14. Minerals and waste processing
14.1 Minerals extraction in Bexley has taken place in the past over considerable areas of the borough, particularly along the rivers Cray, Darent and Thames, where alluvial deposits have been found. Minerals have, and continue to be, a vital component of the construction industry, necessary to facilitate the building of homes, businesses, community facilities and infrastructure.
14.2 By the nature of the exploration, exploitation and storage of minerals there is a desire to minimise the adverse impacts associated with this kind of development, such as increased road traffic, congestion, noise and air pollution, by favouring mineral extraction as close as is environmentally acceptable to the point at which the minerals are needed. This is supported in Strategic Guidance, which stresses the importance of London contributing as much as possible to meeting its own needs, which are expected to remain far in excess of that produced within Greater London.
14.3 By 1996 there was only one active site extracting minerals in Bexley. This site has operated for some time and output is not expected to increase significantly over the Plan period. The Council will seek to safeguard any remaining deposits from surface development. Proposals to exploit them will be considered in the context of the relevant policies below in order to minimise the adverse impacts associated with this form of development and restore sites to a satisfactory standard once the operation is complete.
14.4 The Council recognises that while remaining reserves within the borough will contribute to meeting London's needs, in accordance with Government advice in Minerals Planning Guidance Note 6, the majority of the future minerals demanded will have to be imported from further afield. Close liaison with: neighbouring authorities; the Greater London Authority; regional planning or development organisations, including partners within the Thames Gateway; and the South East Aggregates Working Party; will be maintained in order to address these problems. In addition, existing facilities, which minimise the traffic impact of minerals transhipment, such as deep water wharves on the Thames and rail depots and facilities should be retained where possible.
14.5 Disused mineral sites should be restored to a high standard when operations are complete. One method of restoration includes infilling with waste, which has been carried out in Bexley in the past, causing some problems associated with degradable waste and the resultant gas emissions and leaching. These issues will be considered in the remainder of the chapter and in relation to the Mayors Municipal Waste Management Strategy for London and other emerging waste strategies for the South East.
In considering proposals for the exploration, exploitation and storage of minerals, the Council will seek to ensure that the environment and public amenity and safety are safeguarded, by ensuring that the following criteria are met:
- there is an identified national, regional or local need for the mineral concerned and that the quantity and quality of the reserve should be sufficient to justify the extraction;
- there are no significant adverse effects on the environment, including Sites of Nature Conservation Importance (Policies ENV23-25), and sites of archaeological importance (Policies ENV56-58) or residential property;
- there are no significant adverse effects arising from traffic generation and access/egress to and from the site;
- the proposals should not significantly increase the risk from flooding or adversely effect ground and surface waters; and
- there are satisfactory proposals for the restoration and after‑use of the extraction site.
14.6 Due to the considerable disturbance costs incurred when a decision to exploit mineral reserves is taken, the Council will seek to ensure that these costs are kept to a minimum by meeting the criteria above. In order to reduce the need for further importation of minerals, and meet the SERPLAN supply policy for London, an identified need for the mineral in question in relation to the current supply position in London and the South East should be considered before the release of reserves is approved. In addition, the mineral in question should be of sufficient quantity and quality to justify the impact of extraction on an area.
14.7 Although mineral extraction is a temporary use, the impact on the environment and in particular on nature conservation interests as laid out in Chapter 5 will be taken into consideration when determining an application together with the impact on neighbouring residential property. Traffic generation and access and egress from the site will also be considered, together with policies in Chapter 8 of the UDP. Where these impacts are considered unacceptable the proposals will be resisted.
14.8 Regarding the possible impact of extraction on the flood plain and water quality objectives in general, developers are reminded of the need for early consultation with the Environment Agency.
14.9 Satisfactory proposals for the restoration and after use of extraction sites will be considered in relation to Policy MIN5, taking into account applicants' past record of working and restoring sites. The use of planning conditions and legal agreements to ensure satisfactory restoration may be applied where appropriate.
14.10 Finally, proposals to extract minerals from a site should include a statement by the applicant regarding the significance of the impact on the environment. If this is felt to be unacceptable the proposal will be resisted.
Proposals for mineral exploration, exploitation and storage would not normally be permitted where this use would result in the loss of high quality agricultural land (grades 1, 2 and 3a) and/or land with a high recreational, amenity or nature conservation value unless the Ministry of Agriculture, Fisheries and Food indicate that they are satisfied that after a period of aftercare the lands' former (undisturbed) physical characteristics are likely to be restored as far as it is practicable to do so and would be likely to sustain the demands of commercial agriculture.
Where Policy MIN2 is satisfied, the Council will have regard to the economic viability of any farm units involved and the phasing of extraction.
14.11 The Council recognises the importance of high quality agricultural land in maintaining a viable agricultural industry and to maintain the existing landscape quality of the Green Belt. The Ministry of Agriculture, Fisheries and Food has accepted the principle that land of a high quality can be released for working subject to appropriate restoration proposals. Where this is satisfied, an additional consideration will be the phasing of the development and restoration in order to retain the economic viability of farms, during the operation.
Wherever possible, potentially workable mineral deposits will be safeguarded from surface development that would sterilise the minerals or prejudice their working. Where development is proposed the Council will consider the prior excavation of the mineral, subject to Policy MIN1.
14.12 Any remaining mineral reserves within the borough are likely to be within the Green Belt and, therefore, surface development will be unlikely to sterilise the deposit. In areas outside the Green Belt where deposits may be found, surface development will be permitted only after the reserve has been exploited in accordance with Policy MIN1 in order to meet the objectives of reducing the impact of mineral production wherever possible by making available resources within London.
Restoration after use
The Council will seek to ensure that disused mineral sites are restored to a high quality by the developer, within a reasonable time scale and to a condition such as to make possible an appropriate and beneficial after use. Where infilling is necessary there will be a presumption against the use of degradable waste without satisfactory measures to deal with landfill gas and leachate both during and after operations.
14.13 Strategic Guidance states that UDPs should specify high standards of restoration both in areas to be worked for minerals and also land already damaged by mineral working. As stated above, Bexley has experienced a number of mineral operations in the past, particularly in the more open lands to the east of the borough and within the urban fringe. Some of these operations have led to damage in areas of Metropolitan Green Belt and Metropolitan Open Land. Policy MIN5 seeks to minimise future long-term impacts associated with disused sites in accordance with the overall vision of the Plan. In addition, the Council will resist the use of disused minerals workings for landfill with degradable waste without satisfactory aftercare proposals. This is because of the problems associated with this form of disposal, in particular landfill gas emissions and leachate, and to accord with the relevant waste disposal plan.
14.14 Where appropriate, the use of former minerals workings for recreational uses may help to meet the borough's needs for certain facilities, in particular water based activities, as described in Policy TAL13 in Chapter 10. Use of areas of water in restoration proposals will be the subject of consultation with the Civil Aviation Authority (CAA) with regard to possible bird strikes on aircraft.
Deep-water wharfage and aggregates works
There will normally be a presumption against the loss of existing deep-water wharves and other transhipment facilities for minerals in the borough, unless suitable alternative facilities are proposed or available nearby, either within the borough or neighbouring Thames-side local authorities.
Proposals for new deep water wharfage transhipment facilities and associated aggregates works will be encouraged to locate within the Special Industrial Zones, subject to Policy E13, as shown on the Proposals Map.
14.15 Strategic Guidance states that there should be a presumption against the loss of existing transhipment facilities, and in particular riverside wharves, unless alternative uses exist nearby. The Council recognises the importance of retaining these facilities given the benefits obtained from using water‑based rather than road transport for minerals transportation. However, the Council also recognises the adverse impact of this type of land use on neighbouring uses and therefore proposes to locate future land uses of this type in the Special Industrial Zones where the impact upon the borough as a whole can be minimised and contained. Developers should also have regard to the criteria listed under Policy MIN1 above.
The Council will encourage the efficient use of minerals, including the use of recycled materials to ensure that:
- the borough's limited remaining resources are used appropriately; and
- to minimise the need for the importation of minerals.
14.16 The Council recognises the importance of using mineral resources wisely. In doing so the Council will encourage the appropriate use of minerals in construction projects in the borough to ensure that high quality materials are not used where lower grades would be acceptable. Encouraging the utilisation of recycled materials, where appropriate, will also help to reduce the need to import minerals into London.
14.17 The Council will keep under review and monitor further Government guidance on the efficient use of minerals as set out in MPG6 and RPG3.
Waste transfer and processing
14.18 Bexley Waste Disposal Authority came into being as a statutory body under the Local Government Act 1985 on the abolition of the Greater London Council (GLC) and the transfer of responsibilities for waste disposal to Bexley Council in March 1986. At the time it was one of only two independent disposal and collection authorities in the country. In the London area, the regulation function was, until 1.4.1996 carried out by the London Waste Regulation Authority (LWRA). This body now forms part of the Environment Agency. Bexley has responsibilities for its own contracts in the collection and disposal of waste.
14.19 The Environmental Protection Act 1990, as amended by the Environment Act 1995, provides the present legal framework within which waste disposal is carried out. Part 2 of the Act requires waste collection authorities to investigate the appropriate arrangements required to deal with waste, prepare a statement of the arrangements made or proposed to be made for a specified period (The Recycling Plan) and to further investigate and modify arrangements to take account of changes in the situation. Under the Environmental Protection Act 1990, the waste disposal planning function transferred first to the London Waste Regulation Authority and following the Environment Act 1995, it is now the responsibility of the Secretary of State for Environment, Food and Rural Affairs, to produce the National Waste Strategy. National policies now include tax on landfill to help encourage recycling, the money collected being intended to assist environmental projects.
14.20 The Greater London Authority Act 1999, Section 353, placed an obligation on the Mayor of London to prepare and publish a Municipal Waste Management Strategy for Greater London (published 2002). This includes policies and proposals for the recovery, treatment and disposal of municipal waste originating in Greater London. When preparing this strategy, he must have regard to Boroughs Recycling Plans and consult London Local Authorities and others. To ensure that the policies in the strategy are given effect, the Mayor can direct waste collection and disposal authorities to carry out a function in a specific manner. The Mayor is intending to give effect to the land use requirements of his Waste Strategy through Sub Regional Development Frameworks, to be published as Supplementary Planning Guidance to the London Plan.
14.21 In addition to the National Waste Strategy and the Mayor of Londons Municipal Waste Management Strategy, the Council is also required to include relevant policies in its UDP. PPG10, Planning and Waste Management, states that these policies should have regard to the authority's relevant waste disposal plan and policies for waste minimisation and recycling. Plans should consider the need for new and extended waste management facilities in suitable locations and the planning criteria likely to apply, including geological, hydrological and other considerations. The policies below address these issues.
The Council will take account of the Bexley Waste Minimisation and Recycling Plan in determining proposals for waste management facilities and for other development proposals, which may generate significant waste arisings.
14.22 The draft National Waste Strategy for England and Wales requires Waste Planning Authorities to take full account of Waste Recycling Plans prepared by the Waste Collection Authority. In Bexley the Council is both the Waste Planning Authority and Waste Collection Authority. To ensure a consistent approach, proposals for further waste management facilities and other developments, which may significantly increase waste arisings in the Borough, will be considered in the context of the Bexley Waste Minimisation and Recycling Plan.
Planning applications for the transfer, disposal and processing of waste will not normally be acceptable outside the Special Industrial Zones and in any event must satisfy the following criteria:
- the proposal will not lead to significant adverse impacts on the amenities of residential or commercial areas;
- there are no significant adverse environmental impacts, such as airborne or waterborne pollution, noise, smells, and unreasonable traffic generation;
- sites should have good connections to primary and secondary roads and the proposed use acceptable within the terms of Policy T6;
- where possible, rail and river transport should be used for the transport of waste;
- proposals for landfill should have regard to Policy MIN5 and also the criteria in Policy MIN1, amended as necessary so as to relate to waste disposal;
- the proposal is in accordance with the Waste Recycling Plan;
- there is no conflict with Policy E13 and with the policies contained in Chapter 5 of this Plan; and
- development for waste processing facilities, including energy from waste, should be of an appropriate scale to ensure that waste is processed close to the point at which it is generated, in accordance with the proximity principle.
Where appropriate, an environmental assessment will be required within the terms of the Town and Country Planning (assessment of environmental effects) Regulations 1988, including the measures proposed to overcome any potentially harmful environmental effects. The environmental assessment will be expected to take into account the combined effects of schemes, which are committed but yet to be implemented.
14.23 In accordance with the objectives of the Bexley Recycling Plan, Policy WAS2 seeks to ensure the most efficient and cost effective disposal of waste arising in Bexley Borough, safely and in an environmentally friendly way.
14.24 Proposals for waste disposal in the borough, which concern waste arisings in Bexley, should have regard to the Recycling Plan as criterion 6 states and as indicated by paragraph 13, PPG10.
14.25 In the event of responsibility of the preparation of the Recycling Plan being transferred to another authority over the plan period of the UDP, Policy WAS2 will take account of any replacement statutory document or guidance concerning the future disposal of waste arising within the borough, until such time as the UDP is superseded.
14.26 Strategic Guidance states that boroughs should make appropriate provision in their UDPs for facilities such as incinerators, recycling plants and transfer stations (para. 39 PPG10). In addition, the Government and the European Community stress the importance of minimising the costs on the environment of more traditional methods of waste disposal, such as the dumping of sewage at sea and the problems associated with landfill, such as landfill gas emissions.
14.27 The Council recognises the importance of these methods both as a means of saving finite resources and protecting the environment. However, current methods used for these alternative processes can lead to significant impacts on the environment and neighbouring uses. In order to ensure that the benefits derived from these methods do not lead to an unacceptable impact, the Council will normally require them to be located in the Special Industrial Zones and subject to the criteria contained in Policy WAS2. This is to accord with Policy G1.
14.28 In exceptional circumstances, the Council would be prepared to consider proposals outside the Special Industrial Zones where it can be demonstrated that proposals must, for operational reasons, be located elsewhere in the borough and that there would be no adverse effects on surrounding uses as a consequence of doing so. This is to recognise the diversity of needs of waste operators and the different impacts that their proposals may have on the environment.
14.29 Proposals which include the incineration of waste will not normally be permitted unless the Council is satisfied that there will be no significant effects on the environment within the scope of the matters listed in Schedule 3 to the Town and Country Planning (Assessment of Environmental Effects) Regulations 1988, and there is no conflict with any other policies in the Plan. The Council will, in the circumstances prescribed by the Regulations, seek an environmental assessment before considering such proposals. In addition, it will take into account the cumulative impact of schemes on an area. This is because, where individually a scheme may meet the criteria in Policy WAS2, in combination with the impacts of other, similar schemes on an area yet to be implemented, this may not be the case. Where possible, the Council will seek joint public inquiries into schemes, to ensure that the cumulative impacts of schemes are fully considered.
14.30 As a result of some industrial and medical activities, some waste is generated, which requires special disposal arrangements. These arrangements are currently laid out under the Control of Pollution Act 1974, while the function of disposal is carried out by contractors in the private sector. The Council wishes to ensure that the disposal of special wastes is carried out safely and efficiently and would normally be acceptable only in the Special Industrial Zones, for the reasons set out in paragraph 7.34, and subject to the criteria set out under Policy WAS2.
14.31 Provided a refuse freighter can reach a disposal site without undue disruption to the service, direct delivery is likely to be more cost effective than transfer. However, the Council recognises that over the Plan period distances to landfill and other waste disposal facilities in and around London may increase incurring greater costs. For this reason, the Council will be prepared to consider proposals for waste transfer stations which accord with the waste disposal plan. Where possible, the use of rail and river transport should be utilised in order to minimise the adverse impacts associated with road transport. These waste transfer stations would normally only be acceptable in the Special Industrial Zones because of the adverse impacts such developments may have on neighbouring uses. Exceptions will only be considered in accordance with paragraph 14.28 above.
14.32 The proximity principle has been adopted by the Government in recent guidance on waste and pollution. The Government acknowledges that the disposal or management of waste close to the point at which it is generated creates a more responsible, and hence sustainable, approach to the generation of wastes, and also limits pollution from transport (PPG23 - Planning and Pollution Control July 1994).
14.33 At regional level, paragraph 2.5 of PPG23 notes, with regard to regional self sufficiency that: " nor should it make it acceptable for waste to be transported from one side of the region to the other, when there are adequate facilities nearby - the proximity principle still applies." The Thames Gateway London Partnership also supports these principles in its waste planning and management strategy for Thames Gateway London.
The Council, while supporting renewable energy initiatives, also support the contention that facilities, such as incineration, should not be of such a scale that jeopardises other land use planning objectives, such as the regeneration of an area.
Crayford Marshes landfill site
The Council will seek the restoration of this former refuse tip, now a landfill site, to a use appropriate to the Green Belt, at the earliest opportunity.
At no time will the council permit any operation other than landfill to complete the restoration of the former refuse tip.
The Council will not accept any extension or intensification of the existing landfill operation that would fail to meet the following objectives:
- the protection of the River Cray/River Darent floodplain;
- the protection of views across the Green Belt to the River Cray, River Darent and the marshland landscape;
- the protection of the identified ecological interest of the River Darent, River Cray and Crayford Marshes; and
- the reduction of the amount of traffic using the inadequate access to the site.
14.34 In the past some landfill operations carried out in the borough have not been carried out or restored to a satisfactory degree leading to contamination, landfill gas emissions and poor quality after uses. The Crayford Marshes landfill site represents an inherited responsibility from the Greater London Council, and arrangements have now been agreed which make the site owner responsible for undertaking the completion and restoration of the site to an environmentally satisfactory standard.
14.35 The site is located in the Metropolitan Green Belt and should be restored to an appropriate use at the earliest opportunity. In addition the site has been designated as a site of Borough Importance for Nature Conservation and future proposals on the site should take account of Policy ENV24. Neighbouring sites such as Crayford Marshes and the River Darent are designated as being of Metropolitan Importance for Nature Conservation which should also be taken into account.
14.36 Intensification of the existing landfill operation will be contrary to these objectives, and may also have adverse consequences for the floodplains of the rivers Cray and Darent, the strategic views across Green Belt land and traffic flows into and out of the site.