Coastal landfill sites: risks and solutions

I don’t necessarily foresee any changes on the horizon, but one of the factors that significantly elevates the offsite removal costs is landfill tax. It would be nice if this could be waived or significantly reduced for projects at historic landfill sites/legacy land contamination sites that are aiming at an ‘environmental betterment’ (i.e. are ‘not for profit’ schemes to improve access to public spaces; safeguard wildlife; safeguard public health, etc., and are not simply brownfield remediation that is clearing the way for commercial development).

Whilst I agree that funding is a major constraint, if there is a sufficient political will then something can happen. So, rattle a few political cages. At the Trow Quarry site, which was 15+ years ago now and so under a different FCERM funding regime, we had a sit-down discussion with the Environment Agency Area Manager (who at that time locally controlled funding allocations up to a certain sum – perhaps around £2m from memory) who acknowledged the problem, the need for something to be done and the difficulties in gaining funding using a ‘traditional’ business case method. He agreed (with approval from his national-level seniors) to relax the usual requirements given the bespoke nature of the issues and demanded only a benefit-cost ratio greater than unity to warrant allocating the funding. We considered issues like damage to the natural habitats and species, potential loss of life through encountering cyanide, etc.). At Lynemouth, which was more recent, there was zero prospect of an FCERM grant and so the local authority funded the scheme themselves, through borrowing from central government. There was a recent review of the Treasury Green Book, and recommendations from that placed greater emphasis on non-monetised benefits rather than the traditional Benefit-Cost ratio approach. Maybe that is a way forward …?

The point about ‘aftercare’ is valid. Yes, both scheme examples require aftercare (essentially visual inspection at Trow Quarry and inspection/clear-up at Lynemouth) which are relatively modest costs and are borne by the respective local authority budgets.

Trow Quarry pre-dated the present marine licensing regime but did need a FEPA licence (the equivalent of this now would be a Marine Licence) and planning permission. The waste that was excavated during earthworks (slope re-grading) was relatively small in volume and so was taken off-site for disposal as contaminated material. This aspect therefore did not need licensing.

At Lynemouth, we were surprised that the works did not need a Marine Licence (being located wholly above mean high water springs) but it did need planning permission. Furthermore, because we were treating waste and re-using the treated spoil on site for backfill, we required a Deposit for Recovery Environmental Permit from the Environment Agency. This was a costly, arduous and time-consuming process (the process is geared towards avoiding unregulated deposit of wastes and not well suited for works such as this at an historic coastal landfill – I have a paper forthcoming on this at the ICE Coastal Management Conference in September 2025). The use of an on-site mobile treatment facility needed a deployment notice agreed with the Environment Agency too.  I consider that a streamlining of the environmental permitting process (or a bespoke process) for historic coastal landfill sites would be welcomed. 

Nope, the physical treatment simply separated the ‘waste contraries’ from the colliery spoil so that they were ‘abundantly free’ of those polluting contraries. It was intended as an ‘environmental betterment’ (horrible words) scheme and so this approach was accepted given the low residual risk.

There is not a standard suite as such, I think this needs to be informed by your desk study approach as to what is/may be in the site and guided by land quality specialists, and/or informed by the requirements of any Remediation Strategy/planning permission/environmental permit.  We tested both soils and water (groundwater and surface water) and subjected samples to chemical lab testing for various determinants; we also undertook leachate tests and asbestos tests too. It is important to understand – in advance – what are the limits of detection for the lab you propose to use; we had some difficulties finding labs that had the limits we demanded.