ANAEROBIC DIGESTION FACILITY AT ROUNDHILL SEWAGE …

Anaerobic Digestion Facility Land at Roundhill STW, Staffordshire

Planning Statement July 2015

ANAEROBIC DIGESTION FACILITY AT

ROUNDHILL SEWAGE TREATMENT WORKS, ROUNDHILL,

STAFFORDSHIRE

Planning Application

Supporting Statement

July 2015



Contents

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

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

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

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

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

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

3.1 The Roundhill Site ............................................................................................................................... 4

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

4. PROPOSED DEVELOPMENT .................................................................................................. 8

4.1 Description of Proposal ....................................................................................................................... 8

4.2 Anaerobic Digestion Process ............................................................................................................... 9

4.3 Hours of Operation ........................................................................................................................... 11

4.4 Town and Country Planning (Environmental Impact Assessment)(England) Regulations 2011 .......... 11

4.5 Community involvement and Pre-application Consultation .............................................................. 11

5. PLANNING POLICY APPRAISAL ......................................................................................... 12

5.1 The Statutory Development Plan ...................................................................................................... 12

5.2 Waste ................................................................................................................................................ 14

5.3 Renewable Energy ............................................................................................................................. 16

5.4 Locational Requirements ................................................................................................................... 18

5.5 Landscape and Green Belt ................................................................................................................. 22

5.6 Design ............................................................................................................................................... 27



5.9 Environment ..................................................................................................................................... 30

5.10 Conclusion ......................................................................................................................................... 33

6. THE NEED FOR THE DEVELOPMENT ............................................................................... 35

6.1 Renewable Energy ............................................................................................................................. 35

6.2 Waste Management .......................................................................................................................... 36

6.3 Anaerobic Digestion .......................................................................................................................... 37

6.4 Environmental Benefits ..................................................................................................................... 39

6.5 Economic Benefits ............................................................................................................................. 40

6.6 Summary ........................................................................................................................................... 40

7. WASTE ARISINGS WITHIN STAFFORDSHIRE ............................................................... 41

7.1 Joint Waste Core Strategy Evidence Base .......................................................................................... 41

8. ALTERNATIVE SITES ASSESSMENT ................................................................................. 44

8.1 Introduction ...................................................................................................................................... 44

8.2 Waste Arisings................................................................................................................................... 44

8.3 Site Area............................................................................................................................................ 44

8.4 Comparison of Severn Trent sites to other Alternative Sites ............................................................. 44

8.5 Systematic Assessment of Sites ......................................................................................................... 45

9. GREEN BELT ASSESSMENT ................................................................................................. 49

9.1 Assessment of the proposal on the Green Belt .................................................................................. 49

9.2 Potential Harm to the Green Belt ...................................................................................................... 50

9.3 Assessment against Principles of the Green Belt ............................................................................... 51

9.4 Locational Need ................................................................................................................................ 52

9.5 Wider Environmental and Economic Benefits.................................................................................... 55

9.6 Summary ........................................................................................................................................... 56



10. ENVIRONMENTAL EFFECTS ........................................................................................... 58

10.1 Landscape and Visual Impact ............................................................................................................ 58

10.2 Hydrology .......................................................................................................................................... 59

10.3 Transport .......................................................................................................................................... 60

10.4 Ecology and Arboriculture ................................................................................................................. 61

10.5 Heritage ............................................................................................................................................ 61

10.6 Air Quality Bioaerosols and Odour .................................................................................................... 63

10.7 Noise ................................................................................................................................................. 65

10.8 Vermin and Birds ............................................................................................................................... 65

10.9 Litter ................................................................................................................................................. 66

10.10 Complaints .................................................................................................................................... 66

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



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1. Introduction

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

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

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

and Visual Impact Assessment, Arboriculture Survey, Flood Risk Assessment,

Transport Statement, Ecological Assessment, Air Quality Assessment, Bioaerosols

Assessment and Odour Assessment, Noise Impact Assessment, Heritage Statement,

drawings and application fee to Staffordshire County Council (SCC). The submission

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

Trent).

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

of an Anaerobic Digestion (AD) facility to process and manage up to 48,500 tonnes of

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

reception building, 5 digestate and storage tanks, a gas engine, gas to grid technology

and ancillary equipment at Roundhill Sewage Treatment Works (STW), Staffordshire.

The STW site is located just off Gibbet Lane, approximately 1.5km west of Stourbridge

and 1km southeast of Stourton, close to the County border with Dudley. The proposed

capacity at the AD facility will be met primarily from commercial and industrial waste

sources within 40 miles of the site such as schools, supermarkets, hotels, restaurants

and food manufacturers. Liquid wastes including compost leachate, waste cooking oils,

drinks manufacturing waste, rainwater collected from on-site surface water attenuation

and the harvesting of rainwater that falls on the roof of the reception building can also

be used in the AD process.

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

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

arisings will continue to increase within the immediate area.

1.4 This proposed AD facility would produce 3,285,000m3 of bio methane per year and 500

kilowatts (kW) of electricity for use on the national grid removing a significant amount

of carbon which would be released into the atmosphere should the waste be landfilled

and will also provide a valuable agricultural fertiliser.



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2. Severn Trent and Agrivert

2.1 Severn Trent

2.1.1 Severn Trent Plc. is a FTSE 100 company. Providing and treating water and waste

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

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

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

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

Humber. The company delivers almost two billion litres of water every day through

46,000km of pipes. A further 91,000km of sewer pipes take waste water away to more

than 1,000 sewage treatment works. Severn Trent Water owns and operates the

Roundhill sewage treatment works.

2.1.2 For three consecutive years Severn Trent have satisfied almost a quarter of the

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

generated from their own assets. They have met the target of increasing that to 30%

by 2015 with plans to increase this further to 50% by 2020. Renewable energy plays a

vital role in minimising their net carbon emissions by over 100 thousand tonnes per

year and ensuring the best value for their customers. The economic and environmental

benefits of increasing renewables whilst at the same time reducing consumption are

compelling and Severn Trent are ambitious to develop all viable opportunities. Most of

the company’s renewable energy is produced from the anaerobic digestion of sewage

(105 digesters at 35 STW sites; generating 193 thousand Megawatts per year) but they

also generate power from the anaerobic digestion of food waste and crop silage,

hydroelectric, solar photovoltaics and this year will see the commissioning of their first

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

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

further.

2.2 Agrivert

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

composting solutions for local authority and commercial organisations. With over 20

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

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

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

services are proven in UK commercial scale applications.



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

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

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

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

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

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

Available Standard (PAS) PAS100/PAS110 accredited.

2.2.3 Agrivert operates three PAS110 compliant AD facilities - two in Oxfordshire and a third

AD facility in Surrey, with a further two plants planned to begin construction in summer

2015. They also operate two IVC facilities and three green waste sites.

2.3 Severn Trent and Agrivert

2.3.1 Severn Trent have identified an opportunity to lessen the carbon footprint of the current

operations at Roundhill and reduce the risk around increasing electricity supply; whilst

also capitalising on the availability of excess brownfield land on their substantial land

holding. AD offers a local, environmentally sound option for waste management which

assists the Country in diverting waste from landfill, reducing greenhouse gas

emissions, producing renewable energy which can be used to power homes and

vehicles and also producing a fertiliser that returns valuable nutrients to the land. The

proposed AD facility would be owned and operated by Severn Trent and would be

designed, built and operated using the collective and complimentary expertise of both

companies who both have a proven track record in successfully securing, delivering

and operating AD sites.

2.3.2 Severn Trent and Agrivert have previously worked together to design, build and

operate a Food Waste Anaerobic Digestion Facility at Coleshill Sewage Treatment

Works in Birmingham. The Coleshill AD Facility was successfully commissioned in

December 2014 and is currently running at full capacity. With the success of this project

Severn Trent are committed to commissioning further Anaerobic Digestion Facilities to

recycle food waste and further contribute to moving waste up the hierarchy, the

utilisation of renewable energy and offset of greenhouse gas emissions.



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3. Site Description

3.1 The Roundhill Site

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

Roundhill Severn Trent Water works, to the north of Gibbet Lane, Stourbridge,

Staffordshire situated 3.2km to the west of Stourbridge town centre and 2.7km east of

Kinver (See Location Plan, Section 14). The site is at National Grid reference NGR SO

868 841. Roundhill Sewage Treatment Works (STW) is an existing permitted and

operational large sewage treatment works comprising a traditional STW and a Thermal

Sludge Destruction Plant. On average, the sewage works treats 85,000m3 of raw

sewage per day from the equivalent of 253,341 people in the Stourbridge, Dudley and

surrounding areas of the West Midlands. This figure may rise up to around 153,000m3

per day during inclement weather.

3.1.2 The overall land holding of Severn Trent at Roundhill extends to 13.1ha and

incorporates the proposed development site, measuring approximately 3.8ha and

centred on OS grid reference SO 86929 84157. The STW site is bounded to the north

and east by farm land; to the south mature trees with Gibbet Wood immediately

beyond; to the west a steep embankment leading into Stewponey Quarry.

3.1.3 The site, which is situated wholly in the West Midlands Green Belt, is split in two by a

private access road from the A449 installed for the site (SS.06/10/629 W) which runs

west to east.

3.1.4 The site is located within a low risk area as set out by the Environment Agency Flood

Map. The flood map identifies the development site as being situated outside of both

Floodzone 2 and Floodzone 3 (the extent of the natural floodplain without defences).

The nearest sensitive ecological receptors to the site are located 1.38km to the north

east at Wollaston Ridge Quarry site of Special Scientific Interest (SSSI): Kinver Edge

SSSI is located 3km to the west of the development site. The nearest Special Area of

Conservation (SAC) is located 6.4km to the north east at Fens Pool.

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

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

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

River Stour and the Gallows Brook, matching or bettering exacting quality standards

prescribed by the Environment Agency.



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3.1.6 There are approximately 18 Severn Trent employees based on the site, who are

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

compliment of around 40 other sewage pumping stations and sewage works

throughout the Stourbridge area.

3.1.7 The nearest residential receptors surrounding the site are situated to the north at

Barratt’s Coppice Cottages (215m) and farm (619m); to the north east at High Park

Farm (716m); to the south east at Roundhill Farm (583m); to the northwest at Stourton

Village (592m); and to the west at Dunsley Hall Farm Barns (982m).

3.2 Site Planning History

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

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

permission or under Severn Trent’s Permitted Development rights. The site underwent

significant transformation in 1990 to treat the waste generated by the growing

population in the surrounding area. The site is approached by two entrance gates, one

access from the A449 and the other from Whittington Hall Lane; the latter however is

subject to a planning condition limiting the access of HGV traffic through this access.

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

Reference Description

Roundhill Sewage Treatment Works, Stourbridge, South Staffordshire

SS.0415/97 Extension to sewage treatment works to include tanks treatment

plant and 2 no. buildings - Approved by Planning Committee July

1997 however Departure case referred to Secretary of State and

decision not issued until February 1998

SS.0511/97 Sludge thickener building, buffer storage tank and odour control

unit - Approved by Planning Committee September 1997

however Departure case referred to Secretary of State and

decision not issued until December 1997



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SS.03/17/629 W Construction of a combined heat and power plant – Approved

November 2003

SS.04/05/629 W Construction of a combined heat and power plant and two GRP

Kiosks – Approved April 2004

SS.05/03/629 W Construction of containerised Scrubber Effluent Treatment plant

and two kiosk – Approved March 2005

SS.06/10/629 W Construction of new private access road linking Roundhill

Sewage Treatment Works with the A449 – Approved by Planning

Committee November 2006 however Departure case referred to

Secretary of State and decision not issued until January 2007

SS.06/10/629 W

D1

Submission of details in compliance with condition 4 of planning

permission SS.06/10/629 W relating to surface water drainage

works – Approved June 2007

SS.06/10/629 W

D2

Submission of details in compliance with conditions 6, 8 and 11

of planning permission SS.06/10/629 W relating to landscaping

and aftercare scheme, badger survey and reptile mitigation

strategy – Approved August 2007

SS.07/11/629 W Erection of three buildings associated with an infrastructure

upgrade required by the urban waste water framework –

Approved December 2007

SS.07/11/629 W

D1

Submission of details in compliance with conditions 4 and 5 of

planning permission SS.07/11/629 W regarding landscaping –

Approved November 2008

SS.07/11/629 W

MA1

Minor amendments relating to the layout of chemical storage

tanks and control panel/dosing kiosk – Confirmed Minor

Amendment not requiring separate approval September 2008

SS.10/05/629 W Erection of dosing unit / kiosk – approved 2010



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SS.10/00256

WCA

Consultation from South Staffordshire Council in connection with

a planning application (Ref 10/00256/FUL) to them for permission

for erection of two wind turbines plus underground cabling,

access track, substation compound, temporary site compound

and ancillary development – No objections from Staffordshire

County Council May 2010

SS.10/08/629 W Application not to comply with (to vary) conditions 13 & 14 of

planning permission SS.06/10/629 W to allow access from the

A449 to the Roundhill Sewage Treatment Works for traffic

associated with the construction and maintenance of the

proposed wind turbine. – approved 2010.

SS.12/10/629 W Installation of 2 No. MCC kiosks and 1 No. compressor and

manifold kiosk – approved November 2012.

SS.13/02/629 W Installation of 1 No. MCC kiosk and 1 No. polymer dosing kiosk

– approved April 2013



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4. Proposed Development

4.1 Description of Proposal

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

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

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

to produce biogas. The biogas will be upgraded to bio methane and fed into the

National Grid; with some of the biogas utilised on-site to power a gas engine. A nutrient

rich bio-fertiliser is also produced that can be used as both a fertiliser and a soil

improver. Heat is produced as a by-product, which is partly utilised on site within the

AD process.

4.1.2 The facility would be constructed in an underutilised area of the treatment works site

that has been in use since the 1930s, this area consists of screening equipment for the

removal of gross solids, grit removal equipment, sedimentation tanks, aerated tanks to

assist biological treatments and chemical dosing to assist final sedimentation. The area

is underutilised currently and the site location has been specifically chosen to ensure

that the operations of the wider treatment works site are not affected by the proposal

and that the development is environmentally acceptable. The site design has ensured

that all the built development is grouped together to reduce the mass of the overall site.

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

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

approximately 28m in diameter and 16m in height; the reuse of 2 existing tanks, a 10m

high gas flare; 1 gas engine with a 12m exhaust stack, a gas to grid system with an

18.5 m high water scrubbing tower, silage storage area; and other associated

infrastructure.

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

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

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

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

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

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

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

Staffordshire and surrounding Counties. It is anticipated that the facility would generate

a maximum of approximately 64 HGV movements and 6 staff movements per day.



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4.1.5 A portion of the biogas produced from the waste material will be fed through a gas

engine. It is anticipated that the facility will generate in the region of 500kW of electricity

per annum, which is the equivalent power for approximately 1,250 households. It is

proposed that Severn Trent would utilise a proportion of the electricity generated for

onsite works, in addition to that used for the operation of the AD facility itself. The

remaining biogas will be cleaned of impurities, dried and upgraded to a higher methane

content (> 95%) before being injected into the National Grid. This Bio-methane when

fed directly into the gas network will be used in the same way as natural gas, to provide

heat and power to homes and businesses. Approximately 3,285,000m3 of bio methane

will be produced giving the plant the equivalent electricity output to power 4,875 homes

and diverting this waste utilised in the biogas production from landfill has a carbon

saving equivalent of taking 71,000 cars off the road. Injecting renewable gas (bio-

methane) into the local gas networks will help to make the U.K. gas supply less carbon-

intensive than using imported natural gas.

4.2 Anaerobic Digestion Process

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

absence of oxygen. The process is described in detail in Section 4 (Description of

Works), however a summary is provided below.

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

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

are weighed on the weighbridge and then proceed into the reception building. The

reception building doors are fitted with sensors and therefore automatically open when

they identify an approaching vehicle. The imported wastes are deposited into a bunker

or liquid tank, before the vehicle exits through another automatic door, again being

weighed as it exits the site.

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

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

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

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

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

pumped into the secondary digesters. It remains within the digesters for between 50

and 100 days in total, where it is gently heated and stirred to encourage the digestion

process and biogas production.



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

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

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

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

required.

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

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

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

4.2.6 A portion of biogas is fed into a gas engine, which powers a generator to produce

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

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

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

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

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

improves the reliability of the gas engines and reduces emissions.

4.2.7 The remaining biogas will be cleaned of impurities, dried and upgraded to a higher

methane content (> 95%) before being injected into the National Grid. This upgrading

is done utilising technology to scrub the biogas to remove impurities (Hydrogen

Sulphide, Water Vapour and Carbon Dioxide). This cleaning process upgrades the bio

gas to bio methane. The gas is then measured for its calorific value and propane is

added if needed to ensure uniform calorific content. The gas is re-odourised for safety

and pressurised before injection into the Gas Network.

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

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

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

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

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

using specialised agricultural slurry applicators.

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

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

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

distances.



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4.3 Hours of Operation

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

it is anticipated that waste will only be delivered between the following hours:

• 07:00 to 18:00 Monday to Friday;

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

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

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

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

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

Regulations 2011

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

Staffordshire County Council on 20 June 2014. On 28 July 2013, an Opinion was

received from Staffordshire County Council, which advised that the proposed

development is not considered to be EIA development.

4.5 Community involvement and Pre-application Consultation

4.5.1 Prior to the submission of this planning application Agrivert and Severn Trent contacted

the local Parish Council of Kinver. Invitations were received from Kinver Parish Council

to discuss the proposal with the members of the Parish at a planning meeting on the

10th June 2015. Agrivert and Severn Trent attended the meeting and the views

expressed have been considered in the preparation of this proposal. Members of

Kinver Parish Council also attended a site tour of the existing Anaerobic Digestion

facility at Coleshill on the 29th of June.

4.5.2 In addition, Agrivert, Severn Trent and Consultants under instruction from both have

undertaken discussions with Staffordshire Planning Officers, Archaeologists and

Highways Officers during the preparation of this planning application.



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5. Planning Policy Appraisal

5.1 The Statutory Development Plan

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

applications for planning permission to be determined in accordance with the statutory

Development Plan unless material considerations indicate otherwise.

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

o National Planning Policy Framework (NPPF) 2012

o National Planning Policy Framework for Waste (NPPfW) 2014

o Staffordshire and Stoke on Trent Joint Waste Core Strategy (JWCS) 2010-2026

o South Staffordshire Local Plan (SSLP) 2012

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

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

policies are expected to be applied. The following were analysed in preparation for this

application; Part 7 Requiring Good Design; Part 9 Green Belt; Part 10 Meeting the

Challenges of Climate Change, Flooding and Coastal Change; and Part 11 Conserving

and Enhancing the Natural Environment.

5.1.4 The NPPF provides planning policy for all development classes with the exception of

waste planning uses, paragraph 5 advises that this will be set out within the National

Waste Management Plan for England (NWMP) which upon being published in October

2014 is now titled “the National Planning Policy Framework for Waste” (NPPfW) and

replaces Planning Policy Statement 10: Planning for Sustainable Waste Management

(PPS10). The NPPfW sets out the government’s ambition to work towards a more

sustainable and efficient approach to resource use and management with positive

planning playing a pivotal role in delivering the country’s waste management ambition.

5.1.5 The Staffordshire and Stoke on Trent Joint Waste Core Strategy (JWCS) covers the

plan period 2010-2026. The Joint Waste Core Strategy provides a new Vision for

managing Staffordshire and Stoke on Trent waste and the development of both

counties waste infrastructure for the period to 2026.



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5.1.6 The South Staffordshire Local Plan (Core Strategy Development Plan Document) was

adopted on the 11th December 2012 and sets out the Strategic Objectives, Core and

Development Policies to help to shape a sustainable future for South Staffordshire up

to 2028.

5.1.7 The policies relevant to this proposal are shown in the table below;

Document

Policy

Title

The National Planning Policy Framework

(NPPF)

Part 7 Requiring Good Design

Part 9 Green Belt

Part 10 Meeting the Challenges of

Climate Change Flooding

and Coastal Change

Part 11 Conserving and Enhancing

the Natural Environment

National Planning Policy for Waste

(NPPfW)

Part 3 Identify need for Waste

Management Facilities

Part 4, 5 & 6 Identifying Suitable Sites and

Areas

Part 7 Determining Planning

Applications

The Staffordshire and Stoke on Trent Joint

Waste Core Strategy (JWCS)

Policy 1.1 General Principles

Policy 3.1 General Requirements for

New and Enhanced Facilities

Policy 4.1 Sustainable Design

Policy 4.2 Protection of Environmental

Quality

The South Staffordshire Local Plan

(SSLP)

Policy GB1 Development in the Green

Belt

Policy EQ4 Protecting and Enhancing

the Character and

Appearance of the

Landscape

Policy EQ8 Waste

Policy EQ11 Wider Design Considerations



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5.2 Waste

5.2.1 The Waste Hierarchy is an important factor in European, National and Local policy.

One of the key Objectives in part 1 of the NPPfW is that positive planning plays a

pivotal role in delivering this country’s waste ambitions through the use of the waste

hierarchy; helping to secure the re-use, recovery or disposal of waste without

endangering human health and harming the environment. By implementing positive

planning using the waste hierarchy the Government aims to break the link between

economic growth and the environmental impact of waste.

5.2.2 Part 3 of the NPPfW also drives the principle of moving waste up the waste hierarchy

and encourages recognition of the need for a mix of types and scales of facilities.

Need for additional waste management capacity of more than local significance is to

be considered to reflect any requirement for waste management facilities nationally.

Policy 1.1 of the JWCS states that one of its principals is to grant permission to the

most sustainable option for the management of waste at the top end of the waste

hierarchy. Policy EQ4 of the SSLP advises that proposals must assist in the delivery

of the priorities of the waste hierarchy and that support will be given for the provision

of well-designed recycling facilities.

5.2.3 The hierarchy promotes prevention and reuse over recycling, other recovery (notably

energy recovery) and disposal, giving preference to managing waste further up the

hierarchy. The waste hierarchy now forms the basis of both national and local waste

policy and as such when determining proposals for waste developments, proposals

which move the management of waste higher up the waste hierarchy should be

viewed more favourably.

5.2.4 The policies of the Joint Waste Core Strategy support the waste management

principles in the NPPfW by encouraging proposals where they increase the

proportion of waste managed further up the waste hierarchy. This is also supported

in the SSLP, which seeks to promote waste up the waste hierarchy. Both the JWCS

and SSLP identify the need to drive waste management up the waste hierarchy,

addressing waste as a resource and looking to disposal as the last option is of

particular significance.

5.2.5 Part 1 of the NPPfW encourages the delivery of sustainable development, resource

efficiency and provision of modern infrastructure without harm to the environment.



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5.2.6 JWCS Policy 1.1 (General Principles) advises that when evaluating proposals for

waste facilities the proposal is to be assessed against its ability to minimise waste at

source, through careful design and where this cannot be avoided to reduce the

amount of waste requiring disposal to landfill in due course. It sets out to ensure

waste is managed as a material resource (again reducing the need to landfill), while

reducing carbon emissions, mitigating climate change and creating employment

opportunities. It further advises that permission will not be given where a proposal

would cause significant harm to the protection of human health and the environment.

Proposals must be modern, appropriately located, well-run and well-regulated in line

with the current pollution control techniques and standards. Adverse impacts and

cumulative effects should be avoided with any potential adverse impacts minimised

and mitigated as part of any proposal. A proposals overall benefits (economic, social

and environmental) should outweigh any material planning objections.

5.2.7 Policy EQ 8 of the SSLP similarly advises that Development and activities must

support the minimisation of waste together with the efficient use of materials, and in

particular assist in the delivery of the priorities of the waste hierarchy and that

support will be given for the provision of well-designed recycling facilities.

5.2.8 Both National and local policy set out to achieve the provision of well-designed waste

management facilities preferably high up on the waste hierarchy as set out in SSLP

Policy EQ8, the JWCS Policy 1.1 and part 1 of the NPPfW. The documents

encourage the minimisation of waste and efficient use of materials with any adverse

impacts minimised and mitigated. The overall aim set out in the documents is to

move waste up the waste hierarchy and ultimately reduce the amount of waste

requiring disposal to landfill.

5.2.9 The proposed development of this site for the installation of an AD facility would

optimise the use of biodegradable organic waste as a valuable resource and ensure

the diversion of 48,500 tonnes of this material from landfill and its use further up the

Waste Hierarchy in the recycling tier. The proposal would also generate renewable

energy and is therefore consistent with the aims and objectives of the relevant

national, regional and local planning legislation and policy.



16

5.3 Renewable Energy

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

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

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

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

this target.

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

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

greenhouse gas emissions, whilst minimising vulnerability and providing resilience to

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

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

the economic, social and environmental dimensions of promoting sustainable

development.”

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

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

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

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

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

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

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

security.

5.3.5 NPPF Part 10 paragraph 93 advises that planning plays a key role in helping shape

places to secure radical reductions in greenhouse gas emissions, minimising

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

supporting the delivery of renewable and low carbon energy and associated

infrastructure. This is central to the economic, social and environmental dimensions

of sustainable development.

5.3.6 Paragraph 97 states that to help increase the use and supply of renewable and low

carbon energy, local planning authorities should recognise the responsibility on all

communities to contribute to energy generation from renewable or low carbon

sources. Local planning authorities are encouraged to have a positive strategy to

promote energy from these sources and design policies to maximise its development

while ensuring adverse impacts of such development are satisfactory addressed.



17

They are encouraged to identify suitable areas for renewable and low carbon energy

developments, and support development where this would help secure the

development of such sources.

5.3.7 Paragraph 98 states that when determining planning applications, local planning

authorities should:

o not require applicants for energy development to demonstrate the overall need

for renewable or low carbon energy and also recognise that even small-scale

projects provide a valuable contribution to cutting greenhouse gas emissions; and

o approve the application if its impacts are (or can be made) acceptable.

5.3.8 Once suitable areas for renewable and low carbon energy have been identified in

plans, local planning authorities should also expect subsequent applications for

commercial scale projects outside these areas to demonstrate that the proposed

location meets the criteria used in identifying suitable areas.

5.3.9 Similarly the JWCS Strategic Aim 17 (SA17) advises that to minimise the adverse

impacts of climate change and to move towards zero carbon growth through energy

efficiency that promoting the use of renewable energy sources and green

construction methods in accordance with best practice is required. The SSLP Policy

EQ6 on Renewable Energy also promotes the need for renewable energy generation

and points out that provision should be made for renewable energy generation within

South Staffordshire to maximise environmental and economic benefits whilst also

minimising any adverse local impacts. EQ 6 recommends South Staffordshire to

strive to meet a minimum of 9.6% of its energy demand through renewable energy

sources by 2020 and to achieve this through a variety of technologies.

5.3.10 The proposal will produce up to 3,285,000m3 of Bio methane along with 500kW of

renewable energy and divert biodegradable organic waste from landfill. It has also

been located within close proximity to available commercial and industrial waste

sources, as well as being excellently positioned to provide available capacity for

Local Authorities should it be required. The proposed facility may therefore assist

South Staffordshire reach its minimum of 9.6% renewable energy target by 2020.

5.3.11 Notwithstanding the above; where there is a clear and identifiable need for a

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



18

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

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

of anaerobic digestion.

5.3.12 The AD process utilises combined heat and power to produce renewable energy in

the form of electricity and heat. The facility will produce electricity and gas which will

be fed into the National Grid. In addition, it will be self-sufficient in terms of its power

consumption. This facility will, therefore, be able to significantly contribute to the

requirements of national, regional and local planning policy for renewable energy

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

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

landfill.

5.3.13 Furthermore, the overarching Government strategy for the management of such

wastes is through the promotion of AD technologies (enshrined in national planning

policy and through the Anaerobic Digestion Strategy and Action Plan produced by

the Department for Energy and Climate Change). It is considered that this facility will

produce an overall benefit for reducing the effects of climate change and will meet

the requirements of EN-1.

5.4 Locational Requirements

5.4.1 NPPF Part 3 sets out the policy background for identifying the need for waste

management facilities stating that waste planning authorities should prepare Local

Plans which identify sufficient opportunities to meet the identified needs of their area

for the management of waste streams. Local Plans should identify the tonnages and

percentages of municipal waste and commercial and industrial waste requiring

different types of management in their area over the period of the plan. Also

considering the need for additional waste management capacity of more than local

significance to reflect any requirement for waste management facilities identified

nationally.

5.4.2 Plans for waste management need that arises in more than one waste planning

authority area but where only a limited number of facilities are required must be taken

into account. Waste planning authorities are to collaborate efforts with other waste

planning authorities and, through the statutory duty to cooperate, provide a suitable

network of facilities to deliver sustainable waste management.



19

5.4.3 In part 5 of the NPPfW for identifying suitable sites and areas states that waste

planning authorities should assess the suitability of sites and areas for new or

enhanced waste management facilities against the extent to which the site or area

will support the other policies. The suitability should be based on the physical and

environmental constraints of the development, including existing and neighbouring

land uses, the capacity of existing and potential transport infrastructure to support the

sustainable movement of waste and the cumulative impact of existing and proposed

waste disposal facilities on the well-being of the local community, including any

significant adverse impacts on environmental quality, social cohesion and inclusion

or economic potential.

5.4.4 The JWCS states in paragraph 1.9 that it is not proposed to identify specific sites for

development in the Joint Waste Core Strategy but rather to base the Strategy on the

identification of broad locations. The broad locations set out in the JWCS include

Kinver which is the closest location to the Roundhill Sewage Treatment Works. The

JWCS also advises in paragraph 3.21 that as new planning applications are

considered at existing facilities, it is important that enclosed waste management

facilities are encouraged, environmental standards are met, environmental, social

and economic impacts are minimised including the avoidance of adverse cumulative

impact, the recovery of waste is maximised and high quality design is promoted.

5.4.5 An AD facility needs to be located close to the source of waste, i.e. close to urban

areas; close to the market; and with good access to the highway network. It is often

better located in a rural area, where it can serve the local community and nearby

urban areas; provide much needed digestate to local farms with minimal transport;

and can be located further from residential receptor properties, thereby minimising

any potential amenity issues. Such a facility cannot easily be accommodated within

an urban setting, due to potential disturbances, restrictions on available land and

land values. Therefore special consideration should be given to this facility in its

proposed rural location.

5.4.6 The site at Roundhill is well positioned for access and proximity to the sources of

waste it will serve, being strategically located within the county;

o Co-located with existing sewage works

o The close proximity of the site to the source of waste and to the point of use of

the final recycled digestate product;



20

o The good transport connections of the site;

o The lack of alternative non-green belt sites within the area of search and close to

the sources of waste;

o The appropriate separation of the site from sensitive properties to protect them

from potential disturbance;

o The benefits of existing extensive screening from infrastructure and mature

hedgerows and woodland the site already provides;

o The commercial availability and viability of the site;

o The environmental benefits of the co-location with an existing STW site;

o The ability to reduce the carbon footprint of Severn Trent operational sites.

5.4.7 Wider environmental and economic benefits:

o The urgent need for more recovery of organic waste to achieve higher levels of

landfill diversion of this waste stream;

o A means of treating locally sourced food waste;

o Generates 500kW of renewable energy and 3,285,000m3 bio methane and

offsets the Carbon produced by over 70,000 cars each year;

o AD provides a completely enclosed waste treatment process, limiting the

potential to generate odour, dust and noise;

o The significant savings in greenhouse gases as a result of diverting priority waste

materials from landfill as identified by government;

o Generation of a valuable agricultural product thereby conserving resources;

o Generation of local jobs both during the construction and operation of the site.

5.4.8 Other factors

o The lack of harm to the visual amenity and openness of the Green Belt;

o The minimal impact to amenities of local receptors;

o Landscape and Visual Impact Assessment indication that the proposed

development would be indistinguishable in the wider context.

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

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

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

on their substantial land holding. This is in keeping with paragraph 3.21 of the JWCS



21

which encourages co-located waste facilities. AD offers a local, environmentally

sound option for waste management which assists the Country in diverting waste

from landfill, reducing greenhouse gas emissions, producing renewable energy which

can be used to power our homes and vehicles and producing a fertiliser that returns

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

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

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

successfully securing, delivering and operating AD sites.

5.4.10 Severn Trent have identified the following objectives behind their desire to further

their AD capabilities:

o Offsetting a percentage of their net carbon generation from existing operations;

o Utilise brownfield land that is now surplus to requirements and can currently only

support limited uses;

o Increase and improve Severn Trent’s renewable energy portfolio;

o Existing sewage treatment operations have a high energy consumption which will

be partially offset by the electricity generated by the AD facility;

o Further increase their renewable generation through Anaerobic Digestion;

o Make efficient use of existing, yet redundant, infrastructure.

5.4.11 All of the above form part of Severn Trent’s larger overarching objective to be as

sustainable as possible and have met their goal of increasing their renewable

electricity generation by 23.7% to 30% to offset their current electrical requirements

and they plan to further this to 50% by 2020.

5.4.12 Severn Trent have identified the benefits that they can achieve through Anaerobic

Digestion to help them meet this need. The synergy that Severn Trent can create to

enable the offsetting of a significant amount of carbon and the ability to directly utilise

the electricity and heat produced through AD, has been a major consideration in the

selection of sites. However, given the siting of the proposed AD development within

the Green Belt, an assessment of other sites has been undertaken. These sites

would however need to clearly outweigh the benefits provided through the direct

environmental and economic benefits of locations on or adjacent to an existing STW

site. These sites are outlined and discussed in section 8 of this document.



22

5.4.13 The proposed site ties in with the policies outlined and adheres to the requirement of

them by reuse of brownfield land within the existing sewage treatment works. The

reuse of brownfield land sits at the top of the site reuse hierarchy. Along with this the

site is located centrally to identify commercial waste sources and will offset the

electricity use of the site while creating energy for use on the national grid. Therefore

this is the most appropriate location for a site of this type.

5.5 Landscape and Green Belt

5.5.1 The Government attaches great importance to Green Belts as outlined in the NPPF;

particularly in paragraphs 79 and 80 which outline the fundamental aims of Green

Belt policy; to prevent urban sprawl by keeping land permanently open as the

essential characteristics of Green Belts are openness and permanence serving five

purposes:

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

o to prevent neighbouring towns merging into one another;

o to assist in safeguarding the countryside from encroachment;

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

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

urban land.

5.5.2 Paragraphs Paragraph 87 to 89 of the NPPF considers inappropriate development as

being harmful to the Green Belt and substantial weight is to be given to this in

decisions. Development in the green belt should not be approved unless planning

applications meet exceptions including the limited infilling or the partial or complete

redevelopment of previously developed sites (brownfield land), which by way of

having already been developed would not impact greatly on the openness of the

Green Belt.

5.5.3 Paragraph 111 and 112 of the NPPF outlines that the use of previously developed

brownfield land should be encouraged in both planning policies and decisions and

local planning authorities should seek to use these areas of poorer quality land as a

preference for development.

5.5.4 The NPPfW states (part 6) that Green Belts have special protection in respect to

development and that in the production of Local Plans, waste planning authorities



23

should first look for suitable sites and areas outside the Green Belt for waste

management facilities that would be inappropriate development while also

recognising the particular locational needs of some types of waste management

facilities.

5.5.5 Policy 4.1 of the JWCS encourages sustainable design to avoid adverse impacts and

promote positive contribution to the character and quality of the local natural, historic

and built environment and amenity. Proposals should be compatible with adjoining

land uses and the locality, taking into account national and local policies for

landscape character.

5.5.6 In Policy 4.2 of the JWCS dealing with the Protection of Environmental Quality the

development of waste management facilities outlines that; where development would

not give rise to materially harmful impacts, except where the material planning

benefits of the proposals outweigh the material planning objections they will be

supported. In determining impacts of applications consideration must be given to the

landscape, green belt and countryside.

5.5.7 Policy EQ11 deals with Wider Design Considerations stating that all developments

must be of the highest quality and the submission of design statements supporting

sustainable designs that take into account local character and distinctiveness, and

reflect the principles of;

o Respecting local character and distinctiveness including that of the surrounding

development and landscape by enhancing the positive attributes whilst mitigating

the negative aspects;

o in terms of scale, volume, massing and materials, development should contribute

positively to the streetscene and surrounding buildings, whilst respecting the

scale of spaces and buildings in the local area;

5.5.8 The SSL addresses the Green Belt in Policy GB1: Development in the Green Belt –

outlining the type of development that is considered to be acceptable within the

Green Belt based on the NPPF. It includes ‘appropriate small-scale facilities which

preserve the openness of the Green Belt and which do not conflict with its purposes’

outlined in the NPPF.



24

5.5.9 The polices outlined above show that the impact of developments on the landscape

and green belt must be shown to be within the exceptions outlined in the NFFP and

respect the local character and surroundings of its location. Developments in the

Green Belt must be shown to be exceptions to policy and through good design both

protect the environmental quality of the area and local character and distinctiveness

of the landscape.

5.5.10 Within the South Staffordshire portion of the West Midlands Green Belt as defined on

the Policies Map, development acceptable within the terms of national planning

policy will normally be permitted where the proposed development meets a set

criteria. Of particular importance to this application is section C (Changes of Use of

Land) which advises that development may be permitted where the development

relates to the carrying out of engineering or other operations, or the making of a

material change of use of land, where the works or use proposed would have no

material effect on the openness of the Green Belt, or the fulfilment of its purposes.

5.5.11 The primary aim of the Green Belt is to prevent urban sprawl through keeping the

land permanently open. The essential characteristics are prescribed within the NPPF

as being its openness and its permanence. The proposed AD development would be

situated on brownfield land within an existing Sewage Treatment Works site. Due to

the close proximity of the site to existing STW infrastructure including the Thermal

Sludge Destruction Building the proposed development site has become a relative

enclosed parcel of land and as such has lost a distinct element of its openness.

5.5.12 The facility would comprise a reception building, measuring approximately 42m x


approximately 28m in diameter and 16m in height; the reuse of 2 existing tanks, a

gas engine with a 12m exhaust stack; a gas to grid system with a 18.5m water

scrubbing tower, silage storage area; and other associated infrastructure.

5.5.13 The layout has been specifically designed to provide the optimum operational layout

ensuring that the site can be operated appropriately without giving rise to

unacceptable noise, dust or odour. The scale of the built development on site is

considered to be similar to that of the surrounding. The buildings would be

constructed utilising materials that are in keeping with a Green Belt location and have

been specifically selected to ensure that they do not cause any detriment to the

perceived openness of the Green Belt.



25

5.5.14 An assessment of the proposal against the five purposes of the Green Belt as set out

in the NPPF has been undertaken as part of the Landscape and Visual Impact

Assessment (see Section 5). The assessment concluded that:

o To check unrestricted sprawl of large built up areas;

5.5.15 The presence of the existing sewage treatment works in the Green Belt has

established a comparable development precedent. The proposed scheme is

contained entirely within the boundary of the sewage works and would not give rise

to further urban sprawl nor compromise 'openness' (such as it exists) in the

landscape.

o To prevent neighbouring towns merging into one another

5.5.16 The site is contained within the boundary of the existing sewage treatment works

which has already been developed as an industrial landscape. Further development

of the sewage treatment works would not diminish the feeling of separation between

local communities, nor would it contribute to the merging of settlements.

o To assist in safeguarding the countryside from encroachment

5.5.17 The site does not occupy land that could readily be described as ‘countryside’ and

includes existing building and infrastructure that form part of the wider sewage

treatment works. It is reasonably argued that, as a result of the substantial and

established development within this small portion of a much larger Green Belt, the

function of the Green Belt to prevent encroachment has already been severely

restricted – the addition of the Scheme would have no additional impact on this

function above the baseline condition.

o To preserve the setting and special character of historic towns

5.5.18 This function of the Green Belt is not applicable in this case as the site is located

within an industrial landscape which lacks ‘special character’. There would similarly

be no discernible impact on the setting of nearby settlements.

o To assist in urban regeneration, by encouraging the recycling of derelict and

other urban land

5.5.19 The proposed scheme is contained entirely within the boundary of the sewage

treatment works and will provide a more efficient use of land that has already been



26

developed and since become redundant. This derelict land will be recycled by this

development.

5.5.20 The proposed development may be considered as a listed exception to Green Belt

policy in that it constitutes limited infilling and redevelopment of previously developed

sites (brownfield land) as set out in Paragraph 89 of the NPPF. Notwithstanding this,

there are a considerable number of very special circumstances relevant to the

proposal and the development site that justify an exception to Green Belt policy being

made, these are summarised below.

Locational needs:

o Co-located with the existing sewage works where it will provide power for its

operations in line with Severn Trents aim to meet 50% of their demand from

renewable energy by 2020.

o The close proximity of the site to the source of waste and to the point of use of


o The good transport connections of the site;





o The benefits of existing extensive screening from infrastructure and mature


o The commercial availability and viability of the site;

o The environmental benefits of the co-location with an existing STW site;

o The ability to reduce the carbon footprint of Severn Trent operational sites.

Wider environmental and economic benefits:

o The urgent need for more recovery of organic waste to achieve higher levels of

landfill diversion of this waste stream;

o A means of treating locally sourced food waste;

o Generates 500kW of renewable energy and 3,285,000m3 bio methane and




27

o AD provides a completely enclosed waste treatment process, limiting the


o The significant savings in greenhouse gases as a result of diverting priority waste

materials from landfill as identified by government;

o Generation of a valuable agricultural product thereby conserving resources;

o Generation of local jobs both during the construction and operation of the site.

Other factors


o The minimal impact to amenities of local receptors;

o Landscape and Visual Impact Assessment indication that the proposed


5.5.21 Severn Trent therefore consider that the proposed location constitutes the most

appropriate location for the proposed development and that the proposed

development will not have a detrimental impact on the openness or appreciation of

the Green Belt.

5.6 Design

5.6.1 Part 7 of the NPPF deals with the requirement of proposals to be well designed

stating in paragraph 56 that the Government attaches great importance to good

design and sustainable development. Although visual appearance and architecture

are important it is also required for planning policies to require good design in

aspects relating to the natural environment as outlined in paragraph 61. Great weight

should be given to outstanding and innovative designs which raise the standards of

design and proposals with poor design that does not do so should be refused as

outlined in paragraphs 63 and 64 of the text.

5.6.2 The NPPfW outlines factors which should influence the determination of waste

planning applications in part 7 including to ensure that waste management facilities

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

area in which they are located.



28

5.6.3 The JWCS’s Policy 3.1 General Requirements for New and Enhanced Facilities

states that proposals for the expansion or for new waste management facility

proposals within the broad locations of Policy 2.2 (Including Kinver) should be fully

contained, well designed and purpose build or enclosed structures appropriate for the

technology proposed. The development should be compatible with nearby uses,

appropriate in scale and character to their surroundings giving careful consideration

to the sustainable design principles outlined in Policy 4.2 (Sustainable Design).

5.6.4 Policy 4.4 reiterates the NPPF for the design of waste management facilities to be

appropriate and avoid or minimise unacceptable adverse impacts. Where practicable

they should positively contribute to the character and quality of the local natural,

historic and built environment. A proposal should make a positive contribution

towards decentralised and renewable or low-carbon energy supply and contribute to

green infrastructure initiatives as supported by local policies;

5.6.5 The SSLP has wider design considerations to be taken into account in its Policy

EQ11. Here it provides guidance on the design of all developments which must be of

the highest quality and include design statements supporting and explaining the

design components of proposals will be required. Councils will encourage innovative

design solutions that take into account local character and distinctiveness. In

particular relevance to this proposal the SSLP outlines that proposals should respect

local character and surrounding development and landscape, using good design that

respects and safeguards key views, visual amenity, roofscapes, landmarks, and focal

points. Incorporation of high quality building design, with particular attention given to

appropriately designed elements incorporating renewable energy use, minimising

waste production and providing opportunities for recycling, and minimising pollution

will be encouraged.

5.6.6 Other design considerations outlined by Policy EQ11 include the minimisation of

water use including the incorporation of water recycling, drainage, and rain water

harvesting.

5.5.7 The relevant policies outlined in respect of design look to discourage badly designed

infrastructure proposal which would impact negatively on the environment. Proposals

that show innovative design and the minimisation of impacts through their design will

be encouraged. In particular support will be shown to proposals which make a



29

positive contribution towards decentralised and renewable or low-carbon energy

supply and are regarded as high quality design.

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

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

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

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

operational requirements, to reflect the scale and mass and to ensure that the

proposal would not have a detrimental impact on the appreciation of the Green Belt

from surrounding viewpoints.

5.6.9 The development proposal includes the installation of buildings, including the

reception building and storage/digestion tanks. Without the proposed buildings and

tanks it would not be possible to treat this waste stream in accordance with ABPR

and meet the need for diverting organic waste away from landfill. If possible, the

storage/digestion tanks will be sunk into the ground by up to 1m, depending on

ground conditions, thereby reducing their overall height and minimising visual impact.

Their roofs are conical and, although reaching approximately 16.5m high at the peak,

are not bulky and less noticeable on the skyline. The buildings and tanks have an

agricultural appearance and will be designed and constructed to reduce their

appearance, fit into the local context and rural location and therefore minimise their

impact on the surrounding landscape (see further discussion in Design and Access

Statement in Section 3). As far as practically possible the buildings and structures

have been located in close proximity to the large industrial buildings at Roundhill

Sewage Treatment Works helping to reduce their impact on the wider landscape.

5.6.10 The buildings are grouped together and appropriately coloured to ensure that the

proposal would not have a detrimental impact on the appreciation of the Green Belt

from surrounding viewpoints. AD provides a completely enclosed waste treatment

process which ensures that any facets of the process which may have the potential

to generate odour, dust and noise are undertaken within a completely sealed system,

managed by a robust odour management system incorporating a biofilter and alkali

scrubber; and undertaken within an enclosed building with quick reaction doors.

These factors ensure that any odour, noise or dust that is generated through

operations within the reception building is adequately managed at source. Agrivert

has a proven track record of operating AD facilities within close proximity to

residential and industrial receptors.



30

5.9 Environment

5.9.1 AD provides a completely enclosed waste treatment process which ensures that any

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

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

management system incorporating a biofilter and alkali scrubber; and undertaken

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

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

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

operating AD facilities within close proximity to residential and industrial receptors.

5.9.2 Part 11 of the NPPF lays out policy for Conserving and Enhancing the Natural

Environment stating in paragraph 109 that the planning system should contribute to

and enhance natural and local environment by preventing both new and existing

development from contributing to unacceptable levels of soil, air, water or noise

pollution or land instability. The planning system should contribute to and enhance

natural and local environments through the protection of valued landscapes,

geological conservation interests, soils, ecosystems, biodiversity while remediating

and mitigating despoiled, degraded, derelict, contaminated and unstable land.

5.9.2 Paragraph 122 encourages focus on whether a development is an acceptable use of

the land, the impact of the use, rather than the control of processes or emissions.

Local planning authorities are to assume that these process and emission control

regimes will operate effectively.

5.9.3 Paragraphs 123 and 124 require that significant adverse impacts on health and

quality of life from developments from noise and other pollutants are evaluated.

5.9.4 The NPPfW in both Part 5 and Appendix B recommends Waste planning authorities

to assess the suitability of sites for new or enhanced waste management facilities

against Transport and other significant adverse impacts on environmental quality. In

determining planning applications, waste planning authorities should consider how

factors such as water quality, land instability, landscape and visual impacts, nature

conservation, the historic environment traffic, air quality (including dust and odours),

vermin and birds, noise, litter and potential and use conflicts are impacted. While

assessing these factors it must also be kept in mind the envisaged waste

management facility in terms of type and scale.



31

5.9.5 Support for the development of waste management facilities which would not give

rise to materially harmful impacts outlined in the NPPfW is outlined by the JWCS

Policy 4.2 (Protection of Environmental Quality). The JWCS states that the following

must be taken into account when determining proposals;

o People and local communities, including the potential health effects;

o The highway network and other public rights of way;

o Historic environment;

o Natural environment;

o Biodiversity and geodiversity and wider environment;

o The Landscape;

o Cannock Chase Area of Outstanding Natural Beauty and the setting of the Peak

District National Park

o The Green Belt;

o The Countryside;

o Trees, hedgerows and woodland;

o Agricultural land;

o Open space (including recreational and sporting facilities)

o Protection of air, soil and water and reduction of flood risk;

o Any other interests or acknowledged importance

5.9.6 The above policies all set out the aims of protecting the natural environment from

harm that could be caused by development. Proposals must evaluate the potential

impacts on the environment and constitute an acceptable use of land or contribute to

unacceptable levels of pollution in the local environment.

5.9.7 Severn Trent and Agrivert have commissioned independent reports to evaluate

potential environmental impacts associated with this proposal. They are fully outlined

in section 10 of this document and in the accompanying reports. A summary of the

environmental effects of this proposal are outlined in the following paragraphs.

5.9.8 The landscape and visual impact of the proposal has been assessed, identifying that

the site benefits from extensive screening from man-made infrastructure, mature

hedgerow and woodland planting around the site. The environmental impact of the

proposal in this regard is not thought to be detrimental to the green belt or landscape

as it will be assimilated into the existing industrial infrastructure of the sewage



32

treatment works. It would be considered a small and indistinguishable component of

a broad rural landscape.

5.9.9 A flood risk assessment was carried out to assess potential hydrological impacts of

the development. The assessment concluded that the proposal would not result in

any potential increase in surface run-off rates and have no detrimental environmental

impact in this regard.

5.9.10 The potential effect of the proposal on the surrounding highway network in respect of

vehicle movements has been assessed in a transport assessment. This assessment

has concluded that the proposal would not result in a severe impact on the local

highway network.

5.9.11 Ecology and Arboriculture were assessed on the site of the proposed development

and are considered to not be detrimentally impacted upon by the proposal if

mitigation recommendations set out within the assessments are adhered to.

5.9.12 Air quality, Bioaerosols and Odour assessments were carried out to assess any

potential impact of the proposal on surrounding receptors in the environment. The

assessments have shown that this proposal would not give rise to a detrimental

impact on residential or industrial amenity within the area and the development would

be within acceptable limits set out in legislation.

5.9.13 The potential for noise to be a nuisance on the environment was assessed in a noise

assessment with local receptors not anticipated to be affected by noise associated

with the proposal.

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





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

building is adequately managed at source. Potential adverse impacts upon the

environment resulting from the proposed development have been assessed in line

with planning policy and conclusions drawn about the potential impacts of the

development upon the environment.



33

5.10 Conclusion

5.10.1 The proposed development presents the most efficient and sustainable means of

recovering biodegradable organic waste. It is a key objective of Government policy to

increase the amount of organic material in the waste stream moved further up the

waste hierarchy and diverted from landfill. To fulfil this objective the JWCS set

challenging targets for recycling waste, including the organic element. The proposal

will make a significant contribution to meeting Staffordshire’s targets.

5.10.2 The Waste Strategy 2007, Review of Waste Policy and Defra’s Anaerobic Digestion

Action Plan promote AD, with the Waste Strategy stating that it “has significant

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

effective for food waste if separately collected”.

5.10.3 The facility will also provide a source of renewable energy in the form of bio methane

and electricity, which will be fed into the National Grid and will help in meeting

Government targets for the generation of renewable energy. It will also capture a

significant amount of carbon which would otherwise be lost to atmosphere. The

proposal would also provide a source of renewable heat.

5.10.4 The site is located on brownfield land within an existing sewage treatment works in

the Green Belt. The planning policies recognise that such a location should be

considered and may even be the most appropriate option. The need for such a waste

management facility, the lack of suitable sites outside of the Green Belt and the

environmental benefits associated with the generation of renewable energy, are all

very special circumstances that warrant an exception to Green Belt policy being

made. The magnitude of harm is more than outweighed by the very special

circumstances provided by this proposal.

5.10.5 The proposed development has good proximity to the sources of waste and markets

for the final product, it has good transport networks, is relatively remote from local

residential receptors, and adjacent to suitable facilities for co-location. The facility is

well designed with designed in mitigation measures, which will ensure that any

potential environmental or amenity impacts are not detrimental to the local

environment or amenities of nearby receptors.



34

5.10.6 The proposed built development, which is required to treat biodegradable organic

wastes and to comply with ABPR, has been designed and located to minimise its

disturbance to the local and wider landscape.

5.10.7 This will be an important facility that will contribute significantly to Staffordshire

meeting its recycling and diversion from landfill targets as set out in the JWCS. Its

acceptability in a Green Belt setting has been justified in the above Chapters,

environmental and amenity effects will be negligible, and it is considered to accord

with the general principles and policies of the Development Plan.



35

6. The Need for the Development

6.1 Renewable Energy

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

source 15% of the Countries total energy requirement from renewable energy by 2020.

The Statement remains technology neutral, identifying throughout that there is a need

for a strategic network of various types of renewable energy development to meet this

target.

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

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

gas emissions, whilst minimising vulnerability and providing resilience to the impacts

of climate change, it also has a role in supporting the delivery of renewable and low

carbon energy and associated infrastructure, which is central to the economic, social

and environmental dimensions of promoting sustainable development.”

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

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

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

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

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

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

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

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

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

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

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

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

going to landfill.

6.1.5 The proposal will produce up to 3,285,000m3 of Bio methane along with 500kW of

renewable energy and divert biodegradable organic waste from landfill. It has also

been located within close proximity to available commercial and industrial waste

sources, as well as being excellently positioned to provide available capacity for Local

Authorities should it be required. The proposed facility would therefore assist the Local

Authority in meeting their renewable energy apportionment targets.



36

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

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

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

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

of anaerobic digestion.

6.2 Waste Management

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

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

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

generation and waste management.

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

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

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

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

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

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

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

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

hierarchy should be viewed more favourably.

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

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

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

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

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

economic outcomes.

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

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

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

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

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

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



37

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

food waste if separately collected).

6.2.5 This vision has also been enshrined within the National Planning Policy for Waste,

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

help deliver sustainable development through driving waste management up the waste

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

6.2.6 As stated above, the proposed AD facility would provide 3,285,000m3 of bio methane

and 500 kilowatts of renewable energy capacity, this equates roughly to enough

renewable energy to power 6,125 homes. The net carbon reduction through the AD

process equates to the levels of carbon produced by approximately 71,000 cars,

enough to offset the total cars within Staffordshire twice over (Source: Office of

National Statistics, 2011 Census, Car or Van Availability QS416EW). The facility would

therefore play a small, but nonetheless significant, contribution to meeting the energy

needs of the country and reducing the country’s reliability on fossil fuels. The

renewable energy generation of the facility is therefore consistent with the aims and

objectives of national energy legislation and policies set out with national, regional and

local planning legislation and policy.

6.3 Anaerobic Digestion

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

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

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

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

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

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

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

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

dealing with food waste and avoiding, by more efficient capture and treatment, the

greenhouse gas emissions that are associated with its disposal to landfill” (paragraph

220).

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

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

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



38

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

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

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

environmental benefit, followed by composting and then incineration with energy

recovery” (Paragraph 196).

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

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

industry within England over the coming years. The Strategy advises that in the

majority of cases, the principal purpose of consigning waste to AD is to recover energy

from it. Therefore, in most cases the treatment of biodegradable waste through AD will

be classified as ‘other recovery’ for the purposes of the waste hierarchy. However,

Article 4(2) of the Waste Framework Directive does make provision for specified waste

streams to differ from the waste hierarchy, where justified by positive life-cycle

assessment analysis. In terms of treating food waste, the use of AD, when taking into

account the local economic and environmental considerations, is considered to provide

greater overall environmental benefits than it would if it was to be recycled.

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

in the form of biogas, electricity and heat. The facility will produce up to 3,285,000m3

of bio methane and 500kW of electricity which will be fed into the National Grid. In

addition, the facility will be self-sufficient in terms of its power consumption. This facility

will, therefore, be able to contribute to the requirements of national and local planning

policy for renewable energy generation, and will reduce the emissions of greenhouse

gases by diverting biodegradable organic waste (which produces methane when

broken down) from landfill. Furthermore, the overarching Government strategy for the

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

enshrined in national planning policy and through the Anaerobic Digestion Strategy

and Action Plan).

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

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

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

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

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

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



39

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

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

phosphate content of digestate will thus become increasingly attractive in the short to

medium term.

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

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

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

digestate must accord with PAS110, the quality protocol for digestate derived through

AD. PAS110 ensures that any product produced through the AD process meets the

needs of the market and does not have an adverse impact on the environment. Agrivert

has successfully gained PAS110 at existing AD facilities in Oxfordshire and Surrey,

where they have also marketed the digestate produced to local farms surrounding the

facilities. Severn Trent and Agrivert will seek to ensure that the proposed AD plant

becomes PAS110 compliant within 12 months of the facility receiving waste.

6.4 Environmental Benefits






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

is adequately managed at source. Severn Trent has a proven track record of operating

AD facilities within close proximity to residential and industrial receptors.

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

chapter, however to summarise the proposal would produce 3,285,000m3 of bio

methane and 500 kilowatts of renewable energy, which equates to enough renewable

energy to power 6,125 homes and remove approximately 71,000 cars off the road. The

proposed facility would therefore play a small, but significant, part in meeting the

country’s climate change and renewable energy objectives.

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

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

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



40

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

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

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

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

appropriate.

6.5 Economic Benefits

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

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

industrial sources to reduce the escalating financial cost of Landfill Tax.

6.5.2 The Roundhill AD proposal would employ 6 permanent members of staff from the

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

during the construction phase of the development.

6.6 Summary

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

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

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

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

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

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

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

significant role in meeting current and future energy demand.



41

7. Waste Arisings within Staffordshire

7.1 Joint Waste Core Strategy Evidence Base

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

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

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

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

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

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

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

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

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

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

evidence base for the production of the South Staffordshire Local Plan. The

paragraphs below set out the quantitative analysis of this evidence base, however it

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

and as such any figures should be viewed as approximations.

7.1.3 The Staffordshire and Stoke-on-Trent JWCS Evidence Base Report 2 – Managing

Municipal and Industrial and Commercial Wastes (SCC 2011): Waste Background

Technical Paper was produced to inform the preparation of the Joint Waste Core

Strategy. The paper provides an analytical assessment of the waste processed within

the Counties and the future requirements over the forthcoming 16 years, providing

qualitative and quantitative analysis of municipal waste, commercial and industrial

waste.

7.1.4 The Strategy sets out the anticipated waste arisings within Staffordshire and Stoke-on-

Trent between 2010 and 2026. During this 16 year period it is anticipated that the

Counties combined waste, based on an analysis of local waste arisings, which takes

into account previous trends, current economic decline, recycling and re-use rate of

waste and housing projections for Staffordshire and Stoke-on-Trent, would produce

approximately 10.9 million tonnes of municipal waste and 11.8 million tonnes of

commercial and industrial waste.



42

7.1.5 The Paper states (Paragraph 5.9) that despite the complexity of waste prediction

models, it must be noted that they should not be regarded as definitive predictions.

Comparison between the arisings and RSS growth model is necessary in order to

provide a better understanding of differences between various projections, which

reflect the need to plan for infrastructure at the local level as well as meeting the

demand arising at the national and regional levels. Paragraph 5.10 states that the

research suggests that the RSS growth model of C&I waste should be considered as

a minimum for setting up the targets for the plan period.

7.1.6 Paragraph 9.5 states that Staffordshire and Stoke-on-Trent require an additional

minimum of 2.7 hectares and maximum of 5.7 hectares of land to meet the capacity

gap and manage local need for organic waste treatment. Stating that the above

estimates are based on facilities operating at 100% of capacity at all times, and

therefore actual land take could be nearer double the above estimates. For this reason

these figures should be considered a minimum potential land take requirement.

7.1.7 Based on a predicted minimum future capacity needed of 415,729 tonnes per annum

(240,475 C&I + 175,253 MSW) in 2026 (table 9.3) it is expected that organic waste

arisings from MSW (potentially 41% of total) and commercial and industrial waste

(potentially 17% of total) would be required in order to be able to meet Waste Collection

Authority and Waste Disposal Authority requirements to manage municipal green and

kitchen waste. These potential figures for organic waste arisings show a potential of

40,880 tonnes per annum of commercial and industrial organic waste and 71,853

tonnes per annum for MSW. Table 9.2 outlines the need for 2 – 3 new organic

treatment facilities in order to meet the capacity gap and manage future need.

7.1.8 Information on import and export of MSW and C&I waste from and into Staffordshire

and Stoke-on-Trent is very limited as it is mainly based on contractual agreements

between waste operators who most of the time are difficult to monitor. The evidence

gathered for the report was gathered based on data for facilities with Waste

Management Licences (WMLs) for the year 2006 and 2008. According to the 2008

data, over 1,700,000 tonnes of total household and commercial and industrial waste

was managed in Staffordshire and Stoke-on-Trent, although this data did not contain

information on the tonnage of the waste which originated locally. It is therefore

considered that these values represent the most accurate account of account of waste

management need in Staffordshire.



43

7.1.9 It is therefore evident that there is a prescribed requirement for waste processing

provision within Staffordshire to meet the needs of both the County and to support

imported waste from other Counties.



44

8. Alternative Sites Assessment

8.1 Introduction

8.1.1 Given the location of the site within the Green Belt, Severn Trent are required to

undertake an Alternative Sites Assessment to support the application. The following

statement sets out the methodology behind the Assessment.

8.2 Waste Arisings

8.2.1 As set out in previous section (7) of this report, the JWCS has identified through an

evidence based report that there is a need for 2 – 3 new organic treatment facilities in

order to meet the capacity gap and manage future need. It is Severn Trent’s intention

to tender for Local Authority waste within the immediate area surrounding the facility

when those Council’s come out to tender.

8.3 Site Area

8.3.1 The proposed AD facility would be owned and operated by Severn Trent and would be

designed, built and operated using the collective and complimentary expertise of both

companies (Agrivert and Severn Trent) who both have a proven track record in

successfully securing, delivering and operating AD sites. Utilising Agrivert’s experience

in the organic food waste market, and based on their previous experience at other

sites, the minimum site area required to accommodate this type of proposal would be

3.1ha.

8.3.2 The minimum land requirement is based on the following factors:

o The total anticipated waste to be processed

o The required site infrastructure

o Environment Agency Requirements (Containment Bunding, Digestate Storage)

o Hydrological Requirements (Attenuation Required, Flood Risk)

8.4 Comparison of Severn Trent sites to other Alternative Sites

8.4.1 Severn Trent have identified the following objectives behind their desire to further

their AD capabilities:

o Offsetting a percentage of their net carbon generation from existing operations;

o Utilise brownfield land that is now surplus to requirements and can currently only

support limited uses;



45

o Increase and improve Severn Trent’s renewable energy portfolio;

o Existing sewage treatment operations have a high energy consumption which will

be partially offset by the electricity generated by the AD facility;

o Further increase their renewable generation through Anaerobic Digestion;

o Make efficient use of existing, yet redundant, infrastructure.

8.4.2 All of the above form part of Severn Trent’s larger overarching objective to be as

sustainable as possible and to meet the goal of increasing their renewable electricity

generation to offset their current electrical requirements.

8.4.3 Severn Trent have identified the benefits that they can achieve through Anaerobic

Digestion to help them meet this need and through the success of the Coleshill Food

Waste Anaerobic Digestion plant are committed to further utilising this technology. The

synergy that Severn Trent can create to enable the offsetting of a significant amount

of carbon and the ability to directly utilise the electricity and heat produced through AD,

has been a major consideration in the selection of sites. However, given the siting of

the proposed AD development within the Green Belt, an assessment of other sites has

been undertaken. These sites would however need to clearly outweigh the benefits

provided through the direct environmental and economic benefits of locations on or

adjacent to an existing STW site.

8.4.4 The assessment of these other sites is set out in the following paragraphs.

8.5 Systematic Assessment of Sites

8.5.1 Severn Trent has undertaken a preliminary desk based assessment which

incorporated an appraisal of Local Employment Land Reviews and research from Local

Authority and Land Agent websites. A separate breakdown of the review of Severn

Trent sites was also undertaken. These sites are outlined below:

Location Comments Progress

Southam Cement Works, Southam Road, Southam

Existing quarry located to the east of Southam Road. Quarry still provides landbank of minerals and is subject to an application for an extension to the working areas. Small areas of restored land may be available for development.

Yes

Land to the west of The Common, Baxterley,

Former Shale Mine to the west and east of The Common to the north of Baxterley. Large land holding with immediate access to The Common. Site is located within close proximity of an approved AD facility.

Yes

Land to the east of Trinity Road and to

Site is located on arable land to the east of Trinity Road and is well screened from the road by an existing mature

Yes



46

the west of Kinsbury Wood, Kingsbury

tree belt. The principle of large infrastructure within the immediate area is established through STW uses on the opposite side of the road. Access to the site would be via Trinity Road which connects to Junction 9 and 10 of the M42. Site is located within the Green Belt.

Land at Junction 3, M6.

Site is located off Junction 3 of the M6 to the north of Coventry. A suitable amount of arable land surrounding the junction; however access to the site may be difficult and requires additional consideration. Land is excellently located within proximity of the highway and is considered of suitable distance from nearest residential or industrial receptors. Site is located within the Green Belt.

Yes

Birch Coppice Business Park, nr Tamworth

3 available plots on business park site ranging between approximately 2ha and over 10ha. Located within a business park with existing waste uses.

Yes

Ufton Landfill, Ufton, Southam

Existing Biffa Landfill Site to the east of Ufton village. Site was subject to landfill fires which spread to the surface which has resulted in the proposed amount of waste to be processed being reduced dramatically. Impact of sub-surface gases specifically carbon monoxide is considered to make the utilisation of this site difficult.

No

Ling Hall Landfill Site, Coalpit Lane, Rugby

Former RAF Church Lawson base, now a landfill site. Landform to the south on Lawford Heath Lane is raised and incapable of providing a suitable land allocation for the AD development. Land to the west of Ling Lane may provide a suitable area for development although development within close proximity to an operational landfill site is considered to provide some potentially onerous ground conditions.

No

Ling Hall Concrete Plant, Coalpit Lane, Rugby

Part of former RAF Church Lawson base, now a concrete batching plant. (See Ling Hall Landfill Site above).

No

Judkins Quarry/Landill, Nuneaton

Former Quarry and existing Landfill site to the north of B4114 Tuttle Hill to the north of Nuneaton. Not progressed due to potential contamination issues.

No

Gaydon Airfield, Gaydon

Site of former RAF Base at Gaydon, currently utilised for commercial and industrial process specifically the production of high value automobiles. Not progressed due to proximity to sensitive receptors.

No

Land to the south of Dordon Hill Road, Dordon

Significant arable land to the south of Dordon Hill Road. Site is not located within the Green Belt. Site is located within good proximity of the A5, however access to the site is considered to be poor given the requirement of vehicles to access the site through either Grendon or Dordon villages. It is considered that there are more acceptable sites to progress which do not require access through small villages.

No

Land to the north and south of the A444

Large available arable land assets to the north and the south of the A444 road. Site is not located within the Green Belt. As with the site at Dordon Hill Road, the site

No



47

Weddington Lane, nr Coldecote

would be accessed through Caldecote and Weddington which are not considered to be the most appropriate routes for vehicles.

8.5.2 Severn Trent then sought to assess each site against relevant planning policy, existing

land use and extant planning permissions, the location of the site in respect to nearby

ecological, hydrological or residential receptors, the proximity to digestate sources and

the ability to connect the site to the National Grid. The list was then reduced to the

following sites:

Location Comments Proposed Progression

Land to the west of The Common, Baxterley,

Site is located immediately west of approved Biogen development site at Baxterley. Whilst located outside of the Green Belt, it is considered that the proposed site would be located too close to the other AD site and as such it is not proposed to progress this site. In addition, the proposal is considered contrary to guidance in NPPfW on agglomeration of sites.

No progression due to proximity to competitor

Southam Cement Works, Southam Road, Southam

Site is located to the north of Southam and is within close proximity to houses at The Model Village and Stockton. Site is located outside the area of search however it has excellent access to both the highway and digestate markets.

Discussions with land agent identified no available land

Birch Coppice Business Park, nr Tamworth

Site area is ideal for AD development and proximity to highway network would enable easy access to the site. Site is however further north than the initial area of search however the site has a range of qualities which may make it commercially viable, dependant on the required land value.

Discussions initiated with IM Properties

Land at Junction 3, M6.

Site is located of Junction 3 of the M6 to the north of Coventry. A suitable amount of arable land surrounding the junction; however access to the site may be difficult and requires additional consideration. Land is excellently located within proximity of the highway and is considered of suitable distance from nearest residential or industrial receptors, however the site is located within the Green Belt.

Discussions initiated



48

8.5.3 As part of the final assessment, Severn Trent began discussions with the land owners

of the surrounding sites. From discussions with the various land owners, it was evident

that there was either a lack of interest in the proposal, a lack of available land or the

terms proposed were unacceptable to Severn Trent. A further assessment of current

and future land requirements of Severn Trent’s land allocation was also undertaken.

8.5.4 The Survey of Severn Trent’s land shortlisted 8 potential Sewage Treatment Works

sites; 1 site at Roundhill; Barston; Minworth; Hartshill; Finham; Longbridge; Newbold;

and Milcote. However 3 of these sites, Finham; Newbold and Rugby all fell below the

required 3.1ha land requirement and were quickly ruled out.

8.5.5 Of the 5 remaining sites, 2 of these fell outside of the Green Belt and 3 fell within.

These sites were then assessed against a detailed desk-based assessment criteria

including the existing landscape, proximity to sensitive receptors, site constraints and

waste sources.

8.5.6 Following an in-depth desk based assessment and site visit, 2 of the 5 sites were

identified as being unsuitable for the proposed development. The three remaining

sites, Minworth; Barston and Roundhill were deemed to be suitable for AD

development. However, following the assessment it was determined that Barston and

Minworth both had discerning factors, such as no additional capacity for electricity

generation or proximity to ecological and residential receptors which would require

detailed analysis and in the case of the lack of available capacity would require

substantive capital costs. It was therefore concluded that the proposed Roundhill site

represented the most appropriate location for this proposal.



49

9. Green Belt Assessment

9.1 Assessment of the proposal on the Green Belt

9.1.1 The proposed development site is located within the West Midlands Green Belt and as

such is afforded significant protection through the NPPF. Paragraphs 79 to 92 set out

the NPPF’s policies for protection of Green Belt Land. Paragraph 80 sets out the five

purposes of the Green Belt, these are:

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

to prevent neighbouring towns merging into one another;

to assist in safeguarding the countryside from encroachment;

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

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

other urban land.

9.1.2 As set out in National Planning Policy for Waste, waste management facilities are not

considered to be appropriate development in the Green Belt, unless very special

circumstances can be justified that any exemption to the policy can be made and that

the harm is clearly outweighed by other material considerations.

9.1.3 Paragraph 6 of National Planning Policy for Waste recognises the particular locational

needs of some types of waste management facilities and advises local authorities that

when determining planning applications, locational needs, together with the wider

environmental and economic benefits of sustainable waste management, are material

considerations that should be given significant weight.

9.1.4 In addition to these sections of the National Planning Policy for Waste, Paragraph 91

of the NPPF provides a policy basis for renewable energy developments in the Green

Belt. As discussed in earlier chapters, an important facet of the treatment of waste

through AD is the production of renewable electricity from biogas. Paragraph 91

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

development will comprise inappropriate development and as such developers will

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

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



50

wider environmental benefits associated with increased production of energy from

renewable sources.”

9.1.5 Paragraph 89 of the NPPF provides a definitive list of exceptions by which the

construction of buildings within the Green Belt would not constitute inappropriate

development;

o buildings for agriculture and forestry;

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

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

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

not materially larger than the one it replaces;

o limited infilling or the partial or complete redevelopment of previously developed

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

temporary buildings), which would not have a greater impact on the openness of

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

development.

9.1.6 The final exception is particularly pertinent to this proposal. This exemption states that

the limited infilling or the partial or complete redevelopment of previously developed

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

buildings), which would not have a greater impact on the openness of the Green Belt

and the purpose of including land within it than the existing development would not

constitute inappropriate development.

9.1.7 The proposed development could constitute an exception to Green Belt policy, due to

the fact that the AD facility would be constructed on brownfield land within the Green

Belt; this site also remains in continuous use as part of the wider STW site. The

proposal is therefore considered to meet the underlying principle of the policy.

9.2 Potential Harm to the Green Belt

9.2.1 The primary aim of the Green Belt is to prevent urban sprawl through keeping the land

permanently open. The essential characteristics are prescribed within the NPPF as

being its openness and its permanence. The proposed AD development would be

situated on brownfield land within an existing Sewage Treatment Works site. Due to



51

existing site housing large scale industrial units including a Thermal Sludge Destruction

Plant and the existing STW infrastructure the proposed development site has become

a relative enclosed parcel of land and as such has lost a distinct element of its

openness.

9.2.2 The facility would comprise a reception building, measuring approximately 42m x 34m

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

approximately 28m in diameter and 16m in height; the reuse of 2 existing tanks, 1 gas

engine, a gas to grid system; silage storage area; and other associated infrastructure.

9.2.3 The layout has been specifically designed to provide the optimum operational layout

ensuring that the site can be operated appropriately without giving rise to unacceptable

noise, dust or odour. The scale of the built development on site is considered to be

similar to that of the surrounding industrial units to the east and Sewage treatment

works the south. The buildings would be constructed utilising materials that are in

keeping with a Green Belt location and have been specifically selected to ensure that

they do not cause any detriment to the perceived openness of the Green Belt.

9.3 Assessment against Principles of the Green Belt

9.3.1 An assessment of the proposal against the five purposes of the Green Belt as set out

in the NPPF has been undertaken as part of the Landscape and Visual Impact

Assessment (see Section 5). The assessment concluded that:

o To check unrestricted sprawl of large built up areas;

9.3.2 The presence of the existing sewage treatment works in the Green Belt has established

a comparable development precedent. The proposed scheme is contained entirely

within the boundary of the sewage works and would not give rise to further urban

sprawl nor compromise 'openness' (such as it exists) in the landscape.

o To prevent neighbouring towns merging into one another

9.3.3 The site is contained within the boundary of the existing sewage treatment works which

has already been developed as an industrial landscape. Further development of the

sewage treatment works would not diminish the feeling of separation between local

communities, nor would it contribute to the merging of settlements.

o To assist in safeguarding the countryside from encroachment



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9.3.4 The site does not occupy land that could readily be described as ‘countryside’ and

includes existing building and infrastructure that form part of the wider sewage

treatment works. It is reasonably argued that, as a result of the substantial and



restricted – the addition of the Scheme would have no additional impact on this function

above the baseline condition.

o To preserve the setting and special character of historic towns

9.3.5 This function of the Green Belt is not applicable in this case as the site is located within

an industrial landscape which lacks ‘special character’. There would similarly be no

discernible impact on the setting of nearby settlements.

o To assist in urban regeneration, by encouraging the recycling of derelict and

other urban land

9.3.6 The proposed scheme is contained entirely within the boundary of the sewage

treatment works and will provide a more efficient use of land that has already been

developed.

9.3.7 As stated earlier, Paragraph 6 of National Planning Policy for Waste recognises the

particular locational needs of some types of waste management facilities and advises

local authorities that when determining planning applications, locational needs,

together with the wider environmental and economic benefits of sustainable waste

management, are material considerations that should be given significant weight.

Focusing on the three key topics within paragraph 3, the following sections assess the

locational need, environmental benefits and the economic benefits that contribute

towards very special circumstances.

9.4 Locational Need

9.4.1 Neither the existing Waste Local Plan or the emerging Waste Framework provide an

exhaustive list of allocated sites where waste development may be deemed

acceptable. As such, when Severn Trent assessed the suitability of the Roundhill site

and alternative sites with the potential to support AD development, a criterion of

‘locational need’ was utilised based on Agrivert’s previous experience in successfully

delivering and operating AD facilities.



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9.4.2 In terms of the locational need, the following factors are key considerations when

determining the suitability of a development site for AD.

The proximity of the site to the sources of waste;

The proximity to digestate markets;

The transport connections of the site and access;

The appropriate separation of the site from sensitive properties to protect them


The existing screening benefits the site already provides(whether natural or

man-made);

The lack of harm to the visual amenity and openness of the Green Belt (where

relevant); lack of impact to amenities of local receptors and distance from

ecologically or historically significant sites.

9.4.3 An Alternative Sites Assessment has been undertaken to determine the most

appropriate site for the proposed development. This has identified the most appropriate

site for development to be the Roundhill STW site which forms the basis of this

proposal. However, it is important to prove that the STW site meets the very special

circumstances to meet Severn Trent and Agrivert’s locational requirements. An

assessment against the above criterion has been set out below.

o The proximity of the site to the source of waste;

9.4.4 The proximity of the site to the large settlements and sources of waste within

Staffordshire and the surrounding Counties along with the identification of the need for

2 – 3 new organic treatment facilities in Staffordshire and Stoke-on-Trent to meet a

capacity gap and manage future need. It is Severn Trent’s intention to tender for Local

Authority waste within the immediate area surrounding the facility when those Council’s

come out to tender.

o The transport connections of the site and access;

9.4.5 The site would be accessed from a purpose built private access road off the A449. The

private access road would be the only road used to access the site and has direct



54

access to the A449 and has excellent access to Staffordshire and surrounding

Counties. Severn Trent has undertaken a Transport Statement which has concluded

that the proposed development would not have a detrimental impact on the highway

network and would not result in a severe residual cumulative impact on the local

highway network. The existing access is also designed to ensure it is suitable to enable

HGV movements to access the STW site and as such would be suitable to allow

unrestricted access to both the STW and AD sites. Please refer to the Transport

Statement in Section 7 for additional information.



9.4.6 Please refer to Alternative Sites Assessment in paragraphs 8.1 to 8.5 of the Supporting

Statement which identifies that there are no alternative non-green belt sites which are

commercially or operationally available to Severn Trent. It also identifies that of all the

available Severn Trent sites, the Roundhill proposal represents the ideal opportunity

to reduce the carbon footprint of on-site operations.



9.4.7 The nearest residential receptors surrounding the site are situated to the north at

Barratt’s Coppice Cottages (215m) and farm (619m); to the north east at High Park

Farm (716m); to the south east at Roundhill Farm (583m); to the northwest at Stourton

Village (592m); and to the west at Dunsley Hall Farm Barns (982m).

o The existing screening benefits the site already provides (whether natural or

man-made);

9.4.8 The site benefits from extensive screening from existing site infrastructure and from

mature hedgerow and woodland planting around the site. As such the scheme would

be a small and largely indistinguishable component of a broader rural landscape and

would be largely assimilated into the existing infrastructure of the sewage treatment

works. Please refer to the Landscape and Visual Impact Assessment in Appendix 5 for

additional information and assessment.




55

9.4.9 This has been assessed throughout the Landscape and Visual Impact Section of the

Supporting Statement (See Section 5).

o The low impact to amenities of local receptors.



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



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

is adequately managed at source which will reduce the potential for the proposed

development to have any detrimental impact on local receptors.

9.5 Wider Environmental and Economic Benefits

9.5.1 The wider environmental and economic benefits of the proposal are set out within the

statement on need (Paragraphs 6.4 and 6.5), however in summary these include:

Diversion of biodegradable waste from landfill in line with European and

national policy which will push the treatment of food waste further up the waste

hierarchy;

The facility would provide a means of treating locally sourced food waste;

AD provides a completely enclosed waste treatment process, limiting the


The proposed AD facility would produce 500 kilowatts of renewable energy

capacity and 3,285,000m3 of Bio methane. This equates roughly to enough

renewable energy to power 6,125 homes. The carbon reduction through the AD

process equates to offset the levels of carbon produced by approximately

71,000 cars;

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

a higher rate of first year nitrogen availability than many organic fertilisers;



56

The Roundhill proposal would employ 6 permanent members of staff from the

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

employed during the construction phase of the development.

9.6 Summary

9.6.1 The proposed development may be considered as a listed exception to Green Belt

policy in that it constitutes limited infilling and redevelopment of previously developed

sites (brownfield land) as set out in Paragraph 89 of the NPPF. Notwithstanding this,

there are a considerable number of very special circumstances relevant to the proposal

and the development site that justify an exception to Green Belt policy being made,

these are summarised below.

Locational needs:

• Co-located with existing sewage works

• The close proximity of the site to the source of waste and to the point of use of


• The good transport connections of the site;

• The lack of alternative non-green belt sites within the area of search and close

to the sources of waste;

• The appropriate separation of the site from sensitive properties to protect them


• The benefits of existing extensive screening from infrastructure and mature


• The commercial availability and viability of the site;

• The environmental benefits of the co-location with an existing STW site;

• The ability to reduce the carbon footprint of Severn Trent operational sites.

Wider environmental and economic benefits:

• The urgent need for more recovery of organic waste to achieve higher levels

of landfill diversion of this waste stream;



57

• A means of treating locally sourced food waste;

• Generates 500kW of renewable energy and 3,285,000m3 bio methane and


• AD provides a completely enclosed waste treatment process, limiting the


• The significant savings in greenhouse gases as a result of diverting priority

waste materials from landfill as identified by government;

• Generation of a valuable agricultural product thereby conserving resources;

• Generation of local jobs both during the construction and operation of the site.

Other factors

• The lack of harm to the visual amenity and openness of the Green Belt;

• The minimal impact to amenities of local receptors;

• Landscape and Visual Impact Assessment indication that the proposed


9.6.2 Severn Trent therefore consider that the proposed location constitutes the most

appropriate location for the proposed development and that the proposed development

will not have a detrimental impact on the openness or appreciation of the Green Belt.



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10. Environmental Effects

10.1 Landscape and Visual Impact

10.1.1 The proposed AD site is located within Roundhill Sewage Treatment Works (STW) in

Staffordshire, located just off Gibbet Lane, approximately 1.5km west of Stourbridge

and 1km southeast of Stourton, close to the County border with Dudley (See Location

Plan, Section 14). The STW site is bounded to the north and east by farm land; to the

south mature trees with Gibbet Wood immediately beyond; to the west a steep

embankment leading into Stewponey Quarry.

10.1.2 The site, which is situated wholly in the West Midlands Green Belt, is split in two by a

private access road from the A449 installed for the site (SS.06/10/629 W) which runs

west to east.

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


approximately 28m in diameter and 16m in height; the reuse of 2 existing tanks, a 10m

high gas flare; a gas engine with a 12m exhaust stack; a gas to grid system with an

18.5m high water scrubbing tower; silage storage area; and other associated

infrastructure.

10.1.4 A Landscape and Visual Impact Assessment (LVIA) has been undertaken to support

this application (see section 5). The assessment identifies that the site benefits from

extensive screening from the existing man-made site infrastructure and from mature

hedgerow and woodland planting around the site. The scheme is considered to be

minimal in relation to the wider sewage treatment works development and that it would

be largely assimilated into the exiting industrial infrastructure of the sewage treatment

works. A photographic study of the site has shown that the proposed development

would not be significantly visible from surrounding visual receptors. Due to the

operational nature of the site, the nature and scale of the buildings on the surrounding

land additional planting is not proposed.

10.1.5 The LVIA further assessed the proposed development in terms of Green Belt location

and the potential detriment to the openness of the Green Belt. The Assessment

advised that the site is located within the boundary of the existing sewage treatment

works which has already been developed as an industrial landscape which lacks

‘special character’. It states that the presence of the sewage treatment works in the

Green Belt has established a comparable development precedent, which would not



59

give rise to further urban sprawl or compromise ‘openness’ (such as it exists) in the

landscape.

10.1.6 The proposed site does not occupy land that could readily be described as

‘countryside’ and includes existing building and infrastructure that form part of the

wider sewage treatment works. It also argues that as a result of the substantial and



restricted, as such the addition of the proposed AD facility would have no additional

impact on this function above the baseline condition.

10.1.7 Given the enclosed nature of the site, the scale and mass of the proposed buildings in

relation to the surrounding industrial uses and the limited available visual receptors it

is considered that the proposed development would not have a detrimental impact on

the openness of the Green Belt or in terms of landscape and visual impact.

10.2 Hydrology

10.2.1 AD offers a completely sealed liquid management system. All incoming wastes are

immediately captured in the reception tanks and bunkers. Following reception the

whole process is totally enclosed and no liquids (except rainwater) leave the plant other

than the treated digestate destined as liquid fertiliser, which is collected and

transported in sealed tankers.

10.2.2 The site is situated entirely within Flood Risk Zone 1 as designated by the Environment

Agency. This is the area at the least risk of flooding, assessed as having less than a 1

in 1000 annual probability of flooding (<0.1%). Although the Technical Note to the

National Planning Policy Framework (NPPF) states that all uses are appropriate to

being located within Flood Zone 1, it requires all development of a size greater than 1

hectare to undertake a Flood Risk Assessment (FRA) (see Section 6) to determine

whether there may be any off-site impacts related to the proposed development.

10.2.3 The site is surrounded by a containment bund, capable of containing 25 % of the total

volume of digestate stored on site. The bunds will be constructed in accordance with

CIRIA C736 (Containment Systems for the Prevention of Pollution). The floor within

the bund would also be impermeable to ensure that any water falling within the bund

does not infiltrate the subsurface strata and ultimately the groundwater.



60

10.2.4 This proposal will result in no potential increase in off-site discharge rate from areas of

new hardstanding as outlined in the accompanying Flood Risk Assessment with this

application. New hardstanding areas to be constructed will allow incident rainfall to

percolate to ground leaving no need for mitigation by procedure or contingency action

which is also outlined in the Flood Risk Assessment.

10.3 Transport

10.3.1 A Transport Assessment has been undertaken to support this planning application (see

Section 7). All vehicle movements within the Assessment have been formulated based

on a worst case scenario approach whereby a higher proportion of waste is delivered

in smaller vehicles. In reality, Severn Trent expect that a higher proportion of waste will

be sourced from commercial clients and will be delivered in larger vehicles (i.e. 15

tonnes rather than 2.4 tonnes), thus substantially reducing the potential vehicle

numbers.

10.3.2 It is proposed that vehicles would access the site from an existing access to the

sewage treatment works via the purpose built private access road to the A449. The

Transport Assessment advises that the proposed development would result in an

average of approximately 64 movements (32 loads) in any given day for food collection,

digestate export and silage import; and a further 6 movements (3 cars/vans) for staff

vehicles.

10.3.3 During the spreading season (January to October) there may be instances where

vehicle movements are greater than the daily averages. This is due to the fact that

digestate can only be spread on land when conditions are favourable. There are

predicted to be between 30 and 65 days per annum when the digestate exports from

the site increase. It is anticipated that spreading would result in an additional 33 loads

per day (66 movements) per day.

10.3.4 The Transport Assessment has fully assessed the proposed transport impact of the

scheme on the surrounding highway network and has concluded that the proposal

would not result in a severe residual impact on the local highway network and

therefore, in accordance with guidance in the National Planning Policy Framework, the

proposal should not be rejected on transport grounds.



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10.4 Ecology and Arboriculture

10.4.1 A Preliminary Ecological Assessment (consisting of an ecological desk study and

walkover survey in accordance with Phase 1 Habitat Survey methodology) was

undertaken at the Roundhill site in April 2015 (Section 8) to consider the ecological

significance of the site and therefore the potential for ecological impacts as a result of

the proposed development. The site is not covered by or immediately adjacent to any

statutory ecological designations, however a non-statutory site (Gibbet Wood) is

located adjacent to the development site. This site is deemed unlikely to be affected

by the development as are any UK statutory or Non-Statutory sites.

10.4.2 The survey also assessed the development against likely impact on protected or

notable species, these included Badgers (which were surveyed separately), Bats,

Otters, Polecats, Reptiles, Amphibians, Birds, Plants and Invertebrates. The survey

did not identify any protected or notable species within the immediate survey area,

however there are areas where conditions are suitable to support species such as bats,

badgers, polecat, reptiles, nesting birds (if works take place during nesting season)

and Invertebrates.

10.4.3 It is considered that subject to the recommendations and adherence to species specific

legislation set out in the report the proposed development would not have a detrimental

impact on these species.

10.4.4 An Arboriculture Survey was undertaken in May 2015 and can be seen in Section 9.

The desk study and field survey of the trees present on-site undertaken concluded that

no Tree Preservation Orders within or closely surrounding the study area and that the

site is not situated within a Conservation Area. It is considered that subject to the

recommendations set out in the report the proposed development would not have a

detrimental impact on the trees selected for protection.

10.5 Heritage

10.5.1 There no Scheduled Ancient Monuments (SAM) within 2km of the site. There are

however 4 SAM sites within 5km including, to the west at Kniver Camp (3.4km); to the

north east at The Redhouse, Whitehouse and Newhouse Glassworks (3.5km); to the

north at Greensforge Roman Camp (4.6km) and to the south at Baches Forge (4.6km).

There are 19 Listed Buildings within 2km of the development site including Dunsley

Hall Farm to the west and Stourton Farmhouse to the North West.



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10.5.2 The development of the site and surrounding area has been reviewed by reference to

the historical maps and is summarised in Table below.

10.5.3 Table: Summary of Site History

DATE ON SITE DEVELOPMENT

NEARBY DEVELOPMENT

1882 – 1885

The site comprises two fields.

The site is located within a rural setting immediately surrounded by undeveloped fields to the north, east and southeast and forestry (‘Gibbet Wood’) to the south, west and northwest. ‘Gibbet Lane’ is indicated approximately 170m to the south. An embankment is indicated approximately 220m to the east. Possible ponds are indicated approximately 220m southeast. ‘Roundhill Farm’ is indicated approximately 500m to the southeast.

1901 – 1903

No significant changes to the site are indicated.

A Pheasantry and a pump are indicated 190m to the north. Gibbet Wood remains to the south but is now indicated as ‘Dunsley Bank’ to the northwest. Whittington Sewage Farm is indicated approximately 1km south of the site.

1914 No significant changes to the site are indicated.

‘Roundhill Sewage Farm’ is indicated approximately 250m to the southeast.

1921 – 1948

The site is indicated as one parcel of land.

An old sand pit is indicated approximately 320m to the southwest. The sewage treatment farm is also indicated approximately 500m to the southwest.

1954 No significant changes to the site are indicated.

Tracks are indicated in the woodland immediately to the south and west. A sand pit is indicated approximately 230m to the northwest.

1969 – 1971

Two sluices are indicated on site.

Sluices (4No.) are indicated between approximately 5m and 75m to the north, east and south. A tank is indicated approximately 65m to the east. A tank is indicated approximately 95m to the southeast. A wind pump is indicated approximately 20m to the northwest.

1980 – 1993

The sluices are no longer indicated. The site is indicated to have been developed in the eastern half and appears to be part of Roundhill Sewage Farm. Buildings and tanks are indicated. The western half appears undeveloped.

Roundhill Sewage Farm increases in size over this period. Filter beds are indicated approximately 50m to the southeast and tanks are indicated from 30m to the east and 160m to the southeast.

2002 – 2014

A road is indicated in the west of the site leading from the east.

The sewage farm is indicated to have extended beyond the south of Gibbet Lane. Portions of Gibbet Wood and Dunsley Bank are indicated as sand pits from immediately to the south and approximately 60m to the west.



63

10.5.4 It is considered that due to the significant severance distances between the site and

the surrounding historical assets, the existence and operation of the sewage

treatments works at the location since the 1930’s that the proposed development would

have no detrimental impact on surrounding historical assets.

10.6 Air Quality Bioaerosols and Odour

10.6.1 The Agrivert AD system is specifically designed to incorporate measures that avoid or

minimise potential disturbance to local receptors through the diminishing of local air

quality.

10.6.2 Waste is imported in enclosed vehicles, deposited and treated within an enclosed

building prior to being fed into digestion tanks via sealed pipework. The reception

building has an air extraction system, which maintains the reception building at a slight

negative pressure, and treats the air through a wet scrubber and a bark and woodchip

biofilter prior to exhausting to atmosphere. The building would also be equipped with

electric speed doors which close automatically once vehicles and machinery have

passed through. This maintains the negative air pressure that the filtration system

creates within the building, ensuring that the waste has minimum exposure to the

outside air, and minimises the risk of infiltration by vermin.

10.6.3 All transfer of waste materials from the reception building to the subsequent stages of

the process will be within fully enclosed pipework. No waste will be directly exposed to

atmosphere. The processing of waste, following pre-treatment in the reception

building, takes place within the digestion and storage tanks. Production and capture of

biogas (methane and carbon dioxide) is a fundamental part of the process. The primary

and secondary digester tanks together with the first two storage tanks are fully

enclosed air tight containers designed to facilitate “anaerobic” (in the absence of

oxygen) gas collection within the membrane roofs and to eliminate odour release. No

gas is therefore emitted to the atmosphere prior to combustion in the gas engine or

upgrading and export in the gas to grid system. Built-in measures within the tanks

themselves reduce the sulphur content within the biogas as this is damaging to the gas

engines. The storage tanks will not have an inner gas membrane (similar in style to

agricultural tanks) as the digestate will be relatively inert at this final stage.

10.6.4 Prior to biogas entering the gas engine it is scrubbed to remove elements such as

sulphur and siloxanes. The biogas is combusted in the gas engine which leads to the



64

effective destruction of odour compounds and therefore is considered to be fully

abated. The gas engine emit carbon dioxide (CO2), carbon monoxide (CO), water

vapour (H2O) and very low levels of nitrogen oxide (NOx) at the same level as standard

internal combustion engines. Although CO2 is a by-product of the process, the total

CO2 emissions compare favourably with other treatment solutions such as

composting. All the exhaust gas from the gas engines will be monitored and treated if

required to ensure it does not exceed statutory limits.

10.6.5 The remaining biogas is processed in the gas to grid system. This system is completely

enclosed. In this system the gas will be cleaned of impurities, dried and upgraded to a

higher methane content (> 95%) before being injected into the National Grid. This

upgrading is done utilising technology to scrub the biogas to remove impurities

(Hydrogen Sulphide, Water Vapour and Carbon Dioxide). The gas is then measured

for its calorific value and propane added to raise this value if required. The gas is re-

odourised for safety and pressurised before injection into the Gas Network. This

exhaust gas from the process is treated in two step process to reduce the odour levels

down to acceptable limits. The first step is a biological filter using water and lava rocks

to remove the Hydrogen Sulphite. Step two of the process passes the exhaust gas

through a bed of activated carbon to ensure no traces of Hydrogen Sulphite pass to

the air. The gas from the upgrading unit is passed through a second series of Activated

Carbon Beds to prevent any aromatic hydrocarbons such as Xylenes of Siloxanes

passing through. These beds also prevent odour masking limonenes or pinenes

passing through to the National Grid.

10.6.6 The digestate product is stored within storage tanks until such time as it can be spread

to land. Even at this stage biogas is collected from within the roofs of the first two

storage tanks and is passed through the gas engines. When the digestion process is

fully complete the digestate is stored in the storage tanks until the spreading season

begins. The digestate is collected from the site in sealed tankers, which transport it to

land for spreading using specialist slurry applicators in accordance with relevant

legislation.

10.6.7 The principal sources of dust emissions will be from HGV movements and the

transportation of energy crop silage. Internal haul roads are hard surfaced and do not

therefore generate significant levels of dust. A bowser can be used on site should dust

levels increase sufficiently. The energy crop storage area is enclosed on at least two

sides and covered with plastic sheeting. The energy crop has potential to release some



65

level of odour, particularly when disturbed i.e. when loaded into the feed bunker. This

is, however, agricultural by its nature and should not be particularly strong or offensive.

There is also a risk of dust generation, although the silage will be covered and moisture

content should reduce dust particles becoming air borne. In particularly dry or windy

conditions, it can be sprayed with water (collected on-site) to minimise the drying out

of the surface and dust being produced.

10.6.8 In support of this application an Air Quality Assessment (AQA) (See Section 10)

Bioaerosols Assessment (Section 11) and an Odour Assessment (See Section 12)

were undertaken. The AQA included in Section 10 assessed the predicted

concentrations of those pollutants identified in relevant EU, national and local

legislation. The Air Quality Assessment, Bioaerosols Assessment and Odour

Assessment have concluded that the proposed development would not give rise to any

detrimental impacts on residential or industrial amenity and that any discharges from

the site would be within acceptable limits.

10.7 Noise

10.7.1 The NPPF provides guidance on how the planning system can be used to minimise

the adverse impact of noise, stating that new development should not give rise to any

significant adverse impacts from noise, and should preserve the quality of life for

surrounding land uses. The site has been chosen partly due to its remote location, it is

not sited close to large numbers of sensitive receptors. The nearest receptor is

approximately 200m to the north east of the closest boundary of the facility, known as

Barrett’s Coppice Cottages. However, the proposed development is not anticipated to

result in unacceptable levels of noise. A noise assessment has been undertaken in

support of this application and can be seen in section 13.

10.8 Vermin and Birds

10.8.1 The immediate treatment of incoming waste and a sealed system make it almost

impossible for rats, mice and birds to access the waste. The management processes

and design of the plant, including sealed building and tanks, minimise the potential for

fly and insect infestations.

10.8.2 If necessary, bait stations can be used to prevent intrusion from rodents and a

professional pest control company can be employed.



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10.9 Litter

10.9.1 Litter is unlikely to become a problem on site due to the unloading of waste within an

enclosed reception building. Any contaminants are extracted within the building and

separately stored within a sealed skip. Litter pickers can be employed on site should

there be any requirement.

10.10 Complaints

10.10 A contact number will be provided enabling the public to report any nuisance incidents.

Details can then be cross-referenced with information on the weather conditions and

activities carried out on the day in question, in order to establish the cause of the

nuisance and for appropriate action to be taken on-site to reduce emissions/impacts.

All complaints are recorded through the Company’s complaints procedure which is built

into the Business Management System.



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11. Conclusion

11.1 The proposed development presents the most efficient and sustainable means of

recovering biodegradable organic waste. It is a key objective of Government policy to

increase the amount of organic material in the waste stream which is diverted from

landfill. To fulfil this objective the Waste Strategy set challenging targets for recycling

waste, including the organic element. The proposal will make a significant contribution

to meeting Staffordshire’s targets.

11.2 The Waste Strategy 2007, Review of Waste Policy and Defra’s Anaerobic Digestion

Action Plan promote AD, with the Waste Strategy stating that it “has significant

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

effective for food waste if separately collected”.

11.3 The facility will also provide a source of renewable energy, which will be fed into the

National Grid and will help in meeting Government targets for the generation of

renewable energy, it will also capture a significant amount of carbon which would be

lost to atmosphere and provide a source of renewable heat.

11.4 The site is located on brownfield land within an existing sewage treatment works in the

Green Belt, however the NPPF recognises that such a location should be considered

and may even be the most appropriate option. The need for such a waste management

facility, the lack of suitable sites outside of the Green Belt and the environmental

benefits associated with the generation of renewable energy, are all very special

circumstances that warrant an exception to Green Belt policy being made. The

magnitude of harm is more than outweighed by the very special circumstances

provided by this proposal.

11.5 The proposed development has good proximity to the sources of waste and markets

for the final product, it has good transport networks, is relatively remote from local

residential receptors, and adjacent to suitable facilities for co-location. The facility has

designed in mitigation measures, which will ensure that any potential environmental or

amenity impacts are not detrimental to the local environment or amenities of nearby

receptors.

11.6 The proposed built development, which is required to treat biodegradable organic

wastes and to comply with ABPR, has been designed and located to minimise its

disturbance to the local and wider landscape.



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11.7 This will be an important facility that will contribute significantly to Staffordshire meeting

its recycling and diversion from landfill targets as set out in the Staffordshire and Stoke-

on-Trent Joint Waste Core Strategy. Its acceptability in a Green Belt setting has been

justified in the above Chapters, environmental and amenity effects will be negligible,

and it is considered to accord with the general principles and policies of the

Development Plan.

ANAEROBIC DIGESTION FACILITY AT ROUNDHILL SEWAGE …

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