1.

Planning Statement in support of the application for proposed development of a storage

lagoon at Gateridge Farm to hold nutrient rich food and drinks processing waste material

to be spread on agricultural land for benefit

1. Background

DAF (dissolved air floation) sludge, wash waters and bio-fertiliser are all produced

and derived from the food production industries. Utilisation of these materials by spreading

them onto agricultural land is critical to the success of the factory production operation and

keeping food products entering the supermarket chains. Landspreading of these materials

are also perceived as one of the best options for dealing with food chain waste.

Spreading material onto agricultural land has a number of parameters that must be

met in order to adhere to the strict guidelines of an Environment Permit issued and

regulated by the Environment Agency. The strict measures ensure that the operation is

carried out in a sustainable, safe and sensitive manner so as not to cause any undue

negative impact on the environment. Lagoon facilities are paramount for storage of this

material during certain times of the year when it is deemed unsuitable to spread and when

material cannot be taken to land. Lagoon storage facilities provide an opportunity to keep

the operation running and allow landowners and contractors to comply with the EU

regulations imposed on the UK farming community on matters of cross-compliance, the

Code of Good Agricultural Practice and Nitrate Vulnerable Zones.

2. Proposed Application

This application seeks to develop a lagoon storage facility at Gateridge farm on the

basis of two main reasons; 1) to provide an entirely sustainable source of organic matter

and organic nutrients to be spread onto adjacent land as a replacement fertiliser for

artificial, chemical compounds, 2) to continue to divert food waste material away from

landfill facilities and spread onto agricultural land as part of a best environmental option for

dealing with food chain waste.

The lagoon is designed as a sustainable storage option that can be restored back to

its original state with ease. The material/aggregate destined to be used for the construction

will be obtained from the digging of the hole and all material will be placed back into the

hole when finished.

2.

3. Location & Site Description

The site at Gateridge Farm is set in the heart of the Northamptonshire countryside

off the Brackley Road between the villages of Croughton and Hinton-in-the-Hedges and

approximately 3 kilometres south-west of the town of Brackley. The typography of the area

is undulating. The farmyard sits at the top of the slope with the remaining fields gradually

sloping down towards RAF Croughton to the south. The farm is surrounded by extensive

agricultural fields with few neighbours and the proposed lagoon site is not within 500

metres of any residential dwelling. It is proposed that the lagoon will be sited between the

top two fields of the farm in between trees (Grid Ref: SP 5561534696); these will act as a

natural barrier and help reduce the risk of odour issues while causing minimal disturbance

to the natural landscape. The fields are all within easy reach to empty the lagoon and all

fields can be accessed via an umbilical pipe and tractor.

Gateridge Farm operates an entirely livestock farming system on some free-draining,

seasonally wet loamy soils of moderate fertility. Grass fields under this deployment are used

for a mix of grazing and 2 cut silage making. Land is generally of flat topography with slight

undulation and is situated in an area of moderate rainfall making them ideally suited to the

application of organic material as a means of building soil fertility and reducing artificial,

bagged input. The fields within this deployment have had organic waste material applied in

the past under deployment number GP3598VR/D406 without experiencing any problems,

and with beneficial results to crop growth. These wastes are not classed as high available N

products and therefore will not be subject to statutory closed periods for application in NVZ

areas. The nutrients applied are accounted for in the previous seasons cropping in line with

RB209 and COGAP recommendations.

4. Waste Operations

All liquid waste material proposed for import onto Gateridge Farm are non-

hazardous and are the end product of the food/drinks processing line. These range from

poultry processing DAF (Dissolved Air Flotation) sludges to waste waters from brewery

processing. All waste material is rich in organic nutrients (Nitrogen, Phosphate and Potash

as well as other nutrients) and provides justifiable benefit to crop growth. Similarly to other

organic manures, these materials are used to offset the use bagged fertilisers and are

considered a natural and environmentally friendly way of recycling material back to land

and diverting waste from landfill.

It is proposed that we will fill the lagoon to a total of 3000 tonnes. This complies with

Whites Recycling Ltd Environmental Permit issued by the Environment Agency and the

deployment for land spreading operations. The material will be stored within the lagoon and

retained on site prior to spreading when ground conditions are deemed otherwise suitable

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to spread i.e. when we will provide the greatest agricultural benefit . At times, the material

will be stirred within the lagoon before spreading commences to ensure a greater

consistency of nutrients and to help provide an even application across the fields. The

constraint of the Environmental Permit limits the storage of the material to a maximum

period of 12 months. It is proposed that we will store material on a yearly basis –

predominantly during the winter months during periods of inclement weather – before

spreading in the spring.

5. Highways

The number of vehicles that will be entering the site on an annual basis will vary as

the lagoon will predominantly be used during the winter months. This lagoon is designed to

fill to a maximum of 3000m3 which equates to 107 artic lorry loads. The site access for the

lorries will be along an existing farm track to the local highway. This has been used in the

past by lorries as well as farm traffic without experiencing any problems when we have

been spreading these fields in the past.

6. Need

The material is derived from food/drinks processing factories and is nutrient rich in

Nitrogen, Phosphate and Potash as well as micro nutrients – nutrients that are essential to

crop growth and drivers of yield. The material is low in Potentially Toxic Elements (PTEs)

that are otherwise damaging to the soil. This land has little fertiliser applied to it in the past

and recent soil analysis shows this. The availability of nutrients that will be provided by the

application of the waste will help build soil fertility, increase the productivity of the land and

offset the amount of bagged, chemical fertiliser required. This material is also an entirely

sustainable source of nutrients that would otherwise prove costly to buy. Annual

justification will be sent to the Environment Agency for approval prior to land spreading in

line with the environmental permit to ensure that the material is applied in an

environmentally sensitive and suitable manner making it an entirely transparent operation.

The size of the cropped area is 41 Hectares (101.27 Acres). All land can be accessed

from the proposed lagoon site via an above ground, mobile umbilical pipe that will be

connected to the back of a tractor to an injector to help minimise ground compaction which

will place the material into the soil profile and directly into the plant rooting zone. This

method of application will reduce the risk of odour, run off or leaching and increase nutrient

uptake.

4.

7. Odour

The location of the proposed site of the lagoon has been selected with the main

objective of preventing any odour issues. The selected area is within an agricultural holding

and used for agricultural purposes and approx. 3 miles away from the town of Brackley, and

1.5km away from the nearest village of Croughton. The material is due to be spread on

surrounding agricultural land using an umbilical pipe system to a tractor with injector. This

will place the material into soil profile to reduce the risk of odour and directly into the

rooting zone where the plants can utilise the nutrients.

I have attached a copy of an Odour Management Plan and an Odour Risk Assessment

that will be used in conjunction with the lagoon proposal. This will monitor all odour related

issues and enforce a strict code of conduct to ensure that we do not experience any odour

problems. I must reiterate that this is not a waste transfer station and the lagoon is used for

storage of end material prior to spreading on adjoining land. This will ensure that odour is

kept to a minimum and traffic is limited. A number of these facilities are being used across

the country without experiencing any problems for two main reasons:

1. The material acts in a similar manner to cattle slurry in that it forms a floating crust

which acts as a biofilter. The crust restricts any gaseous emissions and acts like a

cover material for the lagoon. This is largely why any of the other lagoons are linked

with odour complaints.

2. By building the lagoon within a tree area helps to create a screen in which to

blockade any immediate odour. The area of trees surrounding the lagoon has

commonly been used by many of the water companies when building earth banked

lagoons to restrict odour.

These fields have been spread in the past using organic waste material under

Environment Agency approved deployment without experiencing any problems.

3. Lagoon Capacity

The lagoon capacity has been calculated based on the dimensions of the lagoon as

stipulated in the plan. The dimensions of 105mx20m are indicative of the fenced area, not

the fillable area of the lagoon itself. The internal, fillable dimensions of the lagoon are

91mx13mx3m. This gives the total fillable area, allowing for the freeboard of 750mm, of

approximately 3000m3.

5.

4. Pipe and Pump Work

No supporting infrastructure will be required at the site around the lagoon. Sealed

tankers will bring the material to the point of discharge before blowing the material along a

lay-flat pipe laid over ground into the lagoon. This is a temporary pipe that will used to fill

the lagoon. A towable, field pump will be used to help blow the material from the tanker

through the pipe into the lagoon and this too will be taken away once it is not in use.

5. Bank

All cut material will be used to create the earth banks of the lagoon. No material will

be imported or exported from the site for this purpose.

6. Fence

The lagoon is located within a fenced off area with the fence positioned at the lower

outer banks to prevent farm livestock, local wildlife and personnel entering the lagoon

compound. The fence is to have an access gate, which is locked when unattended, to allow

machinery access for bank vegetation maintenance, effluent management and effluent

removal from the lagoon. The height of the fence will be 2.5 metres. (Please note that

example diagrams are representative only)

7. Flood Risk

According to the Environment Agency’s website Flood Map for Planning, the area

around the proposed lagoon site is not within an area of flood risk particularly as this is in an

area of higher ground. The soils surrounding the lagoon site are freely draining loamy soils

over rock. The crack and pores within the rock ensure that water will be absorbed readily

and allow it to drain through the underlying layers. This means that the risk of flooding at

the site, even during periods of heavy rainfall, is minimal. The liner will protect the banks

from erosion helping to preserve the structural integrity of the lagoon.

8. Policy

The recycling of nutrient-rich organic food waste material to agricultural land

currently satisfies the aspirations of the European, national, regional and local waste policy

in a great number of ways. This allows food waste material to be spread onto agricultural

6.

land to be used as a soil improver and to fertilise land in an environmentally, sustainable

and sensitive manner and reduce the artificial input required by chemical products. The

development of a lagoon structure would satisfy the increased demand to dispose of food

waste in a way that is in accordance with these policy aspirations. This proposal is consistent

with the UK’s obligation to reduce greenhouse gas emissions through measures such as the

diversion of organic waste from landfill to be used in a productive manner on agricultural

land.

For the purposes of this document we will reference the Northamptonshire County

Council Minerals & Waste Development Framework Core Strategy and the

Northamptonshire County Council Minerals & Waste Development Framework Control of

Management and Development as the most relevant documents in support of this

application.

I. NCC Minerals & Waste Development Framework Core Strategy

Policy CS 1 – this application supports the waste management capacity and the policy aims

of an entirely sustainable waste management network. Activity is entirely controlled an

audited by the Environment Agency to ensure that it is undertaken is an environmentally

sensitive manner.

Policy CS 3 – the Strategy for Waste Disposal seeks to encourage to diversion of waste away

from landfill facilities. The target is to divert waste away from landfill facilities is 100% as it is

estimated that the landfill capacity will run out by 2016. By recycling organic food waste

material away from landfill and applying to agricultural land in an environmentally sensitive

manner helps to promote a sustainable cycle of food waste, high quality fertiliser leading to

further food production.

Policy CS 7 – the Sustainable Design and Use of Resources encourages the use of recycling or

secondary resources to build the respective facility. In this instance, the lagoon will be built

using the aggregate taken from the hole created and will be banked in a manner that will

seek to blend into the surrounding environment. This will ensure that no new

aggregate/materials will be required to construct the lagoon.

Policy CS 9: Sustainable Transport Movements. The location of the proposed lagoon site is

within close proximity to main road networks which ensures that the material does not

need to be hauled large distances. The material will be retained on-site and spread onto

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adjacent agricultural land via a pump and umbilical pipeline to a tractor and injector. This

will ensure that the material can be continuously pumped reducing the traffic movements

back and forth to the lagoon.

Policy CS 13. Restoration and after-use of minerals and waste development. SR2010No4

(Mobile Plant for landspreading) permits the use of organic based waste material with a

nutrient value to be spread onto land resulting in benefit to agriculture or ecological

improvement. Under the standard rules of the permit, liquid waste material shall be used

for land treatment activities on notified agricultural land under a deployment approved by

the Environment Agency. Under the terms of the permit, the lagoon shall be used as an on-

farm storage facility to store the material during periods of inclement weather when

conditions are unsuitable to spread and provide a consistent blend of nutrients prior to

being spread on adjoining agricultural land.

The lagoon is designed so that the land can be restored back to its original once

operations have ceased. The aggregate used to construct the lagoon will be taken from the

hole created, and the aggregate can be used to fill the hole back in once there is no longer

and requirement for the lagoon.

Policy CS 14: Addressing the impact of proposed minerals and waste development. The

concept of a lagoon for storage of material during periods of inclement weather without

spreading acts in line with the environmental requirements of a landspreading permit. The

lagoon is to be designed in a manner that minimises any visual bearing on the surrounding

impact and will blend into the natural topography of the surrounding landscape. The height

of the structure will not exceed that of the perimeter fence (2.5 metres) and the

surrounding area will be covered by planted trees. Access to the lagoon will be via an

existing farm track. This track has limited vehicular access and suitable locks will be placed

on the gates surrounding the lagoon to restrict any persons or wildlife from entering the

compound.

The location and site of the lagoon on Gateridge Farm will be sited at least 1.3km

away from the nearest village of Croughton. Between the village and the proposed lagoon

site are a number of agricultural fields surrounded by trees, hedges and fences that will

ensure that the lagoon cannot be seen from the neighbouring village nor by users of the

public footpath. The lagoon will not be seen from the Brackley Road adjoining the village of

Croughton either. The size and scale of the lagoon has been designed to fit in with the local

landscape as to ensure that this does not cause any un due visual harm or impact on the

surrounding environment. Overall, I believe that a lagoon will not cause any visual intrusion

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or have an overbearing impact leading to a diminution of conditions to an unacceptable

level.

II. Control & Mangement of Development DPD

Policy CMD 1: Development Criteria for Waste Management. Whites Recycling Ltd recycles

to land a number of different waste streams from the food and drinks industries. This

promotes a sustainable waste network and recovery of nutrient-rich material for

agricultural benefit. The proposed lagoon is sited on local land close to the source factory

providing minimal travel time. Material destined for storage within the lagoon has

undergone preliminary treatment through various means within the factory prior to being

tankered away.

Policy CMD2: Development Criteria for Waste Disposal. The lagoon is designed as a

functional facility for use within a specific catchment area to provide essential storage of

non-hazardous, liquid waste material during periods of inclement weather when it is

deemed unsuitable to spread. The lagoon is to be licensed under the Whites Recycling

Environmental Permit for landspreading operations and material is to be spread on land at

Gateridge Farm. Landspreading of organic food waste material has been recognised by the

Environment Agency as a suitable and sustainable means of disposal with the added benefit

of supplying crop nutrients to productive agricultural land. Material is to be analysed prior

to entering the lagoon by an independent laboratory for its suitability for landspreading.

Analysis is submitted to the Environment Agency for prior approval.

Policy CMD 7: Natural Assets & Resources. Spreading nutrient-rich, organic food waste

material helps to provide a net gain in yield through the addition of organic and readily

available plant nutrients and also reduce the need to apply inorganic, artificial fertilisers.

Policy CMD 8: Landscape Character. The profile of the lagoon is designed to fit into the

natural character of the landscape. The intended position of the lagoon means that it will

not be visible to the local public within neighbouring villages even when using the public

footpath that crosses the farm. The material required to build the structure will be sourced

from the hole and these will form the banks of the lagoon. The banks will be seeded with

grass to ensure that the lagoon blends into the natural landscape. Once the lagoon has been

finished with the site can be restored to its original state by filling the hole back in. This will

ensure that the restoration of the original landscape will always be achieved by simple

means.

9.

Policy CMD 10: Layout & Design Quality. The lagoon is to be sited on a farm and, as such,

this is an agricultural operation within a predominantly agricultural area. The lagoon is to be

sited within an area of the farm that allows permissible access to all fields to ensure that

each field can be reached via an umbilical pipeline. This will prevent continuous traffic from

moving about the fields during spreading operations resulting in unwanted compaction. The

lagoon is construction of the lagoon is to be done in a manner that is safe and meets the

regulatory standards for SSAFO (Silage, Slurry and agricultural fuel oil) enforced by the

Environment Agency. The lagoon will be lined with a synthetic liner approved for use by the

Environment Agency and will be fenced to prevent any animals or persons from entering the

lagoon site unnecessarily. The gate will be locked at all times when not in use and the code

for the lock will be retained by Whites Recycling/Gateridge farm personnel.

Odour Management Plan for the Storage of Odorous Organic Waste Material

1. Procedure Objectives

1.1 To prevent or where that it is not practicable, to minimise, the risks of off Lagoon Site odour

from Organic Material Storage activities as required by the Environmental Permit.

1.2 To ensure relevant persons are aware of the steps which must be taken to reduce the risk of odour from Organic Material Storage activities.

1.3 To ensure relevant persons are aware of the records required.

2. Scope 2.1 This procedure includes the storage of Organic Materials and is specific odour management.

3. Health & Safety Considerations

3.1 There are no significant Health & Safety considerations to be taken into account.

4. Environmental Considerations 4.1 As detailed in the procedure.

5. Responsibility 5.1 A L & C Thompson is responsible for ensuring the records required by these procedures are

completed & securely stored.

5.2 A L & C Thompson is responsible for ensuring checks are undertaken and recorded.

5.3 The A L & C Thompson undertakes an Audit to assess compliance with these procedures.

6. Definitions 6.1 Receptors

Residents of occupied homes and residential areas Employees and customers at industrial and commercial premises.

6.2 Substantiated Complaint A substantiated complaint is considered to be made when the information obtained. Indicated that A L & C Thompson operations are causing an odour nuisance.

7. Odour Management 7.1 If notified by the Environment Agency that the activities are giving rise to pollution

(substantiated complaints/observations) outside the lagoon Site due to odour, the odour management plan will be reviewed.

((Please see location map for nearest receptor)

7.2 To design and implement the plan A L & C Thompson has:

* Identified the likely source of odour * Identified the likely receptors * Determined the control measures to be put in place

* Ensured continuing availability of resources and information necessary to achieve the planned results

* Establish systems to monitor and measure these processes * Identify the action that will be taken of odour is identified as a problem

* Identified who is responsible for taking any required actions

8. Identification of Receptors

8.1 Prior to the application for planning an initial risk assessment was conducted to identify the

receptors (please see location map for nearest receptor).

9. Control Measures to be Employed

9.1 All accepted wastes are sourced from known and approved producers and no unplanned loads

will be accepted. Identification of waste streams will allow any known potential odour issues to be managed.

9.2 A ‘sniff’ test for odours from the Lagoon Site shall be carried out. This shall be recorded.

9.3

On detection or notification of odours that are likely to cause nuisance from waste due to be transported to the Lagoon Site, immediate action shall be taken to stop the waste handling operations that are giving rise to the nuisance. The incident and the remedial actions carried out are recorded.

9.4 A L & C Thompson will take the lead for odour checks. However odour checks will also be

undertaken on other occasions.

9.5 The frequency of the checks will be determined by the likely risk of the exposure which will largely be dictated by the ‘actual’ weather conditions and distance to the receptors.

9.6 Odour checks are carried out by approaching the Lagoon Site from downwind, but if the wind is variable in direction then a wide sweep is carried out to allow a broader area of assessment, prior to making a direct approach to the storage area. It is important for personnel checking odours to allow a period of time (20 minutes or so) away from the storage Lagoon Site to reduce the likelihood of desensitisation. If during these checks an unacceptable level of odour is detected the operation is aborted until the cause of the odour has been ascertained.

9.7 The findings of the checks will be recorded on odour check sheet and these sheets are stored.

10. Action Plan 10.1 Prior to commencement of storage of organic liquids all other integral parts of the Odour

Management Plan must be carried out. In the event of a substantiated complaint the operation will be stopped. A Lagoon Site investigation will be carried out by A L & C Thompson.

10.2 The Operation will only be recommenced when conditions are suitable i.e. wind direction/strength is manageable or storage has ceased to give off offensive odours.

10.3 Authority to recommence will only be given by A L & C Thompson.

10.4 Chain of Command

AL & C Thompson

Agronomy Manager

Farm Liaison Manager

Field Staff

11. Communications

11.1 In the event that complaints are received the. All complaints will be fully investigated and feedback on the findings will be given to the complainant.

11.2 In the event that a problem is detected during the routine checks or following odour complaint where A L & C Thompson are notified by the Environment Agency that an unacceptable odour has been detected off Lagoon Site, storage facilities will cease until reviewed.

12. Incidents and Accidents 12.1 All incidents and accidents relating to the injecting of Organic Material will be dealt with in

accordance with the ‘Emergency Procedures’. The findings of any such incident will be recorded on a non-conformance report.

13. Training

13.1 All persons involved in storing odorous material will be made aware of the procedures in the

odour management plan and their significant responsibilities to ensure compliance. Date: 13/02/2014 Revision Date (unless revision deemed before): 13/08/2014