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Anaerobic Digestion Facility Land at Coleshill STW, Warwickshire

Planning Statement June 2013

ANAEROBIC DIGESTION FACILITY AT

COLESHILL SEWAGE TREATMENT WORKS, COLESHILL, WARWICKSHIRE

Planning Application

Supporting Statement

June 2013



Contents

1. INTRODUCTION ........................................................................................................................ 1

2. SEVERN TRENT AND AGRIVERT ......................................................................................... 2

2.1 Severn Trent ........................................................................................................................................ 2

2.2 Agrivert ............................................................................................................................................... 2

2.3 Severn Trent and Agrivert ................................................................................................................... 3

3. SITE DESCRIPTION .................................................................................................................. 4

3.1 The Coleshill Site ................................................................................................................................. 4

3.2 Site Planning History ........................................................................................................................... 5

4. PROPOSED DEVELOPMENT .................................................................................................. 7

4.1 Description of Proposal ....................................................................................................................... 7

4.2 Anaerobic Digestion Process ............................................................................................................... 8

4.3 Hours of Operation ............................................................................................................................. 9

4.4 Town and Country Planning (Environmental Impact Assessment)(England) Regulations 2011 .......... 10

5. PLANNING POLICY APPRAISAL ......................................................................................... 11

5.1 The Statutory Development Plan ...................................................................................................... 11 Warwickshire Waste Local Plan (August 1999) (Saved Policies) ...................................................................... 12 Warwickshire County Council Waste Core Strategy (WCS) (September 2012) (Submission Version) ............. 13 North Warwickshire Local Plan (July 2006) (Saved Policies) ............................................................................ 15 North Warwickshire District Council Local Plan Core Strategy (February 2013) (Submission Version) ........... 16

5.2 Material Considerations .................................................................................................................... 17 European Policy ................................................................................................................................................ 17 National Policy.................................................................................................................................................. 18 Other Relevant Policy and Guidance ................................................................................................................ 25

6. THE NEED FOR THE DEVELOPMENT ............................................................................... 28



6.1 Renewable Energy ............................................................................................................................. 28

6.2 Waste Management .......................................................................................................................... 29

6.3 Anaerobic Digestion .......................................................................................................................... 30

6.4 Environmental Benefits ..................................................................................................................... 32

6.5 Economic Benefits ............................................................................................................................. 33

6.6 Summary ........................................................................................................................................... 33

7. WASTE ARISINGS WITHIN WARWICKSHIRE ................................................................ 34

7.1 WCC Waste Core Strategy Evidence Base .......................................................................................... 34

7.2 Proximity to Waste Sources and Surrounding Waste Arisings ........................................................... 35

7.3 Overprovision in North Warwickshire ............................................................................................... 38

7.4 Summary ........................................................................................................................................... 39

8. ALTERNATIVE SITES ASSESSMENT ................................................................................. 41

8.1 Introduction ...................................................................................................................................... 41

8.2 Waste Arisings................................................................................................................................... 41

8.3 Site Area............................................................................................................................................ 41

8.4 Comparison of Severn Trent sites to other Alternative Sites ............................................................. 41

8.5 Systematic Assessment of Sites ......................................................................................................... 42

Figure 1: Assessment Against Sites Not in the Ownership of Severn Trent ..................................................... 47

Figure 2: Assessment Against Sites in Ownership of Severn Trent ................................................................. 49

9. GREEN BELT ASSESSMENT ................................................................................................. 51

9.1 Assessment of the proposal on the Green Belt .................................................................................. 51

9.2 Characteristics of the Site .................................................................................................................. 52

9.3 Potential Harm to the Green Belt ...................................................................................................... 53 Assessment against Principles of the Green Belt ............................................................................................. 53

9.4 Locational Need ................................................................................................................................ 55



9.5 Wider Environmental and Economic Benefits.................................................................................... 58

9.6 Summary ........................................................................................................................................... 58

10. ENVIRONMENTAL EFFECTS ........................................................................................... 61

10.1 Landscape and Visual Impact ............................................................................................................ 61

10.2 Hydrology .......................................................................................................................................... 62

10.3 Transport .......................................................................................................................................... 63

10.4 Ecology .............................................................................................................................................. 64

10.5 Air Quality and Odour ....................................................................................................................... 65

10.6 Noise ................................................................................................................................................. 65

10.7 Vermin and Birds ............................................................................................................................... 66

10.8 Litter ................................................................................................................................................. 66

10.9 Complaints ........................................................................................................................................ 66

11. CONCLUSION ....................................................................................................................... 67



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1. Introduction 1.1 This statement supports a formal Planning Application submitted by the Applicant,

Severn Trent PLC (hereby referred to as Severn Trent), comprising planning

application forms, ownership certificates, Design and Access Statement, Landscape

and Visual Impact Appraisal, Flood Risk Assessment, Transport Statement,

Ecological Appraisal, Air Quality and Odour Assessment, a Noise Assessment,

drawings and application fee to Warwickshire County Council (WCC). The

submission has been prepared by Severn Trent and Agrivert Ltd (hereby referred to

as Agrivert).

1.2 The application seeks permanent planning permission for the erection and operation

of an anaerobic digestion (AD) facility to process and manage up to 48,500 tonnes of

biodegradable organic waste per annum. The facility will comprise the erection of a

reception building, 5 digestate and storage tanks, site office, weighbridge(s), 2 gas

engines and ancillary equipment at Coleshill Sewage Treatment Works (STW),

Coleshill, Warwickshire. The STW site is located just off Edison Road, immediately

north of Coleshill. The proposed capacity at the AD facility will be met primarily from

commercial and industrial waste sources within 40 miles of the site such as schools,

supermarkets, hotels, restaurants and food manufacturers. Liquid wastes include

compost leachate, waste cooking oils and drinks manufacturing waste. Rainwater

collected from on-site surface water attenuation and the harvesting of rainwater that

falls on the roof of the reception building can also be used in the AD process.

1.3 The provision of the AD plant would allow surrounding local authorities to consider

alternative methods for the treatment of food waste. It is anticipated that food waste

arisings will continue to increase within the immediate area and although a number of

sites have been identified for the treatment of food waste, there is currently

uncertainty about whether these will become operational.

1.4 This proposed AD facility would produce 2.4 megawatts of electricity per year,

remove a significant amount of carbon which would be released in to the atmosphere

should the waste be landfilled and provide a valuable agricultural fertiliser.



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2. Severn Trent and Agrivert 2.1 Severn Trent

2.1.1 Severn Trent Plc. is a FTSE 100 company. They provide and treat water and waste

water in the UK, and internationally, through our two main businesses – Severn Trent

Water and Severn Trent Services. Severn Trent Water is the UK’s second biggest

water company. It serves more than 4.2m homes and business customers in

England and Wales, stretching from mid-Wales to Rutland and from the Bristol

Channel to the Humber. The company delivers almost two billion litres of water every

day through 46,000km of pipes. A further 91,000km of sewer pipes take waste water

away to more than 1,000 sewage treatment works. Severn Trent Water owns and

operates the Coleshill sewage treatment works.

2.1.2 For the second successive year Severn Trent have satisfied almost a quarter of the

electricity consumption of our water and waste water business with renewable energy

generated from their own assets and are on target to increase that to 30% by 2015.

Renewable energy plays a vital role in minimising their net carbon emission by over

100kT/yr and ensuring best value for their customers. The economic and

environmental benefits of increasing renewables whilst at the same time reducing

consumption are compelling and they are ambitious to develop all viable

opportunities. Most of the company’s renewable energy is produced from the

anaerobic digestion of sewage (105 digesters at 35 STW sites; generating

195GMhr/year) but they also generate power from the anaerobic digestion of crop

silage, hydro, micro PV and this year will see the commissioning of our first large

wind turbines. Severn Trent lead the UK in renewable energy production from

anaerobic digestion and are confident that this provides a strong platform for

expanding further.

2.2 Agrivert

2.2.1 Agrivert Ltd offers Anaerobic Digestion, In-Vessel Composting (IVC), and green

waste composting solutions for local authority and commercial organisations. With

over 18 years of experience in the organic recycling business, they provide merchant,

designed, built, financed and operated AD solutions, ‘soup kitchens’, waste feed

systems and de-packaging equipment. Their technology and food waste treatment

services are proven in UK commercial scale applications.



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2.2.2 Agrivert has established expertise and experience in securing finance, designing,

building and operating plants to process almost any volume of organic waste, as well

as being able to create sustainable agricultural/amenity markets for the end product.

Their design concept allows a diverse intake of waste streams, providing flexibility to

their customers. Agrivert’s composting and AD facilities produce a desirable,

sanitised, stable, low odour fertiliser that is Animal By-Products Regulated (ABPR)

and PAS100/PAS110 accredited.

2.2.3 Agrivert operates two PAS110 compliant AD facilities in Oxfordshire. A third AD

facility is currently in construction in Surrey, with a fourth plant planned to begin

construction in early 2014. They also operate two IVC facilities and three green waste

sites.

2.3 Severn Trent and Agrivert

2.3.1 Severn Trent and Agrivert have identified an opportunity to lessen the carbon

footprint of the current operations at Coleshill and reduce the risk around increasing

electricity prices; whilst also capitalising on the availability of excess brownfield land

on their substantial land holding. AD offers a local, environmentally sound option for

waste management which assists the Country in diverting waste from landfill,

reducing greenhouse gas emissions, producing renewable energy which can be used

to power our homes and vehicles and producing a fertiliser that returns valuable

nutrients to the land. The proposed AD facility would be owned by both Severn Trent

and Agrivert, and would be designed, built and operated using the collective and

complimentary expertise of both companies who both have a proven track record in

successfully securing, delivering and operating AD sites.



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3. Site Description 3.1 The Coleshill Site

3.1.1 The proposed AD site (hereby referred to as ‘the site’) is located within Coleshill

Sewage Treatment Works (STW) in Warwickshire, situated immediately north of

Coleshill and 1km to the east of Water Orton (See Location Plan, Section 12). On

average, the sewage works treats 78,000m3 of raw sewage per day from the

equivalent of 251,000 people along the east fringes of the greater Birmingham area

(parts of Solihull, Meriden and Coleshill). This figure may rise up to around

160,000m3 per day during inclement weather.

3.1.2 The overall land holding of Severn Trent at Coleshill extends to 56ha and

incorporates the proposed development site, measuring approximately 3.2ha and

centred on OS grid reference SP 19664 91273. The STW site is bounded to the east

by Coleshill Parkway Railway Station and the Coleshill Rail/Freight Terminal; to the

south by the Birmingham-Leicester railway line, and beyond that the Coleshill

Industrial Estate; to the west by the A446 Lichfield Road and the Birmingham - Derby

railway line; and to the north by the Hams Hall Distribution Park. Running along this

boundary is the outfall channel for treated water from the much larger Minworth STW,

3km upstream, which joins the River Tame at the far eastern end of the Coleshill

STW site.

3.1.3 The site, which is situated wholly in the North Warwickshire Green Belt, is split in two

by the River Tame which runs approximately north-west to south-east. The north part

of the site, 26ha, consists of the Coleshill Sewage Sludge incinerator and open

sludge drying beds. The southern half of the site 30ha is used for the sewage

treatment works.

3.1.4 The site is located within the floodplain, although it does benefit from existing flood

defences which limit the potential for flooding to occur. There are no sites of

ecological significance within close proximity to the site, however the previously

utilised sludge beds to the north of the river and the River Tame itself are both

proposed Local Wildlife Sites (pLWS).

3.1.5 The STW consists of screening equipment for removal of gross solids, grit removal

equipment, sedimentation tanks, aerated tanks to assist biological treatments and

chemical dosing to assist final sedimentation. Treated carrier water is returned to the



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River Tame matching or bettering exacting quality standards prescribed by the

Environment Agency.

3.1.6 Sewage sludge is pumped to Minworth STW for treatment before being recycled to

farmland. This sludge treatment process produces methane gas which is captured

and burnt in Combined Heat and Power (CHP) engines to generate electricity and

provide heat back into the treatment processes. There is also a grit treatment plant

located on the southern half of the site. This plant receives and washes grit from

sewage pumping stations across the area. Screenings removed from raw sewage are

disposed to landfill. Grit is re-used on Severn Trent sites to backfill excavations and

redundant structures.

3.1.7 There are approximately 20 Severn Trent employees based on the site, who are

responsible for operating and maintaining both Coleshill and Severn Trent’s

compliment of around 40 other sewage pumping stations and sewage works

throughout north Warwickshire.

3.1.8 The nearest residential receptors surrounding the site are situated on Board Cottages

0.5km to the west, properties on Gorsey Way 0.6km to the south west, Spring Farm

1.4km to the north west and Blythe Mill 1.4km to the east.

3.2 Site Planning History

The STW site has been in operation since the 1930’s, during this time functional

amendments have been made to the site through both applications for planning

permission or under Severn Trent’s Permitted Development rights. A brief planning

history for the wider sewage treatment works is set out below:

Reference Description

Coleshill Sewage Treatment Works, Coleshill

NW1381/911146 Replacement of Sludge Destruction Plant (SDP) –

Approved 1990

Unknown Temporary access for plant and machinery regarding

river bank stabilisation – Approved 1991



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NW1381/92CM063 Variation of Condition 3 of SDP permission – restricting

importation of sludge and screenings to the site –

Approved 1993

Unknown Blower house and electricity substation and PD

agreement relating to aeration tanks – Approved 1993

NW/1381/95CM021 Building for storage of sludge and screenings adjacent to

the car park at SDP – Approved 1994

N/A Screen house at SDP – Approved 1995

NW1381/98CM034 2 centrifuge and 1 screen building at SDP site –

Permitted Development 1997

N/A Monitoring apparatus at STW site – Approved 1999

PWAOXX/0332/2004/FAP Creation of a wetland habitat on land to the west of the

SDP site adjacent to A446 – Permitted Development

2000

NW1381/05CM001 SET plant at SDP site – Approved 2004

NW1381/06CM014 A sludge building in the area of an existing dust barn and

PD for plant and machinery at Sludge Treatment Works

site – Approved 2005

NW1381/07CM017 Conversion of existing Coleshill SDP in to an Energy

from Waste Installation – Approved 2007



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4. Proposed Development 4.1 Description of Proposal

4.1.1 The proposed development of the site relates to the construction and operation of an

Anaerobic Digestion (AD) Facility. AD refers to the process where organic material is

biologically treated in the absence of oxygen using naturally occurring micro-

organisms to produce biogas, which is used to generate a renewable green energy,

fed into the National Grid; and a nutrient rich bio-fertiliser that can be used as both a

fertiliser and a soil improver. Heat is produced as a by-product, which is partly utilised

on site within the AD process.

4.1.2 The facility would be constructed in an area of the treatment works site that has been

in use since the 1930s, this area consists of storage tanks, hard standing and

roadways. The area is underutilised currently and the site location has been

specifically chosen to ensure that the operations of the wider treatment works site are

not affected by the proposal and that the development is environmentally acceptable.

4.1.3 The proposal would comprise a reception building, measuring approximately 42m x

34m and approximately 13m in height; 5 digestion and storage tanks measuring

approximately 28m in diameter and 16m in height; a 10m high gas flare; 2 gas

engines with a 18.5m exhaust stack; silage storage area; two weighbridges; a site

office/welfare facility and other associated infrastructure.

4.1.4 The proposed AD facility would have the capacity to receive approximately 48,500

tonnes of biodegradable organic waste per annum. It is intended that the majority of

this waste material would be bulked at local waste transfer stations prior to it being

transported in refuse collection vehicles and articulated vehicles to the site. A large

proportion of the waste will be sourced from commercial waste sources such as food

manufacturers, schools, hospitals and supermarkets. Where possible, Severn Trent

will utilise the site at Coleshill to secure any available Local Authority contracts within

Warwickshire and surrounding Counties. It is anticipated that the facility would

generate approximately 76 HGV movements and 6 staff movements per day.

4.1.5 The biogas produced from the waste material is fed through gas engines, which

generate electricity. The electricity is transmitted directly into the National Grid via a

high voltage connection. It is anticipated that the facility will generate in the region of

2.4MW of electricity per annum, which is the equivalent power for approximately



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5,000 households. It is proposed that Severn Trent would utilise a proportion of the

electricity generated for onsite works, in addition to that used for the operation of the

AD facility itself.

4.1.6 Severn Trent are required by the Environment Agency to provide sufficient storage

for the equivalent of 6 months’ worth of digestate. It is proposed to utilise the existing

concrete storage tanks on site which were previous utilised for the storage of waste

waters on the site. These tanks, alongside the single proposed storage tank, will

provide sufficient capacity to provide the required 6 months’ worth of storage. The

open concrete tanks would be covered with an AeroCover which reduces any

potential for odour generation. This has been further assessed within the Odour

Report (See Section 10).

4.2 Anaerobic Digestion Process

4.2.1 Anaerobic digestion is the process by which food waste is biologically treated in the

absence of oxygen. The process is described in detail in Section 4, however a

summary is provided below.

4.2.2 Solid and liquid wastes are delivered to the site in a range of vehicle types and sizes,

including Refuse Collection Vehicles (RCVs), bulkers and tankers. All delivery

vehicles are weighed on the weighbridge and then proceed into the reception

building. The reception building doors are fitted with sensors and therefore

automatically open when they identify an approaching vehicle. The imported wastes

are deposited into a bunker or liquid tank, before the vehicle exits through another

automatic door, again being weighed as it exits the site.

4.2.3 Air from the reception building is extracted and treated through a wet scrubber, which

removes sulphates, and a wood chip and bark biofilter before venting to atmosphere.

This reduces the odour signature prior to release. The waste is processed within

the reception building, involving reducing the particle size and mixing with liquids,

before being pumped into the primary digesters for approximately 40 days, when it is

then pumped into the secondary digesters. It remains within the digesters for

between 50 and 100 days in total, where it is gently heated and stirred to encourage

the digestion process and biogas production.

4.2.4 Energy crop silage is used as a balancing feedstock. This product has properties that

prevent the digestate becoming unstable and the occurrence of crusting or foaming.



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The energy crop also produces high gas yields. It is stored in the silage storage area

and delivered to the silage bunker using a loading shovel or similar as and when

required.

4.2.5 The biogas produced is stored in the void above the digestion mass, and sealed by a

twin membrane roof. The inner roof membrane inflates and deflates as methane

levels rise and fall, while the outer membrane remains static, acting as weather

protection.

4.2.6 The biogas is fed into gas engines, which power a generator to produce electricity.

This power will be used firstly to provide power to the STW site and the excess

generated would be transmitted directly into the National Grid via a high voltage

connection. The gas engine exhaust is piped through a flue, on the outside of the

insulated container housing the gas engine(s). Prior to being fed into the engines the

gas is passed through a carbon filter removing sulphates and carbon impurities which

improves the reliability of the gas engines and reduces emissions.

4.2.7 The digestate end product is used as a replacement to artificial fertilisers, providing

essential nutrients such as potassium, nitrogen and phosphate to the soil. Spreading

of digestate can only occur at certain times of the year and therefore up to 6 months

storage is required on site. When the ground is ready for spreading, the digestate is

pumped into sealed tankers transported to the point of use, where it is applied using

specialised agricultural slurry applicators.

4.2.8 The biodegradable organic waste will be sourced from commercial sources and

available local authority waste within close proximity of the site. The energy crop,

used to stabilise the food waste, will be sourced locally and therefore have minimal

travelling distances.

4.3 Hours of Operation

4.3.1 The AD process, once initiated, will operate continuously, i.e. 24 hours a day.

However, it is anticipated that waste will only be delivered between the following

hours:

• 07:00 to 18:00 Monday to Friday;

• 07:00 to 16:30 Saturdays; and by exception;



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• 08:00 to 16:30 Sundays and Bank Holidays as required.

4.3.2 These hours of delivery are required in order to accommodate the need to deliver

waste collected each working day and to catch up over Bank Holidays.

4.4 Town and Country Planning (Environmental Impact Assessment)(England) Regulations 2011

4.4.1 The proposed development was subject to a request for a Screening Opinion to

Warwickshire County Council on 14 March 2013. On 26 March 2013, an Opinion was

received from Ian Grace, Principal Planner, which advised that the proposed

development is not considered to be EIA development.



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5. Planning Policy Appraisal 5.1 The Statutory Development Plan

5.1.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires

applications for planning permission to be determined in accordance with the

statutory Development Plan unless material considerations indicate otherwise.

5.1.2 The Act further introduced a new system of Development Plans whereby County

Structure Plans will be replaced by regional plans (referred to as ‘Regional Spatial

Strategies’), and where County Councils are required to prepare ‘Minerals and Waste

Development Frameworks’ which will replace the current Minerals and Waste Local

Plans. In the meantime, existing Plans are to be ‘saved’ for a defined period,

pending their replacement by the new style Spatial Strategies and Frameworks.

5.1.3 In the case of this application the relevant development plan documents include:

o Warwickshire Waste Local Plan (August 1999) (Saved Policies)

o North Warwickshire Local Plan (July 2006) (Saved Policies)

5.1.4 Paragraph 216 of the National Planning Policy Framework (NPPF) (March 2012)

provides clarification in relation to the weight that should be attached to planning

policy within emerging local development frameworks. It states that with immediate

effect, decision-takers may also give weight, unless material considerations state

otherwise, to relevant policies in emerging plans according to:

• the stage of preparation of the emerging plan (the more advanced the

preparation, the greater the weight that may be given);

• the extent to which there are unresolved objections to relevant policies (the

less significant the unresolved objections, the greater the weight that may be

given); and

• the degree of consistency of the relevant policies in the emerging plan

to the policies in this Framework (the closer the policies in the emerging

plan to the policies in the Framework, the greater the weight that may

be given).



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5.1.5 Therefore in accordance with Paragraph 216 the following documents also require

assessment:

o North Warwickshire District Council Local Plan Core Strategy (February 2013)

(Submission Version)

o Warwickshire County Council Waste Core Strategy (September 2012)

(Submission Version)

5.1.6 Relevant policies within these documents are set out below:

Warwickshire Waste Local Plan (August 1999) (Saved Policies)

5.1.7 The Waste Local Plan (WLP) covers the plan period 1995-2005. Whilst several of the

policies have now been superseded by guidance within Planning Policy Statement 10

(see below), six policies were retained awaiting the preparation of the Waste Core

Strategy. Three of these policies are relevant to this proposal and are set out below.

5.1.8 Policy 1 (General Land Use) advises that when evaluating proposals for waste

facilities the proposal would be assessed against its ability to make a positive

contribution to re-use and/or recycling and satisfies the proximity principle. It further

advises that permission will not be given where the proposal would cause significant

harm to features of nature conservation interest; give rise to significant risk of

pollution, including potential harm to local features of nature conservation interest;

have a significant adverse visual impact taking in to account the landscape context;

have a significant adverse impact on the character of the locality or amenity of local

occupiers, by reason of odour, noise, dust and/or local visual intrusion, having regard

to the sensitivity of adjoining land uses and the proximity of residential property; give

rise to traffic that would adversely affect highway safety or have a significant adverse

environmental impact when traversing the routes which generated traffic is likely to

take; or would involve significant loss of or damage to agricultural land within Grades

1, 2 or 3a.

5.1.9 A previous decision from the County Council relating to another proposal for

anaerobic digestion assesses the proposal against Policy 9 (Large Scale

Composting) on the basis that the facility would process vegetable waste which is

similar to open windrow composting. The Policy advises that proposals for facilities

managing plant or vegetable waste will be approved in a rural setting, removed from



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towns and villages. It further advises that decisions will have regard to the proximity

principle and will take in to account the source of waste arisings.

Warwickshire County Council Waste Core Strategy (WCS) (September 2012) (Submission Version)

5.1.10 The Warwickshire Waste Core Strategy (Submission Version) was published in

September 2012. The Strategy is currently under examination to assess its

conformity and is anticipated to be adopted in July 2013.

5.1.11 Policy CS1 (Waste Management Capacity) advises that the County Council will

ensure that there is sufficient waste management capacity to meet the level of waste

arisings in the County to meet, as a minimum, the County’s waste targets. It further

advises that when considering development proposals the Council will take a positive

approach to decision making, reiterating the presumption in favour of sustainable

development set out within the NPPF. It further states:

“Planning applications that accord with the policies in the Development Plan (and,

where relevant, with policies in neighbourhood plans) will be approved without delay,

unless material considerations indicate otherwise.

Where there are no policies in the Development Plan which are relevant to the

application, or relevant policies are out of date at the time of making the decision,

then the Council will grant permission unless material considerations indicate

otherwise – taking into account whether:

i) any adverse impacts of granting permission would significantly and demonstrably

outweigh the benefits, when assessed against the policies in the National Planning

Policy Framework and national waste planning policy taken as a whole; or

ii) specific policies in the National Planning Policy Framework, or national waste

planning policy, indicate that development should be restricted.”

5.1.12 The Spatial Waste Planning Strategy for Warwickshire is set out within Policy CS2.

The Policy advises that within these broad locations new waste developments will be

located on the following type of sites; industrial land or estates, sites with existing

waste management use, active mineral or landfill sites, previously developed land,



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land within or adjoining a sewage works, contaminated or derelict land and within

redundant agricultural or forestry buildings.

5.1.13 Paragraph 8.20 sets out potential locations for AD facilities. The table identifies that

land within all of the areas identified in Policy CS2 may be acceptable for AD

proposals.

5.1.14 Policy CS4 (Strategy for locating small scale waste sites) is of particular relevance to

this proposal and sets out the proposed locational criteria for facilities processing less

than 50,000 tonnes of waste per annum. It states that new facilities should be located

in “the following broad locations:

(i) priority to sites within or in close proximity to the primary or secondary settlements;

or 5km of Coventry MUA

(ii) outside these areas only where it is demonstrated that the proposal is better

suited to such locations through providing greater operational, transport,

environmental and community benefits.”

5.1.15 Policies DM1 and DM2 set out the strategies for Protection and Enhancement of the

Natural and Built Environment; and Managing Health, Economical and Amenity

Impacts of Waste Development respectively.

5.1.16 Policy DM1 advises that new developments should conserve and where at all

possible enhance the natural and built environment, through ensuring that there are

no adverse impacts upon natural resources, biodiversity and geodiversity,

archaeology and cultural heritage, landscape, surrounding land users and Green Belt

policies.

5.1.17 Policy DM2 advises that planning permission will not be granted for waste

management proposals which are to the detriment of the local environment, economy

or communities through an exhaustive criterion of potential impacts including noise,

lighting, odour, dust, emissions, contamination, water quantity and quality; and traffic.

It also reiterates that proposals will only be permitted where these impacts are

avoided, compensated or satisfactorily mitigated.

5.1.18 Guidance relating to Sustainable Transport is set out within Policy DM3 which

advises that developers should demonstrate that facilities are sustainable through



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minimising transport distances, minimising the production of carbon emissions and

through demonstration that there are no unacceptable impacts of safety or capacity

of the road network.

5.1.19 Policy DM4 sets out the Council’s principles on the design of new waste

management facilities. The policy states that “The design of waste management

facilities will be required to address the following points:

(i) minimise the proposal's potential contribution to climate change through

minimising carbon emissions, incorporating energy and water efficient design;

(ii) ensure that the development is resilient or adaptable to future climate changes;

(iii) demonstrate appropriate scale, density, massing, height, landform and materials;

(iv) retain and enhance existing landscape features where possible;

(v) provide a minimum of 10% of the energy needs of new buildings through on-site

renewable energy technology; and

(vi) ensure safe vehicle movements”

5.1.20 Strategies for Flood Risk and Water Quality are set out in Policy DM6 which advises

that “Planning permission will not be granted where waste management proposals

would be at risk of flooding or would be likely to increase the risk of flooding

elsewhere. Planning permission will not be granted where waste management

proposals would have a detrimental effect on water quality or achieving the targets of

the Water Framework Directive.”

5.1.21 Given the advanced stage towards adoption of the WCS, policies within the

Submission Version should be provided with sufficient weight. It is anticipated that

the WCS will be adopted whilst this application is being determined. Once the

Strategy has been adopted, policies within the document will supersede those within

the Waste Local Plan.

North Warwickshire Local Plan (July 2006) (Saved Policies)

5.1.22 The North Warwickshire Local Plan was adopted in 2006. In 2009, the Government

Office for the West Midlands provided a list of Saved Policies that remained relevant



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throughout the preparation of the Councils new Core Strategy. Whilst policies within

the Plan do not relate directly to waste developments, the following policies are

considered of significance.

5.1.23 Policies ENV1 to ENV4 (Protection and Enhancement of Natural Environment; Green

Belt; Nature Conservation and Trees and Hedgerows), ENV8 to ENV13 (Water

Resources; Air Quality; Energy Generation and Conservation; Neighbour Amenities;

Urban Design and Building Design) and TPT1 (Transport Considerations in New

Development) are considered to have relevance to the proposed development,

however given the length of time since the adoption of the Plan, the status of the

Waste Core Strategy and the emergence of the NPPF, these Policies are considered

to have negligible weight.

North Warwickshire District Council Local Plan Core Strategy (February 2013) (Submission Version)

5.1.24 The North Warwickshire Core Strategy is currently progressing towards its

examination stage. It is anticipated that the Strategy will be formally adopted in late

2013. Several of the policies within the emerging strategy are of relevance to this

proposal.

5.1.25 Policy NW8 (Sustainable Development) provides a list of criteria which should be

addressed within development proposals. The following sections of this criterion are

relevant to this proposal:

• Be targeted at using brownfield land in appropriate locations and subject to

maintaining a five year housing supply;

• manage the impacts of climate change through the design and location of

development, including sustainable drainage, water efficiency measures , use

of trees and natural vegetation and ensuring no net loss of flood storage

capacity;

• protect the quality and hydrology of ground or surface water sources so as to

reduce the risk of pollution and flooding, on site or elsewhere;



17

• not sterilise viable known mineral reserves; degrade soil quality or pose risk to

human health and ecology from contamination or mining legacy and ensure

that land is appropriately remediated; and

• seek to maximise opportunities to encourage re-use and recycling of waste

materials, both in construction and operation

5.1.26 Policy NW9 advises that “Renewable energy projects will be supported where they

provide a local energy benefit and they respect the capacity and sensitivity of the

landscape and communities to accommodate them. In particular, they will be

assessed on their individual and cumulative impact on landscape quality, sites or

features of natural importance, sites or buildings of historic or cultural importance,

residential amenity and the local economy.”

5.2 Material Considerations

5.2.1 Many policies contained within the statutory Development Plan were adopted many

years ago and as such many have now been superseded or supplemented by

various elements of European, national and local waste and planning policy and

various guidance notes. These various documents all form material consideration

and form part of the need argument for this proposal. These documents are set out

below, in order of level of Governance.

European Policy

Directive 2008/98/EC: Waste Framework Directive

5.2.2 Directive 2008/98/EC establishes a legal framework for the treatment of waste within

EU Member States. It aims at protecting the environment and human health through

the prevention of the harmful effects of waste generation and waste management.

5.2.3 The Waste Framework Directive (WFD) came in to force on 12 December 2008. The

revised WFD collates several previously separated elements of waste legislation in to

a singular Directive. It introduces the principle of the Waste Hierarchy, which advises

that Member States should take measures for the treatment of their waste in line with

the hierarchy. The hierarchy promotes prevention and reuse over recycling, other

recovery (notably energy recovery) and disposal.



18

5.2.4 The WFD promotes a shift away from the ‘proximity principle’ towards the notion of

waste being “recovered in one of the nearest appropriate installations, by means of

the most appropriate methods and technologies” (Article 16(3)).

5.2.5 This proposal would enable locally sourced food waste to be managed at an

appropriate location within close proximity to a large proportion of the waste source.

The development is considered to be in accordance with the requirements in the

WFD and, as explained in the sections below, would meet the requirements of the

waste hierarchy.

National Policy

National Planning Policy Framework

5.2.6 The National Planning Policy Framework (NPPF) was published in March 2012 and

sets out the Government’s planning policies for England and advises how these

policies are expected to be applied. The NPPF provides planning policy for all

development classes with the exception of waste planning uses, paragraph 5 advises

that this will be set out within the National Waste Management Plan for England

(NWMP). A timetable for the preparation of the NWMP is still awaited, however it is

anticipated that the plan will be published in late 2013. Paragraph 5 further states that

until such time as the NWMP is adopted, developments should be determined in

accordance with policies set out within Planning Policy Statement 10.

5.2.7 The following policies set out below are however considered to be of relevance to this

proposal:

o Sustainable Development

5.2.8 Paragraph 14 of the NPPF states that at the heart of the document is a presumption

in favour of sustainable development, it then goes on to state that in terms of decision

making this would mean; approving development proposals that accord with the

development plan without delay; and where the development plan is absent, silent or

relevant policies are out‑of‑date, granting permission unless any adverse impacts of

doing so would significantly and demonstrably outweigh the benefits, when assessed

against the policies in this Framework taken as a whole; or specific policies in this

Framework indicate development should be restricted.



19

5.2.9 Paragraph 17 provides an overview of the 12 key principles that should underpin land

use planning. These include:

• proactively drive and support sustainable economic development to deliver

the homes, business and industrial units, infrastructure and thriving local

places that the country needs;

• take account of the different roles and character of different areas, promoting

the vitality of our main urban areas, protecting the Green Belts around them,

recognising the intrinsic character and beauty of the countryside and

supporting thriving rural communities within it;

• support the transition to a low carbon future in a changing climate, taking full

account of flood risk and coastal change, and encourage the reuse of existing

resources, including conversion of existing buildings, and encourage the use

of renewable resources (for example, by the development of renewable

energy);

• encourage the effective use of land by reusing land that has been previously

developed (brownfield land), provided that it is not of high environmental

value.

5.2.10 Paragraphs 18 to 149 set out the NPPF’s core policies for delivering sustainable

development. Paragraphs 18 and 19 advise that the Government is “committed to

securing economic growth in order to create jobs and prosperity, building on the

country’s inherent strengths, and to meeting the twin challenges of global competition

and of a low carbon future”, ensuring that “the planning system does everything it can

to support sustainable economic growth. Planning should operate to encourage and

not act as an impediment to sustainable growth. Therefore significant weight should

be placed on the need to support economic growth through the planning system.”

5.2.11 The AD proposal at Coleshill would utilise existing food waste resources to produce

renewable energy and a valuable fertiliser, both of which will assist in removing a

large quantity of gas that otherwise would be released in to the atmosphere annually

contribution to global warming and increased greenhouse gases, assisting the

County in meeting their renewable energy apportionment targets and climate change

objectives.



20

o Design

5.2.12 Paragraph 56 sets out the Government’s aspiration to ensure ‘good’ design, advising

that it “attaches great importance to the design of the built environment. Good design

is a key aspect of sustainable development, is indivisible from good planning, and

should contribute positively to making places better for people.” However Paragraph

60 provides a caveat to the requirement for good design, stating that “planning

policies and decisions should not attempt to impose architectural styles or particular

tastes and they should not stifle innovation, originality or initiative through

unsubstantiated requirements to conform to certain development forms or styles. It is,

however, proper to seek to promote or reinforce local distinctiveness.”

5.2.13 The proposed site has been designed to ensure it can meet the required operational

standards to receive waste deliveries whilst ensuring that the operations of the AD

facility do not impact on the continued operation of the sewage treatment work site.

The proposed reception buildings and tanks have been designed to meet their

operational requirements, to reflect the scale and mass to the surrounding industrial

units and to ensure that the proposal would not have a detrimental impact on the

appreciation of the Green Belt from surrounding viewpoints.

o Green Belt

5.2.14 The NPPF advises that the Government attaches great importance to Green Belts.

Paragraphs 79 to 92 set out the NPPF’s policies for protection of Green Belt Land.

Paragraph 80 sets out the five purposes of the Green Belt, these are:

• to check the unrestricted sprawl of large built-up areas;

• to prevent neighbouring towns merging into one another;

• to assist in safeguarding the countryside from encroachment;

• to preserve the setting and special character of historic towns; and

• to assist in urban regeneration, by encouraging the recycling of derelict and

other urban land.

5.2.15 Paragraph 87 reiterates previous Green Belt policy set out within the superseded

Planning Policy Guidance 2: Green Belts and provides a definition for inappropriate



21

development in the Green Belt. The paragraph states that “inappropriate

development is, by definition, harmful to the Green Belt and should not be approved

except in very special circumstances.”

5.2.16 However, Paragraph 89 provides a definitive list of exception by which the

construction of buildings within the Green Belt would not constitute inappropriate

development, these exceptions include:

• buildings for agriculture and forestry;

• the extension or alteration of a building provided that it does not result in

disproportionate additions over and above the size of the original building;

• the replacement of a building, provided the new building is in the same use

and not materially larger than the one it replaces;

• limited infilling or the partial or complete redevelopment of previously

developed sites (brownfield land), whether redundant or in continuing use

(excluding temporary buildings), which would not have a greater impact on the

openness of the Green Belt and the purpose of including land within it than

the existing development.

5.2.17 In this instance, Paragraph 91 is particularly relevant to this proposal. The paragraph

advises that in the case of developments for many renewable energy projects, the

development will comprise inappropriate development and as such developers will

need to demonstrate very special circumstances if projects are to proceed. The

paragraph goes on to state that “Such very special circumstances may include the

wider environmental benefits associated with increased production of energy from

renewable sources.”

o Climate Change

5.2.18 The NPPF sets out the Governments belief that “planning plays a key role in helping

shape places to secure radical reductions in greenhouse gas emissions, minimising

vulnerability and providing resilience to the impacts of climate change, and

supporting the delivery of renewable and low carbon energy and associated

infrastructure (Paragraph 93).” It further advises that it believes that this is central to

the economic, social and environmental dimensions of sustainable development.”



22

5.2.19 Paragraph 98 advises Local Authorities that when determining applications for

renewable and low carbon energy proposals, they should not require applicants for

energy development to demonstrate the overall need for renewable or low carbon

energy and also recognise that even small-scale projects provide a valuable

contribution to cutting greenhouse gas emissions; and approve the application if its

impacts are (or can be made) acceptable.

o Natural Environment

5.2.20 Paragraph 109 advises that the planning system should contribute to and enhance

the natural and local environment through:

• protecting and enhancing valued landscapes, geological conservation

interests and soils;

• recognising the wider benefits of ecosystem services;

• minimising impacts on biodiversity and providing net gains in biodiversity

where possible, contributing to the Government’s commitment to halt the

overall decline in biodiversity, including by establishing coherent ecological

networks that are more resilient to current and future pressures;

• preventing both new and existing development from contributing to or being

put at unacceptable risk from, or being adversely affected by unacceptable

levels of soil, air, water or noise pollution or land instability; and

• remediating and mitigating despoiled, degraded, derelict, contaminated and

unstable land, where appropriate.

o Status of Existing Planning Policy

5.2.21 The status of emerging planning policy is particularly pertinent in this proposal given

the short timetable for the adoption of the new development plan documents and the

imminent revocation of the RSS.

5.2.22 Paragraph 214 of the NPPF advises that for 12 months from the day of publication,

decision-takers may continue to give full weight to relevant policies adopted since

2004 even if there is a limited degree of conflict with this Framework. It then goes on

to explain within paragraph 215 that “in other cases and following this 12-month



23

period, due weight should be given to relevant policies in existing plans according to

their degree of consistency with this framework (the closer the policies in the plan to

the policies in the Framework, the greater the weight that may be given).”

o Status of Emerging Planning Policy

5.2.23 The status of emerging policy is also pertinent to this proposal, given that the

development plan documents are now at submission stage and therefore carry

increased weight in the decision making process.

5.2.24 Paragraph 216 of the NPPF provides clarification in relation to the weight that should

be attached to planning policy within emerging local development frameworks. It

states that with immediate effect, decision-takers may also give weight, unless

material considerations state otherwise, to relevant policies in emerging plans

according to:

• the stage of preparation of the emerging plan (the more advanced the

preparation, the greater the weight that may be given);

• the extent to which there are unresolved objections to relevant policies (the

less significant the unresolved objections, the greater the weight that may be

given); and

• the degree of consistency of the relevant policies in the emerging plan to the

policies in this Framework (the closer the policies in the emerging plan to the

policies in the Framework, the greater the weight that may be given).

Planning Policy Statement 10: Planning for Sustainable Waste Management

5.2.25 Planning Policy Statement 10 (PPS10) sets out the Government’s policy on waste

planning. The statement reiterates Government’s objectives to move the

management of waste up the ‘waste hierarchy’ through sustainable waste

management and identifies the planning system as playing a pivotal role in the

adequate and timely provision of new investment in waste management facilities. As

stated earlier PPS 10 remains extant policy until such a time as the National Waste

Management Plan for England is published.

5.2.26 It advises (Paragraph 3) that local authorities should prepare and deliver strategies

which:



24

• help deliver sustainable development through driving waste management up

the waste hierarchy, addressing waste as a resource and looking to disposal

as the last option, but one which must be adequately catered for;

• provide a framework in which communities take more responsibility for their

own waste, and enable sufficient and timely provision of waste management

facilities to meet the needs of their communities;

• help implement the national waste strategy, and supporting targets, are

consistent with obligations required under European legislation and support

and complement other guidance and legal controls such as those set out in

the Waste Management Licensing Regulations 1994;

• help secure the recovery or disposal of waste without endangering human

health and without harming the environment, and enable waste to be

disposed of in one of the nearest appropriate installations;

• reflect the concerns and interests of communities, the needs of waste

collection authorities, waste disposal authorities and business, and encourage

competitiveness;

• protect green belts but recognise the particular locational needs of some

types of waste management facilities when defining detailed green belt

boundaries and, in determining planning applications, that these locational

needs, together with the wider environmental and economic benefits of

sustainable waste management, are material considerations that should be

given significant weight in determining whether proposals should be given

planning permission;

• ensure the design and layout of new development supports sustainable waste

management.

o Unallocated Sites

5.2.27 Paragraph 24 advises that development proposed on sites that have not been

identified, or are not located in an area identified, in a development plan document as

suitable for new or enhanced waste management facilities should be considered



25

favourably when consistent with either the policies in this PPS; or the waste planning

authority’s core strategy.

o Design

5.2.28 Paragraph 36 advises that “Waste management facilities in themselves should be

well-designed, so that they contribute positively to the character and quality of the

area in which they are located. Poor design is in itself undesirable, undermines

community acceptance of waste facilities and should be rejected.”

Other Relevant Policy and Guidance

The West Midlands Regional Spatial Strategy (January 2008 – May 2013)

5.2.29 The introduction of the Localism Act in 2011 paved the way for the de-centralisation

of planning functions to give local communities a greater say in the future use of land

within their areas. Receiving Royal Assent on 15th November 2011, the Localism Act

enables the Secretary of State to revoke the whole or any part of a Regional Spatial

Strategy (RSS), subject to the completion of a Strategic Environmental Assessment.

The RSS for the West Midlands was formally revoked on 20 May 2013.

5.2.30 Information contained within the evidence base for the production of the RSS does

however remain a material consideration.

Overarching National Policy Statement (NPS) EN-1

5.2.31 Whilst directly applicable to projects determined under the Planning Act 2008 by the

Infrastructure Planning Commission (IPC) (now National Infrastructure Planning),

NPS EN-1 is a material consideration for any application determined under the Town

and Country Planning Act 1990. The NPS reiterates the Government’s commitment

to sourcing 15% of the Countries total energy supply by 2020 from renewable energy

sources. It advises that to meet this target significant amounts of new energy

infrastructure will need to be developed in the coming years and that generation

capacity will increasingly include plants powered through the diversion of waste from

landfill.

5.2.32 When read in association with policies within the NPPF it is evident that the proposed

AD facility would provide a small, but nonetheless significant contribution to the larger

energy picture and therefore plays a role in providing energy stability and security.



26

Waste Strategy for England 2007

5.2.33 The Waste Strategy 2007, which reiterates Article 5 of the European Landfill

Directive, seeks to encourage much greater consideration of waste as a resource

through increased emphasis on re-use, recycling and recovery of energy from waste

(paragraph 19 of Chapter 1). In addition, the Waste Strategy focuses action on key

waste materials, which have the greatest scope for improving environmental and

economic outcomes.

Government Review of Waste Policy 2011

5.2.34 A Review of Waste Policy in England 2011 was published in June 2011 by the

Department for the Environment, Food and Rural Affairs (DEFRA). The review

recognises that food waste is a valuable resource from which to produce energy, and

that AD can “play an important role as a means of dealing with food waste and

avoiding, by more efficient capture and treatment, the greenhouse gas emissions that

are associated with its disposal to landfill” (paragraph 220).

5.2.35 Paragraph 193 reiterates the Governments long term vision for food waste which

specifically identifies that food waste which arises should be “recognised as a

valuable resource, and is processed to produce renewable energy and a biofertiliser

so that nutrients are returned to the soil” and that no waste should be sent to landfill.

5.2.36 The Review then goes on to state that “Our evidence base shows that of the main

options for the treatment of food waste, anaerobic digestion offers the greatest

environmental benefit, followed by composting and then incineration with energy

recovery.”(Paragraph 196)

Anaerobic Digestion Strategy and Action Plan

5.2.37 In July 2009, the Department for Energy and Climate Chance (DECC) and Defra

published the ‘Anaerobic Digestion Strategy and Action Plan’. The Strategy sought to

promote the uptake of AD and facilitate the growth of the industry within England over

the coming years. The Strategy advises that in the majority of cases, the principal

purpose of consigning waste to AD is to recover energy from it. Therefore, in most

cases the treatment of biodegradable waste through AD will be classified as ‘other

recovery’ for the purposes of the waste hierarchy.



27

Publically Available Specification 110 (PAS110)

5.2.38 PAS 110 was published in February 2010. The Specification seeks to ensure that

digested materials are made using suitable inputs and effectively processed by

anaerobic digestion (AD), to ensure that they are retained for sufficient time and to

ensure that the process has been well managed and monitored so as to produce

digested material that meets market needs and protects the environment. It also

ensures that any producer who claims digested material conforms to the specification

shall ensure that it is fit for purpose at all times.



28

6. The Need for the Development 6.1 Renewable Energy

6.1.1 Overarching National Policy Statement EN-1 outlines the Governments desire to

source 15% of the Countries total energy requirement from renewable energy by

2020. The Statement remains technology neutral, identifying throughout that there is

a need for a strategic network of various types of renewable energy development to

meet this target.

6.1.2 The National Planning Policy Framework (NPPF) advises the Governments belief

that “planning plays a key role in shaping places to secure radical reductions in

greenhouse gas emissions, whilst minimising vulnerability and providing resilience to

the impacts of climate change, it also has a role in supporting the delivery of

renewable and low carbon energy and associated infrastructure, which is central to

the economic, social and environmental dimensions of promoting sustainable

development.”

6.1.3 It then goes on to advise that when local authorities are determining applications for

renewable and low carbon energy proposals, they should not require the applicant to

demonstrate the overall need for renewable or low carbon energy proposals and that

they should recognise that even small-scale projects provide a valuable contribution

to cutting greenhouse gas emissions and thus playing a vital role in meeting national

targets. As such it is accepted that any development which produces renewable

energy regardless of its size has a role to play in meeting future energy need and

security.

6.1.4 The now revoked Regional Spatial Strategy for the West Midlands (RSS) previously

set out expectations on the Local Authorities within their catchment area to exploit

opportunities to both mitigate and adapt the worst impacts of climate change (Policy

CC1). It advised that this could be achieved through developing and using renewable

energy; reducing the need to travel; and reducing the amount of biodegradable waste

going to landfill.

6.1.5 The proposal will produce up to 2.4MW of renewable energy and divert

biodegradable organic waste from landfill. It has also been located within close

proximity to available commercial and industrial waste sources, as well as being

excellently positioned to provide available capacity for Local Authorities should it be



29

required. The proposed facility would therefore assist the Local Authority in meeting

their renewable energy apportionment targets.

6.1.6 Notwithstanding the above, where there is a clear and identifiable need for a

development, this can form an extremely important material consideration in the

determination of a planning application. The sections below set out the argument

relating to the need for waste facilities and in particular assess the need and benefits

of anaerobic digestion.

6.2 Waste Management

6.2.1 The Waste Framework Directive (WFD) established a legal framework for the

treatment of waste within EU Member States, which aimed at protecting the

environment and human health through the prevention of the harmful effects of waste

generation and waste management.

6.2.2 The revised WFD collates several previously separated elements of waste legislation

in to a singular Directive. It introduces the principle of the Waste Hierarchy, which

advises that Member States should take measures for the treatment of their waste in

line with the hierarchy. The hierarchy promotes prevention and reuse over recycling,

other recovery (notably energy recovery) and disposal, giving preference to

managing waste further up the hierarchy. The waste hierarchy now forms the basis of

both national and local waste policy and as such when determining proposals for

waste developments, proposals which move the management of waste higher up the

waste hierarchy should be viewed more favourably.

6.2.3 Waste Strategy for England 2007, which reiterates Article 5 of the European Landfill

Directive, seeks to encourage much greater consideration of waste as a resource

through increased emphasis on re-use, recycling and recovery of energy from waste

(paragraph 19 of Chapter 1). In addition, the Waste Strategy focuses action on key

waste materials, which have the greatest scope for improving environmental and

economic outcomes.

6.2.4 Chapter 4 Paragraph 8 of the Waste Strategy 2007 advises that the Government’s

findings suggest significant potential savings in greenhouse gas emissions (in the UK

and elsewhere) can be achieved through greater diversion of certain materials from

landfill, through recycling and energy recovery, over and above current efforts.

Chapter 5 Paragraphs 24 and 25 of the Strategy set out the Government’s desire to



30

encourage AD, because their recent research suggests that it has significant

environmental benefits over other options for food waste (and may be particularly

cost effective for food waste if separately collected).

6.2.5 This vision has also been enshrined within Planning Policy Statement (PPS) 10,

which states within paragraph 3 that local authorities should prepare strategies which

help deliver sustainable development through driving waste management up the

waste hierarchy, addressing waste as a resource and looking to disposal as the last

option.

6.2.6 As stated above, the proposed AD facility would provide 2.4 megawatts of renewable

energy capacity, this equates roughly to enough renewable energy to power 5,000

homes. The net carbon reduction through the AD process equates to the levels of

carbon produced by approximately 70,000 cars, enough to offset the total cars within

North Warwickshire twice over (Source: Office of National Statistics, 2011 Census,

Car or Van Availability QS416EW). The facility would therefore play a small, but

nonetheless significant, contribution to meeting the energy needs of the country and

reducing the country’s reliability on fossil fuels. The renewable energy generation of

the facility is therefore consistent with the aims and objectives of national energy

legislation and policies set out with national, regional and local planning legislation

and policy.

6.3 Anaerobic Digestion

6.3.1 The Energy White Paper published in 2007 acknowledged AD as an emerging

technology that is under developed in the UK. The Paper recognises the potential to

generate renewable energy, not only in terms of electricity but also identifies the

importance of heat and fuel from manures and slurries and biodegradable organic

waste. It further identifies the benefits of mitigating emissions of methane from

agriculture (through reduced dependence on chemical fertilisers) and landfill.

6.3.2 A Review of Waste Policy in England recognised that food waste is a valuable

resource from which to produce energy, and that AD can “play an important role as a

means of dealing with food waste and avoiding, by more efficient capture and

treatment, the greenhouse gas emissions that are associated with its disposal to

landfill” (paragraph 220).



31

6.3.3 Paragraph 193 of the Review reiterates the Governments long term vision for food

waste which specifically identifies that food waste which arises should be “recognised

as a valuable resource, which is processed to produce renewable energy and a

natural biofertiliser so that nutrients are returned directly to the soil” and that no waste

should be sent to landfill. It then goes on to state that “Our evidence base shows that

of the main options for the treatment of food waste, anaerobic digestion offers the

greatest environmental benefit, followed by composting and then incineration with

energy recovery” (Paragraph 196).

6.3.4 In July 2009, DECC and Defra published the ‘Anaerobic Digestion Strategy and

Action Plan’. The Strategy sought to promote the uptake of AD and facilitate the

growth of the industry within England over the coming years. The Strategy advises

that in the majority of cases, the principal purpose of consigning waste to AD is to

recover energy from it. Therefore, in most cases the treatment of biodegradable

waste through AD will be classified as ‘other recovery’ for the purposes of the waste

hierarchy. However, Article 4(2) of the Waste Framework Directive does make

provision for specified waste streams to differ from the waste hierarchy, where

justified by positive life-cycle assessment analysis. In terms of treating food waste,

the use of AD, when taking into account the local economic and environmental

considerations, is considered to provide greater overall environmental benefits than it

would if it was to be recycled.

6.3.5 Agrivert’s AD process utilises combined heat and power to produce renewable

energy in the form of electricity and heat. The facility will produce up to 2.4MW of

electricity which will be fed into the National Grid. In addition, the facility will be self-

sufficient in terms of its power consumption. This facility will, therefore, be able to

contribute to the requirements of national and local planning policy for renewable

energy generation, and will reduce the emissions of greenhouse gases by diverting

biodegradable organic waste (which produces methane when broken down) from

landfill. Furthermore, the overarching Government strategy for the management of

such wastes is through the promotion of AD technologies (an approach enshrined in

national planning policy and through the Anaerobic Digestion Strategy and Action

Plan).

6.3.6 In addition to the benefits created through the production of renewable energy, the

facility will also offset the use of artificial chemical fertilisers with digestate, a product



32

from the AD process. The Anaerobic Digestion Strategy and Action Plan advises that

digestate produced through AD contains nitrogen in a form that is readily available for

crop uptake, and can help reduce reliance on other (industrially produced) sources of

nitrogen. It then further advises that the Government considers that inorganic

phosphate fertilisers (derived from non-renewable sources) will likely become more

expensive as increasing pressures are placed on limited current supplies. The

phosphate content of digestates will thus become increasingly attractive in the short

to medium term.

6.3.7 The digestate produced through AD will be dealt with as a product, rather than a

waste. To achieve this, the digestate must be proven to meet the national end-of-

waste criterion set out in the Waste Framework Directive. In order to meet this

criterion, digestate must accord with PAS110, the quality protocol for digestate

derived through AD. PAS110 ensures that any product produced through the AD

process meets the needs of the market and does not have an adverse impact on the

environment. Agrivert have successfully gained PAS110 at existing AD facilities in

Oxfordshire, where they have also marketed the digestate produced to local farms

surrounding the facilities. Severn Trent and Agrivert will seek to ensure that the

proposed AD plant becomes PAS110 compliant within 12 months of the facility

receiving waste.

6.4 Environmental Benefits

6.4.1 AD provides a completely enclosed waste treatment process. This ensures that any

facets of the process which may have the potential to generate odour, dust and noise

are undertaken within a completely sealed system, managed by a robust odour

management system incorporating a biofilter and alkali scrubber; and undertaken

within an enclosed building with quick reaction doors. These factors ensure that any

odour, noise or dust that is generated through operations within the reception building

is adequately managed at source. Agrivert has a proven track record of operating AD

facilities within close proximity to residential and industrial receptors.

6.4.2 The energy benefits of the proposed AD facility have been set out earlier in this

chapter, however to summarise the proposal would produce 2.4 megawatts of

renewable energy, which equates to enough renewable energy to power 5,000

homes and remove approximately 70,000 cars off the road. The proposed facility



33

would therefore play a small, but significant, part in meeting the country’s climate

change and renewable energy objectives.

6.4.3 The digestate produced through the AD process is a valuable bio-fertiliser, with a

higher rate of first year nitrogen availability than many organic fertilisers. It also

contains valuable sources of potash, phosphate and sulphur. The digestate helps to

replace the nitrogen, phosphorus and potassium removed from the soils during crop

growth, ensuring that soil depletion does not occur. Spreading of digestate is

undertaken in the spring, the late summer and autumn, which coincides with the

cropping windows where nutrients are most required and soil conditions are most

appropriate.

6.5 Economic Benefits

6.5.1 The facility would provide a means of treating locally sourced food waste, diverting

this waste from landfill. As such, the facility would assist local authorities, commercial

and industrial sources to reduce the escalating financial cost of Landfill Tax. In turn,

the savings made through diversion from landfill can be passed down to rate payers

and/or clients.

6.5.2 The Coleshill AD proposal would employ 3 permanent members of staff from the

surrounding area. In addition and where appropriate, local contractors will be

employed during the construction phase of the development.

6.6 Summary

6.6.1 It can therefore be demonstrated that this proposal will provide a significant

contribution to satisfying the demands of national and local waste planning policies in

relation to the need for waste facilities to meet the continued and growing demands

of Warwickshire and surrounding areas. It would increase the rates of recycling and

diversion of waste away from landfill, and the proposal would assist in meeting

National, Regional, and Local renewable energy targets for the reduction of carbon

emissions and renewable energy generation which would play a small, but

nonetheless significant role in meeting current and future energy demand.



34

7. Waste Arisings within Warwickshire 7.1 WCC Waste Core Strategy Evidence Base

7.1.1 Paragraph 3.13 of the West Midlands Waste Treatment Facility Capacity Study:

Phase 2 Future Capacity Study advises that “The projections indicate that, using

waste deposits in 2001 as a baseline, the quantity of recycling and treatment capacity

for industrial & commercial waste will need to increase by almost 90% by 2005 and

will need to double by 2021. This equates to approximately 83 new facilities being

needed by 2005 and 93 by 2021, with about 40% of the new capacity being required

in the metropolitan area and 60% in the surrounding shire area.”

7.1.2 As the County apportionment targets set out within the RSS are now abolished, the

figures set out within the RSS evidence base provide the most accurate

representation of the levels of waste within the County. These figures have also been

utilised as the evidence base for the production of the Warwickshire Waste Local

Plan. The paragraphs below set out the quantitative analysis of this evidence base,

however it should be noted that the prediction of future waste arisings is not a simple

exercise and as such any figures should be viewed as approximations.

7.1.3 The Waste Core Strategy: Waste Background Technical Paper was produced to

inform the preparation of the Waste Core Strategy. The paper provides an analytical

assessment of the waste processed within the County and the future requirements

over the forthcoming 18 years, providing qualitative and quantitative analysis of

municipal waste, construction and demolition waste; commercial and industrial waste

and hazardous waste.

7.1.4 The Strategy sets out the anticipated waste arisings within Warwickshire between

2010 and 2028. During this 18 year period it is anticipated that the County would

produce over 5.5 million tonnes of municipal waste and 11.8 million tonnes of

commercial and industrial waste.

7.1.5 The Paper states (Paragraph 4.56) that th

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