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THE REVIEW OF NPPG4 LAND FOR MINERAL WORKING

CHAPTER 8. GUIDELINES FOR RECYCLED AND SECONDARY AGGREGATES

8.1. Since the publication of NPPG4, government policy has placed greater emphasis on increasing the amount of recycled and secondary aggregates used in construction. 'Recycled' aggregates refer to aggregates that have been used previously in construction (construction and demolition wastes, asphalt road planings and used railway ballast). 'Secondary' aggregates are by-products of other processes and will not have been used previously as aggregates (e.g. colliery spoil, power station and incinerator ashes).

8.2. The aim of this policy, rooted in the UK Strategy on Sustainable Development, is to minimise the consumption of primary resources and the environmental impacts associated with primary extraction and waste disposal. This policy emphasis is also highlighted in the National Waste Strategy for Scotland (1999) and most recently translated into land use planning in NPPG10: Planning and Waste Management (1996).

8.3. Construction and demolition wastes account for some 50% of controlled waste in Scotland and take up significant landfill space. In addition, there are significant stockpiles of materials from past industrial processes. One of the most prevalent in Scotland is spent oil shale, with recent estimates indicating that around 100,000kt of spent oil shale is stored in tips in the eastern central belt of Scotland.

8.4. The planning system is the main means by which the provision of an adequate network of facilities for the production of recycled and secondary aggregates can be developed. This is acknowledged in the current version of NPPG4, which states that:

• planning policies should provide for the reworking of mineral waste deposits and the recycling of demolition and construction wastes. The latter may require the identification of areas for their storage and processing (para. 53);
• Local Plans should, where appropriate, include policies and identify areas which provide for the re-use of materials in waste tips and construction wastes (para. 96).

8.5. This is reinforced in the National Waste Strategy (1996), which stresses that "local authorities should put in place policies which ensure that they support the development of the network of waste management facilities needed" (pg. 23).

8.6. However, planning for the provision of aggregate recycling sites requires accurate and up-to-date information on the supply of, and demand for, recycled materials. In recognition of this, the Scottish Executive has recently undertaken research to identify the current baseline position for the production and use of recycled and secondary aggregates in Scotland and to determine the way forward for future regular surveys4 ¹¹. The research revealed that in 1998, there were approximately 9,000kt of waste arisings with the potential for reuse as aggregate. It was estimated that approximately 5,000 kt were landfilled and 4,700 recycled (the totals landfilled/ recycled exceed arisings due to the recycling of old or imported industrial wastes). Eighty five percent of the recycled material was reused in low utility applications. Other key findings include:

• a general expectation that the Government should take the lead in increasing the use of recycled aggregates;
• the identification of considerable potential for not only increasing recycling, but for increased recycling in higher quality uses to maximise the economic and environmental gain from recycled aggregates;
• the existence of a number of obstacles to the greater use of recycled and secondary aggregates, including specifications/standards, the complexities of the Waste Management Regulations, 1994, and market related factors (including the plentiful supply and therefore relatively low price of primary aggregates).

8.7. The research concluded that it is hard to set recycling targets in terms of an annual tonnage as the total amount of recycling in any given year is likely to fluctuate with economic activity. This difficulty is compounded by the fact that a significant proportion of Scottish aggregate production is destined for export markets (although this may change in future). The following 'achievable and challenging' targets were suggested for recycling as a percentage of the amount of aggregates reserved for consumption in Scotland:

• 20% of production available for consumption in Scotland in 2000;
• 27% in 2003; and
• 36% in 2006.

8.8. This represents a 10% year-on-year increase, and assumes current levels of waste arisings remain constant.

8.9. Consultation with industry representatives revealed a number of criticisms about the data upon which the findings and recommendations of this research are based, and as a result, a concern that any policy arising from this research could be inappropriate. For example, it was argued that given current market conditions, there is little scope to further increase the quantity of materials recycled (this may change following introduction of the Aggregates Tax). However, it is generally acknowledged that the compilation of statistics on the production and use of recycled and secondary aggregates is a difficult task and that the research represents an important 'first step' in obtaining accurate and up-to-date information on the supply of, and demand for, recycled materials.

8.10. Several operators also highlighted the fact that there are significant regional differences in geography, population and patterns of economic activity across Scotland and that future policy on recycled and secondary aggregates would need to take account of this. There is also considerable support amongst operators for the view that planning is a 'blunt instrument' and may not be suited to some aspects of policy making, particularly on matters which require informed, commercially based judgements. Despite this, it was felt that greater coverage of this issue in NPPG4 could further facilitate recycling activities. Suggestions for further coverage included stronger linkage to waste management and the inclusion of firmer national level targets or assumptions about the levels of recycling. This was supported by a number of NGO interests.

8.11. The reuse of oil shale bings is a particular issue in West Lothian and East Ayrshire. In both areas, the reworking of bings could provide scope for a large supply of secondary aggregates, and also contribute to environmental enhancement. However, there is a need to consider in more detail the general and specific environmental effects which such operations can imply.

8.12. The questionnaire responses revealed strong support amongst local authorities for:

• further policy support to encourage the production of recycled and secondary aggregates (i.e. to establish 'need');
• additional guidance on identifying suitable sites for the processing of recycled and secondary aggregates, in terms of location and size;
• additional guidance on controlling the environmental effects associated with the production of recycled and secondary aggregates; and
• an update of the guidance to reflect more recent improvements in technology (e.g. the increased 'mobility' of crushing and screening plant).

8.13. A number of local authorities feel that this is an area where there is likely to be greater activity in future and that the land use planning implications of the research and technological advances that have taken place post-1994 should be widely disseminated. Further information is requested in relation to the relative merits of on-site recycling versus the development of 'strategic' processing sites, and the provision of Informatives on the practical contribution and limitations of recycled materials. Several respondents also requested further clarification with regard to the linkages with the National Waste Strategy and the production of Area Waste Plans.

8.14. Half of the local authority respondents had referred to NPPG10: Planning and Waste Management (1996) for additional guidance on planning for the production of recycled and secondary aggregates. Only a small number of these felt that NPPG10 conflicts with the guidance/advice contained in NPPG4 (largely due to the different 'ages' of the guidance), provides stronger policy support for the production of recycled and secondary aggregates, or provides supplementary guidance on siting and/or controlling environmental effects. Two authorities cited examples of complementary measures to support recycled and secondary aggregates production. One authority currently 'trades' demolition materials between different projects, whilst another explained that this was being progressed through the Area Waste Strategy.

8.15. The National Waste Strategy for Scotland (December 1999) states that the choice of waste management options should be informed by the use of 'BPEO' (Best Practicable Environmental Option) as a decision-making tool, and that local authorities should take account of guidance on BPEO ¹²:

• in preparing Structure Plans, local authorities should take account of the principles of sustainable waste management, published guidance on BPEO and policy guidance in NPPG10 (pg 30); and
• Local Plans should include specific policies or criteria to allow proposals for waste management facilities to be assessed, including demonstrable need and compatibility with BPEO (pg. 31).

8.16. The overwhelming majority of local authority respondents felt that NPPG4 should provide additional guidance on determining whether recycled and secondary aggregates production represents the BPEO for aggregates supply. For example, in relation to one northern authority, it was stated that there is an imperative to explore and develop recycling, when for this region recycling may not be more sustainable than primary extraction.

KEY ISSUES

• there is an increased policy emphasis on the production and use of recycled and secondary aggregates and this should be reflected in any revisions to NPPG4.
• recycling activities are influenced by a range of economic, technical and regulatory factors. However, land use planning has a role to play in the provision of an adequate network of facilities for the production of recycled and secondary aggregates.
• whilst there are concerns about the availability of information on waste arisings and reuse, the development of targets for the production of recycled and secondary aggregates is supported. These should be reflected in planning policy guidance and should take account of acknowledged regional differences.
• there is strong support for the inclusion of further practical guidance in NPPG4 on identifying sites for the production of recycled and secondary aggregates, controlling environmental effects and on determining whether recycled and secondary aggregates production represents the BPEO for aggregates supply.

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