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Appendix x NEW 

Developments on Peat and Off-Site Uses of Waste Peat 

Legislation & Policy 

The Environment (Wales) Act 2016 introduces the concept of the “sustainable management 
of natural resources”. This means— 

(a) using natural resources in a way and at a rate that promotes achievement of the 
objective of meeting the needs of present generations of people without compromising the 
ability of future generations to meet their needs, and contributing to the achievement of 
the well-being goals in section 4 of the Well-being of Future Generations (Wales) Act 2015 

(b) taking other action that promotes achievement of that objective, and 
(c) not taking action that hinders achievement of that objective. 

One of the 5 Key Planning Principles set out in Planning Policy Wales Edition 10 is making 
best use of resources. The efficient use of resources, including land, underpins sustainable 

The planning system has a vital role to play in making development resilient to climate 
change, decarbonising society and developing a circular economy for the benefit of both the 
built and natural environments and to contribute to the achievement of the well-being 
goals. The national sustainable placemaking outcomes which lead from this principle include 
making the best use of resources and the prevention of waste. 

Peat Resource 

Peat is a body of sedimentary material, usually dark brown or black in colour, comprising the 
partially decomposed remains of plants and organic matter that is preserved in anaerobic 
conditions within an essentially waterlogged environment. 

There are two principal types of peat: 

1. The upper (acrotelm) layer which is quite fibrous and contains plant roots etc. Acrotelmic 
peat in good condition, is wet. This is the part of the peat profile that may dry out during 
the summer or times of drought. Water moves relatively quickly through acrotelmic peat. . 

2. The lower (catotelm) layers are highly amorphous, with very high water content and tend 
to have very low tensile strength. Water moves relatively slowly through catotelm layers. 
The structure of catotelmic peat tends to disrupt completely on excavation and handling. 

Peatlands hold large stocks of carbon. When peat is left undisturbed the carbon is 
protected. Problems only arise when the peat body is drained, burnt or over-grazed. The 
excavation of peat will result in large carbon losses from the excavated peat and also the 
areas affected by drainage. Minimising peat excavation will reduce these potential carbon 
losses and consequently reduce the carbon payback period associated with developments 
on peat. 

Excavated peat will be classified as waste if it is discarded or the holder intends to or is 
required to discard it. Unless the waste peat is certain to be used for construction purposes 
in its natural state on the site from where it is excavated, it will be subject to Natural 
Resources Wales (NRW) regulatory controls. 

The recommended management options for developments on peat are based on the the 
waste hierarchy: 


The best management option for peat on a development site is to design the development 
so that it is left in situ wherever possible. 

This can be done through the use of forward planning, comprehensive on-site investigations 
and the use of Peat Management Plans or Natural resource management plans and 
assessment of alternative construction methods e.g. piling. The early consideration of these 
techniques will allow developers to prevent/minimise the excavation of peat and the 
production of waste peat. 

On-site use 

If the excavation of peat cannot be avoided, developers should prioritise the use of 
excavated peat on-site in the first instanceby exploring restoration opportunities -catotelmic 
peat is very good for use in peat dams, contour bunds etc, whereas acrotelmic peat is not. 
These activities should minimise carbon loss and maximise ecological benefit. 

Off-site options: Uses of peat & recycling/recovery/treatment 

After on-site uses have been exhausted, excavated waste peat may be suitable for use off- 
site within the local area. This should be identified in the peat management plan, including 
estimated volumes for each use, destination, final intended outcome and justification of 
suitability of the peat material and the need for the specified quantities of peat material. 


Highly organic materials such as peat can have a devastating impact on watercourses if they 
wash off from storage areas. It is also important to use the peat as soon as possible after 
excavation (to minimise the exposure of the peat to the air) and to maintain moisture 
conditions in the peat to keep carbon losses to a minimum. 


Disposal of peat, particularly catotelmic peat, can lead to a number of issues due to its very 
low tensile strength and high water content e.g. 

e Itis likely to have a very low load bearing capacity, making it a hazard to people or 
animals walking on it if not used correctly. There are examples of peat dams and low 
contour bunds having been constructed from catotelmic peat. Livestock use these 
dams and bunds to move around on however, they are no more than 30cm high. 

e Slides or movement are highly likely and can be caused by heavy rainfall but only if 
used incorrectly and not re-profiled to allow vegetation colonisation. 
e Potential for contaminated run-off again if used incorrectly. 

Peat arising and requiring management as a waste within a development will require 
characterisation and consideration of its condition upon excavation. 

The propensity of the waste peat to flow will be a key characteristic in determining whether 
it can be landfilled i.e. if it is classified as a liquid it cannot be landfilled without some form 

of pre-treatment.