Transformation and Sustainability SHEFFIELD DEVELOPMENT FRAMEWORK CORE STRATEGY SUBMISSION VERSION WASTE MANAGEMENT BACKGROUND REPORT Development Services Sheffield City Council Howden House 1 Union Street SHEFFIELD S1 2SH September 2007 CONTENTS Chapter Page 1. Introduction 1 2. Waste Development Objectives 5 3. Safeguarding Major Waste Facilities 21 4. Provision for Recycling and Composting 31 Appendix A - Delivery of Core Strategy Waste Management policies 43 List of Tables Page 1 Provision for Municipal and Commercial/Industrial Waste 14 1 INTRODUCTION The Context 1.1 This report provides background information and evidence to support the submitted policies for the Core Strategy of the Sheffield Development Framework. 1.2 The Sheffield Development Framework is Sheffield’s Local Development Framework, which the local planning authority is now required to produce. It will contain all of the City’s planning policies and proposals and will replace the outgoing Unitary Development Plan. Further information about the Sheffield Development Framework can be found in the project programme, known as the Local Development Scheme1. 1.3 The Core Strategy is the first of the development plan documents in the Framework. It sets out the overall planning aims and objectives and establishes the broad spatial framework for all the other documents. 1.4 The Core Strategy has been prepared in several stages, based on periods of consultation. These stages were about: Emerging Options Preferred Options Additional Options (for a few issues only) Submission, for final representations and public examination. The Emerging Options 1.5 The Emerging Options were the broad choices for the Core Strategy and they were set out in a separate document2. They were drawn up to enable the Council to consider and consult on all the possibilities early in the process of drawing up the Strategy. The City Council consulted on these options and then decided which to take forward as Preferred Options. The other options have been rejected but this document sets out how they were taken into account and why the Council is proposing the Preferred Options instead. 1 Sheffield Development Framework: The Local Development Scheme. Sheffield City Council (revised October 2006). SDF Local Development Scheme 2006 2 Sheffield Development Framework: Emerging Options for the Core Strategy. (Sheffield City Council, May 2005, SDF Core Strategy Emerging Options 2005. For background to the options, see Chapter 1. -1- The Preferred Options 1.6 The Preferred Options were published3 and consulted on as the ones that the Council was minded to take forward to submission. However, the choice of option and the way it was expressed remained subject to public comment. The Preferred Options document outlined how the Council had arrived at them and the justification for choosing them. It also indicated which Emerging Options had been rejected. In most cases these Preferred Options were taken forward as policies in the draft submitted Core Strategy4. Additional Options 1.7 Further work indicated that there were a few issues to be covered that had not featured in the earlier options consultations and there were some issues that had been considered where a new option needed to be considered. These were set out in the Additional Options Report 5 and consulted on. Submission Version 1.8 Much of the Submission Version follows the approach proposed in the Preferred and Additional Options and takes account of comments made about those documents. However, the opportunity remains in the final period for representations to draw attention to any outstanding matters that would make the submitted document unsound.The soundness of the document will be decided by a Planning Inspector through a process of public examination. 1.9 The Background Reports set out the Council’s evidence for considering that the Core Strategy is sound. They are prepared specifically to help consultees and the Inspector come to a view about the Council’s position. The Core Strategy itself has space only to summarise the reasons for the chosen policies. So, the more detailed background information and analysis there is all found in the Background Reports. 1.10 The Background Reports are not actually part of the Sheffield Development Framework but they clearly contribute to the statutory process of preparing it. The regulations refer to ‘DPD [Development Plan Document] documents’ and these may include: 3 Sheffield Development Framework: Preferred Options for the Core Strategy. Sheffield City Council, (May 2005). SDF Core Strategy Preferred Options 2006 4 Sheffield Development Framework: Core Strategy – Draft for submission to the Secretary of State. Sheffield City Council (September 2007) 5Sheffield Development Framework: Core Strategy – Additional Options. Sheffield City Council (February 2007) SDF Core Strategy Additional Options 2007 -2- “such supporting documents as in the opinion of the authority are relevant to the preparation of the DPD”6 1.11 The Background Reports all fall within this definition. The versions of the Background Reports supporting the submitted Core Strategy have been made available for inspection with the Core Strategy. The Scope of this Report 1.12 This report supports the submitted citywide spatial policies for Waste Management. The chapters are based on each of the issues covered in chapter 12 on Waste Management and they deal with each of the Inspectorate’s soundness tests in turn. Introduction to the Issues 1.13 The waste content of the Core Strategy comprises a set of three policies designed to provide a strong framework that links higher tier policies to local regulatory and allocation documents in the rest of the Local Development Framework. The over-arching approach to achieving more sustainable waste management is covered in policy SW1 – Waste Development Objectives. This shows how the city intends to move waste management up the ‘waste hierarchy’ 7 in providing for future waste arisings. 1.14 The main spatial implications for the city are followed up in two complementary policies. Policy SW2 – Safeguarding Major Waste Facilities, establishes the longterm use of two disposal facilities that are key elements of the overall waste strategy. Other provision that is significant for achieving the citywide aim of increasing recycling is covered in policy SW3 – Provision for Recycling and Composting. 1.15 The three core policies will be supported by further policies in the City Policies document that will inform decisions about planning applications. Any firm proposals for major new waste infrastructure will be allocated sites in the City Sites document, which is intended to be reviewed on a more frequent basis than other documents in the Local Development Framework. 6 The Town and Country Planning (Local Development) (England) Regulations 2004, Regulation 24(4) The ‘waste hierarchy’ is a conceptual framework that prioritises reduction, re-use, recycling and composting and energy recovery solutions, in that descending order, with disposal to landfill being seen as a last resort. 7 -3- -4- 2 WASTE DEVELOPMENT OBJECTIVES Introduction 2.1 Clear policy objectives are needed at the local level in planning for future capacity and the distribution of waste facilities, and they should be supported by careful analysis of the available data and development opportunities. Those policy objectives need to show alignment with relevant national planning policy, reflect the contribution to delivering the Regional Spatial Strategy (RSS) and integrate with other relevant local strategies specifically the city’s Community Strategy and the current Municipal Waste Strategy8. Specific targets that underpin the approach need to be formulated and monitored to keep the strategy on track. The following policy has been submitted to address these requirements. Policy SW1 2.2 The City’s waste will be managed more sustainably by: (a) encouraging less consumption of raw materials through the reduction and re-use of waste products; and (b) making the best use of existing landfill capacity and only using the city’s Landfill Allowance Trading Scheme allocations when disposing of organic municipal waste; and (c) restricting consent for additional landfill to those cases where local provision can be justified; and (d) meeting the national staged targets for recovering value from municipal waste by utilising the existing energy-from-waste plant and developing services and facilities to meet agreed performance targets for recycling or composting household waste; and (e) permitting a range of additional treatment facilities, mainly in industrial areas, sufficient to meet the regional apportionment for commercial and industrial waste together with requirements for other waste streams where the city is best placed to meet local and wider needs; and (f) avoiding the unnecessary use of greenfield land when identifying suitable sites/ areas and permitting other waste development. Municipal waste includes household waste collected from kerbside and ‘bring’ sites together with other wastes collected by the Council from parks, trade premises and fly-tipped sites. 8 -5- Policy Background (Soundness Test 4) National Policy 2.3 National planning policy on waste management in England is set out in Planning Policy Statement 10: Planning for Sustainable Waste Management9. This forms part of the national waste management plan for the UK. It’s policies complement other national planning policies and has to be read in conjunction with other Government policies for sustainable waste management in particular those set out in the national waste strategy, Waste Strategy for England 200710. A companion guide to PPS1011 provides practical guidance on implementing waste policies. 2.4 Paragraph 16 of PPS 10 requires that a core strategy should set out policies and proposals for waste management that ensure sufficient opportunities for the provision of waste management facilities in appropriate locations, including for waste disposal, for a period of at least 10 years after its adoption. It should accomplish this with reference to the waste component of RSS and any relevant municipal waste strategy. In a note prepared by the Department of Communities and Local Government appended to guidance on LDFs by the Planning Inspectorate12, authorities are encouraged to prepare core strategies that are both spatial and bespoke to add value to higher tier waste policies. 2.5 It is considered that submitted policy SW1 fulfils the requirements of soundness test 4 being part of a spatial plan that is consistent with the relevant provisions of national planning policy on waste management. The following paragraphs support this view. 2.6 Clauses (a) to (d) show how the city positively supports the overall objective on waste within the Government’s strategy for sustainable development by moving waste up the ‘waste hierarchy’, addressing waste as a resource and minimising, but meeting, landfill disposal needs (paragraph 1 of PPS10). Read as a whole, the policy provides part of the spatial framework ensuring that there will be sufficient opportunities in appropriate locations taking account of the local context (paragraph 2 of PPS10). 2.7 In particular, clauses (b), (d) and (e) indicate how sites and areas will be retained or identified, and establish some criteria and broad locations for subsequent designation or allocation in other development plan documents (paragraph 17 of PPS10). Clause (f) has been drafted to be consistent with the national priority 9 Planning Policy Statement 10: Planning for Sustainable Waste Management, ODPM, (July 2005). Waste Strategy for England 2007. DEFRA, (May 2007). 11 Planning for Sustainable Waste Management: Companion Guide to Planning Policy Statement 10. DCLG, (2006). 12 Local Development Frameworks: Lessons Learnt Examining Development Plan Documents. The Planning Inspectorate, (June 2007). 10 -6- given to using previously developed land in identifying suitable waste management facilities (paragraph 21ii of PPS10). 2.8 Finally the policy demonstrates consistency with the Key Planning Objectives required of planning strategies in that it provides a framework for the city to meet most of its needs for locally generated waste whilst also making a strong contribution to achieving national recovery targets for the municipal waste stream (paragraph 3 of PPS10). Regional Policy 2.9 The Yorkshire and Humber Plan (RSS)13 has been prepared in draft and examined by a Panel. The Panel have issued their recommendations and the Government was due to report their proposed changes to the strategy in September 2007. Adopted regional waste policies in the strategy published in December 2004 are considered to be deficient and they have been significantly revised in the current draft. Despite some concerns about compliance of the new waste policies (ENV 12-14) with PPS10, the Panel has recommended on balance that they should be adopted as part of the RSS subject to some further revisions. Those policies are therefore considered to be the most appropriate ones to use at present in testing general conformity to the regional waste plan. 2.10 Policy SW1 conforms with regional waste management objectives in that it gives support to waste minimisation (policy ENV12A) and it shows how the management of municipal and commercial/industrial waste streams will be moved up the ‘waste hierarchy’ (policy ENV12C). In particular, the policy commits to meeting agreed performance targets for recycling/composting household waste and achieving the national staged targets for recovering value 14 from municipal waste which have recently been raised to 75% by 2020 in the new national waste strategy. 2.11 SW1 also conforms to policy ENV13 on the provision of waste management facilities in that it uses the proposed regional apportionments for tonnages of municipal and commercial/industrial waste as benchmarks for its spatial policy. In line with the Panel Report15 and the Companion Guide to PPS10 (paragraph 18 of Annex D) the policy uses mid-points of the ranges given in the revised Waste Tables at Annex C1 and C2. For comparison purposes, and as explained below, the policy also tests available capacity against a lower figure for growth in municipal waste, that is more consistent with the new national waste strategy. Table 12.1 of the submitted Core Strategy sets out an assessment that compares the apportioned waste streams against locally available capacity to demonstrate 13 The Yorkshire and Humber Plan, Draft for Public Consultation. Yorkshire and Humber Assembly, (December 2005). 14 Recovering value includes recycling, composting and energy recovery. 15 Chapter 6 of Volume1 of the Report of the Panel, Examination in Public of the Yorkshire and Humber Plan, (March 2007). -7- that there is currently an equivalent 10 year supply. The assessment takes account of the contribution made by committed and existing waste facilities and their anticipated lifespan. The table shows tonnages that will be passing through the various management methods in a way that conforms to the desired minimum recovery targets set out in policy ENV13. 2.12 Finally, SW1 also conforms to locational criteria in policy ENV14E in that it effectively prioritises the use of previously developed land when assessing the suitability of waste management sites. Sub-Regional Policy 2.13 There are no formal sub-regional documents that have a bearing on this issue. Section 2.52 refers to some advice from the Regional Assembly relating to capacity in licensed landfills in the sub-region that the policy has taken into account. Other Sheffield Policies 2.14 The Council approved a Household Waste Strategy16 covering the period 20032010 (May 2003) that deals with the management of waste for which it is directly responsible. Policy SW1 has been informed by that document and a subsequent report to the Council’s Cabinet in August 2004 relating to its implementation. Given the level of investment already committed to waste infrastructure, there are no significant land use requirements arising from the strategy apart from the need for an additional Household Waste Recycling Centre17 (HWRC) to improve the pattern of centres in the city (see section 4). 2.15 Owing to its investment in recycling and composting and the development of a new and larger Energy from Waste plant, the Council will be able to accept DEFRA’s target tonnages for limiting the landfill of biodegradable waste in the city for the duration of the Landfill Allowance Trading Scheme 18(LATS). Clause (b) of policy SW1 takes account of this aspect of the operational waste strategy. 2.16 The policy is also based on the intention that a target rate of 30% for recycling /composting will be achieved during the plan period and that this will be improved further by extending bring facilities including an extra HWRC. 16 A Household Waste Strategy for Sheffield 2003/2010. Sheffield City Council, (May 2003). A ‘Household Waste Recycling Centre’ is a facilitiy where the public can deliver their household waste, including garden waste and oversized items, for recycling or disposal. They are sometimes also referred to as civic amenity sites. 18 LATS is a trading scheme for municipal waste, operational since April 2005, and designed to help waste authorities to contribute effectively to achieving our national obligations under the European Landfill Directive. 17 -8- Relationship to City Strategy (Soundness Test 5) 2.17 The Core Strategy of the SDF provides the spatial expression of the City Strategy for Sheffield19 which is the name being used for the local statutory Community Strategy. The partnership responsible for the strategy has agreed five themes for strengthening the City in an approved updated version that looks forward to 2010. Under the ‘Environmental Excellence’ theme there is a commitment to pursuing strategies for sustainable energy production and waste management that contributes to a reduced ecological and carbon footprint for the city. The existing central district heating scheme powered by the Energy from Waste plant is strongly promoted in the strategy. Policy SW1 has regard to this priority by demonstrating how critical it is to achieving desired recovery targets for municipal waste in the city. Clause (a) of the policy will assist with the aim of meeting carbon reduction targets by encouraging more waste reduction and re-use options. Consistency with Other Planning Documents (Soundness Test 6) Core Strategy Objectives 2.18 Waste management objectives have been developed to dovetail with objectives for other spatial planning concerns in the city and they particularly amplify specific core objectives for sustainable use of natural resources. Clauses (a) to (d) interpret the strategic objective S12.4 on the positive use of the ‘waste hierarchy’ and clause (f) shows that waste development will be expected to contribute to objective S12.1 by using previously developed land before ‘greenfield’ land. The policy as a whole provides a positive framework for other core policies on waste for lower level plans and for development management. Adjoining local authorities’ plans 2.19 The policy does not conflict with the known waste content of other development plan documents under preparation in the sub-region, nor with the adopted Derby and Derbyshire Waste Local Plan20. The policy has now been drafted to encourage appropriate development that helps to move waste management up the ‘waste hierarchy’ and should therefore address a concern raised by Derbyshire CC at Preferred Options stage (see section 2.57). 2.20 The text of policy SW1 refers to the long- term contingency of the City possibly having to export some waste for final disposal to landfill sites in the rest of the sub-region. The Regional Planning Body accepts21 that there is around a 20 year supply of landfill based just on licensed space in the sub-region against RSS 19 Sheffield City Strategy 2005-2010, Sheffield First Partnership, (August 2007). Derby and Derbyshire Waste Local Plan, DerbyshireCC and DerbyCC, (March 2005) 21 Revised Waste Data RTAB Document & Strategic Messages, Yorkshire & Humber Assembly, (August 2006) – a submission to the Public Examination of Draft RSS in October 2006. 20 -9- forecast requirements for this management method. No intention has been expressed to revoke the relevant planning permissions and it is assumed that this option of exporting some waste would be available once local capacity is eventually exhausted. Options Considered (Soundness Test 7) 2.21 No core policy on this issue was presented at Emerging or Preferred Options stages on the basis that there was probably little scope to elaborate on objectives already set out in national and regional policy and very limited new land-use requirements were being generated in the Council’s Household Waste Strategy. An option EW1 setting out relevant regulatory principles for waste management was included in the City Policies document at Emerging Options stage. In response to calls for a broader context for the sole proposal to expand the recycling network, that particular option was re-presented as a new Additional (Preferred) Option AW1 – Waste Development Objectives (see below). The submitted policy draws on that option but includes other elements to provide a more distinctive spatial statement on objectives for managing waste in the City. Option a – Define local Waste Management Objectives ( as in submitted policy SW1). 2.22 The strengths of this option are: (a) Supports the sustainable development agenda showing how the management of the city’s waste will be moved up the ‘waste hierarchy’, especially by achieving a high recovery target for municipal waste. (b) Provides an appropriate framework for identifying and designating areas for retained or new waste management facilities in other core policies or subsequent development plan documents. (c) Takes on board the need to ensure sufficient opportunities for facilities to manage forecast waste arisings set out in RSS. 2.23 The weaknesses of this option are: (a) Wider waste streams such as hazardous waste are not specifically covered as spatial guidance has yet to be developed at regional level. (b) Policy has had to be formulated in advance of an anticipated review of the Council’s municipal waste strategy. Option b – Have no local policy on this issue and rely on national/regional policy. -10- 2.24 The strength of this option is that: (a) The City will be expected to take account of national and regional objectives for waste management and these are already quite comprehensive. 2.25 The weaknesses of this option are: (a) There would be no local context for any other core policies. (b) No demonstration of how the City intends to move the management of its waste up the ‘waste hierarchy’. 2.26 As mentioned above, a new preferred option was to be added to the Waste Management chapter to strengthen the strategic thrust. That option, repeated below, sets out some general guiding principles for sustainable waste management practice at the local level. Additional Option AW1 – Waste Development Objectives Waste development will be promoted where: (a) there is a clearly established need for the facilities to cater for locally generated waste or waste from the sub-region that it would be appropriate to manage within the city; and (b) the development accords with the objectives and principles of sustainable waste management and contributes to targets for better management of controlled waste resulting from the Regional Spatial Strategy, national strategy and European Directives; and (c) the facilities are located and designed to prevent significant adverse environmental impacts, pollution risks or danger to public health resulting from the activity. This option had the benefit of linkage to European, national and regional waste targets and incorporation of principles protecting human health and the environment when considering waste development. Although the option received support from various stakeholders it has been rejected and replaced by a more bespoke and spatial policy (SW1) that is more explicit on the objectives that the City will follow in sustainable management of its projected waste arisings. Reasons for the Submitted Policy (Soundness Test 7) 2.27 Having considered meaningful alternatives it is considered that the submitted policy is the most appropriate approach on setting waste management objectives -11- for the reasons given below. All key assumptions that underpin the policy are covered in this section of the report. Planning Reasons – Moving Waste up the ‘Waste Hierarchy’ 2.28 Firstly, the policy strongly supports the sustainable development agenda set out at national and regional level by showing that waste will be treated as a resource, and that the City’s waste will be managed in a way that moves it up the ‘waste hierarchy’. 2.29 The Government is now placing a stronger emphasis on waste prevention as part of the drive to tackle climate change. Clause (a) embraces this stance through encouragement for waste reduction and re-use. The planning system cannot exert a strong influence in this area but this part of the policy can provide a platform for other initiatives such as possible obligations for developers to provide home composters or maximise the on-site management of demolition waste. 2.30 The current level of landfilling of municipal waste in Sheffield is relatively low as much of it is already being diverted by a modern Energy from Waste plant together with a supporting Material Recovery Facility. Clause (b) recognises that the Council will therefore be able to keep to the target tonnages that DEFRA has imposed for limiting the landfill of biodegradable waste until the end of the current LATS period in 2020. 2.31 There will still be a continuing need for landfill in the City to deal with the final disposal of residual material including commercial/industrial waste that cannot be treated further and this must be adequately catered for. The landfill site at Parkwood Springs is the only remaining open-gate facility left in the City and there are very few opportunities for any significant new landfill developments given the physical and environmental constraints in the area. Clause (b) therefore acknowledges that it is important to make the best use of this site as part of a responsible and balanced approach on waste management. Policy SW2 emphasises the importance of retaining this particular facility until its consented capacity is used up, and its role in ensuring a 10 years supply to cater for forecast arisings in RSS is covered in section 2.49 below. 2.32 There may be cases where modest provision can be justified in future for landfilling of particular wastes but in view of the capacity available within the city at Parkwood and within the rest of the sub-region, it is appropriate that clause (c) adopts a firm line on restricting further landfill development to minimise the use of this method of last resort. 2.33 The City has achieved statutory recycling/composting targets set for it through the Best Value Performance regime. It is understood that the Government is developing proposals for local authority waste indicators to be included as part of a new local performance framework. The City expects to continue its contribution to this aspect of landfill diversion on the basis that individual recycling rates -12- above universal ‘floor‘ targets will be subject to agreement based on local circumstances. Clause (d) makes the commitment to developing appropriate services to ensure that the household waste stream will be managed in line with those targets. 2.34 On the basis of anticipated growth rates, and its existing investment in waste infrastructure, the City can also commit to meeting the national staged targets for recovery of municipal waste (now 53% by 2010, 67% by 2015 and 75% by 2020). Once again, the contribution of the Energy from Waste plant is critical to this level of performance that is expressed in clause (d). Planning Reasons – Providing a Framework for Identifying Sites 2.35 Secondly, policy SW1 has been formulated to provide a firm framework for designating and identifying sites for waste management in other core policies and other development plan documents. 2.36 The Core Strategy is not expected to allocate sites or specific areas for waste management in its own right but it does need to indicate broad locations or include criteria that will help define such areas. Clauses (b) and (d) refer to current landfill and energy recovery facilities that are critical to the delivery of the strategy’s vision for waste management. This is taken up in policy SW2 and will be translated into specific designations in the City Policies document. 2.37 Clauses (e) and (f) contain criteria relating to the type of areas – established industrial areas and ‘non-greenfield’ land – that will be suitable for new or enhanced waste management facilities. These strategic criteria will be refined further in the City Policies document and any necessary allocations for firm proposals will be included in the City Sites document at the appropriate time. Planning Reasons – Meeting Identified Needs 2.38 Lastly, the Core Strategy is expected to contain policies and proposals that demonstrate sufficient provision of opportunities to meet identified needs of the area for waste management. It is expected to do this in a way that supports the spatial pattern and specific apportionments set out in RSS. The present draft RSS does not yet have a strong spatial basis for proposed facilities but it does provide estimated requirements for municipal and commercial/industrial waste arisings in the City in the form of apportioned tonnages. 2.39 Policy SW1 appropriately uses those benchmark figures and information on operational facilities to demonstrate the necessary requirement to have sufficient capacity to manage expected waste from those streams for at least 10 years beyond adoption of the Core Strategy. The assessment of provision is set out in Table 12.1 of the submitted Core Strategy that is repeated below. The following paragraphs cover the assumptions that have been used in the analysis. -13- Table 1 Provision for Municipal and Commercial/Industrial Waste (million tonnes) 2007-2018 2007-2021 Revised requirement (draws on English Waste Strategy 2007) 2007-21 3.58 0.60 8.72 12.90 4.68 0.75 10.97 16.39 4.20 0.12 10.97 15.29 0.97 1.35 1.21 2.60 6.60 3.25 8.25 3.25 8.25 2.74 12.91 2.75 15.61 2.66 15.37 Draft RSS Forecast Requirement Requirement Municipal waste Incinerator Bottom Ash Commercial and Industrial Waste Total requirement Provision Recycling and composting of municipal waste Energy-from-waste facility Other treatment facilities for Commercial and Industrial Waste Capacity at Parkwood Landfill Site Total Provision Surplus/shortfall +0.00 -0.78 +0.09 Apparent errors due to rounding. Variations in figures for tonnes of landfill is due to differences in the composition and density of waste because of the different amounts of incinerator bottom ash. 2.40 Estimated tonnages of municipal and commercial/industrial waste requiring management in the City during the plan period have been identified in draft RSS Waste Tables at Annex C. They are expressed as ranges, and in the case of municipal waste the forecasts are based on local historical trend and DEFRA’s advised 3% per annum growth rate at the time the regional plan was being prepared. In the case of commercial/industrial waste, the baseline figures rely on modelled data supplied by the Environment Agency, and the range is generated by using an historic trend and an aspirational option related to increased levels of activity in the regional economy. Draft RSS suggests that the latter figures need to be treated with caution at district level because of the reliance on modelled data. 2.41 In line with advice in the Companion Guide to PPS10 (Annex D paragraph 18) the assessment carried out for the Core Strategy uses mid-point figures of the respective ranges for the two waste streams that were included in the amended versions of Tables C1 and C2 presented to the Public Examination. Although -14- there is some minor increase towards the end of the time horizon used, the figures approximate to annual growth rates of some 2.7% for municipal waste and 0.042% for commercial/industrial waste up to 2021. 2.42 Up to 50,000 tonnes per annum of residual incinerator bottom ash (IBA) from processing waste at the City’s Energy from Waste plant will also need to be added back into the requirement figure as this will need to be sent to landfill if it is not recycled. 2.43 It was acknowledged by officers of Yorkshire and Humber Regional Assembly at the Public Examination in 2006 that the assumptions used for Annex C figures had been superseded. In particular the 3% per annum growth in municipal waste is now considered to be too high as it does not reflect sufficient progress on waste reduction or the lower levels now expected in the new English Waste Strategy (2007). The latter states that this waste stream is now growing much less quickly than the economy at 0.5% per annum. 2.44 In the absence of more up to date information from the Regional Planning Body the assessment also models the implications of a lower growth rate of 1.5% per annum for municipal waste in the third column of Table 12.1. This is considered to be a more realistic figure based on local experience of waste growth together with some allowance for growth in the number of households. It also represents the median growth option set out in Waste Strategy 200722. The revised requirement figures also take account of the probable development by the Council’s waste contractor of an IBA recycling plant by 2010 to manage this stream either within the City or the wider region. Diversion of this waste would have a corresponding reduction in landfill requirements. 2.45 The supply side of Table 12.1 is based on a careful assessment of remaining landfill space and the capacity of existing and committed infrastructure for recycling/composting, energy recovery and treatment facilities for commercial/industrial waste. 2.46 With the present infrastructure the Council is achieving a 25% household recycling rate and the approved Household Waste Strategy envisages that this could be raised to 30% principally through the roll-out of a ‘green waste’ collection scheme to most of the city. This can be accommodated without the need for any major new facilities as composting capacity already exists at a site in Tinsley and on local farms. The assessment assumes that recycling of municipal waste is raised to an average of 30% during the 5 year period up to 2018 and that this is increased to 35% thereafter following the introduction of additional bring facilities. 2.47 The new Energy from Waste plant has a design capacity of 225,000 tonnes per annum but allowing for necessary downtime to undertake maintenance it is reasonable to assume that around 216,00 tonnes pa will be available throughout 22 Paragraph 13 of Annex A, Impact of Waste Strategy 2007, DEFRA, (May 2007) -15- the plan period. Although the facility will mainly manage municipal waste it has been designed and sized to accept some commercial/industrial waste too and it is therefore assumed that the available capacity will be taken up. 2.48 Provision of treatment facilities for commercial/industrial waste is estimated at a capacity of not less than 550,000 tonnes per annum based on relatively stable throughput figures for metal recycling (320,00 tonnes), waste transfer stations (150,000 tonnes) and a physico-chemical treatment plant (75,000 tonnes). The figures are derived from the Environment Agency’s Strategic Waste Management Assessment Report (2000) for Yorkshire and the Humber, and other updated information reports produced for the region by the Agency. 2.49 Following completion of tipping at other sites, the Parkwood Landfill site is now the last remaining open-gate facility in the city. Planning consent was granted in 2006 for re-phasing of this tip with infilling expected to be completed by the start of 2019, unless otherwise agreed by the local planning authority. The operator’s returns to the Environment Agency stated the remaining voidspace to be 3.383 million cubic metres at the end of December 2005. This is likely to have fallen to around 3.12 million cubic metres by the start of 2007 given the likely input rates. To express that figure in terms of a tonnage it is necessary to apply a conversion factor. No conversion is required for the proportion of incinerator bottom ash tipped because of the equivalent density of this waste, but using a factor of 0.85 for other municipal and commercial/industrial waste would give a remaining total capacity of some 2.74 million tonnes. This figure would reduce slightly if the tip is no longer required to manage IBA or any other waste stream with such a high density. 2.50 When assessed against the forecast RSS requirements, policy SW1 shows that the City will have equivalent capacity for managing municipal and commercial/industrial waste streams for the 10 years period up to the end of 2018. Although the margin appears tight there is no apparent ‘capacity gap’ because the capacity summarised in Table 12.1 is almost entirely made up of existing facilities that will be available throughout this period, and beyond in most cases. The implications are however, that existing major waste infrastructure should be designated exclusively for waste management purposes and other facilities that contribute significantly to the supply should be placed, wherever possible, in ‘waste management compatible’ industrial areas in supporting development plan documents. Although current supply satisfies the broad test on ensuring sufficient opportunities, specific requirements are likely to emerge from the waste industry that will generate the need for additional facilities. The City has extensive and established industrial areas that already host many existing waste facilities and they will continue to provide suitable opportunities for marginal additions to the stock during the plan period without compromising the supply of industrial land. 2.51 If the more realistic figures are used to reflect slower growth in municipal waste, and IBA from the Energy from Waste facility starts to be recycled soon after the -16- Core Strategy is adopted, then the equivalence referred to above should be maintained for the 2021 plan horizon used in the draft RSS. In the event that the requirement were nevertheless to exceed those figures, then it would be necessary to make some contingency arrangements after 2018, particularly in regard to landfill capacity as this could be exhausted by that date. 2.52 The City has limited opportunities for further landfill development but spare capacity has already been identified in the rest of the sub-region. In developing the draft RSS, the Regional Planning Body stated that South Yorkshire had around 19-21 years supply of licensed landfill space if municipal and commercial/industrial wastes are landfilled at the maximum rate (i.e no more than 33%of arisings) set out in the Waste Tables at Annex C23. On this basis, it should be possible to consider managing the disposal of waste to landfill sites in the rest of the sub-region if this proves necessary in the longer term. In the light of this supply, and other unimplemented permissions, the Regional Assembly has supported the view that provision of further consents for landfill capacity should be resisted in the sub-region. Given these circumstances it should be possible to negotiate variations to the City’s regional waste apportionments in consultation with adjoining authorities to address this mismatch if this proves necessary. Sustainability Appraisal 2.53 The sustainability appraisal has been applied in a way that supports the Government’s objectives for waste management in PPS10 through the incorporation of a specific aim relating to positive use of the ‘waste hierarchy’. 2.54 Policy SW1 was assessed as having a positive impact on all main sustainability themes and was superior to reliance on national/regional objectives because it shows how Key Planning Objectives (paragraph 3 of PPS10) for waste management can be achieved locally. The policy scores better than the rejected option by minimising the transport of waste and the emissions associated with this and by indirectly promoting the provision of local jobs in waste management. The option does this by providing a framework for the City to take responsibility for its own waste and to achieve national recovery targets in managing that waste. Equality Appraisal 2.55 The submitted policy and its alternative option have been assessed as having no impact on any of the groups identified for the purposes of this appraisal. 23 Statement made as part of Strategic Messages for the period 2005-2015 in document referred to in footnote 21. -17- Consultation Responses 2.56 The submitted policy has not been subject to previous consultation but an Additional (Preferred) Option AW1 was prepared to meet a need for a wider and more strategic approach that complied with guidance in PPS10 for positive use of the ‘waste hierarchy’ whilst also catering adequately for disposal needs. That option addressed some of the comments made at earlier stages by Government Office for Yorkshire and the Humber (ref. 4871.026), the Environment Agency (ref. 5281.034), Derbyshire CC (ref. 4925.007) and Viridor Waste Management Ltd (ref. 5119.006). The option was supported unconditionally by Yorkshire Forward (ref.949), Natural England (ref.621) and Viridor (ref. 829). 2.57 However, the Environment Agency (ref.1692) and the Regional Assembly (ref. 623) still felt there was a need for the policy to be more explicit in moving the management of the City’s apportioned waste streams up the ‘waste hierarchy’. The Environment Agency and the local Green Party (ref.115) also echoed other earlier concerns in wanting more support for waste reduction and Derbyshire CC (ref.4925.005) wanted the proposed local ’needs test’ confining to landfill rather than all waste management methods to mirror their own policy. There was also a need for the policy to be more explicit in its coverage of non-municipal waste streams. The submitted policy now addresses those specific additional concerns as part of a spatially distinctive approach on objectives that will deliver more sustainable waste management in the City. 2.58 There are still outstanding concerns raised by Burngreave Area Panel (ref. 5263.015) and the Green Party (ref.115) with another individual (ref.1415) that centre around avoiding landfill and energy recovery measures altogether whilst maximising recycling initiatives. Amendments to the policy along those lines have not been accepted. It is considered that the key objectives of the waste strategy cannot embrace comprehensive recycling regardless of the cost and must recognise the contribution of energy recovery and other disposal methods as part of a balanced approach that fits with local circumstances. The submitted policy has been formulated in close consultation with the Council’s Waste Management service. Conclusions on Reasons for Selecting the Policy 2.59 The submitted policy has been selected because its strengths outweigh any weaknesses and it is preferable to have a local vision for waste management that is set within the context of higher tier policies rather than simply deferring to them. Policy SW1 is the most appropriate option for demonstrating how the City can manage its waste in a way that moves it up the ‘waste hierarchy’. The option provides a firm framework for subsequent designation and identification of waste management sites. Finally, it fulfils the requirement to evidence that there will be sufficient provision to meet identified needs set out in RSS. The advantages of the policy are borne out by the results of sustainability and equality appraisals that are themselves supportive of national objectives for waste management. The -18- policy also addresses most of the concerns raised through consultation, and the Council’s Waste Management Service has co-operated in its formulation. Implementation and Monitoring (Soundness Test 8) 2.60 It is submitted that this policy meets the requirements of soundness test 8 in terms of having clear mechanisms for implementation and monitoring. The Delivery Schedule at Appendix A summarises the implementation arrangements. 2.61 The policy will apply throughout the plan period. Elements at clauses (b) and (d) relating to LATS and recycling performance will be implemented by the Waste Management Authority with delivery being set out in detail in the current Household Waste Strategy and subsequent reviews. Planning control will be exercised in securing the delivery of any new facilities provided by the private sector or the Council’s waste contractor. Clause (c) will operate as a strategic development control policy but other elements set out in clauses (a),(b),(e) and (f) will need to be taken forward in supporting development plan documents to establish more specific regulatory policy and possible site allocations. 2.62 The key target for the policy is to recycle and recover energy from 80% of the City’s municipal waste by 2015. The related indicator is therefore: 2.63 The percentage of municipal waste managed through recycling/ composting or energy recovery. A further Government Core Output Indicator (6b) will also be used to monitor the policy: Amount of municipal waste arising, and managed by management type, and the percentage each management type represents of the waste managed. All the above measures will be included in the SDF’s Annual Monitoring Report. Flexibility and Risk Assessment (Soundness Test 9) 2.64 The policy has been drafted with a view to the likely risks involved in its implementation. Sheffield is already in a position to trade landfill allowances to other authorities that cannot meet their diversion targets. Given maintenance of the current waste infrastructure, and in particular the energy from waste plant, it is highly unlikely that the Council will need to buy or borrow future allowances as it will be able to limit landfilling of its municipal waste well below the projected allocations in the LATS system. 2.65 The policy has been written to provide a consistent framework for development management. In terms of waste minimisation, it is conceded that the planning system can do little to influence matters such as excessive packaging of goods, -19- but Government policy is now placing greater responsibility on businesses to respond themselves on this issue. It may be necessary to consider strengthening policy SW1 when firmer guidance on managing hazardous waste is prepared at regional level. Conclusion 2.66 It is submitted that policy SW1 should be adopted as part of the Core Strategy having considered appropriate requirements and the criteria set out in the various soundness tests. It is considered to be the most appropriate policy for this issue as faced by the City and its content is based on a robust and credible evidence base that is summarised in section 2.59 (test 7). The policy has been prepared in accordance with national planning and waste policy, conforms to the draft RSS and has regard to other relevant plans and strategies, including the City’s Community Strategy (tests 4&5). As drafted, the policy forms part of a coherent spatial approach to managing the City’s waste in the LDF and there are no conflicts with relevant plans prepared by neighbouring authorities (test 6). Clear mechanisms for implementing and monitoring the policy have been developed, including a specific and measurable target relating to recovery of municipal waste. Finally, the policy incorporates some flexibility in providing a reasonably robust framework for development management of future waste infrastructure (tests 8&9). -20- 3 SAFEGUARDING MAJOR WASTE FACILITIES Introduction 3.1 This policy deals with the issue of protecting the future role of waste facilities that are locally significant. It links with policy SW1 in affirming the location and role of two major facilities that are key to the overall waste strategy. Policy SW2 3.2 The energy recovery plant at Bernard Road and the landfill site at Parkwood Springs will be retained to meet the city’s long-term requirements for waste management. Policy Background (Soundness Test 4) National Policy 3.3 Sections 2.3 and 2.4 refer to relevant national policy on waste management and the function of the Core Strategy for this topic. Waste Strategy for England (2007) reminds local authorities of their obligations to demonstrate compliance with Article 7 of the Waste Framework Directive and associated directives. Those directives require the UK to operate a planning system that sets out specific sites for waste facilities or have sufficiently clear locational criteria that acceptable sites can be identified. 3.4 It is considered that submitted policy SW2 fulfils the requirements of soundness test 4 being part of a spatial plan that is consistent with the relevant provisions of national planning policy. The following paragraphs support this view. 3.5 Policy SW2 satisfies requirements of a core strategic policy in that it helps to provide sufficient spatial guidance to ensure that land will be allocated to support the overall waste strategy, including for waste disposal, in line with the RSS. It also looks forward to the longer- term horizon set out in the regional strategy (paragraph 16 of PPS10). 3.6 The policy forms part of a planning strategy that complies with the Key Planning Objectives for sustainable waste management in that safeguarding the energyfrom- waste facility helps to drive waste up the ‘waste hierarchy’, and retaining the landfill site allows the city to take responsibility for its own waste disposal needs. Both facilities help to secure the safe recovery or disposal of the city’s waste in urban locations close to where it is generated (paragraph 3 of PPS10). -21- 3.7 The policy also demonstrates compliance with Article7 of the Waste Framework Directive24 that particularly requires development plans to identify suitable disposal sites or installations for waste management purposes. Until such time as supporting documents are in place this policy provides some clarity over the location of two strategic disposal facilities needed by the city. 3.8 SW2 also supports the new national waste strategy through continuation of a vigorous energy-from-waste policy locally that helps to divert waste from landfill. The technology involved in the Sheffield plant is particularly beneficial in that both heat and electricity can be recovered from the treatment process. Regional Policy 3.9 Section 2.9 refers to relevant regional planning policy on waste management. As mentioned in section 2.38, the current draft RSS does not yet have a strong spatial component that identifies a desired pattern of waste management facilities. It is submitted that the two facilities safeguarded by policy SW2 are of sufficient regional or sub-regional significance to register as part of that pattern when this aspect of regional policy is addressed. 3.10 Although the national waste strategy now uses slightly different terms for them, policy SW2 conforms to the ‘proximity’ and ‘self sufficiency’ principles set out in RSS in policy ENV 12C. The capacity of these existing facilities and their lifespan has been properly considered in assessing local supply against the apportioned waste streams estimated by RSS in policy ENV 13A. Sub-Regional Policy 3.11 There are no formal sub-regional documents that have a bearing on this issue. Despite the sub-regional position on landfill referred to in section 2.52, it is reasonable to safeguard the Parkwood Springs facility as all of its capacity is needed to cater for locally generated municipal and commercial/industrial waste as part of the City’s overall strategy. Other Sheffield Policies 3.12 Policy SW2 reflects the vision set out in the Council’s approved Waste Management Strategy. Firstly, that strategy anticipated the development of a new and larger energy-from-waste plant that was subsequently completed in 2006. The plant is now a key element in the authority’s strategy for achieving more selfsufficiency for waste management because it has the capacity to process most of the non-recycled portion of the municipal waste stream. 3.13 Secondly, the strategy assumes that the city’s residual waste would continue to be managed within the district by sending it to the Parkwood Springs landfill site 24 These obligations are set out in the Waste Management Regulations 1994. -22- until such time as infilling is complete there. Policy SW2 acts as a spatial delivery tool for the operational waste strategy by safeguarding these key facilities. Relationship to City Strategy (Soundness Test 5) 3.14 Section 2.17 refers to the status of the statutory Community Strategy. The existing central district heating scheme powered by the energy-from-waste plant is strongly promoted as part of its theme of sustainable energy production and waste management. Policy SW2 reflects this priority by giving protection to its continued operation in planning terms. Consistency with Other Planning Documents (Soundness Test 6) Core Strategy Objectives 3.15 The policy helps to amplify the core aim for sustainable use of natural resources by interpreting strategic objective S12.4 on the positive use of the ‘waste hierarchy’. It identifies key locations that provide land for energy recovery and final disposal of waste. The policy is consistent with the over-arching policy on waste management objectives SW1, and it will help to provide a basis for a specific development control policy on these facilities in the City Policies document. Adjoining local authorities’ plans 3.16 The policy does not conflict with the known waste management content of other development plan documents under preparation in the sub-region, nor with the adopted Derby and Derbyshire Waste Local Plan. 3.17 Whilst there are no planning conditions preventing waste being imported from other districts to the Parkwood landfill facility, there is no reliance placed on the use of its remaining capacity as part of plans being prepared by neighbouring authorities. Conversely, Section 2.20 covers the long-term contingency of the City possibly having to export some waste for final disposal to consented landfill sites in the rest of the sub-region once tipping is complete at Parkwood Springs. 3.18 Planning consent for the Energy-from-Waste facility does allow for the option of up to 10% of its capacity to be used to process municipal waste from Rotherham or NE Derbyshire if necessary, but this has not been taken up, and there is no evidence that it has been built in to the waste strategies for those districts. Options Considered (Soundness Test 7) 3.19 No options were presented on this issue at Emerging or Preferred Options stages although the preamble to the preferred option PW1 on waste recycling centres -23- made it clear that the Council would be taking advantage of the new Energy-fromWaste plant at Bernard Road to expand the central district heating network. 3.20 At Emerging Options stage the City Policies document contained two separate regulatory options EW3 and EW4 specifying the use of the Bernard Road location and the Parkwood Springs Landfill site respectively. However they were not linked to the Core Strategy until a new Additional (Preferred) Option AW2Safeguarding Major Disposal Facilities was made available for consultation in February 2007. The option was proposed to affirm these facilities as part of the wider spatial strategy. The wording of that option is repeated below. Additional Option AW2 - Safeguarding Major Disposal Facilities ‘The energy recovery plant at Bernard Road and, whilst capacity remains, the landfill site at Parkwood Springs will be retained to meet the city’s longterm requirements for waste management.’ 3.21 The submitted policy is identical to the option above except for the deletion, with respect to the Parkwood site, of the redundant phrase ‘whilst capacity remains’. The facilities identified in this policy are already in use and form a critical element in the current waste strategy. Therefore, the choice was either to affirm their future through a safeguarding policy or discount them and develop or use equivalent alternative capacity. To ensure compliance with landfill diversion targets this would effectively mean developing alternative energy recovery facilities to the Bernard Road plant elsewhere in the city. In the case of landfill, the alternative would be to dispose of other residual waste to sites in neighbouring districts. Option a – Safeguard Existing Major Waste Facilities (as in submitted policy SW2). 3.22 The strengths of this option are: (d) Retention of both facilities is an efficient use of existing infrastructure and previously developed land. (e) The City would satisfy Key Planning Objectives for waste management by taking more responsibility for managing its own waste which would be disposed of in one of the nearest appropriate installations. (f) The existing energy-from-waste plant is sited optimally to serve the central district heating network as well as providing electricity for the national grid. 3.23 The weaknesses of this option are: (c) Retention of the Parkwood Springs landfill site delays the eventual restoration of the land for a new park. -24- (d) The energy-from-waste buildings will continue to impact on city centre views. Option b – Build an alternative EFW plant elsewhere in Sheffield and export residual waste to landfill sites in neighbouring districts. 3.24 The strengths of this option are: (b) Parkwood Springs landfill site could be fully restored at an earlier date with benefits to the well-being of the local community. (c) The impact of the existing energy-from-waste buildings on City Centre views will be removed if the plant is de-commissioned. 3.25 The weaknesses of this option are: (c) Writing off investment in these facilities is unlikely to be affordable and would involve some loss of jobs. (d) Exporting to neighbouring authorities will involve waste travelling far greater distances than if it were managed within the city. (e) An alternative location for an EFW plant will not supply the central district heating network as efficiently or as flexibly. Reasons for the Submitted Policy (Soundness Test 7) 3.26 Having considered meaningful alternatives, it is considered that the submitted policy is the most appropriate approach to identifying major disposal facilities for the reasons given below. All assumptions that underpin the policy are covered in this section of the report. Planning Reasons 3.27 Higher tier policies stress the importance of identifying sites and areas suitable for waste management facilities to give confidence that the local waste strategy is robust and deliverable. Policy SW2 affirms the role of two key facilities in both diverting waste from landfill and catering for final disposal needs in the City’s waste management strategy. Those facilities are capable of handling more than 40% of the anticipated arisings of municipal and commercial/industrial waste in the city and their locations therefore need to be safeguarded for that purpose. The strategic policy acts as a signpost to supporting regulatory policies in the City Policies document that clearly define the nature and physical extent of these waste management areas. -25- 3.28 Following a thorough and detailed assessment, planning permission and a permit under the Pollution and Prevention Control regime were granted for a new Energy-from-Waste facility at Bernard Road to replace the city’s municipal waste incinerator. Alternative sites for the facility were considered as part of an Environmental Statement accompanying the planning application25. The sites assessment that was undertaken by Terence O’Rourke Associates established that the central location offered by Bernard Road is optimal for using and expanding the current central district heating network and to minimising the distance that collected waste needs to travel. None of the other 15 sites considered were superior for the various criteria used in that assessment. 3.29 The new energy-from waste plant has been fully operational since the middle of 2006. It is acknowledged that it is the type of good quality combined heat and power plant that supports the Government’s policies for both energy supply and waste management, and it offers a much better option than landfilling residual waste. Although it has been designed primarily to take municipal waste it is flexible enough to accept some non-municipal waste. The plant is a key element in the City’s strategy of achieving more self-sufficiency for waste management because it has been sized to process most of the non-recycled portion of the anticipated municipal waste stream. 3.30 Given the urgency attached to diverting municipal waste from landfill to comply with the Landfill Directive, the City could not afford the time and expense involved in de-commissioning the present plant and procuring alternative facilities. Such facilities are unlikely to be able to supply the existing central district heating network, serving over 140 buildings, as efficiently as the present plant. 3.31 The amount of municipal waste that needs to be landfilled has been significantly reduced since the new energy-from-waste plant came into operation, and it should reduce further when the Council’s waste contractor builds a new plant to recycle ash produced by the facility. However despite this, and the contribution of other recycling and recovery services, there will still be a need for landfill in the city to deal with final disposal of residual material that can not be recycled or treated further at economic cost. 3.32 Following the closure of the Beighton site the only large open-gate commercial facility in the City is the landfill site currently run by Viridor Waste Management Ltd at Parkwood Springs. The site has planning permission and a licence to accept non-hazardous and inert waste. Acting on the recommendations of an Inquiry set up by the City Council, the operator applied for and was granted consent in 2006 to rephase tipping operations and restore the site progressively in six phases. Based on their analysis of the future market locally for waste 25 Sheffield ERF Planning Supporting Statement, Appendix 1: Alternative Site Assessment, Terence O’Rourke plc (November 2001). -26- disposal and the available voidspace, consultants representing Viridor26 agreed that there would be sufficient arisings (of at least 345,000 tonnes per annum) to complete infilling operations by December 2018. 3.33 There are now no other significant open-gate landfill facilities within 10 kilometres of the City Centre. The Parkwood site is located approximately 2.5 km north east of the centre and it has direct access to the strategic highway network and close links to the city’s industrial areas. It is therefore well located to manage residual non-hazardous waste arisings in the city. The next nearest landfills are located in neighbouring authorities at Chesterfield, Rotherham, Doncaster and Worksop. The alternative of revoking the current planning permission at Parkwood, with consequent compensation, and relying instead on the capacity in other areas would not be a good use of public money. Such an option would also represent an unsustainable waste management practice, as waste would be hauled over much longer distances for final disposal than is necessary. 3.34 Given that it is both a scarce resource in the city, and need has been clearly established to the satisfaction of the planning authority, it is considered essential to reserve the Parkwood site to ensure that there is sufficient capacity for local residual municipal and commercial/industrial waste arisings. 3.35 It is considered that the weaknesses identified for the submitted policy in section 3.23 should not be given much weight. Although the Energy-from-Waste Plant is dominant in some City Centre views it is not practical to consider screening the development and it is considered that the design of the main buildings are of a reasonable quality for such large structures. 3.36 Similarly, whilst there will inevitably be more delay to comprehensive restoration of the Parkwood Springs landfill site than if it were no longer to be used for waste disposal purposes, the current planning consent has provided for re-phased operations to ensure that the area can be restored progressively. It is therefore likely that early stages of the site, comprising restored phases 1-3, will be available for public access before the infilling operations at the site are complete. Sustainability Appraisal 3.37 The sustainability appraisal has been applied in a way that supports the Government’s Key Planning Objectives for waste management through the incorporation of a specific aim relating to the positive use of the ‘waste hierarchy’. 3.38 Policy SW2 was assessed as having several positive impacts, and especially for aims associated with the resource efficiency theme. In comparison the rejected option only has neutral or negative impacts across the board. The submitted policy is particularly superior for maintaining energy supply to the district heating 26 Chapter 16 and Table 6 of Environmental Statement with planning application ref.05/02877/FUL prepared by MJC Associates, (July 2005). -27- network and making efficient use of existing waste infrastructure. Health impacts have been scored as neutral because research carried out for the Government27 to date shows that there is no credible evidence of adverse health outcomes for those living near to modern incinerators or landfill sites that do not accept special waste. The option of discounting this infrastructure and developing or using alternative facilities would waste resources, involve excessive costs and be less sustainable in moving residual waste around. Equality Appraisal 3.39 The submitted policy was assessed as having no impacts on any of the groups identified in the appraisal method. Consultation Responses 3.40 Additional (Preferred) Option AW2 was formulated to cover the management of more than just the municipal waste stream by emphasising the flexibility of the Energy-from-Waste plant and the importance of retaining general capacity for landfill in the city. That option therefore addressed comments made at earlier stages by Government Office for Yorkshire and the Humber (refs. 4871.41 and 6.137), Viridor Waste Management (refs. 4656.07 and 5119.005/6) and two individuals (refs.4471.04 and 4462.19).The option was supported by Yorkshire Forward (ref.949) and Viridor (ref.829). The latter also suggested that the Parkwood Landfill site should be specifically protected against non-waste related development, and that it could be shown as being suitable for other uses that might complement its waste disposal role. These are considered to be valid comments but they will be taken up in a preferred option for a regulatory policy in the City Policies document, The Parkwood site is also shown on the Key Diagram for the Core Strategy as suggested by Viridor (ref.5119.001). 3.41 The Environment Agency (refs.591.16 and 1692) requested that the waste management chapter should clarify whether the policy on the Parkwood landfill relates to the footprint for the consented scheme or some further extension, and also that the issue be addressed of where disposal will take place once tipping is complete at this site. The wording of paragraph 12.10 in the submitted Core Strategy has been amended to clarify the first point and paragraph 12.3 covers contingency arrangements if the Parkwood site is exhausted before the end of the plan period. 3.42 There are outstanding concerns raised by Burngreave Area Panel (ref. 5623.015) and two individuals (refs.4462.19 and 1415) that the Parkwood tip should close early for amenity reasons and that the strategy should be based on comprehensive recycling/waste reduction with no or less incineration. Amendments to the policy along those lines have not been accepted for the same 27 Review of Effects of Environmental and Health Effects of Waste Management, Enviros Consulting Ltd. and Birmingham University, (May 2004). -28- reasons that are set out in section 2.58. The submitted policy has been formulated in close consultation with the Council’s Waste Management Service. Conclusions on Reasons for Selecting the Policy 3.43 The policy has been selected because its strengths outweigh its weaknesses and the alternative option is both impractical and wasteful of public resources. The policy satisfies the requirement to identify facilities that are critical to the overall strategy. There is no superior site to Bernard Road for supplying energy recovered from municipal waste to the existing district heating network, and the current plant is a ‘state of the art’ facility. The City has a need for landfill space that is only available locally at Parkwood Springs. The advantages of the policy are borne out by sustainability and equality appraisals which themselves are supportive of national objectives for waste management. The policy addresses most of the concerns raised during consultation and the Council’s Waste Management Service supports its content. Implementation and Monitoring (Soundness Test 8) 3.44 It is submitted that this policy meets the requirements of soundness test 8 in terms of having clear mechanisms for implementation and monitoring. The Delivery Schedule at Appendix A summarises the implementation arrangements. 3.45 The facilities referred to in the policy already exist and are part of the City’s current waste strategy. They are operated by private sector companies with the benefit of recent planning permissions and waste management licences. The policy will therefore be delivered by Veolia ES Sheffield Ltd and Viridor Waste Management Ltd, or their successors, continuing to run these facilities. In the case of the Energy-from-Waste plant this is guaranteed as part of an integrated waste contract with the City Council that lasts until 2036. 3.46 In the case of the Parkwood facility, Viridor have agreed to re-phase their original landfilling operation at the site in a way that lessens nuisance impact on adjoining residential properties and reduces the potential life of the tip by an estimated 8 years. This should mean that infilling operations could be completed by the start of December 2019 with all restoration completed within a further two years unless it is necessary for the planning authority to agree otherwise. Those dates are based on assumptions on waste growth and the future market for waste disposal in the city. It is therefore unlikely that the company would wish to curtail its operations until that programme is completed. The City Council will support the policy by designating the facilities within Waste Management Areas subject to appropriate land-use policies within the City Policies document. 3.47 Progress on implementing the policy will be monitored by checking the performance of the waste management facilities annually and including the results in the SDF Annual Monitoring Report. A key target has been set that at -29- least 5.5 million tonnes of waste will be managed at the two sites by 2021. This is considered to be an achievable target that allows some flexibility for improvements in waste reduction and/or some under-utilisation of capacity during this period. Flexibility and Risk Assessment (Soundness Test 9) 3.48 The policy has been drafted with a view to the likely risks involved in its implementation. The companies operating the facilities are leading organisations providing waste management services in the UK, and they have strong financial backing. Both companies have a vested interest in maintaining their facilities throughout their expected lifespan. In theory it is possible that there could be changes in law that could impact on the continuation of these facilities in future but it is not possible to foresee such changes happening at present. 3.49 The submitted policy has been written to provide a consistent framework for development management. The weaknesses of the policy are not considered to be significant and they are mitigated to some extent as described at sections 3.35 and 3.36. Conclusion 3.50 It is submitted that policy SW2 should be adopted as part of the Core Strategy having considered appropriate requirements and the criteria set out in the various soundness tests. It is considered to be the most appropriate policy for this issue as faced by the City and its content is based on a robust and credible evidence base that is summarised in section 3.43 (test 7). The policy has been prepared in accordance with national planning policy and the national waste strategy. It conforms to the draft RSS and has regard to other relevant plans and strategies, including the City’s adopted Community Strategy and approved Waste Management Strategy (tests 4&5). 3.51 As drafted the policy forms part of a coherent spatial approach to managing the city’s waste in the LDF and there are no conflicts with relevant plans prepared by neighbouring authorities (test 6). Clear mechanisms for implementing and monitoring the policy have been developed, including a specific and measurable target relating to the throughput of waste that the facilities are expected to handle during the plan period. Finally the policy, and its associated target, incorporates some flexibility in providing a reasonably robust framework for development management of these existing facilities (tests 8&9). -30- 4 PROVISION FOR RECYCLING AND COMPOSTING Introduction 4.1 The Council already operates a successful kerbside collection scheme for household waste paper and card, which is taken to a Materials Recovery Facility (MRF) at Beighton. The City’s five Household Waste Recycling Centres (HWRCs) have also recently been refurbished and now recycle around half of the waste material that is brought in. To date, these services have helped the city to achieve specific recycling targets set out in the Government’s Best Value regime. However, additional investment is required to fulfil the aim of recycling more municipal waste as set out in the City’s Environment Strategy28 and to address any waste indicators that will result from the Government’s new local performance framework. Some parts of the city are still relatively remote from any of the HWRCs and improvement to the network would help to increase access for potential users. 4.2 Similarly, although the Council’s waste contractor is promoting home composting through subsidising compost bins, there is a need to promote other local facilities, and the city will need to collect and manage significant volumes of ‘biowaste’ 29 if it is to meet targets derived from the Landfill Directive. The Council therefore needs to promote a range of facilities to achieve the citywide aim of improving performance for recycling and composting of municipal waste. The following policy has been formulated to support that aim. Policy SW3 4.3 Increased recycling and composting will be enabled by: (a) supporting the development of a network of small-scale community composting schemes and new technologies for treating mixed organic waste and using green waste composting facilities at Tinsley and on local farms; and (b) retaining and improving the current network of five major Household Waste Recycling Centres and, in the longer term, building a new facility to serve the south-west area of the city; and (c) expanding the number of local recycling points, particularly in existing shopping centres, transport interchanges and at education and health facilities. 28 Sheffield Environment Strategy 2003-2006, Sheffield First Partnership (2003). ‘biowaste’ is the biodegradable fraction of waste which comprises mainly paper/card, green waste, kitchen waste and some textiles. 29 -31- Policy Background (Soundness Test 4) National Policy 4.4 Paragraphs 2.3 and 2.4 refer to relevant national policy on waste management and the functions of the Core Strategy for this topic. New national waste strategy is calling for greater separation and sorting of all waste streams to allow more efficient recycling of materials. This requires an expansion in collection and processing facilities and an extension of recycling ‘culture’ into areas beyond the home and office. The strategy also sees the treatment of ‘green waste’ as a good target for increasing landfill diversion whilst gaining environmental benefits at the same time. 4.5 It is considered that submitted policy SW3 fulfils the requirements of soundness test 4 being part of a spatial plan that is consistent with the relevant provisions of national planning policy. The following paragraphs support this view. 4.6 The policy forms part of a planning strategy that complies with the Key Planning Objectives for sustainable waste management in that the proposed provision for recycling and composting helps to drive waste up the ‘waste hierarchy’ and supports targets relating to the diversion of household waste from landfill set out in the national waste strategy. Through the development of an extra HWRC it also helps bulky waste to be disposed of locally without harm to the environment that might otherwise occur. Finally, the policy reflects local concerns and interests expressed during consultation that the strategy should provide more opportunities for recycling or composting waste (paragraph 3 of PPS10). 4.7 Policy SW3 satisfies one of the main requirements of a core strategy in that it helps to identify the type of new or enhanced recycling facilities that should be provided together with some locational criteria for siting them (paragraph 17 of PPS10). 4.8 The policy supports a new theme in the national waste strategy with its proposals to increase the number of recycling points in public places such as shopping centres, interchanges and large institutions. It’s support for composting initiatives, including new technologies, is in line with Government’s current thinking on using ‘green waste’ as a key material in its landfill diversion strategy. Regional Policy 4.9 Section 2.9 refers to relevant regional planning policy on waste management. Policy SW3 conforms with regional waste management objectives in that it will help the City to achieve statutory performance targets relating to recycling and composting (policy ENV12C). Clauses (b) and (c) also comply with the specific requirement on establishing an accessible network of civic amenity or other public ‘bring’ sites for recycling purposes (policy ENV13C). -32- Sub-Regional Policy 4.10 There are no formal sub-regional documents that have a bearing on this issue. In an expanded version of Annex C waste tables included in the draft RSS produced for the Public Examination30, the Regional Assembly has drawn attention to the low level of large-scale composting in South Yorkshire compared with other parts of the region. Policy SW3 will allow the City to make a greater contribution to providing extra treatment capacity for this management method in the sub-region. Other Sheffield Policies 4.11 Policy SW3 gives spatial expression to some important elements of the Council’s approved operational waste management strategy. The Council, along with community partners, has used funds from the Government’s Recycling Fund to develop a series of small-scale composting centres similar to those operating at Heeley City Farm. This initiative allows for green waste collected in parts of the city to be processed into quality compost as well as creating jobs in the community. 4.12 The Council has also used the DEFRA Challenge Fund to set up kerbside collection of green waste from around 45,000 homes in the city. The roll-out of this service to the remainder of the city is likely to be the next major service priority because it will reduce landfill costs and it is considered to be one of the most efficient way of achieving a 30% recycling/composting rate locally. At present, no additional processing facilities have been proposed to treat this waste as there is likely to be sufficient capacity on land at Tinsley and on local farms. The Council is however, keen to explore the scope for new technologies that could, for instance, convert local sewage residues and some ‘biowaste’ to produce energy and compost. 4.13 The Council has recently refurbished the five existing HWRCs to allow them to be used more efficiently. Additional measures are necessary, however, to ensure that the 30% recycling target can be met. These are likely to include a doubling in the number of local ‘bring’ banks across the city together with an extra HWRC. These facilities need to be strategically sited but it is clear that the south west sector of the city between the A57 and A61 corridors lacks a large multi-purpose centre for people to take recyclates and dispose of their bulky household waste items. Policy SW3 reflects all the above strategic initiatives derived from the present Household Waste Strategy. 30 Statement made as part of Strategic Messages for the period 2005-2015 in document referred to in footnote 21. -33- Relationship to City Strategy (Soundness Test 5) 4.14 Section 2.17 refers to the status of the statutory Community Strategy. Under the ‘Environmental Excellence’ theme there is a commitment to pursuing strategies for sustainable waste management and energy production that can contribute to a reduced ecological and carbon footprint for the city. Policy SW3 has regard to that priority as the provision of additional facilities for recycling/composting will reduce greenhouse gas emissions through landfill diversion and the re-use of waste materials. The policy particularly assists a priority of Sheffield First Partnership’s Environmental Strategy to improve the household recycling rate with its proposals for composting more green waste and expanding the number of sites for bringing recyclable materials. Consistency with Other Planning Documents (Soundness Test 6) Core Strategy Objectives 4.15 The policy helps to amplify the core aim for sustainable use of natural resources by interpreting the strategic objective S12.4 on the positive use of the ‘waste hierarchy’. It proposes facilities for recycling/composting waste materials, and these particular methods are at the higher end of the hierarchy, which is accepted as a good general guide to relative environmental benefit of different management options. 4.16 The policy is consistent with the over-arching core policy on waste management objectives SW1, and it will help to provide a basis for specific development control policies in the City Policies document and any site allocations in the City Sites document. Adjoining local authorities’ plans 4.17 The policy does not conflict with the known waste management content of other local development documents under preparation in the sub-region, nor with the adopted Derby and Derbyshire Waste Local Plan. 4.18 The specific proposal for a new HWRC in south- west Sheffield is unlikely to be an important factor in the recycling plans of any neighbouring authorities given that the search area is relatively remote from communities living just beyond the city boundary. Options Considered (Soundness Test 7) 4.19 At Emerging Options stage, that part of the submitted policy relating to HWRCs was expressed as an option to ‘ continue with the present Household Waste Strategy which calls for one new centre to serve the south west area’. In order to emphasise its contribution to the pattern of centres, at Preferred Options stage, it -34- was modified slightly to read, ‘The current network of major HWRCs will be expanded by building a new facility to serve the south west area of the city’. 4.20 Two alternative options were considered for improving the distribution of major recycling centres for household waste. The first involved using density guidelines of the adopted RSS (2004) of one civic amenity site per 15,000 households, which would have meant providing another 10 new centres. The second option relied on providing centres on the basis of catchment areas of around 5 kilometres, which implied a further two or three centres to fill existing gaps. 4.21 To broaden its scope, and to address concerns raised during consultation, the submitted policy SW3 has been expanded to include significant proposals for extending the local ‘bring’ recycling network and managing more green waste. Those extra elements are drawn from an Emerging Option EW2 (a) to (d) on ‘Promoting Material Recovery’ contained in the City Policies document. Option A – Provision for Recycling and Composting ( as in submitted policy SW3). 4.22 The strengths of this option are: (a) It identifies the main area lacking a HWRC in line with the Council’s Waste Management Strategy. (b) The new HWRC can assist the Council to provide a more cost effective kerbside collection service in a less densely populated part of the City. (c) It provides a more integrated strategy for improving recycling performance because it combines one new HWRC with a denser network of local recycling points and an expanded kerbside collection service. (d) Expanding the number of recycling points in public places will make it easier to recycle away from homes and offices. (e) It identifies locations and methods for increasing composting of waste. 4.23 The weakness of this option is: (a) Lack of a sufficiently dense HWRC network could reduce the potential volume of material that is brought for recycling. Option B – Providing 10 new HWRCs to comply with proposed density guideline in adopted RSS. 4.24 The strength of this option is: -35- (a) A major expansion in the number of HWRCs would improve accessibility for those bringing waste to such centres. 4.25 The weaknesses of this option are: (a) The suggested density standard is no longer included in the new draft RSS (2005). (b) In isolation, the standard is arbitrary because it is not integrated with desired standards for local bring sites and kerbside collection schemes. (c) It is unlikely that such provision would be affordable or good value for money in achieving the city’s recycling objectives. Option C – Providing new HWRCs based on catchment areas of 5 km. 4.26 The strength of this option is: (a) Some expansion in the number of HWRCs would improve accessibility for those bringing waste to such facilities. 4.27 The weaknesses of this option are: (a) It may represent poor value for money if it involved having to relocate any existing refurbished HWRCs in order to comply with proposed travel distances. (b) In isolation, the accessibility standard may not assist recycling objectives because it is not integrated with desired provision of local bring sites and kerbside collection service. Reasons for the Submitted Policy (Soundness Test 7) Planning Reasons 4.28 Having considered meaningful alternatives, it is considered that the submitted policy is the most appropriate approach on strategic provision for recycling and composting for the reasons given below. 4.29 The underlying purpose of the policy is to make a local contribution to more sustainable waste and resource management by implementing some cost effective recycling/composting measures. In the first instance, the policy responds to the identified local need for an additional HWRC to serve the south- west area of the city because that sector is relatively remote from any of the other 5 existing centres. Without a new facility people living in that area will have to continue -36- travelling long distances to access multi-purpose recycling facilities and a place to deposit over-sized or bulky waste. 4.30 The Household Waste Recycling Act passed in 2003 means that every waste authority will have to provide a second kerbside collection of at least two recyclable materials by 2010. If this is not provided then the onus is on the local authority to prove that it is either too costly to achieve, or that there are sufficient other recycling opportunities. Whilst the Council will endeavour to provide an appropriate collection service, the development of a strategically sited HWRC, together with a denser network of local recycling points, may offer a more cost effective means of complying with the Act in a less densely populated area such as SW Sheffield. 4.31 The Audit Commission has recommended that it is good practice to provide one ‘bring’ bank for every 750 households. There are now some 200 ‘bring’ sites across the city, but extra sites are needed to achieve the above standard and provision in some districts is lacking. A relatively dense network of local sites can help to improve the recovery of some materials like glass, cans, plastic and textiles which are generally more expensive for authorities to collect with kerbside services. 4.32 The policy proposes to expand the number of local recycling points concentrating on well-used public areas like shopping centres, transport interchanges and large institutional campuses. These facilities will be sited to address deficiencies in the current network. This strategy should result in a cleaner local environment, spread the message that recycling is positive and help to extend the recycling ‘culture’ beyond the home and office. It is understood that the Government intends to publish specific guidance and a voluntary code of practice that authorities can use to enlist the support of owners and developers of major facilities in achieving co-ordinated schemes. 4.33 If they are to accept a broad range of waste materials, the capital costs of providing a new HWRC can be quite substantial, particularly where an authority needs to acquire land. Rather than investing heavily in several large centres the submitted policy reflects the Council’s decision to go for a more integrated strategy in pursuing its recycling objectives. This combines the advantages of developing an additional well-sited HWRC with a denser pattern of local recycling points and an expanded kerbside service, mainly collecting extra green waste. This approach provides a richer hierarchy of opportunities for people to engage in recycling. 4.34 Finally, for completeness, the policy clarifies the way the Council will continue to process green waste that is collected as part of the municipal waste stream. 4.35 Whilst the alternative options (B&C) of building more HWRCs would undoubtedly improve the accessibility of those people wanting to bring waste to such centres, they are unlikely to be as cost-effective as the submitted policy in helping the City -37- to achieve its overall recycling objectives. The Regional Assembly has excluded the specific density standard on Civic Amenity sites from its draft RSS. The City Council has always argued that the standard was arbitrary, uncoordinated and an unnecessary constraint on developing local recycling strategies. Without a clear definition of the intended size and scope of the proposed CA sites, the regional standard lacked any meaning in planning terms. It was also unclear on the balance to be struck between desired provision of CA and non-CA facilities. Whilst Option C would have addressed the uneven access to larger recycling facilities it still fails to provide a fully integrated response that makes the best use of resources available to the Council for improving recycling performance. 4.36 The weakness identified for the submitted policy is not deemed to be significant. The disadvantages of having 6 HWRCs are likely to be offset by the convenience of having both a denser network of local recycling points and the opportunity to participate in an enhanced kerbside collection scheme. A major expansion of larger recycling centres will not necessarily result in a proportionate increase in recycling tonnages as waste may simply be shared out amongst the available deposit points. Sustainability Appraisal 4.37 The sustainability appraisal has been applied in a way that supports the Government’s objectives for waste management in PPS10 through the incorporation of a separate aim relating to positive use of the ‘waste hierarchy’. 4.38 Policy SW3 was assessed as having a positive impact on all main sustainability themes and in particular the resource efficiency aim relating to maximising recycling/composting of household waste. The other two options also scored well for this aim and the option of providing new centres to achieve the density of one per 15,000 households scored marginally better overall because it would be likely to result in greater accessibility for users of these facilities. For the reasons given above, it does not necessarily follow that this option would be superior for maximising recycling though. Despite the appraisal results, the submitted policy has been selected in preference to either of the alternative options. This is because it addresses the uneven distribution of existing HWRCs in a more cost effective way when complemented by proposed additional kerbside collections and an extended network of local bring sites, as set out in clause (c) of the policy. Equality Appraisal 4.39 The submitted policy is assessed as having no negative impacts on any of the groups identified for the purposes of this appraisal. Small-scale composting facilities and the expansion of kerbside collections and local recycling points is likely to be more beneficial for people with low access to private transport than building several larger centres that people will be expected to drive to. -38- Consultation Responses 4.40 As explained in paragraph 4.21, the submitted policy now combines a strategic Preferred Option PW1 on the ‘Distribution of Recycling Centres’ (now SW3b) with part of an Emerging Option on ‘Promoting Material Recovery’ (now SW3a & c), that was included in the City Policies document. This section deals with all responses to the options that are now relevant to the submitted policy. 4.41 At Emerging Options stage for the Core Strategy there was just one objection to SW3b (referred to below). There were 7 comments that were either supportive or neutral, because respondents recognised the need for linkage with other policies for more local bring sites and kerbside collection of recyclable waste. 4.42 At Preferred Options stage, 7 respondents supported option SW3b (including the Environment Agency (ref. 5218.029, and 3 residents groups (refs.174.009, 5126.009, 5288.005 and 5217.001). There were two new objectors (see below) and Government Office (ref.4871.023) queried whether there was a need for more facilities to process recyclates collected by the Council. There is no need to adjust the policy to include such facilities since it is expected that the existing MRF at Beighton would be able to manage any new collections of dry recyclates, and sites are already available within and adjacent to the urban area to accept more green waste. Clause (a) of the submitted policy clarifies that point. 4.43 There were opposing views submitted by Viridor Waste Management Ltd. (ref. 4656.04), Sheffield First Environment Partnership (ref.5257.006) and the local Green Party (ref.4886.011), who all preferred that the Council should aspire to achieve the density guidelines in adopted RSS (2004) as set out as option B. The Council has rejected that option. The guideline no longer appears in the Draft RSS (2005) and the Council has always regarded such a prescriptive standard as arbitrary because it does not take account of local bring site provision and kerbside collection services. The level of expansion implied in the guideline would not represent value for money in achieving recycling objectives in the City when compared to the more integrated strategy set out in policy SW3. 4.44 The submitted policy addresses most of the other concerns raised during consultation including comments on the Emerging Options in City Policies that sought an increase in local recycling points (Broomhill Forum ref. 4903.09), including at new or expanded supermarkets (local Liberal Democrat Party refs. 4865.10 and 5086.06). In its submitted form, policy SW3 expresses spatial elements of the Council’s approved Household Waste Strategy and it has been formulated in close consultation with the Waste Management Service. Conclusions on Reasons for Selecting the Policy 4.45 The policy has been selected because its strengths far outweigh its weaknesses and the alternative options do not represent affordable and integrated strategies for improving recycling performance. The advantages of the policy are borne out -39- by sustainability and equality appraisals, which are themselves supportive of national objectives for waste management. Whilst alternative option B was assessed as slightly better in the sustainability appraisal, the methodology used does not take account of resources that are available to deliver options and this must be a consideration for the local authority. The policy addresses most of the concerns raised through consultation and the Council’s Waste Management Service supports its content. Implementation and Monitoring (Soundness Test 8) 4.46 It is submitted that this policy meets the requirements of soundness test 8 in terms of having clear mechanisms for implementation and monitoring. The Delivery Schedule at Appendix A summarises the implementation arrangements. 4.47 The expansion in the number of local recycling points will be secured both through the Council’s waste contract with Veolia ES Sheffield Ltd. and through obligations associated with planning permissions for major developments. The latter will be taken up, alongside other recycling initiatives, in the City Policies document. 4.48 The proposal for an additional HWRC in the south west will be subject to available resources within the waste contract and a site being identified to serve the sector between the Manchester Road and Chesterfield Road corridors. At present, the facility seems more likely to be implemented between 5 and 10 years from the adoption of the Core Strategy. The City Sites document may be used to allocate suitable land for this specific purpose when resources are committed to this project. 4.49 Progress on implementing the policy will be monitored by recording the number of additional recycling points provided and the tonnages of recycled material delivered to the HWRCs. A key target has been set that the city will have a network of 6 HWRCs by 2018. Flexibility and Risk Assessment (Soundness Test 9) 4.50 The policy has been drafted with a view to the likely risks involved in its implementation. The proposed investment in public facilities depends to a large extent on the ability of the Council to provide sufficient funds in its Waste Management budget to fully implement its current Waste Management Strategy. In its funding strategy the Council is likely to carefully evaluate the contribution that individual proposals can make towards the priority of achieving agreed performance targets for recycling. 4.51 The submitted policy has been written to provide a consistent framework for development management. The weaknesses of the policy are not considered to -40- be significant and they are mitigated to some extent as described at paragraph 4.36. Conclusion 4.52 It is submitted that policy SW3 should be adopted as part of the Core Strategy having considered appropriate requirements and the criteria set out in the various soundness tests. It is considered to be the most appropriate policy for this issue as faced by the City and its content is based on a robust and credible evidence base that is summarised in section 4.45 (test 7). The policy has been prepared in accordance with national planning policy on waste management and the national waste strategy. It conforms to the draft RSS and has regard to other relevant plans and strategies, including the City’s adopted Community Strategy and especially the City’s approved Waste Management Strategy (tests 4&5). 4.53 As drafted the policy forms part of a coherent spatial approach to managing the city’s waste in the LDF and there are no conflicts with relevant plans prepared by neighbouring authorities (test 6). Clear mechanisms for implementing and monitoring the policy have been developed, including a specific and measurable target relating to improving the network of HWRCs. Finally the policy, and its associated target, incorporates some flexibility in providing a reasonably robust framework for development management of these recovery facilities (tests 8&9). -41- Appendix A Delivery of Core Strategy Waste Management policies Policy: SW1 Waste Development Objectives Target: Recycle and recover 80% of the City’s Municipal waste by 2015 Actions required Agencies Timing Probability/risks To deliver: Implement waste reduction measures and additional recycling services and trade in LATS allocations SCC- Waste Management Limit additional landfill developments and permit additional treatment facilities through planning decisions SCC- Planning 0-10 years Some commitment in existing Household Waste Strategy but specific funding needs to be identified To support: Include regulatory policies and allocation Within 5 SCC- Planning proposals in supporting Development Plan years Documents Monitoring Indicator(s): Record waste arisings and proportions of municipal waste that is recycled/composted, recovered or sent to final disposal. -43- Policy: SW2 Safeguarding Major Waste Facilities Target: At least 5.5 million tonnes of waste managed at facilities at Bernard Road and Parkwood Landfill site by 2021 Actions required Agencies Timing To deliver: Continued operation of these treatment and disposal facilities Veolia ES Sheffield Ltd. and Viridor Waste Management Ltd. Throughout plan period or until infilling is completed at Parkwood site To support: Designation of these facilities in Waste SCC-Planning Management Areas in supporting Development Plan Documents Monitoring Indicator(s): Checking the throughput of these facilities annually. -44- Within 5 years Probability/risks -45- Policy: SW3 Provision for Recycling and Composting Target: Six Household Waste Recycling Centres to be operating by 2018 Actions required Agencies Timing Probability/risks To deliver: Identify and develop more local recycling points SCC-Waste Management Oblige major developments to provide or contribute to local recycling facilities through planning decisions SCC-Planning Identify and acquire site to build the southwest HWRC SCC-Waste Management 5-10 years SCC-Planning Within 5 years 0-10 years Commitment exists in the adopted Household Waste Strategy but specific funding still needs to be identified To support: Include regulatory policies and allocation proposals in supporting Development Plan Documents Monitoring Indicator(s): Recording the number of additional local recycling points introduced and the tonnages of recycled material passing through the Household Waste Recycling Centres. -46-