Bespoke Materials Management Plan Framework for Ford Airfield
Enabling sustainable phased earthworks and regulatory agreement for a major residential development in West Sussex
Overview
Omnia Consulting supported our client with a bespoke Materials Management Plan (MMP) on a complex site in Ford, West Sussex.
Ford Airfield is a major phased residential development in Ford, West Sussex, where Vistry South East is bringing forward up to 1,500 dwellings across multiple reserved matters phases. Omnia has supported the project from the pre-purchase stage, acting as geo-environmental consultant and helping the client navigate site investigation, historic data review, hotspot contamination issues and material reuse planning.
A central requirement was to find a practical and robust way to reuse site-won materials across a long-term, multi-phase development while remaining aligned with the principles of the CL:AIRE Definition of Waste: Development Industry Code of Practice. The site presented an important opportunity to avoid unnecessary disposal, reduce import requirements, and support a more sustainable earthworks strategy.
Scope of Works
The development is being delivered through ten reserved matters phases. At the time the strategy was developed, not all phases had full ground investigation coverage, approved remediation strategies or fixed levels information. This created a challenge for a conventional site-wide MMP submission because the standard lines of evidence for protection of human health and the environment, suitability for use, certainty of use and quantity of material could not yet be fully closed out for every phase.
The client also needed flexibility to move clean natural soils between phases and to reuse impacted soils within active phases. Without a bespoke approach, surplus material from early phases may have required off-site disposal, while later phases with material shortfalls may have needed imported soils. The scale of the opportunity was significant: upwards of 65,000 m³ of topsoil and upwards of 285,000 m³ of subsoil are proposed for reuse across the development.
A further complexity was the presence of coal tar material associated with former runway construction. Rather than defaulting to off-site hazardous landfill disposal, the project team explored a managed treatment and reuse route so that approximately 45,200 m³ of coal tar material could be repurposed as road subbase, subject to appropriate controls and approvals.
The Bespoke Materials Management Plan Framework
Omnia developed a phased Materials Management Plan framework designed to work within the CL:AIRE approach while reflecting the practical realities of a large, long-term development. The strategy uses one overarching MMP covering the outline red line boundary to establish the principle of reuse on the site of origin, supported by individual phase-specific MMP submissions as each reserved matters phase comes forward.
- Each phase-specific MMP is to be updated once the relevant reserved matters application, site investigation information and remediation strategy have been approved.
- Clean, naturally occurring surplus soils may be moved between phases where a defined need and suitable receiving area are demonstrated.
- Made Ground and impacted soils are managed within the phase from which they arise and reused only in accordance with the approved remediation strategy, such as beneath hardstanding or proposed cover systems.
- Where contamination is identified, materials are treated, managed or removed as required within that phase before reuse is considered.
Ground Conditions and Material Types
The general ground model comprises topsoil over superficial Brickearth, typically a sandy, gravelly silty clay, underlain by Raised Beach Deposits, typically fine to coarse sand, and then Upper Chalk bedrock. Discrete pockets of Made Ground were identified across the site, associated with historic uses, including coal tar beneath former runway areas. Materials considered within the strategy include topsoil, Made Ground, coal tar material, clay, sand and chalk.
Regulatory Engagement
Early engagement was central to the success of the strategy. Once the proposed route had been developed with the project Qualified Person, Omnia contacted both the Environment Agency and the Local Planning Authority by email to explain the constraints, the proposed phased approach and the safeguards that would be built into future MMP submissions.
The Local Planning Authority confirmed that it had no concerns with the proposal and agreed that a degree of flexibility was appropriate to enable the project to progress across multiple phases. No revisions were requested, and the approach was agreed by email, providing confidence that the project could proceed using a managed, transparent and regulator-aware framework.
Outcomes
Through the development of a flexible phased Materials Management Plan (MMP) framework, Omnia enabled the Ford Airfield project to progress despite each reserved matters phase being at a different stage of investigation, design and approval. The MMP strategy supports the sustainable retention and reuse of significant site-won material volumes, including upwards of 65,000 m³ of topsoil and 285,000 m³ of subsoil across the development, while also allowing approximately 45,200 m³ of coal tar material to be treated and repurposed as road subbase subject to appropriate controls. By using a bespoke Materials Management Plan approach, the project reduces reliance on imported materials and off-site disposal, helping to lower costs, reduce lorry movements and minimise environmental impact. The phased MMP framework also maintains clear governance through phase-specific Qualified Person review and CL:AIRE sign-off as each phase comes forward.
This project demonstrates the value of considering soil reuse early in the design process. By engaging with the client, Qualified Person, Environment Agency and Local Planning Authority at an early stage, Omnia was able to develop a measured and defensible strategy that maximises reuse while maintaining appropriate environmental safeguards.
The approach is particularly relevant to other large, phased developments where not all reserved matters phases are sufficiently advanced to support a single conventional MMP submission. It shows that, with early planning, suitable evidence and clear phase-by-phase controls, the principles of the CL:AIRE framework can be applied in a flexible way that supports sustainable development outcomes.





