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Wrights Pit North
SLR Consulting Limited
Isle of Man Time Extension to Existing Landfill Facility, Additional Imports and Revisions to Restoration scheme
Non Technical Summary (NTS)
Department of Local Government and the Environment
December 2009 SLR Ref: 403-0189-00087
10.1 This Planning Application \& Environmental Statement (PA\&ES) has been prepared by SLR Consulting Limited (SLR) on behalf of the Department of Local Government and the Environment (DoLGE) of the Isle of Man Government in respect of a scheme to extend the period of time in order to continue landfilling operations and implement a revised restoration scheme for the landfill site at Wright's Pit North, Point of Ayre. 10.2 The site, which currently receives inert and mixed construction and demolition waste, operates under planning permission (Ref:PA2/1636) which requires landfilling operations to cease by the 31st December 2008 and for the site to be restored by the 31st December 2009. The full description of development is set out below: 'Continuation of existing waste operations for a 5 year period at c.2,000tpa plus 1 year for restoration and implementation of a revised restoration landform at Wrights Pit North, Point of Ayre.' 10.3 The permitted restoration scheme for the site was in the process of being implemented in late 2009 when it is understood that due to budget restructuring on the Isle of Man (loM) following the UK Government's recent VAT payment demand, various loM infrastructure projects, including the restoration scheme at Wrights Pit North, have undergone budget review. The restoration works for Wrights Pit North, of which the Stage Reports 1 to 3 for the restoration works at Wrights Pit North were submitted and approved have therefore been temporarily suspended and this application is therefore being submitted to extend the timescale for the existing waste operations and to maintain the existing facility. 10.4 During the Environmental Impact Assessment (EIA) process close consultation was maintained throughout with key personnel within Government Departments in order to agree the scope of investigations and surveys and to review potential impacts and appropriate mitigation measures. Following pre submission discussions with the Planning Department is was agreed that it would be appropriate to reference the 2006 Planning Application \& Environmental Statement (PA\&ES). The technical sections included within the 2006 ES are there referred to, as are the various assessments, however where required the data and assessments have been updated. 10.5 This Non Technical Summary (NTS) document contains, in non-technical language, a summary of the proposed development together with the likely effects that it will have on the environment.
10.6 The site is located at the northern end of the Island at Point of Ayre, at the end of the A16 just south of the lighthouse, in the Local Authority district of Bride. The site lies 4 km north of the village of Bride and is centred at NGR NX 463046.
10.7 The area of Wrights pit North is rectangular in shape, approximately 230 m by 200 m surrounded by a 2 m high chain link fence with the access located on the south eastern boundary. No buildings or site infrastructure is located at Wright's Pit North. Vehicles accessing the site use the office and weighbridge facilities located at the adjoining mineral workings west of the site, before continuing the short distance eastwards to the gated entrance at the site. 10.8 Current levels within the site vary from between 5.5 m to 6.5 m in the eastern half of the site where the majority of the waste has been deposited. This area of the site is referred to as Cell 2 and has been restored. Levels on the western half of the site are between 2 m and 3.5 m where less waste has been received. This area of the site is called Cell 1 and the topography represents a bowl shape.
10.9 The site was initially worked for sand and gravel by Island Aggregates (now CEMEX), and subsequently used as a landfill by DoLGE. The original planning application for landfill development within Wright's Pit East and Wright's Pit North was submitted in February 1996 and permission for both sites was granted in 1996 following a public inquiry. This permission required landfilling operations to be completed by December 2000. 10.10 A planning application to vary the 1996 permission for Wright's Pit East was submitted in November 1999 and following a public inquiry in May 2000 planning permission for the amended Wright's Pit East scheme was granted in July 2000. This permission allowed landfilling operations to continue until 31 December 2003 with restoration to be completed by 31 December 2004. 10.11 By December 2000 landfilling operations had not yet commenced in Wright's Pit North, but the earlier 1999 application for Wright's Pit East had identified the importance of the North site as a strategic reserve. Therefore in December 2000 a planning application to amend the landfill profile, capping and completion date for Wright's Pit North was submitted. This application was granted permission in November 2001. Planning consent (Ref.02/1636) was granted in May 2003 as an amendment to extend planning permission for landfill operations at Wright's Pit East and Wright's Pit North. This extended the period for landfilling at both sites to the 31st December 2005 with restoration to be completed by 31st December 2006. 10.12 In 2005 waste disposal operations were completed at Wright's Pit East and that site underwent restoration work to restored the area to Gallic heathland. At this time due to an increase in recycling the quantities of construction and demolition waste reduced across the Island. and the volumes of material proposed for disposal at Wrights Pit North count not be achieved in the period required. The previously approved restoration contours could therefore not be achieved. An application was therefore submitted to continue importation of waste to enable a satisfactory alternative final landform to be achieved and to enable the Government to continue to provide a disposal facility for wastes collected by the local authorities which
could not be recycled or incinerated. Planning consent was subsequently granted on 11th August 2006 to extend the time for landfilling operations until the 31st December 2008, with restoration to be completed by the 31st December 2009.
10.13 It is proposed to continue waste disposal operations for a further 5 years plus 1 year for restoration at a projected input rate of c. 2000 tonnes per annum (tpa). The imported material will remain as per the existing license comprising mixed inert and C\&D (construction and demolition) wastes and waste operations and management of the site would remain as per existing. The projected inputs and increased timescale will necessitate an amended alternative restoration scheme and this is also included within this planning application. This proposal therefore seeks the following:
10.14 The waste to be imported will be, as currently permitted, predominantly, , inert with the remaining comprising Civic Amenity (CA) waste including green waste, wood, paper, glass and metals. The site will not accept either household (black bag) waste or incinerator bottom ash. 10.15 The current approved scheme for the site (under planning consent PA02/1636) divided the site into two phases, Cell 1 (on the west of the site) and Cell 2 (on the east). The eastern phase of Wrights Pit North has been restored in accordance with the approved scheme. The 10,000 tonnes of waste to be disposed of over the five year period (at approximately 2,000tpa) will therefore be placed in the western phase (Cell 1). This will ensure that site operations take place at a lower level and so benefit from the screening provided by the current landform, which will limit the impact of the operations on the surrounding area. 10.16 Whilst it has been necessary to revise the permitted restoration landform to take account the proposals for additional material being placed in the western half of Wrights Pit North, the proposed landform is broadly identical to the approved scheme, as is the restoration scheme and methodology, and when implemented, will allow opportunities for enhancing the anticipated ecological value of the site through the incorporation of a broader range of ground conditions and habitats. 10.17 In all other respects site operations will remain as per the current planning consent and waste licence. Hours of operation will be as per those currently
permitted and will be restricted to ensure that waste deliveries avoid school traffic arrival and departure times in Bride.
10.18 The development proposals have been considered against the current planning policy documents for the Isle of Man. The current Plans relevant to the proposed development include the Isle of Man Waste Strategy, the Isle of Man Waste Plan, and the Isle of Man Strategic Plan. 10.19 The Waste Strategy and Plan provide the strategic future plans and aims for how the government and local authorities will deal with waste during the period of 2000-2020. The Strategy for the island includes implementing the Waste Hierarchy and diverting municipal and commercial waste to the new EfW facility which is currently the case. However the Strategy recognises that there are some wastes that cannot be dealt with by methods higher up the waste hierarchy and that certain wastes can only be disposed via landfill. It is acknowledged that historically the site provided a facility on the island for the disposal of residual hazardous waste. The need for this facility continues and it is necessary in order to deal with residual hazardous waste produced. 10.20 Policies within the Strategic Plan concerned with the Environment, Waste and Transport have been considered against the proposed development. It is considered that the development accords with the aims of the Strategic Plan to protect the environment and minimise the impact of development on local residents.
10.21 This application is being submitted to extend the timescale for the existing waste operations and to maintain the existing facility for disposal of residual wastes which cannot undergo incineration. Currently such wastes (comprising asbestos and contaminated soils - approximately 200 tonnes) are being temporarily stored in containers and waste skips at various locations around the island and it is therefore anticipated that these materials, along with additional arisings will be disposed of at Wrights Pit North following grant of planning consent for continuation of the waste operations. 10.22 Although landfilling is at the bottom of the Waste Hierarchy it is a fundamental element of any integrated waste management strategy, underpinning techniques further up the hierarchy such as recycling, recovery, etc. While alternative technology therefore exists, and is utilised on the island, the need for disposal facilities for residual wastes therefore remains.
10.23 This assessment has employed a qualitative risk assessment methodology, in which the probability of an impact occurring and the magnitude of the impact, if it were to occur, are considered. This approach provides a mechanism for identifying the areas where mitigation measures are required, and for identifying mitigation measures appropriate to the risk presented by the development. 10.24 Wright's Pit North Landfill is a non-engineered landfill that has been developed on a dilute and attenuate basis. The landfill is located in a 5 to 6 m deep void, developed during quarrying of the unsaturated sand and gravel strata of the Point of Ayre Formation. These underlying strata form a highly permeable, unconfined aquifer that extends throughout the Point of Ayre. The base of the landfill lies close to the water table of this aquifer. Groundwater flow direction below the site is towards the coastline, ultimately discharging into the sea. 10.25 The existing historic dilute and attenuate municipal landfills (Ballacallow Phases 1, 2 and 3), which are located up gradient of the site, are having a slight impact upon the groundwater within the underlying unconfined aquifer. 10.26 Given the nature of the proposed development compared to the existing development, the potential unmitigated impacts on the hydrogeological environment would be associated with:
10.27 Potential impacts associated with the extended period of landfilling and restoration should not be significant given that the waste stream would remain unchanged and the waste volume at the landfill is significantly less than was originally approved by previous planning consents, and provided that the previously identified mitigation measures (technical precautions) are continued at the site. 10.28 Given the above assessment, it is considered that the following mitigation measures would need to be continued at the site:
10.29 There should be no residual impacts associated with the proposed application site, based on the above noted development proposals and identified mitigation measures.
10.30 An assessment of the impacts on the local road and transportation network as a result of the development proposals has been undertaken. The Point of Ayre has been characterised by mineral extraction and landfill operations for a number of years. Until recently, both Wrights Pit North and Wrights Pit East, together with the CEMEX Quarry were fully operational and generating HGV (Heavy Good Vehicle) traffic. Wrights Pit East is now restored, there would be no additional HGV movements on the network from the CEMEX waste disposal scheme as those vehicles would backload material (i.e. waste would be transported to the site by returninmg empty mineral wagons). 10.31 The development proposals would result in approximately 2 HGV and 2 / 3 light vehicles accessing the application site per day. In light of the cessation of landfill activities at Wrights Pit East, future traffic levels on the surrounding road network will be significantly less than in recent years, even when taking into account the traffic generated by the application site. 10.32 All highway links and junctions within the study area have been shown to operate well within capacity and would do so when taking into account future traffic generated by the application site. It is therefore considered that the highway network will not be affected by the proposed development.
10.33 A landscape appraisal and visual assessment of both the existing site and the proposed development has been carried out in accordance with local planning guidance and UK landscape and visual assessment guidelines. 10.34 The application site is already extremely disturbed by previous mineral and landfilling operations and is consequently not sensitive to the type of development proposed. 10.35 The proposed development would also not result in a significant spatial or temporal extension to the existing landfill facility. Final restoration of the site would have the same duration and the result as per the approved scheme. Therefore, the only additional landscape and visual impacts arising form the proposed development, in comparison with the existing permitted development, would be a short extension of time, up to five years, for the existing landfill operations and a relatively modest alteration to the final restoration landform. 10.36 The proposed development, and subsequent restoration works, would be confined to the western half of Wrights Pit North, and the final landform and scheme would be consistent with the character and form of the permitted scheme. Overall the proposals, as with the existing scheme, are considered
to pose a moderate improvement to the existing character and condition of the site. Both the permitted and proposed schemes would result in the removal of the site perimeter fence, which is the most visible aspect of the existing site. 10.37 The proposed development would support the relevant planning policies and overall it is therefore concluded that the development would not cause unacceptable landscape and visual impacts.
10.38 The site comprises an active permitted landfill that occupies a former sand and gravel pit at the Point of Ayre. The Point is dominated by a beach ridge topography upon which is Gallic heathland. Also within this setting are former mineral workings where flooding and natural colonisation has led to an increase in the biodiversity and nature conservation value of the area. 10.39 The proposed development would not lead to any further loss of habitat to that already permitted. The habitats present are those of an operational landfill and as such they are of negligible value to flora and fauna. There would, due to the mitigation adopted so far as part of the previous applications and development at the site, be no further impact upon protected species or populations of ecological importance. 10.40 The proposed restoration scheme is almost identical to the approved scheme and continues to provide a habitat that fits into the existing Gallic heath dominated landscape but also provides an environment similar to that lost prior to landfilling. As the scheme did not result in the removal of Gallic heath it is considered unlikely that the delay in the delivery of this habitat as part of the restoration scheme shall have any adverse impact upon those species present in the vicinity. Though the restoration of the area to such habitat is considered to be a significant benefit it is considered that the sustainability of the surrounding habitats and fauna and flora supported by them would not be compromised by a delay in its delivery. 10.41 The provision of low lying areas where natural colonisation can occur could potentially lead to the re-establishment of protected and notable plant species. The proposed restoration scheme is considered to provide a more diverse and valuable feature for flora and fauna.
10.42 Detailed information on how the disposal operations will be controlled and managed for the purposes of waste licensing reference is included within the Working Plan which will be submitted directly to the Licensing Authority Environmental Protection Section Department of Local Government and the Environment. 10.43 The review in the Planning Application \& Environmental Statement (PA\&ES) of environmental effects of the proposed development identifies that there
would be no unacceptable environmental effects arising from the continuation of landfilling operations at this location. Details of specific issues are outlined and addressed below:
10.44 The site is remote from dust sensitive properties and will be receiving much lower quantities of waste then has previously been the case. It is therefore considered that the continuation of landfilling operations is unlikely to have any unacceptable adverse effects in respect of dust. 10.45 Notwithstanding this it is still considered appropriate to ensure that good site management practices are applied to the operations. The site manager will be responsible for the day to day control and will ensure that if activities are generating excessive levels of dust that they are suspended until either weather conditions improve or effective dust suppression measures are implemented.
10.46 The potential for the site to generate unpleasant odours has been assessed in the 2006 Environmental Statement and previous submissions by having regard to the distance to sensitive receptors; the prevailing wind direction; the largely inert nature of the wastes to be accepted and the application of standard good site management practices. 10.47 The material to be imported through these proposal will be similar and will not comprise either household (black bag) waste or incinerator bottom ash and therefore the potential for odour to arise through material importation or decomposition of materials is considered to be limited. On this basis it is considered that the continuation of landfilling operations at this location should not have any unacceptable adverse odour impact.
10.48 The site is within close proximity to an active sand and gravel operation, permitted landfill operations and is remote from residential properties. The day to day operation of the landfill would be relatively low key with a low level of plant use. This combined with the simple nature of site operations, which involve delivery and deposition of relatively small quantities of waste mean that there is limited potential to generate unacceptable levels of noise. It is therefore considered that noise levels generated by the continuation of operations at this location will not pose a significant risk to the local environment.
10.49 Given the nature of the wastes (i.e. no household or bottom ash) to be accepted at the site it is considered that the potential for the operations to attract vermin or generate litter is limited. Existing arrangements for the control of litter, including the perimeter fence and the regular collection of
any litter that is blown outside of the operational area of the site, will be maintained.
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