Letter from Dr David Dickerson, Principal Sustainability Consultant, to Mr David Trigwell, Head of Planning at BANES

24 Highmead Gardens,

Bishop Sutton,


BS39 5XB.

Tel: 01275 332746Mob: 07766331146

12 September 2011

Dear Mr Trigwell,

I am writing in relation to the planning decision of 7 July 2011 regarding the decision in favour of disposal of asbestos waste by landfill at Stowey Quarry.

I understand that the decision making process involved consideration of the West of England (WoE) Joint Waste Core Strategy (JWCS). The JWCS did not identify a need for such hazardous waste disposal facilities because there were sufficient facilities within the South West region as a whole and therefore the (WoE) would continue to export this waste stream to other areas. However, national waste policy in PPS10 recommends that waste should be disposed of at the nearest appropriate facility (the proximity principle) and a strategic objective of the JWCS is that communities and businesses of the WoE take responsibility for the waste they generate. Stowey Quarry would provide such a facility in the WoE and would therefore satisfy PPS10.

Section 6.10.10 of the JWCS states in relation to Hazardous Waste Landfill: "There are no hazardous waste landfill facilities within the plan area. Such specialist facilities are recognised as being facilities of regional and national importance. There is no identified strategic need for new hazardous waste landfill capacity within the plan area; however policies 8 and 9 provide the relevant framework to enable the sub-region to meet its own needs." However, the Environment Agency (who issue permits and regulate hazardous waste landfill facilities) shows that there are already 2 sites in WoE permitted for the disposal asbestos waste, Avonmouth (up to 20,000 tonnes pa) and Yanley (up to 6,000 tonnes pa) (see the spread sheet from the link on the Environment Agency web site showing Permitted Landfills accepting hazardous waste and gypsum (calcium sulphate in plaster and plasterboard) of June 2009 at: http://www.environment-agency.gov.uk/business/topics/waste/32148.aspx)

There is thus provision for up to 26,000 tonnes pa of asbestos waste in current hazardous waste landfill facilities in the WoE.

Policy 8 of the JWCS includes: 2. the proposed development involves the minimum quantity of waste necessary to deliver the sub-region's needs Quantities of asbestos waste produced in the SW region and WoE sub-region in 2010 are available from the Environment Agency at: http://www.environment-agency.gov.uk/research/library/data/132647.aspx#South_West

This shows that less than 7,000 tonnes of construction, demolition and asbestos waste (European Waste Category (EWC) 17) was produced and 1,200 tonnes disposed of in the WoE in 2010. The current capacity to receive asbestos waste is therefore at least 3 times greater than the amount currently produced in the sub-region. By applying the proximity principle, it is likely that asbestos waste produced in Bristol and South Gloucestershire would be disposed of at Avonmouth and Yanley whilst waste produced in North Somerset would be disposed of at Avonmouth or Bridgwater. The only district that would benefit from an asbestos disposal facility at Stowey would be BANES, but the amount of construction, demolition and asbestos waste likely to be generated in BANES is approximately 20% of the WoE or around 1,200 tonnes per year and at this rate, it could take a very long time to fill the quarry from local sources.

The total amount of construction, demolition and asbestos waste produced in the whole of the south west region ( Cornwall , Devon, Dorset, Somerset , Wiltshire, West of England and Gloucestershire) amounted to 55,000 tonnes in 2010. The approval of the disposal of 650,000 tonnes of asbestos waste in Stowey Quarry over 10 years (65,000 tonnes per year) exceeds the sub-region's needs by a factor of at least 10; this could hardly be described as "the minimum quantity of waste necessary to deliver the sub-regionís needs" (JWCS Policy 8.2). I question how this fulfils the proximity principle and where all the asbestos waste is anticipated to come from since in the south west region there are already 10 landfill sites that are permitted to receive asbestos waste. Furthermore, since there are 42 landfill sites in England and Wales permitted to recieve asbestos waste and 8 of these (nearly 20%) are in the WoE or neighbouring counties (Somerset, Wiltshire and Gloucestershire), it is apparent that we are more than adequatly served by such facilities.

In the light of the above, I would be grateful if you would review the decision made by the planning committee as it appears that there is no need for this facility at Stowey. If the planning committee had been in possession of these facts, I think it is likely that they would have reached a different decision.

Yours faithfully,

David Dickerson BSc, MSc, PhD, MCIEH, AIEMA

Principal Sustainability Consultant.