BRIEFING NOTE FOR WILTS COUNTY COUNCILLORS

REF:"WILTSHIRE & SWINDON WASTE LOCAL PLAN 2011;
ISSUES AND OPTIONS"

 

Communities south of Salisbury are alarmed that this document proposes the construction of a 50-acre "Household Waste Management Facility" somewhere within an 'Area of Search' between the villages of Whiteparish and Alderbury.

With 6 waste sites already established (8 if car breakers yards are included) within a 5-mile radius, this alarm is not a case of 'NIMBY'ism.

Serious policy issues are raised by the proposal.

This note is intended to outline what these are and, more crucially, to argue the case for withdrawing the highly contentious 'Area of Search'.

 

WHAT'S IT ALL ABOUT?

The document proposes splitting the county up for the purposes of managing household waste.

BUT there are no current guidelines advocating a cellular approach to waste management on this scale.

On the contrary, such an approach is likely to fail viability and sustainability targets set by current guidelines.

The plan sets out to identify suitable sites for Swindon, North Wilts, Kennet, West Wilts, and the Salisbury District area.

BUT Salisbury District area is the only one where the (50-acre) proposed site is not based on an existing waste activity (in an urban industrial situation).

INSTEAD, and uniquely, a 10-mile long, 2-mile wide (?) rectangular 'Area of Search' has been indicated. This runs from Alderbury to Whiteparish with its axis on the A36.

The officers have vehemently denied that they already have a specific site in mind within this area.

(Planning permission exists, but has not yet been implemented, for a 50-acre sand extraction operation and back-fill with dry inert commercial waste at Newton Corner on the A36. This is inside the Area of Search.)

WASTE IMPORTATION

By far the most important issue is that the Wiltshire is in the embarrassing position of being a net importer of waste.

The council's own document states that it has to dispose of a just over 1 million tonnes of waste per year.

Around 30% of this (300,000 tonnes) comes from outside the county.

The south of the county is the biggest target for these imports, and is consequently under the greatest pressure.

Positioning a new waste facility in this area will, because of its closeness to Southampton, Eastleigh, Portsmouth & Bournemouth, lead to an uncontrollable and exponential increase in waste imports into the county.

(Officers have publicly conceded that, once constructed, no controls can be imposed on the source of incoming waste.)

This directly conflicts with policy.

For many years now, this area south of Salisbury has been under unrelenting pressure from waste contractors. They are attracted by its good access (A27 & A36) and the substantially more lax waste policy regime in Wiltshire, contrasting sharply with that of Hampshire (growing fast & producing a huge and increasing domestic, commercial and industrial waste output).

This is the solution the private waste industry want because it suits them.

SHOULD WILTSHIRE CONTINUE TO BE THE EVER-MORE BURDENED RUBBISH TIP OF THE SOUTH ?

This argument alone should be strong enough grounds to reject the current approach to south Wiltshire's future waste management plans & policies.

 

A more positive way forward would be for Household Waste Management policies to be based on treating the county as an entity (perhaps with the exception of Swindon and/or North Wilts, both of which are already well provided for).

This will have the advantage of more certainly meeting sustainability & viability targets.

The current haulage contract (which has around 16 years to run) for conveying Salisbury's waste to the north of the county could be re-assigned, minimising wasted resources.

The 'Proximity Principle' would be centred somewhere just south of the geographical centre of the county - where there are existing waste operations with potential for further development.

Other relevant issues follow -

DOCUMENT METHODOLOGY

At public meetings held in villages threatened by the proposals (2 meetings had to held in Whiteparish because of the overwhelming numbers who attended), Mr Geoff Chequers (Minerals Officer) and Ms Rachel Ness (Senr. Planning Officer), together with Mr Lander (Head of Environmental Services), set out to justify their 10-mile 'Area of Search'.

It was explained that for the Salisbury District area, a simple "sieve" test approach had been taken. This involved sequentially overlaying maps with outlines of 'excluding' criteria such as: prime agricultural land, AONBs, Heritage Sites (Stonehenge World Heritage Site being the most significant), SSSIs, Aircraft Movement zones etc.

This methodology is now widely regarded as a crude and outdated approach to a challenge of this nature, generally rejected by local authorities.

No mention is made in the plan of any Environmental Impact studies.

Little evidence was shown of any convincing effort to find potential sites within existing urban/industrial environments.

 

LANDSCAPE CONTEXT

The entire AoS(Area of Search) is designated 'Special Landscape Area'.

Pepperbox Hill, a National Trust owned open space & viewpoint, lies right in the centre of the AoS.

It is also host to at least three (3) SSSIs (Sites of Special Scientific Interest).

This fact has been inexcusably omitted from the Consultation Document.

Other sites with SSSIs are rejected on these grounds alone.

Pepperbox Hill is part of a chalk ridge forming the natural, geological limit of the historic New Forest. At present, the New Forest Heritage Area does not extend this far, but the boundary is expected to be reviewed when it receives National Park status, due shortly.

No additional risk of environmental threat should be entertained at this stage.

 

WASTE MANAGEMENT CONTEXT

Waste importation has already been addressed.

There are currently 6 active waste tip sites within a 5 mile radius (8 if car breakers yards are included) - a totally disproportionate figure compared with areas to the north and west of Salisbury.

Several other local sites (both legal & illegal) have been filled and restored - with varying degrees of environmental acceptability.

The biggest currently active site, operated by Biffa Ltd., is less than a mile from Pepperbox. It is constantly offensively smelly, and from being just a modest agricultural lime quarry only recently, it is now a vast operation.

 

THE 'PROXIMITY PRINCIPLE'

For the Salisbury District area, the plan employs a 'Proximity Principle',

applied as a 10 mile radius centred on Salisbury.

Applying the 'Proximity Principle' in this way again lacks any appropriate grounding in existing Government & European guidelines/legislation.

Applying it in its current form on Salisbury as a centre is unacceptably flawed in two respects.

  1. The circle created extends well into Hampshire - covering land not available (although two large waste sites exist within a few miles, one taking at least 3 x 40 tonne trucks of waste from London daily).
  2. It fails to acknowledge the demographic 'offset' effect of the secondary population centres of Amesbury, Wilton & Mere - all to the north & west of Salisbury. These are also all centres allocated for future residential development in the Salisbury District Local Plan, and so will weight future domestic waste output still further in that direction.

If the 'Proximity Principle is to be applied at all, it's centre-point should be well to the north-west of Salisbury, and it should have a much greater radius.

 

PLANNING CONTEXT

In addition to the Landscape setting aspect already covered, the scale of the 50-acre 'Household Waste Management Facility' will require buildings, structures and machinery on an industrial scale and with consequent environmental impact.

In Planning terms, no new industrial operation on this scale would be entertained in open countryside.

Imposing what is already amounting to 'Planning Blight' on this vast swathe of Special Landscape Area is unacceptable and should be withdrawn immediately.

 

TRAFFIC IMPLICATIONS

Salisbury's existing traffic congestion problems would be further exacerbated by additional waste traffic having to pass through/around the city's inadequate roads.

The A36 south exit/ingress from Salisbury is one of the worst traffic bottle-necks in the region.

No new policies should be implemented which would add to this congestion.

 

VIABILITY & FUTURE CONTROL

WCC officers have conceded that they have no idea what size operation will be commercially viable (this site will be operated by the private sector), but they have committed themselves to 50 acres, with 'some' landfill.

They admit that there may be a need for an incinerator, but cannot say what size/output level or whatever.

They admit that they will not be able to control who uses it once it is established.

They cannot give the parameters of what will constitute 'commercial viability', stating that they expect the private sector to provide this information.

 

SUMMARY

This is a flawed document with some mis-guided proposals that have not been thought through, some of which are in direct conflict with existing policies.

There are significant errors.

The proposed 'Area of Search' is the most obvious example of the document's shortcomings.

The residents of Wiltshire, and particularly those south of Salisbury, rely on you to take this forward in the positive way suggested by proposing and voting for the withdrawal of the 'Area of Search' in both principle and detail.

Thank you for taking the trouble to read this, and we look forward to seeing you give your support when we attend your next committee meeting.

Thank you.

Author: Malcolm.Adams, Whiteparish.

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