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e) in the case of landfill sites working shall be in accordance with a phased scheme of restoration and landscaping e.1) not applicable. f) the proposal does not sterilise other significant mineral deposits f.1) existing site so not applicable. g) the proposal will not have an unacceptable adverse impact on airport safety by, for example, increasing the risk of bird strike. g.1) not applicable.
8.1 As the WPS does not identify or acknowledge for any specific type of recycling facility, we have looked to the United Kingdom as a best practice guide.
8.2 Article 4 of the EU Waste Framework Directive 2008/98/EC sets out the following 5 steps in dealing waste (the waste hierarchy) with the highest priority at the top:
8.3 The Department of the Environment Northern Ireland (DOENI) document Applying The Waste Hierarchy: Evidence Summary 2011 (see appendix 2) states that:
8.3.1 Article 4(2) of EU Directive 2008/98/EC allows Member States to depart from the hierarchy for specific waste streams in order to deliver the best environmental outcome. However this has to be justified by life cycle thinking on the overall impact of generating and managing these waste streams.
8.3.2 Life Cycle Assessment evidence suggests that for food waste, wet or dry anaerobic digestion is better than other recycling and recovery methods.
8.3.3 Options for the treatment of food waste include, in order of environmental benefit (greatest at the top)
8.3.4 The combination of outputs (biogas and digestate) makes anaerobic digestion environmentally preferable to composting.
8.3.5 Food waste is combustible but its high moisture content means that it is best suited to anaerobic digestion.
8.4 The Department of Energy & Climate Change (DECC) and the Department for Environment Food & Rural Affairs (DEFRA) have jointly published the Anaerobic Digestion Strategy and Action Plan (ADSAP) in which the UK Government has committed to substantially increasing energy from waste through anaerobic digestion (see appendix 3).
8.5 Life-cycle assessment evidence suggests that for food waste, ‘wet or dry anaerobic digestion is better than other recycling or recovery options’ The DOENI report ‘Applying the waste hierarchy: Evidence Summary’ of 2011, page 6 (appendix 2).
9.1 The Ballaharra Quarry site has two distinct operations:
9.1.1 Mineral extraction and associated ancillary activities ie CDW waste recycling
9.1.2 Industrial use in the form of manufacturing facilities for concrete products, readymixed concrete, ready-to-use mortars and calcium silicate bricks.
9.2 This industrial use of part of the site has existed since 1972. 9.3 The AD process is industrial and would fit within the existing industrial area, namely the former calcium silicate brickplant. 9.4 There would be no material change of use as the area is already industrial. 9.5 Located within the existing industrial area, the AD plant would have no negative impact upon mineral extraction or C&D recycling.
10.1 The proposed development is for the installation of a renewable energy micro-generation facility for the recycling of decomposable waste through Anaerobic Digestion (AD) capable of processing up to 370 tonnes of biodegradable waste per annum to produce biogas, heat and digestate fertilizer.
10.2 Such biodegradable wastes are currently disposed of at the EfW. 10.3 It is recognised that AD is an environmentally better method of recycling biodegradable waste than incineration with energy recovery. 10.4 Energy recovery by AD would move the recycling of biodegradable waste higher up the Waste Hierarchy. 10.5 An AD plant would help improve the recycling of commercial waste on Island and promote a Circular Economy. 10.6 The AD operation is carbon neutral. There is a total recovery of energy as methane and fertiliser and a total recovery of water.
10.7 Anaerobic digestion is the only system for dealing with organic waste which is sustainable, recovers the maximum energy, is a completely closed system with no emissions to air or land, which retains the fertiliser and water content and facilitates the recovery of heavy metals.
10.8 The proposed development is compliant with Environmental Policy 1 & 2 as it will be sited almost entirely within an existing building which will not require any modification.
10.9 The overall solution has been selected because it promotes a circular economy, fits with the waste hierarchy and on the basis that it can meet an identified need using reliable technology that is flexible and integrated both with the different waste streams proposed to be accepted at the application site and with the existing waste facilities and infrastructure.
In preparing this submission we have consulted:
Sarah Corlett, Senior Planning Officer, DoI Stephanie Gray, Head of Waste Management, DoI Stuart McMillan, Environmental Protection Officer, DEFA
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