Southwest Environmental Limited

Waste Recovery Plan

A waste recovery plan outlines the practices that you will use to recover waste, rather than dispose of waste. In support of an Environmental Permit that aims to permanently deposit waste with the aim of recovery, improvement, re-profiling, the waste recovery plan needs to prove that the waste is being recovered not being disposed of.

Use Specific Waste Recovery Plans

 Construction of Lakes  Re- Profiling of Agricultural Land  Construction of Bund

Waste Recovery Plan - Case Study

Example 1:

A firm creates more crushed concrete than it can use in its construction activities, and a nearby farmer consents to the re-profiling of a field that often causes damage to his equipment owing to its undulose nature.

Working on this principal, waste might be recovered in use to re-profile the land, filling in large hollows.

Getting your waste recovery plan right first time is important it could been the difference between applying for a recovery permit and a disposal permit, where possible disposal permits should be avoided.

Image: Peter Craven [CC BY 2.0], via Wikimedia Commons

Waste Recovery - Accepted Uses

It is becoming harder and harder to apply for a waste recovery permit, and the information contained with a waste recovery plan needs to as complete as possible in order to stand the best chance of having your initiative passed of my the Environment Agency.

When assembling a waste recovery plan Southwest Environmental Limited use as much quality data as possible, in order to put across the best possible argument for proving recovery.

For example a waste recovery permit which seeks to mitigate visual impact in prepared along the line of a visual impact assessment, which will include 3D models and computer generated views from various receptors, if a case were to be built on the mitigation of noise impact rather then visual then a quantitative argument can be presented in dictation likely pre and post development noise levels at nearby sensitive receptors.

Another accepted use may be for the re-profiling of a field that has had historic industrial uses this might include marl pits, or clay pits which can be a nuisance to farmers and can render large areas of their land un-workable, as well as being a hazard to livestock.

Waste Recovery - EA Guidance

At present the Waste Recovery vs Disposal concept is set out in RGN13, which is a very thin document for such a complex business. At present Recovery vs Disposal is rife with subjectivity. Problems arise with the phrase "is the minimum amount of waste being used", as this is very hard to prove in most cases. It is easy to prove benefit, but harder to justify a considered volume, and at present no quantitative guidance is available from the EA which can cause problems. See below examples:

Lack of Waste Recovery Guidance  - Case Study

EAWML OOOOO

This application was initially turned down owing to “lack of evidence to support recovery operation”, extra evidence was provided and the bund height was reduced to levels where it provides little visual mitigation. The original bund height was deemed appropriate by the South Somerset LPA Landscape Architect who has visited the site on numerous occasions, yet we had EA staff operating from an office in the northern counties vetoing this notion and reducing visual mitigation. Planning permission has now to be reapplied for because of the altered bund . . .all very time consuming.

We appreciate that planning law and waste law are two different things entirely, but there is some overlap and at present it would seems that the EA are not listening to LPAs.

EAWML OOOOOO

This scheme is somewhat related to the above scheme as it forms part of a larger farm redevelopment, and indeed falls under the same landscaping master plan. In the case of this recovery operation we feel I have supplied sufficient evidence to prove recovery. We have explained benefits as fully as we can, and have illustrated them as clearly as possible to the waste recovery staff. This application has stopped being considered and I am not even allowed to debate its worthiness. Adequate reason for this decision has not been provided other than general comments such as “we need more evidence” . . . . which evidence we have not been told.

In relation to the above two cases I would suggest the following:

• The EA publish a more extensive set of guidance with relation to waste recovery, which includes quantitative guidance on concepts as “minimum quantities of waste”.

• There are low risk allowances made for WR schemes that incorporate solely sub soil as a fill medium, or fill activities involving sub soil only should be exempt.

• A one step assessment process should be implemented. Assessor has “one chance” to ask for information, if this information is then provided the WR Plan should be passed off, this would avoid the time consuming “drip feed” of information which I have had to provide for the above two cases.

• Appropriate Quantities should be tied more rigidly to landscaping plans. This will avoid time consuming reapplications, and put the “quantity question” in the hands of people who know their area’s needs.

This critique’s aim is purely to inform you of working case studies within your area, I appreciate the complexities involved in enforcing such “young” legislation. I haven’t named any names because I don’t believe anyone is to blame, but at present the time scales involved in assessing waste recovery do not relate to real world project timelines . . . it just takes far too long.

Specifc Waste Recovery Operations

Construction of Bund

The visual impact of the (for example) grain stores can be mitigated via the construction of the proposed bund, the bund extends to around X meters in height, which will obscure the view of the grain store when viewing from the open country side. On completion of the bund trees are to be planted along the ridge to increase its effectiveness as a visual barrier.

The bund is a logical choice for a visual barrier owing to the waste stream being produced by PPP, rather than this waste go to landfill it is a more sustainable option to recover this waste in the construction of a bund that mitigates visual impact. Trees would be slow to provide this barrier perhaps taking 10 years or more to grow to a sufficient height to provide a visual barrier, other manufactured solution would create unjustified environmental impacts owing to the ready and plentiful source of inert materials occurring on a daily basis, from the company’s construction activities.

So as to prove the mitigating effect of the bund with regards to visual impact a selection of 3D visualisations should be prepared;

Construction of Lakes

Drought Resilience

Whether it be drinking water for livestock or water for irrigation purposes, there is a steady demand for water on farms (see below graph).This steady demand is mismatched with an unsteady supply. Rain fall is not equally spread throughout the year as was demonstrated in the dry spring of 2011 that saw stunted crop growth, and subsequent price rises in bedding and fodder in the autumn of that same year. 

[1]

Annual Water Use

 During drought crops can be irreversibly damaged leading to financial losses and economic instability both on national and local levels[3].

To counter act these extreme weather conditions greater reservoir capacity is needed on farms, President of the National Farmers Union Peter Kendell has said;

“More reservoir capacity is needed on farms to cope with the unpredictability of weather patterns in      recent times”

The Environment Agencies Drought Prospects Report[4] aims to promote water security to farmers and others alike, having its own water supply Corton Wood Farm will be more drought resilient Reservoirs can be filled with surface water run-off during wetter periods to provide irrigation water during drier periods. 

“The farming industry is also considering how it can become more resilient to dry weather . . . . . as well as considering building or enlarging their farm reservoirs.”

The Environment Agency recommends[5] the filling of reservoirs using winter abstraction which if over 20 m³ per day requires an abstraction licence.

Climate change[6] shows the UK becoming drier, and a growing population. Water ergo food security is of high importance. There is clear benefit from creating an embankment reservoir to supply stored to the farm. Not only will it decrease the farms sensitivity to drought but it will decrease loads on the water grid during times of drought. [2]

Profiling of Agricultural Land

Operation of Machinery

The land is currently in arable use. Sewing, spraying and harvesting of crops is now carried out using machinery of a very large size. Combine harvesters for example are commonly 10 meters in width, sprayer booms can be wider still and require level ground on which to operate. This is particularly important in the headlands of fields where turning of equipment on undulous ground may cause booms and combine heads to come in to contact with the ground.  You can demonstrate benefit in this instance by taking a scale rule, and placing on the cross sections. A ten meter straight line (representative of a sprayer boom or combine), when placed on undulous areas will show it present it is impossible to operate modern arable farm machinery in the proposed areas.

There may be benefit from increased domestic production and less reliance on imports (emissions from shipping are saved). There is benefit from less machine hours per unit of production  (emissions saved from reduced machine operation). There is benefit from less damaged  equipment due to grounding (emissions saved from non-replacement machine parts).

Use in Drainage Drainage

Some agricultural or development land can be plagued by poor drainage. "French drains" or culverts can be constructed with crushed recycled aggregates.

Site Condition Report

Site Management Plan