1. PEAT, WASTE &
BORROW PITS
Jane MacDonald
Wednesday 21st Oct 09
2. KEY QUESTIONS
1) Why borrow pits?
2) What does it have to do with ‘waste’?
3) Why am I talking about it today and what relevance
does it have for CLAD?
3. 1. Why borrow pits?
Borrow pits are required to win rock / aggregate for
road and other wind farm infrastructure construction.
Restoration of borrow pits to pre-construction ground
profile is preferable for habitat restoration and
visual / land use amenity purposes.
7. 2. What does it have to do with ‘waste’?
One of the principle objectives
Site
Office of the WFD directive is to
minimise impacts to the
environment and human health
from waste disposal to land.
Are we creating landfills in
restoring borrow pits?
Its all in the interpretation
of legal definitions…
8. DEFINITIONS OF WASTE & DISPOSAL
WFD WASTE DEFINITION
“any substance or object [ ] which the holder discards or intends or
is required to discard”.
“Products for which the holder has no further use.”
WFD DEFINITION OF DISPOSAL
Deposit into or on to land, including surface impoundment and
specially engineered landfill.
Is excavated peat ‘waste’ and is borrow pit restoration ‘waste
disposal’?
No, because….
9. A MORE PRAGMATIC CONSTRUCTION PERSPECTIVE?
• GENERALLY ACCEPTED PRINCIPLES:
Excavated soils used on site, would not generally be regarded as being
discarded (i.e. not waste) provided:
• They are suitable for that use and require no further treatment
• Only the quantity necessary for the specified works is used
• Their use is a not a mere possibility but a certainty.
The Developer / Contractor has to provide sufficient justification to
prove that the materials are not classified as waste in the first
place and there use does not pose a risk to human health or the
environment.
Otherwise, what are the implications?…..
10. WHAT ARE THE IMPLICATIONS IF RESTORATION OF BORROW
PITS IS DETERMINED TO BE WASTE MANAGEMENT?
• WML exemption will be required for surplus material – however: use
constrained by volume and throughput limitations.
• PPC license may be required:-
Prohibition on liquid disposal
EWC excludes peat as inert waste (classified as non-hazardous waste).
Separate planning application, EIA and landfill design risk assessments for
each borrow pit ‘landfill’ (delay and cost implications)
Landfill regs require pre-treatment of wastes (little or no additional
environmental benefit in this instance??)
Public opposition /perception of ‘landfills’ / landowner lease implications
11. 3) Why am I talking about it today and what
relevance does it have for CLAD?
• Clearly there is a need for the industry to demonstrate the requirement for
restoration of borrow pits and ways of achieving this without endangering
human health and the environment.
• Can we define best practice in handling and storage of excavated
materials, as well as final placement in borrow pits such that C losses are
minimised?
Is there a need to quantify C losses and environmental impacts for
alternative off-site options (landfill disposal, re-use as fuel etc) and on-site
uses?
Can we demonstrate that restoration of borrow pits is the BPEO? (e.g.
through quantification of C losses, ecological monitoring programmes on
existing sites etc)
