-use and recycling of waste where possible.

This Policy aims to reduce the generation of waste and toencourage re-use and recycling.The Plan promotes the waste hierarchy, to determine themost sustainable method of waste disposal, with wastedisposal being the final option.

The Plan also promotes the proximity principle as indetermining the waste disposal location, where waste hasto be transported it should be most the most sustainablemeans and encourages movement by rail and rivertransport to minimise environmental impact.

The Council promotes the use of the waste hierarchy.The Council promotes the recycling/reuse of demolitionwaste wherever possible, where this wouldn’t causesignificant adverse local impact. This will assist in therequirement for primary and secondary aggregates andthe need for material going to landfill.

Applicants would be expected where possible andfeasible to transport waste by rail or water.

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City of Westminster Unitary Development Plan (adopted 1997)

City of Westminster draft replacement Unitary Development Plan (2004)) This Plan was approved for adoption by the Council inDecember 2004, but the Secretary of State has issued a Direction relating to affordable housing, which prevents this Plan from being adopted.

Greenwich Unitary Development Plan: Second Deposit Plan (2004)

Hammersmith and Fulham Revised Unitary Development Plan (adopted 2003)

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Policy No.

Policy MDW1

Policy MDW5

Policy MDW6

PolicyMDW12

PolicyMDW13

PolicyMDW16

Policy MIN19

Policy MIN21

MIN22

MIN24

STRAT 52

PU15

Policy Thrust

Minerals and WasteDisposal

Use of agricultural landfor waste disposal

Transport implicationsof landfill sites

Importation/Distribution ofaggregatesWaste Recovery/Recycling

Landfill sites

Disposal of Category AWaste

Impacts of landfill onhydrology

Siting of Landfill sites

Access to MineralsSites

Reuse of DemolitionMaterials

Comments

When considering the location and operation of landfillsites, the environment and public amenity will besafeguarded.The deposit of waste in agricultural land will not bepermitted unless the land would benefit from being raised.In these circumstances only inert waste would beapproved for deposit.When considering traffic implications of landfill sites, theeffect on the roads and amenity of residents in the vicinityof the site and along the access routes should beconsidered.Whilst not stated in context of landfill/waste disposal, theuse of rail/water for the importing/distribution ofaggregates is promoted.Waste recycling/recovery is promoted as an alternative towaste disposal, only where there is no conflict with thecountryside, environment and transport policies.The Council will only allow landfill at identified sites in thePlan.

The Council will promote he use of category A waste forthe restoration of sand and gravel pits. The Councilrecognises that clean inert material can be used toimprove the quality of existing derelict or damaged land tosecure agricultural improvements.The Council will seek assurances from applicants thatthere will be no impacts on the hydrological systems of anarea from landfill – this will need to be monitored.Landfill sites will not be permitted within 60m of a school,residential property or hospital, or within 15m of any otherbuildings.Although not specified in relation to waste sites, theCouncil promotes good access to the primary roadnetwork for aggregates sites

This Policy supports the ‘proximity principle’, wastereduction, the maximisation of recycling and the bestpracticable environmental options for non-recyclableresidual waste.This policy encourages the re-use of constructionmaterials in development schemes.

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Hillingdon Unitary Development Plan (adopted 1998)

The Royal Borough of Kensington and Chelsea Unitary Development Plan (adopted 2002)

Havering Unitary Development Plan (adopted 1993)

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Policy No.

Para. 3.141

Para. 3.149

Policy EQ58

Policy KR25

Policy KR27

Policy KR28

Policy MIN27

Policy U7

Para. 3.7

Policy ENV12

Policy ENV13

Policy Thrust

Proximity Principle

Land filling

Land filling

Waste

Waste Reduction

Waste Handling

Rail Access toConstruction Sites

Waste Disposal andRecyclingWaste Transport

Recycling ofConstruction Waste

Waste ManagementFacilities

Comments

The Council promotes the proximity principle in order toensure that waste is disposed of as close to its source aspossible.Newham doesn’t have sites for tipping of waste, exceptinert waste.Proposals for the tipping of waste and land filling willnormally be permitted where it constitutes tipping of inertwaste materials, where it is part of an agreed scheme forthe reclamation of derelict or contaminated land or is onlyrequired temporarily.

The Council promotes the waste hierarchy in determiningthe BPEO for waste disposal, and the need to tailor thewaste disposal method to the environmentalcharacteristics of the area.The Council promotes waste reduction and theminimisation of waste within major development.When determining waste handling sites and recyclingplant, the Council will consider the proximity principle andalso the effects on the surrounding area; and alsoconsider its proximity to the major road network and/orrail.The Council promotes major construction sites beingserved by rail depots.

This Policy promotes the transfer, disposal and waste onlyin allocated employment areas.This paragraph promotes the siting of waste transfer sitesnext to the river and the transportation of waste by water.

This Policy requires that construction waste is sorted on-site for re-use and recycling, provided adverse impactsfrom noise, dust and transport are minimised. On largesites, the Council willrequire details of working methods and make conditionsand agreements about how the work is carried out.This Policy advocates the disposal of waste using thewaste hierarchy and promotes reuse/recycling of waste inpreference to landfill, the method which is the BPEOoption and proximity principle. It also require access tothe primary road network and uses where appropriate railand water transport.

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Redbridge Unitary Development Plan (adopted 2003)

Tower Hamlets Unitary Development Plan (adopted 1998)

Tower Hamlets Unitary Development Plan: Deposit Plan (2002)

Newham Unitary Development Plan (adopted 2001)