C:\DOCUMENTS AND SETTINGS\HANNAH.SMITH\DESKTOP\AVE DPD RESPONSE 4 FEB 2011 - ISSUE.DOCX

Ove Arup & Partners Ltd | Registered in England & Wales Registered Number: 1312453 | Registered Address: 13 Fitzroy Street London W1T 4BQ

Our ref 209196-00/HS

Admiral House Rose Wharf

78 East Street Leeds

LS9 8EE United Kingdom

t +44 113 2428498 f +44 113 2428573

hannah.smith@arup.com arup.com

Natural Resources and Waste DPD Jacobs UK 1 City Walk Leeds LS11 9DX

4 February 2011

Dear Sir/Madam

Natural Resources and Waste DPD Publication Draft Aire Valley Environmental Consultation Response

I write on behalf of Aire Valley Environmental (AVE), a joint venture of Kelda Water Services Ltd and Covanta Energy Ltd with regards to the Natural Resources and Waste Development Plan Document (NRWDPD), upon which consultation is currently being undertaken on the publication draft of the document. As you will be aware, at the same time as the development of the DPD, Leeds City Council is seeking to secure , through a PFI procurement, the building of a major treatment facility that from 2015, will provide an alternative to sending the City Council’s residual waste to landfill. AVE is bidding for this Leeds City Council PFI Waste Contract and is proposing to deliver a strategic waste management facility within Aire Valley. AVE proposes to develop the facility on its own land adjacent to Knostrop Wastewater Treatment Works (WwTW). Arup is acting as planning adviser to AVE. AVE supports the overall emphasis of the Natural Resources and Waste DPD Publication draft, including the aspirations of the City Council for Leeds district to meet its own waste management needs, whilst also accepting that some management of waste across districts might be needed for certain waste streams. AVE specifically supports the recognition that Energy from Waste has an important role to play in meeting future energy requirements. AVE believes that the document is sound. AVE is pleased that policy Waste 6: Strategic Waste Management Sites identifies the land within Knostrop Wastewater Treatment Works (WwTW) as appropriate for a strategic waste management site suitable for major residual waste treatment, including energy recovery and the co-location of other supporting facilities ancillary to the main operation. It is noted that the extent of land identified within the WwTW has been refined. However the site identified in document reference number 202 in Map D (contained within the document Map Book Sites: XC2 – Map E) does not precisely reflect the extent of the site proposed for the AVE facility. The AVE site extends marginally further southwards than

209196-00/HS

24 January 2011 Page 2 of 2

C:\DOCUMENTS AND SETTINGS\HANNAH.SMITH\DESKTOP\AVE DPD RESPONSE 4 FEB 2011 - ISSUE.DOCX

the proposed allocation shown in the DPD Map Book. Enclosed with this consultation response is an accurate site plan ref AVE Knostrop Site Boundary: Drawing Number 000 Issue P3, and it is requested that the boundary shown on Map D is altered to reflect the full extent of the AVE site. AVE is broadly supportive of the emerging NRWDPD, and also provides support in relation to the following specific policies: Energy 3: Heat and Power Energy Recovery AVE supports the contents of this policy, particularly the requirement for the proposed facility to have an identified outlet for any energy produced. Specifically, AVE supports that any energy recovery from waste should demonstrate the potential to contribute to CHP and that CHP proposals should demonstrate the potential to connect to an outlet for any energy produced. I trust these comments are of assistance in finalising the DPD. If you require any further information to assist you with this, please do not hesitate to contact me on the details above. Yours faithfully Hannah Smith Senior Planner cc David Clayton - AVE

Nigel Gould - Covanta Stephanie Walden - KWS

434000

4310

00

Job No209196-00

Drawing No Issue000 P3

Drawing StatusPreliminary

Scale at A3

Drawing Title

Job Title

Client

Admiral House Rose Wharf78 East Street Leeds LS9 8EETel +44 (0) 113 242 8498 Fax +44 (0) 113 242 8573www.arup.com

0 100 20050

Metres

Issue Date By Chkd Appd

P3 2011-01-21 ST LM AGH

\\Glob

al\eu

rope\L

eeds

\JOBS

\2000

00\20

9196

-00\0

Arup

\0-20

GIS

\Work

spac

es\Le

eds O

S Ope

n Data

map

base

Plan

ning A

3.mxd

Legend

AVE Knostrop Site Boundary!°

© Arup

Contains Ordnance Survey data © Crown copyright and databaserights 2010.

1:5,000

Aire Valley Environmental

AVE

AVE Knostrop Site Boundary

A3

Template A3: Version 2

24/01

/2011

12:01

:51

Registered Office Yorkshire Water Services Limited Western House Halifax Road Bradford BD6 2SZ Registered in England and Wales No. 2366682 www.yorkshirewater.com

Registered Office Yorkshire Water Services Limited Western House Halifax Road Bradford BD6 2SZ Registered in England and Wales No. 2366682 www.yorkshirewater.com

NRWDPD Publication Draft Consultation Response Jacobs 1 City Walk Leeds LS11 9DX 3 February 2011 Dear Sir/Madam RE: Natural Resources and Waste DPD Thank you for consulting Yorkshire Water on the Natural Resources and Waste DPD. Yorkshire Water is broadly supportive of the document and its approach and appreciates that many of our original comments in the previous consultation have been included within this DPD. I enclose a map highlighting further areas suitable for inclusion as a future waste management use. If you have any questions regarding the response please do not hesitate to contact me. Yours Sincerely, Matthew Naylor Development Planner

Land, Property and Planning Yorkshire Water Western House Halifax Road Bradford BD6 2LZ T 01274 692916 F 01274 692643 E Matthew.Naylor@yorkshirewater.co.uk

Response by Yorkshire Water to Leeds Natural Resources and Waste Development Plan Document- Publication Document Yorkshire Water (YW) has an interest in all parts of the Natural Resources and Waste Development Plan Document (NRWDPD) and so we welcome the integrated approach that has been adopted in its preparation. Our comments below are set out in the same order in which the relevant chapters appear in the document:- Chapter 4- Waste YW fully supports the aspiration for Leeds to become a Zero Waste City (stated in para. 2.24) whereby, whilst fully recognising the waste hierarchy that gives reduction primacy followed by reuse/recycling, society treats waste as a valuable resource, for example by utilising energy recovery technology. 4.26 We note that the NRWDPD recognises that the Aire Valley to the east of the city provides

a strategic and sustainable location for waste facilities. Knostrop Waste Water Treatment Works (WWTW) is situated here and other types of waste treatment technology provide a use of land that is both compatible with and has great potential to be complementary to its operation. WWTW are significant power users and so the co-location of an energy from waste facility within the vicinity of the WWTW, provides the opportunity for YW to reduce its dependency on conventional energy generation within the Leeds district.

We are therefore fully in support of policy Waste 3

4.28 We support policy Waste 4 whereby waste management facilities will be treated as an industrial use of land and that policies relevant to the industrial use of land will apply

equally.

4.29 Policy Waste 5- We support the inclusion of land within Knostrop WWTW as being part of the Cross Green Industrial Estate preferred location for new waste management facilities. It is an obvious site for certain of the waste processes listed in Policy Waste 3, Item 1, notably anaerobic digestion.

Please note that we have suggested an amendment to map E (document reference no. 206) to better reflect YW’s land ownership in terms of land availability for future waste management activity, including the treatment of waste water.

4.32 Policy Waste 6- YW supports the inclusion of land within Knostrop WWTW as a Strategic

Waste Management Site. Please note that there is a typographical error in the policy where it refers to the “Sewage Water Treatment Works”, rather than Waste Water Treatment Works.

Any alternative employment use should be compatible with the proximity of the WWTW, with B2 or B8 most appropriate in the areas closest to YW’s operations.

Chapter 5- Energy Yorkshire Water fully supports the objectives for energy and recognises the logic of applying an energy hierarchy based on that used for waste. Operating the public water supply and waste water infrastructure is increasingly energy intensive and we seek to reflect the energy hierarchy as laid out in para. 4.6 in our operations. This includes the use of renewable technologies such

as wind and energy from waste but also the exploitation of other energy sources, particularly combined heat and power (CHP) which can be a by-product of the waste water treatment process. We similarly welcome the approach taken in the supporting Energy Topic Paper which makes clear that energy generation should not be seen in isolation from the rest of the NRWDPD. It recognises the links with waste (energy from waste), water (energy efficiency which is critical to Y.W’s. operations) and land (reducing land take, presumably by co-location). 5.23-5.25 Policy Energy 3 and Policy Energy 4- We are in full agreement with these policies, in

particular that proposals for low carbon energy recovery methods, including CHP, and its supporting infrastructure. Mapping the opportunities for implementing district energy networks will assist potential suppliers in the planning of the necessary infrastructure. We note that para. 1.17 of the supporting Energy Topic Paper makes specific reference to the Aire Valley, where Knostrop WWTW is located, as representing one of the best opportunities in the city in this regard. As noted above, our infrastructure is very energy “hungry” and so 1.18 could perhaps add utilities as one of the likely users of CHP generation (as well as renewable sources).

Chapter 6- Air Quality Policy Air 1- states that all applications for major development will be required to ensure that any impact on air quality, including unpleasant odours, is mitigated. If odour is to be included within the air quality section, then there should be a policy stating that new sensitive receptors will not be permitted within the proximity of existing land uses that produce malodours as a result of their normal and lawful operation. Yorkshire Water seeks to minimise odour emissions that arise as a result of its operations as statutory sewerage undertaker and for example has recently installed a new odour control plant at Knostrop waste water treatment works (WWTW). However, it is impossible to completely eradicate odour at plants such as Knostrop and it is important that local planning policy reflects PPS 23 whereby Para. 11 states that "Where for example, new housing is proposed close to a source of pollution, the risk of pollution from the normal operation of the process or the potential impacts and the extent to which the proposals address such risks will influence whether or not development should proceed....". Appendix A of the same document goes further and provides a list of matters that should be taken into account in drawing up development plan documents and that may also be material in the consideration of individual planning applications. The list includes "the need to separate necessary but potentially polluting and other land uses...so as to reduce conflicts, for example by identifying where necessary areas around existing sources of pollution in which proposed new developments and uses should be carefully considered in terms of their potential as pollution receptors". Chapter 6- Water Yorkshire Water is the statutory water and sewerage undertaker for the whole of Leeds district. We commented on the earlier NRWDPD Policy Position Statement and note that our comments have been reflected in the draft Publication Document. We support all the policies within this section (that is Water Policies 1-7) although the Environment Agency is better placed to comment on those relating to fluvial flooding. We look forward to continuing the multi-agency approach adopted with respect to flood risk management within Leeds District, reflected in the consensus between YW, Leeds C.C. and the Environment Agency regarding a reduction in surface water run-off from previously developed sites (Policy Water 7)

Chapter 6- Land We note that the para. 6.32 recognises the benefit of reducing land-take by co-locating natural resource/ waste facilities on the same sites and that such proposals will be supported by the Council. Yorkshire Water suggests that a specific policy should be created to reflect this statement and include energy generation facilities.