La Collette Waste Management Site – Development Plan.

STATES OF JERSEY

LA COLLETTE WASTE MANAGEMENT SITE – DEVELOPMENT PLAN

Lodged au Greffe on 6th April 2023 by the Minister for Infrastructure Earliest date for debate: 23rd May 2023

STATES GREFFE

2023  P.17

PROPOSITION

THE STATES are asked to decide whether they are of opinion −

1. to support the short/medium term Plan for Waste Management at La Collette Reclamation Site Phase II to include:

1. a combined waste management approach for hazardous waste and inert soils under a  ‘La Collette Waste Management Site – Development Plan’, as detailed in drawing 22023-100;
2. the formation of the ‘East Headland’ and ‘South Headland’ by deposition of hazardous  waste  in cells  as  per plans submitted under application P/2016/1647;
3. the formation of the ‘West Headland’ by deposition of inert waste soils in a mound;
4. the landscaping and restoration of the East Headland and South Headland as per the plans submitted under application P/2016/1647; and
5. the creation of a publicly accessible one-mile-long coastal path around the perimeter of the site once landscaping and restoration is complete; and

2. to request that, in the period enabled by the short/medium term plan, the Minister for Infrastructure and the Minister for the Environment develop the long-term plan for the future waste strategy for Jersey, and any site requirements are used to inform the next review of the Island Plan, 2026 onwards.

MINISTER FOR INFRASTRUCTURE

REPORT Introduction

The La Collette Waste Management Site occupies the reclaimed land within La Collette Reclamation Phase II. The site is the location of the majority of the Island’s solid waste management facilities. Since completion of the reclamation site construction, the La Collette Waste Management Site has evolved as land has been progressively reclaimed, waste management facilities in other locations have reached the end of their service life, and in response to the Island’s changing waste management needs. The development of the site has been in accordance with policy and planning permissions have been sought as the site has developed. An application made for permission to create the ‘La Collette Headland’ through the deposition of hazardous waste in cells has recently been refused. Therefore, the island is without a facility for the management of hazardous waste. Furthermore, permissions for the disposal of inert waste soils at the site will be exceeded in the short term.

The Minister for Infrastructure is proposing a short/medium term plan, as shown on drawing number 22023-100, that will address the immediate issues the Island faces in relation to the management of hazardous waste and inert waste soils. This plan will also provide the necessary time to develop and implement a long-term strategy to deliver on the Government’s solid waste related policy objectives.

Background

The relevant planning history to the reclamation site and in relation to the deposition of waste at the La Collette Waste Management Site is considered as commencing in 1993 when, in the October of that year, permission was granted under application 17742 for the construction of the rock armour revetment (a full breakdown of all related planning applications/approvals can be found in Table 5. In the appendices)

Further planning applications 17742/A and 17742/B enabled filling the reclamation site up to the level of the breakwater for inert waste soils and hazardous waste respectively. Planning application 17742/C allowed landscaped tipping of the North Mound to a height of 10m above the top of the breakwater

On 11th  July 2000, the  States Assembly approved proposition  P.96/2000 and the proposed La Collette Reclamation Site Phase II - Development Framework

This provided the framework for the future development of land at  La Collette Reclamation Site Phase II, including the designation of:  

1. an area of reclaimed land for the purposes of industrial,  storage and warehousing use,  
2. an area of reclaimed land to be used for super-filling and  subsequently  for  the  purposes  of  providing  a  major  landscaped feature and an area of reclaimed land to the  south of the tanker berth for the public open space,  
3. purposes of storing aggregate material imported through   St. Helier Harbour as an option pending the outcome of a  feasibility study to assess the viability of this use,  
4. an area of reclaimed land for access to the water at all states  of the tide and for associated facilities for marine leisure  craft.  

One of the key objectives of this framework was based on the  rationale  that:  “Given  the  difficulties  in  finding  a  satisfactory  alternative for the future disposal of inert and non-combustible waste  materials, it is considered to be in the Island’s best interests to  maximise the lifetime of La Collette as a tip site and to incorporate super-filling. This will also enable the creation a landscaped buffer, screening the site from the east, and provide an area of public open space.”

At the time the framework was adopted, ‘Safety Zones’ around the fuel storage facilities had not been conceived (pre Buncefield event - 11th December 2005), with these now used to determine appropriate types of development in proximity to the bulk fuel storage facilities (which fall predominantly in the DPZ, Inner Zone and Middle Zone). As a result, the nature of the public open space (refer point ii.) that the La Collette Headland can provide is restricted, and likely to be limited to:

• A landscaped backdrop

• A coastal walk around the perimeter of La Collette

Recognising Challenges at La Collette – The Island Plan

As early as 2002, the Island Plan recognised that La Collette was filling faster than predicted:

Section 14.28 - The Solid Waste Management Strategy recognises the need to provide additional  capacity  for  waste  disposal  in  Jersey.  The  Strategy  recommends  that additional space be created at La Collette through land raising by developing a landform above the sea wall level.

Furthermore, the current Bridging Island Plan recognises that: ‘The Government of Jersey landfill facility at La Collette is, currently, the only licensed terrestrial inert waste disposal site in the island. The facility is reaching the end of its operational life’.

The La Collette Waste Management site

The waste operation at La Collette  includes  the management  of municipal and  bulky  waste  through the  Energy  Recycling Facility (ERF), the Clinical Waste  Incinerator  (CWI), Household  Recycling Centre  (HRC),  Metals Recycling Facility (MRF), organic  recycling, aggregate  recycling,  inert waste,  and  hazardous waste, including asbestos.

The  one  hectare  of remaining land is to be used

for bulky waste storage to enable  the  ongoing

management of Islanders municipal and bulky waste disposal during the ERF scheduled maintenance periods. This is subject to a future planning application.

With the ongoing high volumes received into the site, issues surround the management of hazardous waste, which is now in breach of its permission condition, and inert waste, which is likely to breach its condition in the short term.

Inert Waste

Inert waste soils are generated through island wide developments. The vast majority of inert waste soils are received at the Inert Waste Soils Reception at the La Collette Waste Management Site, which is one component of the overall inert waste soils and aggregate recycling operation at the site. There are number of small facilities around the island that  can  receive  and  recycle  inert  waste  soils.  However,  the  La  Collette  Waste Management Site is the only facility that has permission for disposal of any surplus non- recyclable content.

Approximately 200,000 tonnes of inert materials are received at La Collette Waste Management site annually. Of this, approximately 120,000 tonnes are recycled into aggregates for use in construction. The surplus 80,000 tonnes are disposed of at the site.

The current planning permissions covering the inert waste soils and aggregate recycling operation permit disposal and landfilling up to the top of the rock armour revetment that forms the perimeter of the site. Stockpiling of soils and aggregates to an average height of 10m and a maximum height of 20m above the top of the revetment is also permitted. The site is currently full and soils and recycled aggregate products are now being stockpiled. At current rates of reception and recycling, it is expected that the permitted stockpiling limits will be exceeded in the short term. This is subject to a future planning application.

Hazardous Waste

Hazardous waste generation is a consequence of essential functions that support Island life. There are three main hazardous waste streams in Jersey:

• Ash and residues from incineration of waste (ERF, CWI, and ACI – Animal Carcass Incinerator)

• Asbestos containing materials (ACMs)

• Contaminated soils

There are other hazardous waste types generated on Island, primarily through industrial activity such as boat cleaning, however, the quantities of these types of waste are relatively small.

The majority of ash and residues come from the ERF and are exported to the UK. This is possible and permitted by the relevant UK authorities as this waste is exported for recovery so is moved up the waste hierarchy by exporting from Jersey. Relatively small quantities of ash and residues arise from the CWI and ACI.

Asbestos containing materials arise from the refurbishment and demolition of buildings, received  from  homeowners  undertaking  work  on  their  property  and  commercial customers and licensed asbestos removal contractors carrying out refurbishment and demolition works for others. Asbestos waste cannot be exported as permission has been refused by the relevant UK authorities.

Contaminated soils are generated through development of contaminated land which exists across the island and are normally the result of historic industrial and commercial operations, for example:

• Old gas works sites & petrol stations

• Scrapyards

• Land reclamation and waste landfilling

• Industrial plant waste storage and treatment facilities

Hazardous waste is disposed of in waste containment cells at the La Collette Waste Management Site. The design, construction and operation of these cells is stringently regulated under the Waste Management (Jersey) Law 2005. The site has a Waste Management Licence issued under this law for the receipt and disposal of hazardous waste.  It is  a  condition of this  licence that the  design of cells is  undertaken by independent specialists and meets the requirements of international standards. The design must be approved by the Waste Regulator prior to construction. Construction of cells is supervised by an independent Construction Quality Assurance (CQA) Engineer. A  CQA  Validation  Report  confirming  cells  have  been  properly  constructed,  in accordance with the design, must be sent to the Waste Regulator for approval before the cell  can  become  operational.  The  waste  deposition  operation  is  undertaken  in accordance with a Waste Regulator approved Working Plan.

Over the last 10 years, approximately 250,000 tonnes of hazardous waste have been disposed of at La Collette. The producers and sources of this waste is summarised in the following table 1:

 

Producer	Ash and residues from waste incineration			Asbestos containing materials	Contaminated soils	Total
	ERF	CWI	ACI
Government	61,900	200	800	500	24,300	87,700
ALO’s	0	0	0	100	145,300	145,400
Third party	0	0	0	6,700	12,700	19,400
Total	61,900	200	800	7,300	182,300	252,500

1. All quantities are given in tonnes to the nearest 100 tonnes.
2. The majority of the 24,300 tonnes of contaminated soils produced by Government of Jersey was due to the construction of the New Sewage Treatment Works.
3. ALO – Arms-Length Organisation

Some significant activities that will generate hazardous waste in the future are listed in the following table 2:

 

Activity	Producer	Hazardous Waste Type	Quantity (tonnes)
Animal carcass incineration	Government	Ash / Residue	150 pa
Clinical waste incineration	Government	Ash / Residue	40 pa
General asbestos removal	-	Asbestos	730 pa
New Healthcare Facilities	Government	Asbestos / Contaminated Soils	Unknown
Tunnel St / Gas Place development	Government	Contaminated Soils	Unknown
Overdale Hospital works	Government	Asbestos / Contaminated Soils	Unknown
Southwest St Helier Masterplan	ALO	Contaminated Soils	360,000
Elizabeth Harbour redevelopment	ALO	Contaminated Soils	Unknown

With the exception of the ‘North Mound’ which has specific permission linked to the ERF permission (P17742/C), planning permits for disposal of hazardous waste at the site generally give permission for waste to be filled to the top of the rock armour revetment. Hazardous waste super-filling is already above this with the highest point being approximately 17m above the top of the revetment.

Planning Application – Hazardous Waste

In 2016, planning application P/2016/1647 – ‘Construction of La Collette Headland for super-filling with hazardous waste’ was submitted. The resolution of the planning application has been delayed significantly, and in March 2023, whilst the Planning Officer recommended the application be approved, the Planning Committee chose to refuse the application, siting:

1. Policy MW3 – In this instance, insufficient information has been submitted with the application to satisfy the comprehensive after-use restoration plan requirement of the policy,
2. Policy  GD9  –  given  the  proposed  siting,  height,  scale,  and  profile  of  the development proposed, together with a lack of information to demonstrate how this proposal can be satisfactorily mitigated, the development will result in visual harm to the skyline, and
3. Policy GD9 – the development given its siting, height, scale, and profile in this location with obstruct significant views to the Noirmont Headland

This is due for formal confirmation of the refusal on the 13th April 2023

The  application  did  include  a  proposed  Landscaping  Strategy,  Landscaping  & Restoration Drawings, Construction Environmental Action Plan, and Working Plan

required under the facility Waste Management Licence which were submitted alongside the  application.  The  Landscape  and  visual  impact was  discussed in  detail  in  the application, and an assessment in accordance with recognised standards was undertaken and described in the Environment Impact Assessment. This EIA concluded that the Headland would see no significant impact and instead deliver moderate benefits. It was also felt, as the Headland would provide an essential facility for the  Island for which  there is no viable alternative, that the overall community benefit outweighs the adverse effects.

The Impacts of Planning Refusal

Given that the La Collette Waste Management Site is already exceeding its permission with regards to hazardous waste, the site will need to close to the receipt of hazardous waste from the 14th April 2023 once the planning refusal is confirmed. This effectively means that the Island will be without a facility or solution for the management of Hazardous Waste.

The result of this means that existing activities generating hazardous materials will need to cease –including:

1. Clinical waste and animal carcass incineration
2. Asbestos removal and disposal
3. Any  construction/development  on  a  contaminated  site  (as  listed  with Environmental Health or otherwise)
4. Boat washings and any other small scale domestic hazardous waste creation. e.g. driveway planings, etc.

For a full list of current/ongoing activities that will need to cease, refer to table 6 in appendices.

Additionally, future developments on contaminated sites (detailed in table 2.) would not be able to progress, with Planning already advising likely refusal of some applications on the basis of the Hazardous Waste decision. Finally, there is a significant increase in the environmental risk of fly-tipping hazardous materials on Jersey.

This is likely to impact all aspects of the Governments’ ability to deliver the seven priorities  for  change  under  the  common  strategic  policy.  Furthermore,  this  will significantly hinder the future housing growth strategy as defined in the Bridging Island Plan.

Short/Medium Term Plan

A full options appraisal has been undertaken on the management of hazardous waste (see Appendices, Table 3.), with two options shortlisted (see Appendices, Table 4.) and only one viable option identified:

La Collette Headland – Super-fill La Collette reclamation site as per refused planning application

Given the additional challenge of the inert waste soils also being at risk of breaching its conditions in the near future, it is proposed to address both the hazardous waste and inert soil waste together under a revised ‘La Collette Waste Management Site – Development Plan’. This will form the short/medium term plan.

The ‘La Collette Waste Management Site – Development Plan’ as shown on drawing number 22023-100, is summarised as follows:

• Formation of ‘East Headland’ and ‘South Headland’ by deposition of hazardous waste in cells as per plans submitted under application P/2016/1647

• Formation of the ‘West Headland’ by deposition of inert waste soils in a mound

• Landscaping and restoration of the East Headland and South Headland as per the plans submitted under application P/2016/1647

• Creation  of  a  publicly  accessible  one-mile-long  coastal  path  around  the perimeter of the site

The exact shape, form, and proposed landscaping and restoration of the West Headland will be refined hereafter, and a separate planning application made for its construction. At the current rates of receipt and recycling, the West Headland is expected to be formed in 24 months. The East and South Headlands are estimated to take 5 – 7 years to form. The coastal path will be developed thereafter.

Long Term Strategy

The short/medium term plan will provide the necessary time to complete ongoing work to update the Government’s Solid Waste Strategy and implement any measures this strategy proposes for future waste management. This could include the identification and preparation of new or extended waste management sites around the Island and the development of any infrastructure needed to support these. The strategy will be aimed at  achieving  the  Government’s  waste  related  policy  objectives  with  a  focus  on prioritising waste reduction, re-use, and recycling as per the waste hierarchy.

Additional Impacts

Should the La Collette Waste Management Site become unavailable for the receipt of hazardous waste materials, then there are two potential options, albeit both carry considerable challenges for the Island.

1. Remove hazardous waste at source – Requires the restriction of construction activities  that  generate  hazardous  waste,  likely  the  refusal  of  planning permission  on  any  contaminated  area  construction.  This  would  have  a widespread local impact (construction industry and the Public) in the short term

2. Develop an alternative waste site – Requires plans to bring forward rapid construction of an alternative site to facilitate hazardous waste management. This carries a number of environmental challenges, and would not be a quick solution – likely to be 2-3 years minimum

It is also worth noting that there is no option to export hazardous waste given that any Duly Reasoned Request (DRR) to do so would be rejected due to Basel Convention and DEFRA  requirements.  Furthermore  the  cost to  export  hazardous  waste  would  be significant:

Export existing stock to UK: £100,000,000 (approx. 505,000t over last 20 years) Exporting expected Waterfront volumes to UK: £72,000,000 (over next 10-15 years) Normal operational volumes exported to the UK: £50,000,000 (over next 10 years) £200 cost per tonne

Financial and manpower implications

Support for this proposition will not directly influence the financial position the Department will be in should the planning application be refused.

The hazardous waste budget is designed to cover the operational and infrastructure costs and therefore there are no financial implications attributed to this proposition.

Annual budgeted net income for inert waste is £2.3M, with circa £100k of internal manpower resource allocated to the waste management operation for inert waste. Support of this proposition will confirm the States agreement of the Development Plan, which should enable planning permission to be considered in this context, and the continuation of this operation.

APPENDICES Topography & Images

Safety Zones within La Collette Reclamation Site Phase II

 

Option	Description	Advantages	Disadvantages	Viability Commentary	Viable	Short List
1	La Collette Headland – Super-fill La Collette reclamation site as per refused planning application	• Site is available and owned by Government of Jersey • Co-location with other GoJ solid waste management functions • Existing infrastructure and operations to support facility • Planning application submitted • Application recommended for approval by Planning Officer • Provides maximum capacity for hazardous waste at La Collette • Accords with historic States Assembly in principle approvals for the management of waste at La Collette	Planning application refused by Planning Committee	Other than the refusal of permission by the Planning Committee, which could be contested, there are no other disadvantages	Yes	Yes
2	Super-fill La Collette reclamation site to reduced height and super-fill other areas of La Collette	• Site is owned by Government of Jersey • Co-location with other GoJ solid waste management functions • Existing infrastructure and operations to support facility • Reduced height would address concerns of Planning Committee • Provides maximum capacity for hazardous waste at La Collette • Accords with historic States Assembly in principle approvals for the management of waste at La Collette	• Site is not available due to current land uses for other waste management functions at La Collette • Other possible visual / environmental impacts due to additional super-fill areas	Lack of site availability is an obstructive disadvantage	No	No
3	Super-fill La Collette reclamation site to a reduced height	• Site is owned by Government of Jersey • Co-location with other GoJ solid waste management functions • Existing infrastructure and operations to support facility • Reduced height would address concerns of Planning Committee • Accords with historic States Assembly in principle approvals for the management of waste at La Collette	• Reduced capacity for hazardous waste that is unlikely to support the island’s needs in the medium / long term • Requires additional measures (Option 6) to minimise the generation of hazardous waste in the future that would have significant impact on the public, construction industry and ability to deliver key GoJ policy objectives (e.g. Housing)	• The concerns of the Planning Committee may be addressed • Would require restriction of activities that generate hazardous waste that would have a widespread local impact in the short term • However, these measures are likely to be required in the long-term whichever solution is adopted	Yes	Yes

Full options appraisal – Table 3.

Option	Description	Advantages	Disadvantages	Viability Commentary	Viable	Short List
1	La Collette Headland – Super-fill La Collette reclamation site as per refused planning application	• Site is available and owned by Government of Jersey • Co-location with other GoJ solid waste management functions • Existing infrastructure and operations to support facility • Planning application submitted • Application recommended for approval by Planning Officer • Provides maximum capacity for hazardous waste at La Collette • Accords with historic States Assembly in principle approvals for the management of waste at La Collette	Planning application refused by Planning Committee	Other than the refusal of permission by the Planning Committee, which could be contested, there are no other disadvantages	Yes	Yes
2	Super-fill La Collette reclamation site to reduced height and super-fill other areas of La Collette	• Site is owned by Government of Jersey • Co-location with other GoJ solid waste management functions • Existing infrastructure and operations to support facility • Reduced height would address concerns of Planning Committee • Provides maximum capacity for hazardous waste at La Collette • Accords with historic States Assembly in principle approvals for the management of waste at La Collette	• Site is not available due to current land uses for other waste management functions at La Collette • Other possible visual / environmental impacts due to additional super-fill areas	Lack of site availability is an obstructive disadvantage	No	No
3	Super-fill La Collette reclamation site to a reduced height	• Site is owned by Government of Jersey • Co-location with other GoJ solid waste management functions • Existing infrastructure and operations to support facility • Reduced height would address concerns of Planning Committee • Accords with historic States Assembly in principle approvals for the management of waste at La Collette	• Reduced capacity for hazardous waste that is unlikely to support the island’s needs in the medium / long term • Requires additional measures (Option 6) to minimise the generation of hazardous waste in the future that would have significant impact on the public, construction industry and ability to deliver key GoJ policy objectives (e.g. Housing)	• The concerns of the Planning Committee may be addressed • Would require restriction of activities that generate hazardous waste that would have a widespread local impact in the short term • However, these measures are likely to be required in the long-term whichever solution is adopted	Yes	Yes

Full options appraisal – Table 3 (cont.)

 

Description	Advantages	Disadvantages	Viability Commentary	Viable	Short List
Export hazardous waste	No local environmental impact	• Requires permission from relevant authority in receiving country – indication that permission would not be granted • Obstructive costs for export would have significant impact on the public, construction industry and ability to deliver key Government policy objectives (e.g. Housing)	Inability to secure necessary permissions from relevant authority in receiving country is an obstructive disadvantage	No	No
Disposal on island at another site - either landfill or super-fill	Possible reduced environmental impact relative to other options	No site available in Government or third-party ownership	Lack of site availability is an obstructive disadvantage	No	No
Severely restrict on island activities that generate hazardous waste and work towards ‘Zero Waste’	• Accords with Bridging Island Plan Policy WER 1 o  Waste Minimisation • Lowest environmental impact relative to other options • Long term solution that must be strived for to support all options	• ‘Zero Waste’ in the context of hazardous waste in Jersey is not possible in the foreseeable future due to the ongoing existence of sources of hazardous waste • Significant impact on the public, construction industry and ability to deliver key GoJ policy objectives (e.g. Housing)	Inability to achieve ‘Zero Waste’ in the context of hazardous waste in the short to medium term is an obstructive disadvantage that could only be overcome if Option 1, 2 or 3 was chosen to provide a facility during the period required to implement necessary measures	No	No

2023  P.17

Options appraisal – Short List – Table 4.

 

Option	Description	Public Impact	Commentary	Rank
1	La Collette Headland – Super-fill La Collette reclamation site as per refused planning application	Low	Impact is limited to a visual impact to a very small volume of the population due to obstruction of views of Noirmont Headland from coastal areas from Grève D’Azzette to Le Squez   This is mitigated to an extent through the landscaping restoration that would be developed along the Headland, masking already visible aspects of the La Collette waste operation	1
2	Super-fill La Collette reclamation site to reduced height and super-fill other areas of La Collette	High	• Reduced visual impact • However, views of Noirmont Headland from coastal areas from Grève D’Azzette to Le Squez would still be obstructed / compromised • Requires restriction of activities that generate hazardous waste that would have a widespread local impact in the short term or… • …Requirement to bring forward rapid construction of an alternative site to facilitate hazardous waste management	2

THE ONLY VIABLE OPTION IS OPTION 1 – LA COLLETTE HEADLAND Full details of Planning applications/approvals - Table 5.

Date	Planning Ref.	Description	Decision
October 1993	17742	Construction of breakwater	Approved
January 1995	17742/A	Filling of the reclamation site with inert waste soils up to the level of the top of the breakwater (14m above admiralty chart datum)	Approved
September 1995	17742/B	Filling of the reclamation site with hazardous waste in the form of incinerator bottom ash up to the level of the top of the breakwater (14m above admiralty chart datum)	Approved
October 1996	17742/C	Landscaped tipping within the area of the ‘North Mound’ to height of 10m above the top of the breakwater (24m above admiralty chart datum)	Approved
July 1998	17742/D	Super-filled landscape mound for asbestos disposal	Withdrawn
July 2000	P.96/2000	La Collette Reclamation Site Phase II – Development Framework approved by the States Assembly	Approved
November 2015	P/2015/1461	Construction and filling of Cell 30 with asbestos	Approved
November 2016	P/2016/1647	Construction of La Collette Headland for super-filling with hazardous waste	Refused (7 years after submission)

2023  P.17 List of current hazardous waste activities that will need to cease on 14th April should the planning application refusal be formalised - Table 6.

 

Hazardous Waste Activity	Dates / Amounts (where known)
Remediation and likely disposal of materials from warehouse on albert pier	Requested for April disposal
Contaminated soil remediation currently in progress	Presently on site – once remediated disposal.
Sand Blasting Media with Marine Antifoul	Various Producers – Requested for April
Unconfirmed contaminated material Residential Property	Expected to be requested for April
Haut Du Mont Incident – Government of Jersey	Ongoing
Soil, Insecticide and Mixed contaminants	Expected to be requested for April
IHE Operational wastes: Animal Carcass Incinerator Bottom Ash	Every 6 to 8 weeks
Clinical Waste Incinerator Bottom Ash	Every 4 weeks
STW Gas Stack Scrubber Media	Quarterly
Asbestos
The former Play dot com/BOA warehouse/Northern Quarter	Approx 50 T
HM Prison La Moye	Approx 3T
Midbay Pumping Station works	Not known
Various domestic projects, including licensed works	Not known

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