AUGEAN EAST NORTHANTS RESOURCE MANAGEMENT FACILITY
APPENDIX CRAL
REPRESENTATIONS TO THE MINERALS AND WASTE DEVELOPMENT FRAMEWORK
March 2012 Minerals and Waste Development Framework Issues and Options Paper Growth Management Northamptonshire County Council PO Box 163, County Hall Northampton NN1 1AX
Dear Sirs Minerals and Waste Development Framework Kings Cliffe Western Extension We are pleased to enclose our response to the Issues and Options Paper together with submissions for the allocation of the extension of the hazardous waste landfill at Kings Cliffe in the MWDF.
In support of the inclusion of Kings Cliffe Western Extension we provide an appraisal of the extension area undertaken following the County Site Assessment Methodology together with a landscape report and a hydrogeology report. We have commissioned an Agricultural Land Classification survey, a Phase 1 habitat survey and a historic environment desk study which should be available by the end of May 2007. We should be pleased to provide you with copies of these documents.
We trust this information is suitable for your purposes. We should be pleased to meet to discuss the proposals is this would be of assistance. Please do not hesitate to contact us should you have any queries or need further information.
Yours faithfully
Gene Wilson Group Technical Director
WS010001/ENRMF/CONSAPPCRAL 1 Minerals and Waste Development Framework Issues and Options Paper Growth Management Northamptonshire County Council PO Box 163, County Hall Northampton NN1 1AX
20 June 2007
Dear Sirs
Minerals and Waste Development Framework Kings Cliffe Western Extension
Further to our submission of 12 April 2007, we are pleased to provide three reports to supplement the submissions made:
Cultural Heritage Baseline Report – May 2007 Soils and Agricultural Land Classification – May 2007 Kings Cliffe Potential Extension Phase 1 Habitat Survey – 11 June 2007
Based on the conclusions of the reports, we consider that no archaeological, ecological or agricultural issues have been identified that would preclude development of the site in accordance with our proposals. It is recognised that further surveys will be needed in respect of ecology and perhaps archaeology to support the application for planning permission. We should intend to agree the scope of such surveys as part of the Environmental Impact Assessment that will be necessary for the development. Any mitigation necessary will be determined during the process and incorporated in the design proposals for the site.
We trust that this information is of assistance to you. Please do not hesitate to contact us should you have any queries.
Yours faithfully
Gene Wilson Group Technical Director cc Phil Watson
Enc
WS010001/ENRMF/CONSAPPCRAL 2 Agenda Item No: D2 NORTHAMPTONSHIRE COUNTY COUNCIL
CABINET
10 September 2007
Report by Director for Community Leadership
Cabinet Member for the Environment: Councillor Ben Smith
Subject: Minerals and Waste Development Framework: Core Strategy and Locations for Minerals and Waste Development Preferred Options
Advice: Cabinet is asked to agree that consultation on the Preferred Options can be initiated.
1. Intended Outcome
1.1 Approval of the preferred options for consultation, leading to the ultimate adoption of the core strategy and locations documents as fundamental parts of the new Minerals and Waste Development Framework (MWDF). The MWDF will drive investment in minerals and waste development in Northamptonshire to 2026.
2. Relevant Council Strategic Goal and Priority
2.1 The Medium Term Plan vision is ‘one council focussed on customers and community leadership priorities’. The adoption of key parts of the MWDF helps achieve the following strategic goals and priorities:
Medium Term Plan and Strategic Goals Council Priority
Communities A cleaner and greener The built, natural and public county environment is better developed and maintained.
3. Background
3.1 The Planning and Compulsory Purchase Act (September 2004) brought in a totally changed development planning system. This sees the replacement of local plans by development frameworks.
3.2 In the case of minerals and waste planning authorities such as Northamptonshire County Council, our Waste and Minerals Local Plans (adopted March and May 2006 respectively) will be replaced by a Minerals and Waste Development Framework (MWDF). Unlike a local plan, which is a comprehensive document covering the whole of its area, the MWDF is actually the name given to a portfolio of what are known as ‘Development Plan Documents’; these are effectively a series of local plans covering specific issues and topics. These Development Plan Documents (DPDs) will cover that
WS010001/ENRMF/CONSAPPCRAL 3 which is necessary to set out the future land use planning context for Northamptonshire for minerals and waste development.
3.3 The MWDF for Northamptonshire is to comprise the following DPDs: The Core Strategy for minerals and waste development- this is the main component of the MWDF and sets out the development strategy for minerals and waste by outlining the broad provision that needs to be made for such development to 2026, and the strategic spatial considerations that will apply to enable this provision to be accommodated within Northamptonshire. The Locations for Minerals Development- this identifies locations for minerals development in Northamptonshire and the particular considerations that will apply, especially in relation to the specific sites allocated in the DPD. The Locations for Waste Development- which will identify locations for waste development in Northamptonshire and the particular considerations that will apply, especially in relation to the specific sites allocated in the DPD. Control and Management of Development- this sets out policies on which individual proposals for minerals and waste development will be determined and then implemented- this will include proposals for both allocated and non-allocated locations and uses. The MWDF will also comprise a non-statutory supplementary planning document (SPD) on Development and Implementation Principles- this provides more detailed guidance on the standards and requirements for developing, implementing and restoring sites identified for minerals and waste development and also covers general matters of minimising waste in new development. This SPD was adopted by the County Council in March 2007.
3.4 The Core Strategy and the two ‘location’ DPDs are those that are currently being taken forward. Work will not commence on the Control and Management of Development LDD until next year.
3.5 The process of moving to adoption is substantially different for DPDs compared to the old local plans. There are two formal stages of consultation- preferred options and submission. Preferred options set out the planning authority’s emerging view of the way forward and the likely policies and locations that should be pursued- there is a six weeks formal consultation on preferred options. The submission stage is when the final DPDs we would wish to adopt are submitted to the Secretary of State for a subsequent public examination (and at submission also consulted on formally for six weeks).
3.6 Following submission a public examination into each DPD is held- this may be nine months to a year after the submission. A public examination is not the same as the old local plan public inquiry, as its purpose is not to deal with all objections to the DPDs but rather to examine through roundtable sessions whether the plan is sound. There are a number of tests of soundness that have to be met, and if they cannot be met, or small changes made to the DPD to enable it to be met, then the DPD cannot be adopted. The independent inspector who chairs the public examination will make this judgement and this is binding on the county council. Appendix 2 shows the soundness tests that will need to be met by the county council in its DPDs.
4. Consultation
4.1 Over the past sixteen months work has been ongoing on getting to the stage where it is considered we have preferred options that are sound. There has been consultation and engagement as part of this process.
WS010001/ENRMF/CONSAPPCRAL 4
4.2 In May 2006 there was a request for those who wanted to put sites forward for possible inclusion in the MWDF to do so. There was a full consultation on the issues that had been identified and options for the way forward held from February to April this year; this consultation included opportunities to comment on the acceptability of the sites that had been put forward for possible inclusion in the relevant DPDs. We have also met with GO- EM and with statutory bodies including Natural England during the preparation of the preferred options to discuss issues arising and how to address them. We also separately consulted with neighbouring minerals and waste planning authorities in drawing up our proposed spatial strategy.
4.3 The issues and options consultation held in the spring led to responses being made by 320 individuals and organisations. A number of respondents gave a response for each issue and option, but the largest number were representations solely objecting to the possible inclusion of one or more sites in the location DPDs. The majority of site specific objections (and half of all representations) related to the possibility of mineral extraction at Welford Lodge Farm; this illustrated not so much unacceptability of development here, but rather the existence of a strong action group in the vicinity.
5. Proposal
5.1 As is the case with any planning documents their content is not solely shaped by the consequences of consultation, but also by general planning principles, by central government guidance and by the situation on the ground. One of the major considerations we have to have regard to in developing preferred options is to the test of soundness, and particularly in this respect for the DPDs we have prepared to have a coherence within and between them and for this to be underpinned by a clear spatial strategy. County councils elsewhere who have reached preferred options stage have generally up to now been found wanting in these respects, and we therefore need to have an emerging strategy and policies that can clearly be demonstrated to be sound.
5.2 We have undertaken a sustainability appraisal including strategic environmental assessment of the emerging strategy and policies, and have assessed all sites put forward in respect of a wide variety of criteria (we consulted on the criteria used with the statutory environmental bodies), and for those in the proximity of the special protection area for birds in the Nene Valley, a Habitats Regulation Assessment that has to approved by Natural England; they have done this, seeing our HRA as an exemplar for other authorities to follow.
5.3 The generality of what the county council is therefore proposing, following assessment and consultation, as the key elements of its preferred options is summarised in the remaining paragraphs of this section. It should be noted that identification of a location for a minerals or waste-related use in any adopted DPD will not imply that planning permission will automatically be granted.
Core Strategy
Vision and Objectives
5.4 It is proposed to have a vision and objectives that are more specific to Northamptonshire.
5.5 The proposed new vision is:
WS010001/ENRMF/CONSAPPCRAL 5 The Northamptonshire of 2026 will have undergone rapid, widespread growth. Investment in the delivery of a high quality built and natural environment will be underpinned by materials resource efficiency and addressing waste as a resource.
The Minerals and Waste Development Framework will support the creation of sustainable communities in Northamptonshire through the provision of appropriate mineral resources and the development of a modern waste management network.
5.6 The objectives have been radically revised and been reduced to a more manageable and appropriate number of twelve.
Providing for Minerals
5.7 In relation to the provision for mineral extraction, the core strategy proposes to roll forward the current annual regional apportionment for Northamptonshire through to 2026- for Sand and Gravel this will be 0.97 million tonnes per annum, and for Crushed Rock 0.4 million tonnes per annum.
5.8 Because of the particular difficulties in finding soft sand sites in the county a specific apportionment figure for soft sand within the wider sand and gravel apportionment is not currently proposed to be made. There will be soft sand sites identified within the Locations for Mineral Development DPD to form part of the allocations for sand and gravel, but these will not be to the proportion that could be expected on the basis of past sales. However if any new potential soft sand sites are put forward during the preferred options consultation that, following assessment, are considered to be acceptable then we may reconsider this policy stance at submission stage.
5.9 No specific provision figure for building and roofing stone will be identified in the Core Strategy. However sites for the extraction of building and roofing stone will be allocated in the Locations for Mineral Development DPD where acceptable sites for such extraction have come forward. In addition criteria for further extraction of building and roofing stone at other locations (beyond the provision coming from the allocated sites) will be included.
5.10 Sites with old mineral permissions (those dating from before the modern planning control system when permissions for mineral extraction were for perpetuity) will not count towards meeting our apportionment of crushed rock largely as these are in most cases sites that are effectively permanently dormant. The apportionment will be met by specifically allocated sites in the DPD. However part of the site with an old permission at Wakerley will be counted as an allocated site for crushed rock.
Providing for Waste Generated
5.11 Further technical work on forecasting waste generation has been undertaken. This has identified that during the core strategy period we need to move towards meeting the following indicative provision. It should be noted that these are indicative figures for all waste and not just the 12% of waste that is municipal waste: Recycling and composting (both municipal and commercial and industrial waste) capacity of 820,000 and 970,000 tonnes per annum for 2016 and 2026 respectively. Landfill diversion (both municipal and commercial and industrial non-inert waste) capacity of 455,000 and 520,000 tonnes per annum for 2016 and 2026 respectively.
WS010001/ENRMF/CONSAPPCRAL 6 Inert recycling capacity of 930,000 and 1,090,000 tonnes per annum for 2016 and 2026 respectively. Hazardous waste management of 45,000 and 50,000 tonnes per annum for 2016 and 2026.
5.12 In developing our waste forecasts we are proposing a slight divergence from regional policy. Regional policy supports no growth in waste generation across the East Midlands as a whole beyond 2016; whilst this is a laudable aim, it is our contention that the mechanisms and drivers to bring this about are not clarified to prove this is realisable, and that therefore this has to be seen as an aspiration and not a firm target. Additionally this county will also be one of the country’s fastest growing areas up to and well beyond 2016 and therefore there has to be some acceptance here, if not the region as a whole, of growth in waste continuing post 2016. On this basis we are proposing to assume that waste generation growth progressively reduces but that it does not end after 2016. Taking this approach will ensure that we are not left with a capacity gap if, as we consider will be the case, growth in waste generation is unable to cease after 2016 in our part of the region.
The Spatial Strategies to Meet Provision
5.13 Spatial strategies have been proposed to guide the location of mineral extraction and of waste management facilities.
5.14 The spatial strategy proposed for mineral extraction is: - to focus on the county’s pre-glacial and glacial deposits, but to also complement extraction in these locations by allowing extraction of remaining high quality reserves from the previously and currently worked river valleys of the Nene (between Northampton and Wellingborough) and the Great Ouse; - to safeguard the predominantly un-worked river valleys of the Welland, Tove, Ise and the Nene (east of Stanwick) from minerals extraction throughout the whole of the Core Strategy plan period.
5.15 This strategy is a change from that which has operated for the previous 15 years, and is different in that it would no longer prevent additional extraction in the Nene Valley west of Stanwick beyond existing proposals, and would also allow similar in the Great Ouse Valley. This change would be the only key policy change from the existing Local Plans across all three of the new DPDs.
5.16 The rationale behind the previous policy stance was that extraction was more environmentally significant in river valleys because of its restoration to water, which changes the character of the valley. However by filling extracted sites with inert fill (ie earth), then there will not need to be a restoration to large areas of water. Furthermore the previously favoured location of the glacial areas is not without difficulty: there are often landscape impacts to consider that are as great as those in the river valleys, and for restoration either the same inert fill is required or a re-profiling of the gradient of the site has to take place.
5.17 It should also be noted that although there was a policy of restriction in respect of river valley extraction over the past fifteen years, there remained sites identified for extraction in Local Plans, so no embargo on development in the Nene Valley had actually occurred. In addition no glacial sites had commenced working during this period (other than at Bozeat); this was partly due to the quality of reserves which are of poorer quality compared to those in the river valleys and therefore industry interest was correspondingly muted.
WS010001/ENRMF/CONSAPPCRAL 7 5.18 Therefore it is considered that allowing extraction from those parts of the valleys where extraction is taking place would actually result in no greater environmental impact than the previous policy stance. Interestingly it would also only lead to two river valley sites not previously allocated being allocated this time around.
5.19 The spatial strategy for waste management is to develop a sustainable network of advanced and preliminary waste management facilities serving neighbourhood, local, sub-regional, and where appropriate regional and national catchments, that: - are focussed on Northamptonshire’s main urban spine (identified as Northampton- Wellingborough/ Rushden- Kettering- Corby); - has a secondary focus at Daventry; - has facilities of an appropriate scale and role at the remaining urban/rural service centres in the county, including those within the urban spine; - has facilities best located in rural areas located within those rural areas, but linked to existing rural employment uses. Urban-based facilities should be located either within industrial areas or integrated with new residential and commercial development. Facilities of a national and regional scale that are most appropriately placed in urban areas should be concentrated in the top two tiers of the spatial development hierarchy.
5.20 The core strategy identifies within the main urban spine, three locations where a significant integrated waste management facility will be developed by 2026- the exact nature of the facility is not stated, but in all cases it will not be a ‘mass burn’ incinerator. Two of the three locations identified in the core strategy are Corby and Northampton; there should also be a location to serve the central part of the urban spine (bounded by Kettering, Wellingborough and Rushden).
5.21 For landfill the preferred strategy is that any increase in landfill capacity should be met by small extensions to operational sites rather than any new standalone facility; there will be no additions to capacity until at least 2016.
Locations for Minerals Development DPD
End Date of the DPD
5.22 In line with the end date of the Core Strategy, this LDD will have an end date of 2026.
Sand and Gravel
5.23 The sites for sand and gravel identified in the DPD will comprise the following (site reference numbers relate to those from the issues and options consultation): Allocations at Dodford (Site 11) and Earls Barton West (Site 17) that are in the existing Minerals Local Plan will be carried forward; around half of the Earls Barton West allocation is currently the subject of a planning application. The soft sand site at Collingtree (Site 4) in the Minerals Local Plan will also be carried forward. New sites within glacial and pre-glacial areas proposed to be included are: An extension to the existing site at Bozeat (Site 3/19). Heyford (Site 14)- a site listed as being for ‘further consideration’ in the adopted 2006 Minerals Local Plan that was also previously allocated in the 1997 Minerals Local Plan. West Haddon (Site 8)- a site listed as being for ‘further consideration’ in the adopted 2006 Minerals Local Plan but which had been supported for full allocation by the Local Plan Inquiry Inspector. Sites within the river valleys proposed to be included are:
WS010001/ENRMF/CONSAPPCRAL 8 Earls Barton West Extension (Sites 16)- a site listed as being for ‘further consideration’ in the adopted 2006 Minerals Local Plan that was also previously allocated in the 1997 Minerals Local Plan. The area south of the river adjacent to Cogenhoe that was shown in the issues and options documentation has not been included. There is an additional area to the west adjacent to the Great Billing Waste Water Treatment Works (Site 15 from the issues and options consultation) that is also being included. Earls Barton Duchy of Lancaster Site (Site 18)- this is a relatively small site adjacent to an area of previous working in the Nene Valley. Passenham (Site 21)- an area adjacent to previous working in the Great Ouse Valley, but which is further away from Passenham village than this previously worked area.
5.24 The above sites will contribute approximately 19.1 million tonnes of sand and gravel provision to the total provision of 19.36 million tonnes that needs to be found in the DPD to 2026. There will be some further provision coming forward from windfall contributions (for example from prior extraction before housing development commences or related to agricultural working) which should enable us to meet our sand and gravel apportionment.
5.25 Sand and gravel sites it is not proposed to pursue are: Stoke Albany West (Site 2)/Stoke Albany East (Site 1)- there would be a significant environmental impact from extraction of these soft sand sites, but by not identifying a specific provision for soft sand in the core strategy there is now no need to push forward these sites solely because they are the only ones that could help us meet a notional soft sand provision. Welford Lodge Farm (Site 5)- this is a site that although acceptable in principle is not a particularly good site in comparison to others at the present time, including the current cumulative impact from extraction from sites across the Leicestershire border. Land East of Woodford Grange (Site 7)- this site is in the unexploited part of the Nene Valley and extraction here is therefore not in accordance with the proposed spatial strategy. There should be no re-consideration of this site whilst this spatial strategy remains in place. Land East of Great Harrowden Parish (Site 9)- this site is in the Ise Valley and extraction here is therefore not in accordance with the proposed spatial strategy. There should be no re-consideration of this site whilst this spatial strategy remains in place. Watford Gap (Site 10) - this is a site that although acceptable in principle is not a particularly good site in comparison to others at the present time. Dodford Brookfield Farm (Site 12)- interest in developing this site has been withdrawn. East of Barton Seagrave (Site 6)- No evidence of resources being present here.
Crushed Rock
5.26 The allocated site in the Minerals Local Plan of Duddington Extension (Issues and options Site 23) now has planning permission. It is proposed to identify two new allocations, although to prevent oversupply one of these would be prevented from coming forward for extraction until much of the other allocation has been worked. The allocation for working first will be part of the site with an old permission at Wakerley (Site 24). The site to come forward later in the plan period will be at Ringstead (Site 29). This is considered to be a more appropriate site overall than the site at Woodford Grange (Site 28) which will not be taken forward in the DPD.
WS010001/ENRMF/CONSAPPCRAL 9
Building and Roofing Stone
5.27 Specific sites identified for building and roofing stone will be a site south of the existing Pury End site for building stone (Pury End (South)- Site 30) and a small site at Collyweston Village for roofing stone. As there is a need for further building stone beyond the provision from this new site, criteria for the identification of additional building stone sites is to be included in the DPD. However extensions to committed and allocated sites for sand and gravel and crushed rock in the DPD for the purposes of building and roofing stone extraction would not be permitted if only a small proportion of such stone would be extracted overall.
Locations for Waste Development DPD
End Date of the DPD
5.28 In line with the end date of the Core Strategy, this DPD will have an end date of 2026.
Waste Management
5.29 It is proposed to allocate a number of locations for waste management facilities that will go towards meeting the provision that needs to be found. This will not account for the full provision as outlined in paragraph 5.11 above, but there needs to be some flexibility to allow the private sector to bring forward schemes on the basis of new technologies and local requirements during the plan period. More significant waste management sites have been included where sites have either been promoted to us and we consider them to be acceptable, or where there is already a current planning permission for such a use. Sites serving urban extensions have not been identified as this needs to come forward through the wider planning of each urban extension.
5.30 The locations below are proposed for inclusion in the DPD for waste management uses. Sites with an asterisk could be an appropriate site for one of the three significant integrated waste management facilities proposed in the Core Strategy.
Within the Northamptonshire main urban spine: Northampton- Great Billing Wastewater Treatment Works* (Site 51) Boughton Quarry (Site 47)- an appropriate location for a high standard in-vessel composting facility. Grange Park - this site has a planning permission for waste management that will run out in December this year. However it is a suitable location for waste management use and such a use should therefore continue to be encouraged here.
Wellingborough/Rushden- Sidegate Lane- the existing area (and not the extended area identified as Site 45 in the issues and options material) is suitable for a waste management facility. Leyland Trading Estate, Wellingborough (Site 46)- this is an extension of the existing facility.
Corby- Gretton Brook Road (Site 34)- for use as a waste transfer station/materials recycling facility (preliminary treatment facilities). Corby Waste Water Treatment Works (Site 35)
WS010001/ENRMF/CONSAPPCRAL 10 Oakley Waste Management (Site 36)- an extension to the existing waste transfer/materials recycling facility. Corby Landfill Site (Site 37) and Weldon Compost Site (Site 38)*
Beyond the main urban spine: Kings Cliffe Regeneration Centre (Site 32)- to serve a catchment area comprising the rural hinterlands of Oundle, Corby and Stamford. Kilsby (Site 44)- to help meet the need for a facility to serve the Daventry sub- regional centre and its rural hinterland. Chelveston - this is a location that came forward as a consequence of the issues and options consultation and will help serve locations within the central part of the urban spine as well as the rural hinterlands of Rushden, Raunds and Thrapston.
5.31 The following locations put forward are not considered appropriate to include as preferred options for permanent facilities, especially because of landscape impact : Potato Store, Oundle (Site 39) Brixworth Landfill Site (Site 43) Land East of M1 Junction 16 (Site 50)
5.32 Although these sites are not unacceptable, they considered to be of too small a scale to be specifically allocated within the DPD: Pebble Hall, Theddingworth (Site 40) (this proposal has since received planning permission). Grain Store, Nobottle (Site 48) East Lodge, Nobottle (Site 49)
5.33 The Mitchell Road site at Corby (Site 33) has not been included as the developer has withdrawn interest and it now has permission for a non-waste management use.
Landfill
5.34 Our technical work is projecting that, despite an anticipated step-change in reuse, recycling and treatment, it is likely that an increase in non-hazardous landfill provision will be required at some stage up to 2026. This increase will be needed to primarily accommodate residual waste from treatment. Our best estimate is that this will be after 2016 but before 2021. The core strategy proposes that any increase in landfill capacity should be met by small extensions to operational sites rather than any new standalone facility. We are proposing that the potential extensions for non-hazardous landfill are not identified in the Locations for Waste Development DPD.
5.35 However following a representation made to the issues and options consultation, and because of the significance of the site, it is proposed that the landfill site at Kings Cliffe that deals with hazardous waste should have a reserve area added to it. However planning permission should not be forthcoming for this extension until at least 2016, and furthermore the extension should be for hazardous waste from a defined catchment area of less than a 50 mile radius.
5.36 Proposed extraction sites in the Locations for Minerals Development DPD will require inert landfill for the purposes of restoration. This will apply to all sites within the minerals LDD whether they are in glacial or river valley areas. To ensure there is an appropriate supply of inert waste for such restoration no sites for inert landfill will be identified within the Locations for Waste Development DPD. The locations of Weekley Hall Wood/Long Drow Pits (Site 41) and Cranford Landfill Site (Site 42) put forward at issues and options stage for inert landfill will not therefore be included in the DPD.
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6. Timetable for Implementation
6.1 Following approval by Cabinet, consultation on the preferred options for the three DPDs will commence in October for eight weeks (six of these eight weeks will be the statutory consultation as set out in regulations). There will then be an analysis of responses with particular weight given to matters of soundness, with the final draft DPDs submitted to the Secretary of State in spring 2008 following approval by Cabinet. Public examinations into all three documents will be held by the independent Planning Inspectorate to test their soundness later in 2008 or for the ‘locations’ DPDs in early 2009. Approximately six months after each examination the Inspectors Report will be received by the County Council and following this the respective DPDs will be adopted.
7. Alternative Options Considered
7.1 The alternative options were those set out in the issues and options consultation, and the preferred options documents and background material details why we are proposing the preferred options we wish to progress. How we have decided on the preferred options and the robustness of how we have carried this out will be a key test of soundness for discussion at the public examination.
8. Financial Implications
8.1 The costs of the consultation will be met from within the budget for development planning.
9. Risk Management
9.1 It is important that DPDs we submit to examination are found to be sound. As we move towards submission we will need to be particularly aware of issues GOEM may raise, and also address and prioritise staff resource issues, to ensure we progress in line with our timetables for plan preparation. In line with this we will keep the risk management assessment we have produced for the MWDF up to date.
10. List of Appendices
Appendix 1: The Preferred Options Document (available on request from Democratic Support Service) Appendix 2: The Tests of Soundness Appendix 3: Issues and Options Consultation: Schedule of Responses (available on request from Democratic Support Service) Appendix 4: Technical Appendix- Site Assessments and Waste Forecasts (available on request from Democratic Support Service) Appendix 5: Sustainability Appraisal (available on request from Democratic Support Service)
Author: Name: Mark Chant Team: Growth Management- Planning Policy Contact details: Tel: 01604 236831 Fax: 01604 236065 Email: [email protected] Background Papers: Adopted Waste Local Plan (March 2006)
WS010001/ENRMF/CONSAPPCRAL 12 Adopted Minerals Local Plan (May 2006) MWDF Issues and Options (February 2007) Is this report proposing a key decision is YES taken? If yes, is the decision in the Forward YES Plan? Is this report proposing an amendment to YES the budget and/or policy and framework? Have the financial implications been YES cleared by the strategic finance manager Name of SFM: Eric Symons (SFM)? Has the report been cleared by the YES relevant Service/Board Director? Name of Director: Danny Brennan Have any legal implications been cleared NA by Legal Services? Has an Equalities Impact Assessment NO been carried out in relation to this report? Environmental implications: All components of the Minerals and Waste Development Framework are subject to a Sustainability Appraisal (SA) including a Strategic Environmental Assessment. An SA has been carried out on the Preferred Options (see appendix 5). A Habitats Regulation Assessment has also been carried out. Human Rights implications: No direct implications. Constituency Interest: All constituencies.
WS010001/ENRMF/CONSAPPCRAL 13 Agenda Item No: 3
Democratic Support Service PO Box 136 County Hall Northampton NN1 1AT
CABINET
Minutes of the meeting held on 10th September 2007
Venue: Council Chamber, County Hall
(Meeting held in public)
PRESENT:
Councillor Jim Harker (Chairman and Leader) Councillor Rosemary Bromwich Councillor Andre Gonzalez De Savage Councillor Ursula Jones Councillor Joan Kirkbride Councillor Bill Parker Councillor Bob Seery Councillor Ben Smith
Also Present: (for all or part of the meeting) Councillor James Ashton Councillor Brian Binley Councillor George Blackwell Councillor Julie Brookfield Councillor Robin Brown Councillor Brandon Eldred Councillor Eileen Hales Councillor Stan Heggs Councillor Michael Hill Councillor Brian Hoare Councillor Jane Hollis Councillor David Hugheston-Roberts Councillor Belinda Humfrey Councillor Bernard Ingram Councillor Christopher Lamb Councillor Derek Lawson Councillor John McGhee Councillor Ken Melling Councillor Gina Ogden Councillor Alan Pote Councillor Michael Tye Councillor Jonathan West Councillor Terry Wire
Also in attendance: (for all or part of the meeting) Rory Borealis Director for Customers and Strategy Breda Carter Committee Manager (Customers and Strategy) Harry Darby Interim Director for Children and Young People Vivienne Farrell Committee Assistant (Customers and Strategy) (minutes) Chris Grethe Public Speaker Desiree Kelly Committee Manager (Customers and Strategy) Graham Mabbutt Liberal Democrat Political Assistant (Customers and Strategy) John Neilson Director for Business Support Michael O’Leary Labour Political Assistant (Customers and Strategy) Adam Simmonds Leadership Support Manager (Customers and Strategy) Jeff Woolley Public Speaker – Welford Action Group
There were 13 members of the public in attendance.
106/07 Apologies for non attendance
WS010001/ENRMF/CONSAPPCRAL 14 Councillor Liz Tavener
107/07 Notification of request from members of the public to address the meeting
Jeff Wooley (Welford Action Group): Items C1 and D2 Chris Grethe: Item C1
108/07 Minutes of the meeting held in public 13th August 2007
RESOLVED: Cabinet agreed the minutes of the meeting held in public on 13th August 2007.
109/07 Declarations of Interest by Councillors
Item Councillor Type Nature C1 Jones Personal Chairman of Boughton Parish Council D2 Kirkbride Personal Resident of village affected by mineral extraction document C1/D3 Pote Personal Kettering Borough Councillor D2 Blackwell Personal Resident of Earls Barton
110/07 Announcements
None
111/07 Medium Term Plan
SUBMITTED by: the Director for Customers and Strategy
Councillor Harker introduced the report (copies of which had been previously circulated) and made the following points:
Page 11 showed that there were to be open workshops in August, these had been moved to the end of September; Two years ago a list of commitments were made in their manifesto, it was now time to gain opinions on how well the Council had performed and to see if the goals and priorities set were still relevant; The MKSM growth programme was beginning to have a real effect across the County. It was hoped that Northamptonshire was a County that people came to live in for reasons other than reasonable house prices and good rail links; The views of the current 650,000 residents of Northamptonshire should not be forgotten; and Once a wide range of opinions had been gathered, the information would be reported back for consideration in October.
Councillors made the following points:
The report stated that a Sustainable Communities Strategy had been developed. The report should state that it is a draft strategy and all councillors should be able to participate in its development; and
WS010001/ENRMF/CONSAPPCRAL 15 The review mentioned should have the involvement and engagement of councillors included.
Councillor Harker responded by stating that:
During the development of the strategy there would be chances for everyone to contribute; and The open workshops at the end of September were a good opportunity for councillors to participate.
Councillors raised the following points:
Any engagement with the public was welcomed. However, some outlines were requested on how this was to operate as the website was a limited form of communication and there were only a small number of reports available in the libraries; and The report stated that there would be consultation with most of the county; it was asked what was meant by this.
Councillor Harker responded with the following points:
Directors, staff groups, residents’ panels, residents’ online forums, operating partners, town and parish councils, schools and local business would all be consulted with; and All town and parish councils would be involved therefore this would ensure a wide geographical spread across the whole county.
RESOLVED: Cabinet agreed to commission a review to ensure that the Council’s Medium Term Plan is fully cognisant of the broader county context.
112/07 Scrutiny Review of the Council’s Approach to Consultation
SUBMITTED by: the Enterprise Scrutiny Committee
Councillor Ashton introduced the report (copies of which had been previously circulated) and made the following points:
Apologies were given as the report should have been available in June. However, this was not possible due to delays in the work programme; There were significant areas where there was a lack of consultation following the end of Area Committees; Councillors were urged to attend the focus groups; The report highlighted the need for improved consultation with the voluntary sector; and Attention should be given to town and parish councils, including urban areas where these bodies did not exist.
Councillor Harker thanked the Enterprise Scrutiny Committee for all their work and agreed that there were several areas of inadequate consultation. He stated that work would be done to decide which Director would be best suited for the position of Consultation Champion.
WS010001/ENRMF/CONSAPPCRAL 16 The following points were raised by councillors:
The strategy had to be owned strongly by a Director and an annual report should be presented to Cabinet; and Thought should be given to the turnaround time for responses as town and parish councils may have difficulty in collating responses within three to four weeks.
Councillor Harker responded by agreeing that response turnaround times were an issue that would be taken into account.
RESOLVED: Cabinet agreed to:
1) Appoint one of the Council's Directors as Champion of public and councillor consultation and ensures that as the Champion, that Director examines the implementation of:
a) The Council's Public Participation Strategy; b) The document "Councillors' Rights" dated May 2003 referred to in Part 5 of the Council's Constitution; c) The Advice given in the report of the Overview Committee on its Scrutiny Project on "consultation" dated 29 March 2005, namely: That the Cabinet agree: A) That the Divisional Councillor is a key stakeholder for all local consultation exercises and that this role is incorporated into the Council’s Public Participation Strategy B) The underlying principles identified by the Overview Committee for consultation in paragraph 8.2 of that report being: To recognise the distinction between public participation, notification and consultation and label different participation approaches to public engagement accordingly. Consultation should be unbiased and undertaken with integrity with the rules and requirements of the consultation exercise enforced consistently. When communicating about the consultation details of the 'weighting' given to the exercise on the decision should be honest and not raise expectations inappropriately The rationale for selecting the sample size for consultation should be made clear. That feedback is made available to everyone involved in the consultation exercise. If officers are unsure about who or how to consult, they should liaise with the local councillor C) The concept of a ‘consultation cycle’ be applied by officers to future consultation exercises.
WS010001/ENRMF/CONSAPPCRAL 17 D) The set of standards identified in paragraph 8.4 of the Overview Committee’ report be considered for incorporation into the Council’s Public Participation Strategy; 2) Agree a requirement for the Champion of public and councillor consultation to report progress annually to a meeting of the Council; it is suggested that this report should be presented at the first Council meeting following the Annual Council meeting in each year; and 3) Ensure that all managers are aware that no decision can be validly made without first conducting appropriate consultation.
113/07 Transport Strategy for Growth
SUBMITTED by: the Head of Sustainable Transport
Councillor Smith introduced the report (copies of which had been previously circulated) and made the following points:
The draft strategy had been approved by Cabinet on the 8th of January, the largest change was that all papers had been brought together to form one document; The Administration did realise that as towns grow any opposition to cars would be of detriment to Northamptonshire; An increase in the use of public transport would only succeed if it was reliable, punctual, clean and provided comfort; and There were two major road schemes the A43 and the A509, however this did not mean that town schemes would be forgotten.
Public Speaker Chris Grethe stated that more stress should be placed on improving bus services, and that the difficulties for the elderly and people with disabilities should be considered.
Public Speaker Jeff Woolley (Welford Action Group) raised the following points:
The Welford Action group had submitted proposals on three separate occasions and that no response had been received; There are extreme problems with freight traffic within Welford due to road works on the M1/M6/A14 Junction; and Signage was not the answer as it was constantly being ignored and Welford was continually used as a through route for heavy goods vehicles.
Councillor Smith responded to the public speakers by stating that their issues would be looked into.
The following points were raised by Councillors:
Growth could have a negative effect on some rural areas; Weight restriction orders were opposed by Leicester, therefore the problems in Welford, however work was underway to address the issue; It was asked if Eagle Drive in Northampton Town Centre had been taken from the agenda;
WS010001/ENRMF/CONSAPPCRAL 18 The representative of Barton and Burton welcomed the Kettering Eastern Avenue as it would remove the problem of traffic going through villages; It was asked why there was no mention of opening a railway line between Kettering and Northampton; Page 126 shows that the prioritisation of Eagle Drive was awaiting this was due to Delapre’s concerns of having a road across a battle site; The projected growth figures were concerning as by 2031 it stated an increase of 107% in car transport; There were many additional houses to be developed around Banks Lane, this would cause problems as the sewers had collapsed once before and were on the verge of collapsing again. Therefore the building of the North West Bypass should be done; The pedestrianism of Northampton town centre would be of detriment to the town and local businesses; It was asked if the Towcester would be considered for a bus interchange and if the roundabouts were going to be improved before new houses were developed; The Kettering Eastern Bypass should be built, and if the full amount of funding could not be found then part of the bypass should be built near Stamford Road and Windmill Avenue; Stress was placed on the creation of the Isham Bypass to avoid the creation of a bottleneck from Wellingborough. It was asked that the residents of Redhill Grange be listened to and that weight limits be changed to divert traffic away from Eastfied Road; Bus fares had gone up by 10%, if there was to be improved public transport then costs needed to be taken into account; and Page 123 showed the downgrading of the A361 to a B road, however only half of the road was shown to be downgraded.
Councillor Smith responded with the following points:
Eagle Drive had been removed form the agenda and there was no further information at present; There were issues around developers not having the ufll amount of funding necessary; The Transport Strategy for Growth did not replace the Local Transport Plan; By 2031 it was hoped that bus use would have increased by 100%; Scrutiny of the document was welcomed; Housing developments would not go forward if the correct infrastructure was in place; To build only part of a bypass that could still be functional was an idea that would be taken forward; It was agreed that bus fares should be kept as low as possible, however some routes were heavily subsidised; and Freight issues in rural and urban areas and all other issues raised would be examined.
RESOLVED: Cabinet agreed to adopt the Transport Strategy for Growth as Council Policy.
WS010001/ENRMF/CONSAPPCRAL 19 114/07 Draft Joint Municipal Waste Management Strategy Review
SUBMITTED by: The Director for Community Leadership
Councillor Smith introduced the report (copies of which had been previously circulated) and made the following points:
Recycling had increased countywide and a draft strategy had been produced which was the first document on waste management solutions to come from the districts and boroughs; It was a statutory requirement to produce a document dealing with municipal solid waste, consultation would start in October and last eight weeks; The target was to have recycling at 70% by 2010 and to have further successful prosecution of excess packaging; and The enhancement of mechanical, biological treatment (MBT) was hoped to be developed in partnership with Milton Keynes Council.
RESOLVED: Cabinet approved the public consultation phase of the Draft Northamptonshire Joint Municipal Waste Management Strategy Review.
115/07 Minerals and Waste Development Framework: Core Strategy and Locations for Minerals and Waste Development Preferred Options
SUBMITTED by: the Director for Community Leadership
Councillor Smith introduced the report (copies of which had been previously circulated) and made the following points:
The strategy had taken over from the Minerals Local Plan and the Waste Local Plan; An options paper was consulted on which led to the preferred options paper that had identified sites for minerals and waste development; After the consultation there would be a submission plan that would start discussions with an independent inspector; Waste generated needed to be dealt with in purpose built centres; Consultation would commence in mid October and continue till December, parish and borough councils and libraries were to be given copies of the document, it would also be available on the council website; and Cabinet had recommended the removal of the West Haddon site however officers advised that it remain included. There were concerns with leaving the site included as sand and gravel had never before been excavated in a special landscaped area.
Public speaker Jeff Woolley, acting on behalf of the Welford Action Group, requested that the planning permission given for Pebble Hall be rescinded with immediate effect. He stated that the people of Welford had not been consulted, that large heavy goods vehicles were passing through the narrow roads and emitting a foul smell, and that Welford had already had a land site for the past twenty years.
WS010001/ENRMF/CONSAPPCRAL 20 Councillor Smith responded by stating that it was not possible to rescind planning permission that had been granted through due process. Pebble Hall had been included in the Issues and Options Paper and no objections had been received form the Welford Action Group.
Councillor Kirkbride questioned the inclusion of Hayford as a mineral extraction site. The Hayford site had been removed twice before as all objections could not be satisfied. There were many arguments against this site, including concerns around the reality of the drop from high risk status to low risk status, due to the proposed mitigation measures.
RESOLVED: Cabinet agreed that consultation on the Preferred Options can be initiated.
116/07 Kettering Household Waste Recycling Centre relocation
SUBMITTED by: the Director for Community Leadership
Councillor Smith introduced the report (copies of which had been previously circulated) and raised the following points:
The report was a good example of partnership working with the borough council; and The new site was double the size of the previous site and recycling was already over 60%.
The Councillor for the division where the centre would be located gave his full support for the scheme.
Councillor Parker stated that he was a little concerned over the proposed timescales, however he certainly supported the scheme.
RESOLVED: Cabinet
1. Approved the recommendation to enter into a Lease Agreement with Kettering Borough Council.
2. Approved the recommendation to tender for a “Design, Build, Finance and Operate” contract.
3. Approved the recommendation to use Compulsory Purchase Powers to secure access into the site.
117/07 1st Proposal of the Governing Bodies of Danetre and William Parker Schools, Daventry, to change the age range of the schools by the addition of a sixth form.
SUBMITTED by: the Strategic Manager (Schools)
Councillor Kirkbride introduced the report (copies of which had been previously circulated) and made the following points:
WS010001/ENRMF/CONSAPPCRAL 21 The report would have originally gone to the Schools Organisation Committee which no longer existed; There had been only one objection which was then rescinded, many of the parents were in full support of the addition of a sixth form; and The Danetre and William Parker Schools were the last schools in the county who did not have a sixth form.
The following points were raised by Councillors:
Further education funding was less than schools funding therefore there would be financial benefits from moving to a sixth form arrangement; Previously schools had been created with no sixth form, however years later great educational and social benefits could be seen from the inclusion of one; The issue was wider than just the inclusion of a sixth form, it also showed the importance of working in partnership; It was pleasing to see that mobiles would not be used.
Councillor Kirkbride stated that all schools were realising that by working alone they could not fully deliver the 14-19 agenda, therefore partnership working was an important issue.
RESOLVED: Cabinet determined the proposal, taking into account the guidance issues by the Secretary of State.
118/07 Monthly Finance Report
SUBMITTED by: the Director for Business Support
Councillor Parker introduced the report (copies of which had been previously circulated) and made the following points:
It was requested that the addition of the Dignity with Care Grant, to the 2007-11 MTCP, be added to the advice; and Overspend had been reduced from £7.1m to £4.1m and there were positive comments about debtors and creditors.
The following points were raised by Councillors:
There were still adverse variances being shown due to the Integrated Change Programme and it was feared that further slippage would be a problem; £550,000 had been drawn down from reserves during a recruitment freeze period; The reductions in overspend were welcomed however concerns were expressed on what effect in year savings were having on services. A more thorough examination would be done by the Enterprise Scrutiny Committee; and It was stated previously that the Integrated Change Programme was a high risk project and that was why a very high level of reserves had been built in. The government had cut revenue grants and there were likely to be further cuts.
Councillor Parker stated that the £550,000 drawn down from reserves was from debt restructuring and that a £1m saving next year was the preferred option.
WS010001/ENRMF/CONSAPPCRAL 22 Councillor Bromwich gave additional information of the extra piece of advice that was recommended by Councillor Parker. The Department of Health had allocated a capital grant of £805,000 to Northamptonshire to promote the safeguarding of elderly people. Providers must be able to show an audit trail and it was hoped that the funding would be spent by October this year.
RESOLVED: Cabinet
1. Noted the current financial position for 2007-08. 2. Agreed that the Dignity with Care Grant scheme be added to the 2007-11 MTCP
119/07 Appointment to NEA Properties Limited
SUBMITTED by: the Committee Manager
Councillor Harker introduced the report (copies of which had been previously circulated) and requested the appointment of Councillors Brookfield and Gonzalez de Savage as members of NEA Properties Limited.
RESOLVED: Cabinet agreed to appoint a Councillors Brookfield and Gonzalez de Savage as members of NEA Properties Limited.
120/07 Urgent Business: Future arrangements for the provision of the Connexions specification to young people aged 13-19
SUBMITTED by: the Director for Children and Young People
Councillor Kirkbride introduced the report (copies of which had been previously circulated) and made the following points:
Apologies were given on the lateness of the report. However, there was the need to demonstrate a direction of intention to the Government Office of the East Midlands (GOEM). GOEM were concerned that the expertise of Connexions was not being fully utilised; From April 2008 funding would no longer go directly to Connexions but to the local authority for distribution. The company could not be left as it was as they had received dramatic cuts in funding, if the Council owned 51% then there would be some tax benefits; and Further legal advice would be sought before proposals were implemented.
The following points were raised by Councillors:
The make up of the board was disappointing as no councillors were involved; and Further evidence on other options was requested as well as the involvement of all councillors before a final decision was made.
Councillor Kirkbride responded by stating that all councillor suggestions would be taken on board and gave the assurance that further legal advice would be sought.
RESOLVED: Cabinet agreed in principle
WS010001/ENRMF/CONSAPPCRAL 23 (a) the changes in the responsibility for the provision of the Connexions specification and Information, Advice, Guidance and Support (IAGS) across Children and Young People’s Services;
(b) that Connexions Northamptonshire Limited (“Connexions”) continue to provide the Connexions specification/Information, Advice and Guidance Services (IAGS) in the County;
(c) to recommend that the County Council works with the board of Connexions to alter its (Connexions) constitution to ensure that the transition to the new arrangements is effective and efficient;
(d) that agreement be given in principle to the establishment of Connexions as a company controlled by the county council;
(e) that the contract be agreed for a 3 year period subject to annual review of performance;
(f) That further legal advice be obtained to ensure that the Council enters into the most suitable arrangement.
There being no further business, the meeting concluded at 4.00pm
Vivienne Farrell Committee Assistant
WS010001/ENRMF/CONSAPPCRAL 24 Preferred Options –Locations for Waste Development DPD
Do you agree with the preferred approach for locational criteria for waste development?
Respondent Response Chelveston Renewable Energy Yes Ltd Daventry District Council Yes Deanshanger Parish Council Yes East Northamptonshire Council Concerns that the only sites considered are those that have been promoted by landowners and developers, as such the locational strategy does not sufficiently accord with the Core Strategy. There appears to be no consideration of where the sites may be required in terms of supply of waste and therefore most suitable locations closest to the source. This would be a more sustainable approach and eliminate much of the transportation and movements of waste. One of the key strategic development considerations is to encourage alternative transport methods, sites in East Northamptonshire do not meet this aim, as the only access will be by roads, principally using HGVs. Identified sites do not adhere to the emerging MWDF CS19. English Heritage Generally supports the approach subject to revisions to policy CS12. Environment Agency Yes: However the possibility of growth targets increasing should be considered. GOEM Consideration of future landfill sites in terms of their continued existence and potentially future role of permanent waste management facilities is excellent and links well with wider sustainability issues, particularly transport considerations are good in this instance. Natural England Fully supports the requirements for sustainable management of local waste and proximity principle proposed. Whilst the sustainable re-use of brownfield land is generally supported, would urge caution and highlight the need for full assessment of impacts on the natural environment, particularly in the use of brownfield sites and redundant farm buildings. The potential biodiversity value of brownfield sites as in addition the potential biodiversity value of redundant farm buildings can include protected species such as a range of British species of bat, many nesting birds including raptors and passerines, also roosting birds such as barn owl outside the nesting season. Locational criteria for waste management facilities: notes and supports the locational approach set out within the preferred approaches, and would only add that any policy criteria should include reference to the protection and enhancement of the natural environment. Northampton Borough Council Preferred approach is supported. Raunds Town Council No Response from residents of Separation distance in criteria W4 should be increased to 1000m to minimise risk and uncertainties associated with non inert preliminary Boughton waste treatment. Boughton Residents Action As Boughton Response Group Beryl Addington As Boughton Response Mr John Allin As Boughton Response Mr Neil Amos As Boughton Response
1 WS010001/ENRMF/CONSAPPCRAL 25 Respondent Response H.E Anderson As Boughton Response J Anderson As Boughton Response Mrs Maureen Anderson As Boughton Response R G Anderson As Boughton Response E.M Ashby As Boughton Response R V Ashby As Boughton Response Amanda Askew As Boughton Response Mr Jeremy Askew As Boughton Response Michele Austin As Boughton Response Mr Phil Austin As Boughton Response Mr Jeffrey Barringer As Boughton Response Judith Barringor As Boughton Response Ms Elizabeth Barron As Boughton Response Rachel E Barron As Boughton Response Mr Richard W Barron As Boughton Response Ruth Charlotte Barron As Boughton Response Dr J.H Bason As Boughton Response Mrs S Bason As Boughton Response Michelle Batchlor As Boughton Response Ms Denise Bates As Boughton Response Barry Bayes As Boughton Response Sally Bernham As Boughton Response A Bernhay As Boughton Response Mr William J Berry As Boughton Response Mr Kenneth Botwright As Boughton Response Valerie Botwright As Boughton Response Ms M.E Boullemier As Boughton Response Mr Tony Boullemier As Boughton Response Mrs Inez Dorothy Butler As Boughton Response Mr John Butler As Boughton Response Mr Kevin Callis As Boughton Response N Callis As Boughton Response Ms Brenda Callow As Boughton Response Haurice Callow As Boughton Response L Cardew No Andrea Carnel As Boughton Response R L Cawthra As Boughton Response
2 WS010001/ENRMF/CONSAPPCRAL 26 Respondent Response Naomi Cebula As Boughton Response E D Chapman As Boughton Response Dr H M Coghill As Boughton Response Mrs E Colin-York As Boughton Response Mrs M.W Collier As Boughton Response Mr S Collier As Boughton Response E. Compton As Boughton Response T.L Compton As Boughton Response David Cooper Appreciate that developing a strategy and determining locations is difficult in the context of the planned growth in the county, as there remains uncertainty around locations and the forms. Some proposals are included for new developments like the AD plant at Chelveston but there appears to be no consideration for further end of life vehicle disposal plants as that at Daventry, nor of more than one provision for WEEE. Composting is seen as a single line process, although possible combination with waste water treatment needs more detailed consideration. The division of solid and water waste treatment requires re-examination particularly in the changing technologies. These are tending to reduce the area requirement for water treatment, both using closed vessels more and generating gases for energy production. Mrs Hazel Cooper As Boughton Response J A Cooper As Boughton Response Mr Ronald Cooper As Boughton Response Ms Elaine Copperwaite As Boughton Response Mr Peter James Courier As Boughton Response Mr Paul Cox As Boughton Response Mrs B Critchell As Boughton Response Mr Harry Critchell As Boughton Response Mr Martin Cullen As Boughton Response Mrs Valerie Cullen As Boughton Response Mr L Curtis As Boughton Response Mr Richard Daniels As Boughton Response Sandra Daniels As Boughton Response Diana Darlington As Boughton Response Mr Malcolm Graham Darlington As Boughton Response Mrs B.M. Davenport As Boughton Response R N Davenport As Boughton Response I Davies As Boughton Response Ann Davison As Boughton Response Mr Russell Davison As Boughton Response T I Dayigs As Boughton Response M.B Deady As Boughton Response Arabelle Dean As Boughton Response
3 WS010001/ENRMF/CONSAPPCRAL 27 Respondent Response Mr Michael John Dean As Boughton Response Mr David Deane As Boughton Response Mrs Delia Deane As Boughton Response Ms Fiona Dickenson As Boughton Response Mr R P Dickenson As Boughton Response Mr Edward Digby As Boughton Response Melanie Digby As Boughton Response Mr Richard Digby As Boughton Response Mr William Digby As Boughton Response Miss L Dinonpoint As Boughton Response Mr Joe Docker As Boughton Response Mr Dan Dorgan As Boughton Response Pam Dorgan As Boughton Response Joanne Downie As Boughton Response Mr Jon Downie As Boughton Response Duffy As Boughton Response Charlotte Duffy As Boughton Response J B Duffy As Boughton Response Rebecca Duffy As Boughton Response Sophie Duffy As Boughton Response Jean Dunn As Boughton Response Mrs Lynda Dunne As Boughton Response Mr Noel Dunne As Boughton Response B Dunstone As Boughton Response Mrs Carol Dunstone As Boughton Response Sheldon Fenning As Boughton Response Simone Fenning As Boughton Response Ms Catherine Field As Boughton Response Mr Robert Field As Boughton Response A. Fleming As Boughton Response Ms Karen Fletcher As Boughton Response Graham Fogden As Boughton Response Giuseppe Forgione As Boughton Response Louise Forgione As Boughton Response Mr D Foster As Boughton Response J Foster As Boughton Response Mr A Fox As Boughton Response
4 WS010001/ENRMF/CONSAPPCRAL 28 Respondent Response Mrs I Fox As Boughton Response Mr Mark Gaterell As Boughton Response Stephanie Gaterell As Boughton Response Mrs H. Gaudin As Boughton Response Mr M Gavdin As Boughton Response Ms Jill Gist As Boughton Response Mr Robert Gist As Boughton Response Carolyn Glanney As Boughton Response Mr A.J.S Gledhill As Boughton Response Mr L.J Gledhill As Boughton Response A.P. Goddard As Boughton Response Gillian H Gogden As Boughton Response Mrs Helen Graft As Boughton Response Lesley Gray As Boughton Response Mr Mark Gray As Boughton Response Mr Kevin Greatorex As Boughton Response Ms Sue Greatorex As Boughton Response M Greener As Boughton Response R Greener As Boughton Response Mr Stuart Greenslade As Boughton Response Victoria Greenslade As Boughton Response Maureen Haddon As Boughton Response Mr Peter Haddon As Boughton Response Mrs C Handshaw As Boughton Response Mr Chris Handshaw As Boughton Response R R Hardwick As Boughton Response Mr J.T Harris As Boughton Response Mrs Joyce Harris As Boughton Response Mrs K.N Harris As Boughton Response Mr David James Harrop As Boughton Response Mrs Dorothy Harrop As Boughton Response Mr John Hewerson As Boughton Response Sara Hewertson As Boughton Response Mr Thomas Hewitt As Boughton Response Katie Higgs As Boughton Response Mrs Daphne Higham As Boughton Response Mrs Shirley Hillier As Boughton Response
5 WS010001/ENRMF/CONSAPPCRAL 29 Respondent Response Mr David Houriham As Boughton Response Mrs Sonja Hourihan As Boughton Response Anne Hughes As Boughton Response S.R Hughes As Boughton Response Mr I Humby As Boughton Response Mr Matthew Hunt As Boughton Response Oonagh Hunt As Boughton Response Mr Brian Hurren As Boughton Response Margaret Hurren As Boughton Response June Insall As Boughton Response R Insall As Boughton Response Mrs O.M James As Boughton Response Ms Ann Jones As Boughton Response Ms Catherine Jones As Boughton Response Ms Christine Jones As Boughton Response Mr Derek Jones As Boughton Response Ms Gillian Kingston As Boughton Response Mr Jonathan Kingston As Boughton Response Mr Neil Kitchener As Boughton Response Mr Richard Kitchener As Boughton Response Mrs Val Kitchener As Boughton Response Mrs D Knitt As Boughton Response Mr J.A Knitt As Boughton Response Ms Rita Lantsbery As Boughton Response Mr Andrew Laurie As Boughton Response Glenda Laurie As Boughton Response Alastair Lawrie As Boughton Response Catherine Lawrie As Boughton Response Mrs C Lea As Boughton Response Mr M J Lea As Boughton Response R Lee As Boughton Response S Lee As Boughton Response E Legrand As Boughton Response Ms Rachel Legrand As Boughton Response S A Lett As Boughton Response Mr Peter Lindsley As Boughton Response H C Lonell As Boughton Response
6 WS010001/ENRMF/CONSAPPCRAL 30 Respondent Response Ms Sylvia Ellen Lovell As Boughton Response Mrs J Mabbutt As Boughton Response Mr P Mabbutt As Boughton Response Oliver Mackaned As Boughton Response Charlotte Mackaness As Boughton Response Mrs Eleanor Maltby As Boughton Response Mr Terence Maltby As Boughton Response Joan Mason As Boughton Response Mr Philip Mason As Boughton Response Anwen McDonnell As Boughton Response Mr Daniel McDonnell As Boughton Response Rosemary McDonnell As Boughton Response W McDonnell As Boughton Response Joanne McGowan As Boughton Response Ms Mary McGowan As Boughton Response Mr Thomas McGowan As Boughton Response Mr Thomas McGowan As Boughton Response Mrs Imelda McQuillan As Boughton Response Dr W.J McQuillan As Boughton Response Mr Derek Millard As Boughton Response Ms Anna Moore As Boughton Response Mr Frank Moore As Boughton Response Janet T Morris As Boughton Response Mr Neville Morris As Boughton Response Ms Ann Murphy As Boughton Response Mrs S Mynolt As Boughton Response Mr R.E Mynott As Boughton Response Mr Rish Napier As Boughton Response Sue Napier As Boughton Response Mr George Neophiton As Boughton Response Linda Neophiton As Boughton Response Ms Margaret Palmer As Boughton Response Mr Roy Palmer As Boughton Response Mrs Dorothy Parkinson As Boughton Response Mrs N Pearson As Boughton Response Mr John Penny As Boughton Response Mr Adrian Perez As Boughton Response
7 WS010001/ENRMF/CONSAPPCRAL 31 Respondent Response Mr Giles Perez As Boughton Response Mr Harry Perez As Boughton Response Suzanna Perez As Boughton Response Dilys Pettitt As Boughton Response Mr Guy Phillips Wallin As Boughton Response Mr Anthony Philpott As Boughton Response Mr Arthur Piggins As Boughton Response Mrs P Rapkin As Boughton Response Mr R Rapkin As Boughton Response Mr Alan Rhodes As Boughton Response H M E Rhodes As Boughton Response Mrs M Rhodes As Boughton Response Mr Maxwell John Rhodes As Boughton Response Ms Sharon Ringsell As Boughton Response C.S Robinson As Boughton Response Mr P C Robinson As Boughton Response Mrs P.B Robinson As Boughton Response R.H Robinson As Boughton Response Ms Eileen Rouse As Boughton Response Mr John B Rouse As Boughton Response Annewen Rowe As Boughton Response Mr John Rowe As Boughton Response J B Rushton As Boughton Response Mrs M J Rushton As Boughton Response Gillian Scotney As Boughton Response Mr Paul Scotney As Boughton Response Harriet Scott As Boughton Response Mrs Marlon Scott As Boughton Response Mr Peter Scott As Boughton Response Tess Scott As Boughton Response Angelia Seelig As Boughton Response Carlene Seelig As Boughton Response I.M Seelig As Boughton Response Mr M.P Seelig As Boughton Response P R Seelig As Boughton Response Ms Sarah Seelig As Boughton Response Mr Stephen Seelig As Boughton Response
8 WS010001/ENRMF/CONSAPPCRAL 32 Respondent Response Mrs Theresa Seeling As Boughton Response R L Sellig As Boughton Response Mr Roger Skinner As Boughton Response J M Smith As Boughton Response Mr Neil Smith As Boughton Response Ms Stephanie Smith As Boughton Response A Soteriou As Boughton Response Kay Soteriou As Boughton Response Janice Squires As Boughton Response Mr John Squires As Boughton Response Mr Andrew Stables As Boughton Response Mr Graham Stacey As Boughton Response Mrs J Stacey As Boughton Response Jo Stevens As Boughton Response Mr Andrew Stirling As Boughton Response Patricia Stirling As Boughton Response Mrs K.G Sturgess As Boughton Response Shirley Suler As Boughton Response Mr David Suter As Boughton Response Mr Robert Swannell As Boughton Response Mrs June Taray As Boughton Response Mr John Taylor As Boughton Response Mr Mark Taylor As Boughton Response Samantha Taylor As Boughton Response Mr Simon Tebbatt As Boughton Response Ms Christina Tebbott As Boughton Response Mrs G M Tebbutt As Boughton Response Mr S.J Tebbutt As Boughton Response L.A Thompson As Boughton Response Mrs Linda Thompson As Boughton Response Mr Peter Thompson As Boughton Response Mr Walter Thompson As Boughton Response G J Tomlins As Boughton Response S & G J Tomlins As Boughton Response Ms Caroline Trott As Boughton Response Rev Stephen Trott As Boughton Response D L Turner As Boughton Response
9 WS010001/ENRMF/CONSAPPCRAL 33 Respondent Response Mrs Inez Turner As Boughton Response Katrina Varnsverry As Boughton Response Michael John Varnsverry As Boughton Response Mrs A Vewes As Boughton Response Audrey Walker As Boughton Response Mrs J Walton As Boughton Response Mr John Walton As Boughton Response Carla Watson As Boughton Response Derrick Watson As Boughton Response Jackie Watson As Boughton Response Christine Weatherley As Boughton Response Mr Richard Weatherley As Boughton Response Mr David Whalley As Boughton Response Margaret Wheeler As Boughton Response Mrs Carol Wilkinson As Boughton Response Mr Mark Wilkinson As Boughton Response Dr Royston William As Boughton Response E.K Williams As Boughton Response Mrs H S Williams As Boughton Response Mrs Jane Williams As Boughton Response Mr Russell Wilson As Boughton Response Mrs Susan Wilson As Boughton Response T S Woolton As Boughton Response Mrs S Wootton As Boughton Response J Wright As Boughton Response Terri Wright As Boughton Response Ms Jill Yelding As Boughton Response Mr Richard Yelding As Boughton Response Mr E Yuzbasioglu As Boughton Response Mrs G Yuzbasioglu As Boughton Response
10 WS010001/ENRMF/CONSAPPCRAL 34 Do you agree with the intent of the emerging Locations for Waste Development policies?
Respondent Response Anglian Water Services Ltd W6/7: Development of a sustainable waste management network is the correct approach in that it will allow the most flexibility in terms of the technologies chosen, and allow for the development of new forms of treatment or improvements to existing ones to be managed without alteration to the plan. W5: Approach to ensure that local waste management facilities can demonstrate a relationship between either a Sustainable Urban Extension or location for new development, there is logic to this; however policy does not make clear how this is to be achieved. W6-10: Would support the criteria based approach for determining applications for different types of waste management facilities. W4: Would support the approach for locational criteria. W1-3: The approach is now to balance need with capacity in the same way as for minerals development. It is important that all of the sites are assessed and selected using a transparent and balanced method in order that the MWDF is declared sound. Barton Plant Objects to W3. No sites are allocated for the disposal of inert waste, although the note refers to the fact that existing commitments will be listed in the submission DPD. It is only by reading the cabinet report and the comments in table 5 that it becomes obvious that inert sites where not taken forward to ensure there is enough inert waste to restore minerals workings. There is a lack of clarity in the policy documents and the decision has not been justified. Bovis Homes Ltd and Does not support emerging policies. Wellingborough East W1: The general policies are not objected to but revisions are required to reflect the importance of the requirements and sensitivities of the Landowners residential and employment development associated with the plans for the Growth Area. Campaign to Protect Rural Would like to see a much stronger emphasis on eventual use of sites and their rehabilitation. Disposal sites are profitable and as with England quarrying money must be earmarked for the necessary amenity improvements. Chelveston Renewable Supports emerging policies. Energy Ltd Supports policies W1, 4, 5, 7. Daventry District Council Supports emerging policies. East Midlands Regional W1: The plan period is proposed up to 2026. The draft RSS also plans to 2026, however the waste section of the draft RSS plans to 2020 in Assembly line with current available data. It is unclear why the plan in terms of waste provision seeks to go beyond the data available within the draft RSS. W2: In terms of individual technologies that may be taken forward to provide for the waste management needs of the authority, the Regional Assembly would have no comment to make. It would be sensible however to maintain a flexible approach in order to accommodate emerging technologies as detailed. W5: In terms of provision for local waste management provision, whilst in certain circumstances it may be desirable to develop at the local level, policy within the RSS states that for the southern sub-area of the region the majority of development for waste should be concentrated in a centralised pattern around urban centres. W7, 8, 9 and 10 level of locational guidance: It is important that provision has been made to accommodate any emerging technologies, however in terms of location guidance and specific location sites, government policy expresses that vague strategies or broad criteria based policies on where to site facilities are not good enough within the plan led system. In terms of the process to identify sites, unless this is robust enough in terms of the locational aspect then the plan risks being seen as unsound. W4: In terms of identifying sites there is a need to be prescriptive. Whilst it is desirable and unnecessary as stated not to re-iterate National or
11 WS010001/ENRMF/CONSAPPCRAL 35 Respondent Response Regional policy within the Waste DPD it is important that the requirements that are set out therein are taken on board. W1-3: When identifying the preferred sites it is important to be spatial in approach and not be overly directed by existing infrastructure. Local development frameworks should contain within its documents an integrated set of polices which are based on clear understanding of the economic, social and environmental need of the area and any constraints on meeting those needs. Taking this into account existing sites or topping up of provision may not satisfactorily take this into account. It should be remembered that existing sites were sited and development under a completely different planning and regulatory regime which may not be suitable under today’s requirements. English Heritage Supports policies 2-10. Concerns over W1. W1: Broadly support the policy; however in view of issues raised regarding specific sites it is necessary to register an objection to the policy at this stage. Ensign Group Ltd Supports W1 to 3. Agree that you should balance the need for sites with the capacity of an area to accommodate them. Agree that a fully market led approach will not provide an appropriate balance between waste related development and environmental capacity. A market led approach is not considered to be consistent with the Sustainability Appraisal objectives as it does not allow for a holistic objective site selection process. In these circumstances endorse the preferred approach which requires the site selection for the Locations for Waste Development should be based on balancing need with capacity. Environment Agency In terms of sewage and waste water treatment, locations must be in a sustainable location and ensure no adverse impact on the environment. GP Planning Objects to Policies 4 and 7. W4: This policy sets out the general locational criteria for waste management facilities and introduces a criterion that waste development should be located at least 250m from sensitive receptors, unless otherwise specified by the facility siting criteria. No justification for this distance and only development where distance is justified is large scale green waste open window composting. It would be better to take restriction out of policy W4 and include it in relevant section of W7. The approach recommended by the council to safeguard waste uses by discouraging development within 250m of a waste site is fully supported. This fails soundness tests 6 and 7. W7: Sets out the criteria for waste treatment locations. In the section on open windrow composting, reference is made to a suburban situation as being appropriate. Commercial scale composting needs to be confined to the rural area: suburban implies housing for which the only suitable composting operations are those carried out by householders in their own gardens. Reference should be made in this section to the need for a buffer zone between large scale open windrow composting sites and sensitive receptors. W7 fails soundness test 6. Hargrave Conservation The proposal that national locational guidance is followed is fully supported. Recognising local distinctiveness is vital and particularly so when Society considering the landscape characteristics, appearance and structure. W1-3: A fully market lead approach would be crude and unthinking approach that would cut directly across the policies set out in the MWDF document and the various planning guidance's. It would exaggerate fundamental flaws and inefficiencies and destroy confidence in the safeguards of the planning system. The MWDF is correct to discard such an approach. National Farmers Union Supports policy W7. Supports composting but anaerobic digestion on dairy farms may not be able to maintain a low profile structure. Should be re-worded to take account of anaerobic digesters that are available for dairy farms. Natural England Would welcome the addition of criteria relating to the protection and enhancement of the natural environment as part of polices W4, W5 and W6, and is suggested that the following bullet points are added: W4, "located where negative impacts on sensitive sites or features that are of importance to the protection and enhancement of the natural environment will not occur" W5 and 6, "ensure a net gain for the natural
12 WS010001/ENRMF/CONSAPPCRAL 36 Respondent Response environment, in terms of landscape, biodiversity and connectivity". W7: Because this policy makes reference to the need to comply with previous policies, subject to the additional bullet points being added to these policies, Natural England does not have any further concerns with regards to policy W7. W8: Supports the policy proposal, but advises that the following amendments should be made to the first bullet point within the policy, to incorporate the sensitive natural environment features within the list of sensitive receptors and also include the need to mitigate for any impacts on such features: "Locations close to sensitive receptors such as housing, commercial, recreational areas or areas of landscape or biodiversity importance should generally be avoided where possible unless risk assessment demonstrates that any impacts would be acceptable and can be fully mitigated". W10: Generally supported, but it is advised that further requirements with regard to waste water development need to be added to the policy wording. Natural England proposes the addition of the following text to the end of the policy, "Waste water infrastructure and sewage treatment to accommodate new housing should be provided where current capacity is inadequate to absorb the new development without degradation of water quality and environmental harm, and should be in place prior to the development of the new housing it will serve. Any such development relating to waste water infrastructure and treatment should only proceed in locations where the development will not cause harm to sites or features of importance to landscape character and/or nature conservation”. Northampton Borough Supports policies W4-10. Council PGR Recycling Ltd W5: Believe there is a typing error in the document as after the second criterion the word “and” has been added, yet the two criterions either side appear to be mutually exclusive. After each of the criteria the word “or” should be added, making it clear that provided that the site fits one of the criteria, it will be acceptable under this policy. Policy as worded appears to exclude the possibility of extending waste management sites. The policy should provide explicit support for extensions to existing sites, provided that the extension complies with the environmental criteria of the plan. Criterion 2 is restrictive as it refers to redundant industrial or farm buildings. There should be no prerequisite the premises are redundant, the future use of industrial or farm buildings should depend upon the commercial prospects and interest of the owner/tenant. If it is more profitable to use buildings for waste management it should be up to their discretion. There is always the proviso that the use should not cause adverse environmental impacts, which would be demonstrated in a planning application. The policy fails soundness tests 6 and 9, it is too restrictive, and more reliance could be placed on the requirement to meet the environmental policies in the plan. Provided that a waste development does not cause significant adverse environmental impacts, there should be no harm resulting from allowing local waste facilities to be developed on a wide range of different types of site. By widening the scope of the criteria for selecting sites for local facilities it will provide more flexibility at a time of rapidly changing circumstances. Raunds Town Council Does not support emerging policies. Thornby Parish Meeting Supports emerging policies. Response from residents of Does not agree with intent of the emerging policies. Boughton Supports policies 1, 2, 3, 6, 8, 9, 10. Objects to policies 4, 5, 7. W4- Proposed separation distance not supported. W5- Equal priority should not be given to location on former or existing minerals or waste facilities. Priority should be given to existing or designated industrial land, as this accord with PPS10. W7- It is assumed commercial and industrial areas, means areas allocated for this use but it is not clear from the wording. Questionable whether in vessel composting is suitable for urban area. Priority location for such facilities should be industrial areas and brownfield sites.
13 WS010001/ENRMF/CONSAPPCRAL 37 Respondent Response Boughton Residents Action As Boughton response Group Beryl Addington As Boughton response Mr John Allin As Boughton response Mr Neil Amos As Boughton response H.E Anderson As Boughton response J Anderson As Boughton response Mrs Maureen Anderson As Boughton response R G Anderson As Boughton response E.M Ashby As Boughton response R V Ashby As Boughton response Amanda Askew As Boughton response Mr Jeremy Askew As Boughton response Michele Austin As Boughton response Mr Phil Austin As Boughton response Mr Jeffrey Barringer As Boughton response Judith Barringor As Boughton response Ms Elizabeth Barron As Boughton response Rachel E Barron As Boughton response Mr Richard W Barron As Boughton response Ruth Charlotte Barron As Boughton response Dr J.H Bason As Boughton response Mrs S Bason As Boughton response Michelle Batchlor As Boughton response Ms Denise Bates As Boughton response Barry Bayes As Boughton response Sally Bernham As Boughton response A Bernhay As Boughton response Mr William J Berry As Boughton response Mr Kenneth Botwright As Boughton response Valerie Botwright As Boughton response Ms M.E Boullemier As Boughton response Mr Tony Boullemier As Boughton response Mrs Inez Dorothy Butler As Boughton response Mr John Butler As Boughton response Mr Kevin Callis As Boughton response N Callis As Boughton response
14 WS010001/ENRMF/CONSAPPCRAL 38 Respondent Response Ms Brenda Callow As Boughton response Haurice Callow As Boughton response L Cardew As Boughton response Andrea Carnel As Boughton response R L Cawthra As Boughton response Naomi Cebula As Boughton response E D Chapman As Boughton response Dr H M Coghill As Boughton response Mrs E Colin-York As Boughton response Mrs M.W Collier As Boughton response Mr S Collier As Boughton response E. Compton As Boughton response T.L Compton As Boughton response Mrs Hazel Cooper As Boughton response J A Cooper As Boughton response Mr Ronald Cooper As Boughton response Ms Elaine Copperwaite As Boughton response Mr Peter James Courier As Boughton response Mr Paul Cox As Boughton response Mrs B Critchell As Boughton response Mr Harry Critchell As Boughton response Mr Martin Cullen As Boughton response Mrs Valerie Cullen As Boughton response Mr L Curtis As Boughton response Mr Richard Daniels As Boughton response Sandra Daniels As Boughton response Diana Darlington As Boughton response Mr Malcolm Graham As Boughton response Darlington Mrs B.M. Davenport As Boughton response R N Davenport As Boughton response I Davies As Boughton response Ann Davison As Boughton response Mr Russell Davison As Boughton response T I Dayigs As Boughton response M.B Deady As Boughton response Arabelle Dean As Boughton response
15 WS010001/ENRMF/CONSAPPCRAL 39 Respondent Response Mr Michael John Dean As Boughton response Mr David Deane As Boughton response Mrs Delia Deane As Boughton response Ms Fiona Dickenson As Boughton response Mr R P Dickenson As Boughton response Mr Edward Digby As Boughton response Melanie Digby As Boughton response Mr Richard Digby As Boughton response Mr William Digby As Boughton response Miss L Dinonpoint As Boughton response Mr Joe Docker As Boughton response Mr Dan Dorgan As Boughton response Pam Dorgan As Boughton response Joanne Downie As Boughton response Mr Jon Downie As Boughton response Duffy As Boughton response Charlotte Duffy As Boughton response J B Duffy As Boughton response Rebecca Duffy As Boughton response Sophie Duffy As Boughton response Jean Dunn As Boughton response Mrs Lynda Dunne As Boughton response Mr Noel Dunne As Boughton response B Dunstone As Boughton response Mrs Carol Dunstone As Boughton response Sheldon Fenning As Boughton response Simone Fenning As Boughton response Ms Catherine Field As Boughton response Mr Robert Field As Boughton response A. Fleming As Boughton response Ms Karen Fletcher As Boughton response Graham Fogden As Boughton response Giuseppe Forgione As Boughton response Louise Forgione As Boughton response Mr D Foster As Boughton response J Foster As Boughton response Mr A Fox As Boughton response
16 WS010001/ENRMF/CONSAPPCRAL 40 Respondent Response Mrs I Fox As Boughton response Mr Mark Gaterell As Boughton response Stephanie Gaterell As Boughton response Mrs H. Gaudin As Boughton response Mr M Gavdin As Boughton response Ms Jill Gist As Boughton response Mr Robert Gist As Boughton response Carolyn Glanney As Boughton response Mr A.J.S Gledhill As Boughton response Mr L.J Gledhill As Boughton response A.P. Goddard As Boughton response Gillian H Gogden As Boughton response Mrs Helen Graft As Boughton response Lesley Gray As Boughton response Mr Mark Gray As Boughton response Mr Kevin Greatorex As Boughton response Ms Sue Greatorex As Boughton response M Greener As Boughton response R Greener As Boughton response Mr Stuart Greenslade As Boughton response Victoria Greenslade As Boughton response Maureen Haddon As Boughton response Mr Peter Haddon As Boughton response Mrs C Handshaw As Boughton response Mr Chris Handshaw As Boughton response R R Hardwick As Boughton response Mr J.T Harris As Boughton response Mrs Joyce Harris As Boughton response Mrs K.N Harris As Boughton response Mr David James Harrop As Boughton response Mrs Dorothy Harrop As Boughton response Mr John Hewerson As Boughton response Sara Hewertson As Boughton response Mr Thomas Hewitt As Boughton response Katie Higgs As Boughton response Mrs Daphne Higham As Boughton response Mrs Shirley Hillier As Boughton response
17 WS010001/ENRMF/CONSAPPCRAL 41 Respondent Response Mr David Houriham As Boughton response Mrs Sonja Hourihan As Boughton response Anne Hughes As Boughton response S.R Hughes As Boughton response Mr I Humby As Boughton response Mr Matthew Hunt As Boughton response Oonagh Hunt As Boughton response Mr Brian Hurren As Boughton response Margaret Hurren As Boughton response June Insall As Boughton response R Insall As Boughton response Mrs O.M James As Boughton response Ms Ann Jones As Boughton response Ms Catherine Jones As Boughton response Ms Christine Jones As Boughton response Mr Derek Jones As Boughton response Ms Gillian Kingston As Boughton response Mr Jonathan Kingston As Boughton response Mr Neil Kitchener As Boughton response Mr Richard Kitchener As Boughton response Mrs Val Kitchener As Boughton response Mrs D Knitt As Boughton response Mr J.A Knitt As Boughton response Ms Rita Lantsbery As Boughton response Mr Andrew Laurie As Boughton response Glenda Laurie As Boughton response Alastair Lawrie As Boughton response Catherine Lawrie As Boughton response Mrs C Lea As Boughton response Mr M J Lea As Boughton response R Lee As Boughton response S Lee As Boughton response E Legrand As Boughton response Ms Rachel Legrand As Boughton response S A Lett As Boughton response Mr Peter Lindsley As Boughton response H C Lonell As Boughton response
18 WS010001/ENRMF/CONSAPPCRAL 42 Respondent Response Ms Sylvia Ellen Lovell As Boughton response Mrs J Mabbutt As Boughton response Mr P Mabbutt As Boughton response Oliver Mackaned As Boughton response Charlotte Mackaness As Boughton response Mrs Eleanor Maltby As Boughton response Mr Terence Maltby As Boughton response Joan Mason As Boughton response Mr Philip Mason As Boughton response Anwen McDonnell As Boughton response Mr Daniel McDonnell As Boughton response Rosemary McDonnell As Boughton response W McDonnell As Boughton response Joanne McGowan As Boughton response Ms Mary McGowan As Boughton response Mr Thomas McGowan As Boughton response Mr Thomas McGowan As Boughton response Mrs Imelda McQuillan As Boughton response Dr W.J McQuillan As Boughton response Mr Derek Millard As Boughton response Ms Anna Moore As Boughton response Mr Frank Moore As Boughton response Janet T Morris As Boughton response Mr Neville Morris As Boughton response Ms Ann Murphy As Boughton response Mrs S Mynolt As Boughton response Mr R.E Mynott As Boughton response Mr Rish Napier As Boughton response Sue Napier As Boughton response Mr George Neophiton As Boughton response Linda Neophiton As Boughton response Ms Margaret Palmer As Boughton response Mr Roy Palmer As Boughton response Mrs Dorothy Parkinson As Boughton response Mrs N Pearson As Boughton response Mr John Penny As Boughton response Mr Adrian Perez As Boughton response
19 WS010001/ENRMF/CONSAPPCRAL 43 Respondent Response Mr Giles Perez As Boughton response Mr Harry Perez As Boughton response Suzanna Perez As Boughton response Dilys Pettitt As Boughton response Mr Guy Phillips Wallin As Boughton response Mr Anthony Philpott As Boughton response Mr Arthur Piggins As Boughton response Mrs P Rapkin As Boughton response Mr R Rapkin As Boughton response Mr Alan Rhodes As Boughton response H M E Rhodes As Boughton response Mrs M Rhodes As Boughton response Mr Maxwell John Rhodes As Boughton response Ms Sharon Ringsell As Boughton response C.S Robinson As Boughton response Mr P C Robinson As Boughton response Mrs P.B Robinson As Boughton response R.H Robinson As Boughton response Ms Eileen Rouse As Boughton response Mr John B Rouse As Boughton response Annewen Rowe As Boughton response Mr John Rowe As Boughton response J B Rushton As Boughton response Mrs M J Rushton As Boughton response Gillian Scotney As Boughton response Mr Paul Scotney As Boughton response Harriet Scott As Boughton response Mrs Marlon Scott As Boughton response Mr Peter Scott As Boughton response Tess Scott As Boughton response Angelia Seelig As Boughton response Carlene Seelig As Boughton response I.M Seelig As Boughton response Mr M.P Seelig As Boughton response P R Seelig As Boughton response Ms Sarah Seelig As Boughton response Mr Stephen Seelig As Boughton response
20 WS010001/ENRMF/CONSAPPCRAL 44 Respondent Response Mrs Theresa Seeling As Boughton response R L Sellig As Boughton response Mr Roger Skinner As Boughton response J M Smith As Boughton response Mr Neil Smith As Boughton response Ms Stephanie Smith As Boughton response A Soteriou As Boughton response Kay Soteriou As Boughton response Janice Squires As Boughton response Mr John Squires As Boughton response Mr Andrew Stables As Boughton response Mr Graham Stacey As Boughton response Mrs J Stacey As Boughton response Jo Stevens As Boughton response Mr Andrew Stirling As Boughton response Patricia Stirling As Boughton response Mrs K.G Sturgess As Boughton response Shirley Suler As Boughton response Mr David Suter As Boughton response Mr Robert Swannell As Boughton response Mrs June Taray As Boughton response Mr John Taylor As Boughton response Mr Mark Taylor As Boughton response Samantha Taylor As Boughton response Mr Simon Tebbatt As Boughton response Ms Christina Tebbott As Boughton response Mrs G M Tebbutt As Boughton response Mr S.J Tebbutt As Boughton response L.A Thompson As Boughton response Mrs Linda Thompson As Boughton response Mr Peter Thompson As Boughton response Mr Walter Thompson As Boughton response G J Tomlins As Boughton response S & G J Tomlins As Boughton response Ms Caroline Trott As Boughton response Rev Stephen Trott As Boughton response D L Turner As Boughton response
21 WS010001/ENRMF/CONSAPPCRAL 45 Respondent Response Mrs Inez Turner As Boughton response Katrina Varnsverry As Boughton response Michael John Varnsverry As Boughton response Mrs A Vewes As Boughton response Audrey Walker As Boughton response Mrs J Walton As Boughton response Mr John Walton As Boughton response Carla Watson As Boughton response Derrick Watson As Boughton response Jackie Watson As Boughton response Christine Weatherley As Boughton response Mr Richard Weatherley As Boughton response Mr David Whalley As Boughton response Margaret Wheeler As Boughton response Mrs Carol Wilkinson As Boughton response Mr Mark Wilkinson As Boughton response Dr Royston William As Boughton response E.K Williams As Boughton response Mrs H S Williams As Boughton response Mrs Jane Williams As Boughton response Mr Russell Wilson As Boughton response Mrs Susan Wilson As Boughton response T S Woolton As Boughton response Mrs S Wootton As Boughton response J Wright As Boughton response Terri Wright As Boughton response Ms Jill Yelding As Boughton response Mr Richard Yelding As Boughton response Mr E Yuzbasioglu As Boughton response Mrs G Yuzbasioglu As Boughton response
22 WS010001/ENRMF/CONSAPPCRAL 46 Do you agree with the identification of preferred sites for waste development?
Respondent Response Anglian Water Services Ltd Supports WA11 and WA12. WA11: Suggestion that site will take MSW and C&I waste but due to location of site away from sensitive receptors and close to A45 treatment of other wastes may be appropriate. Site is in close proximity to Northampton and therefore complies with PPS10. Site should be identified as a significant integrated waste management facility, as site is close to existing waste water treatment works and that new facility would be within the context of an already developed area rather than isolated in the open countryside. Augean Supports WA16. The area of land on the map in the document is incorrect; the western part of the existing site does not have planning permission for landfill. The western area should be included in the extension area of the allocation. To be consistent with a recently made application the proposed uses should be hazardous waste disposal and treatment. The purpose of the site is the management of hazardous waste, although the site assessment mentions MSW and C&I. Hazardous waste is a specialised part of these waste streams hence the statement is misleading. The site is important locally and regionally and we consider that site is an essential facility on a sub regional basis. The current permission finishes in 2011 hence planning for extension of the site would need to be granted before this date. The proposal to restrict the site to a sub- regional market does not appropriately take into account the specialised nature of the facility, the current national network of similar facilities and runs counter to the policies in PPS10. The restriction of the catchment will result in waste having to travel greater distances to the other sites or even to travel past Kings Cliffe to get to other sites. Clearly this will not be reducing the transport of waste from its origin. The catchment proposed for the site is likely to affect the economic viability of the site, as other sites have no catchment constraints. The effect of the catchment constraint is that the other sites will be able to compete in the constrained catchment and forces the cost of disposal down. This will have the effect in planning terms of lower landfill costs will result in less recycling and recovery and increased travel of waste. Borough Council of WA3: Further clarification as to the type of inert waste to be recycled at the plant should be included in the plan. Wellingborough Boughton Parish Council Objects to WA2. No industrial operators exist in the area, waste processing site is out of character with the rural and residential area. Impacts on landscape character. The need for bunding is incompatible. Concerns over impacts from noise, odours, traffic, vermin and litter. Concerns that disturbance and impacts on health cannot be calculated. Concerns that facility needs very professional management and monitoring on an ongoing basis. Concerns that transport infrastructure cannot support the traffic movements at present and would not be able to support the increase. Concerns that site will attract vermin but drive away other wildlife. Tests of soundness, test 1: it is assumed that NCC have prepared the document in accordance with MWDS, however with regard to timing of the IVC, we assume that a decision on this will not be taken until the preferred options document has been agreed. Test 2: Failed, Liaison Committees was not informed of the issue and options and the parish council was not informed. Only 5 responses received, figures miscalculated and statutory responses were given equal weight as an individual. Test 3: Failed, site was due for reinstatement for agricultural use in 2015; this only leaves 5 years for the facility to achieve a return. Test 4: Failed, site is totally incompatible with the assumed strategically planned residential developments in an obvious residential/rural area. Test 5: Failed. Test 6: Failed, site is objected to by DDC as is contrary to their key principles on Health and Safety. DDC raised issues of close proximity to registered parks and gardens at issues and options but this was not highlighted in the preferred options. The development due at Buckton Fields is not shown on the map or mentioned in the document. This should be considered when deciding on the Preferred Waste sites. Test 7: The industrial nature of the IVC would more appropriate less close to residential properties. Concerns that site is developer rather than strategically led. Site should be designated on industrial or brown field site 1000m away from
23 WS010001/ENRMF/CONSAPPCRAL 47 Respondent Response residential properties. Test 8: Failed, concerns over management and monitoring of existing facility, let alone the IVC facility of which there is little experience in the UK. Concerns over close proximity of site to residential areas, existing and proposed. Test 9: Failed, choice of Boughton as a preferred site is not considered flexible due to the facilities on it having a detrimental impact on the surrounding environment, its totally incompatible with surrounding area, it is restricted by lack of sufficient road infrastructure, it is prone to environmental nuisance and it only has a life span until 2015 when it is due to return to agricultural use. Bovis Homes Ltd and Does not support site selection. Wellingborough East Objects to WA6 and WA13. Landowners Do not necessarily object to further development of the Sidegate Lane Facility or Leyland Trading Estate Facility, but much depends on the nature and extent of the proposed development and the mitigation measure that will be put in place. Moreover, the development needs to take account of the approved development of Stanton Cross and its planned further extension, to the East of Wellingborough. Brixworth Parish Council Objects to WA2. Concerns over the ability of the infrastructure to support the increase in HGV movements. Concerns that with the 500 homes at Buckton Fields East and the other 1000 homes that may be built close by roads will become impassable at peak times. Chelveston Renewable Energy Supports site selection. Ltd Supports site WA8. Support the allocation of the former Chelveston airfield as a proposed waste management facility. Chelveston-Cum-Caldecott Objects to WA8. Parish Council Site is contrary to National and European Policy, as site is in a rural area and away from the primary sources of waste on the urban spine. Contrary to PPS10. Selection of site is contrary to the proximity principle and CS12. Site is designated open countryside and was designated as greenfield in the Three Towns Plan; site would be contrary to PPS10 and CS12. Emerging draft East Midlands Regional Plan states a centralised pattern of large facilities around urban areas is better. Site is contrary to policy 37 -regional policies for waste management, the East Midlands Freight Strategy and the East Midlands Regional Waste Strategy, as site is not within urban spine, does not have good transport links and is on a greenfield site. Site is contrary to local LDF policy and CS11, CS12 and W7 in the emerging MWDF policy. Concerns over access to the site and that major improvements would be required to the infrastructure and not the minor improvements that are stated in the document. There are no rail or water freight transfer stations near the site. Infrastructure cannot support increase in HGV movements contrary to PPS10, CS19 and W4. Concerns that site assessment is for a much smaller facility than proposed by the developer. Concerns that the 4 miles of recently opened rights of way is not acknowledged in the assessment. Concerns that site is referred to as a former airbase, but buildings were removed from the site. Site is Grade 2 agricultural land. Concerns that site is on plateau, site is on watershed between River Ouse and River Nene with potential for contamination, site is 800m from SSSI contrary to PPS10. Concerns over impacts on heritage sites which is contrary to PSS10. Site is located close to sensitive receptors, and the impacts on these from a 24hr operation. Concern that site is located in close proximity to existing waste sites and cumulative effect of these sites. Site fails soundness test 6 and 7. Church and Chapel Brampton Concerns over WA2. Parish Council Concerns over the increase in traffic through the village, controls should be placed on the operators. Collyweston Parish Council WA16: No objection to site providing it has no adverse effect on Fineshade and Collyweston Great Woods ecology, that the site continues to operate at its current high standard and the NCC continue to carefully monitor the site. Corby Borough Council WA4: No objection in principle, subject to improvements to the transport network and measures to safeguard the Brookfield Plantation County Wildlife site. These protection measures should be robust and protected throughout the set up as well as the operation of the facility.
24 WS010001/ENRMF/CONSAPPCRAL 48 Respondent Response WA5: No objection given that the site is already allocated within the Waste Local Plan and on the basis that any planning application should be subject to mitigation measure to limit impacts. WA7: In principle support the site, subject to implementation of measures to mitigate potential environmental, landscape and infrastructure impacts. It should be clarified that the proposal should be linked to the proposed Corby Landfill Site. WA12: No objection in principle subject to reservation concerning environmental and potential cumulative impacts, in particular the impact on the existing transport network. WA14: In principle support the site as site is already allocated in Waste Local Plan. Detailed assessment of development impacts and mitigation techniques will be required at the application stage. Daventry District Council Supports WA1. Objects to WA2. WA1: Site not objected to in principle; however concerns that impacts of noise and odours due to increase in vehicle movements is properly mitigated. WA2: Site is contrary to key principle 12, due to impacts from noise and odours on residential amenity. Concerns over increase in vehicle movements on the highway network. Concerns over the proximity of the site to the registered park and gardens and conservation area of Boughton. Dean and Shelton Parish Objects to WA8 Council Concerns that proposed site is on a greenfield site and is not located close to any principle sources of waste. Concerns that the transport infrastructure cannot support increase in HGV movements as they are minor, unclassified roads. Concerns over effect on landscape character, loss of recreation areas and impacts on ecology. East Midlands Regional In terms of the potential sites, the locations should be in line with draft RSS in that the concentration should be around urban centres and Assembly areas of growth. East Northamptonshire Council Supports WA15 and WA16. Objects to WA8. WA15: There are fewer nearby residential sites. There is no tonnage in the document, however if composting and anaerobic digestion are excluded there would be no objection to the site subject to details. Considered site is not strategically located as most waste will be generated at Corby. Cross boundary issues need to be considered. Concerns over cumulative effects of the developments. Council would require a Green Infrastructure Mitigation Package. WA16: Site should be monitored to above the relevant specifications. Concerns over a major aquifer in the area. Concerns that site is located next to Fineshade Wood, a visitor attraction. A buffer around the site would be required. Site is a national facility and developer contributions to local facilities would be required. If extension was to proceed, the approach of only accepting waste from a 50 mile radius would be supported. WA8: Concerns that despite CS12 the site is on greenfield land. Identification of the site does not conform to the Three Towns Plan; site was considered for development under the plan but was rejected due to unsustainable location, visual impacts on open countryside and the wider environmental effects on the quality of life of local residents. Site is not sound as the Three Towns Plan would have not been considered. The site conflicts with surrounding landuse and does not link into the wider community. The site is located 4.8miles from large scale developments. Site would have significant impact on the transport network in the area as only way of reaching the site is by road. Air base houses are residential properties and therefore sensitive receptors. Concerns over odours, access to the site. No tonnage information or likely capacity is stated, impacts on landscape character. Cumulative impacts from other waste sites needs to be considered. Overall
25 WS010001/ENRMF/CONSAPPCRAL 49 Respondent Response evaluation is not correct as site is near sensitive receptors; the land is surrounded by agricultural and other uses. Site does not have potential to serve growth areas on a sub regional basis. Ecton Parish Council/ CLEAN Objects to WA11 Concerns that site is out of character with the area, whilst site is located next to the water sewage treatment works it is currently open fields. Not clear exactly what the proposed use of the site is in terms of waste type or treatment type. Concerns that document states the site is away from residential areas, there is housing in Ecton Brook and also in Crow Lane. Concerns that the travellers’ site adjacent to the site has not been considered and has been over ridden. Concerns that litter will impact on the area. Concerns over access to the site from Lower Ecton Road. English Heritage Objects to WA13. Supports WA1-12 and 14-16. Supports sites subject to the proposed archaeological and landscape mitigation. WA2: Support with reservations. Site is opposite Grade II park and gardens. Impacts could be appropriately mitigated by landscaping. WA13: Site is adjacent to a group of Grade II listed buildings. Although the area has experienced a long period of disturbance, the technical appendix does not provide an adequate assessment of the impact of these new proposals on the setting of the listed buildings. Ensign Group Ltd Objects to WA2. Concerns that assessment for site makes no reference to Buckton Fields a site allocated by Daventry to accommodate new housing, Buckton Fields is a long standing allocation, the location of the waste site will prejudice the achievement of the Governments intentions for the planned extension of the Northamptonshire Principle Urban Area. The Waste site contradicts national and regional spatial planning objectives. Proposals to locate a sub-regional waste management facility adjacent to Buckton Fields is unsound. Waste site is located in close proximity to existing residential areas. Site is contrary to PPS10 and the East Midlands Regional Waste Strategy. Site is contrary to CS12 of the Core Strategy. Concerns that site is proposed to be sub-regional receiving waste for 30-50 miles away, it would be prudent to locate such sites on a primary transportation network within Northamptonshire’s main urban spine. Concerns that a section of the Buckton Fields development would be within the proposed 250m buffer zones around waste sites, assessment has not considered the likely implications for proposed developments in the vicinity as set out in PPS10. If site continues to receive support there is potential for a land use conflict. Site is not well related to the strategic development spine of Northamptonshire described in the MKSMSRS, it is distant from transportation routes and is adjacent existing and proposed residential areas. Concerns over impacts noise, emissions and vibrations. Site is within a Rural Access Area in policy EN11 of the Daventry Local Plan. Environment Agency WA3: Site will form part of an existing mineral extraction operation sited within identified flood zone and with history of flooding. Whilst restoration by inert landfill might be technically feasible, delivery issues may prevail. However site might offer potential for floodplain restoration to overcome the restoration complications caused principally by the desire to use landfilling. WA4: This site is identified flood zone. WA6: It is noted that the site abuts historic flood area and appears to be raised above the area liable to flooding. WA7: Site is correctly stated that site is away from residential areas, however if proposed development of Weldon Park goes ahead it will be directly downwind of the site. Site overlays a major aquifer. WA9: Proposed site is a closed landfill, it is next to M1 and A45 so has good access but it is located close to residential areas. WA10: Site is close to hotel and holiday centre so potential for impacts. Site is potential at a high risk of flooding and should be avoided for MSW. WA11: Site is close to sensitive receptors, minerals workings should not prejudice sewage treatment works operation and possible
26 WS010001/ENRMF/CONSAPPCRAL 50 Respondent Response expansion. Part of site may serve as active floodplain and hence be avoided. WA12: Noted that site is adjacent to indicative floodplain and bordered by main river, while risks may be low EA may wish to see positive mitigation measures to protect the main river from contamination. WA13: Waste activities are occurring on site, occasional issues regarding odour. Proposals for residential development west of site. WA14: Over a major aquifer. Due to position on a major aquifer, the EA will need to consider objections to WA12 and WA16 should they proceed and mitigation proposals cannot meet our objectives. If opportunities exist to relocate these proposals away from aquifers, they should be pursued. To secure a sound delivery of the plan, advised that it should propose a fall back position in the event that the site does not move forward. Part of WA11 and WA1 are in floodplain so there is a likelihood of flooding. Objection is precautionary in relation to concerns regarding possible contamination of the watercourse and susceptibility to flood risk. Composting sites present risks due to the mobility of the waste and its likelihood of blocking structures along watercourses. H.B Paynter Ltd Supports WA8 Site will provide business and employment opportunities. By product could be a source of fertilizer. Many former airfields have been used for industrial development. Site has little biodiversity interest and woodlands added on periphery would provide a screen. Area is sparsely populated and away from settlements. Transport links from A6 is suitable. Site is not in an area of natural beauty and is featureless. Technology will control emissions. Hargrave Conservation Society Objects to WA8 Contrary to objective 3, 8, 9, 10, 12. Site does not fit with the waste spatial strategy. Contrary to the Core Strategy outlined in the document. Site is contrary to government guidance in PPS10, Regional Spatial Strategy, PPS22, and PPS7. Area is not earmarked for development, it is not located on the urban spine, and there is no trunk road available to access the site. The growth areas in the county are not located close to the site; the rural characteristics of the area are being retained. Site does not fit with the proximity principle. Concerns over increase in traffic movements, and that urban waste will be transported to rural areas for disposal. Local population is far too small to support the CHP scheme. Concerns that site is only in the plan as it has been put forward by a developer. Concerns that if site was allowed to proceed, over time the site will expand to accept further waste types. Concerns over loss unique grassland and impacts on landscape character. Site has been designated as Greenfield and is only used for seasonal farming. Site is located in the rural hinterland and waste produced in the area should be disposed of in the urban spine. There are no other suitable transport methods other than roads. Concerns over the cumulative effects of other waste sites located near by. Site at Wymington has enough capacity to handle all the waste arisings from the rural hinterland of that part of Northamptonshire. Concerns over odours due to topography of the area and noise. Concerns that there is no other industrial or commercial activity within 3 miles of the site. Concerns over impacts on historical buildings located in nearby villages. Concerns that site will provide minimal employment and could easily be provided any way by an expansion to Wymington. Concerns the distribution of liquid fertiliser from an AD process is constrained by market pricing issues and there is no guarantee that is would be used locally. Site contains a large amount of ecology (foxes, hares, deer, owls, buzzards). Hargrave Parish Council Objects to WA8 Site is contrary to objective 2, as infrastructure cannot support the increase in traffic movements, the land is agricultural land and has been designated as greenfield in the Three Towns Plan. Contrary to objective 5, as site is nether urban focussed or in close proximity to source of waste. Site is away from the growth areas shown on the development spine. Contrary to objective 10 as site is on a plateau and will impact on the landscape character. Site has no modern day development. Contrary to objective 12, as bridleways and footpaths cross the site, impacts on the recreation areas. Concern over impacts on health and safety in the area. Concerns over close proximity of site to sensitive
27 WS010001/ENRMF/CONSAPPCRAL 51 Respondent Response receptors. There are no alternative methods of transport available on the site whereas the main urban towns are served by rail links. The site should be allowed to remain for agricultural production as site was used for agriculture apart from its military use. Site is contrary to the government guidance in PPS22, PPG2, PPS10 and PPS7. Highways Agency WA6: More information is required before the use of site for waste disposal can be assessed, its potential impact should be ascertained alongside those sites allocated for minerals workings in the area and may also feed into the junction of the A45/A509. WA9: Sited next to junction 15 of M1, already suffers congestion, development of site could lead to further stress being placed on the trunk roads and therefore a greater understanding of the potential impact on the junction and links combined with potential minerals extraction at MA4 should be developed through a full transport evaluation. WA10 and 11: Located close to A45 and would reduce distances waste would travel but site is located close to minerals sites and with existing capacity issues the potential impacts on the traffic network needs to be considered. WA13: Due to size of site and variety of materials potential exists for high number of trips. Not directly located on A45 but could place stress on the network. Kilsby Parish Council Objects to WA1 Local residents had been under the impression that the site would be closed in 2009 and site re-instated to agricultural. Concerns over increase in traffic movements on A361 and A5. Concerns over access to site, if site has to continue operating an access slip must be constructed with increased signage. Concerns over odours. Concerns that at present plastic are lost from HGVs arriving at the site and little effort is made to clean up the surrounding areas. If the east side of the site is to be used, an access should be created on that side. Kings Cliffe Parish Council Objects to WA16 Concerns over extension of the site as original planning consent was for 10 yrs. Concerns that high pressure gas and oil pipes pass under the proposed extension area. Lambert Smith Hampton for Proposes new site located at Pytchley adjacent to Junction 9 of the A14. Proposal for a waste management facility for municipal solid NCC Waste Management waste. 17ha area that is currently farmland. Adjacent to the junction of A509 and A14. Close to the urban area of Kettering. Low flood risk. Northampton Borough Council WA2: Concerns that adequate consideration is given to impact of additional traffic movement on the surrounding network. Consideration of this site should include impact on residents and businesses of Northampton Borough as well as surrounding rural areas. WA10: Concerns that adequate consideration is given to impacts on residents and businesses. Consideration should be given to environmental interest including water resources. Potential for cumulative impacts is highlighted in the document and is supported; reference should be made to cumulative impacts as a result of A45. WA11: Concerns that impacts should be minimised and mitigated. Safeguards must be put in place to address impacts on general amenity, water resources, landscape and biodiversity. Highlighting of cumulative impacts is supported. Consideration must be given to increase in traffic movements on surrounding network. Peter Bennie Ltd Support WA2 Reference is made to in-vessel composting and commercial and industrial waste transfer. In view of the location of the site on the outskirts of Northampton and therefore close to the largest source of waste in the county, the council should have considered the suitability of the site for a much wider range of waste management. Site is suitable for a recycling centre to handle municipal kerbside and trade dry-recyclables inputs, to be sorted into single stream materials for transfer off site to processors of new items. This would include the handling of glass, paper, card, wood and green waste and plastics. Other operations would be appropriate at this include, small scale wood to heat plant, Household Waste recycling centre for local residents, trade waste recycling centres for local traders, aggregate recycling, education centre, bio-diesel plant, ancillary HGV garage and workshop and WEEE sorting and bulking up.
28 WS010001/ENRMF/CONSAPPCRAL 52 Respondent Response Peterborough City Council WA16: Noted and supported. Cambridgeshire and Peterborough minerals and waste preferred sites do not identify landfill of hazardous waste because of the proximity of the area to Kings Cliffe. The site currently has permission to 2013 and are pleased to note that if an extension to site is permitted it is likely to be available for the whole plan period. Preserve Objects to WA8. Concerns that site is against policy guidelines. Three Towns Plan states the site is greenfield, contrary to PPS22, PPG2, PPG10 and PPG7, waste plants should be located in or very close to urban areas. East Midlands Regional Plan states sites should be in proximity to existing or new development with good transport links. Site does not comply with locational criteria in preferred options and cannot be described as brownfield or industrial land. Access to the site would be via an unclassified road or through villages. Output figure is not given so assessment cannot be completed. Concerns that transport assessment was only for one hour on an inappropriate section of road, should have been completed on B645 as this would be the designated access. Existing transport infrastructure cannot support the increase in HGV movements, contrary to PPS10. Site is grassland used for grazing and has been cleared of any buildings for many years. Concerns that risk assessment is flawed as volumes have been excluded. Concerns that site is located on a plateau and is visible over long distances. Concerns over impacts on rights of ways and bridleways, document does not mention that 4 miles of bridleway have recently opened on the site. Landscape description is not accurate, as the site is Grade 2 agricultural land. Concerns over impacts on SSSI as there is potential for contamination of water courses. Concern over the impacts of odours as they can travel some distance. Concerns over impacts of noise especially at night. Lighting will be visible for many miles. Impacts on heritage sites, contrary to PPS10 annex E. The site is located close to many sensitive receptors and as operations will be 24 hours impacts cannot be negligible. Concerns over cumulative effect of waste sites already located in close proximity, represents an excessive concentration. Site is not located in the urban spine and Rushden is a smaller town not scheduled for expansion. Site will not reduce transporting of waste and does not comply with proximity principle. Refute suggestion mitigation techniques can combat an unknown development. Concerns that as site is in the plan it signals approval. Site fails soundness tests 6 and 7 as site in not consistent with core strategy and is not based upon a robust and credible base. Raunds Town Council Does not support site selection. Objects to WA8. Site is contrary to W5 as the site is isolated from areas of development and is served by a transport infrastructure that cannot support the increase. Site is located on greenfield land that was recognised in the Three Towns Plan. Contrary to W4 as site is not served by A class roads and the minor roads are not suitable for HGV traffic. Contrary to W7 as site is isolated from other facilities so is nether urban focussed nor in close proximity to the source of waste. Site is not within the urban spine. Contrary to BAP 95, PPG17 and PPS10 as due to the location of site it will impact on landscape character. Concerns over noise, vibration and odours, concerns that details of traffic have not been outlined in document, concerns that transport infrastructure cannot support traffic. Concerns over access to the site and the impacts on the sensitive receptors. Contrary to PPG 4 as the Northamptonshire Local Transport Plan 2006/7 -2010/11 states that the A14 and A45 are already congested. Contrary to Highways Act 1980, PPG17, Countryside Rights of Way Act 2000, Policy IC1 Northamptonshire Structure Plan and Policy GEN2 of ENC Local Plan as proposed site will impact on footpaths and bridleways on the site. Contrary to PPS22 as site is developer led and other matters associated with the site have not been demonstrated within the documents. RSPB No objection in principle to WA11 but more clarity is needed about the type and size of the facility. Rutland County Council WA14: Concerns about traffic impacts on the roads in Rutland and would request council is consulted should an application be received. WA15: Support in principle subject to details of the specific proposed use and waste types to be handled. South Northamptonshire District Concerns over WA9.
29 WS010001/ENRMF/CONSAPPCRAL 53 Respondent Response Council Concerns that site could be used for other waste related development and its close proximity to residential areas. Stanwick Parish Council Objects to WA8. Concerns that site is against policy W5, site is not located close to areas of waste generation and has a poor transport infrastructure. Concerns that site is a greenfield site, policy states sites should be on brownfield or industrial. Site is against policy W4 as site does not have good access roads. Transport infrastructure cannot support increase in traffic movements. Site has neither road nor rail access. Wellingborough would be more appropriately placed to meet this criteria. Contrary to W7. Impacts on landscape character. Impacts from odours and noise. Site does not contribute to a sustainable waste management network. Site does not minimise transportation of waste from source. Storefield Plant (Rushton) Ltd Supports WA4. Since the initial submission land has been identified as suitable for use in connection with the whole of this area north of Gretton Brook Road. Constraints would be considered in detail during preparation of an EIA. The need to provide compensation habitat or other ecological mitigation measure will be considered. The Boughton Estate Weekley Hall Wood: Estate is in discussions with potential operators of a commercial scale gasification plant to produce energy and heat from the thermal treatment of wood waste. Proposal is to treat 32,000 tonnes per annum of wood and wood waste, to produce 4MW of energy for uploading to the National Grid. Heat would be transferred using hot water pipes to commercial development on the estate. Estate would provide 10% of wood from its own sustainable forestry, 20% from other local wood producers. The Wildlife Trust WA16: Site is located close to a variety of designated sites of different categories, some of which contain ancient woodlands. Operations should be sensitive and mindful of the ecological constraining factors. Of importance would be delivering of a suite of appropriate biodiversity enhancement measure in mitigation that achieve both county BAP objectives and GI provision. Thornby Parish Meeting Supports site selection. Weldon Plant Land at Princewood Road, Corby. The Rockingham Castle Estate has identified an old ironstone gullet that is suitable for restoration using inert waste. Site would be developed by Weldon Plant for use in connection with its construction business. 215,000m3 of fill, generated from site clearance and development work around Corby. Access would be from Princewood Road, which is part of an industrial estate with adequate transport infrastructure. Site is bordered by industrial units to south and open country side and woodland to the north. Constraints would be considered in a planning application but need to provide compensation habitat and other ecological mitigation measure will be considered. Response from residents of Does not support site selection. Boughton Supports sites WA1, 3, 11 and 13. Objects to site WA2. WA2: The location of site on north western extremity of Northampton takes it away from transport infrastructure that serves the spine. This prejudices the sub regional status of WA2 and conflicts with W4 and CS11. Transport infrastructure does not have capacity to cope with HGV movements. Site assessment does not consider uncertainties associated with limited data and evidence concerning emissions, current technology could not mitigate the adverse effects. Due to this uncertainty separation distance should be 1000m. Site conflicts with CS19 as site will attract traffic movements over a wide catchment area. Site not in accordance with PPS10 to give priority to re-use of previously developed land or to avoid potential land use conflict. Assessment does not consider Daventry District Local Plan policy HS2 which proposed housing within the 250m separation distance. Quarry is currently being restored; this should be completed without being complicated by new activity. Other sites within plan are better suited due to distance of separation, existing use and proximity to transport network.
30 WS010001/ENRMF/CONSAPPCRAL 54 Respondent Response Boughton Residents Action As Boughton response Group Concerns over the production of odours at the site and the bio-filtration systems are the only barrier between the odours and the wider environment, bio-filters cannot be considered reliable. Concerns over lack of treatment for emission such as water/acid/aclkali. Closest residential dwelling to the site is 150m away which is within the 250m guidelines set out by the Secretary of State. Expansion of Northampton has been to the south of the town and a full infrastructure is already in place in the area where Boughton Quarry is served by poor transport links. WA11: Site has good access to major transport links and possible rail links. Site is not located close to residential areas. The sewage plant is long established and will not be relocated, there will always be odours generated from the treatment plant. IF IVC was located at this site wet scrubbing units could be sued to ensure full removal of odours. Water from site could be treated at the sewage plant. May be possible to provide essential nutrients for the composting process via treated sludge generated from the adjacent sewage treatment works. Site would also be a good location for gasification plant operating in conjunction with the composting facility. WA13: Site would serve Wellingborough and has good access links. Site has been identified as requiring lechate treatment. In this event, technology would be available for treating waste waters from the in-vessle composting process. Site is not located close to residential areas. WA3: Site is remote from residential areas and has good access links. Potential new sites: Areas south of Junction 1 of the A14, west and east of the A5199. Area to west has been subject to quarrying, and landfill site to east is now full but has had considerable time to settle and maybe stable enough for lightweight buildings needed for IVC. These two sites would not affect Northampton or surrounding villages with emissions, and the site has good road links. Another potential site is north of Welford that has been used for quarrying and is remote from residential areas. The Harlestone extraction/landfill site is not recommend for IVC as is located to close to the village and is remote from the spine. The site is a large site that has been operational for many years. It in not clear why this site has been excluded from the preferred sites when Boughton has been included which is much closer to housing and likely to have more traffic problems. Mr Terry Abbott Objects to WA8. Concerns that site is not located close to urban centres that it is intended to serve so vehicles will have to travel long distances to the site. Mrs P Adams Objects to WA8. Concerns over increase in HGV movement on country roads. Concerns that site is a greenfield site. Beryl Addington As Boughton response Diana Allan Objects to WA8. Site is not close to any of the major urban areas that it is intended to serve. Industrial processes should not be located on rural greenfield sites. Concerns over the increase in HGV movements on local narrow country roads. Concerns over effect on landscape character due to construction of industrial buildings. Concerns over the cumulative effect of the waste sites already located near by. K. M Allan Objects to WA8. Concerns over the increase in HGV movements on narrow country roads. Mr Patrick Allan Objects to WA8. Concerns over the impacts on ecology and historical buildings. Odours and vermin. Located in close proximity to existing waste sites. Increasing lorries through villages. Cllr Tim Allebone Supports WA13. Pleased to see the potential for CHP exists as the technology has to be embraced with today’s environment. Ms Teresa Allen Objects to WA8
31 WS010001/ENRMF/CONSAPPCRAL 55 Respondent Response Concerns that site is proposed for a greenfield site. Impacts on ecology (buzzards, owls, cranes, kingfishers, great crested newts). Located close to existing waste sites. Odours and noise. Concerns that development could lead to further developments. Mr John Allin As Boughton response Mr Neil Amos As Boughton response H.E Anderson As Boughton response J Anderson As Boughton response Mrs Maureen Anderson As Boughton response R G Anderson As Boughton response Mr David Andrews Objects to WA8. Concerns over impacts on landscape character due to construction of industrial buildings. Ms Karen Andrews Objects to WA8. Concerns over increase in traffic movements on local narrow country roads which cannot support the increase. E.M Ashby As Boughton response Mrs J Ashby Objects to WA8. Concern over impacts on local transport infrastructure, odours. R V Ashby As Boughton response W.J Ashby Objects to WA8. Concerns over increase in HGV movements and ability of infrastructure to support increase. Impacts on landscape character. Odours and noise. B Ashdown Objects to WA8. Concerns over effect on landscape character on a previously unspoilt area. Should be trying to reduce amount of waste produced first. R Ashdown Objects to WA8. Environmental concerns are being tackled from the wrong end, should reduce the amount of waste produced in the first place. Amanda Askew As Boughton response Mr Jeremy Askew As Boughton response Ms Jane Aspin Objects to WA8. Concerns that site is located in close proximity to existing waste sites, cumulative impact needs to be considered. Michele Austin As Boughton response Mr Phil Austin As Boughton response Ms Gillian Aylott Objects to WA8. Concerns that waste will have to travel long distances to the site, roads network cannot support increase in HGV movements. Concerns over loss of recreation areas (footpaths). Residents had been assured that land would return to agriculture when MOD no longer used the site. Concerns over effects on landscape character as would not be possible to mitigate. Effects on ecology. Noise. Mr David Bagley Objects to WA8. Concerns over increase in traffic on country roads. There is already a site at twinwoods. Site is not located close to towns it will serve. Effects on landscape character. Noise. Mrs M.K Bagley Objects to WA8.
32 WS010001/ENRMF/CONSAPPCRAL 56 Respondent Response Concerns that site is not located close to towns it would serve. Concerns over noise and odours. Site is a greenfield site not suitable for industrial processes. Concerns over increase in HGV movements. Site is located close to existing waste sites. G Baker Objects to WA8. Concerns over the increase in HGV movements, transport infrastructure cannot support this increase. Mrs Gill Baker Objects to WA8. Concerns over the increase in HGV movements on rural roads that cannot support the increase. Mr Jeffrey Barringer As Boughton response Judith Barringor As Boughton response Ms Elizabeth Barron As Boughton response Rachel E Barron As Boughton response Mr Richard W Barron As Boughton response Ruth Charlotte Barron As Boughton response Dr J.H Bason As Boughton response Mrs S Bason As Boughton response Michelle Batchlor As Boughton response Ms Denise Bates As Boughton response Barry Bayes As Boughton response Mrs V Bernacki Objects to WA8. Concerns over development of a greenfield site. Increase in HGV movements on small country roads. Noise and odours. Sally Bernham As Boughton response A Bernhay As Boughton response Mr William J Berry As Boughton response Mr L Betts Objects to WA8. Concerns over emissions and odours. Transport infrastructure cannot support the increase in HGV movements. Impacts on landscape character. Site is not located close to areas of waste generation it is intended to serve. Mrs T Betts Objects to WA8. Concerns that site is a greenfield site, impacts on landscape character, mitigations measure would be unsuccessful. Concerns that site is not located close to areas of waste generation, increase in traffic movements, infrastructure cannot support increase. Site is against government criteria for locating sites. Mrs Joan Beveridge Objects to WA8. Concerns over the increase in traffic movements on local narrow country roads, and the ability of the infrastructure to support the increase. Justin Beveridge Objects to WA8. Concerns over the increase in HGV movements on local narrow country roads, and the ability of the infrastructure to support the increase. Mr D.A Botterill - Scott Objects to WA8. Concerns that site is not located close to urban centres that it is intended to serve, which is against government guidance. Concerns that the transport infrastructure cannot support increase in HGV movements. Concerns over the close proximity of existing waste sites and the cumulative effect of these.
33 WS010001/ENRMF/CONSAPPCRAL 57 Respondent Response Mrs Y. L Botterill- Scott Objects to WA8. Concerns that is not located close to urban centres that it is intended to serve, which is against government guidance. Concerns that the transport infrastructure cannot support increase in HGV movements. Concerns over the close proximity of existing waste sites and the cumulative effect of these. Mr Kenneth Botwright As Boughton response Valerie Botwright As Boughton response Ms M.E Boullemier As Boughton response Mr Tony Boullemier As Boughton response Mr John Braga Objects to WA8. Concerns over increase in traffic movements. Odours. Ms Amanda Brodie Objects to WA8. Concerns that industrial processes will be located on Greenfield site. Site is a local amenity (riders). Effects on landscape character. Mr Andrew Brodie Objects to WA8. Concerns that proposed site is located close to existing waste sites and the potential cumulative impact. Miss A Brooks Objects to WA8. Concerns over the close proximity of existing waste site and the cumulative effect of this. Concerns that the infrastructure cannot support the increase in HGV movements. Ms Christine Brooks Objects to WA8. Concerns that industrial process is proposed for a rural greenfield sites. Site provides a local amenity. Patrick and Sarah Brooks Objects to WA8. This site is not located close to any major areas of waste generation that it is intended to serve. Concerns over the increase in HGV movements on local narrow country roads. Mr Tony Brooks Objects to WA8. Concerns that site is not located close to the centres of waste generation it is intended to serve. G. M. I Brown Objects to WA8. Concerns over the distance the site is from urban centres, the large number of HGV movements and the effects of noise and impacts on landscape character of a greenfield site. Mrs J Brown Objects to WA8. Concerns that industrial processes are proposed for greenfield sites. Site provides a local amenity. Mrs S. E Brown Objects to WA8. Concerns over the large number of HGV movements travelling from distant urban centres. The cumulative effects of other waste sites located near by. M.A Burch Objects to WA8. Concerns over effects on landscape character of the rural area. Concerns that transport infrastructure cannot support increase in traffic. Odours. There is already a waste site located near by. Mrs B Burns Objects to WA8. Concerns over impacts on landscape character due to close locations to residential property, and construction of industrial infrastructure. Mr I.W Burns Objects to WA8.
34 WS010001/ENRMF/CONSAPPCRAL 58 Respondent Response Concerns over the increase in traffic movements. Increase in emission and odours. Concerns that site does not meet government criteria for locating sites. Sheila Burr Objects to WA8. Concerns that site is not located close to areas of waste generation that it is intended to serve. Increase in traffic movements on narrow country roads, infrastructure cannot support the increase. Industrial processes should not be located on rural greenfield sites. Mrs J.K Burt Objects to WA8. Concerns that site is a greenfield site that has been used for agriculture when not used as military airfield. Site should be located in brownfield or industrial land to reduce transport distance of waste. Increased HGV movements along small country roads. Mrs Inez Dorothy Butler As Boughton response Mr John Butler As Boughton response Mr David Butter Objects to WA8. Concerns over effects on recreation. Site is not located near any urban areas it is intended to serve. Effects on landscape character. Poor transport network. Concerns over potential fluids leaking into streams. Concerns over potential for birdstrike. Industrial processes should not be located on greenfield sites. Effects on ecology. Mrs Susan Butter Objects to WA8. Concerns over effects on landscape character and recreation areas. Concerns that site is not located close to sources on waste. Transport infrastructure is not suitable for HGVs. Concerns over potential vermin. Concerns that fluids may leak into nearby streams. Concerns over effects on ecology. Mr Kevin Callis As Boughton response N Callis As Boughton response Ms Brenda Callow As Boughton response Haurice Callow As Boughton response L Cardew Does not support site selection. Objects to WA15 and WA16. Concerns that WA16 could be extended to 2026, increasing hazardous waste brought to the rural area. Andrea Carnel As Boughton response Mrs G.H Carr Objects to WA8. Concerns over the increase in HGV movements, odours and air pollution. Mr K.S Carr Objects to WA8. Concerns over air pollution and odours, the increase in HGV movements. Concerns that site is located near populated areas, should not be within 5 miles. K Carter Objects to WA8. Concerns that site is not located close to the areas of waste generation. Transport infrastructure cannot support the increase in traffic movements. Ms Shelia Carter Objects to WA8. Concerns over odours, impacts on landscape character. Increase in traffic movements on narrow country roads. Ms Abby Casey Objects to WA8. Concerns that rural infrastructure cannot support the increase in HGVs. Concerns over industrialisation of a greenfield site.
35 WS010001/ENRMF/CONSAPPCRAL 59 Respondent Response Ms Holly Casey Objects to WA8. Concerns over impacts on landscape character. Concerns over increase in traffic movements on narrow roads, infrastructure cannot support the increase. Jinny Casey Objects to WA8. Concerns that site is not located close to urban centres for waste generation which goes against government guidance (PPS10, PPS22, and PPS7). Concerns over increase in HGV movements on narrow country roads. Site is a greenfield site and would affect the landscape character. Concerns over noise and odours. Concerns that transport assessments were carried out at the entrance of the site and not the routes proposed for access. Mr John Casey Objects to WA8. Concerns that site is greenfield. Increase in HGV movements on small roads, infrastructure does not have trunk roads or rail links. Noise and odours, potential to attract vermin. More economic to place site in existing industrial site where facilities already exist. Concerns that transport assessments were carried out at the entrance of the site and not the routes proposed for access. R L Cawthra As Boughton response Naomi Cebula As Boughton response E D Chapman As Boughton response Mrs M Charters Objects to WA8. Concerns over traffic on narrow country roads and that the proposed site is on rural greenfield site. Concerns over loss of open countryside. Mr M. A Charters Objects to WA8. Concerns over traffic on narrow country roads and that the proposed site is on rural greenfield site. Concerns over loss of open countryside. Mr K Chesher Objects to WA8. Concerns over the effects on landscape character for the surrounding area due to the construction of industrial infrastructure. The airfield is an important local amenity. Mrs R Chesher Objects to WA8. Concerns over increase in traffic movements on local narrow country roads, infrastructure cannot support the increase in traffic. Mr S Chesher Objects to WA8. Concerns that site is not located close to areas of waste generation that it’s intended to serve. Claire Clark Objects to WA8. Concerns over the increase in HGV movements on local narrow roads. Concern that site is a greenfield site. Peter Clark Objects to WA8. Concerns that other waste sites are already located in close proximity. Goosey lodge is recognised as a local air pollutant. Mrs P Clarke Objects to WA8. Concerns that site is located close to existing waste sites. Noise and odours. Increase in traffic movements on narrow country lanes. The site is a greenfield site not a brownfield site. Dr S Clarke Objects to WA8. Concerns over increase in traffic movements, infrastructure cannot support the increase in movements. Mrs C.J Clay Objects to WA8. Concerns over increase in HGV movements on local narrow country roads. Infrastructure cannot support the increase in HGV movements. Dr H M Coghill As Boughton response
36 WS010001/ENRMF/CONSAPPCRAL 60 Respondent Response Mrs E Colin-York As Boughton response Mr Ron Collard Objects to WA8. Concerns that site is a historical greenfield site. The transport infrastructure cannot support the increase in HGV movements. Concerns over the cumulative effect with the three existing sites located close by. Ms Jean Collatd Objects to WA8. Concerns that site is a greenfield site and that the transport infrastructure cannot support the increase in HGV movements. Concerns over cumulative effect of the waste sites already located close by. Mrs M.W Collier As Boughton response Mr S Collier As Boughton response D.S Colvin Objects to WA8. Concerns that effluent could seep into rivers and water courses. Development would lead to area becoming an industrial site. S.H Colvin Objects to WA8. Concerns over odours carried on prevailing winds. Increase in HGV movements on narrow lanes, increasing dust and vibrations. E. Compton As Boughton response T.L Compton As Boughton response Mrs Hazel Cooper As Boughton response J A Cooper As Boughton response Mr Ronald Cooper As Boughton response Ms Elaine Copperwaite As Boughton response Mrs J Cordell Objects to WA8. Concerns that site is against government criteria for locating sites. Site is not located close to areas of waste generation. Transport infrastructure cannot support traffic movements. Impacts on landscape character. Dr J.M Cordell Objects to WA8. Concerns that site is located on a greenfield site, impacts on landscape character. Site is not located close to centres of waste generation. Transport infrastructure cannot support the traffic movements. Site is against government guidance for locating sites. Mr Roger Coulthard Objects to WA15 and WA16. WA16: Concerns that site would create a disproportionately high concentration of hazardous material in one location. Concerns that operators have not kept up safety standards. Concerns over stability of the Lincolnshire Limestone under the site and the potential risk of contamination water courses. Concerns that site is crossed by gas, oil and water pipes. Should be looking to the long term and encouraging development of more sustainable strategies. WA15: Concerns that site would generate increased traffic movements, infrastructure cannot support the increase. Concerns that site is titled as Kings Cliffe Industrial Estate despite the fact there is already an industrial estate within the village. Mr Peter James Courier As Boughton response Pam Cousens Objects to WA8. Concerns over the cumulative impact of the existing waste sites (Twinwood, Goosey Lodge). Concerns over the increase in HGVs on rural country roads. Concerns that the site is greenfield and not located close to any of the urban centres being serviced. Mr Michael Cousins Objects to WA8. Concerns that site is not located close to the urban centres it is intended to serve. Increase in traffic movements. Effects on landscape
37 WS010001/ENRMF/CONSAPPCRAL 61 Respondent Response character. Proposed site is on greenfield area. Cumulative effect of waste sites already located close by. Mrs P.M Cousins Objects to WA8. Concerns over increase in HGV movements on country roads. Site is not located close to the areas of waste generation it would serve. Industrial processes should not be located on greenfield sites. Effects on landscape character. Cumulative effects of the waste sites already located in the area. Mrs G Cox Objects to WA8. Concerns that industrial processes are proposed for a greenfield site. Increase in traffic movements. Site is not located close to the areas of waste generation. Mr M Cox Objects to WA8. Concerns that site is not located close to areas of waste generation. Increase in traffic movements. Concerns that greenfield site is proposed for industrial processes. Site is in close proximity to existing waste sites. Mr Paul Cox As Boughton response Mrs Crewe Objects to WA8. Concerns over the increase in HGV movements on narrow country roads that cannot support the increase. Mr P Crewe Objects to WA8. Concerns that an industrial process is being located on a rural greenfield site. Site provides a local amenity. Effects on landscape character due to construction of industrial buildings. Mrs B Critchell As Boughton response Mr Harry Critchell As Boughton response Nick Croft Objects to WA8. Concerns that industrial processes are being located in open countryside. Concerns over increase in HGV movements along narrow rural roads. Site is not located close to the centres of population that it is intended to serve, resulting in increased travel distances. Sarah Croft Objects to WA8. The site is a rural greenfield site and is not located close to any urban areas. Concerns over the traffic on the narrow country roads. M. J Crouch Objects to WA8. Concerns over the effect on landscape character for the surrounding areas due to industrial infrastructure. R. L Crouch Objects to WA8. Industrial processes should not be located on a rural greenfield site. The airfield is an important local amenity. Mr Martin Cullen As Boughton response Mrs Valerie Cullen As Boughton response John Cunningham Objects to WA8. Concerns over the effect on the landscape character of the surrounding countryside. Concerns over the increase in traffic. Susan Cunningham Objects to WA8. The site is a short distance from existing plant at Twinwoods and Goosey Lodge. Plant at Goosey Lodge contributes to air pollution in the area. Mr L Curtis As Boughton response Mr Adrian Dale Objects to WA8. Concerns that site is a greenfield site located away from urban spine. Site has poor transport links.
38 WS010001/ENRMF/CONSAPPCRAL 62 Respondent Response Lynne Dale Objects to WA8. Concerns that the transport infrastructure could not support the increase in HGV movements as the roads are narrow country roads. The increase in HGV movements is inappropriate for the rural location. Mr Richard Daniels As Boughton response Sandra Daniels As Boughton response Diana Darlington As Boughton response Mr Malcolm Graham Darlington As Boughton response Mrs B.M. Davenport As Boughton response R N Davenport As Boughton response I Davies As Boughton response Ann Davison As Boughton response Mr Russell Davison As Boughton response T I Dayigs As Boughton response M.B Deady As Boughton response Arabelle Dean As Boughton response Mr Michael John Dean As Boughton response Mr David Deane As Boughton response Mrs Delia Deane As Boughton response Mrs Desoutter Objects to WA8. Concerns over the increase in traffic movements, odours and concerns that site is a greenfield site. Ms Fiona Dickenson As Boughton response Mr R P Dickenson As Boughton response Mr Edward Digby As Boughton response Melanie Digby As Boughton response Mr Richard Digby As Boughton response Mr William Digby As Boughton response Miss L Dinonpoint As Boughton response Mr Robert Dixon Objects to WA16. Concerns that consultation was not publicised so resident where not aware it was taking place. Concerns that life of the site has been extended to 2016 and further extension to 2026 is proposed. Concerns that extension of the site will impact on ground and soil strata increasing risk of seepage and contamination to existing water courses. Increase in traffic, concerns that at present HGVs ignore routing agreements. Mr Joe Docker As Boughton response Brian Dodd Objects to WA8. Concerns that waste sites are already located close to the site. Mr Dan Dorgan As Boughton response Pam Dorgan As Boughton response
39 WS010001/ENRMF/CONSAPPCRAL 63 Respondent Response Mrs J Dormer Objects to WA8. Concerns that site is within a rural area and is not located close to urban centres it will serve. Concerns over the effects on landscape character. Increase in HGV movements on minor country roads. Joanne Downie As Boughton response Mr Jon Downie As Boughton response Mr and Mrs S Drage Objects to WA8. Concerns over access to site, should create direct access from A14 so that HGVs avoid Avenue Road and the villages. Duffy As Boughton response Charlotte Duffy As Boughton response J B Duffy As Boughton response Rebecca Duffy As Boughton response Sophie Duffy As Boughton response Jean Dunn As Boughton response Mrs Lynda Dunne As Boughton response Mr Noel Dunne As Boughton response B Dunstone As Boughton response Mrs Carol Dunstone As Boughton response Ray Dyer Objects to WA8. Concerns that site is a greenfield site. Concerns over increase in HGV movements on small narrow country lanes. Site is not located close to the areas of waste generation. Impacts on landscape character. Doreen Easy Objects to WA8. Industrial processes like AD should not be located on a rural greenfield site. The airfield provides a major local amenity. Horace G Easy Objects to WA8. The site is only a short distance for existing plant at Twinwoods, the waste facility at Goosey Lodge and the site at Westwood Rushden. The cumulative effect needs to be considered. The plant at Goosey Lodge is recognised as a contributor to local air pollution. Mrs B. M Elldred Objects to WA8. The site is a short distance from existing plants at Twinwoods, Goosey Lodge. Plant at Goosey Lodge contributes to air pollution in the area. W. J Elldred Objects to WA8. Concerns over the increase in traffic on narrow local country roads which is inappropriate for such a rural location with poor transport infrastructure. Mrs C Ellis Objects to WA8. Concerns that site is located close to existing waste sites, and the cumulative effect of all the sites. Mr R Ellis Objects to WA8. Concerns over increase in traffic movements on local narrow country roads, infrastructure cannot support the increase. Mrs J Eshelby Objects to WA8. Concerns over the effect on transport infrastructure due to increase in HGV movements. Effects on landscape character due to construction of buildings.
40 WS010001/ENRMF/CONSAPPCRAL 64 Respondent Response M Etherington Objects to WA8. Concerns over increased HGV movements on narrow country roads. The site is in a rural aspect and will impact on the landscape character. Concerns over the pollution and noise impact on the rural surroundings. Miss S Farmer Objects to WA8. Concerns that site is not located close to areas of waste generation. Transport infrastructure cannot support increase in HGV traffic. Concerns site is against national policy, not to use greenfield sites. Mr Stephen Faulker Objects to WA8. Concerns that industrial processes are proposed for a rural greenfield site. Site provides a local amenity. Impacts on landscape character, due to construction of industrial infrastructure. Mrs Jane Faulkner Objects to WA8. Concerns that site is not located close to areas of waste generation that it is intended to serve. Increase in traffic movements on local, narrow country roads, infrastructure cannot support the increase in movements. Sheldon Fenning As Boughton response Simone Fenning As Boughton response Dr J Fentem Objects to WA8. Concerns that site is located close to existing waste sites and the potential cumulative effects. Goosey Lodge is a recognised contributor of air pollution. Increase in traffic movements on narrow country roads. Ms Catherine Field As Boughton response Mr Robert Field As Boughton response Mrs C.M Fieldhouse Objects to WA8. Concerns that site is a greenfield site. Site should be located closer to the areas of waste generation. Concerns over increase in HGV movement on infrastructure that cannot support the increase. Odours. Mr D.H Fieldhouse Objects to WA8. Concerns that site is a greenfield site. Local transport infrastructure cannot support the increase in HGV movements. Site should be located on a brownfield site closer to areas of waste generation that is located close to road and rail links. Impacts of odour. A. Fleming As Boughton response Ms Karen Fletcher As Boughton response Mr J.K Flynn Objects to WA8. Concerns that site is located close to existing waste sites. Site is a greenfield site; industrial processes should not be sited on greenfield site. Mrs Janet Flynn Objects to WA8. Concerns over impacts on landscape character. Site is not located close to areas of waste generation that it is intended to serve. Graham Fogden As Boughton response Giuseppe Forgione As Boughton response Louise Forgione As Boughton response Mr D Foster As Boughton response J Foster As Boughton response Mr Michael Foulger Objects to WA8.
41 WS010001/ENRMF/CONSAPPCRAL 65 Respondent Response Concerns that site is proposed for a greenfield site as confirmed in Three Towns Plan. Concerns over access to site, not served by rail or A roads, current infrastructure cannot support the increase in HGV movements. Industrial processes should be located on industrial sites. Concerns that site is not located close to areas of waste generation. Concerns that after treatment the treated waste will have to be removed causing more HGV movements. Impacts on landscape character. Concerns that site is against government guidance on locating sites. Mr A Fox As Boughton response Mrs I Fox As Boughton response Mr Derek Francis Objects to WA8. Concerns over the increase in HGV movements. Concerns that site is a green field site, it should be located closer to urban areas. A.L Freeman Objects to WA8. Concerns that infrastructure cannot support increase in traffic, roads are narrow country roads. Industrial processes should not be located on greenfield sites. Site is a local amenity. Effects on landscape character due to construction of industrial buildings. Site not located close to the sources on waste. Proposed site is located close to existing waste sites. L.J Freeman Objects to WA8. Concerns that infrastructure cannot support increase in traffic, roads are narrow country roads. Industrial processes should not be located on greenfield sites. Site is a local amenity. Effects on landscape character due to construction of industrial buildings. Site not located close to the sources on waste. Proposed site is located close to existing waste sites. B.D Garley Objects to WA8. Concerns over increase in HGV movements and impacts on landscape character. Mr Mark Gaterell As Boughton response Stephanie Gaterell As Boughton response Mrs H. Gaudin As Boughton response Mr M Gavdin As Boughton response Ms Jill Gist As Boughton response Mr Robert Gist As Boughton response Carolyn Glanney As Boughton response Mr A.J.S Gledhill As Boughton response Mr L.J Gledhill As Boughton response Mr Stephen Glen Objects to WA15 and WA16. WA15: Impacts of noise and odours, emissions. Impacts on recreation in adjacent woodlands. Potential for pollution of aquifer and other water courses. Impacts on amenity and landscape character. Increase in traffic movements on infrastructure that cannot support the increase (Wansford Road). Concerns over mud on the roads. Impacts on wildlife (deers cross the site could consume contaminated materials, crossing roads). WA16: Concerns over potential for ground and surface water pollution. Soil contamination. Dust and emissions. Noise and vibrations and impacts on sensitive environmental receptors adjacent the site (woodlands). Increase in traffic movement on infrastructure that cannot support the increase (Wansford Road). Cumulative effect with existing hazardous waste facility. Concerns over operations of the site and the risk it carries (management, fires). A.P. Goddard As Boughton response
42 WS010001/ENRMF/CONSAPPCRAL 66 Respondent Response Gillian H Gogden As Boughton response P.A Gonsalves Objects to WA8. Concerns that industrial processes should not be located on rural greenfield sites. Site is a local amenity. Ms Sally Gowsalves Objects to WA8. Concerns over increase in traffic movements on local narrow country roads, rural transport infrastructure cannot support increase in traffic. Mrs Helen Graft As Boughton response l.A Graham Objects to WA8. Concerns over increase in traffic on narrow roads. Site is located close to existing waste sites. Should not be located on greenfield sites. R.W Graham Objects to WA8. Concerns over noise and odours. Infrastructure will not support increase in traffic movements. Liz Grasmeder Objects to WA8. Concerns that industrial processes should not be located on rural greenfield sites. Impacts on landscape character due to construction of industrial infrastructure. R C Grasmeder Objects to WA8. Concerns that industrial processes should not be located on rural greenfield sites. Impacts on landscape character due to construction of industrial buildings. Dr Alexander Gray Objects to WA8. Concerns over the effects on the landscape character and historic sites. Concerns over the effects on recreation (footways, bridleways) and also the risk from HGVs crossing the paths. Concerns over the transport infrastructure. Concerns over the cumulative effect of other biomass plants already located in the area, one site is known to be a source of air pollution. D J Gray Objects to WA8. Concerns that site is located close to existing waste sites, cumulative impacts need to be considered. Goosey Lodge recognised as a contributor to local air pollution. Dr Diane Gray Objects to WA8. Concerns that site is a Greenfield site that does not have rail, water or roads links and can only be accessed using minor roads. Concerns that nearby villages contain listed buildings and historical features. L Gray Objects to WA8. Concerns that industrial processes are being proposed for rural green field site. Site provides a local amenity Lesley Gray As Boughton response Mr Mark Gray As Boughton response Mr Roger Gray Objects to WA8. Concerns that site is located close to existing waste sites, which would generate a cumulative effect. Goosey Lodge is a recognised contributor of air pollution. Mr Kevin Greatorex As Boughton response Ms Sue Greatorex As Boughton response M Greener As Boughton response R Greener As Boughton response Mr Stuart Greenslade As Boughton response
43 WS010001/ENRMF/CONSAPPCRAL 67 Respondent Response Victoria Greenslade As Boughton response Miss Grey Objects to WA8. Concerns that site does not comply with government guidance. Concerns over noise and odours. Concerns over increase in traffic movements. The effects on landscape character. Potential for disease and vermin. Concerns that transport assessment was carried out at the entrance of the site and not the proposed access. Concerns that non industrial traffic has not been considered. Ms C.A Hackett Objects to WA8. Concerns over the increase in traffic on narrow country roads. Concerns over the effects on landscape character. Air pollution. Concerns over the distance away from the grid. Concerns over loss of amenity. Mr David Hackett Objects to WA8. Concerns that site is not located near the centres of waste generation. Transport network cannot support increase in HGV movements. Concerns over noise and odours. Concerns that industrial processes are being considered for a rural greenfield site. Maureen Haddon As Boughton response Mr Peter Haddon As Boughton response Mr Andy Hall Objects to WA8. Concerns over increase in traffic movements on local, narrow country roads, infrastructure cannot support the increase. Mrs Carole Hall Objects to WA8. Concerns that site is located on a greenfield site, impacts on landscape character, nature conservation and historical environment. Site is a local amenity, loss of recreation areas. Increase in HGV movements on narrow country lanes, infrastructure cannot support the increase. Site is not located close to areas of waste generation. Noise and odours. Site is located close to existing waste sites. Mr Jonathan Hall Objects to WA8. Concerns that site is located on a greenfield site, impacts on landscape character, nature conservation and historical environment. Site is a local amenity, loss of recreation areas. Increase in HGV movements on narrow country lanes, infrastructure cannot support the increase. Site is not located close to areas of waste generation. Noise and odours. Site is located close to existing waste sites. Mrs Paula Hall Objects to WA8. Concerns over the increase in HGV movements on local, narrow country roads. Concerns that the site is not located close to the urban areas it is intended to serve. Industrial processes should not be located on rural greenfield sites. Impacts on the ecology of the site. Concerns over the effect on landscape character. Need to consider Avian Flu and Blue tongue. Mrs M.E Hamilton Objects to WA8. Concerns that site is inappropriate for rural development. P.J Hamilton Objects to WA8. Concerns that site is proposed for a rural location. Potential impacts on air quality. Mrs C Handshaw As Boughton response Mr Chris Handshaw As Boughton response R R Hardwick As Boughton response Mr J.T Harris As Boughton response Mrs Joyce Harris As Boughton response Mrs K.N Harris As Boughton response Mr David James Harrop As Boughton response
44 WS010001/ENRMF/CONSAPPCRAL 68 Respondent Response Mrs Dorothy Harrop As Boughton response Mr Charles Hartop Objects to WA8. Concerns that transport infrastructure cannot support increase in traffic and the weight of the HGVs. Mrs J Harwood Objects to WA8. Industrial processes should not be located on a rural greenfield site. The air field is an important local amenity. Mrs C Hatch Objects to WA8. Concerns that site is a greenfield site. Proposed site is located in close proximity to existing waste sites. Effects on landscape character. Concerns over increase in HGV traffic. P.J Hatch Objects to WA8. Concerns that site is a rural greenfield site that provides recreation areas. Concerns that site is not located close the urban areas it is intended to serve. Concerns over increase in HGV movements on narrow country lanes. Concerns over the effects on landscape character for the surrounding villages. Noise and odours. Concerns that putting down concrete will increase runoff of rainwater which could lead to flooding, contaminated water could leak into local water courses. Concerns that other waste sites are already located in close proximity to the site. Crispin Heesom Objects to WA16. Concerns that site is located in close proximity to sports facilities that are in the process of being developed. Concerns over odours. Mr and Mrs Hellard Objects to WA15 and WA16. WA15: Concerns that facility would increase traffic flow (A47, Wansford Kings Cliffe Road junction) infrastructure cannot support the increase in traffic. Concerns that naming site Kings Cliffe regeneration centre would cause HGVs to travel into village instead. WA16: Concerns that extension would be nearer the village and also a community sports and leisure facility. Facility would be in line of NW winds from the site. Dr Mike Henchy Objects to WA16. Further extension of the existing facility for high level waste processing is unjustified. Adds to potential terrorist threat of a nearby military installation. Mr John Hewerson As Boughton response Sara Hewertson As Boughton response Mr and Mrs Hewitt Objects to WA8. Concerns over the increase in traffic, noise, odours, effects on landscape character and the effects on the environment. Mr Thomas Hewitt As Boughton response Katie Higgs As Boughton response Mrs Daphne Higham As Boughton response Mr Graham Hill Objects to WA8. Concerns that transport infrastructure cannot support increase in traffic. Site is located on a greenfield site. Site is not located close to the urban centres that it is intended to serve. There are already existing waste sites located near by. Potential for odours. Effects on ecology on the site. Mrs J.L Hill Objects to WA8. Concerns over increase in HGV movements on local narrow country roads. Mrs Judith Hill Objects to WA8.
45 WS010001/ENRMF/CONSAPPCRAL 69 Respondent Response Concerns that transport infrastructure cannot support increase in traffic. Site is located on a greenfield site. Site is not located close to the urban centres that it is intended to serve. There are already existing waste sites located near by. Potential for odours. Effects on ecology on the site. P.J Hill Objects to WA8. Concerns that industrial processes are proposed to be located on rural greenfield site. Site provides a local amenity. Mrs Shirley Hillier As Boughton response Ms C Hilton Objects to WA8. Concerns that site is not located close to the major urban centres that it is intended to serve, which goes against government guidance. Concerns over increase traffic on local, narrow country roads. Concerns over effects on landscape character and archaeology. Concerns that site is referred to as brownfield when it is a greenfield site that is a local amenity. Concerns that site is located close to existing sites (Goosey Lodge, Westwood). Mr Barry Hobbs Objects to WA8. Concerns over increase in traffic. Mr and Mrs Holden Objects to WA8. Concerns that site is not located close to any of the major urban centres of waste generation. Concerns over increase on HGV movements on rural infrastructure. Concerns that industrial processes are being located on greenfield site, area is a major amenity. Effects on landscape character due to construction of industrial buildings. The proposed site is located in close proximity to existing waste site. Ms Alison Holley Objects to WA8. Concerns over increase in HGV movements on local narrow country roads. Rural infrastructure cannot support the increase. Mr Peter Holley Object s to WA8. Concerns over impacts on landscape character. Odours and increase in HGV movements. Lianda Hollyman Objects to WA8. Concerns that site is not located close to any of the major urban centres that it is intended to serve. Mark Hollyman Objects to WA8. Concerns that site is not located close to the urban centres that it is intended to serve. Mrs M Honour Objects to WA8. Concerns over impacts on landscape character due to construction of industrial buildings. Increase in traffic movements and odours. Ms Sherie Honour Objects to WA8. Concerns over potential spillage from HGVs transporting the waste. Increase in HGV movements. Effects on landscape character. Site is not located close to the source of waste. Air pollution. Mr Simon Honour Objects to WA8. Concern over increase in traffic, that site is proposed for a greenfield site. Potential for spillages on the roads. Site is not located near the sources of waste. Emissions, odours. Ms Stephanie Honour Objects to WA8. Concerns over potential spillage from HGVs transporting the waste. Increase in HGV movements. Effects on landscape character. Site is not located close to the source of waste. Air pollution. Mr David Houriham As Boughton response Mrs Sonja Hourihan As Boughton response
46 WS010001/ENRMF/CONSAPPCRAL 70 Respondent Response D.J Howard Objects to WA16. Concerns that life of the site is now much longer than residents are lead to believe. Concerns that as the sandstone is porous spillages could seep through to ground water. Concerns that expansion of site will mean a large increase in hazardous material disposed of at the site. Mr Michael Hudson Objects to WA8. Concerns over increase in traffic which is not suitable for rural roads. Effects on the landscape character of the area. Anne Hughes As Boughton response S.R Hughes As Boughton response Mr David Hull Objects to WA15 and WA16. Concerns over the potential for water contamination. Concerns that extension is going against what resident were told in original plans. Concerns that site is not monitored and the potential for air borne pollutions. Impacts on the ecology. Concerns that site is located close to residential areas. Odours. Concerns over increase in HGV movements. Impacts on recreation. Concerns that there is currently no warning system in place to advice of incidents on site. Mr I Humby As Boughton response Mr Matthew Hunt As Boughton response Oonagh Hunt As Boughton response Mr M.H Hunter Objects to WA8. Concerns that site is against national guidelines on locating sites. Site is not located on urban spine which is against East Midlands plan and MWDF strategy. Concerns that site is not served by rail or A roads. Mr Brian Hurren As Boughton response Margaret Hurren As Boughton response June Insall As Boughton response R Insall As Boughton response Abigail Isserlis Objects to WA8. Concerns that site is not located close to areas of waste generation. Increase in traffic movements. Industrial processes should not be located in a rural area. Mr Neil Isserlis Objects to WA8. Concerns that site is not located near areas of waste generation. Increase in traffic movements. Industrial processes should not be located in rural areas. Mrs J Izzard Objects to WA8. Concerns over increase in HGV movements on narrow country roads. Concerns that it will not be local waste going to the site. Concerns that site is a greenfield site. Impact on landscape character. M.J Izzard Objects to WA8. Concerns that site is proposed for greenfield site. Mr M.J Izzard Objects to WA8. Concerns over increase in HGV movements on narrow country roads. Site is not located close to areas of waste generation. Concerns site is proposed on a greenfield site. Impacts on landscape character H S Jackson Objects to WA8.
47 WS010001/ENRMF/CONSAPPCRAL 71 Respondent Response Concerns over impacts on landscape character due to construction of industrial buildings. Noise, odours, vibrations and vermin. Concerns that site is located in close proximity to existing waste sites and the cumulative effect of this. Concerns over increase in traffic movements on narrow country roads, on infrastructure that cannot support the increase in movements. Mrs O.M James As Boughton response D Jameson Objects to WA8. Concerns over the traffic on narrow village roads, effects on landscape character and the prevailing wind carrying odours. Mrs G.D Jeffcoat Objects to WA8. Concerns over increase in HGV movements on local narrow country roads. Concerns that site is a greenfield site. Mr R Jeffcoat Objects to WA8. Concerns that site has been designated a greenfield site in the three towns plan. Concerns over increase in traffic movements on narrow, local country roads. Mr Michael Jefferson Objects to WA8. The proposals for the site are against national planning guidance (PPS22, PPG2, PPS10, and PPS7). PPS22: Site is designated as greenfield, long distance from sources of waste, roads cannot support increase in HGV, no railway link, not easily connected to the Grid. PPG2: Site is inappropriate development on greenfield site. PPS10: No Sustainability appraisal or SEA, doesn’t meet criteria of "without harming the environment" or "one of the nearest installations". PPS7: Does not meet the key principles set out in the guide "priority should be given to the re-use of previously developed sites". Prof A Jenkinson Objects to WA8. Concerns that site does not comply with government guidelines. Concerns that site is a rural greenfield site. Ms Sally Jenkinson Objects to WA8. Concerns that transport infrastructure cannot support HGVs. Effects on archaeology (Yelden). Concerns over noise and odours and the increase in HGV movements. Mr David Johnson Objects to WA8. Concerns over the increase in HGV movements on local, narrow country roads. The transport infrastructure cannot support this increase. M Johnson Objects to WA8. Concerns over increase in HGV movements on narrow country roads. Concerns that site is a greenfield site. Mr A Johnstone Objects to WA8. Concerns that an industrial process is being located on rural greenfield site. The site is a local amenity. Ms Ann Jones As Boughton response Ms Catherine Jones As Boughton response Ms Christine Jones As Boughton response Mrs D Jones Objects to WA8. Concerns that site is not located close urban centres that it is intended to serve. Concerns over increased traffic movements on country roads. Concerns that industrial processes are being considered for greenfield site. Effects on landscape character. Noise and odours. Mr Derek Jones As Boughton response Mr E.G Jones Objects to WA8. Concerns that site is not located close urban centres that it is intended to serve. Concerns over increased traffic movements on country roads. Concerns that industrial processes are being considered for greenfield site. Effects on landscape character. Noise and odours.
48 WS010001/ENRMF/CONSAPPCRAL 72 Respondent Response Mrs Anne Joyner Objects to WA8. Concerns that site is a greenfield site. Effects on recreation (walkers). Infrastructure is not able to support the development. Other facilities nearby are available to deal with the waste. Mrs C. J Judson Objects to WA8. The site affects the landscape character of the surrounding countryside. With industrial buildings, possible chimney stacks, lighting and other industrial infrastructure. M Judson Objects to WA8. Industrial processes such as AD should not be located on a rural greenfield site. The former airfield is a major local amenity. M Karl Objects to WA8. Concern over increase in HGV movements through the villages. Site is greenfield and a local amenity. Mrs Linda Kelly Objects to WA8. Concerns that site is not located close to urban centres of waste generation that it is intended to serve. Concerns that industrial processes are being located on rural greenfield sites. Mr Andrew Kemp Objects to WA8. Concerns that site is not located close to urban areas and is on a greenfield site. Transport infrastructure cannot support increase in traffic movements. Loss an amenity. Impacts on the landscape character of the area. Ms Zoe Kemp Objects to WA8 Concerns that site is not located close to urban areas and is located on a greenfield site. Transport infrastructure cannot support increase in HGV movements. Loss of a local amenity. Impact on landscape character. J Kightley Objects to WA8. Concerns over the lack of detail in relation to size of site. Concerns over increase in HGV movements in the area. Concerns over the potential contamination from the site. Concerns that site is located on greenfield site from 3 towns plan. D Kightly Objects to WA8. Concerns over odours. Increase in HGV movements on a transport infrastructure that cannot support the increase. Concerns that site is a greenfield site and the impacts on ecology. N King- Underwood Objects to WA8. Concerns that site is not located close to the urban centres it is intended to serve. Proposed site is located in close proximity to existing waste sites. Concerns over increase in HGV movements on country roads. Effects on landscape character. Ms Gillian Kingston As Boughton response Mr Jonathan Kingston As Boughton response Mr Neil Kitchener As Boughton response Mr Richard Kitchener As Boughton response Mrs Val Kitchener As Boughton response D. L Knight Objects to WA8. Road network is not suitable. Should be located close to urban areas. Concerns over odours. Concerns that there are already waste sites close to the proposed site. Mrs D Knitt As Boughton response Mr J.A Knitt As Boughton response
49 WS010001/ENRMF/CONSAPPCRAL 73 Respondent Response Mrs H Lambert Objects to WA8. Concerns over the potential cumulative effect of existing waste sites located near by. The site at Goosey Lodge is recognised as a contributor to air pollution. Mr S.J Lambert Objects to WA8. Concerns over the increase in HGV movements on local narrow country lanes. The site has a poor transport infrastructure. Ms Rita Lantsbery As Boughton response Mrs D Laughton Objects to WA8. Concerns that site is not located close to the areas it is intended to serve and it does not have good road or rail links which goes against government guidance. Concerns that site is a greenfield site. Concerns over increase in HGV movements on narrow country roads. Concerns over noise and odours. Concerns over effects on landscape character. Concerns over cumulative effect of existing waste sites in close proximity. Peter Laughton Objects to WA8. Concerns that site is a greenfield site. The effects on landscape character (site on plateau 34 m higher). Concerns over the lack of transport infrastructure (no A roads, rail links) and increase in traffic on country roads. Site is not located close to areas it is intended to serve. Noise and odours. Effects on recreation (footpaths, bridleways). Effects on ecology. Cumulative effect of Goosey Lodge. Potential for fluids to leak into ground from site. Transport site assessment was carried out at the entrance of site and not on the access routes that are proposed. Potential conflict with non-industrial traffic has not been considered in the assessments. Mr Andrew Laurie As Boughton response Glenda Laurie As Boughton response Alastair Lawrie As Boughton response Catherine Lawrie As Boughton response Mrs C Lea As Boughton response Mr M J Lea As Boughton response R Lee As Boughton response S Lee As Boughton response E Legrand As Boughton response Ms Rachel Legrand As Boughton response S A Lett As Boughton response M.A Limb Objects to WA8. Concerns that site is a greenfield site that is a buffer zone around the expanding Rushden. Loss of recreation area. Impacts on landscape character. Concerns that transport infrastructure cannot support the increase in traffic movements. Mr Peter Lindsley As Boughton response Mr B Linke Objects to WA8. Concerns over the increase in traffic on local narrow country roads. The transport network is inappropriate. Concerns over possible increase in rodents. Mrs C Linke Objects to WA8. Concerns that site is not located close to the urban areas that it is intended to serve. Industry should not be located on rural greenfield sites. Ms Penny Lloyd Bennett Objects to WA16.
50 WS010001/ENRMF/CONSAPPCRAL 74 Respondent Response Concerns that site already has potential for health implications. Expansion would increase odours and traffic movements. Increase in land contaminations. Mr Peter Lloyd Bennett Objects to WA16. Concerns that site is located close to villages that are expanding, impacts on landscape character. Concerns over contamination of soil and air. Concerns that transport infrastructure cannot support increase in HGV movements. H C Lonell As Boughton response Ms Sylvia Ellen Lovell As Boughton response Mrs J Mabbutt As Boughton response Mr P Mabbutt As Boughton response T Macavoy Objects to WA8. Concerns over the effect on landscape character for the surrounding villages due to construction of industrial infrastructure. Oliver Mackaned As Boughton response Charlotte Mackaness As Boughton response J Maisey Objects to WA8. Concerns that site is located close to existing waste sites. Site is not close to areas of waste generation. Local infrastructure cannot support increase in HGV movements. S.L Maisey Objects to WA8. Concerns that site is located close to existing waste sites. Site is not close to the areas of waste generation. Local transport infrastructure cannot support the increase in traffic movements. Mrs Eleanor Maltby As Boughton response Mr Terence Maltby As Boughton response Mrs J Marlow Objects to WA8. Concerns that industrial processes are proposed for a greenfield site, it provides a local amenity. Site is not located close to the areas of waste generation. Increase in traffic movements on narrow country roads. Site is located close to existing waste sites. Impacts on landscape character. Mr J Marlow Objects to WA8. Concerns that site is proposed for a greenfield site that is not located close to areas of waste generation. Increase in traffic movements, infrastructure cannot support the increase. Impacts on landscape character. Mr C D Marriot Objects to WA8. Concerns that site is not located close to areas of waste generation that it is intended to serve. Increase in traffic movements on local narrow country roads. Industrial processes should not be located on rural greenfield sites. Mrs A Marriott Objects to WA8. Concerns that industrial processes are proposed for a rural greenfield site. Site is a local amenity. Increase in traffic movements on narrow country roads. Dr Geoff Mason Objects to WA16. Concerns over the potential leakage of the hazardous materials and the impacts on Kings Cliffe and Willow Brook as groundwater flows in this direction under the site. The Lincolnshire is shown as a major aquifer, the environment agency would object to landfill on a major aquifer. Concerns that mitigation would be relying on a man made seal to prevent leakage. Site should be located in an existing clay pit.
51 WS010001/ENRMF/CONSAPPCRAL 75 Respondent Response Joan Mason As Boughton response Mr Philip Mason As Boughton response Ms Mia McAughtrie Objects to WA15 and 16. Gas and water pipes cross the site. Transport infrastructure is not suitable for increase in traffic movements. Concerns that site is vulnerable to management errors leading to contamination. McBratney Object to WA8. Concerns over the increase in traffic and HGVs on narrow country roads. Ms Melanie McCall Objects to WA15 and 16. WA16: Concerns that site is not monitored. Concerns that area has already received large amounts of hazardous waste. Concerns over potential impacts on water. Impacts on landscape character and ecology. Concerns over proximity of schools to the site. Concerns over increase in HGV movements. Mrs L.S McCormack Objects to WA8. Concerns that site is not located close to the centres of waste generation. Increase in traffic movements. Concerns that site is a greenfield site that is a local amenity. Mr M McCormack Objects to WA8. Concerns that site is not located close to urban areas; this would require increased traffic movements. Anwen McDonnell As Boughton response Mr Daniel McDonnell As Boughton response Rosemary McDonnell As Boughton response W McDonnell As Boughton response Adrian McGlynn Objects to WA8. Concerns over the effects on the local rural roads. Industry is not suitable for rural sites. Concerns over air pollution and the effects on the landscape character. Brian McGovern Objects to WA8. Concerns that the industry is inappropriate for rural areas. The location of the site is wrong in relation to the area it will serve. Ria McGovern Objects to WA8. Concerns that industrial processes are being located in rural greenfield area, should be located in industrial areas. Joanne McGowan As Boughton response Ms Mary McGowan As Boughton response Mr Thomas McGowan As Boughton response Mr Thomas McGowan As Boughton response Mr Kevin McMahon Objects to WA8. Concerns that industrial processes are being proposed for rural greenfield site. The site provides a local amenity. Ms Sally McMahon Objects to WA8. Concerns that site is not located close to the areas of waste generation that it is intended to serve. Janet McMillan Objects to WA8. Concerns that site is a greenfield site. Concerns over increase in traffic movements on local narrow country roads. The rural infrastructure cannot support the increase in HGV movements.
52 WS010001/ENRMF/CONSAPPCRAL 76 Respondent Response Ms Jane McMonagle Objects to WA8. Concerns that site is not located close to the urban centres of waste generation which is against government guidelines. Concerns over increase in HGV movements on local narrow country roads, as no main road access. Current waste sites already contribute to air pollution. Mr Martin McMonagle Objects to WA8. Concerns over increase in HGV movements, effects on landscape character and the potential for air pollution. Mrs Imelda McQuillan As Boughton response Dr W.J McQuillan As Boughton response Dr Jeremy Mead Objects to WA8. Concerns over increase in traffic movements on local country roads, infrastructure cannot support the increase. Concerns that industrial processes are proposed for a greenfield site. Site is a local amenity. Mr R.G Miley Objects to WA8. Concerns over increase in HGV movements on narrow roads and the odour. Mr Derek Millard As Boughton response Helen Mills Objects to WA8. Concerns over the effect on landscape character for surrounding villages due to the construction of industrial infrastructure. Tim Mills Objects to WA8. Industrial processes should not be located on a rural greenfield site. The former airfield is a major local amenity. Mrs P Mommersteeg Objects to WA8. Concerns that site is not located close to areas of waste generation. Increase in traffic movements and infrastructure cannot support increase. Site is greenfield. Impacts on ecology and flora and fauna. Impacts on recreation. Ms Anna Moore As Boughton response Mr Frank Moore As Boughton response Mr Peter Morgan Objects to WA8. Concerns that site is a greenfield site and not suitable for industrial processes. The site is not located close to the areas of waste generation, requiring increased HGV movements on rural roads. Concerns that odours and other effects could not be mitigated. Effects on amenity, ecology and landscape character. Mrs Rosemary Morgan Objects to WA8. Concerns that site is a greenfield site and not suitable for industrial processes. The site is not located close to the areas of waste generation, requiring increased HGV movements on rural roads. Concerns that odours and other effects could not be mitigated. Effects on amenity, ecology and landscape character. B.S Morris Objects to WA15 and 16. Concerns over odours and emissions. Concerns that life of site is being extended to 2026 when residents had been assured site would close in 2011. Concerns over the ability of the infrastructure to support increase in traffic movements. HGVs will not follow the routing agreements. Both sites need to be considered together to consider the cumulative effect. Janet T Morris As Boughton response Mr Neville Morris As Boughton response Master Ethan Morrish Objects to WA8. Concerns over the loss of recreation areas.
53 WS010001/ENRMF/CONSAPPCRAL 77 Respondent Response Ms Nicola Morrish Objects to WA8. Concerns over noise, odours and effects on ecology. Impacts on landscape character. Gwenn Morrison McIntyre Objects to WA8. Concern over impacts on recreation (Footpaths, bridleways). Impacts on landscape character and ecology on the site (Bats, voles, great crested newts). Impacts on the historical buildings surrounding the site and the archaeology located on the site. Concerns over potential for leaks into the water course and the increase risk of flooding. Increase in HGV movements. Noise and odours. Impacts on landscape character. J Morton Objects to WA8. Concerns over increase in HGV movements on local narrow country roads. Concerns that site is a greenfield site. M.J Muncaster Objects to WA8. Concerns that processes are unsuitable for rural areas. Transport infrastructure cannot support traffic movements. Noise and emissions. Ms Ann Murphy As Boughton response Jane Murphy Objects to WA8. Concerns that industry is being located in a rural area, with increase in traffic. Site is a greenfield site. Not located close to towns it will serve. Similar site located nearby. Miss M Murphy Objects to WA8. Concerns that the site is not located close to any of the major urban centres that it is intended to serve. Concerns over the increase in HGV movements on a poor transport infrastructure. Concerns that site is a rural greenfield site. Mr Matt Musselle Objects to WA8. Concerns that site is located in a greenfield area. Site will impact on landscape character, ecology and the historical environment. Site is used for recreation. Concerns over increase in HGV movements on narrow country roads. Site is not located close to the sources of waste. Noise and odours. Site is located close to existing waste sites. Ms Stephanie Musselle Objects to WA8. Concerns that site is located in a greenfield area. Site will impact on landscape character, ecology and the historical environment. Site is used for recreation. Concerns over increase in HGV movements on narrow country roads. Site is not located close to the sources of waste. Noise and odours. Site is located close to existing waste sites. Mrs S Mynolt As Boughton response Mr R.E Mynott As Boughton response Mr Rish Napier As Boughton response Sue Napier As Boughton response Mrs C Neal Objects to WA8. Concerns that site is not located close to areas of waste generation. Increase in traffic movements on narrow country roads. Site is a greenfield site that provides a local amenity. Impacts on landscape character. Mr P Neal Objects to WA8. Concerns that site is not located close to areas of waste generation. Concerns over traffic movements on narrow country roads. Site is a greenfield site that provides a local amenity. Impacts on landscape character. Mr George Neophiton As Boughton response Linda Neophiton As Boughton response
54 WS010001/ENRMF/CONSAPPCRAL 78 Respondent Response Mrs E Nichlson Objects to WA8. Concerns over effects on landscape character, noise, odours. Concerns that site is a rural greenfield site. The increase in HGV movements on narrow country roads. Effects on ecology and recreation areas (bridleway, footpaths). Potential to attract vermin. J. M Nicholson Objects to WA8. Concerns over noise and odours. Effects on landscape character. Concerns that industrial buildings would be located on rural greenfield site. Concerns over the increase in HGV movements. Mr Gordon Noble Objects to WA8. Concerns site goes against government criteria as is not near major road or rail network that serve waste generation areas. Concerns over increase in HGV vehicles on narrow country roads. Concerns that site is a greenfield site, the effects on landscape character and recreation. Noise and odours. Concerns waste will attract vermin. Concerns fluid will leak into the water system. The site is located in close proximity to existing waste sites. Stephanie Noble Objects to WA8. Concerns that site is not located close to major roads or rail network to the major urban centres of waste generations, which goes against government guidance. Concerns over the increase in HGV movements on narrow country roads. Concerns that the site is a greenfield site that is a local amenity that is used for recreation. Effects on landscape character. Concerns over noise and odours. Potential to attract vermin. Potential for fluid to leak into water systems. Concerns that site is located close to existing waste sites. Ms Gillian Nursaw Smith Objects to WA8. Concerns over increase in traffic movements on local narrow country roads, infrastructure cannot support the increase in movements. A.J Palfreeman Objects to WA8. Concerns that site is a greenfield site, impacts on landscape character. Increase in HGV movements on minor B roads. A.J Palmer Objects to WA8. Concerns that the site is located to close to villages and houses. Concern over lorries using country lanes. Site is a greenfield site. Ms Margaret Palmer As Boughton response Mr Roy Palmer As Boughton response Mrs Dorothy Parkinson As Boughton response H Parry Objects to WA8. Concerns over odours. Increase in HGV traffic. Proposed site is a greenfield site. Mr Peter Parry Objects to WA8. Concerns that site is not located close to major urban centres. Concerns over increase in traffic. Site is located in close proximity to existing waste sites. C Patterson Objects to WA8. Concerns over the increase in HGV movement on local narrow country roads. Mrs Carol Pattison Objects to WA8. Concerns that the site is not close to any urban centres that the site will service. Concerns over air pollution, CO2 emissions and noise. Concerns over the increase in HGV movements on local rural roads. The site is a major local amenity. Concerns that industrial development would be taking place on a greenfield site and would affect the landscape character. The prevailing winds would carry air pollution over a large area. Site would effect other counties historic and natural environment by air and water pollution. Matthew Pattison Objects to WA8.
55 WS010001/ENRMF/CONSAPPCRAL 79 Respondent Response Concerns over increase in HGV movements on small country roads. Concerns over the distance vehicles will be travelling to and from the site. Mrs N Pearson As Boughton response Mrs G Penlelow Objects to WA8. Concerns that site is in rural area and the transport infrastructure cannot support increase in traffic. Mr John Penny As Boughton response P Pentelow Objects to WA8. Concerns over increase in traffic, odours and noise. Concerns that site is a greenfield area. Mr Adrian Perez As Boughton response Mr Giles Perez As Boughton response Mr Harry Perez As Boughton response Suzanna Perez As Boughton response Mr M Perkins Objects to WA8. Concerns that proposed site is located in close proximity to existing waste sites and cumulative impact needs to be considered. Mrs V Perkins Objects to WA8. Concerns over increase in HGV movements on narrow country roads as infrastructure cannot support the increase. Dilys Pettitt As Boughton response Mrs Anna Phillips Objects to WA8. Concerns over the ability of the infrastructure to support the traffic movements. Site is not located close to the sources of waste Mr Guy Phillips Wallin As Boughton response Mr Anthony Philpott As Boughton response A and S Pick Objects to WA16. Concerns that existing site has caused problems for surrounding villages. It was understood that site would be closed in 2011.Current site has not met planning conditions imposed. Mr Arthur Piggins As Boughton response Mr A Pippard Objects to WA8. Concerns those industrial processes are being located on a rural greenfield site. Area provides a major local amenity. Mrs M Pippard Objects to WA8. Concerns that site is not located close to the areas of waste generation it intended to serve. Concerns over close proximity of existing sites. Mrs Hazel Plummer Objects to WA8. Concerns that the site is greenfield. The increase in HGV movements on local narrow country roads. The site is not located close to any major urban centres. Concerns over the effects on landscape character due to construction of industrial buildings. Concerns over odours and noise. The cumulative effect of existing waste sites located near by. Concerns that the site does not meet national planning guidance. Mr T.W Plummer Objects to WA8. Concerns that there are already a number of waste sites located near by. The transport infrastructure cannot support the increase in HGV movements. Concerns that industrial processes should not be located on rural greenfield sites. Elizabeth Pond Objects to WA8.
56 WS010001/ENRMF/CONSAPPCRAL 80 Respondent Response Concerns over increase in traffic and odours. Lesley-Ann Pond Objects to WA8. Concerns that transport infrastructure cannot support increase in HGV movements. Concerns over odours. Mr Michael Pond Objects to WA8. Concerns that site is a greenfield site. Odours and the potential vermin. Effects on landscape character. Concerns over increase in traffic movements. Mr Stuart Pond Objects to WA8. Concerns over increase in HGV movements. Increase in odours and noise. Site would be better located in a more isolated and secluded area. T Powell Objects to WA8. Concern over the increase in traffic on local narrow country roads. There are existing waste sites located close to the site, one is recognised as a contributor to air pollution. The site is a greenfield site. Mr and Mrs Price Objects to WA15 and 16. Concerns over the close proximity of the sites to conservation areas and surrounding villages. Miss A.J Ranson Objects to WA8. Concerns that industry would be on a greenfield site and the increase in HGV movements on narrow roads. Mrs J Ranson Objects to WA8. Concerns that greenfield site would be used for industrial use. HGV movements on narrow roads. Concerns over pollution. Mr S.J Ranson Objects to WA8. Concerns that site would be on a greenfield site. Should expand Goosey Lodge instead. Mrs P Rapkin As Boughton response Mr R Rapkin As Boughton response D.J Rawlings Objects to WA8. Concerns over effects on landscape character. The site is on greenfield site. Concerns that site is located near existing waste sites. Goosey Lodge recognised as local air polluter. Mrs R Rawlings Objects to WA8. Concerns that site is located on a greenfield site that is a local amenity. Site is not located close to the areas it is intended to serve. Site is located close to existing waste sites. Concerns that transport infrastructure cannot support increase in traffic. Respondent (Name illegible) Objects to WA8. Concerns over impacts on ecology and that the site is unsuitable for a rural location. Respondent Objects to WA8. Concerns over increase in traffic movements on local narrow country roads, the transport infrastructure cannot support the increase. Respondent Objects to WA8. Concerns over traffic and odours. Respondent Objects to WA8. Should be located at Rookery Pit instead. Respondent Objects to WA8. Concerns over the effect on landscape character due to construction of buildings. Concerns over air pollution as other sites are located
57 WS010001/ENRMF/CONSAPPCRAL 81 Respondent Response close by. Mrs F Reynolds Objects to WA8. Concerns over increase in traffic movements on narrow country roads. Industrial processes should not be located on rural greenfield sites. Impacts on landscape character. John A Reynolds Objects to WA8. Concerns over access to the site for HGVs, as access would have to be through Chelveston village. Local roads are unclassified roads. Mrs M P Reynolds Objects to WA8. Concerns over increase in HGV movements. Site is not located close to areas of waste generation. Impacts on landscape character. Mr Alan Rhodes As Boughton response H M E Rhodes As Boughton response Mrs M Rhodes As Boughton response Mr Maxwell John Rhodes As Boughton response M Ridoutt Objects to WA8. Concerns over increase in traffic movements on infrastructure that cannot support the increase. Odours. Impacts on landscape character. W Ridoutt Objects to WA8. Concerns that transport infrastructure cannot support the increase in traffic, odours and impacts on landscape character. C.T Riggs Objects to WA8. Concerns that industrial processes are proposed for a rural greenfield site. Site provides a local amenity. Mrs R.A Riggs Objects to WA8. Concerns over the increase in HGV movements on local, narrow, country roads, transport infrastructure cannot support the increase in traffic. Ms Sharon Ringsell As Boughton response Jill Roach Supports WA2. Accepts that waste needs to be disposed off. Present operations have had little or no impact. Although site would be larger possibilities of future problems would be minimised through normal planning process. C Roberts Objects to WA8. Industrial processes should not be located on greenfield sites. Increase in traffic on narrow rural roads. Mr M Roberts Objects to WA8. Concerns that site is not located close to areas of waste generation. Industrial processes should not be located on greenfield sites. C.S Robinson As Boughton response Mr P C Robinson As Boughton response Mrs P.B Robinson As Boughton response R.H Robinson As Boughton response Ms Eileen Rouse As Boughton response Mr John B Rouse As Boughton response Annewen Rowe As Boughton response Mr John Rowe As Boughton response
58 WS010001/ENRMF/CONSAPPCRAL 82 Respondent Response Mr David Rushton Objects to WA16. Residents had understood the site was to be closed in 2011, no explanation to residents as to why this date is not being kept to. J B Rushton As Boughton response Mrs M J Rushton As Boughton response Mr Peter Rushton Objects to WA8. Concerns that site is not located close to the sources of waste. Concerns over increase in traffic on local roads. Concerns over effect on landscape character. Ms Jan Russell Objects to WA8. Concerns over increase in HGV movements on local narrow roads that cannot support the increase. Mr Malcolm Russell Objects to WA8. Concern that site is not suitable for waste treatment. Mrs Shirley Russell Objects to WA8. Site not suitable for waste treatment. Mrs N Sanders Objects to WA8. Concerns over the increase in HGV movements on narrow country roads. Impacts on the landscape character of the area. Site is not located in close proximity to the urban centres it is intended to serve. Mr S Sanders Objects to WA8. Concerns that an industrial process is proposed for a rural greenfield site. Site is a local amenity. Concerns that there are already waste sites located close by. Impacts on landscape character. E.A Savage Objects to WA8. Concerns that industrial process being proposed for rural greenfield site (site was greenfield before airfield). Concerns over increase in traffic and odours. J, L and P Savage Objects to WA8. Concerns over effects on landscape character. Industrial processes on agricultural land. Concerns over increased HGV movements on already congested roads. Concerns that other waste plants are already located close by. Site should be closer to towns and the railway to be more efficient. P Savage Objects to WA8. Concerns that site is a greenfield site (site was greenfield before the airfield). Proposed site is located close to existing waste sites. Gillian Scotney As Boughton response Mr Paul Scotney As Boughton response Harriet Scott As Boughton response Mrs Marlon Scott As Boughton response Mr Peter Scott As Boughton response Tess Scott As Boughton response Angelia Seelig As Boughton response Carlene Seelig As Boughton response I.M Seelig As Boughton response
59 WS010001/ENRMF/CONSAPPCRAL 83 Respondent Response Mr M.P Seelig As Boughton response P R Seelig As Boughton response Ms Sarah Seelig As Boughton response Mr Stephen Seelig As Boughton response Mrs Theresa Seeling As Boughton response R L Sellig As Boughton response Rosamund Sheppard Objects to WA8. Concerns that a greenfield site is being considered for industrial development. Site is located on high ground so will be visible from long distances. Concerns that waste will be brought long distanced from major urban centres. Transport Infrastructure could not support HGV movements. Concerns over the cumulative effect of waste sites already in the area. Prevailing winds would carry the odours into Hargrave village. Mr Frederick Shilham Objects to WA8. Concerns over increase in traffic movements. Sites should be located in brownfield sites. Impacts on landscape character and a local amenity. Emissions. Mrs M Shilham Objects to WA8. Concerns over increase in traffic on local narrow country roads. Concerns that industrial processes are proposed for a rural greenfield site. Concern over the cumulative effect of the site along with existing waste sites located near by. Mr Roy Shutz Objects to WA8. Concerns that industrial processes are proposed for a rural greenfield site. Concerns that transport infrastructure cannot support the increase in HGV movements. C.L Silk Objects to WA8. Concerns that site is a greenfield site, and that transport infrastructure cannot support the increase in traffic movements. Ms Gemma Silk Objects to WA8. Concerns over increase in traffic and noise in a rural area. Odours. Infrastructure cannot support increase in traffic. Site should be considered a greenfield site. R.C Silk Objects to WA8. Concerns that local infrastructure cannot support increase in traffic movements. Noise. Site should be considered a greenfield site. Mr Roger Skinner As Boughton response K Smart Objects to WA8. Concerns that site is a greenfield site, site should be located closer to areas that generate the waste. Mrs S.R Smart Objects to WA8. Concerns that site is not located close to the urban centres it is intended to serve. Concerns over increase in HGV movements on local country roads. Site is a greenfield site.
60 WS010001/ENRMF/CONSAPPCRAL 84 Respondent Response Mr and Mrs KM and JG Smid Does not support site selection. Objects to WA15 and 16. WA16: Concerns that site would create a disproportionately high concentration of hazardous material in one location. Concerns that operators have not kept up safety standards. Concerns over stability of the Lincolnshire Limestone under the site and the potential risk of contamination water courses. Concerns that site is crossed by gas, oil and water pipes. Should be looking to the long term and encouraging development of more sustainable strategies. J M Smith As Boughton response Mrs K. J Smith Objects to WA8. Concerns that the site is located on greenbelt land, impacts on recreation (footpaths). Effects on landscape character, the effects of odours and noise. Transport infrastructure is unsuitable. Michael Smith Objects to WA8. Concerns over the possible ground and atmospheric pollution. Concerns over the impact on the historic airfield. The impact on recreation. The site does not have adequate water supply or drainage. Concerns over the increase in HGV movements. Mr Neil Smith As Boughton response Ms Stephanie Smith As Boughton response Mr and Mrs M Smyth Objects to WA8. Concerns that proposed site is located close to existing waste sites and the potential cumulative effect. A Soteriou As Boughton response Kay Soteriou As Boughton response C J T Spencer Objects to WA8. Concerns over potential for spillage into water courses. Vermin. Odours. Transport infrastructure cannot support increase in traffic. Impacts on landscape character. Mrs J S Spencer Objects to WA8. Concern over potential for spillage in water courses. Vermin. Odours. Local transport infrastructure cannot support increase in traffic. Impacts on landscape character. C Spurdin Objects to WA8. Concerns that site is not located close to the centres of waste it is intended to serve. Janice Squires As Boughton response Mr John Squires As Boughton response Mr Andrew Stables As Boughton response Mr Graham Stacey As Boughton response Mrs J Stacey As Boughton response Mrs J Stedman Objects to WA8. Supports Preserve. J.D Steele Objects to WA8. Concerns that site is not located near the urban centres of waste generation. Concerns that site is a greenfield site. Located in close proximity to existing waste sites. Conflicts with government policy. Mr W Steele Objects to WA8.
61 WS010001/ENRMF/CONSAPPCRAL 85 Respondent Response Concerns that site is not located near the areas where the waste is produced and requires long transport distances. Concerns that the village roads are to narrow and that a greenfield site will be taken over by industrial processes. Concerns that similar sites are already located near by. Mrs J Stephenson Objects to WA8. Concerns that site is not located in close proximity to areas of waste generation. Industrial processes should not be located on a rural greenfield site. Mr M Stephenson Objects to WA8. Concerns over the increase in HGV movements on local narrow country roads. The site is located in close proximity to existing waste sites. Mr M.R Stephenson Objects to WA8. Government guidance states sites should be close to urban locations, the proposed site is some miles from towns. Concerns over increase in HGV movements down narrow roads. Site is a greenfield site, used for recreation, should not locate industrial processes on these sites. Odours, noise and vibrations. Potential to attract vermin. Effects on landscape character, ecology and historic environment. Proposed site is located in close proximity to existing waste sites. Concerns over leaks of substances into surrounding land. Jo Stevens As Boughton response Mr Andrew Stevenson Objects to WA8. Concerns over increase in traffic on local narrow country roads, the transport infrastructure cannot support the increase. C Steward Objects to WA8. Concerns over air pollution. Concerns that transport infrastructure cannot support increase in HGV movements. Mr Andrew Stirling As Boughton response Patricia Stirling As Boughton response J.N.P Stuart Object to WA8. Concerns that transport infrastructure cannot support increase in HGV movements. Concerns over odours. Concerns that site is not located close to sources of waste. Mrs K.G Sturgess As Boughton response Shirley Suler As Boughton response Mr David Suter As Boughton response Mr Robert Swannell As Boughton response P. K Symes Objects to WA8. Concerns over the cumulative effects of the other waste sites located close to the proposed site (Goosey Lodge, Twinwoods and Westwood) Industrial processes should not be located on rural greenfield sites. Mrs S. A Symes Objects to WA8. Site is not close to any of the major urban areas that it is intended to serve. Industrial processes should not be located on rural greenfield sites. Concerns over the increase in HGV movements on local narrow country roads. Concerns over effect on landscape character due to construction of industrial buildings. Concerns over the cumulative effect of the waste sites already located near by. G Tame Objects to WA8. Concerns over the increase in traffic on a deteriorating road network. Concerns over the distance of the site from the area to be serviced. Concerns over the use of a historical site. Mr P. J Tame Objects to WA8.
62 WS010001/ENRMF/CONSAPPCRAL 86 Respondent Response Misuse of an historical greenfield site, increased HGV activity on poor road network, increased noise, emissions, vibration and odours, visual intrusion on landscape, increase in disease and vermin. Mrs June Taray As Boughton response Gayle Taylor Objects to WA8. Concerns that site is not located close to the urban areas it is intended to serve. Concerns over increase in HGV movements on local narrow country roads. Concerns over the effect on landscape character due to construction of industrial buildings. Concerns that there are existing waste sites already located in close proximity. Concerns that transport assessments were carried out at the entrance of the site and not the routes proposed for access. Survey does not seem to have considered non- commercial traffic. Mr John Taylor As Boughton response Mr Mark Taylor As Boughton response Ms Nicola Taylor Objects to WA8 Concerns over odours. Transport infrastructure cannot support increase in traffic. Concerns over industry being placed in rural areas. Mr Phil Taylor Objects to WA8 Concerns that site is not located close to urban centres that it is intended to serve, which does not fit with government guidance. Concerns over the increase in HGV movements on local narrow country roads. Concerns over the effect on landscape character due to construction of industrial buildings. Site is greenbelt so does not fit with government guidance. Concerns over the cumulative effect of the existing waste sites located in close proximity. Concerns that transport assessments were carried out at the entrance of the site and not the routes proposed for access. Survey does not seem to have considered non- commercial traffic. S Taylor Objects to WA8 Concerns over noise and odours. Impacts on landscape character. Increase in HGV movements on narrow country roads. Site does not meet government guidelines of being close to the areas of waste generation. Samantha Taylor As Boughton response Mr Simon Tebbatt As Boughton response Ms Christina Tebbott As Boughton response Mrs G M Tebbutt As Boughton response Mr S.J Tebbutt As Boughton response Ms Felicity Thistlethwaite Objects to WA16 Concerns that site is located next to existing hazardous waste site and cross contamination of materials could occur. Potential for pollution of ground and surface water, and surrounding soils. Concerns that site is located close to sensitive receptor (Ancient woodland, SSSI and pond that house great crested newts). Mrs Lynne Thomas-Mead Objects to WA8 Concerns over impacts on landscape character due to construction of industrial buildings. Concerns over cumulative effect of the existing waste sites located near by. L.A Thompson As Boughton response Mrs Linda Thompson As Boughton response Mr Peter Thompson As Boughton response Mr Walter Thompson As Boughton response M.A Thorncroft Objects to WA8
63 WS010001/ENRMF/CONSAPPCRAL 87 Respondent Response Concerns over increase in HGV movements on local narrow country roads. Concern that infrastructure cannot support the increase. Concerns that site is in a rural greenfield area. Impacts on landscape character due to construction of industry infrastructure. R W Thorncroft Objects to WA8 Concerns over increase in traffic movements. Noise and odours. Impacts on landscape character. Mrs J Timkey Objects to WA8 Concerns over the HGV traffic on local country roads. The possible smell, noise and light pollution. AD is an unproven technology. The effect on the rural landscape character and impact on wildlife. The site will increase CO2 emissions and is over development, Mr J Timkry Objects to WA8 Concerns over the HGV traffic on local country roads. The possible smell, noise and light pollution. AD is an unproven technology. The effect on the rural landscape character and impact on wildlife. The site will increase CO2 emissions and is over development, G J Tomlins As Boughton response S & G J Tomlins As Boughton response Ms Caroline Trott As Boughton response Rev Stephen Trott As Boughton response Mr and Mrs Trussler Objects to WA8 Concerns that lorry drivers will take shortcuts down unsuitable roads within the village. Mrs C.D Turner Objects to WA8 Concerns that site is a greenfield site which is contrary to government guidance (PPS22, PPG2, PPS10, and PPS7). Concerns that transport infrastructure cannot support increase in HGV movements. Concerns over health and safety risk as no data is available. Mr C.D Turner Objects to WA8 Concerns that site is a greenfield site which is contrary to government guidance (PPS22, PPG2, PPS10, and PPS7). Concerns that transport infrastructure cannot support increase in HGV movements. Concerns over health and safety risk as no data is available. D L Turner As Boughton response Mrs Inez Turner As Boughton response Mr A.J Verney Objects to WA8 Concerns that site is not located close to the areas of waste generation. Increase in traffic movements on country roads. Industrial processes should not be located on greenfield sites. Impacts on landscape character. Site is located in close proximity to existing waste sites. Mrs A Vewes As Boughton response Audrey Walker As Boughton response Margaret Walsh Objects to WA8 Concerns over the increase in traffic. Site not suitable for a rural area. Concerns over possible pollution. P Walsh Objects to WA8 Concerns over the increase in traffic and that the site is too rural for this development. Mrs J Walton As Boughton response Mr John Walton As Boughton response Mrs Emma Wantling Objects to WA8 Concerns that site is located on a rural greenfield site. The site is not located close to the major urban centres that it is intended to serve.
64 WS010001/ENRMF/CONSAPPCRAL 88 Respondent Response Concerns over the effects of landscape character. Mr Simon Wantling Objects to WA8 Concerns over the effects on landscape character due to the construction of industrial buildings. Concerns that site is on a rural greenfield site. Claire Ward Objects to WA8 Concerns over increase in HGV movements on local narrow country roads. The transport infrastructure is inappropriate. Graham Ward Objects to WA8 Concerns over the effects on landscape character due to the construction of industrial infrastructure. Mr Gary Warne Objects to WA8 Concerns over impacts on landscape character. Carla Watson As Boughton response Derrick Watson As Boughton response Jackie Watson As Boughton response Christine Weatherley As Boughton response Mr Richard Weatherley As Boughton response C Welbourn Objects to WA8 Concerns that site is not located close to the urban areas it is intended to serve. Concerns over increase in traffic movements. Mrs B.H.M West Objects to WA8 Concerns that Netwon Road is already busy without increase in HGVs. Concerns that the site would encourage more development in the area. Industrial processes should not be located on rural greenfield site. Site is not located near areas it is to serve. Mr David Whalley As Boughton response Margaret Wheeler As Boughton response Ms J.A Whitehead Objects to WA8 Concerns that site is a greenfield site, the transport infrastructure cannot support increase in HGV movements. Site is not located near areas that it is intended to serve. Concerns over effects on landscape character. Existing waste sites are already located close to the proposed site, cumulative impacts need to be considered. Site is a local amenity. Mr N.P Whitehead Objects to WA8 Concerns that site is a greenfield site, the transport infrastructure cannot support increase in HGV movements. Site is not located near areas that it is intended to serve. Concerns over effects on landscape character. Existing waste sites are already located close to the proposed site. Site is a local amenity. Mrs Carol Wilkinson As Boughton response Mrs J.A Wilkinson Objects to WA8 Concerns that transport infrastructure cannot support increase in traffic due to increases HGV movements on narrow country roads. Mr Mark Wilkinson As Boughton response Dr P.S Wilkinson Objects to WA8 Concerns over the effects on landscape character due to construction of industrial buildings. Dr Royston William As Boughton response
65 WS010001/ENRMF/CONSAPPCRAL 89 Respondent Response E.K Williams As Boughton response Mrs H S Williams As Boughton response Mrs Jane Williams As Boughton response Mr Russell Wilson As Boughton response Mrs Susan Wilson As Boughton response T Wilson Objects to WA8 Concerns over effects on landscape character due to construction of industrial buildings. Concerns that site is located close to existing waste sites. B Wingfield Objects to WA8 Concerns over impact on local traffic, effects on landscape character. Odours and noise. Potential to attract vermin. Mrs C.S Wingfield Objects to WA8 Concerns that industrial processes is being located on rural greenfield sites. The site provides a local amenity. P Wingfield Objects to WA8 Concerns over increase in HGV movements on transport infrastructure that cannot support the increase. Concerns over air quality. S Wingfield Objects to WA8 Concerns over increase in traffic movements. Impacts on ecology. Impacts on landscape character. Odours. Impacts on recreation (footpaths and bridleways) Mr Mark Withers Objects to WA8 Concerns over increase in HGV movements. Noise and vermin. Concerns over future expansion of the site. Mrs M Wlodarczyk Objects to WA8 Concerns over increase in traffic on country roads. Effects on landscape character and ecology. Potential noise, vibrations and odours. Z Wlodarczyk Objects to WA8 Concerns over potential odours and noise. Effects on ecology. Effects on landscape character. Concerns over the increase in HGV movements on local roads. M Wooding Objects to WA8 Concerns that site is a greenfield site, it is not located close to the major contributors of waste. Concerns over the effect on landscape character, that there is no transport plan in place. Concerns that there are already a number of waste sites in the area. R Wooding Objects to WA8 Concerns that site is a greenfield site, it is not located close to major contributors of waste. Concerns over the visual impact and possible pollution. Concerns over the cumulative effect of sites already in the area. Concerns that there is no real traffic plan in place. T S Woolton As Boughton response Mrs S Wootton As Boughton response Mr A. E Wright Objects to WA8 Concerns that industrial processes should not be located on a rural greenfield site. The airfield is a major local amenity. J Wright As Boughton response John Wright Objects to WA8 Concerns over increase in HGV movements on local minor roads, odours and that the site is located on a greenbelt. Mr John Wright Objects to WA8
66 WS010001/ENRMF/CONSAPPCRAL 90 Respondent Response Concerns over increase in traffic, noise and odours. Terri Wright As Boughton response Ms Jill Yelding As Boughton response Mr Richard Yelding As Boughton response Ms Z Yerrell Objects to WA8 Concerns over increase in HGV movements, noise and vermin. Concerns over future expansion of the site. B.J Young Objects to WA8 Concerns that site is located in close proximity to existing waste site and the cumulative effect of this. Increase in HGV movements on country roads. J.E Young Objects to WA8 Concerns that site is located in close proximity to existing waste sites and the cumulative effect of this. Increase in movements on country roads. Mr E Yuzbasioglu As Boughton response Mrs G Yuzbasioglu As Boughton response
Is the proposed monitoring framework appropriate and relevant in relation to the emerging Locations for Waste Development policies?
Respondent Response Chelveston Renewable Energy Ltd Yes Daventry District Council Yes Deanshanger Parish Council Yes Northampton Borough Council Monitoring framework is appropriate and relevant in relation to the emerging locations for waste policies. Raunds Town Council No Thornby Parish Meeting Yes Boughton Response No certainty that adequate resources will be available for effective monitoring. Boughton Residents Action Group As Boughton response Beryl Addington As Boughton response Mr John Allin As Boughton response Mr Neil Amos As Boughton response H.E Anderson As Boughton response J Anderson As Boughton response Mrs Maureen Anderson As Boughton response R G Anderson As Boughton response E.M Ashby As Boughton response
67 WS010001/ENRMF/CONSAPPCRAL 91 Respondent Response R V Ashby As Boughton response Amanda Askew As Boughton response Mr Jeremy Askew As Boughton response Michele Austin As Boughton response Mr Phil Austin As Boughton response Mr Jeffrey Barringer As Boughton response Judith Barringor As Boughton response Ms Elizabeth Barron As Boughton response Rachel E Barron As Boughton response Mr Richard W Barron As Boughton response Ruth Charlotte Barron As Boughton response Dr J.H Bason As Boughton response Mrs S Bason As Boughton response Michelle Batchlor As Boughton response Ms Denise Bates As Boughton response Barry Bayes As Boughton response Sally Bernham As Boughton response A Bernhay As Boughton response Mr William J Berry As Boughton response Mr Kenneth Botwright As Boughton response Valerie Botwright As Boughton response Ms M.E Boullemier As Boughton response Mr Tony Boullemier As Boughton response Mrs Inez Dorothy Butler As Boughton response Mr John Butler As Boughton response Mr Kevin Callis As Boughton response N Callis As Boughton response Ms Brenda Callow As Boughton response Haurice Callow As Boughton response Andrea Carnel As Boughton response R L Cawthra As Boughton response Naomi Cebula As Boughton response E D Chapman As Boughton response Dr H M Coghill As Boughton response Mrs E Colin-York As Boughton response Mrs M.W Collier As Boughton response
68 WS010001/ENRMF/CONSAPPCRAL 92 Respondent Response Mr S Collier As Boughton response E. Compton As Boughton response T.L Compton As Boughton response Mrs Hazel Cooper As Boughton response J A Cooper As Boughton response Mr Ronald Cooper As Boughton response Ms Elaine Copperwaite As Boughton response Mr Peter James Courier As Boughton response Mr Paul Cox As Boughton response Mrs B Critchell As Boughton response Mr Harry Critchell As Boughton response Mr Martin Cullen As Boughton response Mrs Valerie Cullen As Boughton response Mr L Curtis As Boughton response Mr Richard Daniels As Boughton response Sandra Daniels As Boughton response Diana Darlington As Boughton response Mr Malcolm Graham Darlington As Boughton response Mrs B.M. Davenport As Boughton response R N Davenport As Boughton response I Davies As Boughton response Ann Davison As Boughton response Mr Russell Davison As Boughton response T I Dayigs As Boughton response M.B Deady As Boughton response Arabelle Dean As Boughton response Mr Michael John Dean As Boughton response Mr David Deane As Boughton response Mrs Delia Deane As Boughton response Ms Fiona Dickenson As Boughton response Mr R P Dickenson As Boughton response Mr Edward Digby As Boughton response Melanie Digby As Boughton response Mr Richard Digby As Boughton response Mr William Digby As Boughton response Miss L Dinonpoint As Boughton response
69 WS010001/ENRMF/CONSAPPCRAL 93 Respondent Response Mr Joe Docker As Boughton response Mr Dan Dorgan As Boughton response Pam Dorgan As Boughton response Joanne Downie As Boughton response Mr Jon Downie As Boughton response Duffy As Boughton response Charlotte Duffy As Boughton response J B Duffy As Boughton response Rebecca Duffy As Boughton response Sophie Duffy As Boughton response Jean Dunn As Boughton response Mrs Lynda Dunne As Boughton response Mr Noel Dunne As Boughton response B Dunstone As Boughton response Mrs Carol Dunstone As Boughton response Sheldon Fenning As Boughton response Simone Fenning As Boughton response Ms Catherine Field As Boughton response Mr Robert Field As Boughton response A. Fleming As Boughton response Ms Karen Fletcher As Boughton response Graham Fogden As Boughton response Giuseppe Forgione As Boughton response Louise Forgione As Boughton response Mr D Foster As Boughton response J Foster As Boughton response Mr A Fox As Boughton response Mrs I Fox As Boughton response Mr Mark Gaterell As Boughton response Stephanie Gaterell As Boughton response Mrs H. Gaudin As Boughton response Mr M Gavdin As Boughton response Ms Jill Gist As Boughton response Mr Robert Gist As Boughton response Carolyn Glanney As Boughton response Mr A.J.S Gledhill As Boughton response
70 WS010001/ENRMF/CONSAPPCRAL 94 Respondent Response Mr L.J Gledhill As Boughton response A.P. Goddard As Boughton response Gillian H Gogden As Boughton response Mrs Helen Graft As Boughton response Lesley Gray As Boughton response Mr Mark Gray As Boughton response Mr Kevin Greatorex As Boughton response Ms Sue Greatorex As Boughton response M Greener As Boughton response R Greener As Boughton response Mr Stuart Greenslade As Boughton response Victoria Greenslade As Boughton response Maureen Haddon As Boughton response Mr Peter Haddon As Boughton response Mrs C Handshaw As Boughton response Mr Chris Handshaw As Boughton response R R Hardwick As Boughton response Mr J.T Harris As Boughton response Mrs Joyce Harris As Boughton response Mrs K.N Harris As Boughton response Mr David James Harrop As Boughton response Mrs Dorothy Harrop As Boughton response Mr John Hewerson As Boughton response Sara Hewertson As Boughton response Mr Thomas Hewitt As Boughton response Katie Higgs As Boughton response Mrs Daphne Higham As Boughton response Mrs Shirley Hillier As Boughton response Mr David Houriham As Boughton response Mrs Sonja Hourihan As Boughton response Anne Hughes As Boughton response S.R Hughes As Boughton response Mr I Humby As Boughton response Mr Matthew Hunt As Boughton response Oonagh Hunt As Boughton response Mr Brian Hurren As Boughton response
71 WS010001/ENRMF/CONSAPPCRAL 95 Respondent Response Margaret Hurren As Boughton response June Insall As Boughton response R Insall As Boughton response Mrs O.M James As Boughton response Ms Ann Jones As Boughton response Ms Catherine Jones As Boughton response Ms Christine Jones As Boughton response Mr Derek Jones As Boughton response Ms Gillian Kingston As Boughton response Mr Jonathan Kingston As Boughton response Mr Neil Kitchener As Boughton response Mr Richard Kitchener As Boughton response Mrs Val Kitchener As Boughton response Mrs D Knitt As Boughton response Mr J.A Knitt As Boughton response Ms Rita Lantsbery As Boughton response Mr Andrew Laurie As Boughton response Glenda Laurie As Boughton response Alastair Lawrie As Boughton response Catherine Lawrie As Boughton response Mrs C Lea As Boughton response Mr M J Lea As Boughton response R Lee As Boughton response S Lee As Boughton response E Legrand As Boughton response Ms Rachel Legrand As Boughton response S A Lett As Boughton response Mr Peter Lindsley As Boughton response H C Lonell As Boughton response Ms Sylvia Ellen Lovell As Boughton response Mrs J Mabbutt As Boughton response Mr P Mabbutt As Boughton response Oliver Mackaned As Boughton response Charlotte Mackaness As Boughton response Mrs Eleanor Maltby As Boughton response Mr Terence Maltby As Boughton response Joan Mason As Boughton response
72 WS010001/ENRMF/CONSAPPCRAL 96 Respondent Response Mr Philip Mason As Boughton response Ms Melanie McCall No Anwen McDonnell As Boughton response Mr Daniel McDonnell As Boughton response Rosemary McDonnell As Boughton response W McDonnell As Boughton response Joanne McGowan As Boughton response Ms Mary McGowan As Boughton response Mr Thomas McGowan As Boughton response Mr Thomas McGowan As Boughton response Mrs Imelda McQuillan As Boughton response Dr W.J McQuillan As Boughton response Mr Derek Millard As Boughton response Ms Anna Moore As Boughton response Mr Frank Moore As Boughton response Janet T Morris As Boughton response Mr Neville Morris As Boughton response Ms Ann Murphy As Boughton response Mrs S Mynolt As Boughton response Mr R.E Mynott As Boughton response Mr Rish Napier As Boughton response Sue Napier As Boughton response Mr George Neophiton As Boughton response Linda Neophiton As Boughton response Ms Margaret Palmer As Boughton response Mr Roy Palmer As Boughton response Mrs Dorothy Parkinson As Boughton response Mrs N Pearson As Boughton response Mr John Penny As Boughton response Mr Adrian Perez As Boughton response Mr Giles Perez As Boughton response Mr Harry Perez As Boughton response Suzanna Perez As Boughton response Dilys Pettitt As Boughton response Mr Guy Phillips Wallin As Boughton response Mr Anthony Philpott As Boughton response
73 WS010001/ENRMF/CONSAPPCRAL 97 Respondent Response Mr Arthur Piggins As Boughton response Mrs P Rapkin As Boughton response Mr R Rapkin As Boughton response Mr Alan Rhodes As Boughton response H M E Rhodes As Boughton response Mrs M Rhodes As Boughton response Mr Maxwell John Rhodes As Boughton response Ms Sharon Ringsell As Boughton response C.S Robinson As Boughton response Mr P C Robinson As Boughton response Mrs P.B Robinson As Boughton response R.H Robinson As Boughton response Ms Eileen Rouse As Boughton response Mr John B Rouse As Boughton response Annewen Rowe As Boughton response Mr John Rowe As Boughton response J B Rushton As Boughton response Mrs M J Rushton As Boughton response Gillian Scotney As Boughton response Mr Paul Scotney As Boughton response Harriet Scott As Boughton response Mrs Marlon Scott As Boughton response Mr Peter Scott As Boughton response Tess Scott As Boughton response Angelia Seelig As Boughton response Carlene Seelig As Boughton response I.M Seelig As Boughton response Mr M.P Seelig As Boughton response P R Seelig As Boughton response Ms Sarah Seelig As Boughton response Mr Stephen Seelig As Boughton response Mrs Theresa Seeling As Boughton response R L Sellig As Boughton response Mr Roger Skinner As Boughton response J M Smith As Boughton response Mr Neil Smith As Boughton response Ms Stephanie Smith As Boughton response
74 WS010001/ENRMF/CONSAPPCRAL 98 Respondent Response A Soteriou As Boughton response Kay Soteriou As Boughton response Janice Squires As Boughton response Mr John Squires As Boughton response Mr Andrew Stables As Boughton response Mr Graham Stacey As Boughton response Mrs J Stacey As Boughton response Jo Stevens As Boughton response Mr Andrew Stirling As Boughton response Patricia Stirling As Boughton response Mrs K.G Sturgess As Boughton response Shirley Suler As Boughton response Mr David Suter As Boughton response Mr Robert Swannell As Boughton response Mrs June Taray As Boughton response Mr John Taylor As Boughton response Mr Mark Taylor As Boughton response Samantha Taylor As Boughton response Mr Simon Tebbatt As Boughton response Ms Christina Tebbott As Boughton response Mrs G M Tebbutt As Boughton response Mr S.J Tebbutt As Boughton response L.A Thompson As Boughton response Mrs Linda Thompson As Boughton response Mr Peter Thompson As Boughton response Mr Walter Thompson As Boughton response G J Tomlins As Boughton response S & G J Tomlins As Boughton response Ms Caroline Trott As Boughton response Rev Stephen Trott As Boughton response D L Turner As Boughton response Mrs Inez Turner As Boughton response Katrina Varnsverry As Boughton response Michael John Varnsverry As Boughton response Mrs A Vewes As Boughton response Audrey Walker As Boughton response Mrs J Walton As Boughton response
75 WS010001/ENRMF/CONSAPPCRAL 99 Respondent Response Mr John Walton As Boughton response Carla Watson As Boughton response Derrick Watson As Boughton response Jackie Watson As Boughton response Christine Weatherley As Boughton response Mr Richard Weatherley As Boughton response Mr David Whalley As Boughton response Margaret Wheeler As Boughton response Mrs Carol Wilkinson As Boughton response Mr Mark Wilkinson As Boughton response Dr Royston William As Boughton response E.K Williams As Boughton response Mrs H S Williams As Boughton response Mrs Jane Williams As Boughton response Mr Russell Wilson As Boughton response Mrs Susan Wilson As Boughton response T S Woolton As Boughton response Mrs S Wootton As Boughton response J Wright As Boughton response Terri Wright As Boughton response Ms Jill Yelding As Boughton response Mr Richard Yelding As Boughton response Mr E Yuzbasioglu As Boughton response Mrs G Yuzbasioglu As Boughton response
Do you have any other comments regarding the preferred options for the Locations for Waste Development DPD?
Respondent Response Barton Plant When looking at the disposal of inert waste need to consider many factors. Active minerals sites are only located in certain parts of the county, large areas of the county are more than 10miles from such sites. Implementation if the sustainable approach to managing waste means that heavy, low value inert waste must travel on the roads the minimum distance possible. It is essential that a geographical assessment is carried out of the source of inert waste arising and of potential destinations to establish whether there is an adequate network of facilities across the county to meet the needs of development sites. In promoting the policy approach of limiting inert waste disposal at active minerals sites, the council is relying on statements made by the minerals industry; this is a smoke screen and if minerals operators were forced to catch up on restoration requirements inert waste would become available.
76 WS010001/ENRMF/CONSAPPCRAL 100 Respondent Response The council should look at claims that minerals sites need inert waste for restoration. The need for a geographical spread of inert waste should be taken in to account when considering proposals from the mineral industry through the planning application process. Some of the mineral sites could be restored at a lower level, so that a better geographical spread of inert sites across the county can be achieved. Bovis Homes Ltd and Support the removal of the extension to the landfill site that was outlined at the Issues and Options stage. Would like to explore Wellingborough East Landowners opportunities for the facility to contribute to the sustainable development proposed at Stanton Cross. Brixworth Parish Council Supports the removal of Brixworth site. Bugbrooke Parish Council Supports the removal of the site on Land east of Junction 16, M1. Burton Latimer Town Council The options do not appear to take into account the geographical location of developments up to 2021 in the Kettering area. The locations should have the following criteria as a guiding principle. Easy access to road for the majority of households. Be of sufficient capacity to cater for householders and small businesses. Be appointed in the interests of the user rather than the operator. Be open so that employed users can gain easy access. Allow whole range of waste to be disposed of at single site. Consider site adjacent to A14 junctions 8 and10. Vans should be allowed at all times. Principles should encourage use rather than fly tipping. Campaign to Protect Rural England In view of the damaging affect of Methane compared to CO2 should we not be advocating high temperature incineration. The collection of various categories of waste is a good idea but we fear the separation and storage for people in terraced houses and flats is a problem. If collection is not made easier, or is taxed, this will encourage fly tipping which is an even greater cost. Corby Borough Council Document is disappointing as virtually all the proposals are static easy options. The plan seeks to expand on existing sites or respond to operator proposals rather than bringing forward pro-active proposals to meet challenges of climate change or to capitalise on new and emerging technologies. It is also important to highlight the problems with the existing management of current facilities. Daventry District Council Support the exclusion of Brixworth Landfill site, The Grain Store, Nobottle and East Lodge, Nobottle. Daventry Town Council Concerns over suggestions of the introduction of a food waste collection in Daventry, as it would mean the introduction of another bin. Concerns that the district council given its position at the forefront of waste recycling, might seek to provide one of the compost plants in Daventry. East Northamptonshire Council The concentration of proposals for waste management facilities in the northern part of the East Northamptonshire is not appropriate. A preference towards extending existing sites will exacerbate the situation in this already sensitive location. An approach should be considered where locations are identified near to the source of the material. Ensign Group Ltd The identification of sites for waste related development should be based upon the spatial strategy already established in the MKSM SRS, as this directs significant elements of development to Northampton and the linked growth towns of Corby/Kettering/Wellingborough. In light of the clear spatial framework, would expect the Core Strategy DPD to promote a policy approach to waste related development that reflects the wider spatial policy framework. In such circumstances the strategy should direct sites intended to fulfil a sub-regional role to locations well-related to the strategic highway network in the central part of Northamptonshire. These routes represent the primary structural transportation elements in the Northamptonshire element of the sub region and should be the focus for the accommodation of new waste management facilities expected to fulfil a sub regional role. Hallam Land Management The decision not to allow the expansion of the Sidegate Lane site on environmental grounds is supported. It is noted in the technical appraisal which identifies various impacts including traffic, archaeology and air bourne contaminates from the landfill. Highways Agency The transport assessments carried out on each site appears to have been considered in isolation, the cumulative effect needs to be considered. Further detailed work should be carried out as part of the front loading. JL &D Robinson and D Sheppard It is made clear in the document that inert waste will only be permitted for disposal at active mineral sites, for use in restoration.
77 WS010001/ENRMF/CONSAPPCRAL 101 Respondent Response Currently there are no active minerals sites in the Daventry area, there for the waste arisings from the proposed major development around Daventry will have to be transported long distances to sites either out of the county or in the Nene Valley. Long Buckby Parish Council Further consideration would be needed should sites be removed and new sites need to be identified. Mid Northamptonshire Parishes Question the siting of waste facilities at junction 15 and possibly 16 of the M1 motorway due to the plans focus on the urban spine of Northamptonshire including Northampton, Wellingborough, Rushden, Kettering and Corby, as all waste materials and minerals would have to be transported by road across Northampton Town which goes against the proximity needs of the plan. Natural England Identification of preferred waste management sites: Support the development of facilities that enable significant increases in the reuse and recycling of waste, in suitable locations where impacts on the wider environment are of a positive nature. Peter Bennie Ltd The plan should have considered all sites put forward for the widest possible range of uses, especially as the document acknowledges that additional facilities will be required to meet the annual waste management capacity. The plan fails test 7 and 9; it does not provide for a best fit of site allocations to enable the industry to develop facilities to ensure that the county can achieve its objective of delivering a strategic, urban focussed flexible waste management network with particular encouragement of integrated waste recovery and treatment facilities. The approach is too restrictive thus preventing the industry from reacting to changing circumstances. South Northamptonshire District Mention is made of national and regional facilities without detailed examination of the issues involved; more information should be Council included in the framework on these facilities and what they might involve. There should be discussion on where plants should or should not be located and the criteria for deciding. Criteria should be included to ensure that such plants are not located near residential areas. Sites for these larger facilities should be located nearer the centre of the urban spine according to the proximity principle. As the preferred options stands these facilities would most probably be located in the urban areas or rural brownfield sites. Tighter criteria should be potential sites in or near to urban areas. For larger sites, especially those with airborne emissions, tighter environmental criteria should be applied. Thames Water Plc Supports the general objective of waste reduction and sustainable management, however in relation to our role as a statutory sewerage undertaker, it should be recognised that as population growth increases, so does the amount of sewage sludge, which is the waste product of the sewage treatment process. TWUL has to respond to any increase in the amount of sewage sludge produced as a consequence of the increase in production of wastewater from new development; this may require upgrades to existing infrastructure or the provision of new infrastructure. Increase in population and more stringent effluent quality standards, will result in greater volumes of sludge, which will require a larger land bank to recycle to. This is likely to necessitate the transportation of sludge over greater distances, often by road to treatment centres. Plans and strategies should continue to recognise the importance of providing an adequate network of waste water treatment facilities. Plans and strategies should recognise the issues surrounding the treatment, recycling and disposal of wastewater sludge. They should support a network of treatment and disposal facilities. The precise size and mix of these facilities will vary over time with changes in the quantity produced and availability of recycling and disposal routes. Response from residents of Separation distance should be increased to 1000m. W7 Preliminary treatment facilities: an additional paragraph should be added Boughton requiring in-vessel composting facilities should not be located within 1000m of residential areas. Boughton Residents Action Group As Boughton response Beryl Addington As Boughton response Cllr Tim Allebone Endorsing of MBT is at odds with district councils. Need to be aware of and receptive to newer technologies that are emerging. Need to keep an open mind on possible new solution to the treatment of waste.
78 WS010001/ENRMF/CONSAPPCRAL 102 Respondent Response Mr John Allin As Boughton response Mr Neil Amos As Boughton response H.E Anderson As Boughton response J Anderson As Boughton response Mrs Maureen Anderson As Boughton response R G Anderson As Boughton response E.M Ashby As Boughton response R V Ashby As Boughton response Amanda Askew As Boughton response Mr Jeremy Askew As Boughton response Michele Austin As Boughton response Mr Phil Austin As Boughton response Mr Jeffrey Barringer As Boughton response Judith Barringor As Boughton response Ms Elizabeth Barron As Boughton response Rachel E Barron As Boughton response Mr Richard W Barron As Boughton response Ruth Charlotte Barron As Boughton response Dr J.H Bason As Boughton response Mrs S Bason As Boughton response Michelle Batchlor As Boughton response Ms Denise Bates As Boughton response Barry Bayes As Boughton response Sally Bernham As Boughton response A Bernhay As Boughton response Mr William J Berry As Boughton response Mr Kenneth Botwright As Boughton response Valerie Botwright As Boughton response Ms M.E Boullemier As Boughton response Mr Tony Boullemier As Boughton response Mrs Inez Dorothy Butler As Boughton response Mr John Butler As Boughton response Mr Kevin Callis As Boughton response N Callis As Boughton response Ms Brenda Callow As Boughton response Haurice Callow As Boughton response
79 WS010001/ENRMF/CONSAPPCRAL 103 Respondent Response Andrea Carnel As Boughton response R L Cawthra As Boughton response Naomi Cebula As Boughton response E D Chapman As Boughton response Dr H M Coghill As Boughton response Mrs E Colin-York As Boughton response Mrs M.W Collier As Boughton response Mr S Collier As Boughton response E. Compton As Boughton response T.L Compton As Boughton response David Cooper Plan reflects the current pattern of the separation of collection and disposal functions between the District and County authorities. There are few proposals for the locating of transfer stations, material recovery- recycling facilities which have major planning implications of operation and siting and which require to be sensible in terms of collection round patters. The county operated waste recycling centres are also barely mentioned; their technology has developed in the last 15yrs and could do further, whilst user distance travelled needs to be reduced. Hazardous waste proposals do not include provision for medical waste; this could be linked with an incineration plant to deal with waste residuals from the solid waste stream. Mrs Hazel Cooper As Boughton response J A Cooper As Boughton response Mr Ronald Cooper As Boughton response Ms Elaine Copperwaite As Boughton response Mr Roger Coulthard Concerns that residents of Kings Cliffe did not know about the consultation and therefore could not register any opposition in a properly considered manner. Mr Peter James Courier As Boughton response Mr Paul Cox As Boughton response Mrs B Critchell As Boughton response Mr Harry Critchell As Boughton response Mr Martin Cullen As Boughton response Mrs Valerie Cullen As Boughton response Mr L Curtis As Boughton response Mr Richard Daniels As Boughton response Sandra Daniels As Boughton response Diana Darlington As Boughton response Mr Malcolm Graham Darlington As Boughton response Mrs B.M. Davenport As Boughton response R N Davenport As Boughton response I Davies As Boughton response Ann Davison As Boughton response
80 WS010001/ENRMF/CONSAPPCRAL 104 Respondent Response Mr Russell Davison As Boughton response T I Dayigs As Boughton response M.B Deady As Boughton response Arabelle Dean As Boughton response Mr Michael John Dean As Boughton response Mr David Deane As Boughton response Mrs Delia Deane As Boughton response Ms Fiona Dickenson As Boughton response Mr R P Dickenson As Boughton response Mr Edward Digby As Boughton response Melanie Digby As Boughton response Mr Richard Digby As Boughton response Mr William Digby As Boughton response Miss L Dinonpoint As Boughton response Mr Joe Docker As Boughton response Mr Dan Dorgan As Boughton response Pam Dorgan As Boughton response Joanne Downie As Boughton response Mr Jon Downie As Boughton response Duffy As Boughton response Charlotte Duffy As Boughton response J B Duffy As Boughton response Rebecca Duffy As Boughton response Sophie Duffy As Boughton response Jean Dunn As Boughton response Mrs Lynda Dunne As Boughton response Mr Noel Dunne As Boughton response B Dunstone As Boughton response Mrs Carol Dunstone As Boughton response Sheldon Fenning As Boughton response Simone Fenning As Boughton response Ms Catherine Field As Boughton response Mr Robert Field As Boughton response A. Fleming As Boughton response Ms Karen Fletcher As Boughton response Graham Fogden As Boughton response
81 WS010001/ENRMF/CONSAPPCRAL 105 Respondent Response Giuseppe Forgione As Boughton response Louise Forgione As Boughton response Mr D Foster As Boughton response J Foster As Boughton response Mr A Fox As Boughton response Mrs I Fox As Boughton response Mr Mark Gaterell As Boughton response Stephanie Gaterell As Boughton response Mrs H. Gaudin As Boughton response Mr M Gavdin As Boughton response Ms Jill Gist As Boughton response Mr Robert Gist As Boughton response Carolyn Glanney As Boughton response Mr A.J.S Gledhill As Boughton response Mr L.J Gledhill As Boughton response A.P. Goddard As Boughton response Gillian H Gogden As Boughton response Mrs Helen Graft As Boughton response Lesley Gray As Boughton response Mr Mark Gray As Boughton response Mr Kevin Greatorex As Boughton response Ms Sue Greatorex As Boughton response M Greener As Boughton response R Greener As Boughton response Mr Stuart Greenslade As Boughton response Victoria Greenslade As Boughton response Maureen Haddon As Boughton response Mr Peter Haddon As Boughton response Mrs C Handshaw As Boughton response Mr Chris Handshaw As Boughton response R R Hardwick As Boughton response Mr J.T Harris As Boughton response Mrs Joyce Harris As Boughton response Mrs K.N Harris As Boughton response Mr David James Harrop As Boughton response Mrs Dorothy Harrop As Boughton response Mr John Hewerson As Boughton response
82 WS010001/ENRMF/CONSAPPCRAL 106 Respondent Response Sara Hewertson As Boughton response Mr Thomas Hewitt As Boughton response Katie Higgs As Boughton response Mrs Daphne Higham As Boughton response Mrs Shirley Hillier As Boughton response Mr David Houriham As Boughton response Mrs Sonja Hourihan As Boughton response Anne Hughes As Boughton response S.R Hughes As Boughton response Mr I Humby As Boughton response Mr Matthew Hunt As Boughton response Oonagh Hunt As Boughton response Mr Brian Hurren As Boughton response Margaret Hurren As Boughton response June Insall As Boughton response R Insall As Boughton response Mrs O.M James As Boughton response Ms Ann Jones As Boughton response Ms Catherine Jones As Boughton response Ms Christine Jones As Boughton response Mr Derek Jones As Boughton response Ms Gillian Kingston As Boughton response Mr Jonathan Kingston As Boughton response Mr Neil Kitchener As Boughton response Mr Richard Kitchener As Boughton response Mrs Val Kitchener As Boughton response Mrs D Knitt As Boughton response Mr J.A Knitt As Boughton response Ms Rita Lantsbery As Boughton response Mr Andrew Laurie As Boughton response Glenda Laurie As Boughton response Alastair Lawrie As Boughton response Catherine Lawrie As Boughton response Mrs C Lea As Boughton response Mr M J Lea As Boughton response R Lee As Boughton response
83 WS010001/ENRMF/CONSAPPCRAL 107 Respondent Response S Lee As Boughton response E Legrand As Boughton response Ms Rachel Legrand As Boughton response S A Lett As Boughton response Mr Peter Lindsley As Boughton response H C Lonell As Boughton response Ms Sylvia Ellen Lovell As Boughton response Mrs J Mabbutt As Boughton response Mr P Mabbutt As Boughton response Oliver Mackaned As Boughton response Charlotte Mackaness As Boughton response Mrs Eleanor Maltby As Boughton response Mr Terence Maltby As Boughton response Joan Mason As Boughton response Mr Philip Mason As Boughton response Ms Melanie McCall Concerns that there is no monitoring of health issues or air borne pollution. Concerns that monitoring will not continue. Anwen McDonnell As Boughton response Mr Daniel McDonnell As Boughton response Rosemary McDonnell As Boughton response W McDonnell As Boughton response Joanne McGowan As Boughton response Ms Mary McGowan As Boughton response Mr Thomas McGowan As Boughton response Mr Thomas McGowan As Boughton response Mrs Imelda McQuillan As Boughton response Dr W.J McQuillan As Boughton response Mr Derek Millard As Boughton response Ms Anna Moore As Boughton response Mr Frank Moore As Boughton response Janet T Morris As Boughton response Mr Neville Morris As Boughton response Ms Ann Murphy As Boughton response Mrs S Mynolt As Boughton response Mr R.E Mynott As Boughton response Mr Rish Napier As Boughton response Sue Napier As Boughton response
84 WS010001/ENRMF/CONSAPPCRAL 108 Respondent Response Mr George Neophiton As Boughton response Linda Neophiton As Boughton response Ms Margaret Palmer As Boughton response Mr Roy Palmer As Boughton response Mrs Dorothy Parkinson As Boughton response Mrs N Pearson As Boughton response Mr John Penny As Boughton response Mr Adrian Perez As Boughton response Mr Giles Perez As Boughton response Mr Harry Perez As Boughton response Suzanna Perez As Boughton response Dilys Pettitt As Boughton response Mr Guy Phillips Wallin As Boughton response Mr Anthony Philpott As Boughton response Mr Arthur Piggins As Boughton response Mrs P Rapkin As Boughton response Mr R Rapkin As Boughton response Mr Alan Rhodes As Boughton response H M E Rhodes As Boughton response Mrs M Rhodes As Boughton response Mr Maxwell John Rhodes As Boughton response Ms Sharon Ringsell As Boughton response C.S Robinson As Boughton response Mr P C Robinson As Boughton response Mrs P.B Robinson As Boughton response R.H Robinson As Boughton response Ms Eileen Rouse As Boughton response Mr John B Rouse As Boughton response Annewen Rowe As Boughton response Mr John Rowe As Boughton response J B Rushton As Boughton response Mrs M J Rushton As Boughton response Gillian Scotney As Boughton response Mr Paul Scotney As Boughton response Harriet Scott As Boughton response Mrs Marlon Scott As Boughton response
85 WS010001/ENRMF/CONSAPPCRAL 109 Respondent Response Mr Peter Scott As Boughton response Tess Scott As Boughton response Angelia Seelig As Boughton response Carlene Seelig As Boughton response I.M Seelig As Boughton response Mr M.P Seelig As Boughton response P R Seelig As Boughton response Ms Sarah Seelig As Boughton response Mr Stephen Seelig As Boughton response Mrs Theresa Seeling As Boughton response R L Sellig As Boughton response Mr Roger Skinner As Boughton response Mr and Mrs KM and JG Smid Concerns that residents of Kings Cliffe did not know about the consultation and therefore could not register any opposition in a properly considered manner. J M Smith As Boughton response Mr Neil Smith As Boughton response Ms Stephanie Smith As Boughton response A Soteriou As Boughton response Kay Soteriou As Boughton response Janice Squires As Boughton response Mr John Squires As Boughton response Mr Andrew Stables As Boughton response Mr Graham Stacey As Boughton response Mrs J Stacey As Boughton response Jo Stevens As Boughton response Mr Andrew Stirling As Boughton response Patricia Stirling As Boughton response Mrs K.G Sturgess As Boughton response Shirley Suler As Boughton response Mr David Suter As Boughton response Mr Robert Swannell As Boughton response Mrs June Taray As Boughton response Mr John Taylor As Boughton response Mr Mark Taylor As Boughton response Samantha Taylor As Boughton response Mr Simon Tebbatt As Boughton response
86 WS010001/ENRMF/CONSAPPCRAL 110 Respondent Response Ms Christina Tebbott As Boughton response Mrs G M Tebbutt As Boughton response Mr S.J Tebbutt As Boughton response L.A Thompson As Boughton response Mrs Linda Thompson As Boughton response Mr Peter Thompson As Boughton response Mr Walter Thompson As Boughton response G J Tomlins As Boughton response S & G J Tomlins As Boughton response Ms Caroline Trott As Boughton response Rev Stephen Trott As Boughton response D L Turner As Boughton response Mrs Inez Turner As Boughton response Katrina Varnsverry As Boughton response Michael John Varnsverry As Boughton response Mrs A Vewes As Boughton response Audrey Walker As Boughton response Mrs J Walton As Boughton response Mr John Walton As Boughton response Carla Watson As Boughton response Derrick Watson As Boughton response Jackie Watson As Boughton response Christine Weatherley As Boughton response Mr Richard Weatherley As Boughton response Mr David Whalley As Boughton response Margaret Wheeler As Boughton response Mrs Carol Wilkinson As Boughton response Mr Mark Wilkinson As Boughton response Dr Royston William As Boughton response E.K Williams As Boughton response Mrs H S Williams As Boughton response Mrs Jane Williams As Boughton response Mr Russell Wilson As Boughton response Mrs Susan Wilson As Boughton response T S Woolton As Boughton response Mrs S Wootton As Boughton response
87 WS010001/ENRMF/CONSAPPCRAL 111 Respondent Response J Wright As Boughton response Terri Wright As Boughton response Ms Jill Yelding As Boughton response Mr Richard Yelding As Boughton response Mr E Yuzbasioglu As Boughton response Mrs G Yuzbasioglu As Boughton response
Late Responses
Do you agree with the preferred approach for locational criteria for waste development?
Respondent Response SITA UK No. Waste disposal requirements need to be specified.
Do you agree with the intent of the emerging Location for Waste Development policies?
Respondent Response SITA UK Objects to policies W2-8 W2: Only provides for hazardous waste and not MSW and C&I. Existing commitments should be clearly identified. W4: It is not clear what is meant by "the facility siting criteria" W6 and W7: There is no definition of what "advanced" or "preliminary" treatment facilities are in the glossary.
Do you agree with the identification of preferred sites for waste development?
Respondent Response L Dunphy Objects to WA8 Concerns over increase in HGV traffic on roads that cannot support the increase in traffic. SITA UK Does not support site selection Supports WA13 and WA14 The preferred site should include sites for the disposal of non-inert wastes.
88 WS010001/ENRMF/CONSAPPCRAL 112 Is the proposed monitoring framework appropriate and relevant in relation to the emerging Locations for Waste Development policies?
Respondent Response SITA UK No: There is no provision for reviewing the policies if, for example, there are changes to the RSS or national policy and guidance. To avoid a 'capacity gap' the review should include an annual assessment of existing operational capacities and those that have been granted planning permission in that year but not developed yet. This will determine the need for provision of additional capacity and will assist developers in deciding what the development needs are. This will encourage investment because it will reduce risk and uncertainty.
Do you have any other comments regarding the Preferred Options for the Locations for Waste Development DPD?
Respondent Response SITA UK Supports the extension to Cranford Landfill site in order to meet capacity requirements and due to its strategic location in the urban spine. Should reference the development of renewable energy schemes from landfill gas, such as the one at Cranford. Any extension will make use of existing infrastructure.
89 WS010001/ENRMF/CONSAPPCRAL 113 Northamptonshire MWDF Preferred Options Augean response
Core Strategy
Objective 5: Spatial distribution of waste development
Facilitate the delivery of a strategic urban-focussed flexible waste management network which supports the proximity principle, with particular encouragement of integrated waste recovery and treatment facilities.
As the proximity principle is no longer defined in national policy or the Waste Strategy the term should not be used. Reference should be made to the equivalent policies and terminology in PPS10. That is in respect of facilities to meet the needs of the community and to enable waste to be deposited in one of the nearest appropriate installations. By the use of the term “proximity principle” the County risks misleading itself in respect of the appropriate basis for geographic planning of waste facilities.
The preferred approach: Categories of waste management facilities
The classification of waste management facilities should identify the capacity (relating to the facility catchment area) and function (by level of treatment) of facilities within Northamptonshire’s sustainable waste management network.
The capacity of waste management facilities should be defined as:
National - Facilities with a catchment area which extends beyond two regions from Northamptonshire (generally more than 100 miles).
Regional - Facilities receiving waste from at least three sub-regions either within the East Midlands or adjacent to Northamptonshire (generally more than 50 miles).
Sub-regional - Facilities receiving waste from at least two sub-regions either within the East Midlands or adjacent to Northamptonshire (generally 30 to 50 miles).
Local - Facilities receiving waste from within Northamptonshire (generally 30 miles).
Neighbourhood - Facilities which specifically serve ‘neighbourhood development’ involving any one or more of the following:
• the provision of 100 or more dwelling houses;
• retail or shopping centres where development or redevelopment relates to floor space of more than 500 square metres;
Northamptonshire MWDF Preferred Options Augean response 4 December 2007 1 of 6 WS010001/ENRMF/CONSAPPCRAL 114 • major transport, leisure, recreation, tourist, community, commercial or industrial facilities or those attracting significant number of people;
• development or redevelopment where occupation is likely to generate significant quantities of waste (or special waste); and
• development or significant redevelopment where occupation presents viable opportunities for integrated waste management (due to waste type and quantity) and would accommodate the provision of neighbourhood waste management facilities (such as commercial or industrial parks).
The level of treatment should be defined as:
Preliminary treatment – household waste recycling centres, materials recycling facilities, composting (open windrow and in- vessel), anaerobic digestion, mechanical biological / heat treatment, inert processing, other recycling facilities and waste transfer stations.
Advanced treatment – thermal, pyrolysis, gasification, other waste to energy processes and other emerging advanced technologies.
Disposal – non-inert land fill / raise and inert landfill.
Sewage and waste water treatment – sewage and waste water treatment plant.
The allocation of specific catchment areas for specific waste management facilities is a Utopian approach to planning seriously flawed in respect of the economics of waste management facilities and the market. The proposal does not recognise the availability elsewhere of facilities. The policy promotes a situation where new waste facilities in the County have a limited market while existing facilities in the County and any facilities outside the County will be able to compete in these restricted areas. It is inevitable that the new facilities will be at a competitive disadvantage and ultimately fail unless the business is underpinned by contracts. On this basis there is a serious danger that the plan will not be deliverable.
The allocation of specific distances for catchment areas is arbitrary and unlikely to relate to a viable catchment.
Different technologies will need considerably different catchments to make them viable. Investments in technologies are made on the anticipation of minimum waste inputs over a payback period. Unless the catchments are sufficiently large to facilitate the minimum waste inputs the investment will not be made.
Northamptonshire MWDF Preferred Options Augean response 4 December 2007 2 of 6 WS010001/ENRMF/CONSAPPCRAL 115 In our view the policy goes beyond the intention of PPS10. We refer you to the Secretary of State’s decision in the case of Clay Hanger Hall Farm APP/Z0645/V/06/1199020 and 1199021 (Copy attached). At paragraph 53 it is stated:
The preferred approach: Identifying our future waste management capacity
Northamptonshire will seek to move towards the provision of the indicative waste management capacities identified through the development of a gradually declining medium growth profile that incorporates waste management targets, as detailed below:
• Recycling and composting (MSW and C&I) capacity of 820,000 and 970,000 tonnes per annum for 2016 and 2026 respectively;
• Landfill diversion (MSW and C&I) capacity of 455,000 and 520,000 tonnes per annum for 2016 and 2026 respectively;
• Inert recycling capacity of 930,000 and 1,090,000 tonnes per annum for 2016 and 2026 respectively; and
• Hazardous waste management of 45,000 and 50,000 tonnes per annum for 2016 and 2026 respectively.
While it is appropriate to identify the need for hazardous waste capacity it must be recognised that the capacity figures will not define the need for hazardous waste management facilities. The 45,000tpa to 50,000tpa includes a wide range waste types needing a range of specialist facilities not one facility which will manage the 50,000tpa.
The preferred approach: Identifying our waste management catchment area
Northamptonshire’s waste management catchment area should provide adequate capacity for waste arisings from within Northamptonshire whilst also recognising sub regional movements and the importance of specialist facilities of regional or national importance (in exceptional circumstances).
It is considered that the policy is generally appropriate although there is a need to clarify what is meant by exceptional circumstances.
Northamptonshire MWDF Preferred Options Augean response 4 December 2007 3 of 6 WS010001/ENRMF/CONSAPPCRAL 116 The preferred approach: Requirement for landfill
There will be no specific provision for new standalone landfill or landraise sites for non-inert waste disposal during the plan period. Where it can be clearly demonstrated that additional waste disposal capacity is required preference will be given to existing sites where appropriate. All waste intended for disposal must undergo both preliminary and advanced treatment to ensure that only residual waste is disposed of.
An extension of the existing hazardous landfill site is proposed through the Locations for Waste Development DPD in order to serve sub-regional hazardous waste disposal requirements specifically relating to residual waste produced from advanced waste management technologies. The extension would be phased to complement the development of advanced waste treatment facilities, and would not therefore be expected to be permitted until post 2016.
The appropriateness of sub-regional hazardous waste facilities needs to be examined in relation to the range of hazardous waste management techniques proposed. There are few hazardous waste facilities that could operate commercially on a restricted catchment. In respect of landfill there are only 6 facilities in the UK that provide disposal services for a wide range of hazardous wastes. All of these sites by the nature of the wastes that they manage and their distribution operate on a sub national basis.
The basis of the need for the extension by 2016 is unclear. The need should relate to the life of the existing facilities. Unless further void space is secured before the closure of the current landfill in 2011 there will be an interim shortfall.
The preferred approach: Safeguarding mineral and waste uses
In relation to Northamptonshire’s waste management network, new development adjacent or in close proximity to (250m) planned and operational waste management facilities (including sewage treatment works) should only be permitted where it can be demonstrated that the proposed development would not prevent or prejudice the use of the waste management facility. Locations for national, regional and sub- regional advanced treatment facilities (existing and allocated) should be safeguarded from non-waste related development unless alternative provision is made elsewhere (for national and regional facilities this may be outside Northamptonshire) and there is not an unacceptable break in operations whilst this alternative provision is made. Locations for local, district or neighbourhood advanced and preliminary treatment facilities should be safeguarded from alternative non-waste related development unless alternative provision in the vicinity can be implemented, or if it can be clearly proven that there is no longer a need for a waste management facility at that location.
This is an essential policy to ensure delivery of a network of sustainable waste management facilities.
The preferred approach: Transporting minerals and waste
Northamptonshire MWDF Preferred Options Augean response 4 December 2007 4 of 6 WS010001/ENRMF/CONSAPPCRAL 117 Minerals and waste-related development should minimise road-based transport movements and maximise the use of sustainable or alternative transport modes. Where alternatives to road-based transport are not viable development should incorporate measures to reduce and / or offset carbon and other greenhouse gas emissions.
The practicability and enforceability of this policy cannot be assessed without a clear indication of what measures the County intends to impose. This policy does not take into account the nature of the minerals or waste managed, the practicality of using more sustainable modes of transport in the County (which is limited) or whether such measures are already covered by good management practice or other regulatory regimes such as PPC Permits.
The policy of the County to move to more locally based waste management facilities is directly in conflict with the economic realities of water or rail borne waste transport.
Kings Cliffe
1. The area of land allocated is incorrect as the western part of the existing site does not have planning permission for landfill. It is proposed that the western part of the existing site is included in the extension area the subject of the allocation.
2. Proposed use; Consistent with the recently made application for planning permission to develop a soil treatment centre at the site it is proposed that the proposed use should be “Hazardous Waste Disposal and Treatment”.
3. It is stated in the site assessment
“Kings Cliffe Extension site benefits from being able to potentially provide
significantly to future waste management capacity for MSW and C&I waste both locally and regional”.
The purpose of the site is the management of hazardous waste. Hazardous waste is a specialised part of these waste streams hence the statement is misleading by referring to MSW and C&I in general terms. As will be clear below although the site is important locally and regionally we consider that the site is an essential facility on a sub national basis.
4. It is stated in consistency with emerging Core Strategy
“It is intended that planning permission would not be forthcoming until
at least 2016.”
Northamptonshire MWDF Preferred Options Augean response 4 December 2007 5 of 6 WS010001/ENRMF/CONSAPPCRAL 118 The extant planning permission expires in 2011 hence the planning for extension of the site would need to be granted before this date.
5. The proposal to restrict the site to a sub-regional market is does not appropriately take into account the specialised nature of the facility, the current national network of similar facilities and runs counter to the policies in PPS 10.
“Furthermore the extension should be restricted to a sub-regional catchment only in order to reduce the transport of waste from its origin.”
There are currently only 6 landfill sites in the UK that take a wide range of hazardous wastes. The nearest sites to Kings Cliffe that receive a similar range of wastes are located on the Humber Estuary near Hull, at Swindon and near Gloucester. The restriction of the catchment of the site will result in wastes having to travel greater distances to the other sites or even to travel past Kings Cliffe to get to those sites. This clearly will not reduce the transport of waste from its origin.
“Although located beyond the main urban spine, the site currently serves a sub-national catchment; approval for the extension however will only be forthcoming if it was to serve no more that a sub-regional catchment area (which would include some areas outside Northamptonshire in both the East Midlands and east of England regions).”
If the catchment of the Kings Cliffe site is constrained to a 30 to 50 mile radius it is likely that the economic viability of the site will not be sustainable. There are no catchment constraints on the other similar sites in the UK. The additional effect of the catchment constraint is that the other sites will be able to compete in the constrained catchment and force the costs of disposal down. This will have two undesirable impacts in planning terms. Lower landfill costs will result in less recycling and recovery. Increased travel of waste generated in the catchment to sites outside the catchment. There will be further reduction of the viability of the site and an inevitable closure of the site.
“Given the specialist nature of such a facility the proximity principle must be applied with due consideration to the facility type and catchment area.”
Proximity principle is no longer a term used in the waste planning policy as set out in PPS10 or in the Waste strategy. Please see comments in respect of Objective 5.
Northamptonshire MWDF Preferred Options Augean response 4 December 2007 6 of 6 WS010001/ENRMF/CONSAPPCRAL 119 Northamptonshire Minerals and Waste Development Framework Control of Management of Development – Discussion Document
Augean plc comments
Augean wishes to make brief general comments on a few aspects of this document.
Carbon offsetting: While we understand the purpose of this policy we have significant concerns how such a policy can be implemented and the precise expectations of the authority in this regard. This is exacerbated by the fact that there is not a comprehensive infrastructure within Northamptonshire to achieve sustainable transport in all but a few areas of the County. The document must provide clear guidance to development.
Buffer zones: There should be no prescription of buffer zones. The impacts from development are dependant on the location, design and operation of mineral and waste development. Prescription will only lead to buffer zones that are inappropriately small or large. The buffer zones should be determined on the basis of environmental assessment taking into account the factors specific to the development.
Pollution control: The County should seek to minimise overlap with other authorising systems. There needs to be better understanding between the planning authority and the Environment Agency of their respective powers.
The planning authority should resist the temptation of setting conditions requesting schemes when not needed in particular when the necessary details have been set out in the application documents.
Page 1 of 2 WS010001/ENRMF/CONSAPPCRAL 120 Cumulative impact: We consider that the proposed policy in the MWDF is adequate. It is our view that the matter is also adequately addressed in the Environmental Assessment Regulations.
Pre-application discussions: The County should set out its commitment to developers in this regard and how it will support this approach.
Planning conditions: Planning conditions should not repeat the content of the application documents or request as reserved matters information that is presented in the application documents. The consent of a well drafted application should need few conditions other than the date of commencement and confirmation that the development should be carried out in accordance with the application.
Page 2 of 2 WS010001/ENRMF/CONSAPPCRAL 121 WS010001/ENRMF/CONSAPPCRAL 122 WS010001/ENRMF/CONSAPPCRAL 123 WS010001/ENRMF/CONSAPPCRAL 124 WS010001/ENRMF/CONSAPPCRAL 125 WS010001/ENRMF/CONSAPPCRAL 126 WS010001/ENRMF/CONSAPPCRAL 127 Northamptonshire Minerals and Waste Development Framework For Office Use Only
Ref No. Locations for Waste Development DPD Date Received: Date Acknowledged:
Proposed Submission Representation Form Entered By:
PART A
Personal Details Agents Details (if applicable)
Name: Augean Plc Name: Claire Brook
Address: East Northants Resource Management Address: Facility Stamford Road Kings Cliffe PE8 6XX Tel: Tel: 01780 444900 Fax: Fax: 01780 444901 E-mail: E-mail:
Making Your Response
Please use a separate form for each representation that you submit. You are advised to keep your own copy of all the representations that you submit. Representation Forms should be returned to:
Locations for Waste Development Proposed Submission Spatial, Economic and Environmental Planning Northamptonshire County Council PO Box 163, County Hall Northampton NN1 1AX
Or emailed to: [email protected] or faxed to 01604 236065
Responses should be received no later than 5.00pm on Thursday 12 March 2009. Please note that the Inspector is not obliged to consider representations received after the closing date. Only those objectors whose objections are made within the consultation period will have a right to have their objections considered by the Inspector.
What will happen to my response?
All responses will be made available for public viewing. They cannot be treated as confidential. The Data Protection Act 1998 requires Northamptonshire County Council to notify you that the information you have given will be held in a computer database. The County Council will consider all representations that it receives during the period for representations.
If you have any questions regarding making your response please contact the Planning Policy team on (01604) 236014 or by e-mail: [email protected]
Signature: Date: 11 March 2009 Claire Brook WS010001/ENRMF/CONSAPPCRAL 128 PART B Please use a separate sheet for each representation
1. Which paragraph or policy (or to the proposals map) of the Locations for Waste Development DPD (Development Plan Document) does your representation relate to? Paragraph 3.23 Policy Proposals Map
2. If your representation is an objection it must relate either to the Locations for Waste Development DPD not complying with legal requirements, or it not being sound in relation to one of the Tests of Soundness. Is your representation concerned with: Not complying with legal requirements Not meeting the Test of Soundness x
Please refer to the guidance notes at the rear of this form for further information on the Tests of Soundness.
3. If your representation is an objection because of the Locations for Waste Development DPD not meeting a Test of Soundness, what Test of Soundness do you consider it fails? The justification test x The effectiveness test x The test of consistency with national policy x
4. Please make your comments below (they need to be made in reference to not meeting legal compliance or the Tests of Soundness). This should cover succinctly the evidence and supporting information necessary to support/justify your representation and any suggested changes you are proposing. After this stage further submissions will only be at the request of the examination Inspector. You can continue your comments on a separate sheet if necessary.
We consider the approach of not allocating specific sites for hazardous waste disposal, is unsound. The justification, for all types of waste disposal, provided in the Core Strategy, is that it is difficult to forecast the potential void space required to accommodate residual wastes, and it is expected that there will be no need for an increase in landfill provision until at least 2016. The Core Strategy goes on to state that proposals for additional capacity later in the Plan Period will be required to robustly justify need and preference will be given to extensions of existing sites. In the context of hazardous waste, we do not consider that such an approach is justified. Firstly, there is only one landfill site in the County, at the East Northants Resource Management Facility (Kings Cliffe Landfill Site). The current planning permission for this site expires in 2013 and there will be a need for additional capacity during the Plan Period. The precise extent of this need will have to be considered as part of any planning application but it should not preclude the allocation of a suitable site in the Locations Document. PPS 10 provides that in general waste planning authorities should identify sites suitable for waste management and be able to demonstrate how capacity equivalent to “at least ten years” could be provided. At the Preferred Options stage, an extension of the Kings Cliffe Landfill (Site WA16) was assessed and included as a suitable site. No other potential sites were considered or put forward as appropriate for hazardous waste disposal. The Core Strategy indicates that a preference will be given to extensions of existing sites, a position supported by Augean. In light of the above, there is justification that a more reasonable alternative would be to allocate a proposed extension at Kings Cliffe Landfill site in the Locations Document. This would also help to ensure deliverability of the Development Plan Document. WS010001/ENRMF/CONSAPPCRAL 129 Continued from previous page .
5. If your representation is seeking a change to the Locations for Waste Development DPD, what change do you think should be made?
We would like to see a Policy with an allocation for an extension at the Kings Cliffe Landfill site for hazardous waste disposal included in the Locations Document. In terms of its role, we consider this should remain as a national/regional facility. Alternatively, if a Policy with an allocation is not considered appropriate, we would like a specific reference in the Locations Document to a preference being given to an extension at the Kings Cliffe Landfill site to meet appropriate future hazardous waste disposal needs.
WS010001/ENRMF/CONSAPPCRAL 130 6. If your representation is seeking a change to the Locations for Waste Development DPD, do you consider it necessary to present this to the inspector at a public session of the examination?
Yes x No
7. If you wish to participate at a public session of the examination, please outline why you consider this to be necessary. We would like to attend a public session of the examination as there may be a need to explain some of the complexities associated with hazardous waste disposal and/or to deal with any site specific questions in respect of the proposed extension.
Further copies of this response form have been made available on our website at http://www.northamptonshire.gov.uk/Environment/Planning/policy/Minerals/plannews or hard copies can be sent on request. You can forward your completed response forms (in Word .doc format please) by e-mail to [email protected] Guidance Notes for respondents ______
The importance attached to getting DPDs (Development Plan Documents) right is reflected in the fact that they are subject to independent examination. Given the potential impact of DPDs, it is vital that the plan is the most appropriate. This is partly why there is an independent examination to provide assurance. The examination of any DPD is concerned with the two separate matters of legal compliance and soundness.
Legal compliance
Under the Planning and Compulsory Purchase Act 2004 S 20(5)(a) an Inspector is charged with firstly checking that the plan has complied with legislation. This includes, in particular, checking that the DPD: . has been prepared in accordance with the Local Development Scheme and in compliance with the Statement of Community Involvement and the Regulations; . has been subject to sustainability appraisal; . has regard to national policy; . conforms generally to the Regional Spatial Strategy; and . has regard to any sustainable community strategy for its area (i.e. county and district).
Soundness
To be ‘sound’ a DPD should be justified, effective and consistent with national policy.
Justified means that the document must be:
. Founded on a robust and credible evidence base Evidence gathered should be proportionate to the job being undertaken by the plan, relevant to the place in question and as up-to-date as practical having regard to what may have changed since the evidence was collected.
. The most appropriate strategy when considered against the reasonable alternatives The ability to demonstrate that the plan is the most appropriate when considered against reasonable alternatives delivers confidence in the strategy. It requires the local planning authority to seek out and WS010001/ENRMF/CONSAPPCRAL 131 evaluate reasonable alternatives promoted by themselves and others to ensure that they bring forward those alternatives which they consider the LPA should evaluate as part of the plan-making process.
Effective means that the document must be:
. Deliverable A DPD should show how it will be delivered and by whom, and when. This includes making it clear how infrastructure which is needed to support the DPD will be provided and ensuring that what is in the DPD is consistent with other relevant plans and strategies relating to adjoining areas.
. Flexible A strategy is unlikely to be effective if it cannot deal with changing circumstances. The MWDF should look over a long time frame and be able to show how it will handle contingencies.
. Able to be monitored A DPD must have clear arrangements for monitoring and reporting results to the public and civic leaders. Monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered. The delivery strategy should contain clear targets or measurable outcomes to assist this process.
The above is a summary of guidance based on the Government’s Planning Policy Statement (PPS) 12 on Local Spatial Planning.
WS010001/ENRMF/CONSAPPCRAL 132 STATEMENT ON NORTHAMPTONSHIRE MWDF CORE STRATEGY REPRESENTATIONS 2293, 2325 and 2357
WS010001/ENRMF/CONSAPPCRAL 133 1. INTRODUCTION
1.1. Regulation of hazardous waste management
1.2. The regulation, and subsequent management, of Hazardous Waste has altered dramatically following the introduction of the Landfill Directive and its transposition into UK law by the Landfill (England and Wales) Regulations 2002.
1.3. The key impacts of these Regulations on hazardous waste disposal have been:
1.3.1. To ban certain hazardous wastes from landfill completely (e.g. liquid wastes and tyres).
1.3.2. The reclassification of landfills into non-hazardous, hazardous and inert, bringing an end to the co disposal of hazardous and non hazardous wastes (save for certain stable non reactive hazardous wastes in separate cells at non-hazardous landfills) (July 2004).
1.3.3. To require all hazardous waste destined for landfill to be treated first (July 2004)
1.3.4. To exclude hazardous waste that does not meet the final waste acceptance criteria (WAC) to be disposed of to any landfill (July 2005).This is subject to a caveat that for waste streams disposed of in hazardous waste landfills, the WAC may be exceeded by up to 3 times by risk assessment.
1.3.5. To require asbestos to be disposed of separately to all other stabilised hazardous waste in non-hazardous waste landfills (July 2005).
1.4. In addition, the List of Wastes (England) Regulations 2005 and the Hazardous Waste (England and Wales) Regulations 2005 has increased the number of wastes that are now classified as hazardous wastes.
1.5. Current Management of Hazardous Waste
1.6. The end of co-disposal and the creation of specific landfill sites for the disposal of hazardous wastes resulted in a substantial change in the structure of the Landfill Sector. There is a general perception within the Waste Management Industry that landfills for hazardous waste represent a high commercial risk and a long term liability, consequently the vast majority of co-disposal sites were reclassified as non- hazardous landfills (Document 1014,Page 13).
Statement on Northamptonshire MWDF Core Strategy 2 Representations 2293, 2325 and 2357 WS010001/ENRMF/CONSAPPCRAL 134 1.7. Less than 20 of the several hundred co-disposal sites were reclassified as landfills for the disposal of hazardous waste. There are currently 17 Permitted hazardous waste landfills of which 2 are not operational, 6 are limited to contaminated construction and demolition wastes and two are restricted to principally incinerator residues. This leaves only 7 sites in England and Wales which accept a wide range of hazardous wastes to serve the remainder of the market (See Document 1003).
1.8. There are additionally 49 non-hazardous waste landfill sites which are permitted to take asbestos (without other hazards), stable non-reactive hazardous wastes (SNRHW) and gypsum (which is mostly non-hazardous). Of these sites 20 accept mostly soils permitted as SNRHW and 39 are permitted for asbestos.
1.9. The locations of the 7 hazardous landfill sites accepting a wide range of waste are shown on Document 1011. The landfill at East Northants Resource Management Facility in the north east of the County is the only landfill for a wide range of hazardous waste in the County and the Region. There are no similar sites in the East of England or the South East Region. The nearest similar sites are on the Humber, near Gloucester and near Swindon.
1.10. A meaningful list of hazardous waste treatment facilities is not available. Treatment includes recycling, recovery and preparation for recycling, recovery and disposal of hazardous and non-hazardous wastes. Facilities for the treatment of hazardous waste are generally specialised, treat specific waste streams and are geographically widely spread. For example there are only two high temperature hazardous waste incinerators in the UK which are located in Ellesmere Port and Southampton. There is only one cement stabilisation process located at Cannock. There are 4 soil treatment Centres which are located in Surrey, Merseyside, Teesside and at Kings Cliffe Northamptonshire. It is therefore unlikely that the full range of hazardous wastes produced in an individual county can be treated within that county and even the Region and the wastes need to be transported to the appropriate facilities.
1.11. To reduce transport distances the market is served by transfer stations where the specific waste streams are bulked for delivery to the specific treatment facilities. The co-location of complementary facilities also has the potential to reduce transport of hazardous waste. At the East Northants Resource Management Facility, Augean has planning permission for soil treatment (Document 1010). The facility has a series of integrated activities comprising soil washing of contaminated soils
Statement on Northamptonshire MWDF Core Strategy 3 Representations 2293, 2325 and 2357 WS010001/ENRMF/CONSAPPCRAL 135 recovering 80% of the soil, stabilisation of filter cake from soil washing and disposal of the final residue in the landfill.
1.12. The treatment of hazardous wastes has traditionally been undertaken by low technology methods most infamously mixing in pits, which were brought to an end only recently in November 2008. The Government, in Waste Strategy 2007, promotes the development of a modern hazardous waste management infrastructure (Annex C9). Through the industry/regulator Hazardous Waste Steering Group, DEFRA is developing a set of principles for the sustainable management of hazardous waste (Document 1015). One of the key objectives of the principles is to promote investment in the Sector to deliver the necessary facilities.
1.13. Hazardous waste statistics
1.14. The most recent comprehensive hazardous waste statistics are for 2007 and were published by the Environment Agency in 2008 (Documents 1004, 1005 and 1008). The statistics show that as a result of the legislative changes described above there has been a significant change in hazardous waste classification, production, treatment and disposal between 2004 and 2006. As a result statistics for years prior to 2005 are of limited value for the interpretation of the need for, and distribution of, facilities.
1.15. The table for Hazardous Waste Production Trends by Region (Document 1004) shows that the East Midlands produced 362,710 tonnes of hazardous waste in 2007. The table for Hazardous Waste Deposit Trends by Region shows that 592,302 tonnes of hazardous waste was managed in the East Midlands in 2007. Based on a national hazardous waste arising of 6,431,165 tonnes in 2007 the East Midlands produces 5.6% of the national hazardous waste and manages 9.2% of the national arisings. The table of Movements of all Hazardous Wastes 2007 shows that just under half (271,605 tonnes) of hazardous waste generated in the East Midlands was exported from the East Midlands. The statistics illustrate the description of the market given above showing a complex set of movements to deliver hazardous waste to appropriate facilities.
1.16. The Figure entitled Deposits and Movements of Hazardous Waste to Landfills between Planning Regions shows that when compared with the distribution of the 7 hazardous landfill sites accepting a wide range of wastes (Document 1007), the wastes generally move to the closest site. Hazardous waste for landfill from the East
Statement on Northamptonshire MWDF Core Strategy 4 Representations 2293, 2325 and 2357 WS010001/ENRMF/CONSAPPCRAL 136 of England, the South East and the West Midlands generally move to the East Midlands to the landfill at East Northants Resource Management Facility.
1.17. The Environment Agency table for the East Midlands; Hazardous Waste Produced by EWC Chapter and Sub-Region (Document 1005), shows that in 2007 62,702 tonnes of hazardous waste was produced in Northamptonshire. This contrasts with the Core Strategy, based on pre-2005 statistics, which forecasts a rising production to 50,000 tonnes per annum by 2026 (Page 21, Paragraph 6.25). The table of East Midlands Hazardous Waste Movements shows that in 2007 of the 62,702 tonnes 48,728 tonnes was exported from the County while 134,143 tonnes was imported to the County. This is largely accounted for by the landfill at East Midlands Resource Management Facility.
2. SOUNDNESS OF COUNCIL’S PROPOSED STRATEGY FOR DEALING WITH HAZARDOUS WASTE
2.1. Paragraph 6.26
2.2. The hazardous waste disposal facility of national significance referred to in the Core Strategy at Paragraph 6.26 is at the East Northants Resource Management Facility. The paragraph goes on to state that it has this status as it is one of a few such facilities nationally. This is verified by the evidence referred to above and contained in Document 1003.
2.3. The facility includes a landfill site together with a soil treatment facility comprising bioremediation, soil washing and stabilisation. The soil treatment facility will be commissioned during April 2009. As is clear from the statistics referred to above, the facility principally serves the Region and surrounding regions where there are currently no similar facilities. The planning permissions issued in 2006 and 2008 do not include any conditions restricting the catchment of the facility (Documents 1009 and 1010).
2.4. Paragraph 6.26 goes on to suggest that other regions and parts of the East Midlands Region should begin to provide their own hazardous waste disposal during the plan period such that the catchment area for the facility will ‘ naturally’ reduce. In terms of any extension, the Council seek to impose a restricted catchment area of 50 miles.
Statement on Northamptonshire MWDF Core Strategy 5 Representations 2293, 2325 and 2357 WS010001/ENRMF/CONSAPPCRAL 137 2.5. Soundness of this approach
2.6. The Council does not justify why it is appropriate for other parts of the East Midlands Region to provide their own hazardous waste disposal or how this could be achieved in the Plan Period. There is no ‘robust or credible evidence’ to justify this approach. As such, they are not able to justify that the catchment area for the East Northants Facility will in fact ‘naturally’ reduce. This is a purely aspirational policy. The allocation of specific distances for catchment areas is arbitrary. No evidence is presented by the Council that 50 miles represents a viable or appropriate catchment for the East Northants Facility.
2.7. As explained in Section 1 above, hazardous waste management currently operates in a national market. This market is served by a few specialist facilities generally focusing on a narrow range of waste streams. There are few hazardous waste facilities that could operate commercially on a restricted catchment. In respect of landfill there are only 7 facilities in the UK that provide disposal services for a wide range of hazardous wastes. All of these sites by the nature of the wastes that they manage and their distribution operate on a sub national basis.
2.8. Different technologies will need considerably different catchments to make them viable. Investments in technologies are made on the anticipation of minimum waste inputs over a payback period. Unless the catchments are sufficiently large to facilitate the minimum waste inputs the investment will not be made hence the provision will not be delivered.
2.9. The allocation of restricted catchment areas for hazardous waste management facilities does not recognise the availability elsewhere of facilities. New waste facilities in the County with a specified catchment will have a restricted market while existing facilities in the County and any facilities outside the County will be able to compete in these restricted areas. It is inevitable that the new facilities will be at a competitive disadvantage to those facilities which do not have restricted catchments. Ultimately the facilities with restricted catchments will fail unless the business is underpinned by contracts. Generally the hazardous waste market is not based on long term contracts. In this respect there is a serious danger that the plan will fail and will in practice discourage investment in the County for hazardous waste facilities.
2.10. The catchments proposed are insufficiently flexible to encourage development of new hazardous waste facilities and will undermine the modernisation of the sector.
Statement on Northamptonshire MWDF Core Strategy 6 Representations 2293, 2325 and 2357 WS010001/ENRMF/CONSAPPCRAL 138 2.11. Is the Proposed Strategy in accordance with National Policy?
2.12. PPS10 on waste management no longer specifically refers to the principle of ‘self sufficiency’ but it does place an obligation on regional planning bodies and planning authorities to aim to provide sufficient opportunities to meet the identified needs of their area for waste management. It is widely acknowledged that the goal should be one of “net” self sufficiency, to allow for cross boundary movements of waste so as not to conflict with enabling waste to be disposed of in one of the ‘nearest appropriate installations.’
2.13. The approach of a restricted catchment area as advocated by the Council does not accord with the principles of regional net self –sufficiency and enabling waste to be disposed of at the nearest appropriate installation. PPS10 does not refer to catchment areas or a need to impose them.
2.14. Whilst PPS10 does apply to the management of all waste streams, including hazardous waste, it is worth noting the recent provisions introduced in the Planning Act 2008. The Act introduces the Infrastructure Planning Commission which will be responsible for determining planning applications for ‘nationally significant infrastructure projects’. Hazardous landfill facilities disposing of more than 100,000 tonnes per annum and other disposal or recovery facilities dealing with in excess of 30,000 tonnes per annum are defined as nationally significant infrastructure projects. A National Policy Statement is due to be produced to set out Government Policy for the management of hazardous waste. It is not expected to be released for consultation until Spring 2010 but as the Act states at Section 5 it is likely to include criteria for determining the suitability of locations and may identify sites.
2.15. At the very least these provisions demonstrate that the Government view hazardous waste management as a matter of national significance requiring bespoke national policy. Proposed facilities that exceed the thresholds are by definition likely to be to meet an identified ‘national’ need. It would be premature to introduce a regional or sub-regional policy which conflicts with such an approach.
2.16. Annex C9 of Waste Strategy 2007 deals with hazardous waste. Paragraph 24 recognises that hazardous waste has “always travelled across regional boundaries” but notes that “there is scope for minimising this with a regional distribution of facilities more closely matched to regional arisings”.
Statement on Northamptonshire MWDF Core Strategy 7 Representations 2293, 2325 and 2357 WS010001/ENRMF/CONSAPPCRAL 139 2.17. Regional Policy
2.18. The East Midlands Regional Waste Strategy published in January 2006 refers to a number of priority issues (Document 203). Priority Issue 4 is the prevention and improved management of hazardous wastes. At page 55 the Regional Assembly acknowledges that the increased legislative control on the remaining hazardous waste landfill sites places increased pressure on available void space in those facilities and this is likely to be compounded with the lack of available void space in other parts of the UK. As such they consider there will be increased inter-regional movements of hazardous wastes. “Although it is unlikely - and in many cases inappropriate that any Region will be fully self sufficient in the management of this waste, the East Midlands should aim to ensure that hazardous waste management capacity is developed and maintained at a level equivalent to Regional hazardous waste arisings.”
2.19. It is not apparent that the Council has had regard to the policy approach set out in the Regional Waste Strategy or that imposing restrictive catchments on new facilities would deliver the aims set out in the Strategy.
2.20. Policy Approach in other Regions
2.21. In assessing the soundness of the Core Strategy and whether it will be effective, it is relevant to consider the approach taken by other Regions. Again, it is not clear that the Council has done this in order to develop a coherent approach.
2.22. In the South East Region, SEERA commissioned a survey on hazardous waste and this was published in May 2005 (Document 1014). As an example of the impact of the legislative changes on hazardous waste management, the South East Region went from a position of substantial self-sufficiency to one of almost total reliance on adjacent regions to deal with the hazardous waste overnight in July 2004.
2.23. In its recommendations on planning policy, the survey states, “For many types of hazardous waste, a regional, or even national approach to hazardous waste planning makes good economic sense because this allows wastes to be collected from a wider area and obtains high enough inputs to make processing facilities cost effective. Operators need the confidence that the planning system understands the need for a regional perspective so that they make the long-term commitment of investing in facilities.”
Statement on Northamptonshire MWDF Core Strategy 8 Representations 2293, 2325 and 2357 WS010001/ENRMF/CONSAPPCRAL 140 2.24. It is fair to point out that the Executive Summary also notes as follows, “However, the environmental effects associated with the transportation of waste over long distances, increasing haulage costs due to fuel prices, coupled with the fundamental strategic drivers of the proximity principle and regional self sufficiency means the objective of net regional self-sufficiency in capacity should be pursued...”
2.25. The Draft Revised South West RSS makes the following comments about hazardous waste at paragraphs 7.4.10 and 7.4.11 (Document 1016) - “the market for hazardous waste disposal at sites established for that purpose is now a highly specialised activity that operates in a market of at least regional and more probably national scale. The region is broadly self-sufficient in hazardous waste treatment capacity and has facilities for the transfer, treatment and recycling of hazardous wastes...The specialist nature of hazardous waste landfill may restrict the type of waste inputs, but the region should also seek to make a contribution to the national need in line with its own regional requirements. Existing sites being located on the region’s eastern boundary and close to the primary road network are well positioned to serve the regional and the wider national market for hazardous waste disposal. Existing sites should be safeguarded with proposals for extension considered within the context of the region’s contribution to wider national needs and the proposal’s local environmental impact.”
2.26. There is recognition in these other policies that hazardous waste management operates on a national basis and that it is unrealistic to set policy which ignores this position. Whilst a goal of making adequate regional provision is advocated in a number of cases, there is an acknowledgement that this will not preclude cross boundary movements and for some facilities to continue to operate as ‘national’ facilities.
2.27. Policy CS1
2.28. It appears that the County has assumed in policy CS1 that provision can be made for the entire hazardous waste arisings in the County. Unlike non-hazardous waste hazardous waste is highly variable in its nature, each waste stream needing specific treatment. Northamptonshire produces amongst other wastes organic and inorganic chemicals, paints, varnishes, adhesives, inks, fly ash, heavy metal contaminated materials, oil and oil water mixes, solvents, contaminated packaging and PPE, healthcare and hazardous household wastes (Document 1005).
Statement on Northamptonshire MWDF Core Strategy 9 Representations 2293, 2325 and 2357 WS010001/ENRMF/CONSAPPCRAL 141 2.29. The management of these wastes needs a wide range of specialist techniques either to facilitate recovery or to render the waste suitable for landfill. These techniques generically include:-
Physico-chemical treatment Thermal destruction Thermal Separation Thermal Recovery Physical Separation Biological Treatment Immobilisation – Solidification/Stabilisation Immobilisation – Vitrification
2.30. It is unrealistic to expect to provide for every type of treatment on a County basis or even on a regional basis for some waste streams. For the reasons stated above, it is not considered that self sufficiency in Northamptonshire is deliverable. Such an approach is unsound as it is contrary to the approach set out in the Regional Waste Strategy.
2.31. The indicative capacity of 45-50,000 tonnes per annum for hazardous waste set out in Policy CS1 is based on out of date figures referred to in paragraph 6.25 of the Core Strategy and the latest statistics from the Environment Agency demonstrate that in 2007, 62,702 tonnes of hazardous waste was produced in Northamptonshire. These latest statistics should form the evidence base for the Core Strategy.
3. INSPECTOR’S QUESTIONS
3.1. Should the Core Strategy set out the circumstances in which national and regional scale facilities would be appropriate in Northamptonshire? (6.17) – Yes. At the moment, the Strategy states only that they will be appropriate if they are of a ‘specialised nature’ with ‘genuine specialised catchment areas’ with no explanation of what these phrases mean. In the context of hazardous waste facilities, it is considered that national and/or regional facilities may well be appropriate for the reasons stated above.
3.2. What is the basis of the catchment sizes that define National, Regional and Local/ sub regional facilities? Are they appropriate? Would the policy be
Statement on Northamptonshire MWDF Core Strategy 10 Representations 2293, 2325 and 2357 WS010001/ENRMF/CONSAPPCRAL 142 effective? (6.20) It is not clear from the Strategy how the catchment sizes have been arrived at and for the reasons stated above, Augean do not consider them to be appropriate or effective.
3.3. Is it reasonable to control the source of waste/ catchments for hazardous waste (6.21) No, for the reasons stated above.
3.4. Should the spatial strategy address the management of other waste types – e.g. hazardous waste (6.14) The spatial strategy for waste management relates to a network which serves Northamptonshire. Whilst any hazardous waste facility will in part serve the needs of Northamptonshire, it is also likely to serve the needs of the East Midlands region and perhaps adjacent regions. As such, the locational aspects of the spatial strategy are not likely to be appropriate for hazardous waste.
4. PROPOSED CHANGES TO CORE STRATEGY
4.1. Proposed change to paragraph 6.26
4.2. In the third sentence we propose the deletion of the words “and other parts of the East Midlands region”. We propose deleting the fourth sentence. In the fifth sentence, we propose rewording to state “any long term expansion of hazardous waste management at this location will have to be justified by a need and be considered in the context of both national and regional waste policy.”
4.3. Proposed change to Policy CS1
4.4. For the reasons given in Section 2, it is not considered appropriate to refer to the provision of facilities for hazardous waste management at County level. As such, it is proposed that the fourth bullet point should be deleted from Policy CS1.
4.5. We do not believe there is a need for a Policy on hazardous waste in the Core Strategy as this is adequately addressed in the East Midlands Regional Waste Strategy.
Statement on Northamptonshire MWDF Core Strategy 11 Representations 2293, 2325 and 2357 WS010001/ENRMF/CONSAPPCRAL 143 WS010001/ENRMF/CONSAPPCRAL 144 WS010001/ENRMF/CONSAPPCRAL 145
Northamptonshire Minerals and Waste Development Framework For Office Use Only
Ref No.
Date Received: Control and Management of Development DPD Date Acknowledged:
Proposed submission representation form Entered By:
PART A
Personal Details Agents Details (if applicable)
Name: Gene Wilson Name: Address: East Northants Resource Management Facility Address: Stamford Road Kings Cliffe PE8 6XX
Tel: Tel:
Fax: 01780 444901 Fax:
E-mail: E-mail:
Making your response
Please use a separate form for each representation that you submit. You are advised to keep your own copy of all the representations that you submit. Representation Forms should be returned to:
Control and Management of Development DPD Proposed Submission Planning Policy Northamptonshire County Council PO Box 163, County Hall Northampton NN1 1AX
Or emailed to: [email protected] or faxed to 01604 236065
Responses should be received no later than 5.00pm on Thursday 22 July 2010. Please note that the Inspector is not obliged to consider representations received after the closing date. Only those objectors whose objections are made within the consultation period will have a right to have their objections considered by the Inspector.
What will happen to my response?
All responses will be made available for public viewing. They cannot be treated as confidential. The Data Protection Act 1998 requires Northamptonshire County Council to notify you that the information you have given will be held in a computer database. The County Council will consider all representations that it receives during the period for representations.
If you have any questions regarding making your response please contact the Planning Policy team on (01604) 236014 or by e-mail: [email protected]
WS010001/ENRMF/CONSAPPCRAL 146
Signature: Date: 21 July 2010 PART B
Please use a separate sheet for each representation
1. Which paragraph or policy (or to the proposals map) of the Control and Management of Development DPD (Development Plan Document) does your representation relate to? Paragraph 3.3, 3.4, 3.30 Policy Proposals Map and 3.31
2. If your representation is an objection it must relate either to the Control and Management of Development DPD not complying with legal requirements, or it not being sound in relation to one of the Tests of Soundness. Is your representation concerned with: Not complying with legal requirements Not meeting the Test of Soundness X Please refer to the guidance notes at the rear of this form for further information on the Tests of Soundness.
3. If your representation is an objection because of the Control and Management of Development DPD not meeting a Test of Soundness, what Test of Soundness do you consider it fails? The justification test X The effectiveness test The test of consistency with national policy
4. Please make your comments below (they need to be made in reference to not meeting legal compliance or the Tests of Soundness). This should cover succinctly the evidence and supporting information necessary to support/justify your representation and any suggested changes you are proposing. After this stage further submissions will only be at the request of the examination Inspector. You can continue your comments on a separate sheet if necessary.
. Paragraphs 3.3, 3.4, 3.30 and 3.31: The planning permission for the only hazardous waste management facility in the County expires in 2013. The County has clearly demonstrated a continuing need for the facility through out the plan period to 2026 in respect of County arisings of hazardous waste (Core Strategy Table CS4) and recognised the national significance of the existing facility. Whilst it is accepted that there is a need for flexibility and a balance needs to be struck between identifying allocations and also allowing non-allocated sites to come forward as stated in paragraph 3.4, given the strategic nature of the facility, the identified need and the lack of alternative sites, it is considered that the proposal to not make an allocation for hazardous waste has not been justified nor does it accord with the national policy advice in PPS10 in respect of identifying land for waste management facilities. In these respects it is considered the plan is not sound.
WS010001/ENRMF/CONSAPPCRAL 147
Continued from previous page
5. If your representation is seeking a change to the Control and Management of Development DPD, what change do you think should be made? To correct the plan in recognition that there is is shortfall in hazardous waste management capacity and that provision should be made.
WS010001/ENRMF/CONSAPPCRAL 148
6. If your representation is seeking a change to the Control and Management of Development DPD, do you consider it necessary to present this to the inspector at a public session of the examination? Yes X No
7. If you wish to participate at a public session of the examination, please outline why you consider this to be necessary. To ensure that the complexities of hazardous waste management provision are properly understood
Further copies of this response form have been made available on our website at http://www.northamptonshire.gov.uk/en/councilservices/Environ/planning/policy/minerals/Pages/ContMa nage.aspx or hard copies can be sent on request.
You can forward your completed response forms (in Word .doc format please) by e-mail to [email protected]
WS010001/ENRMF/CONSAPPCRAL 149
Guidance notes for respondents
The importance attached to getting DPDs (Development Plan Documents) right is reflected in the fact that they are subject to independent examination. Given the potential impact of DPDs, it is vital that the plan is the most appropriate. This is partly why there is an independent examination to provide assurance. The examination of any DPD is concerned with the two separate matters of legal compliance and soundness.
Legal compliance
Under the Planning and Compulsory Purchase Act 2004 S 20(5)(a) an Inspector is charged with firstly checking that the plan has complied with legislation. This includes, in particular, checking that the DPD: . has been prepared in accordance with the Local Development Scheme and in compliance with the Statement of Community Involvement and the Regulations; . has been subject to sustainability appraisal; . has regard to national policy; . conforms generally to the Regional Spatial Strategy; and . has regard to any sustainable community strategy for its area (i.e. county and district).
Soundness
To be ‘sound’ a DPD should be justified, effective and consistent with national policy.
Justified means that the document must be: . Founded on a robust and credible evidence base Evidence gathered should be proportionate to the job being undertaken by the plan, relevant to the place in question and as up-to-date as practical having regard to what may have changed since the evidence was collected. . The most appropriate strategy when considered against the reasonable alternatives The ability to demonstrate that the plan is the most appropriate when considered against reasonable alternatives delivers confidence in the strategy. It requires the local planning authority to seek out and evaluate reasonable alternatives promoted by themselves and others to ensure that they bring forward those alternatives which they consider the LPA should evaluate as part of the plan-making process.
Effective means that the document must be: . Deliverable A DPD should show how it will be delivered and by whom, and when. This includes making it clear how infrastructure which is needed to support the DPD will be provided and ensuring that what is in the DPD is consistent with other relevant plans and strategies relating to adjoining areas. . Flexible A strategy is unlikely to be effective if it cannot deal with changing circumstances. The MWDF should look over a long time frame and be able to show how it will handle contingencies. . Able to be monitored A DPD must have clear arrangements for monitoring and reporting results to the public and civic leaders. Monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered. The delivery strategy should contain clear targets or measurable outcomes to assist this process.
The above is a summary of guidance based on the Government’s Planning Policy Statement (PPS) 12 on Local Spatial Planning.
WS010001/ENRMF/CONSAPPCRAL 150
Northamptonshire Minerals and Waste Development Framework For Office Use Only
Ref No.
Date Received: Control and Management of Development DPD Date Acknowledged:
Proposed submission representation form Entered By:
PART A
Personal Details Agents Details (if applicable)
Name: Gene Wilson Name: Address: East Northants Resource Management Facility Address: Stamford Road Kings Cliffe PE8 6XX
Tel: Tel:
Fax: 01780 444901 Fax:
E-mail: E-mail:
Making your response
Please use a separate form for each representation that you submit. You are advised to keep your own copy of all the representations that you submit. Representation Forms should be returned to:
Control and Management of Development DPD Proposed Submission Planning Policy Northamptonshire County Council PO Box 163, County Hall Northampton NN1 1AX
Or emailed to: [email protected] or faxed to 01604 236065
Responses should be received no later than 5.00pm on Thursday 22 July 2010. Please note that the Inspector is not obliged to consider representations received after the closing date. Only those objectors whose objections are made within the consultation period will have a right to have their objections considered by the Inspector.
What will happen to my response?
All responses will be made available for public viewing. They cannot be treated as confidential. The Data Protection Act 1998 requires Northamptonshire County Council to notify you that the information you have given will be held in a computer database. The County Council will consider all representations that it receives during the period for representations.
If you have any questions regarding making your response please contact the Planning Policy team on (01604) 236014 or by e-mail: [email protected]
WS010001/ENRMF/CONSAPPCRAL 151
Signature: Date: 21 July 2010 PART B
Please use a separate sheet for each representation
1. Which paragraph or policy (or to the proposals map) of the Control and Management of Development DPD (Development Plan Document) does your representation relate to? Paragraph Policy CMD2 Proposals Map
2. If your representation is an objection it must relate either to the Control and Management of Development DPD not complying with legal requirements, or it not being sound in relation to one of the Tests of Soundness. Is your representation concerned with: Not complying with legal requirements Not meeting the Test of Soundness X Please refer to the guidance notes at the rear of this form for further information on the Tests of Soundness.
3. If your representation is an objection because of the Control and Management of Development DPD not meeting a Test of Soundness, what Test of Soundness do you consider it fails? The justification test X The effectiveness test X The test of consistency with national policy
4. Please make your comments below (they need to be made in reference to not meeting legal compliance or the Tests of Soundness). This should cover succinctly the evidence and supporting information necessary to support/justify your representation and any suggested changes you are proposing. After this stage further submissions will only be at the request of the examination Inspector. You can continue your comments on a separate sheet if necessary.
. Policy CMD2: Augean is concerned that whilst there are statements regarding hazardous waste management in the plan (paragraphs 3.30 to 3.32) there is no specific policy. The non-inert waste Policies CMD1 and CMD2 do not recognise the specialist nature of hazardous waste, the regional and national significance of hazardous waste or accurately reflect the statements in paragraphs 3.30 to 3.32. It is considered that the policies CMD1 and CMD2 should be amended to allow for the specialist nature of hazardous waste facilities or a specific policy included in the plan. We draw to your attention that the lack of a policy conflicts with paragraph 6.29 of the Core Strategy which indicates that a specific policy would be included in the CMD document to deal with the complexities of the hazardous waste planning.
Any policy requirement on hazardous waste management facilities should avoid constraining the facilities in a manner that will distort the market. The market for hazardous waste is national and constraints imposed on sites on one side of the country can result in market shifts the other side of the country with consequent rises in transport of waste. Given the limited number of hazardous waste facilities, their specialist nature and the wide range of wastes generated from a wide geographic area it
WS010001/ENRMF/CONSAPPCRAL 152
will be difficult to impose effective conditions on any planning consent that can enforce restrictions on the sources of waste. Nationally based drivers such as landfill Tax and landfill restrictions affecting all sites at once are being effective in ensuring that increasing amounts of treatment are being achieved and that wastes are managed in the nearest available facility.
Continued from previous page
5. If your representation is seeking a change to the Control and Management of Development DPD, what change do you think should be made? The provision of a specific policy for the management of hazardous wastes
WS010001/ENRMF/CONSAPPCRAL 153
6. If your representation is seeking a change to the Control and Management of Development DPD, do you consider it necessary to present this to the inspector at a public session of the examination? Yes X No
7. If you wish to participate at a public session of the examination, please outline why you consider this to be necessary. To ensure that the complexities of hazardous waste management are debated and to assist the inpsector
Further copies of this response form have been made available on our website at http://www.northamptonshire.gov.uk/en/councilservices/Environ/planning/policy/minerals/Pages/ContMa nage.aspx or hard copies can be sent on request.
You can forward your completed response forms (in Word .doc format please) by e-mail to [email protected]
WS010001/ENRMF/CONSAPPCRAL 154
Guidance notes for respondents
The importance attached to getting DPDs (Development Plan Documents) right is reflected in the fact that they are subject to independent examination. Given the potential impact of DPDs, it is vital that the plan is the most appropriate. This is partly why there is an independent examination to provide assurance. The examination of any DPD is concerned with the two separate matters of legal compliance and soundness.
Legal compliance
Under the Planning and Compulsory Purchase Act 2004 S 20(5)(a) an Inspector is charged with firstly checking that the plan has complied with legislation. This includes, in particular, checking that the DPD: . has been prepared in accordance with the Local Development Scheme and in compliance with the Statement of Community Involvement and the Regulations; . has been subject to sustainability appraisal; . has regard to national policy; . conforms generally to the Regional Spatial Strategy; and . has regard to any sustainable community strategy for its area (i.e. county and district).
Soundness
To be ‘sound’ a DPD should be justified, effective and consistent with national policy.
Justified means that the document must be: . Founded on a robust and credible evidence base Evidence gathered should be proportionate to the job being undertaken by the plan, relevant to the place in question and as up-to-date as practical having regard to what may have changed since the evidence was collected. . The most appropriate strategy when considered against the reasonable alternatives The ability to demonstrate that the plan is the most appropriate when considered against reasonable alternatives delivers confidence in the strategy. It requires the local planning authority to seek out and evaluate reasonable alternatives promoted by themselves and others to ensure that they bring forward those alternatives which they consider the LPA should evaluate as part of the plan-making process.
Effective means that the document must be: . Deliverable A DPD should show how it will be delivered and by whom, and when. This includes making it clear how infrastructure which is needed to support the DPD will be provided and ensuring that what is in the DPD is consistent with other relevant plans and strategies relating to adjoining areas. . Flexible A strategy is unlikely to be effective if it cannot deal with changing circumstances. The MWDF should look over a long time frame and be able to show how it will handle contingencies. . Able to be monitored A DPD must have clear arrangements for monitoring and reporting results to the public and civic leaders. Monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered. The delivery strategy should contain clear targets or measurable outcomes to assist this process.
The above is a summary of guidance based on the Government’s Planning Policy Statement (PPS) 12 on Local Spatial Planning.
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This statement has been prepared following the exchange of e-mails between The County and Augean dated 19th October, 22nd October and the 26th October 2010. It is an updated version of the proposed changes suggested to the County submitted on the 22nd October and takes into account the comments of the County in the e-mail of 26th October providing Augean’s further reasoning for the need for the changes.
CMD DPD
The County has on second thoughts suggested that any changes to the CMD should be made at the CMD examination process. Augean considers that the Locations Document and the CMD are inextricably linked in respect of the matter of provision for hazardous waste and that the issue should logically be resolved now.
The County has suggested that provision for hazardous waste management can be clarified by making clear how the commitments from the WLP carry forward to the MWDF and accordingly has proposed amendments to the Locations Document. Augean considers that these proposals could assist in resolving the issue of soundness in respect of provision for hazardous waste but is concerned that statements in the CMD could potentially undermine the proposed solution. Augean has accepted the change to the CMD as suggested by the County in the e-mail of 19th October and proposed the following additional amendments to the CMD to ensure that the provision for hazardous waste management is secured.
(i) At paragraph 3.34 add the following sentence- "However, the [ENRMF/Kings Cliffe] site is identified as a commitment in the Locations for Waste Development DPD."
The purpose of this amendment is to ensure clarity.
(ii) Delete footnote 4 “Subject to the existing planning permission”. Augean considers that this footnote is unnecessary. The planning permission is a matter of fact and the point that the land must be used in accordance with the consent self evident. Augean has concerns that this footnote could be interpreted as suggesting the commitment is limited to the life of the site that is 2013. On this basis the proposals to make clear, in the locations document, the status of commitments from the WLP will not result in provision for hazardous waste management and the plan will therefore remain unsound.
Locations DPD
(i) Add a bullet point to paragraph 2.2 to state "identify existing commitments for waste-related developments"
If commitments are to form one of the means by which provision is made provision it should be made clear in the text.
Add new sub-section after paragraph 2.16:
Commitments
2.17 In addition to specific allocations, this DPD also includes existing commitments (i.e. sites with planning permission or equivalent) for waste-related development. These commitments make a
\MAIN\16423690.1 1 WS010001/ENRMF/CONSAPPCRAL 192 fundamental contribution in delivering the waste infrastructure that will enable the treatment of Northamptonshire’s waste to 2026 and for the MWDF to meet its objectives. It should be noted that the Core Strategy contains a policy (Policy CS11) that seeks to safeguard waste sites from alternative non-waste uses.
The tables in Appendix 2 identify commitments in the county at the commencement of the plan period (January 2006) for:
- Non-inert waste management
- Inert waste management
- Non-inert waste disposal
- Inert waste disposal
- Hazardous waste management and disposal
- Waste water treatment
Proposals for extensions or change in waste-related development on the committed sites (and on other sites on which planning permission for waste use has been subsequently granted) must be in accordance with the CMD policies. However, it is accepted that being commitments confers a favourable status on these sites for a continuation of a waste use where this meets the intent of the MWDF core strategy and policies and is also in accordance with national planning policy.
The proposed amendments are to ensure that the contributions of the Commitments to provision are clear.
Add new Appendix 2 below (and in doing so renumber existing Appendix 2 as Appendix 3):
APPENDIX 2: SCHEDULE OF COMMITMENTS FOR WASTE USE
Commitments in the county at the commencement of the plan period (January 2006) are set out in the schedule below:
- Non-inert waste management
- Inert waste management
\MAIN\16423690.1 2 WS010001/ENRMF/CONSAPPCRAL 193 - Non-inert waste disposal
- Inert waste disposal
- Hazardous waste management and disposal
- Sewage and waste water treatment
Note: The location of existing commitments are not indicated on the MWDF Proposals Map DPD. This information can be viewed in hardcopy upon request to the County Council or via the County Councils MWDF online map interface (http://northamptonshire.devplan.org.uk/document.aspx?display=maps).
\MAIN\16423690.1 3 WS010001/ENRMF/CONSAPPCRAL 194 Northamptonshire Minerals and Waste Development Framework For Office Use Only Ref No. Draft Revised Development and Implementation Principles Supplementary Planning Document Date Received: Date Acknowledged: Form for Making Representations Entered By:
Personal Details Agents Details (if applicable) Name: Name: Gene Wilson Augean Plc Address: Address:
East Northants Resource Management Facility Stamford Road Kings Cliffe PE8 6XX Tel:
Tel: 01780 444900 Fax:
Fax: 01780 444901 E-mail:
E-mail:
Returning Your Representation Form
This representation form should be returned to:
Development and Implementation Principles SPD Consultation Planning Services Northamptonshire County Council PO Box 163, County Hall Northampton NN1 1AX
Or emailed to: [email protected] or faxed to: 01604 236065
Representations should be received no later than 5.00pm on Thursday 28 July 2011
What will happen to my representation?
. All representations will be made available for public viewing. They cannot be treated as confidential. . The Data Protection Act 1998 requires Northamptonshire County Council to notify you that the information you have given will be held in a computer database. . The county council will consider all representations that it receives during the consultation period.
If you have any questions regarding making your representation please contact Planning Services- Minerals and Waste Policy on (01604) 236014 or by e-mail: [email protected]
Signature: Date: Augean Plc 28 July 2011
WS010001/ENRMF/CONSAPPCRAL 195 DEVELOPMENT AND IMPLEMENTATION PRINCIPLES FOR GENERAL DEVELOPMENT
1. Do you agree with the guidance, as revised, on development related waste minimisation? Yes No If not, how should this part of the SPD be changed?
2. Do you agree with the guidance, as revised, on incorporating waste design and neighbourhood facilities with other development? Yes No If not, how should this part of the SPD be changed?
3. Do you agree with the new section on preventing land use conflict and the guidance provided? Yes No If not, how should this part of the SPD be changed?
WS010001/ENRMF/CONSAPPCRAL 196 DEVELOPMENT AND IMPLEMENTATION PRINCIPLES FOR MINERALS AND WASTE DEVELOPMENT
4. Do you agree with the new section on catchment areas for waste management facilities and the guidance provided? Yes No If not, how should this part of the SPD be changed? x
See attached sheet
5. Do you agree with the guidance, as revised, on the sensitive design of minerals and waste development? Yes No If not, how should this part of the SPD be changed?
6. Do you agree with the guidance, as revised, on responsible stewardship and restoration? Yes No If not, how should this part of the SPD be changed?
WS010001/ENRMF/CONSAPPCRAL 197 MONITORING THE SPD
7. Is the proposed monitoring framework appropriate and relevant, particularly in relation to the SPD objectives? Yes No If not, how should this part of the SPD be changed?
8. Do you have any other comments regarding the draft SPD? Yes No
(please continue overleaf if required)
WS010001/ENRMF/CONSAPPCRAL 198 (continued from overleaf)
WS010001/ENRMF/CONSAPPCRAL 199 Draft Revised Development and Implementation Principles SPD
In relation to question 4 of the representation form, Augean does not agree with certain aspects of the new section on catchment areas.
The issue of catchment areas has been considered at a number of stages in the preparation of the MWDF.
Core Strategy
The Core Strategy deals with catchment areas at paragraph 4.16 and states:-
“The Core Strategy recognises that waste management is becoming more specialised and is also a higher value industry than previously. It is not appropriate to oppose facilities serving wider catchments when other industries and commercial enterprises are not so constrained. However, in the wider interests of sustainability, it is not envisaged that Northamptonshire should take on a role as a key sub-national location for waste management facilities.”
The Inspector also considered the issue of catchment areas in his Report on the Core Strategy and in particular noted at paragraph 1.12 that the Core Strategy would be sound provided that a number of changes were made including “deletion of the indicative catchment sizes for waste management facilities in the strategy for waste disposal”.
The Inspector dealt more substantively with catchment areas at paragraph 6.14 onwards and raised a number of concerns namely:-
At paragraph 6.14 the Inspector raises concern about the use of specific radii to define the different catchment areas identified. He states that NCC has little or no evidence to support its particular choice of catchment sizes; and it has confirmed that no detailed technical work was undertaken to arrive at them. This position remains the same.
At paragraph 6.18 he states “I am satisfied that catchments can, in principle, be a factor to be taken into account in determining the most appropriate location for waste development. They can serve to minimise unnecessary transport and thereby further the aims of sustainability. … But other factors, not least the type of waste; the type of facility; the transport mode, the physical relationship to main transport links and the position occupied by the facility in the wider network can also affect sustainability and choice of location. Moreover, a crude radius is not necessarily a good measure of accessibility or sustainability; and the size of a catchment may vary depending on the circumstances…Great care therefore needs to be taken with the use of catchments as a tool for locational guidance. Even so, subject to the deletion of the specific definitions from the Plan, I am content that the policy should have regard to catchments expressed in general terms, which may then be refined in the CMDDPD having regard to the full range of variables. “
In relation to hazardous waste and the ENRMF, the Inspector deals with the issue of catchment area at paragraph 6.21 and states, “The facility is specialised and of national importance, and since there are so few of this type in the country (indeed it is the only one of its type in the East Midlands, East of England, South East and London Regions), it is likely to remain so in the future. Artificially restricting the catchment would be contrary to the guidance of the Regional Waste Strategy 2006 (RWS) [CD203], which (Policy RWS 1.6) says that waste planning authorities should make provision for hazardous waste transfer, treatment and disposal capacity in the context of regional and national needs. Further, a limited catchment could make the facility economically unviable. Therefore, without good evidence, it is inappropriate for the CS to take this approach. And second, in common with the approach to catchments generally, there is no basis for the 50 mile radius, which in any
\MAIN\18146170.1 1 WS010001/ENRMF/CONSAPPCRAL 200 case would be unacceptable for a facility of national importance. This section of the Plan is therefore unsound as submitted. “
On the basis of the Inspector’s conclusions, the Core Strategy was amended to remove all references to specific radii for defining catchment areas.
Control of Management and Development Plan
Catchment areas are dealt with at paragraph 3.6 onwards in the Plan. Again the issue of catchment areas was dealt with by the Inspector following a number of representations on the Proposed Submission document. It was a different Inspector to the one who dealt with the Core Strategy.
The Inspector raised a number of questions on catchment areas in advance of the Examination in Public. He asked whether defining the market areas should be left to the SPD and if so how would they be defined (Q2.2 on Issue 2 Definition of Catchment Areas for waste development). In response the Council accepted that it should be left to the SPD and stated that the “use of such mechanisms within the MWDF is not meant to be overly prescriptive but it is felt necessary to address monitoring and capacities.” The Council go on to state that the SPD will include a more detailed definition of each catchment area and relate this to geographical representations “but not to give specific catchment distances or boundaries that should be used.”
The Inspector makes the following points in his Report:-
At paragraph 15, he deals with national policy and states, “The idea of identifying catchment areas seems to draw on the principle that, for reasons of sustainability, the transportation of wastes should be minimised (ie minimisation of „waste miles‟) and, in particular, to discourage the importation of waste into the county. Whilst these may be understandable aims they are not rooted in national guidance on waste management and disposal. PPS10 only seeks to ensure that waste is disposed of as close as possible to the source2; PPS10 does not seek to control the movement of waste prior to disposal. “
He goes on at paragraph 16 to consider PPS1 and states, “Looking at sustainability, whilst Planning Policy Statement 1 Planning for Sustainable Development (PPS1) promotes sustainable development and the optimal use of resources, and Planning Policy Guidance 13 Transport (PPG13) seeks to minimise travel, there has to be a balance struck between minimising „waste miles‟, self-sufficiency, the multiplicity of waste handling streams, specialist waste processes, driving waste up the hierarchy, and commercial viability. One factor alone cannot control policy formulation or the implementation of waste management policy through planning permissions. Inevitably, a compromise has to be recognised which is both sustainable and pragmatic. “
At paragraph 17 he considers the commercial and practical aspects and states, “Waste processing is a commercial activity and the various streams – sources and intermediate products – are not readily susceptible to geographical restrictions if the processing plant is to work efficiently and to maximum benefit. A geographical limit may not be appropriate for all stages of waste management processing; unsorted collected materials will produce sorted or graded streams, which are likely to need to be bulked up with similar streams from other sources in order to be further processed into useable products. That is, whilst it might just about be feasible to identify catchment areas for the collection or reception of waste, thereafter it would be both difficult and inappropriate to seek to geographically constrain subsequent treatment processes.”
At paragraph 20 he states, “Furthermore, as waste processing is a commercial operation (as acknowledged under Objective 3 of the Core Strategy), it would be unreasonable for a
\MAIN\18146170.1 2 WS010001/ENRMF/CONSAPPCRAL 201 planning authority to seek to limit an area of operations relating to a particular site, restricting trade and potentially constraining competition.”
On the issue of a planning condition he states at paragraph 22, “Having regard to the six tests in Circular 11/95, if a catchment area restriction relating to haulage distance for waste from its arising is to be imposed through a planning condition (either directly or indirectly through requiring compliance with information supplied to support a planning application), it is most unlikely that such a condition would be enforceable. The origin of waste passing through various processing streams from collection, bulking up, sorting and further processing would be very hard to track. “
At paragraph 25 he states that “imposing catchment areas could lead to uneconomic and inefficient waste management; neither of which would accord with the principles of sustainability. This would conflict with the guidance at paragraphs 18 and 25 of PPS10 which advise that local policies should not stifle innovation nor should decisions prejudice movement up the waste hierarchy.”
He concludes at paragraph 26 that “seeking to impose catchment areas is prima facie in conflict with national policy, as expressed in PPS10 – or at least, not supported by it - and the guidance in Circular 11/95. Nothing put forward either in the DPD or in the CS supports a contention that the CMD policy is in response to a specific local requirement identified within Northamptonshire which is supported by evidence. In which case, the CMD would be unsound if it were adopted in its submitted form.”
At paragraph 27 the Inspector acknowledges that “whilst it may be reasonable for an applicant to identify the likely extent of the market area for a proposed facility or operation, it would be unreasonable to take this forward to a fixed constraint as its geographical catchment area. The initial assessment would inform a decision on whether the scheme would be of an appropriate size or scale for the intended location, or if it accorded with the hierarchy (or scale of operation) set out at Box CS3 of the Core Strategy, but thereafter it ought to be a commercial decision of the operator to ensure a sufficient supply is maintained to make the operation economic, having regard to the competition in a locality and technological changes in the waste processing industry.”
At paragraph 33 he concludes that “whilst it is reasonable to require a developer to show the envisaged catchment (or market) area for a proposed site, this should only be indicative, to allow for fluctuations in prospective sources of waste or variations in commercial contracts which may arise subsequent to a grant of planning permission. Having regard to the tests given in the Annex to Circular 11/95, it would be unreasonable to seek to control the commercial contracts of a company through a planning condition – which is the implication underlying an intention to rigidly restrict a company‟s operating area according to a close, map-based, identification of the catchment area of a plant or site.”
Finally at paragraph 34 he concludes that “an indicative plan would provide enough information to show the proposed scale of the proposed operation, its intensity in terms of activity, traffic generation etc., and the potential to interfere with neighbouring land uses, but flexible enough to allow for variations in commercial decisions on contracts, and operating practices.”
SPD
In light of the unequivocal conclusions of both Inspectors on the Core Strategy and the Control and Management of Development Plan on the issue of catchment areas as referred to above, it is surprising that the Council has still sought to impose maximum radii limits to rigidly define catchment
\MAIN\18146170.1 3 WS010001/ENRMF/CONSAPPCRAL 202 areas in Table SPD 3. For the reasons outlined by the Inspectors above, these limits should be removed. As part of the CMD Examination in Public the Council accepted that the use of catchment areas should not be ‘overly prescriptive’ and that ‘specific catchment distances’ should not be used.
At paragraph 3.8, the SPD requires that intended catchment areas should be ‘clearly shown on a map’ and in the final bullet point provides that such maps are to be of an appropriate size, “to allow the WPA to determine the areas within, and boundary of, the catchment area”. At paragraph 3.9 the second sentence provides that “permitted development is to be undertaken in accordance with the approved catchment area(s) and accompanying maps(s).” At paragraphs 27, 33 and 34 of the Inspector’s Report on the CMD, the Inspector gives clear advice that whilst it may be reasonable to ask a developer to give details of an envisaged catchment area, this should only be indicative and it would be unreasonable to take this forward to a fixed constraint as its geographical catchment area. The Inspector therefore imposed a change to the CMD to introduce the word “indicative” before “map” at paragraph 3.11. The intention was for the SPD to provide a flexible approach to catchment areas and it is considered that the current wording at 3.8 and 3.9 is actually more restrictive than the adopted Core Strategy and CMD. We consider that any references to a ‘map’ in paragraphs 3.8 and 3.9 should be amended to “indicative map”. Further, given that such maps are only intended to be indicative, we consider that the wording in the final bullet point is inappropriate and recommend deletion of the words “to allow the WPA to determine the areas within, and boundary of, the catchment area”.
The Inspector for the CMD also considered whether imposing a planning condition to restrict waste inputs by reference to a catchment area would meet the test of Circular 11/95 and he concluded at paragraphs 22 and 33 that it would not and further, that such a condition would be difficult to enforce. We concur with the Inspector and consider that the standard condition referred to at paragraph 3.12 entitled “compliance with identified catchment areas” should be deleted. Such a condition would also be inconsistent with paragraph 3.13 of the CMD which states that “catchment areas are not intended to form a development constraint.” In terms of the second standard condition proposed at paragraph 3.12, whilst it may be appropriate to have a monitoring report requirement for waste inputs to a particular site this should not be by reference to ‘compliance with catchment area’ and should be amended accordingly.
Hazardous Waste
Both the Core Strategy (paragraph 4.16 and 6.27 to 6.28) and the CMD (paragraph 3.8) recognise the specialised nature of disposing of hazardous waste and the need for a continued national catchment for the ENRMF in Kings Cliffe.
Paragraph 2.3.6 of the draft National Policy Statement on Hazardous Waste considers the proximity principle in respect of hazardous waste and acknowledges that “for some hazardous wastes arising in relatively small quantities, and requiring specialist treatment there will only be one or two facilities in each Member State able to deal with the waste, and such waste might therefore have to travel further to such a facility.”
The Inspector on the Core Strategy considered the issue of a catchment area for the ENRMF at paragraph 6.21 and was very clear that it was wholly inappropriate to impose any restriction as this may make the facility economically unviable. As such he concluded that “there is no basis for the 50 mile radius, which in any case would be unacceptable for a facility of national importance”. For the same reasons it is considered that imposing an arbitrary maximum radii of 127 miles for a national catchment area in Table SPD3 is not appropriate.
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