Energy from Waste with Combined Heat and Power … Waste Management Limited Energy from Waste with...

$: Energy from Waste with Combined Heat and Power … Waste Management Limited Energy from Waste with Combined Heat and Power Facility, Oxwellmains Supporting Statement May 2008 O:\Projects\0602SAW\Revised\Revised$
Viridor Waste Management Limited

Energy from Waste with Combined Heat

and Power Facility, Oxwellmains

Supporting Statement

May 2008

O:\Projects\0602SAW\Revised\Revised Supporting Statement\Viridor Supporting Statement (Revised) Final 30.04.08.doc

Viridor Waste Management Limited

Energy from Waste with Combined Heat and Power

Facility, Oxwellmains Landfill

Supporting Statement

Prepared by: Reviewed by: Steve Newlands/Alan Pollock David Harper Ocean Point One 4th Floor 94 Ocean Drive Edinburgh EH6 6JH Tel: 0131 555 5011 Fax: 0131 555 4911 Email [email protected]

Planning & Development

Viridor Waste Management Limited May 2008

EfW Facility Supporting Statement (Revised) RPS Planning & Development SAW0602/SN/DRH Final

Contents

1. The Proposals ................................................................. 1

1.1 Introduction ...........................................................................................1 1.2 The Site & Surrounding Land Use.......................................................2 1.3 Waste Management in the ELSB’s Area..............................................2 1.4 The Applicant.........................................................................................6

2. The Application Process ................................................ 7

2.1 Introduction ...........................................................................................7 2.2 Environmental Impact Assessment (EIA) and Scoping ....................9 2.3 Integrated Pollution and Prevention and Control ............................18 2.4 This Document ....................................................................................18

3. Proposal Details ............................................................ 20

3.1 The Facility...........................................................................................20 3.2 Buildings ..............................................................................................20 3.3 Design and Materials ..........................................................................21 3.4 Access..................................................................................................21 3.5 Parking and Pedestrian Access.........................................................21 3.6 Gatehouse and Weighbridges............................................................22 3.7 Vehicle Wheel Wash............................................................................22 3.8 Flood Protection..................................................................................22 3.9 Landscape Planting ............................................................................22 3.10 External Lighting .................................................................................23 3.11 Operating Hours ..................................................................................23 3.12 Plant Maintenance and Shutdown.....................................................23 3.13 Staff ......................................................................................................23 3.14 Control of Amenity Impacts ...............................................................24 3.15 Construction ........................................................................................24 3.16 Decommissioning and Restoration...................................................25 3.17 General .................................................................................................25 3.18 Waste Reception, Storage and Handling ..........................................26 3.19 Furnace Overview and Operation......................................................26 3.20 Stack.....................................................................................................29 3.21 Ash and Residue Handling.................................................................29 3.22 Energy Recovery .................................................................................30



4. How do the Proposals relate to the Lothian & Borders Area Waste Plan?.......................................................... 31

4.1 Introduction .........................................................................................31 4.2 Waste Arisings ....................................................................................31 4.3 Waste Management Strategy .............................................................32 4.4 Facility Benefits...................................................................................36

5. The Results of the Environmental Impact Assessment ………………………………………………………………...38

5.1 Air Quality & Human Health ...............................................................38 5.2 Natural Heritage and Archaeology ....................................................39 5.3 Aviation ................................................................................................39 5.4 Ecology ................................................................................................39 5.5 Hydrology and Hydrogeology............................................................40 5.6 Land Contamination and Ground Conditions ..................................41 5.7 Landscape and Visual.........................................................................42 5.8 Noise and Vibration.............................................................................43 5.9 Traffic and Transport ..........................................................................44 5.10 Socio Economic ..................................................................................44 5.11 Amenity ................................................................................................45 5.12 Cumulative Impacts ............................................................................45 5.13 Conclusions of the EIA.......................................................................45

6. Policy Analysis and Compliance................................. 46

6.1 Background .........................................................................................46 6.2 International Conventions ..................................................................47 6.3 European Directives............................................................................47 6.4 UK Legislation and Policy ..................................................................48 6.5 Scottish Government Policy – Waste Management and

Environment ........................................................................................49 6.6 Scottish Government Planning Policy ..............................................50 6.7 Development Plan Policy....................................................................60 6.8 Policy Conclusions .............................................................................66

7. Conclusions................................................................... 67

7.1 Environmental Effects ........................................................................67 7.2 Sustainable Waste Management........................................................67



Appendix 1 – Further Information on the Applicant .......... 69 Appendix 2 – List of Consultees.......................................... 73

Figures Figure SS1 Site Location Plan Figure SS2 Facility Application Boundary Figure SS3 Existing Lothian’s and Borders Area Waste Plan (2003) BPEO Figure SS4 Proposed Building Plan Figure SS5 Site Layout Plan Figure SS6 Proposed Cladding Elevations (North West & South East Elevations) Figure SS7 Proposed Cladding Elevations (North East & South West Elevations) Figure SS8 Outline Surface Water Drainage Strategy Figure SS9 Simplistic Process Flow Diagram Figure SS10 Predicted Residual Waste Arisings for Municipal Solid Waste (MSW) Figure SS11 Predicted Residual Waste Arisings for Commercial and Industrial Waste (C&I) Figure SS12 European Waste Management Comparison Table Figure SS13 Innerwick Photomontage Figure SS14 Access Road to White Sands Photomontage



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1. The Proposals 1.1 Introduction

Viridor Waste Management Limited (‘Viridor’) proposes to develop an Energy from Waste with Combined Heat and Power (CHP) facility (the Facility) at Oxwellmains Landfill, approximately 4.5km south-east of Dunbar town centre (Figure SS1). The total capacity of the Facility will be 300,000 tonnes per annum, based on 2 lines with a capacity of 150,000 tonnes each. The fuel would comprise of both residual Municipal Solid Waste (MSW) and residual Commercial and Industrial (C&I) Waste from the Edinburgh, East Lothian and Midlothian areas, arriving by both road and rail. Residual wastes are those remaining following extraction of materials for reuse or recycling, either at source by householders (as part of separate kerbside collections organised by the Waste Collection Authorities), or following segregation at business and commercial premises or treatment at other facilities such as Materials Recycling Facilities (MRF’s).

Indicative sources for the 300,000 tonnes per annum input are as follows:

� 150,000 tonnes of residual MSW arising from the target authorities of the City of Edinburgh, East Lothian and Midlothian; and

� 150,000 tonnes of residual commercial and industrial waste from the target

authority catchment areas. It should be noted that residual wastes from the Edinburgh and East Lothian areas currently go the Oxwellmains landfill. Full proposal details are presented within Chapter 3 of this Supporting Statement. The proposed capacity has been arrived at following detailed consultation, consideration of need within the locality and Scottish Government policy on waste management. Planning and PPC permit applications were submitted in January 2008 for the same Facility but with designed capacity of 450,000 tonnes per annum. Indicative sources for the 450,000 tonnes were as follows: � 300,000 tonnes of residual MSW arising from the target authorities of the City

of Edinburgh (with whom Viridor has an existing contract), West Lothian, East Lothian, Midlothian and the Scottish Borders; and

� 150,000 tonnes of residual commercial and industrial waste from the target

authority areas. Post submission of the Planning Application a decision was taken by Viridor to re-consider the capacity of the proposed Facility. The revision of the capacity of the Facility was taken in light of the following: � recent Scottish Government announcements in respect of waste strategy

within Scotland;



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� removal of West Lothian and the Borders areas from the authorities considered (this is in recognition of both councils now pursuing their own projects); and

� consideration of feedback from continued stakeholder engagement. The needs assessment for the proposed Facility concluded that there is a requirement for a Facility of 300,000 tonnes based on the proposed waste streams. This application is therefore for the reduced capacity Facility of 300,000 tonnes per annum. The proposals meet the requirements of the LBAWP with regard to residual waste treatment. The key difference from the original Facility is the reduction of the number of feedstock lines from 3 to 2.

1.2 The Site & Surrounding Land Use The proposed site for the Facility, which is owned and operated by Viridor benefits from excellent road and rail access, and is relatively remote from sensitive receptors. It is set within a standalone quasi-industrial area, presently dominated by Torness Nuclear Power Station and the Lafarge Cement Works. The proposed site forms part of a former quarry, a large proportion of which is currently being operated by the Applicant as a non-hazardous landfill site. The Facility will be located within an area allocated as cells 9 and 10 of the landfill, which will no longer be developed for landfill but rather will be set-aside for the purposes of the proposal. The Planning Application boundary is shown in Figure SS2 and will cover 7 hectares within the 70 hectare Oxwellmains Landfill site, the footprint of the Facility being approximately 5-6 hectares. The remainder of the landfill will continue to operate as at present. The combined total annual input of both the landfill and the proposed Facility would be in the region of 400,000 tonnes, an additional 50,000 tonnes over and above what is currently received. Site Selection The site for the Facility was chosen following an extensive and detailed selection process which considered a number of possible locations within the Edinburgh, Lothian’s and the Scottish Borders (ELSB) area. The selection process began in March 2006 and was completed in October 2006, narrowing an initial 143 identified sites down to the final site at Oxwellmains Landfill. The Oxwellmains site was chosen because it was the most suitable, when assessed against a range of environmental parameters and planning considerations. The full Site Selection report is contained within Appendix 3 of the Environmental Statement (ES).

1.3 Waste Management in the ELSB’s Area

Lothians and Borders Area Waste Plan (LBAWP)

Scotland is committed to meeting a range of national targets aimed at minimising waste and diverting the waste away from landfill and recovering value through recycling, composting and energy recovery. These targets are outlined in the EU landfill Directive 99/31/EC, the National Waste Plan Scotland, and the delivery of



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Area Waste Plans. An announcement made by cabinet secretary, Mr Richard Lochead on 24 January 2008 outlined a new vision for waste which will also address how we deal with waste in the future. The waste management strategy for the ELSB’s area is described in detail in the Lothians and Borders Area Waste Plan (2003) (LBAWP). The LBAWP covers the local authority areas of Edinburgh City, East, Mid and West Lothian and the Scottish Borders.

The Lothian and Borders Area Waste Plan considers household and commercial wastes collected by the five local authorities of the City of Edinburgh, East Lothian, Midlothian, West Lothian and Scottish Borders and details how the Lothian and Borders area will meet its share of the targets. The Lothian and Borders Area Waste Plan was developed by the Scottish Environment Protection Agency, the five local authorities and representatives from local business, industry, non-governmental organisations and the community recycling sector. Combined they make up the Waste Strategy Area Group. Phase 1 delivery of the Area Waste Plan has been focussed on supporting the provision and enhancement of the kerbside recycling collection systems, as well as the introduction of new and upgraded recycling centres and points. Phase 2 delivery of the Area Waste Plan focuses on the need to treat and divert residual municipal waste from landfill in order to further complement the recycling and composting performance targets realised from Phase 1 activities and to ensure compliance with EU Landfill Directive targets.

Section 3 of the Area Waste Plan focuses on the Best Practicable Environmental Option (BPEO) which details the preferred way to manage municipal waste in the Lothian and Borders over the next thirteen years. An alteration to the BPEO was recently adopted and published on the 13 March 2008. The alteration resulted from Strategic Environmental Assessment of the Area Waste Plan, in parallel with a BPEO review. Figure SS3 summarises the new Lothians and Borders Best Practicable Environmental Option (BPEO) for Municipal Solid Wastes (2020). A key consideration with regard to meeting these targets is residual waste treatment. Section 3.2.5 of the LBAWP deals with residual waste treatment. The following section provides an overview of the key points which will be a material consideration with regard to the proposed Facility at Oxwellmains. Residual Waste Treatment Section 3.2.5 of the LBAWP plan states the following:

…As recognised within the 2003 Area Waste Plan BPEO, the mid to long-term statutory targets to reduce biodegradable waste disposed of to landfill will be more challenging to achieve, and will therefore require the development of residual waste infrastructure to supplement ongoing waste prevention, recycling and composting (pre sorted) activities. Residual waste treatment facilities will also seek to recover further value from wastes prior to disposal to landfill, which is in line with the principles of the waste hierarchy. The scale of other treatment technologies required will largely depend on the short to medium term achievements of waste prevention, recycling and composting that will be optimised where practicable, but given the position of

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residual waste treatment in the waste hierarchy, the capacity of residual treatment should not be procured at the expense of complying with waste prevention and recycling targets. However, the provision of residual waste treatment does have a place as a viable alternative to landfill. In order to achieve the output percentage targets set out in Table 1, residual waste input capacity of around 45% - 56% (of total municipal waste arisings) may need to be developed in Lothian and Borders by 2020. This will however, be very much dependent on the technology developed and will be dealt with at the procurement stage that will also define the number and capacity of facilities. The 2003 Area Waste Plan also noted that the L&B BPEO is an evolving option that will need to be reviewed to accommodate the findings of research on available residual waste technologies and assessment of ongoing waste trends. Residual waste treatment facilities that are developed in Lothian and Borders will contribute to the overall Recycling and Composting target. The BPEO assumes that a minimum of 10% of total waste arisings will be added to overall recycling and composting targets for the area. This may be increased depending on the technology developed. Recycling from residual waste facilities can be achieved through activities such as recycling of thermal treatment ash, extraction and recycling of metals and stabilisation of biowaste through mechanical biological treatment. The main component of residual waste treatment facilities is additional diversion from landfill through process loss, for example, evaporation of the moisture content within biowaste, reduction by thermal treatment and production of Refuse Derived Fuel for subsequent burning. All residual waste treatment will produce residues, even after all processing has taken place, which require disposal to landfill (these have been included in the total municipal waste to landfill percentage target, also see section 3.2.6). The BPEO is no longer technology prescriptive, and the residual waste treatment performance target in Table 4 could be met through a range of residual waste treatment technologies.

It further goes on to state that any proposals will be subject to public consultation under the statutory land use planning system, Environmental Impact Assessment requirements and Pollution Prevention and Control (PPC) Permit applications. The consideration of residual waste treatment proposals will take the following into account: � consideration should be given to incorporating appropriate segregated wastes

or refuse-derived fuel as an alternative fuel source to fossil fuels in suitable industrial processes, e.g. cement manufacture where appropriate;

� any proposals incorporating mixed waste composting processes should aim

to optimise the quality of the end product to suit end market availability and regulatory requirements;

� the Waste Strategy Area Group ruled out sending unsegregated municipal

waste directly for thermal treatment, historically this has been termed mass burn incineration. This decision is supported by the SEPA Guidelines for



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Thermal Treatment of Municipal Waste found at http://www.sepa.org.uk/pdf/nws/guidance/thermal_treatment.pdf;

� any Thermal Treatment options should take SEPA’s Thermal Treatment

Guidelines into account; � the capacity of residual waste treatment for municipal waste in Lothian and

Borders will not interfere with recycling and composting (pre sorted) aspirations;

� residual waste treatment proposals should seek to further optimise recycling

and/or composting performance targets where practicable with full consideration of market availability and compliance with environmental regulation (see residual waste recycling/composting performance targets);

� all opportunities should be investigated to meet required standards and

respond to available end-product markets;

� consideration should be given to locating any EfW facilities in proximity to heat users as there is potential for EfW to produce heat which can be used for industrial, commercial or residential use;

� consideration should be given to potential synergies with Commercial and

Industrial wastes in the area; and

� consideration should be given to the proximity principle, transportation distances and the carbon footprint.

The Scottish Executive previously proposed to provide funding to Local Authorities to meet their long term contractual requirements from the Strategic Waste Fund (SWF) and in order to receive funding groupings of authorities were required to work together in partnership. As such, the five authorities within the ELSB’s were grouped together under the Lothians and Borders Public Private Partnerships (PPP) project, although any procurement will probably now follow the “Competitive Dialogue Procedure”. Although the proposed funding has subsequently been withdrawn (in the form of the ring fenced SWF) from the Lothian's and Borders PPP project, the authorities named above are still in discussion about working together on a residual waste treatment project, taking on board the work done to date on the PPP project. Furthermore, via the Oxwellmains landfill site operated by the applicant, residual waste disposal services are currently being provided to Edinburgh and East Lothian. The key aim of the Facility is to ensure the Local Authorities are in a position to meet their required targets for diversion of Municipal Solid Waste (MSW) from landfill, as outlined in the National Waste Plan: Scotland (NWP) 2003 and legislated for in the Waste Emissions and Trading (WET) Act 2003; and as more particularly required by the Landfill Directive (1999/31/EC). The proposed Facility provides a solution to the problem of residual waste diversion from landfill whilst making an additional contribution to the ELSB’s recycling and composting targets.



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1.4 The Applicant

Viridor, owned by the Pennon Group, is part of a major Plc focused on the water and waste management industries and with assets of over £2 billion. Viridor is one of the UK’s leading waste management companies, and at present operates 25 regional landfill sites, numerous regional recycling facilities and over 200 waste processing sites1.

Viridor is playing a major role within the UK in helping to achieve ever more demanding recycling, waste treatment and disposal targets. The Company aims to become an exemplary secondary materials recycler by continuing and developing further approaches to this area of waste management built on economic, social and environmental sustainability principles. Waste management services offered by Viridor include: � Materials Recycling Facilities (MRF); � bulking and transfer stations; � materials collection; � glass reprocessing; � composting; � green and In-Vessel Composting (IVC); � waste treatment; � transportation; � Household Waste Recycling Centres (HWRC); � product destruction/recovery; � residual waste disposal; � landfill gas utilisation; and � Energy from Waste Facilities (EfW). Further information on the Applicant is contained within Appendix 1 of this Supporting Statement.

1 http://www.viridor-waste.co.uk/index.php?id=38&menu=aboutus



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2. The Application Process 2.1 Introduction

This Supporting Statement is submitted to East Lothian Council under the Town and Country Planning (Scotland) Act 1997 on behalf of Viridor in support of the Planning Application for the Facility. The planning application package comprises of the following: � the application forms and certificates; � this Supporting Statement; � an Environmental Statement and Technical Appendices; � a Design Statement; � a Non-Technical Summary of the Environmental Statement; and � detailed plans of the site and the proposed buildings. The Environmental Statement The Environmental Statement presents the findings of the Environmental Impact Assessment (EIA), as specified in the Environmental Impact Assessment (Scotland) Regulations 1999. Information that must be provided in the ES is included in the Regulations (Part II of Schedule 4) – namely: (1) a description of the proposed development comprising information on the site,

design and size of the development; (2) a description of the measures envisaged in order to avoid, reduce and, if

possible, remedy significant adverse effects; (3) the data required to identify and assess the main effects which the

development is likely to have on the environment; (4) an outline of the main alternatives studied by the applicant or appellant and

an indication of the main reasons for their choice, taking into account the environmental effects; and

(5) a non-technical summary of the information provided. The Chapters titles within the ES are as follows: � Introduction Chapter 1; � Planning Context Chapter 2; � Project and Site Description, Chapter 3; � Air Quality & Health Risk Assessment Chapter 4; � Archaeology & Cultural Heritage Chapter 5; � Aviation Chapter 6; � Ecology Chapter 7; � Hydrology & Hydrogeology Chapter 8; � Land Contamination and Ground Conditions Chapter 9; � Landscape and Visual Chapter 10; � Need, Alternatives and BPEO Chapter 11; � Noise & Vibration Chapter 12; � Traffic, Transport and Access Chapter 13; � Socio-economic Impacts Chapter 14; � Amenity Issues Chapter 15; � Cumulative Impacts Chapter 16; and



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� Conclusions Chapter 17. Chapter 1 presents a general introduction and overview of the proposals; Chapter 2 presents the planning context of the proposals, and how the project is supported by relevant local and national planning policy; Chapter 3 provides a description of the development, including its physical characteristics and land-use requirements. This includes a description of the proposed plant and main characteristics of the processes. Sources and characteristics of waste products are also presented. The envisaged need for and benefits of the proposal, and an indication of how the EIA process has altered the project design (point 4, above) are also presented; The relevant technical sections (4 to 16) follow a standard pattern, with some variations according to the area under study. Each Chapter contains an Executive Summary of the methodology and findings of the assessment, followed by an Introduction to the assessment. Methodologies used to predict and assess environmental effects are presented, followed by the results found for both Baseline and Impact Assessments. Any recommended mitigation is proposed, and the significance of any remaining residual effects is assessed. These Chapters therefore provide further information required under in the Regulations (points 2 and 3 above). Chapter 17 summarises the findings and conclusions of the individual impact assessments, and reaches conclusions regarding the EIA as a whole. Appendices to the Environmental Statement contain the following: � Appendix 1 – Scoping Letter and Report; � Appendix 2 – East Lothian Council’s Screening Opinion; � Appendix 3 – Site Selection Report; � Appendix 4 – Heat Plan; � Appendix 5 – Air Quality Technical Report; � Appendix 6 – Human Health Risk Assessment; � Appendix 7 – Ecological Technical Reports; � Appendix 8 – Flood Risk Assessment; � Appendix 9 – Interpretative Site Investigation Report; � Appendix 10 – Transport Assessment; � Appendix 11 – Sustainability Appraisal; � Appendix 12 – Statement of Community Engagement; � Appendix 13 – Carbon Footprint; � Appendix 14 – Glossary of Technical Terminology and Acronyms; and � Appendix 15 – Footnote References. The ES should be read as a supporting document to the planning application, which makes reference to specific sections as appropriate. In producing technical statements of this nature, the Environmental Impact Assessment Regulations recognise the need to produce a Non-Technical Summary of the specialist reports. The Non-Technical Summary (NTS) The NTS is provided as both a stand alone document and at the start of the main ES. It provides an easy to understand summary of the proposals and the findings of the Environmental Impact Assessment.



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The Design Statement The purpose of the Design Statement is to provide an outline of the following: � the proposed Facility; � the site context; � the design of the buildings and plant; and � the relationship of the proposal to the existing site and wider landscape and

environment. The Design Statement explains the design principles and design concept of the proposed layout, landscape, scale and materials. The report documents the design evolution of the proposed Facility and illustrates the design solution. 'Designing Places A Policy Statement for Scotland' produced by The Scottish Government sets out its policy on design and the role of the planning system in delivering these policies. The Design Statement has been prepared in accordance with some of the environmental objectives within the policy document and in accordance with advice set out in PAN68 published by the Scottish Government.

2.2 Environmental Impact Assessment (EIA) and Scoping Introduction

EIA is a process intended to ensure that permission for developments, which may have significant effects on the environment, should be granted only after prior assessment of the potential environmental effects of those developments, has been carried out. The assessment must be carried out on the basis of information supplied by the developer, in the form of an Environmental Statement, which is supplemented by information received following consultation with statutory consultees and other bodies and members of the public.

Legal Background

The necessity for EIA to be carried out as a preliminary to securing planning permission for certain classes of development is required in the Environmental Impact Assessment (Scotland) Regulations 1999. These regulations enact the European Directive 85/337/EEC (the “EIA Directive”) as amended by 97/11/EC European Directive. The scoping, preparation and production of the Environmental Statement has been conducted in accordance with the latest Government Regulations and advice on good practice comprising: � Environmental Impact Assessment (Scotland) Regulations 1999; � Circular 15/1999 The Environmental Impact Assessment (Scotland)

Regulations 1999; � Planning Advice Note (PAN) 58 – Environmental Impact Assessment,

September 1999; � Preparation of Environmental Statements for Planning Projects that require

Environmental Assessment, A Good Practice Guide (Department of the Environment, 1995);

� A Handbook on Environmental Impact Assessment, Scottish Natural Heritage, January 2002; and



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� Institute of Environmental Management & Assessment (IEMA)/RPS Guidelines for Environmental Impact Assessment, 2004.

Stages of EIA

Environmental Impact Assessment (EIA) is a process that identifies the potential

environmental effects of a development and then seeks to avoid, reduce or offset any adverse effects through mitigation measures. EIA follows a series of stages:

� site selection and development initiation; � screening – is an EIA required?; � pre-application discussions; � scoping – consultation on proposed scope and methodology; � environmental baseline studies – establish what is there; � assessment of effects – determine the potential effects; � mitigation – modify proposals to incorporate mitigation measures and re-

assess residual effects; � preparation of an Environmental Statement; � submission of a Planning Application with Environmental Statement; � consideration of the application and environmental information by East

Lothian Council and consultees; � decision to refuse or grant consent (with or without conditions); and � implementation and monitoring.

Good practice advises that EIA should be treated as an iterative process rather than a one off, post design environmental appraisal. In this way the findings of the EIA can be fed into the design process, leading to the design of a development, which achieves a ‘best fit’ within the environment. As potential adverse effects are identified, the design of the development will be adjusted and mitigation measures proposed. Consultation, a vital component of the EIA process, continues throughout each stage and contributes both to the identification of potential effects and to the mitigation measures.

Screening No formal request for a screening opinion under the Environmental Impact Assessment (Scotland) Regulations 1999 was made to East Lothian Council as the development was classed as a Schedule 1 development, in Paragraph 10 of the Environmental Impact Assessment (Scotland) Regulations 1999 (the EIA Regulations). This lists …Waste disposal installations for the incineration or chemical treatment) as defined in Annex II to Directive 75/442/EEC under heading D9) of non-hazardous waste with a capacity exceeding 100 tonnes per day… as a development requiring an EIA. Scoping

Consultees

There is no obligation on the developer to consult as to the information to be included

in an Environmental Statement. However, as the Planning Authority and Consultation Bodies will possess local and specialised information, their involvement at an early stage is likely to be beneficial to the EIA and the development design processes. They are also likely to be able to provide preliminary advice on those areas of the development that are likely to be of concern.



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Therefore, under Regulation 10 of the EIA Regulations, a developer may ask the Planning Authority or Scottish Ministers for their formal opinion on the information to be supplied in the ES. When asked for its opinion, the Planning Authority will consult the “Consultation Bodies”, including:

� any adjoining planning authority likely to be affected by the proposed development; � Scottish Natural Heritage; � The Scottish Environment Protection Agency (SEPA); � Water and Sewerage Authorities (in this case, Scottish Water); � The Health and Safety Executive; and � The Scottish Ministers.

A request for a Scoping Opinion from East Lothian Council was submitted on 15 June 2007. This took the form of a Scoping Report and a Scoping Letter asking for opinions on the proposed scope of work and methodologies and information that may be available on the site. The Scoping Report set out perceived likely effects that could be anticipated as a result of the proposed development, and the assessment process by which these effects would be evaluated. The Council formally issued its scoping opinion response on the 3 August 2007 (Appendix 2 of the ES).

The same report and letter was sent to “non-statutory” consultees, including

community and interest groups. Non-statutory bodies and individuals will not automatically be consulted by the Planning Authority although they will have the opportunity to provide comment on the Application once submitted. However, these bodies and individuals may also possess local knowledge and information useful in compiling the ES. A list of consultees is provided within Appendix 2.

By conducting this consultation exercise as early as possible in the design process,

the overall development planning and design has taken account of any alterations or measures that could resolve potential issues and minimise possible impacts of the proposed development.

Responses from all consultees are summarised in Table 2.1. Responses are

referenced to the Chapter of the ES under which they will be considered, or, if outwith a particular Chapter, the general topic covered by the response is provided. Technical Chapters detail how the responses have been dealt with.

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14

Community & Stakeholder Consultation

Consultation is a key element in the overall project development and application process and took place during the preliminary stages of the EIA, continuing throughout the process of formulation of the proposals, preparation of the Environmental Statement and preparation of the Application.

A Statement of Community Engagement has been submitted with this planning application (Appendix 12 of the ES). It describes details of the communications programme undertaken by Viridor, together with an overview of the work carried out and planned prior to submission of the planning application. It does not cover the extensive consultation with statutory consultees, local authorities and non-statutory consultees carried out as part the Environmental Impact Assessment (EIA) scoping process (this information is contained within the Environmental Statement accompanying the application).

Prior to submission of the planning application, Viridor informed the public of the proposed development. Viridor has publicised the proposals and explained the development in a clear and open manner by way of a website, public exhibitions, a stakeholder workshop, presentations to Community Councils and leaflets. In doing so Viridor has strived to increase public knowledge of the waste issues being faced within the Lothians, Edinburgh and Scottish Borders and within Scotland as a whole. This pre submission community engagement programme is in accordance with PAN 81 which encourages best practice including that those who make comments on the planning application to be informed of the decision and the reasoning behind it. The public exhibitions, stakeholder workshop and presentations to Community Councils were held over the summer and into autumn 2007. Local people and local interest groups were invited to find out about the proposed development and what is planned for the site at Oxwellmains Landfill. Viridor has provided members of the public with the opportunity to feed in their views and concerns, enabling those to be considered and, where practical, incorporated before the application is finalised and submitted. A summary of the community engagement programme carried out in 2007 is outlined below: � a dedicated website was developed giving details on the proposals which

became live on 13 August 2007, and is updated regularly; � leaflets were produced giving background on the proposal which were sent to

key stakeholders and local communities of Dunbar, West Barns and East Lammermuir;

� advertising of public exhibitions through covering letters sent out with the leaflets and adverts placed in the local news papers;

� presentation to the Oxwellmains site local liaison committee meeting on 22 August 2007;

� stakeholder briefing at the Rocks Hotel on 23 August 2007 for local politicians and members of the community councils;

� two day public exhibition of the proposals held at Dunbar leisure centre on 24 August and 25 August 2007; and

� public exhibition of the proposals at Innerwick village hall on 30 August 2007. The majority of responses positively supported the proposal or were supportive so long as certain criteria were met. The main issues raised from the community engagement process were air quality and emissions, landscape and visual impact



15

and the impact of traffic. Other comments received from the engagement process included ‘disposing of waste in a controlled manner to create energy is the way forward’ and that ‘EfW is better than disposing of waste to landfill’. The issues raised from the public and other interested parties were taken into consideration within the EIA process, as appropriate. This also helped to inform the specialised studies within the ES and to mitigate against any major concerns, where possible. The consultation also provided information on what people considered positive about the proposal which was also taken into consideration within the EIA. Consultation and stakeholder engagement has continued in late 2007 and 2008, this has included the following: � a second mail-out providing updated information following initial consultation; � additional meetings of liaison group - updates on EfW proposals provided and

queries responded to; � on-going provision of update position statements sent to key community

contacts and stakeholders and via press; � attendance at and presentation of information to a public meeting organised

by Dunbar Town Council held at Dunbar Grammar School 11 February 2008; � updated information on website; and � responses provided to all enquiries received on proposals via

website/email/dedicated information line, etc. Consultation will continue to be an ongoing process and it is planned that this will follow on from the submission of the revised Application to address concerns and objections if these arise. In addition, regular updates on progress with the construction and operation of the Facility, if consented, will be provided and if there are issues within the community, these can be raised and discussed with Viridor and addressed via Community Liaison Groups. The Statement of Community Engagement submitted as part of the Planning Application package outlines in more detail the discussions undertaken at the various consultation events and contains copies of the presentation material and other analysis of comments made. Summary The scoping opinion from the Council considered the Scoping Report to be comprehensive, identifying all the main environmental issues and set out a priority in respect of the main environmental impacts to be addressed, as follows: � the visual impact of, firstly, the stack required as part of the proposed

development and, secondly, the principal building required to accommodate the operation;

� the impact of built development on the landscape character of the wider rural area;

� the impacts of noise and emissions, including air quality and the effects on human health, from the proposed development;

� the impact of development on nearby SPA/RAMSAR designations; and � the impact of traffic. Other issues have been raised by consultees and these have been addressed as appropriate.



16

The environmental impacts raised above were taken forward for detailed assessment and have been reported on in the ES. Environmental Effects and Assessment Criteria

Following scoping and identification of potential environmental effects, technical assessments were carried out in order to predict potential impacts associated with the development, and identify proposed measures, where appropriate, to mitigate the identified effects. Each assessment Chapter within the ES (Chapters 4-16) follows a systematic approach, as described below. Baseline Description

In order to evaluate environmental effects, information relating to the existing environmental conditions (baseline) of the proposed site was collected. For each separate technical assessment, methods of data collection were discussed with relevant consultees. Existing data was gathered from records and other archive sources. Where appropriate, field surveys and monitoring were carried out. Within each Technical Chapter a description of the data sources consulted and fieldwork carried out to collect baseline data is presented. The timing of work and the study area are also outlined. A description of the baseline conditions (in terms of the particular assessment) is presented and its importance and sensitivity considered. Where appropriate, existing processes of change in the environment, which would occur in the absence of the development, are also identified.

Prediction of Potential Effects

Development of the Facility can be split into three distinct phases: � Construction (including commissioning); � Operation; and � Decommissioning. During each phase of development different environmental effects are likely to arise. For example, during construction, effects associated with excavation and traffic would differ from those effects associated with the operation of the site. For each technical assessment, the type of effect identified covers direct effects as well as indirect, cumulative, short, medium and long term, permanent and temporary, positive and negative effects (for example during operations) together with their interactions.

Assessment of Effects

Following identification of potential environmental effects, baseline information is used to predict changes to existing site conditions, and allow an assessment of these changes. The effect that the proposed Facility may have on each environmental receptor will be influenced by a combination of the sensitivity of the environment and the predicted degree of alteration from the baseline state (both positive and negative). Environmental sensitivity may be categorised by a multitude of factors such as threat



17

to rare or endangered species, transformation of natural landscapes, changes to soil quality and land use. The initial assessment, consultation and scoping phases identified these factors along with the implications of the predicted changes. In order to evaluate environmental effects, assessment criteria are identified within each Chapter. Thresholds of significance are then used to make explicit the conclusion of the assessment process. Significance is based on the structured evaluation of three main criteria: � identifying the nature and form of any predicted environmental effects; � assessing whether effects identified are significant; and � assessing the likelihood of identified effects. For the purposes of environmental impact assessments ‘effect’ is generally considered in terms of: � Negligible – minimal or no change; � Minor – a detectable but non-material change to a location, environment or

species; � Moderate – a material, but non-fundamental change to a location,

environment or species; and � Major – a fundamental change to a location, environment or species. The ES generally follows this theoretical approach. Where specific topic areas follow a variant of this approach, this is identified within the particular assessment Chapter, and an explanation is provided as to why the approach has been varied. Within each assessment Chapter the criteria for assessing significance of effects are made explicit. Each Chapter also proposes measures to avoid, reduce or remedy significant adverse effects (mitigation measures). Significance of effects is determined by comparing the magnitude of the effect, with the sensitivity of the receptor. Each technical assessment assesses significance in different, topic specific manners, but generally uses a matrix similar to that in Table 2.2.

TABLE 2.2 – GENERIC SIGNIFICANCE MATRIX Receptor Sensitivity Impact Magnitude

High Medium Low Severe Major Major/Moderate Moderate/Minor Substantial Major/Moderate Moderate Minor Moderate Moderate Moderate/Minor Minor/Neutral Slight Minor Minor/Negligible Negligible No Significant Change Negligible Negligible Negligible

The assessment process concludes with an examination of residual effects, that is, those effects remaining after mitigation has been applied. Mitigation

Where the assessment process identifies any likely significant adverse effects, mitigation measures are proposed during the design phase. Such measures include the consideration of alternatives, physical design, project management and operation to avoid, reduce or remedy any significant adverse effects on the environment.



18

This strategy of avoidance, reduction and remediation is a hierarchical one that seeks first to avoid potential impacts, then to reduce those that remain and lastly, where no other measures are possible, to put forward remediation measures. Where required, specialist consultants identify mitigation measures. In order to ameliorate significant adverse effects, these measures are integrated into the overall design strategy. In developing the proposal, the technical design remains flexible with regards to location of buildings and plant. This allows the engineering design to respond to the findings of consultation and EIA.

Alternatives

Alternatives to the proposals are considered in the design process. These include consideration of different sites (the Site Selection exercise, Appendix 3 of the ES), building design (discussed in the separate Design Statement) and alternative technology (discussed in Chapter 11 of the ES). Where the alternatives are significant, the advantages and disadvantages are investigated as part of the assessment process.

2.3 Integrated Pollution and Prevention and Control

Whilst positive determination of the Planning Application will enable construction of the Facility to proceed, before the plant can be operated it will require a Permit under the Integrated Pollution and Prevention and Control (IPPC) Regulations. IPPC is administered by the Scottish Environment Protection Agency (SEPA). The Permit to operate will be issued by SEPA and a Permit application (revision) will be submitted soon after submission of this planning application, thereby allowing issues arising to be considered in parallel.

2.4 This Document This Support Statement provides background information about the proposal. The remainder of this document falls into the following sections:

� The Proposal Details (Section 3); � How do the proposals relate to the ELSB’s Waste Strategy? (Section 4); � The results of the Environmental Impact Assessment (Section 5); � Policy Analysis and Compliance (Section 6); and � Conclusions (Section 7).

Copies of the Environmental Statement and supporting information are available on request for: � £120 Full Paper Copy; and � £20 CD Copy. Copies of the Non-Technical Summary are available F.O.C. All requests for copy documentation should be made to:



19

Viridor Waste Management Limited c/o RPS Planning and Development Ocean Point One 4th Floor 94 Ocean Drive Edinburgh EH6 6JH

Tel (0131) 555 5011 Fax (0131) 555 4911



20

3. Proposal Details The following Chapter is divided into 2 Sections. The first provides detail on the key elements of the proposed Facility and the second provides detail on the more process related aspects.

The Component Parts of the Development

3.1 The Facility The main elements of the proposal and the layout of the Facility are illustrated in Figure SS4, and the site layout plan in Figure SS5. The Facility will include the following: � waste reception hall and storage bunker; � waste handling and feed hoppers; � moving grate furnaces; � bottom ash handling system including electromagnetic separator to separate ferrous metals for recycling; � boilers, steam turbines, air cooled condensers; � provision of steam off-takes on the turbines for heat export – subject to a suitable heat customer being identified; � flue gas treatment system; � control room; � stack; � an administration, visitor and educational facility; � an amenities block; � gatehouse with two weighbridges and associated infrastructure; � internal road system and staff and visitor parking; � fuelling and vehicle washing facilities; and � site landscaping and lighting.

3.2 Buildings The Facility will comprise a single main building of five components, the reception hall, refuse bunker hall, flue gas cleaning building, boiler hall and stack. There will be a separate administration, visitor and educational building. Elevations of the buildings are shown on Figure SS6 and SS7. The maximum building height will be circa 47m, although the stack will be 80m high. The waste reception hall will be circa 26m in height, the refuse bunker hall will be circa 41m in height, the flue gas cleaning building will be circa 25m in height and the aerocondensor will be circa 32m in height. The primary axis of the EfW buildings will run approximately south-north, as illustrated in the building plan of the Facility shown in Figure SS4. The administration, visitor and educational building will be placed on the southern side of the main operational buildings. The main buildings are positioned within the northern part of the site, the southern areas being occupied by access roads and services areas, weighbridges, the gatehouse and staff and visitors parking areas.

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21

3.3 Design and Materials The design process for the buildings reflects the technical requirements of the process together with the external appearance of the Facility. The relationship of the Facility to the neighbouring Lafarge Cement Works has also been carefully considered within the design process, and has influenced the site layout, building orientation, and building massing. Scale, form and materials have been considered as part of the architectural design. The size of the proposed Facility reflects the scale of the existing industrial structures in the area, thereby avoiding any awkward comparisons of scale. The Facility has been configured to provide a functional form, access and layout. The arrangement of the basic components (reception hall, residue bunker, boiler house, stack, aerocondensor and turbine hall) brings an integrity to the overall design. The Facility is designed to sit against the exposed face of the old quarry workings, forming a series of staggered contrasting elements. The curved roof design reflects the slopes in the surrounding landscape.

Materials to be used for the Facility will include pre-cast concrete, horizontally laid Corus colour coated profiled cladding system, of microrib and trapezoidal profile. The canopy of the building will incorporate pressed metal eaves and profiled metal roof and soffit panels. Other materials will include aerocondensor pipework, an extruded aluminium architectural louvre system and aluminium framed double glazing windows. Final colours to be agreed with the Planning Authority.

3.4 Access Access to the site is gained from an improved new junction on the A1, and directly via the existing landfill access road. Railway sidings located outwith the site application boundary to the east, provide an additional means of access for transporting waste. These rail sidings are currently utilised by Viridor for transportation of waste into the landfill site and it is intended that the use of rail would be maximised with potentially up to 180,000 tonnes arriving by rail. Access to the site is provided from the south-west along a landscaped access route. The landscaping extends around the perimeter of the site. The access route extends north-east into the site. A gatehouse and two weighbridges incorporating controlled barrier access are present on the entrance and exit routes. The access route leads to a staff/visitor parking area and coach parking area in the west of the site. The staff/visitor parking area incorporates five disabled parking bays, together with cycle and motorcycle storage. The access route also leads into a HGV parking area and quarantine bay in the south eastern part of the site. A wheel wash is positioned off to the side of the exit route. An emergency vehicle access track is located along the north western boundary of the site.

3.5 Parking and Pedestrian Access Parking for 32 cars including 5 disabled parking bays will be provided on the site adjacent to the administration, visitor and education building at the location shown on Figure SS5. This parking will be for the use of the Facility staff and visitors. Parking



22

spaces are also provided for coaches. The proposed site layout also allows for pedestrian and emergency vehicle access.

3.6 Gatehouse and Weighbridges A single story rectangular shaped weighbridge/site control building will be located on the site access road in the south-western part of the site as shown in Figure SS5. All vehicles carrying waste, residues or process materials will be required to weigh in and out of the Facility.

3.7 Vehicle Wheel Wash A vehicle wheel wash will be located on the eastern side of the access road to ensure all vehicles leaving the site pass via this system.

3.8 Flood Protection A flood risk assessment has been undertaken for the proposals in accordance with principles of Scottish Planning Policy 7: Planning and Flooding (SPP 7), and Planning Advice Notes 61 (Planning and Sustainable Urban Drainage Systems) and 69 (Planning and Building Standards Advice on Flooding). The surface water runoff during the operational phase will be controlled and managed through a surface water management strategy. Key to this strategy will be the capture and control of the surface water generated within the development through the use of positive drainage and intercept swales with discharge to a wet/dry attenuation basin. The system will be designed to manage events up to a 1 in 100 year event including allowance for climate change, with the volumes of water discharged from the development reduced, thus lowering the flood risk offsite. The ‘clean’ uncontaminated roof water will be discharged untreated to the surface water management system and thereafter discharged to suitable attenuation pond(s). The surface water from potentially contaminated areas (e.g. access roads and parking areas) will be discharged to the attenuation basin via oil interceptors and/or silt traps. Figure SS8 illustrates the outline surface water drainage strategy. The foul waters will be discharged through a sewer system to be constructed as part of the development to the public system in the A1. The Facility is not expected to discharge operational waters on a regular basis as it will be operated using grey water (recycled), which will reduce the demand placed upon the public water supply network.

3.9 Landscape Planting At present the site contains very little vegetation and is not landscaped. As such it is of little merit and is not sufficiently remarkable as to warrant conservation in its present form. The development therefore affords the opportunity for landscape design appropriate to the setting, utilising selective planting and the contouring of the land necessary for flood protection or landscape requirements. The Ecological assessment suggested that a suitable Habitat Management Plan (HMP) will enhance the biodiversity interest, in the form of both flora and fauna, within the survey area and footprint of the Facility. This has been taken into consideration in preparation of the site plan for the Facility.



23

3.10 External Lighting The Facility will have 24 hour lighting for safety reasons. The landscape and visual impact assessment of this has been considered with Chapter 10 of the ES. 3.11 Operating Hours

The Facility will operate on a 24-Hour basis throughout the year. Waste will normally be received between 07:00 and 17:30 hours Monday to Friday, and 08:00 and 15:00 hours on Saturdays. With the approval of the Authority, occasional deliveries and/or collections may take place outside these hours to avoid peak hour traffic flows and to prevent waste being stored within Refuse Collection Vehicles (RCVs) overnight, at weekends or during holiday periods.

3.12 Plant Maintenance and Shutdown

A yearly shutdown period of 2 weeks for maintenance is anticipated. The design of each of the lines therefore ensures an availability of 7,800 hours per annum. During the shutdown periods waste deliveries would be directed to alternative disposal facilities, which in this instance is likely to be the adjacent landfill.

The bunker capacity is sized to retain four days volume of waste in the event of plant breakdown, with the neighbouring landfill providing additional emergency capacity should the need arise.

The Facility is carefully designed with sufficient backup equipment to ensure a high level of operational availability. All equipment within the Facility will be subject to a Planned and Preventative Maintenance Programme to minimise the occurrence of unplanned shutdowns.

3.13 Staff

The Facility will employ approximately 47 full time staff comprising operating shift staff, maintenance employees, weighbridge operators, clerical and administrative staff and plant management staff. During construction it is envisaged that 100-150 workers will be employed.

TABLE 3.1– STAFFING ANALYSIS (taken from Feasibility Report, May 2006) Employee Position No. of Employees Plant Manager 1 Operations Manager 1 Maintenance Manager 1 OSS & Maintenance Planning 1 Laboratory & Environmental Compliance 1 Electrical/ICA Supervisor 1 Mechanical Supervisor 1 Technicians 10 Tipping Hall Control 1 Labourers 4 Shift Manager 5 Shift Process Controller 5 Shift Plant Operator 10 Shift Crane Driver 5 Total 47



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It is envisaged that Keppel Seghers (the technology provider) will be contracted to operate the Facility initially alongside Viridor who will then take over full control within a two year period once the plant is fully commissioned.

3.14 Control of Amenity Impacts Odour

Air within the waste reception/tipping/bunker hall has the potential to be odorous because of the presence of raw waste. Air emissions from the waste reception/tipping/bunker hall will be avoided through the maintenance of negative air pressure such that dust and odours are drawn into the furnace along with combustion air. The odour carrying gases will be destroyed by combustion, virtually eliminating the possibility of odour detection outside the Facility.

Vermin Control

The main area where vermin could be potentially attracted to is the waste reception/ tipping/ bunker hall. This area will be subject to high standards of ‘housekeeping’ and in addition, standard pest control methods will be implemented.

3.15 Construction General

Due to the Facility being in the early stages of development it is not possible to provide further detail at this stage in respect of certain construction activities as detailed below, therefore only an outline construction programme has been provided.

� Hours of Operation. � Site Investigation. � Site Enabling Works. � Site Excavation. � Utilities & Infrastructure. � Raw Materials Supply. � Installation and Erection of Plant & Equipment. � Construction Wastes & waste Management. � Storage of Construction Plant Oil/Fuels/Materials. � Discharges and Emissions. � Testing & Commissioning. � Landscaping.

Construction Programme

The construction programme, including commissioning, is currently estimated at 36 months. The estimated programme for the main site activities during the construction phase is as follows (note, elements overlap): � Civils Works – 18.5 Months; � Equipment Manufacture and Purchase – 16 Months; � Equipment Installation – 12 Months; and � Commissioning and Start Up – 8 Months.



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3.16 Decommissioning and Restoration

The design life of the Facility is 25 years at the end of which time it will be decommissioned. This will be undertaken in accordance with the relevant legislation prevailing at the time. The PPC Permit will require a decommissioning plan to be submitted. The Facility will be designed and constructed in a modular way, using sustainable construction materials which have a retained recoverable value post decommissioning. During the procurement process, Keppel Seghers will be required to consider decommissioning within the design. This will form part of the contractual agreements. A site restoration plan will also be a requirement of any PPC Permit issued by SEPA.

The Facility Process 3.17 General The process of the Facility is described below and is illustrated in the simplistic process flow diagram in Figure SS9. The key components of the technology are also shown in Figure SS4.

Figure SS9 Simplistic Process Flow Diagram As stated above, the Facility will be equipped with Keppel Seghers technology, which has been used in numerous installations for the thermal treatment of municipal, industrial, and biomass fuel. The installation will consist of two lines, each comprising a hydraulically driven feeding grate and air cooled combustion grate, complete with air supply facility, auxiliary burners, primary air preheating and an integrated horizontal boiler with Keppel Seghers’ PRISM (an innovative secondary air injection system designed to improve the combustion and post-combustion process). The plant will employ a combination of primary and secondary abatement plant to



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ensure that emissions to air meet the required emission limit values. The main abatement plant will comprise: � combustion control; � fabric bag filters; � activated carbon injection; � dry lime injection; and � Selective Non Catalytic Reduction (SNCR).

3.18 Waste Reception, Storage and Handling The Facility process will be enclosed within an entirely new building. Waste will be delivered to the site by covered vehicles and transferred from the rail terminal in boxes, thereby ensuring that waste does not escape. The vehicles having entered the reception hall will tip their contents into the refuse bunker. Operators will use grab cranes positioned over the bunker to blend the waste so that the feed to the furnace is relatively uniform at a controlled rate. In the event of breakdown, the bunker capacity is sized to retain four days volume of waste, with the neighbouring landfill providing additional emergency capacity should the need arise. It is expected that a small volume of liquid run-off will result from the normal operation of the tipping hall and bunker. This liquid will be contained and routed to the wastewater recycling system.

3.19 Furnace Overview and Operation The overhead crane feeds the waste to the furnace by dropping it into the charging hopper. The hopper guides the waste into the furnace through the water-cooled feeding chute. The feeding chute ensures consistent feeding of the waste to the grate where it is burnt at high temperatures. The grate, combines vertical and horizontal movement to mix the waste and is the heart of the combustion system. It functions as support for the horizontal combustion processes, including drying, gasification, pyrolysis, oxidation, burnout and cooling. An adequate air supply to ensure optimum combustion of the wastes is maintained through injection of air into the grate. The furnace will be designed to ensure a minimum flue gas temperature of 850oC for two seconds to ensure the destruction of dioxins, furans, Poly Aromatic Hydrocarbons (PAH’s) and other volatile matter. The staged combustion process is designed to ensure a complete combustion/oxidation of the flue gases in the complete absence of hot spots. Computational Fluid Dynamics modelling is used to optimise the furnace boiler system. This results in effective primary Nitrogen Oxides (NOx) reduction (and Carbon Monoxide (CO) reduction) in the flue gas combustion chamber. The Selective Non Catalytic Reduction (SNCR) system is installed to reduce the remaining NOx down to the required level. The multi-level injection system is based on the injection of ammonia. The Keppel Seghers PRISM, mentioned previously, ensures a uniform temperature and velocity profile in the furnace, optimising conditions for the injection of the ammonia and guaranteeing optimal operation of the SNCR. The SNCR process works on the basis that the nitrogen oxide is chemically decomposed to Nitrogen and water by the injection of the ammonia into the combustion chamber.



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Steam Boiler In the energy recovery process, the steam boiler transfers heat present in the flue gas to the water/steam circuit. When leaving the furnace the hot flue gas flows through the empty passages of the boiler, releasing heat so that the temperature at the inlet of the convection section (final superheater) is less than 650°C. In the convection section, the flue gas further releases its heat such that its temperature at the outlet of the boiler is 200°C or less. Meanwhile, the water inside the boiler pipes is converted into superheated steam. The high pressure steam is directed into a turbine for electricity production and/or a condenser for use in low grade heating of local homes and businesses.

The steam boiler is a critical part of the Facility. The boiler design proposed for the Facility is well known, with a proven history in operation on many EfW plants. The proposed boiler design is characterised by: � high availability; � high duty cycles, without operation for manual cleaning; � low operation costs for heating surface cleaning (no sootblowers); � high accessibility to the heating surface; and � easy maintenance. The proposed boiler is of the water tube type, with natural circulation. The boiler consists of a vertical, three-pass radiant section with membrane walls and a convection section with one horizontal flue gas passage with vertically placed boiler bank tubes. The enclosure walls of the three vertical passes are fabricated as a gas tight membrane wall construction. The first three boiler passes are designed as radiant passes. The fourth horizontal pass includes the superheater, the evaporator and the economiser bundles. To prevent the flue gas temperature from dropping below the minimum temperature allowed for the flue gas cleaning plant, a feed water preheating system is installed in the drum to increase the feed water temperature at the economiser inlet at reduced boiler loads. Flue Gas Treatment General Concept As suggested earlier, a combination of primary and secondary abatement plant will be employed to ensure that emissions to air meet the required emission limit values. Set out below is a brief overview of the key techniques proposed to be employed: Control of visible particulate plumes: the releases from the stack will predominately be water vapour and carbon dioxide. Water vapour within the exhaust gases can give rise to a visible plume. As part of the Air Quality Assessment and modelling work (see Appendix 5 of the ES), consideration was given to plume visibility which concluded that the impact of a visible plume would be low. No plume suppression is therefore proposed. Particulate Matter: Fabric filters will be used for the abatement of particulates. The bag system proposed will include multiple compartments which permit isolation of a compartment in the event of bag failure, also allowing for maintenance work to be undertaken without the potential for breaching emission limits.



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A pulsed air cleaning system will be included to remove Air Pollution Control (APC) residues collected within the bag filters. The fly ash will be taken from the bag house hoppers by pneumatic conveying units, which will transfer the ash to a silo. Fly ash will also be collected from under the boiler passes and conveyed pneumatically to the silo. Oxides of Nitrogen: NOx formation can be controlled using both primary measures that minimise its formation in the first instance and secondary measures which reduce further the generation of NOx. The plant design will minimise formation of the NOx by: the optimisation of the primary and secondary air feeds; design of the plant to ensure it is air tight as possible; and control of the combustion stage to ensure that optimum combustion conditions are maintained. Further abatement of NOx will be provided using SNCR with ammonia used as a reagent injected into the first empty pass. The Ammonia reduces the levels of NOx in the exhaust gases producing nitrogen and water. Acid Gases and Halogens: again, primary measures will be put in place to as far as possible minimise the formation of acid gases by removal of problematic wastes and by ensuring loads are well mixed before entering the furnace. Control of the acid gases formed in the furnace will be provided by means of a dry abatement system using hydrated lime. Dry injection of hydrated lime will occur at the inlet of the bag filter to neutralise acid gaseous compounds (Hydrogen Chloride (HCl), Sulphur Dioxide (SOx), Hydrogen Fluoride (HF)). Carbon Monoxide (CO) and Volatile Organic Compounds (VOCs): high levels of CO and VOCs are indicative of poor combustion. The furnace will be designed and operated to ensure that effective combustion is achieved; these measures will ensure that CO and VOC levels are controlled below required limits without the need for further abatement. Dioxins and Furans: the primary technique for limiting dioxins and furans formation is through the control of the temperature in the furnace and through the avoidance of combustion gas cooling, thereby limiting the potential for formation. In addition to furnace and boiler control, activated carbon together with lime will be used, injected into the gas stream at the inlet of the bag filter. The activated carbon also reduces the emission of mercury. Metals: with the exception of mercury, which is present as a vapour, heavy metals will be present as particulates and will be removed in the bag filters provided for particulate control. Clean flue gases exiting the bag filter having been subject to the various abatement techniques are discharged through the Induced Draft (ID) fan and the stack. The flue gas treatment system will be designed to comply with the defined standards of the EC Directive on Waste Incineration (2000/75/EC), which will be enforced by the Scottish Environment Protection Agency (SEPA), through conditions attached to the Facility’s PPC Permit. The final design of the abatement plant will be agreed with SEPA as part of the PPC Permitting process.



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It should be noted that in line with best practice, Viridor is submitting an application for the PPC Permit to be considered in parallel with this application.

3.20 Stack The two lines will each have a single dedicated flue which will form one conjoined stack with a proposed height of 80m, located to the rear of the buildings. The height has been determined through extensive computer dispersion modelling of emissions with the height selected for optimum dispersion. The stack has been designed with consideration given to site specific meteorological conditions. The outer surfaces of the stack will be clad with neutral colours to further minimise visual impact effects. 3.21 Ash and Residue Handling

It is envisaged the Facility will generate the following tonnages of ash (based on 2 operational lines): � bottom ash: 91,333 tonnes per annum (assuming inert content of 25% in

incoming waste); � boiler ash: 3633 tonnes per annum; and � flue gas cleaning residues: 11,093 tonnes per annum. The figures above are those supplied by (Keppel Seghers). All ash generated by the Facility will be contained within suitably engineered silos.

This Section provides an overview of the outlets proposed by Viridor to manage the arisings of ash. Proposed Ash Handling Methods

Metal Recovery Prior to storage and subsequent removal of the bottom ash, ferrous metals will be removed by means of a magnetic separator. They will then be transported to a re-processor for recycling/recovery. It is estimated that the Facility will produce circa 9,000 tonnes per annum of ferrous metals (which equates to 3% of the total input by weight). DEFRA is currently considering whether these materials should contribute towards local authority recycling rates. Bottom Ash Is it proposed that a percentage of the bottom ash produced will be used for landfill engineering at the Oxwellmains landfill (estimated at 500 tonnes per week), which equates to approximately 25,000 tonnes per annum of the 91,333 tonnes produced. The remaining 66,333 tonnes will be exported from the site for recycling and use within the secondary aggregates market. Viridor is currently in discussion with Ballast Phoenix with regard to this re-use route. Consideration of the road traffic generated by the export of the ash has been considered within the Transport Assessment contained within Appendix 10 of the ES.



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Boiler & Flue Gas Treatment Residues Both the boiler and flue gas treatment residues generated by the Facility are considered hazardous by virtue of their alkalinity. It is proposed that the total 14,726 tonnes be removed from site by road to a suitably licensed facility or alternatively, there may be uses for this material in the Chemical industry and this will also be considered. Viridor may apply for a PPC Permit for a hazardous cell within the Oxwellmains Landfill to receive this ash.

3.22 Energy Recovery

In order to demonstrate that Energy from Waste represents the Best Practicable Environmental Option for dealing with the waste streams proposed, it is an increasing expectation that the design of the Facility addresses the use of the surplus heat as well as maximising electricity generation. This production of heat and power is often referred to a Combined Heat and Power (CHP). The Facility will generate circa 22.7MW of electricity (net). Based on electricity production alone this represents an efficiency level of 26%. The 22.7MW net electrical output assumes a gross electricity output of 25.6MW, with a parasitic load of 2.9MW (which is the load the Facility itself will use). If a suitable outlet is identified for the heat produced by the Facility this would significantly improve the overall efficiency. For example, capturing heat at efficiency levels of 60% would reduce electrical efficiency to 15%, but produce an overall efficiency of 75%. During the course of preparing the ES, Viridor has consulted widely with regard to the development of a CHP scheme. Consultees have included SEPA as well as local authorities, landowners and local industries and businesses. The consultation process and the details of discussions to date are contained within a Heat Plan provided within Appendix 4 of the ES. In considering the potential for maximising heat and power recovery from the Facility, Viridor recognises that SEPA’s thermal treatment guidelines (SEPA Guidelines for Thermal Treatment of Municipal Waste, August 2004) are a material consideration. In order to maximise the potential for use of the heat output from the Facility, the initial design will incorporate steam off-takes on the turbines.



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4. How do the Proposals relate to the Lothian & Borders Area Waste Plan?

4.1 Introduction

This Planning Application by Viridor will provide a solution to the issue of residual waste treatment within the target authority areas by providing the infrastructure to divert residual waste from landfill, whilst making an additional contribution to recycling and composting targets.

The Joint Council’s Strategy set out in the Lothian and Borders Area Waste Plan (LBAWP) (2003) and recently adopted BPEO amendments represent their response to the National Waste Strategy (1999), which in turn reflects the obligations on the UK Government from European Directives, particularly in respect of the Landfill Directive 99/31/EC.

The main objective of the Strategy is to encourage reduction in the amount of residual waste produced, and then to recycle, compost and recover as much of the waste resource as practically possible, whilst reducing the volume of waste sent to landfill. The Strategy therefore aims to move waste management up the “Waste Hierarchy” to ensure provision of facilities local to sources of production (therefore complying with the “Proximity Principle”) and to assist in self sufficiency in the management of municipal waste.

The principles contained in Scottish Planning Policy 10, Planning for Waste Management (SPP10) have also guided the development of the Lothian and Borders Waste Management Strategy and choice, size and location of all of the recycling and recovery facilities. SPP10 sets out four key objectives to be taken into account in identifying the most suitable combination of facilities and waste management options for an area. Within the key heading of sustainable waste management, it highlights:

� The Waste Hierarchy; � The Polluter pays Principle; � The Best Practicable Environmental Option; and � The Proximity Principle.

The LBAWP and Strategy adhere to these principles. Currently each of the Councils’

principal recycling programmes comprise of various elements of recyclate collection, composting and residual waste collection. They also have numerous recycling centres and bring banks across the whole ELSB region, in addition to individual commercial collections. The residual waste left over, after these programmes have been implemented, is currently landfilled.

4.2 Waste Arisings

An independent need assessment was undertaken, which investigated the availability of the proposed waste streams for the Facility. The full assessment, contained within Chapter 11 of the ES, provides details on the tonnages envisaged in the future. The following two figures summarise the key points in respect of the available waste tonnages.



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Figure SS10 – Predicted Residual Waste Arisings for MSW for 1.8% Growth Rate, Stabilising in 2010. Figure SS11 – Predicted Waste Arisings for C&I Wastes

Waste arisings were modelled to determine the amount of residual waste left after achieving recycling and composting targets, and therefore the amount of waste that would need further treatment and disposal. The assessment demonstrated that even when the area achieves the challenging waste minimisation, recycling and composting targets, there is still a clear need for additional residual waste treatment capacity. In consideration of the residual MSW tonnages the assessment has taken into account achievement of the zero waste aspirational recycling rates, which are currently subject to consultation.

4.3 Waste Management Strategy The need for the waste management strategy and associated residual waste treatment infrastructure in the ELSB area is driven principally by:

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� the requirement to meet targets for diverting Municipal Solid Waste (MSW) from landfill;

� the National Waste Plan: Scotland (NWP); � the Waste Emissions and Trading (WET) Act 2003; and � the Landfill Directive (1999/31/EC). The BPEO conclusions from the LBAWP highlighted that the long-term biodegradable waste diversion requirements of the Landfill Directive would be more challenging to achieve through recycling and composting alone, and other treatment technologies would need to be considered. The scale of the ‘other’ treatment technologies would be determined by the levels of recycling and recovery achieved. Despite improvements in recycling rates etc it is clear that the Councils must radically reduce their reliance on landfill as a significant disposal option within its current waste management strategy and consequently new residual waste treatment facilities are needed urgently. The proposed Facility meets the requirements of the BPEO (see below) within the recently revised LBAWP. LBAWP and BPEO The proposed Facility complies with the requirements of the recently adopted LBAWP BPEO in that it will provide infrastructure for residual waste treatment, which is a key element of the BPEO. A number of the specific commitments set out in the LBAWP in consideration of residual waste treatment proposals will be met by the proposed Facility, namely: � The Waste Strategy Area Group ruled out sending unsegregated municipal

waste directly for thermal treatment, historically this has been termed mass burn incineration. This decision is supported by the SEPA Guidelines for Thermal Treatment of Municipal Waste.

The proposed Facility is intended only for residual waste treatment and therefore complies with this commitment. � Any Thermal Treatment Options should take SEPA’s Thermal Treatment

Guidelines into account. The proposed development submission has taken account of SEPA’s Thermal Treatment Guidelines. The development is intended to play an integrated role within the target authorities waste management strategies; with the CHP element of the proposals it is intended to ensure that maximum efficiency is achieved; and the development has been sized and located accordingly to meet the requirements of the local authority areas. � The capacity of residual waste treatment for municipal waste in Lothians and

Borders will not interfere with recycling and composting (pre-sorted) aspirations.

� Residual waste treatment proposals should seek to further optimise recycling

and/or composting performance targets where practicable with full consideration of market availability and compliance with environmental regulation (see residual waste recycling/composting performance targets)



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The proposed Facility is intended to complement the recycling and composting aspirations of the authorities considered. Viridor has significant prior experience of liaising with authorities to ensure recycling and composting targets are met and integrated with residual waste treatment options. Viridor believes that efficient and highly utilised kerbside and bring schemes and household waste recycling centres will be fundamental in delivering Scotlands' recycling and composting targets. Furthermore, a clean source of recycling and composting materials will be necessary to promote a market for recycled materials. Appropriate education and monitoring initiatives will be fundamental in this process. For example, in Somerset Viridor achieves significant recycling levels at the HWRCs (>70%), and processes food waste which is separately collected at the kerbside. With kerbside schemes collecting mixed recyclate, the recycling level is approaching 55%. This also reflects accepted practice in Europe and beyond. Viridor proposes to assist the local authorities in on-going waste compositional analysis (which is a requirement of the Facility in monitoring the calorific value of the input streams). By using this ‘monitoring facility’ Viridor proposes to liaise with the authorities concerned so that areas of the recycling and composting initiatives which require targeting in the form of further education or otherwise can be addressed on an on-going basis. The proposed Facility will also contribute further to the recycling targets for the region by recycling the bottom ash within the secondary aggregates market and by extraction and recycling of metals. The evidence from Europe suggests that high levels of recycling and composting of municipal waste can be achieved when combined with EfW facilities processing residual waste. Kerbside schemes, bring banks, community recycling centres and EfW facilities can be used as complementary measures to divert waste from landfill and recover economic value from the waste. The output from these measures being valuable recyclate and energy. For example, the price of low grade recycled paper has increased from £4.3/tonne in 1998 to £20-£30/tonne in 2005. This market increase has provided an incentive for waste management companies to collect and recycle paper. Figure SS12 below furthermore supports the fact that high recycling and composting targets can be achieved alongside EfW processing facilities. The figure shows that countries with the lowest level of landfilling of municipal waste (less than 25%) also have a high rate of recycling, composting and EfW processing (e.g. Switzerland Netherlands, Sweden and Denmark). Countries with a high rate of landfill (over 50%), have limited recycling, composting and EfW processing (e.g. Spain, Italy, Portugal and Finland).



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Figure SS12 European Waste Management Comparison Table

Source: Europe’s Environment – The Fourth Assessment (2005) � Consideration should be given to locating any EfW facilities in proximity to

heat users as there is potential for EfW to produce heat which can be used for industrial, commercial or residential use.

The proposed Facility is not directly located next to potential users, although Viridor have produced a Heat Plan within Appendix 4 of the ES which provides details on proposed users within the vicinity and a plan to ensure suitable outlets for the heat are pursued. � Consideration should be given to potential synergies with Commercial and

Industrial wastes in the area. The proposed Facility has been designed to accept residual Commercial and Industrial wastes. � Consideration should be given to the proximity principle, transportation

distances and the carbon footprint. The proposed Facility location has been chosen with consideration given to the proximity principle in that it is to be located centrally within one of the target authority areas, and within close proximity to the other authorities. A Carbon Footprint assessment has been undertaken (contained within Appendix 13 of the ES) which has included consideration of transportation distances, the conclusion of which is that the EfW offers a positive benefit in respect of carbon footprint over other potential residual waste management scenarios. SEPA’s Thermal Treatment Guidelines (August 2004) This document provides four principle guidelines of which three are particularly applicable to the proposed development.



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Guideline 1

…In accordance with the National Waste Strategy: Scotland, where thermal treatment with energy recovery is appropriate, it must play an integrated role with other waste management methods. These methods could include waste prevention, reuse, biological treatment, recycling and landfill. Guideline 2 …Thermal treatment of appropriate segregated waste, with efficient energy recovery (for example, combined heat recovery and power generation), may be an appropriate method for management of waste. Guideline 4 …Where the development of a thermal treatment plant is consistent with the National Waste Plan, local authorities and/or others should work in partnership to ensure that the thermal treatment plant is appropriately sized and suitably located on a national basis. The proposed Facility is supported in the adopted LBAWP BPEO which considers thermal treatment as an appropriate treatment option for residual waste. In addition energy recovery forms an integral part of the proposals and the Facility has been specifically sized to meet the requirements of three of the authorities within the ELSB region.

4.4 Facility Benefits The benefits which the proposed Facility offers are summarised below: � the Facility offers a safe and sustainable alternative to landfill for residual

wastes from local homes and businesses that are leftover after recycling has been carried out and composting;

� circa 22.7MW of electricity will be supplied annually to the National Grid; � the proposed site is already located within an operational landfill, complete

with a dedicated rail siding. Using a rail link significantly reduces the need for traffic movements and is more sustainable;

� the proposed site has excellent access to the road network, namely the A1; � a large proportion of the residual waste from the target areas is already

coming to Oxwellmains Landfill (from Edinburgh and East Lothian);

� the Facility will enable National Targets on landfill diversion, to be met or even exceeded and therefore costly fines avoided;

� the Facility will offset the significant economic impact of landfill tax (£48 per

tonne in 2010), which would otherwise be passed onto Council tax payers; � the Facility will be situated on brownfield land resulting from past quarry

operations and the backdrop will be the Lafarge Cement Works and Torness Nuclear Power Station;



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� the proposed site is relatively remote and as a result only has a limited number of dwellings in close proximity;

� the Facility has the potential to supply heat and power to local homes and

businesses, which will improve resource efficiency and offset reliance on fossil fuels;

� the CHP aspect of the proposed development may act as a catalyst for future

economic growth elsewhere within the area;

� development of the Facility will provide employment for approximately 47 new permanent staff and additional contract/temporary staff;

� the local economy will benefit from additional employment and be sustained

by wages and salaries received and spent in the local economy by people directly employed on the operational site, and through the use of local services; and

� the proposed Facility meets the criteria of the LBAWP BPEO in respect of

providing a solution for the treatment of residual waste.



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5. The Results of the Environmental Impact Assessment

The main findings of the Environmental Impact Assessment are summarised below.

5.1 Air Quality & Human Health An assessment of the air quality effects associated with the proposed Facility was undertaken. The Facility is required to meet stringent standards included in the European Union Waste Incineration Directive. It has therefore been designed to minimise atmospheric emissions using Best Available Techniques and to render harmless any residual emissions by release through a stack of an appropriate height (80m). The potential impacts to sensitive community and ecological receptors have been assessed utilising two separate computer dispersion models in accordance with good practice. The impact of traffic on air quality associated with the Facility has also been assessed together with the impacts of odour and the visibility of the plume from the stack. The most significant pollutants emitted from the process, in the context of a comparison with relevant air quality criteria, are nitrogen dioxide (NO2) and sulphur dioxide (SO2). For all pollutants regulated under the Waste Incineration Directive, predicted contributions from the Facility are not significant relative to relevant air quality criteria. The development proposals do not, therefore, conflict with any national, regional or local policies in respect of air quality. Deposition of metal, dioxin and furan contributions from the Facility to identified areas where people might be affected, have been derived through dispersion modelling. A long-term human health impact assessment has been undertaken to determine the effect from exposure to potential contaminants accumulating in the soil following 50 years of deposition. The results of the assessment demonstrated that none of the chemicals exceeded the relevant limits. Therefore the identified levels of exposure are not considered to pose any significant health risk to the identified receptors. Cumulative modelling undertaken including emissions from the neighbouring Lafarge Cement Works determined that emissions are not significant relative to relevant air quality criteria. Modelling undertaken using local meteorological data to assess Haar conditions showed very close agreement between the modelling undertaken with local meteorological data and meteorological data from Edinburgh. The modelling indicates that pollutant concentrations are not significantly increased under Haar conditions. Contributions of air pollutant concentrations and deposition from the Facility to designated ecological sites have been calculated based on dispersion modelling results and compared against relevant critical levels and critical loads. Effects on the vegetation and ecosystems are not ecologically significant. Emissions from traffic accessing the site during both the construction and operational phase of the proposed project are predicted to have no significant additional impacts.



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Dispersion modelling has been undertaken to determine the frequency of visible plumes from the Facility. A plume will be visible beyond the site boundary for approximately two and a half percent of the total operating time. The results of the plume visibility modelling are not considered significant.

5.2 Natural Heritage and Archaeology A desk-based assessment was carried out for the proposed site which lies within an area rich in cropmark sites, with some of the most significant early prehistoric evidence discovered in Scotland in recent years recorded in the locality. Despite this, the site is itself archaeologically sterile, having been extensively quarried to supply the adjacent Lafarge Cement Works. The only cultural heritage issues relate to indirect impacts to sites in the vicinity of the development. These cannot be easily mitigated, and as such were simply identified and assessed. Chief in these are the scheduled ancient monuments along the ridge to the south of the quarry, in which the Facility will sit. It is not considered that the development will be of more than moderate significance to the cultural heritage, as the development is situated adjacent to the Lafarge Cement Works, and as such will form a contiguous extension of it, thus minimising visual impact to surrounding sites (indirect impacts).

5.3 Aviation An assessment was undertaken of potential aviation safety issues that may be impacted upon by the Facility. The airspace around aerodromes that is required to be kept clear for aircraft manoeuvres is well defined. The airspace required by the Ministry of Defence (MoD) for necessary training and practice in low flying and for air defence is also defined although this information is not as publicly available. Less obvious, but still important, is the airspace required by navigation aids such as radar and radio beacons (operating from aerodromes or what are termed “aeronautical technical sites”). Five key sites were identified in the assessment for consideration, these were: � East Fortune Aerodrome; � RAF Leuchars; � Edinburgh Aerodrome; � St Abbs Head; and � Torness. The assessment determined that the proposed development would have no effect on these sites and/or navigation aids.

5.4 Ecology An assessment was carried out on the possible effects of the Facility on all Valued Ecological Receptors (VERs) within an area larger than the application boundary and all designated sites of importance for natural heritage within a 15km radius of the application boundary. Where potential impacts on VERs were identified, proposed mitigation measures are expected to reduce any adverse impact to a level that is negligible or slight. The assessment undertaken included fieldwork which was carried out in 2006 and 2007 which encompassed the following:



40

� an Extended Phase I Habitat Survey, which included surveying for any signs of European Protected Species and UK protected mammals;

� breeding bird surveys; � winter bird surveys; and � great crested newt surveys. During the Phase I Habitat Survey, no legally protected, rare or scarce flora species or habitat types were recorded. There are no areas of ancient woodland within the survey area. No protected mammal species were breeding within the survey area. No great crested newts were found in any of the water bodies within the survey area during surveys undertaken in 2007. A suitable Habitat Management Plan (HMP) is proposed which will enhance the biodiversity interest, in the form of both flora and fauna, within the survey area and footprint of the Facility, enhancing the overall value for biodiversity.

5.5 Hydrology and Hydrogeology The nearest water receptors to the proposed development include the Dry Burn and tributaries, the Carboniferous Limestone aquifer, the Lafarge Cement Works, the Lafarge abstraction borehole and Blue Lake. The Carboniferous Limestone is considered to be a Highly Permeable Aquifer with soils of a High Leaching Potential. The Dry Burn is not gauged by SEPA and is known to be dry in summer periods. SEPA floodmapping indicates areas of flooding local to the Dry Burn however the extent of flooding does not affect the existing site and proposed development. Groundwater flooding is considered unlikely due to the watertable being 15 to 20 m below the ground level on site. A Flood Risk Assessment (FRA) was undertaken for the site and has been completed to meet the guidance of SPP7. The FRA considered the watercourses, surface water flows and flooding issues for the existing site and proposed development. In addition the water qualities of the adjacent watercourses and local groundwater were considered along with the potential water quality impacts of the development. Measures have been incorporated within the design of the development to ensure negligible to low impacts on the flood risk and water quality impacts. The development has been assessed for the impacts of fluvial flooding from the Dry Burn for design return period events of up to 100 years now or in the future taking account of climate change. The assessment demonstrates that the development is at negligible risk of flooding in such an event as a result of intervening topography preventing flow due to the development. No formal drainage system is located within the existing site with water flowing to the existing minor drain on the northern side of the site. This minor drain discharges to the Lafarge Cement Works Blue Lake. The proposed development would increase the potential runoff to this minor drain, the Lake and ultimately the Dry Burn. Therefore a surface water drainage strategy has been prepared for the development to mitigate this potential impact and ensure controlled discharge via the existing minor drain. This will be achieved using formal drainage (i.e. pipes), grassed intercept swales and ditches to intercept surface runoff from the development and to



41

convey the flows to attenuation storage ponds. The incorporation of the surface water drainage strategy would result in a negligible impact on surface water flooding and fluvial flooding in the minor ditch, Lafarge Cement Works and Blue Lake and Dry Burn. The low average annual rainfall and low average annual infiltration values for Dunbar suggest that the redevelopment of the site is likely to have a negligible impact on the local recharge of the aquifer. The existing surface water quality within the Lafarge Cement Works Lake, Blue Lake and Dry Burn is considered to be fair. The proposed development would use separate land drainage systems for surface water and foul water/trade waste/process water. The surface water conveyance system would incorporate interceptors for road and yard areas while the attenuation storage ponds would incorporate reed beds or similar to help improve water quality prior to discharge. The existing groundwater quality beneath the site is considered to be good with some evidence of increased mineralisation down gradient. This is considered to be due to natural processes. Saline intrusion may also occur on the down gradient side of the site. There is some evidence of an up gradient off site source of minor contamination. The drainage systems within the site would incorporate a mechanism (i.e. stop valve) to prevent discharge to the minor drain in the event of an emergency spillage incident. In addition the emergency spill containment and management strategy for the development would reduce the risk to water quality in such an event. The water quality treatment systems and emergency shutdown provisions provided for in the development should result in a negligible impact on the existing water quality. The potential for the redevelopment and operation of the site to cause significant contamination of the aquifer is considered to be negligible to low.

5.6 Land Contamination and Ground Conditions The site is located upon an area that has historically been used for quarrying and which was subsequently backfilled with quarry waste material. It is therefore considered that the development is located on Brownfield land which could have historical contamination. To prove the underlying ground conditions at the site an Intrusive Site Investigation was undertaken by Waterside Environmental, supervised by RPS. This included the completion of a number of boreholes, soil gas and groundwater monitoring installations. During the investigation analytical testing and site monitoring was carried out to provide data on the geology, the chemical condition of the site soils and the level of soil gases present underlying the site. The results of the site investigation revealed that there is a limited impact to site soils. None of the results exceeded the soil guideline values (SGV) or generic assessment criteria (GAC) for a Commercial and Industrial land use scenario. Where any impacts are evident these are typically associated with the made ground and are present at relatively minor levels. These are not considered likely to present any significant implications for future land use at the Facility site. The assessment identified a number of potential impacts that may be associated with the construction and operation of the Facility. The impacts identified can be mitigated to levels considered to be of negligible significance through the



42

implementation of construction management practices or readily practiced engineering design principles.

5.7 Landscape and Visual A desk study was carried out to identify the baseline landscape and visual characteristics of the proposed site and wider study area, extending to 20 km where appropriate. In addition, field surveys were undertaken to assess the surrounding landscape, undertake viewpoint photography and inform the assessment process. Identified landscape and visual effects were used to inform the design process to avoid, reduce or offset these effects. Mitigation of the Facility was considered throughout the process, through site selection, consultation and design development. The site is a former limestone quarry that has been infilled with quarry waste. The landscape of the site is therefore considered to be a regenerating Brownfield site and is consequently considered to be of low sensitivity. Four landscape character areas were identified, each comprising several landscape character units. Together, these were considered to define the site and its surroundings. The proposed Facility is to be sited in a large-scale landscape, where the Dunbar Plain stretches along the Dunbar coastline and where the North Sea extends outwards to the east. There are relatively few residential receptors in the immediate area of the site. There are existing large industrial facilities which inform and influence the existing landscape character. These include the existing Lafarge Cement Works at Oxwellmains and the Torness Power Station at Thorntonloch. The existing quarrying and landfill operations associated with the cement works neighbouring the site also inform the character of the landscape. There are also other major infrastructure elements, including major pylon lines, roads and railways. The sensitivity of the local landscape resource, and the local visual amenity, is consequently generally considered to be low to medium to further industrial development. There are no national (National Scenic Areas) or regional (Regional Scenic Areas) landscape designations either along the coastline or within the 20km study area. The Dunbar Coastline, Berwickshire Coast, the Lammermuir Hills and Garleton Hills and North Berwick Law all have areas that are locally designated landscapes. These are less settled if at all, and are important in providing recreation and amenity. Although they are generally more sensitive, the increasing distance from the Facility site, intervening topography and vegetation means that the magnitude of change from the Facility is no higher than low. Therefore, the significance of effects will be moderate or minor. Designed Landscapes within the study area were also considered within the scope of this assessment. Although these had fairly high sensitivity, existing industrial elements in the view, together with intervening vegetation and topography means that the magnitude of effect is generally low. The significance of effect was therefore moderate or minor. In local views, the road embankment south of the site will have an effective role, all year round, of screening many of the smaller ancillary elements of the Facility, and the majority of operations. The upper part of the building and the stack and plume will be visible, but will tend to be viewed with the sky as a backdrop. In more distant



43

views, the large scale of the receiving landscape assists in preventing the Facility from appearing out of scale, and consequently tends to have a reducing effect on the anticipated magnitude of change. This is further helped by the increasing intervening distances. The relationship of the Facility to the Lafarge Cement Works was carefully considered within the design process, and influenced the site layout, building orientation, and building massing. Cumulative impacts from all the industrial developments in this area, when considered collectively, are not considered to be higher than moderate/minor and therefore not significant. The Facility is located at sufficient distance to other industrial plants, in particular the Torness Power Station, to avoid any visual confusion or uncomfortable comparisons of scale arising. However, the presence of the Lafarge Cement Works directly to the west, and the operational landfill to the east, means that there is already a strong industrial presence in the area, and whilst the scale of the Facility will add slightly to this baseline, the degree of change is not considered to be equivalent to a significant cumulative effect. The appropriateness of the landscape to accommodate this type of development, and the sensitively chosen location, massing and orientation of the Facility, mean that there are not anticipated to be any significant effects from the proposed development on either the landscape or visual resource. Figures SS13 and SS14 illustrate two Photomontages which show the views which will be seen from Innerwick and the access road to White Sands.

5.8 Noise and Vibration

An assessment of the potential noise and vibration effects arising from the construction and operation of the Facility at Oxwellmains was undertaken in accordance with the appropriate methodologies and relevant British Standards and guidance documents. Cumulative construction and operation noise impacts were also considered. Baseline information was obtained from noise surveys carried out at the nearest noise sensitive receptors (NNSRs), which are residential properties located some distance from the Facility. These are affected by the surrounding road networks, and to a lesser extent, the existing industrial activity (including existing rail handling activities) on and around the site. Observations on-site and the survey data indicated that the ambient and background noise levels are influenced by both of these two sources. The assessment of noise and vibration effects from the proposed construction activities, including on and off-site traffic, has indicated that no significant effects at any NNSRs are likely to arise. The assessment of noise and vibration effects from operational activities, including traffic, has indicated that significant effects would not be likely to arise at the NNSRs provided that good design principles and implementation of best practice are adhered to. During construction, an appropriate Code of Construction Practice will serve to minimise any effects and ensure appropriate noise mitigation is included in the design of the Facility.

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44

5.9 Traffic and Transport The traffic impact of the Facility was examined for transport of wastes, other materials and staff, and with regard to the latter, accessibility of the site was examined for all transport modes including walking, cycling, public transport and cars.

The traffic generation for the Facility was calculated based on the known existing sources of wastes and other materials arriving at the Landfill and the distribution for the Facility assigned to the local highway network. As an indication of the current site operation, in the 12-month period starting November 2005, the site recorded 28,822 vehicle trips, of which 43% were associated with the rail transfer facility. The use of the rail terminal significantly reduces the number of road trips. The existing traffic flows were determined from automatic traffic count data supplied by Transport Scotland and from independent turning movement surveys. In addition, a materiality test was undertaken which has demonstrated that due to the relatively moderate existing traffic flows, the Facility would have a material impact on the local highway junctions albeit they have considerable spare capacity to accommodate the extra usage. The Institution of Highways and Transportation “Guidance for Traffic Impact Assessment” identifies the threshold for an impact to be considered as material as “where traffic to and from the development will exceed 10% of the existing two-way traffic (or 5% in congested or other sensitive locations) ……..”. The junction of the A1087 onto the A1 and Trunk Road Network was assessed in addition to the roundabout of the A1087 with the local road leading to the Oxwellmains site using the TRL software packages PICADY v5 and ARCADY 6 respectively. Both the construction and operational phase modelling has demonstrated that the junctions would operate in a satisfactory manner. The assessment is based on the worst case scenario i.e. no rail usage. Viridor intends to continue to utilise the rail link where 180,000 tonnes per annum can be transported to the site. The assessment therefore has considered volumes which are considerably higher than actually proposed. Road Safety records for the wider highway network around the site have been examined and it has been determined that there are no road safety issues. The assessment has demonstrated that the residual traffic impacts associated with the Facility can be fully accommodated on the existing highway network.

5.10 Socio Economic A qualitative assessment was undertaken to consider the impact of the Facility in terms of employment, economic impact and community gains. The assessment considered employment, business, tourism, and land-use issues in and around the development of the Facility, and provided comment where they were likely to be affected by the proposal. The assessment concluded that the overall impact from the Facility would be positive, providing employment for the local area and economic benefit (both direct and indirect).



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5.11 Amenity The potential adverse impacts on local amenity at identified receptors from litter, vermin, waste, traffic, noise, odour and air quality can be adequately mitigated using standard procedures associated with good waste management practice. These standard procedures will be required under the terms of the site’s PPC Permit. In view of the mitigation measures it is considered that the development will not give rise to any unacceptable impacts in terms of amenity. Whilst it is recognised that residues are generated as a result of the EfW process, assuming worst case, a 90% reduction in the volume of incoming waste would be achieved. This will reduce the potential for landfill associated amenity nuisance to be caused within the Dunbar area. The process will also recover energy from waste that would otherwise be sent to landfill.

5.12 Cumulative Impacts The environmental assessment process within this ES considered the potential for cumulative impacts to arise, as a result of the proposed development in conjunction with other developments within the vicinity of the Facility site.

There are no significant cumulative impacts as a result of the proposed development. Where potential for cumulative impacts has arisen this has been determined to either be not significant or mitigated against. The assessment of cumulative impacts has been conducted for all relevant topic areas. These assessments have concluded that the Facility will not cause significant cumulative impacts.

5.13 Conclusions of the EIA

The findings of the Environmental Impact Assessment for the Facility concluded that, overall, the effects of the development are not considered to be significant as a result of proposed mitigation. The impacts which could be considered to be contentious (landscape and visual, air quality/human health) have been fully mitigated as a result of the iterative design process of the Facility, through careful consideration of emissions control and abatement techniques, and high quality architectural and landscape design.



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6. Policy Analysis and Compliance 6.1 Background

This Section of the Supporting Statement draws together and analyses the key policies affecting the proposals. In addition, Section 2 of the ES provides an analysis in detail of the main policy drivers at national, regional and local levels that provide the framework for the proposals, in relation to the waste, renewable energy, planning and environmental policy with a particular focus on planning. The Traffic & Transport Assessment (Appendix 10 and Chapter 13) of the ES set out the transport policy context. It is appropriate within the Supporting Statement to focus on the important policies and consider how the proposed Facility complies or otherwise with such policies.

Overall, the Facility proposal at Oxwellmains has been considered in the context of policies on the following issues: � Waste Management; � Renewable Energy; � Planning; and � Environment.

These policies apply at different levels, as follows: � International Conventions; � Europe; � United Kingdom; � Scotland; � Edinburgh, Lothians & Borders; and � More specifically East Lothian. This Section examines each of the above policy levels in turn and summarises the relevant policies concerning the issues listed. Any considerations of policy must bear in mind the following three critical points:

� relevant policy for Sustainable Waste Management has significantly changed

recently, most notably through the introduction of SPP10 which effectively postdates much of the Development Plan;

� notwithstanding the above point, the proposals must be considered in the

context of the primacy of the Development Plan, which comprises the Edinburgh & Lothian’s Structure Plan (2004) and the East Lothian Local Plan (2000); and

� there are numerous legislative requirements to be complied with, which

require improved levels of waste reprocessing and renewable energy production. EfW has emerged to meet these drivers, and all policy, including the Development Plan, must be read in the context of these requirements.

In relation to the second point and of key importance to the policy analysis, is establishing the hierarchy and significance of the varying documents, and the relative weight which can be attached to them. Sections 25 and 37(2) of the Town and Country Planning (Scotland) Act 1997 require that applications for planning



47

permission should be determined in accordance with the Development Plan unless material considerations indicate otherwise. In relation to the third bullet above, since the late 1990s, the UK Government, in conjunction with its European partners, has actively promoted the concept of sustainable waste management. This concept has been driven forward by a range of legislation, most notably the EU Landfill Directive (99/31/EC), which has in turn generated secondary legislation and the production of waste management strategies. The overall thrust of the UK Government’s policy is to reduce the Country’s reliance on landfill as the principal form of waste management.

6.2 International Conventions Waste Management and Environment Conventions UNFCCC Kyoto The United Kingdom was a participant at the 1990 Earth Summit in Rio de Janeiro and at the Global Climate Change conference in Kyoto in 1997. The UK Government has ratified and agreed to many of the objectives agreed at these meetings, and in particular the United Kingdom signed the United Nations Framework Convention on Climate Change (the Climate Change Convention) in 1992. Tokyo Treaty Agreements

The promotion of renewable energy sources of electricity generation is an integral part of the UK Government’s (including Scotland) energy policy. Renewable energy is identified as having a key role in the UK Government’s commitment to addressing the cause of climate change and the introduction of measures in support of the UK ‘Climate Change Programme’. In order to meet its Tokyo Treaty commitments, the UK has accepted a legally binding target of reducing emissions of greenhouse gases by 12% below 1990 levels by 2008-2012. Reducing dependence on fossil fuels and replacing them with non-fossil fuels is a way of reducing net greenhouse emissions. In February 2000 the UK Government set a target of 10% of the UK’s electricity supplies to be obtained from renewable sources by 2010. The UK Government’s Energy White Paper, published in May 2007, also introduced an aspiration to achieve renewable generation of 20% of all electricity by 2020. The proposed Facility at Oxwellmains will assist in meeting these international objectives.

6.3 European Directives

European Waste Management Legislation The European Commission’s Framework Directive on Waste (75/442/EEC amended by 91/156/EEC) provides the basic framework for waste management in Member States. It encourages them to take appropriate measures to reduce waste production, recover the useful components of waste and draw up National Waste Management Plans. The Commission adopted the Landfill Directive (99/31/EC) in 1999, requiring Member States to significantly reduce the landfilling of the biodegradable or putrescible elements of household and municipal waste. The main target in the Directive is based on the weight of this waste which each Member State actually landfilled in



48

1995. By 2016, the amount landfilled should be no more than 35% of the 1995 figure. Intermediate targets of 75% for 2006 and 50% in 2009 are included. Member States relying on landfill for more than 80% of all household and municipal waste in 1999 may seek an extension of four years to each of these dates. The UK has successfully gained such a derogation.

The European Council has also adopted a Directive on the Incineration of Waste to reduce emissions to air, water and land, (2006/76/EC). The Waste Incineration Directive imposes strict air emissions standards, which will be met by the EfW proposal. The Facility will require a PPC Permit issued by SEPA in order to operate. European Environmental Legislation The Environmental Statement submitted with this application, reports the details of an Environmental Impact Assessment (EIA) of the proposed Facility. The requirement for EIA on this type of proposal stems from two European Council Directives, 85/337/EEC and 97/11EC on Environmental Impact Assessment. Section 5 provides more information in this regard.

6.4 UK Legislation and Policy Waste Management & Renewable Energy National Waste Strategy Scotland 1999 (The National Waste Plan 2003) The National Waste Strategy: Scotland, provides a framework within which Scotland can reduce the amount of waste which it produces and deal with the waste which has been produced in more sustainable ways. The National Waste Plan 2003 forms the keystone in the implementation of the National Waste Strategy. It pulls together the 11 Area Waste Plans which were published in parallel and which aim to promote consensus on the right way forward (the best practicable environmental option), for sustainable waste management in each area.

White Paper on the Environment A key White Paper which outlines the UK Government policy on the environment is: Securing the Future – UK Government Sustainable Development Strategy (DEFRA, 2005), in conjunction with the Strategic Framework (DEFRA, 2005). The aim of the policy is to ensure that development is environmentally benign in terms of impact and is thereby sustainable. The strategy incorporated responses from the previous Strategy Papers from 1999, and sets out the UK Government’s (including Scotland) plan of action towards delivering and promoting sustainable development. The Energy Paper and Energy Review Energy policy was updated in 2006 upon the release of the UK Government’s Energy Review – The Energy Challenge. The target of achieving 10 gigawatts of Good Quality Combined Heat and Power (CHP) by 2010 remains the same as that set in the UK Government’s Energy White Paper (2007). The Energy Review indicated that the current installed capacity was 5.6 gigawatts in 2004, 90% of which was large scale plant. It has been concluded that the great majority of CHP capacity in the UK will have to continue to come from large scale CHP Plant in the short term. There are still a number of limiting factors to large-scale plant growth such as the lowering of wholesale gas prices and the logistical factor that the heat cannot be transported



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long distances. This has meant that there has been little progress in the last 5 years in increasing installed CHP capacity. The economic benefits of the burgeoning business sector of EfW and energy/waste solutions were also recognised more recently by Elliot Morley MP, Minister of State (Climate Change and Environment). In a speech to the Environmental Industries Commission Annual Conference (27 October 2005) he said:

…As for the business opportunities, there is great potential for companies offering solutions to divert waste from landfill – such as composting, energy from waste, recycling and re-use.

6.5 Scottish Government Policy – Waste Management and

Environment Securing a Renewable Future: Scotland’s Renewable Energy (Scottish Executive, 2003)

This document sets out the Scottish Government’s policy for renewable energy targets in order to reduce carbon dioxide emissions, the main contributor to global warming. The Scottish Government has set a target that by 2010 18% of electricity generated in Scotland should come from renewable sources and an aspiration of 40% by 2020. It recognises that in order to achieve this, it is likely that the development of new technologies such as biomass amongst others would have to be promoted. EfW facilities would represent a ‘flexible and predictable source’ of energy. Delivering the New Generation of Energy – Route-map to Scotland’s Renewable Future (Scottish Renewables, 2006)

This document sets out what renewables could practically contribute towards Scottish energy needs by 2010, 2020 and 2050. The Scottish Government has estimated that Scotland currently has sufficient renewable energy resources to provide up to 75% of UK electricity needs and Scotland’s renewable electricity sector is already meeting around 16% of Scotland’s electricity needs.

Audit Scotland – Key Messages: Sustainable Waste Management (September 2007)

Audit Scotland has reviewed Scotland’s progress towards meeting EU Landfill Directive targets of reducing the amount of waste being sent to landfill, and advises that Councils, the Scottish Government and other agencies need to work more effectively together in order to achieve these. The Landfill Directive is aimed at reducing the amount of Biodegradable Municipal Waste (BMW) going to landfill to 1.3 million tonnes by 2010; and thereafter, to 0.88 million tonnes by 2013; and to 0.62 million tonnes by 2020. Currently however, 1.54 million tonnes of biodegradable municipal waste goes to landfill sites in Scotland, while the total amount of municipal waste generated in Scotland has been rising by 1.25 per cent a year over the long term and is expected to continue to rise. This is against a background of a predicted increase in the total waste generated in Scotland from around 3.3 million tonnes at present to around 4.3 million tonnes by 2020 at the current annual growth rate. The problem is further being compounded by slow progress in developing facilities to treat residual waste resulting from early delays and a lack of organisational capacity within councils and the Scottish Government.



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There is therefore a real risk that EU Landfill Directive targets may not be met, and in particular, Audit Scotland advises, that the 2013 target will not be achieved. If Scotland is to meet the EU Landfill Directive targets a sharp reduction in the amount of waste going to landfill is required. Audit Scotland considers that this reduction will only be achieved with the creation of additional facilities for treating residual waste. Estimates prepared for the previous administration indicate that Scotland needs plants capable of treating annually 1.14 million tonnes of residual waste by 2020. Paragraph 28 of Key Messages: Sustainable Waste Management, accordingly advises that the challenge facing councils and the Scottish Government in the near future is to ensure that the facilities required for the treatment of residual waste are delivered on time to meet Landfill Directive targets. In Paragraph 13, Audit Scotland recognises and highlights the potential for Energy from Waste (EfW) to contribute towards the treatment of residual waste, and therefore to the achievement of the EU Landfill Directive targets of reducing the amount of waste being sent to landfill.

In its recognition of the potential contribution of Energy from Waste plants to the reduction of residual waste going to landfill, Key Messages: Sustainable Waste Management is supportive of the proposed development.

6.6 Scottish Government Planning Policy

National Planning Framework The National Planning Framework for Scotland (2004) recognises the need to support economic development while safeguarding communities and fostering environmental stewardship, as an important policy objective. With specific regard to renewable energy, it notes that Scotland will require between 2,000 and 2,500MW of electricity generated from renewable sources by 2020, which represents a build rate of around 120 to 150MW per year. With specific regard to waste management, it is noted that the targets set by the National Waste Plan require substantial investment in new EfW facilities. It advises that in the Central Belt Market Area, which includes Edinburgh and the Lothians, local authorities will need to work closely together to ensure that facilities are appropriately located; to identify the most sustainable transport options; and avoid duplication and achieve economies of scale. In this regard it is noted in Paragraph 141 that: …Relevant considerations in the siting of facilities will include the proximity principle and their relationship to the transport network and remaining landfill sites. Modern treatment and transfer centres are contained facilities which can be accommodated on industrial estates. Where possible, they should be located close to the population centres they serve. They should be linked to landfill sites in a ‘hub and spoke’ arrangement, where possible by rail. National Planning Framework 2: Discussion Draft

The Planning etc. (Scotland) Act 2006 amended the Planning (Scotland) Act 1997 to put the National Planning Framework on a statutory footing. The legislation places duties on Ministers to prepare the National Planning Framework with the objective of contributing to sustainable development and to review it every 5 years.



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The National Planning Framework 2: Discussion Draft was published for consultation on 8 January 2008. It identifies that Scottish Government policy on waste reduction and management are currently being reviewed. However, it recognises that the targets set by the EU Landfill Directive necessitate a move away from landfill, and a greater recognition of the substantial potential of waste as a resource. It is stated that the existing capacity to divert some 1 million tonnes from landfill will need to be increased to some 1.5 million tonnes by 2010, over 2 million tonnes by 2013 and some 2.5 million tonnes by 2020. Additional capacity will also be required to treat commercial and industrial waste In relation to waste management technologies, it notes in paragraph 137 that the Scottish Government is seeking to ensure that …any energy from waste plants that are built have high levels of efficiency through, for example, combined heat and power. In terms of planning guidance for waste management facilities, it reiterates and updates the advice contained in the 2004 Framework. In paragraph 234 it states that …relevant considerations in siting will include the proximity principle, the transport network and the relationship of intermediate transfer and treatment facilities to tertiary waste management facilities. Modern treatment and transfer centres are contained facilities which can be accommodated on industrial estates. Where possible, they should be located close to the population centres they serve. They should be linked to tertiary waste management facilities in a ‘hub and spoke’ arrangement, where possible by rail or water. Scottish National Planning Policy

National Planning Policy and Guidance

Approved National Planning Policy Guidance currently takes the form of Scottish Planning Policies (SPPs) and National Planning Policy Guidance (NPPGs). These provide statements of Scottish Government policy on nationally important land use and other planning matters. The Scottish Government is phasing out NPPGs with a view to replacing these with SPPs. While several NPPGs are still current, these will eventually be superseded by SPPs, some of which have been published in draft form for public consultation. Planning Advice Notes supplement SPPs and NPPGs, by providing advice on good practice and other information relevant to the planning process. The SSPs most directly relevant to this project are: � SPP10: Planning and Waste Management; � SPP6: Renewable Energy; � SPP1: The Planning System; � SPP7: Planning and Flooding; and � SPP2: Economic Development Relevant guidance and policy arising from the NPPGs/SPPs are outlined below: SPP1: The Planning System (2002) Summary of Relevant Content

SPP1 requires development that meets the needs of the community to be realised in as sustainable a form and location as possible. Planning authorities are accordingly



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advised to have regard to the extent to which a proposed development will ensure an appropriate balance between economic growth; the promotion of social justice; and the minimisation of the expenditure of natural and cultural resources required to fulfil these objectives. In addition, SPP1 reaffirms the primacy of the Development Plan within the decision making process. Policy Assessment

The proposals comprise a sustainable development in that the Facility will provide the necessary infrastructure in line with the LBAWP BPEO principles including the waste hierarchy, self sufficiency and the proximity principle. In addition, the Facility will: � support local employment during construction and operation; � provide for the safe management of waste on behalf of the community; � divert residual waste away from landfill and will incorporate a high standard of

environmental control measures; and � by its nature involves the recovery of resources, and will reduce the demand

on natural resources. The site is shown on the Proposals Map of the adopted local plan to be within the Countryside and Developed Coast and is not allocated for waste management. However the adopted East Lothian Local Plan 2000 (April 2001) is now out-of-date and the Council has accordingly prepared the Finalised East Lothian Local Plan 2005 to succeed it. The Finalised local plan has been the subject of a Public Inquiry, and it is anticipated that it will be adopted by mid-2008. It supports the identification of the site as a suitable location for waste treatment and disposal. Thus, although the site is not allocated for waste management in the adopted local plan, the fact that it is identified as such in an Finalised local plan that has recently been the subject of a Public Inquiry is a material consideration that strongly justifies a departure from the statutory development plan.

SPP2: Economic Development (2002) Summary of Relevant Content

SPP2 states that planning authorities should seek to accommodate economic development that is required to meet the needs of the community, in an appropriate form and location. This requires them to consider how to make the best and most efficient use of land, transport, infrastructure and community resources, while ensuring that there is no unacceptable impact upon the natural or built environment. Policy Assessment

The Facility provides the opportunity to offset the significant impact of landfill tax (£48 per tonne in 2010) which would otherwise be passed onto Council Tax payers. The local economy would further benefit from increased employment opportunities, sustained by wages and salaries received and spent in the local economy by people directly employed at the Facility and through the use of local services. The Facility supports the economic development of the Lothians, by providing a facility that will improve waste management within the region, making sustainable use of an existing waste management site, providing energy from a renewable source and helping to reduce the amount of waste for disposal by landfill.



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SPP6: Renewable Energy (2007) Summary of Relevant Content SPP6 emphasises the importance of generating energy from clean and sustainable sources to help tackle climate change. It recognises the need to ensure secure and diverse energy supplies and support the full range of renewable energy generation technologies. The Scottish Ministers have made a commitment to increasing the amount of electricity generated from renewable energy sources and have set a target of generating at least 18% of Scotland’s energy from renewable sources by 2010, and at least 40% (6GW) by 2020. The intention of SSP6 is to help ensure the delivery of these renewable energy targets as well as supporting the development of a mix of renewable energy technologies over the longer term, to include energy from waste facilities. Policy Assessment The proposed development will make an effective contribution to ensuring secure and diverse energy supplies and supports the full range of energy generation technologies. It will help the Edinburgh, Lothians and Scottish Borders Region fulfil its commitment to meeting the amount of electricity generated from renewable energy sources. As the site of an operational landfill, which is allocated for waste treatment and disposal in the Finalised Local Plan, the proposed development will be located in a setting that is appropriate both in terms of its impact upon the environment and upon residential amenity and in terms of its ability to accommodate this Facility without compromising its function and operation. The proposed development will not have an unacceptable impact upon the environment or upon residential amenity, either in isolation or in conjunction with the operation of other developments. It is appropriate for the Council to consider proposals to develop energy recovery from waste because it will not only provide an opportunity to generate renewable energy from a sustainable source but will also allow it to meet pending legal requirements in respect of targets for diversion of waste from landfill. The site is within an industrial/Brownfield context that is located close to the electricity grid/or other potential heat and power users, which offers the opportunity to further develop the use of the excess energy generated by the Facility.

SPP7: Planning and Flooding (2004)

Summary of Relevant Content SPP7 advises that new development should neither materially increase the probability of flooding within its locality nor add to the area that requires to be protected from flooding.

Policy Assessment The site is not located in an area recognised to be at risk of flooding, but notwithstanding this, a full hydrological study and flood risk assessment has been carried out in full accordance with the provisions of SPP7. This is summarised in Section 5, above and is fully included within Chapter 8 of the ES.



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SPP10: Planning and Waste Management Summary of Relevant Content

SPP10 was published in August 2007 and places particular emphasis on a plan-led approach to waste management identifying sites for installations. It highlights the importance of community engagement in the planning process; stresses the need to meet statutory targets on time; and describes the approach planning authorities should adopt to promote a better fit between development plans and Area Waste Plans in order to secure shared Ministerial objectives and take account of SEPA’s policy role in waste management. SPP10 establishes the principles of sustainable waste management, within which it highlights: � The Waste Hierarchy; � The Polluter Pays Principle; � The Best Practicable Environmental option; and � The Proximity Principle.

Policy Assessment

The Facility proposal is in accordance with these principles. The proposal provides an environmentally acceptable solution, and as such offers the opportunity to meet sub-regional and regional self sufficiency while adhering to both the proximity principle and the waste hierarchy.

With regard to the policy context required by SPP10, the adopted East Lothian Local Plan (2001) does not identify sites for waste management. However the Finalised East Lothian Local Plan, which should be taking into account as a material consideration, identifies the site of the proposed Facility for waste treatment and disposal (Policy W1: Oxwellmains, Dunbar). Although the Finalised Local Plan is not yet adopted, the safeguarding of the site through Policy W1 has been rigorously tested through the local plan public consultation process to a degree that more readily satisfies the requirements of SPP10 than any other site in the local authority area.

Although the site is not recognised as employment or industrial land in either the adopted or Finalised Local Plan, it is currently the location of a waste management facility and is therefore already recognised to be an appropriate location for the processing of waste.

The site is located in close proximity to the electricity grid and/or users and is also well located for potential CHP users. NPPG13: Coastal Planning (1997)

Summary of Relevant Content

NPPG13 recognises the importance of the coast and presents guidelines that provide a framework within which planning authorities can address the issues that arise in a complex and sensitive environment. With specific regard to energy generation, it advises in Paragraph 47 that …the visibility of new development can be very pronounced on the coast, buildings and structures associated with the provision of renewable energy should be allowed on the undeveloped coast where they are



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primarily aimed at meeting local demand and as far as is practicable, are sited in an unobtrusive location. Policy Assessment

The landscape and visual impact assessment undertaken has demonstrated that the appropriateness of the landscape to accommodate this type of development, and the sensitively chosen location, massing and orientation of the Facility, mean that there are not anticipated to be any significant effects from the proposed development on either the landscape or visual resource.

The Facility has been purposely located in a quarry thereby reducing the effective height of the building relative to surrounding land. Similarly the building has been sensitively designed to sit within the landscape. It is also important to recognise that the Facility will be operated in accordance with EMS ISO14001 (the highest available international standard) at all times and will therefore, be subject to meeting on-going standards and targets in respect of maintaining the environment within which it sits. NPPG14: Natural Heritage (1999)


NPPG14 advises as to how the Government’s policies for the conservation and enhancement of Scotland’s natural heritage should be reflected in land use planning. With regard to Sites of Special Scientific Interest, planning authorities are required to consult SNH when determining an application for a development that might affect a SSSI.

Policy Assessment The Environmental Impact Assessment demonstrates that the impact of the proposed development upon the natural heritage resources within the surrounding area will have no unacceptable effects upon local flora and fauna, through the employment of appropriate mitigation strategies.

SPP15: Planning for Rural Development (2005) Summary of Relevant Content

SPP15 considers that Scotland’s rural areas have significant long term potential as places to live and work. In order for this potential to be realised, however, it is recognised that there is a need to identify appropriate ways in which to accommodate development. Not only will this support vigorous and prosperous rural communities but it will provide sites for developments that can only be appropriately accommodated in rural areas. Policy Assessment The proposed development can be satisfactorily accommodated within this rural area, particularly as it is located in an area with an industrial character. The site is also suitable by virtue of its excellent road and rail access links. In addition it will help to support and sustain the rural local economy.



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SPP17: Planning for Transport (2005) Summary of Relevant Content

SPP17 requires that developments should be made safely and conveniently accessible by appropriate means of transport, and that developments should be located to make the most sustainable use of the local transport network. Any viable opportunities to utilise more sustainable methods of transport should be taken where these are available. With regard to freight, this means identifying opportunities to make use of rail connections, wherever these can be viably utilised, to minimise the amount of road traffic required to transport raw materials or products to and/or from the site of a proposed development. Policy Assessment The site is located on the main east coast railway line, serving both Edinburgh and Berwick, and has an operational rail head. It is also located on the A1 and is readily accessible to and from all the main urban centres in the surrounding area by road. Given the nature of the Facility, it is not required to be readily accessible to the public. It is therefore a highly suitable site for a waste management facility in that it affords good opportunities for the sustainable transportation of waste by both rail and road. The Traffic & Transport Assessment undertaken has demonstrated that the traffic associated with the Facility can be fully accommodated on the existing highway network.

Planning Advice Notes

PAN 33: Development of Contaminated Land (2000) Summary of Relevant Content

PAN 33 emphasises the need to re-use and redevelop previously developed land wherever possible, but stresses the need to take full account of the previous uses of a site when considering whether or not it is an appropriate location for a proposed development.

Assessment

As the site of an existing waste management facility, the site is an appropriate location for the proposed development. In addition, a full intrusive site investigation was undertaken for the site of the proposed development, the outcome of which is contained within Chapter 9 of the ES.

PAN 45: Renewable Energy Technologies (2002) Summary of Relevant Content PAN 45 supports SPP6 by providing information and advice on the technologies for harnessing renewable energy for electricity generation. It considers that there is existing capacity to accommodate new generation in the Central Belt and South of Scotland, and notes that electricity generation proposals under 50 MW should be authorised under the Town and Country Planning (Scotland) Act 1997 as opposed to



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under Section 36 of the Electricity Act 1989. It recognises that energy can be derived from municipal solid waste. Assessment In its recognition of capacity in the Central Belt and South of Scotland to accommodate new energy generation facilities, and in its recognition that energy can be derived from MSW, PAN 45 is supportive of the proposed development. The site is appropriate for energy facilities using waste as fuel. It is well located in terms of waste arisings and there is capacity for export of the electricity to the grid and/or users. PAN 51: Planning, Environmental Protection and Regulation (2006)


PAN 51 states that: …any consideration of the potential impacts arising from development, where there is a potential risk to the quality of land, air or water, leading to a proven impact on health, is capable of being a material consideration, insofar as it may arise from any land use. Assessment The fact that the site is the location of an existing waste management facility supports the view that this an appropriate place in which to develop an energy from waste plant. Similarly, it has been demonstrated that the Facility will have no detrimental impact on human health or the environment and it is therefore an acceptable use of the land. The impact of the proposed development upon the surrounding landscape will be acceptable because of the location and design of the Facility.

PAN 56: Planning and Noise (1999) Summary of Relevant Content PAN 56 recognises that excessive noise can impact adversely upon human health and quality of life, and upon the environment. It advises planning authorities to take account of noise generation by ensuring that development is located to allow it to function appropriately, while restricting the impact of noise upon local communities and the environment to an acceptable level. Assessment The proposed development will operate in accordance with the required noise standards. Similarly the PPC Permit will specify noise levels which will not be exceeded during operation of the Facility.



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PAN 60: Planning for Natural Heritage (2000) Summary of Relevant Content PAN 60 seeks to identify the ways in which development and land use planning can enhance Scotland’s natural heritage and create high quality environments for working and living.

Assessment The proposed development will support the objectives of the waste management strategy identified within the LBAWP, and the National Waste Plan and therefore at a Regional and National level, offers considerable potential to reduce the need for new landfill development. PAN 63: Waste Management Planning (2002) Summary of Relevant Context PAN 63 is intended to complement SPP 10. It seeks to promote good practice in the design of waste management installations, building on the information given on land use planning for waste management in the National Waste Strategy: Scotland. Assessment The Finalised local plan clearly identifies the site as an appropriate location for the treatment and disposal of waste. As an existing waste management facility, with good rail and road access, adjoining other industrial uses, the site is a highly appropriate location at which to minimise the impact on the environment to an acceptable level. The Facility will produce electricity and have the potential for CHP and it therefore accords with the principles of sustainable waste management. In terms of the considerations outlined in PAN 63, the site is a suitable place in which to locate a waste management facility. With regard to the key principles outlined in Annex Paragraph 1 of the PAN 63 the following should be noted: The Facility has been designed with the principles of sustainable waste management in mind, with the proposals being brought forward to form part of the integrated sustainable waste management strategy proposed within the LBAWP. A Sustainability Assessment has been undertaken as part of the EIA process (contained within Appendix 11 of the ES). The principles of self sufficiency and the proximity principle have formed a key part in the choice of location for the proposed Facility. It is intended to service the residual waste disposal requirements of three of the local authorities in the region in which it is located. Thus, it meets the requirements of both principles. Energy from Waste is considered to have a place in the Waste Hierarchy in conjunction with prevention, reuse, and recycling. This is recognised in the L&BAWP.



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The proposals have been assessed against the recently revised and adopted LBAWP BPEO and it has been concluded that the Facility would provide the required infrastructure to meet the residual waste treatment requirements of the BPEO and wider LBAWP Strategy. PAN 68: Design Statements (2003) Summary of Relevant Content PAN 68 explains the role and use of design statements. It advises that design issues should be considered at the earliest stage of the development process, and outlines a five stage framework within which to create a design solution; namely, Stage 1 – Site and Area Appraisal; Stage 2 – Identifying the Design Principles; Stage 3 – Analysis; Stage 4 – Design Concept(s); and Stage 5 – Design Solution. Assessment A Design Statement that takes full cognisance of PAN68 has been submitted as part of this planning application. PAN 75: Planning for Transport (2005) Summary of Relevant Content PAN 75 provides guidance on the integration of transport and land use planning. Planning authorities, developers and others are advised to adhere to this guidance during policy development, proposal assessment and project delivery. Assessment The proposed Facility has good rail and road links, and will support sustainable transport patterns, as described more fully in the Transport Assessment and Transport Section of the Environmental Statement. This is summarised in Section 5 of this Supporting Statement. PAN 81: Community Engagement – Planning with People (2007) Summary of Relevant Content PAN 81 details how the planning system is being reformed principally through The Planning etc. (Scotland) Act 2006. It advises that the planning system needs to be more inclusive and accessible to the public and includes advice on how planning authorities, developers and community groups can better engage the local community. The guidance and examples provided, illustrate the variety of ways in which the public can get involved in the planning process and sets out the approaches that planning authorities can use to encourage greater public involvement.

Assessment

A Statement of Community Engagement has been submitted with this planning application. This document demonstrates compliance with the provisions of PAN81.



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6.7 Development Plan Policy The Development Plan comprises the approved Edinburgh and Lothians Structure Plan (approved June 2004) and the East Lothian Local Plan (adopted 2000). Table 6.1 summarises the main policy provisions of the development plan. The Structure Plan was to have been the subject of a review commencing in 2006, but this has been abandoned. A more fundamental reassessment of strategic policy in line with the requirements of the Planning etc. (Scotland) Act 2006 as well as recent updates in national guidance and planning advice is now to be pursued. In the absence of such a review, and in advance of the preparation of a Strategic Development Plan, the approved Structure Plan remains the only and most up-to-date statement of the Councils’ strategic development objectives, policies and proposals. The East Lothian Local Plan 2005, subsequently modified by Pre-Inquiry Modifications in January 2006 will replace the East Lothian Local Plan 2000 in due course. It has been subject to a Local Plan Inquiry, and East Lothian Council anticipate that it will be adopted in mid 2008.

TABLE 6.1 – MAIN POLICY PROVISIONS OF THE DEVELOPMENT PLAN Approved Edinburgh and Lothians Structure Plan (June 2004)

� TRAN5: Transport Implications of New Development � TRAN 6: Freight Movement � ENV1A: International Natural Heritage Designations � ENV1B: National Natural Heritage Designations � ENV1C: International and National Historic or Built Environment Designations � ENV1D: Regional and Local Natural and Built Environment Interests � ENV 1G: Design of New Development � ENV 3: Development in the Countryside � ENV 5: The Coast � ENV 6: Renewable Energy � ENV 11: Waste Management � ENV 12: Water Management and Flooding

The East Lothian Local Plan, (2000)

� DC1: Development in the Countryside � DC3: Wildlife/Geological Areas � DC4: Areas of Great Landscape Value � DC5: Historic Gardens & Landscapes � ENV3: General Design Criteria � ENV9: Listed Buildings � ENV11: Monuments/Archaeology � BUS5: Proposals on Unallocated Land � NRG2: Torness Consultation Zone � T1: Development Location � T6: Rail Freight Transport � T7: Parking Standards

The Finalised East Local Plan (2005)

� DC1: Development in the Countryside � NH1: Wildlife and Geological Areas � NH2a: Internationally Protected Areas � NH2b: Sites of Special Scientific Interest � NH4: Areas of Great Landscape Value � ENV3: Listed Buildings � ENV7: Scheduled Ancient Monuments and Archaeological Sites � ENV8: Historic Gardens and Designed Landscapes � BUS8: Proposals on Unallocated Land. � NRG2: Torness Consultation Zone � W1: Oxwellmains, Dunbar � INF3: Infrastructure and Facilities Provision � T1: Development Location and Accessibility



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TABLE 6.1 – MAIN POLICY PROVISIONS OF THE DEVELOPMENT PLAN � T2: General Transport Impact � DP1: Landscape and Streetscape Character � DP2: Design � DP4: Design Statements � DP18: Transport Assessment and Travel Plans � DP22: Private Parking

The Local Plan is the key Development Plan consideration for the proposed operations and outlines the specific policy for the Oxwellmains Landfill. The Approved Structure Plan and the Area Waste Plan provide the wider Development Plan policy context. Key Policies of relevance to the proposed Facility are detailed below and assessed in respect of the Facility. Structure Plan Policy ENV 6: Renewable Energy states that the development of renewable energy resources will be supported where this can be achieved in an environmentally acceptable manner, including consideration of cumulative impact. A detailed quantitative and non-quantitative assessment of need has demonstrated very strong support for the project. The Facility provides a clearly balanced environmental benefit and contributes towards the goal of achieving sustainable waste management and/or renewable energy production in the Lothian area. It is therefore considered the proposal accords with Policy ENV6. Policy ENV 11: Waste Management states that proposals meeting LBAWP BPEO and capacity and infrastructure requirements, which accord with the principles of sustainable waste management and with approved Structure Plan policies ENV1, ENV2 and ENV3, will be supported in principle. The proposed Facility meets the requirement of the LBAWP BPEO. The independent BPEO and needs assessment undertaken in preparation of the proposals demonstrate the capacity and infrastructure requirement for the Facility. The site of the proposed Facility is on a former quarry site, which is effectively Brownfield land, and which sits in a setting that includes Scotland’s largest cement works and Torness Power Station. The location of the site within this industrial context and adjacent to the A1 road network and a rail facility means that the proposal accords with this policy and is acceptable. In the Finalised Local Plan, Policy W1: Oxwellmains, Dunbar states that Oxwellmains is supported as a site for waste treatment and disposal, and that development that restricts its continued operation for this purpose will not be permitted. The Environmental Statement accompanying this application and the following analysis of policies ENV1, ENV2 and ENV3 demonstrates that there is no conflict and that the proposal is in full compliance with Policy ENV11. Policy TRAN 5: Transport Implications of New Development states that local plans should include policies to ensure that new development that is likely to generate significant amounts of travel or otherwise have a material effect on travel by road, is required to be the subject of a transport assessment to consider, inter alia, access arrangements; methods of transport; highway capacity; transport improvements; and developer contributions.



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Policy TRAN 6: Freight Movement states that in allocating land for development likely to generate major freight movements, local plans should ensure that priority is given to locations that are readily accessible to the rail network or suitable port facilities, and that are easily accessible by the strategic road network. Such developments should not be located where they will generate major new lorry movement on all-purpose roads through built-up areas. An assessment has been undertaken in preparation of the ES which meets the requirements of both TRAN 5 and TRAN 6. Policy ENV 1A, Policy ENV 1B and ENV 1C set criteria to be met in respect of the protection of International and National natural, historic and built environment designations. Policy ENV 1D sets criteria in respect of regional or local areas of natural heritage and built environment interests, or their settings. The Environmental Impact Assessment has demonstrated that there will be no unacceptable impact on the natural, historic and built environment (either on international or national designations, or on regional or local designations). Policy ENV 1 G: Design of New Development requires the Councils to promote a high quality of design in all developments. A detailed Design Statement, undertaken in accordance with PAN68 has been submitted with this planning application, which demonstrates that a high degree of thought and consideration has gone into the design of this proposal, to make it sympathetic to its coastal setting and the countryside environment. Policy ENV 3: Development in the Countryside states that development will be permitted in the countryside where it can be demonstrated that it has an operational requirement for such a location that cannot be met within an urban area or on land allocated for that purpose elsewhere. A site selection exercise has been undertaken in support of the application which justifies the choice of location for the proposed Facility. Policy ENV 5: The Coast requires that development on the undeveloped coast will only be permitted where a need can be demonstrated for a coastal location, that the benefits outweigh any detrimental environmental impact and that there is no alternative site. The site is not located on the defined coastline, although it does lie within close proximity. Further, the land in question has been developed previously as a quarry, so that this policy does not strictly apply, although it is important to note that there is a demonstrable need and that the benefits of the scheme outweigh any detrimental environmental impacts, as fully explained in the accompanying Environmental Statement.

Policy ENV 12: Water Management and Flooding states that development proposals should include sustainable drainage systems for the attenuation and treatment of surface water and to assist in reducing the risk of flooding unless local conditions prevent this approach. The flooding section, summarised in Chapter 8 and fully explained in Appendix 8 of the Environmental Statement, addresses this policy issue and demonstrates that



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there is no negative impact in terms of flooding arising from the proposed development. Local Plan Key Policies Policy DC1: Development in the Countryside and Undeveloped Coast of the adopted Local Plan outlines the types of development that will be acceptable in principle within the countryside and undeveloped coast. Part 1(c) of Policy DC1 states that, in considering development used for business and leisure uses other than those stated in parts 1(a) [agricultural, horticultural, forestry operations or countryside recreation] and (b) [tourism and leisure development], of which this is one, the Council must be satisfied that there is an operational requirement for the proposed location. The Council requires to be satisfied that the proposed development could not reasonably be accommodated in an existing business or industrial area. This policy is retained in the Finalised Local Plan. The proposed site lies outwith the settlement boundaries as defined on the Proposals Map and is therefore Countryside. However, the site selection report submitted in support of this application justifies the choice of the site location for the proposed facility and the reasons why the proposed development should be considered as an acceptable departure to policy DC1. Policy BUS 5: Proposals on Land Not Allocated for Business or Industry of the adopted local plan outlines that proposals for business and industrial developments on land not allocated for this purpose will not normally be permitted unless no alternative allocated sites are available and appropriate road and infrastructure are available. This policy is retained and updated as Policy BUS8: Proposals on Unallocated Land in the Finalised Local Plan. The site is not allocated for business or industrial use in the adopted Local Plan or the Finalised Local Plan. However, under Policy W1: Oxwellmains, Dunbar of the Finalised Local Plan, which represents the most up to date expression of planning policy, the site is supported for waste treatment and disposal. The proposed development is in full compliance with Policy W1. In addition, a site selection exercise has been undertaken in support of the application which justifies the choice of location for the proposed facility and the reasons why the proposed development should be considered as an acceptable departure to policy BUS5.

Policy NRG2: Torness Consultation Zone of the adopted Local Plan requires that all planning applications to develop land within a 4 km radius of the Torness Power Station will be referred to British Energy. Along with a number of other key community groups and stakeholders, British Energy has been consulted on the proposed development from a very early stage and it has so far raised no issues. It can be suggested, therefore, that the provisions of this policy are fully met.

Relevant Policies Policy NH2a: Internationally Protected Areas and Policy NH2b: Sites of Special Scientific Interest of the Finalised Local Plan combined are essentially an update of Policy DC3: Wildlife and Geological Areas of the adopted Local Plan. These policies state that development affecting a Natura 2000 area or a RAMSAR site will not generally be permitted unless there are no alternative solutions and there are



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imperative reasons of overlying public interest. Development affecting Sites of Special Scientific Interest (SSSI) will only be permitted where the objectives of the designation and overall integrity of the site will not be compromised or where there are no alternative solutions and any significant adverse effects are clearly outweighed by social, economic or environmental benefits of national importance. Policy NH1: Wildlife and Geological Areas of the Finalised Local Plan requires that where development is permitted which affects a site of designated natural heritage value, wherever possible appropriate mitigating measures must be provided to enhance and safeguard the remaining interest.

Whilst these natural heritage policies are accepted as being relevant to the proposal, the Environmental Statement demonstrates that there is no conflict and the proposal is therefore acceptable in this regard. Policy NH4: Areas of Great Landscape Value of the Finalised Local Plan and Policy DC4: Areas of Great Landscape Value of the adopted Local Plan both state that development that harms the landscape character and visual amenity of AGLVs will not be permitted. The proposed development does not lie within, or close to any designated AGLV. Therefore the proposed development affects neither the landscape character nor the visual amenity of any designated AGLV. The Landscape and Visual impact assessment undertaken support this statement. Policy DC5: Historic Gardens and Landscapes of the adopted Local Plan and Policy ENV8: Historic Gardens & Designed Landscapes of the Finalised Local Plan relate to effects on conservation, setting and landscape. The proposed development does not affect the setting of any Historic Garden or Designated Landscape, either directly or indirectly and there is, therefore, no conflict with any of the above policies in this regard. Policy ENV9: Listed Buildings and Policy ENV11: Scheduled Ancient Monuments of the adopted Local Plan both of which are carried through into the Finalised Local Plan, the former into Policy ENV3: Listed Buildings, and the latter into Policy ENV7: Scheduled Ancient Monuments relate to effects on the setting of Listed and or Historic Buildings. The proposed development does not affect the setting of any Listed Building or Scheduled Building, either directly or indirectly and there is therefore no conflict with any of the aforementioned policies in this regard. Policy T1: Development Location and Accessibility of the Finalised Local Plan, which updates Policy T1: Development Location of the adopted Local Plan specifically requires that new development be located on sites capable of being conveniently and safely accessed by public transport, foot and cycle as well as by private car. Exceptions to this general policy will be considered where there is a specific operational requirement for a location that does not meet the terms of the Policy, or where there are overall planning benefits to be gained. Policy T2: General Transport Impact of the Finalised Local Plan, requires that new development must have no significant adverse consequences for road safety; the safety and convenience of cyclists and walkers in the surrounding area; the safety and convenience of public transport users; the capacity of the road network to



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accommodate traffic unrelated to the proposed development; and residential amenity, as a consequence of an increase in traffic. The impact on the local highway network is considered to be acceptable, conforming to above transport policies. A full Transport Assessment has been submitted with this application which addresses these transport policy considerations and confirms that, with appropriate measures in place, there is no issue in this regard. A summary of the Transportation Section of the Environmental Statement is contained in Section 5 of this Statement. Policy INF3: Infrastructure and Facilities Provision of the Finalised Local Plan states that new development will only be permitted where the developer makes appropriate provision for infrastructure and community facilities required as a consequence of their development. Section 3 of the Environmental Statement addresses these infrastructure and facilities issues. It is considered that the infrastructure required for the development to take place will be confined to on-site works and the necessary upgrading of the access and road network. Policy DP1: Landscape and Streetscape Character, Policy DP2: Design and Policy DP4: Design Statements of the Finalised Local Plan principally relate to design. Policy DP2 of the Finalised Local Plan is an update of Policy ENV3: General Design Criteria of the adopted Local Plan. In accordance with the above design policies, a detailed Design Statement undertaken in accordance with PAN68 has been submitted with this Planning Application. This Design Statement demonstrates that a high degree of thought and consideration has gone into the design of this proposal to make it sympathetic to its coastal landscape setting and its immediate environment. Policy DP18: Transport Assessment and Travel Plans of the Finalised Local Plan requires that development which is likely to generate significant levels of personal travel or have a significant effect on the transport system should be accompanied by a Transportation Assessment. This application is accompanied with both a full Transport Assessment and a Green Travel Plan, which has been prepared in full accordance with this policy. Policy DP22: Private Parking of the Finalised Local Plan updates Policy T7: Parking Standards of the adopted Local Plan. It requires car parking provision to conform to the Council’s adopted parking standards, and to be sited and designed to minimise its visual impact and effect on neighbouring properties. Car parking design should also take account of safety through provision of effective lighting and layout. As explained in the Transport Assessment, the parking to be provided for staff and visitors using the Facility meet the Local Standards and do not exceed the National Standard, as specified in SPP17, in full accordance with the above Parking Policies in both the adopted and Finalised Local Plans. Policy T6: Rail Freight Transport of the adopted Local Plan, states that initiatives to transfer freight by rail will be supported by the Council, including applications for Freight Facilities Grant and Track Access Grant under the Railways Act 1993.



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As stated in the Transport Statement, the rail service currently serving the site will be further utilised, thus minimising the impact on the local road network and contributing towards a more sustainable form of development.

6.8 Policy Conclusions The proposals accord with international, European, national, regional and local policies for waste management and planning. The development will assist in meeting targets for waste management and climate change specifically within Scotland and promotes a more sustainable and integrated approach to waste management. The principle of an EfW development within East Lothian is also supported within the development plan, in particular through policy ENV 6: Renewable Energy of the Structure Plan and Policy W1: Oxwellmains, Dunbar of the Finalised Local Plan. The main area of non-compliance between the proposed development and the development plan policy is Policy DC1: Development in the Countryside and Policy BUS 5: Proposals on Land Not Allocated for Business or Industry of the adopted local plan. However, it is considered that Policy W1: Oxwellmains, Dunbar of the Finalised Local Plan, which supports the development of the site for waste treatment and disposal, justifies the acceptability of the proposal. Further justification for the site location is also provided in the site selection exercise submitted in support of this application.



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7. Conclusions This Section provides a summary of key issues.

7.1 Environmental Effects The findings of the Environmental Impact Assessment for the Facility concluded that the effects of the development are not considered to be significant as a result of proposed mitigation. The impacts which could be considered to be contentious (landscape and visual, air quality/human health) have been fully mitigated as a result of the iterative design process and through careful consideration of emissions control and abatement techniques and high quality architectural and landscape design.

7.2 Sustainable Waste Management

The proposals if granted planning permission would providing suitable and sustainable waste management infrastructure for the ELSB Region and provide the following benefits: � the Facility offers a safe and sustainable alternative to landfill for residual

wastes from local homes and businesses that are leftover after recycling and composting has been carried out;

� circa 22.7MW of electricity will be supplied annually to the National Grid; � the proposed site is already located within an operational landfill, complete

with a dedicated rail siding. Using a rail link significantly reduces the need for traffic movements and is more sustainable;

� the proposed site has excellent access to the road network, namely the A1; � a large proportion of the residual waste from the target area is already coming

to Oxwellmains Landfill (from Edinburgh and East Lothian);

� the Facility will enable National Targets on landfill diversion, to be met or even exceeded and therefore costly fines avoided;

� the Facility will offset the significant economic impact of landfill tax ( £48 per

tonne in 2010), which would otherwise be passed onto council tax payers; � the Facility will be situated on brownfield land resulting from past quarry

operations and the backdrop will be the Lafarge Cement Works and Torness Nuclear Power Station;

� the proposed site is situated 4.5km to the south-east of Dunbar town centre

and as a result only a limited number of dwellings are in close proximity; � the Facility has the potential to supply heat and power to local homes and

businesses, which will improve resource efficiency and offset reliance on fossil fuels;

� the CHP aspect of the proposed development may act as a catalyst for future

economic growth within the area;



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� development of the Facility will provide employment for approximately 47 new permanent staff and additional contract/temporary staff;

� the local economy will benefit from additional employment and be sustained

by wages and salaries received and spent in the local economy by people directly employed on the operational site, and through the use of local services; and

� the proposed Facility meets the criteria of the LBAWP BPEO in respect of

providing a solution for the treatment of residual waste. The proposals are demonstrably of a high quality and in line with planning and waste management policy at all levels. They are also considered to provide an overall environmental benefit. The carbon footprint assessment demonstrates that the Facility would provide an estimated positive impact on the greenhouse gas emissions footprint in comparison to the current waste disposal route. For these reasons, the Planning Application should be supported so that the infrastructure can be provided to drive forward sustainable waste management both in the ELSB Region and in Scotland as a whole.



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Appendix 1 – Further Information on the Applicant



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Corporate Responsibility Viridor's parent, the Pennon Group, publishes an annual report on its corporate responsibility for environmental and social issues. The 2007 report provides a valuable source of information on performance across the entire organisation. The Group is fully supportive of the Government's aim of moving towards sustainable waste management, through better waste minimisation, reuse, recycling and recovery. Viridor works closely with its public and private sector partners and clients to help achieve the Government's waste strategy targets. The Group's main corporate responsibility priorities are the environment, occupational health and safety and governance, and Viridor's performance is shown in the report. Viridor also reports annually against the Environmental Performance Indicators for the Waste Industry, developed by the Green Alliance.

Environmental Responsibility

Viridor is committed to the principles of environmental sustainability. It demonstrates environmental and social responsibility and leadership by operating all facilities and services to the highest environmental and professional standards. Specifically, the Company is dedicated to meeting the following aims:

� continuous improvement in environmental performance, maximising environmental

benefits and taking all necessary steps to prevent pollution; � setting and monitoring of objectives and targets that reduce negative impacts on the

environment and augment positive impacts; � using energy and natural resources more efficiently and encouraging the

development and use of alternative fuels and recycled products; � identifying and implementing, environmental improvement schemes to benefit the

public, stakeholders and employees wherever possible; � achieving and maintaining registration to EN ISO 14001 (Environmental Management

System), the highest available international standard; � complying with all relevant legislation, including environmental and health and safety,

which represents the minimum standard; � providing training and information for all employees so they gain a better

understanding of health, safety and environmental issues and the company's commitment, policies and programmes for protecting and enhancing the environment;

� proactive consultation and dialogue with the public, stakeholders and employees on the company's environmental performance; and

� effectively communicating the policy to all employees and other stakeholders.

Environmental Management

Viridor is an experienced waste management company committed to meeting or exceeding environmental performance standards as specified in any planning permissions and any other relevant consents or authorisations, for example PPC Permits.

Viridor was the first company in its sector to gain ISO14001 accreditation (the highest available international standard) at all of its major operational sites. Forty four centres are currently accredited, covering 108 operational sites. The EMS is introduced immediately, whenever the Company takes over existing facilities or opens new ones. This system would



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be applied to the Facility, ensuring continual improvement in environmental performance and providing assurance to customers and communities alike.

The operator will also apply a maintenance programme to ensure high performance from the plant. A comprehensive programme of plant condition monitoring will be implemented. A skilled internal team will carry out daily maintenance that will be supplemented by specialist external resources as required.

Relevant Case Studies

Viridor has a considerable track record in delivering large infrastructure projects some of which are provided below.

Lakeside Energy from Waste Plant

Viridor has joined forces with Grundon Waste Management Ltd and set up a joint venture company, Lakeside Energy From Waste Limited, to build and operate an energy from waste plant near Slough. The plant will have a capacity of 400,000 tonnes per annum. Investment is projected to be £160m in the period to 2008. The facility will assist local councils in meeting their landfill diversion targets and avoiding penalties under the Landfill Allowance Trading Scheme (LATS). It will also provide power generation capacity of 32 megawatts of electricity which will be fed into the national grid. The plant will be built at Grundon's strategically located site at Colnbrook, which has relevant permissions and permits in place. The plant is scheduled to be commissioned mid-2008.

Devon Composting Partnership

The Devon Composting Partnership comprises Devon County Council, Mid Devon District Council, South Hams District Council, Teignbridge District Council, Viridor and Devon Waste Management. A successful bid by The Composting Partnership for £5.6million from Defra's Waste Minimisation and Recycling Fund has enabled the implementation of kerbside collection of organic waste from over 120,000 households in Mid Devon, South Hams and Teignbridge District Council areas and the construction of two in-vessel composting facilities at Viridor sites (Heathfield and Broadpath). Heathfield in-vessel composting plant is the first of a network of facilities that will be required in Devon to recycle biodegradable waste such as food and garden waste throughout the County and enable the Council to achieve the increasingly tough recycling/composting targets set by the Government and the European Union. Composting about 25,000 tonnes a year, the facility became operational in 2005 and is Animal By-Products Regulations compliant. The compost produced will be used primarily for land restoration in the surrounding area. This project shows what a strong partnership can achieve in a short time. Viridor is committed to helping Devon meet its targets by recycling the collected organic waste from local households and producing a good quality compost for agriculture and land restoration. Current Dunbar Landfill Operation: A Rail Transport Solution Dunbar Landfill Site, East Lothian is a fully operational landfill site complete with custom-built rail terminal utilised to serve a 150,000 tonnes per annum waste-by-rail disposal contract with City of Edinburgh Council. This significantly reduces road traffic movements and associated atmospheric emissions. With the potential to develop rail connections at three other waste facilities, Viridor has the capability and experience to promote and deliver more rail-based transport solutions.



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Materials Reclamation Facilities (MRF)

Viridor now operates a total of thirteen MRF across the UK, recovering materials from industrial, commercial and domestic waste streams. These include Masons MRF, a pioneering facility near Ipswich. Masons serves the Suffolk Recycling Consortium, made up of six local authorities and has recently undergone a substantial £2 million upgrade to install cutting-edge mechanical sorting technology, meeting today’s demanding processing standards. The contract between Viridor and the Suffolk Consortium won the Best Local Authority and Industry Partnership awards in the 2005 DEFRA-sponsored Awards for Excellence in the Waste and Recycling Industry. Other MRFs include facilities in Manchester, Glasgow, Edinburgh, Sheffield, Bristol, Kent and Cornwall. Materials recovery rates at these facilities can exceed 90 per cent of inputs. The Company also undertakes significant recycling at some of its commercial waste transfer stations.

Reclaim West Sussex Reclaim West Sussex is a partnership of all the local councils in West Sussex working with Viridor Waste Management. The partnership was formed when Viridor secured a 25 year PFI waste handling and recycling contract with West Sussex County Council. It is committed to improving waste recycling facilities and is working to achieve a target of 45% of household waste being recycled by 2015. In order to achieve the 45% target, Reclaim West Sussex needs to update existing essential recycling and waste facilities within the County, and to provide new ones. Nine proposals for new and improved sites have been progressed. Achievements include: Littlehampton, Bognor, Billingshurst HWRS’s – all built & operational, Westhampnett and Crawley new transfer stations and HWRS’s – 10 currently under construction, Burgess Hill transfer station and HWRS – planning consent granted, Ford MRF and Lancing transfer station -applications submitted.

Exeter CHP Plant, Devon

The Exeter CHP Plant in Devon was recently given planning permission by Devon County Council. By using the heat produced, the facility will increase its overall thermal efficiency. Viridor will aim to provide renewable energy at a steady price, protected from the volatility of the prices of fossil fuels.

Due to the need for pipework, potential users of the heat need to be in relatively close proximity to the plant and the Exeter facility offers the possibility of providing energy to a number of potential users. Viridor is to hold further discussions with potential customers and intends entering into commercial and technical agreements with local energy consumers. One possibility is a nearby rendering plant which is a strategically important business which needs reliable and economic energy provision.

Another possibility is a metal finishing company which requires heat to operate its plating process. The Company currently obtains its heat from natural gas and by utilising heat from the EfW plant this would improve thermal efficiency and reduce the plating plant’s carbon footprint. Due to the development being in the early stage discussions are still being undertaken to bring this to fruition.



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Appendix 2 – List of Consultees



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1. Statutory Consultees – these are issued direct by East Lothian Council East Lothian Council – including: Head of Planning Regeneration Department/Officer Environmental Health Officer Highways Department Development Plan Officer Natural Heritage Planner Head of Waste Management Council Archaeologist Landscape Architect Scottish Natural Heritage SEPA Historic Scotland Scottish Executive Scottish Executive Highways Department (Trunk Roads) Scottish Water Scottish Power Health and Safety Executive Defence Estates Scottish Borders Council – Landscape Architect

2. Non-Statutory Consultees – these will be issued direct by RPS

Local Community Councils Dunbar Community Council West Barns Community Council Lammermuir Community Council

Local Interest Groups East Lothian Local Access Forum Lothian Bat Group Lothians Bird Club East Lothian Heritage East Lothian Biodiversity Lothian Health Board East Lothian Health Care Network Rail Site Liaison Group – Dunbar Landfill

National Interest Groups

Scottish Wildlife Trust RSPB Other

Lafarge Cement Works Torness Power Station

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