To respond to consultation by Cambridgeshire County Council and Peterborough City Council on the two draft supplementary planning documents relating to waste management. The Appendices are attached to the electronic version of the agenda on the Council’s website.
The Portfolio holders for Planning and New Communities AGREED the responses to the consultation on the two Supplementary Planning Documents (SPDs) as given below and in Appendix 2 for The Location and Design of Waste Management Facilities SPD and Appendix 3 for RECAP Waste Management Design Guide SPD:
“The Location and Design of Waste Management Facilities SPD (draft)
“South Cambs welcomes the detailed guidance produced in this SPD and welcomes that rural locations have been considered separately thereby recognising the different considerations that must be given to locating waste management facilities in countryside settings such as is found in much of South Cambridgeshire. Also that separate consideration is given to urban fringe sites and major development sites of which South Cambs has within its boundaries.
“There needs to be recognition within the SPD that South Cambs has a number of adopted planning policy documents in the Local Development Framework. For planning applications for waste management facilities within this district there are a number of relevant Development Plan Documents (DPD) and Supplementary Planning Documents (SPD) that would need to be considered.
“In the principles to apply for rural locations one must be added that considers the traffic generated by a waste facility particularly heavy commercial vehicles (HCV) so that there is not an increase in unsuitable traffic on rural road through rural settlements. The criteria is applied to both urban and urban fringe locations but is equally as valid in rural areas if traffic ends up going through nearby villages.
“There also needs to be consideration of impact that locating a waste management facility will have on the existing local communities in urban fringe and major development sites. The needs of these communities must be taken into account in planning these facilities.
“The SPD promotes the idea of the co-location of related waste facilities which although may have significant benefits, would obviously result in a much larger of scale development. This would be potentially more intrusive on the environment thereby reducing those sites that could be considered suitable.
“Waste Management sites have potential to cause significant and complex noise impact. South Cambs has concerns about how noise is addressed in the SPD. In the section considering noise (page 36) reference is made to a noise report ……..and appropriate mitigation measures…………but does not detail that the main purpose is to assess noise impact locally, characterise the existing noise climate at noise sensitive premises and use the best practical means to mitigate any adverse noise as necessary. This must be included in this section to safeguard amenity and minimise noise disturbance from any future facilities.
“Also in the SPD reference is made to guidance against World Health Organisation Community Noise Guidelines and actual dB levels are quoted e.g. 55dB day 45 night and or no more than 5 to 10 dB increase in background. These actual dB noise levels should be used with caution as these levels can be misleading and understate impact. South Cambs requests that any reference to actual dB noise levels should be removed and simply state that noise will be assessed on a site by site basis on its merits having regard to local circumstances. It would be simpler within the SPD to refer to assessment in accordance with PPG 24 methodology and recommended noise guidance in WHO and best practice such as British Standards.
“The SPD considers the air quality of waste facilities but narrows this consideration to the impact arising from traffic. There should also be included the air quality issues arising from the on-site operations of the facility.”
“The Recycling in Cambridgeshire and Peterborough Partnership (RECAP)
Waste Management Design Guide SPD (draft)
“Whilst recognising that this document has been in existence for a while it does not appear to have been reviewed thoroughly before it has been approved for consultation as a draft SPD. An SPD cannot create new policies but must support policies in an adopted Development Plan Document and it is not clearly stated within the SPD which policies the SPD is providing guidance to. The structure of the SPD must be revised so that this fundamental fact is made clear at the beginning of the document.
“The SPD states that one of the purposes of the document is to be ‘ a strategic tool for use for Planning Authorities when assessing development applications.’ An SPD cannot have this strategic role – it can only provide guidance for local planning authorities when they are considering planning applications, supporting policies in a Development Plan Document.
“Mention is made in the SPD of the need for a ‘ waste audit ‘ to be carried out by a developer of a development proposal but there is no definition of this term or what it may include. This must be included in the SPD to assist both developers and local planners.
“If this is to be used by planners and developers the SPD as a design guide must be easy to use and the SPD as drafted needs to be revised so that it is clearer what the planners should ask for from developers submitting planning applications e.g. if a waste audit is required and what developers should provide when submitting a planning application. It is unclear whether a developer would be expected to produce both a waste audit and to complete the Toolkit included in the SPD.
“If it is expected that a ‘Toolkit’ be filled out for each planning application submitted by a developer then consideration needs to be given as to the format of the SPD and where the Toolkit is placed within the document. Consideration should be given to making the Toolkit section of the SPD as a clearly identifiable part. Suggestions to achieve this include putting it at the end of the SPD with a different coloured background or font to make it easily seen. As a paper document the SPD could have a pocket in the cover in which the Toolkit is placed so that it can be accessible. An electronic version of the SPD could have the Toolkit as a separately accessible document, which could either be downloaded as a Word document or printed off so that it can be filled in and submitted with a planning application.
“The earlier version of the Waste Design Guide was adopted by South Cambs as Council Policy in March 2008 and planners have referred developers to the guide before they submit planning applications to the Council. South Cambs encourages pre-applications discussions with developers. There is no indication in the current SPD or in the accompanying report, which was prepared by County planners in September 2009 of the success of the guide, and details of which other local planning authorities within Cambridgeshire had adopted it as Council Policy. It would be useful to know what success there was been in improving the waste management content of planning applications as a result of the existence of the guide. The toolkit appears to be a useful way of assessing the waste needs of a development but are developers submitting these with their applications?
“The chapter setting the planning and policy context of the SPD refers to documents but does not make it clear who has published these and the relevance of their content. The section on the Minerals and Waste Development Plan is particularly weak and does not appear to reflect that the MWDP is at the proposed Submission stage, being out for consultation at the same time as this SPD. This must be amended and further highlight the difficulties of consulting on this SPD when the MWDP is not yet adopted.
“Part 3 on ‘Waste Management in Context’ needs to mention the fact that Cambridgeshire comes within the area identified by Central Government as an area where there will be a step change in growth and that this is planned for in the East of England Plan up to 2021 and beyond. It is not just the popularity of the area that has led to an increase in its population but it has been specifically identified as a growth area where there will be a planned step increase in house building.
“The SPD in considering the practical needs of how to assist a developer in planning for waste management in residential and commercial developments is welcomed by South Cambs. It will assist planners to recognise the need to consider waste within proposed developments. However the emphasis seems to be upon the technical / functional specifications needed for waste facilities at the expense of considering the aesthetic design of such facilities to fit into their surroundings. This should be addressed in the SPD.
“The SPD should highlight to developers that there will be financial implications relating to the provision of waste management infrastructure. These will vary according to the nature and scale of the proposed development and associated supporting infrastructure and will be based on any additional costs likely to be incurred by the local authority arising out of the proposed development.
“The Council is concerned at the lack of information within the Design Guide to justify the request for contributions to household recycling centres. Planning obligations cannot be used to ask developers to simply provide contributions to extra sites. There are five tests that have to be satisfied to allow obligations to be sought.
1. Relevant to planning;
2. Necessary to make the proposed development acceptable in planning terms;
3. Directly related to the proposed development;
4. Fairly and reasonably related in scale and kind to the proposed development; and
5. Reasonable in all other respects.
“In the MWDP Core Strategy in Policy CS16 it states that ‘…New housing development will contribute to the provision of household recycling centres. Contributions will be consistent with RECAP Waste Guide….’. South Cambs is concerned that the DPD cannot require such contributions from planning obligations and as drafted the SPD does not contain sufficient information about this matter to provide guidance to developers.”
The Planning Portfolio Holder and New Communities Portfolio Holder considered a report seeking agreement to a proposed response by South Cambridgeshire District Council to consultation currently being carried out by Cambridgeshire County Council and Peterborough City Council. The consultation related to Supplementary Planning Documents relating to
· The Location and Design of Waste Management Facilities
· The Recycling in Cambridgeshire and Peterborough Partnership (RECAP) Waste Management Design Guide.
The Planning and New Communities Portfolio Holders agreed that the Council should respond to Cambridgeshire County Council in the terms contained in the report and as set out in Appendix 2 for The Location and Design of Waste Management Facilities SPD and Appendix 3 for ReCAP Waste Management Design Guide SPD.