WEST OF ENGLAND PARTNERSHIP
WEST OF ENGLAND
JOINT WASTE CORE STRATEGY
NON-RESIDUAL WASTE TREATMENT FACILITIES
ON BEHALF OF
PERSIMMON HOMES
Persimmon Homes Special Projects Western
Verona House
Tetbury Hill
Malmesbury
Wiltshire
SN16 9JR
Telephone: (01666) 824721
Facsimile: (01666) 826152
Date: 5th November 2010
West of England Joint Waste Core Strategy
Response on behalf of Persimmon Homes
Non-Residual Waste Treatment Facilities
Key Issue: Whether there is clear and appropriate provision for the development of non-residual waste management facilities.
Q11
Is there adequate justification for identifying the total area of the urban extensions for the location of non-residual waste treatment facilities?
1. Persimmon Homes own the 386 acre former Weston Airfield, which it acquired in 2001, and has promoted for mixed-use development, as part of the proposals that have emerged through the abolished Regional Spatial Strategy, the former Weston Area Action Plan and the emerging North Somerset Core Strategy for an urban extension to Weston-super-Mare. Planning permission has been approved by North Somerset Council to provide units for B1 business, hotel, public house/restaurant and a crèche in the north eastern part of the Airfield and for B1, B2 and B8 in the Industrial Quarter in the south west part of the site, together with the provision of a Cross Airfield Link Road. This has recently been supplemented by a Reserved Matters Application to deal with details of roads, landscaping, drainage and services, which has yet to be determined by the Council. Contracts with a number of commercial operators are in place and negotiations continue with others.
2.A third planning application, which is expected to be reported to Committee in December, is for the first residential phase for the provision of up to 900 homes, a mixed-use Local Centre incorporating a supermarket and other retail units, a primary school and public open space and various engineering works.
3.This background information is important to emphasise that Weston Airfield does not present a blank canvas as part of a planning proposal in a future Core Strategy document whose implementation is someway off, but it is very much a live project, parts of which have planning permission and where works will begin very shortly as soon as the Reserved Matters Application is determined. In our view it is therefore inappropriate for the Joint Waste Core Strategy (JWCS) to identify the Weston urban extension area in its entirety as appropriate for the location of non-residual waste treatment facilities, because of these emerging proposals, which the JWCS does not recognise. Whilst this particular comment relates entirely to Weston-super-Mare, other comments below on the principle of identifying all urban extensions for the location of non-residual waste treatment facilities also apply in other locations.
4.The specific question to address is whether there is adequate justification for identifying the total area of the urban extensions for the location of non-residual waste treatment facilities. However, in our view there is no justification in the strategy for this approach to urban extensions set out Policy 2, and further, that there is actually no justification whatsoever in Paragraphs 6.5.1 to 6.5.6 for any of the locational guidance set out in Parts 1, 2 and 3 of Policy 2. Indeed, the Policy appears to stand entirely alone.
5.Looking in detail at the individual paragraphs: -
-6.5.1 describes the operation of Household Waste Recycling Centres.
-6.5.2 refers to the operation of Transfer Stations.
-6.5.3 discusses different technologies available with a reference that they maybe grouped with other industry.
-6.5.4 does provide locational guidance, that waste treatment facilities are preferred within the urban fabric, although this does not specifically appear in Policy 2.
-6.5.5 cross references with Policy 3.
-6.5.6 cross references with Policy 5.
6.In these introductory paragraphs to the Policy, there is no reference to urban extensions at all and certainly no explanation why they are appropriate. Neither is it clear in Part 2 why previously owned land (or more appropriately previously developed land) is linked as an alternative to urban extensions. Specifically in relation to the guidance that is provided, urban extensions are not part of the urban fabric, but by definition are on the periphery and are generally housing led and housing dominated proposals.
7.Whilst in responding to the Preferred Options Consultation progress update on the 29th July 2009, we suggested an area of search approach would be preferable in addressing the urban extensions, rather than site specific allocations, we did not expect the whole of the urban extension to be identified without further guidance. This is far too blunt an approach and we would have expected a criteria based Policy to enable areas of search to be identified within each urban extension (unless in particular cases it was possible to identify specific areas).
8. Equally, to include within the Policy all of the previously identified urban extensions was also a very blunt Policy approach, which is wide ranging and does not provide proper guidance. Instead a full assessment should have been carried out to show whether they were all an appropriate size and in appropriate locations to accommodate non-residual waste treatment facilities, in order to demonstrate the Policy was deliverable.
9.On the basis that there is no explanation of why it is appropriate to identify the whole urban extension for non-residual waste facilities, we consider Policy 2 fails the test of soundness in PPS12 because it is not justified. One of the key elements of this Policy Test is whether the strategy is the most appropriate strategy when considered against the reasonable alternatives. Again, in this case we say it is not.
10.Firstly, we look at what the JWCS should have considered and then look at subsequent changes in circumstances and consider whether these would dictate a different approach.
11.In looking at what justification is provided, it is clear that non-residual waste treatment facilities are an industrial activity. Paragraph 6.5.3 says such uses maybe grouped together “or with other industry”. In addition, Paragraph 6.5.6 says sites identified in Policy 5 may also be appropriate for non-residual waste related facilities and these are all existing industrial sites. That being the case, there may have been some justification in identifying employment areas within urban extensions as potential locations for such activities. In our view the JWCS should have tested that alternative and assessed whether employment locations in urban extensions would have been appropriate locations for non-residual waste treatment facilities. However, there needs to be a qualification to that, because we do not consider that a blanket assumption that all employment areas would be suitable is appropriate.
12.In the case of Weston Airfield, the employment permission includes a Business Quarter, which will consist principally of B1 office uses, and an Industrial Quarter, which will comprise a mixture of B1, B2 and B8 uses. The Business Quarter will provide a high quality Business Park different in character to what has been provided previously in Weston-super-Mare. Notwithstanding the view expressed in Paragraph 6.5.4 that “the recycling and processing of waste is increasingly being carried out within enclosed, modern, purposed design buildings that can be located in a range of locations”, we consider the perception of a waste treatment facility in the prestige Business Park would be inappropriate.
13.Therefore, if Policy 2 had been amended to refer to employment locations within the urban extensions, this would need to provide some flexibility and ensure that it does not prejudice specific locational Policies in subsequent strategies and plans. Therefore, new Policy guidance would need to be qualified with the word “appropriate” and refer to subsequent Core Strategy, Site Allocation, or Master Plan documents where it would be more appropriate to provide any necessary more detailed locational guidance.
14.If the above approach had been appropriate at the time the submission document was drafted, it is now necessary to examine whether it is still appropriate in the context of the changes to the planning system. Most significant is the Government’s decision to abolish Regional Spatial Strategies, where Policy 2 relies on an RSS Policy requirement for urban extensions, which no longer exists, and in the context of the specific Policy wording will never become adopted. We have seen the Authorities in the JWCS area reconsidering their Core Strategies in the light of this National Policy change, with a general Policy stance to protect the green belt, which is likely to result in most of the urban extensions not being pursued. Weston-super-Mare is outside the green belt, but even here North Somerset Council have fundamentally changed their approach to the expansion of the town by dropping references to an urban extension and reducing the overall size of the proposed extension from 9000 to 5000 – 6000 dwellings. It is now based on a place making and community building approach, leading to the creation of 2 new villages each with their own character and sense of community. These proposals are currently out for Consultation until the 22nd November 2010.
15.Whilst it is clear that proposals for urban extensions both in Weston-super-Mare and elsewhere no longer exist and the wording in Part 2 of Policy 2 “or land that is located within an adopted urban extension area” should be deleted. It therefore follows that the approach we set out above to respond to the position prior to the abolition of RSS by referring to appropriate employment areas in urban extensions would also no longer apply.
16.Further, as there is no explanation in the JWCS of why urban extensions were particularly singled out as appropriate locations for non-residual waste treatment facilities over any other new development allocations, we consider the matter is best dealt with by a simple deletion of the above words, rather than the need to substitute alternatives. The main justification is that non-residual waste treatment facilities should be grouped with other industry and that is allowed for in Part 1 of the Policy, which identifies locations on land allocated for industrial and storage purposes in both existing and new development plan documents. This has the added advantage that new development plan documents should then specifically address the issue of appropriate locations for such facilities which is the right level for such decisions to be considered, in the context of more detailed local strategies, rather than an over-arching JWCS. In that case it would then be helpful if an additional paragraph were added to the JWCS to indicate that in identifying land for industrial purposes, local development documents should identify those sites which are appropriate for the location of non-residual waste treatment facilities.
17.Finally, as referred to above, we assume the first part of Part 2 of Policy 2 should read “previously developed land” and not “previously owned land” and therefore we request that it should be amended accordingly.
5th November 20101