1 APPENDIX 1 Summary of Representations to the Consultation
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APPENDIX 1 Summary of Representations to the Consultation on the Waste Local Plan, Employment Land Areas of Search Supplementary Planning Document Responses are in plan order Plan Part Comment Name Date Summary of Representation HCC Response ID: Received General WLPSPD2 Office of Rail 17-06-2015 Have no comments to make on The Office of Rail and Road and Road the SPD. (formerly known as the Office of Confirmed that the ORR only Rail Regulation) is a statutory requires to be consulted if the consultee and is listed as an plan mentions or impacts on a organisation which the Waste mainline railway, tramway or the Planning Authority must engage London Underground network. with under the ‘duty to co- operate.’ General WLPSPD8 Cambridgeshire 01-07-2015 Confirmed that Cambridgeshire Comment noted. No response County Council County Council have no necessary. comments to make on the SPD. General WLPSPD9 Natural England 06-07-2015 Welcomes the production of the Comment noted. No response SPD and, in particular the necessary. inclusion of the ‘traffic light’ coding of each ELAS for size, groundwater and access issues, which should provide increased clarity for applicants. General WLPSPD10 Highways 08-07-2015 Confirmed that Highways Comment noted. No response 1 England England have no comments to necessary. make on the SPD. General WLPSPD11 Aylesbury Vale 08-07-2015 Confirmed that Aylesbury Vale Comment noted. No response District Council District Council have no necessary. objections to the SPD. General WLPSPD13 Welwyn Hatfield 08-07-2015 The SPD should be amended to The National Planning Practice Borough refer to the relevant policy that it Guidance (NPPG) which was Council relates to and to explain how it launched in March 2014 states relates to Appendix A of the that SPDs should build upon and adopted plan. provide more detailed advice or guidance on the policies in the Local Plan. The purpose of the SPD is to provide further planning guidance into the suitability of waste related development on all of the 60 ELAS identified in the Local Plan. Paragraph 1.3 has been expanded to make it clear that the SPD relates to Policy WSA2 in the Waste Site Allocations document, as this is a criteria based policy, whereby proposals for waste development that are submitted on the ELAS will be judged against, along with other relevant policies in the Waste Local Plan. General WLPSPD12 Aldenham 09-07-2015 Confirmed that Aldenham Parish Comment noted. No response 2 Parish Council Council have no comments to necessary. make on the SPD. General WLPSPD29 Historic England 10-07-2015 Content with the historic The Waste Planning Authority environment references in many has checked whether any of the of the individual site briefs. ELAS are situated in close However, there are a few cases proximity to conservation areas where references to heritage and amendments have been assets are lacking, which have made accordingly. been addressed in separate comments. It is not clear whether conservation areas have been identified in every case, and we advise that this is checked. General WLPSPD34 Environment 10-07-2015 Confirmed that the Environment Comment noted. No response Agency Agency has no site specific necessary. comments to make, as any concerns can be covered through the general ELAS Waste Brief in the Waste Site Allocations document. General WLPSPD35 Marine 10-07-2015 Recommends that reference to It is considered that this is an Management marine aggregates be included issue for the Minerals Local Plan Organisation within the document. Land rather than the waste planning locked counties that include document. Hertfordshire, may have to consider the role that marine sourced supplies play. 3 General WLPSPD36 HCC Historic 10-07-2015 Wording should be added within The requirement for a desk Environment the SPD to state that based archaeological impact undesignated heritage assets assessment, which is outlined in should also be considered and the ‘Detailed Assessments the potential for yet unknown Required’ section of the general heritage assets to exist within ELAS waste brief in Appendix A allocations acknowledged. of the Waste Site Allocations It should not be assumed that if document, does not consider the a site is not within an Area of potential for as yet unknown Archaeological Significance that heritage assets. it has no potential to contain An additional sentence has heritage assets. therefore been added to each key planning issues section, stating Where the need for Archaeological Desk-Based the need to consider the potential Assessments is mentioned, this for as yet unknown heritage should be expanded to consider assets within each ELAS. the potential for as yet unknown heritage assets. General WLPSPD37 CPRE Herts 13-07-2015 Changes to planning legislation There is recognition within the may mean that there is an SPD (paragraphs 4.7 and 4.8) of increasing prospect of waste the possibility of buildings within management facilities being current employment land development adjacent to changing to residential uses, residential areas, or where under the government’s new residential areas are being permitted development rights. developed. These paragraphs clearly state that proposals for new waste The key planning issues section for ELAS187-Former Sunnyside management facilities should Nursery should be amended to take into consideration proposals for residential development within 4 state that new housing the ELAS or in close proximity to development has been built on it. the opposite of the A10, facing There is also recognition within ELAS187. the general ELAS waste brief in Appendix A of the Waste Site Allocations document of the need to consider the location of sensitive receptors. The key planning issues section for ELAS187 has been amended to reflect the development of new housing that is within 100m to the east of ELAS187. General WLPSPD38 North Mymms 16-07-2015 Will not support any more The acceptability of the 60 ELAS Parish Council applications for waste as suitable locations for waste management within the parish, management development was due to noise, nuisance, traffic established during the and other problems. examination of the now adopted Remoter locations off major Waste Site Allocations document. transport routes would be better. Issues concerning noise, traffic, hours of operation, dust etc, can be mitigated against through the imposition of suitable planning conditions. General WLPSPD50 HCC 24-07-2015 Confirmed that HCC Comment noted. No response Development Development Services have no necessary. Services comments to make on the SPD. Has provided some general observations for some of the 5 ELAS that may wish to be considered. Paragraph 2.8 WLPSPD3 Hertsmere 24-06-2015 The paragraph should refer to The Waste Planning Authority Borough the 2012 Regulations and not has amended the wording of Council the 2012 Act. paragraph 2.8, in order to reflect that consultation on the SPD has now taken place. Paragraph WLPSPD4 Hertsmere 24-06-2015 The following sentence should Agreed. This has been added to 2.19 Borough be added: the end of paragraph 2.19. Council “All local plans (and development plan documents) will be material planning considerations and will therefore be taken into account after formal publication.” Paragraphs WLPSPD14 Welwyn Hatfield 08-07-2015 Paragraph 2.23 should be Paragraphs 2.23-2.26 have been 2.23-2.26 Borough amended to refer to all policies deleted, as the wording in Council in the Waste Site Allocations paragraph 2.22 sufficiently states document which would apply to the county council’s approach to the determination of a windfall dealing with waste management application and to remove the applications submitted on other inference that they would not employment land. have to demonstrate why Extra wording has been added at proposals could not be provided the end of paragraph 2.22. on an allocated site. Paragraphs 2.24-2.26 should be deleted as they set out criteria for sites which are not the 6 subject of this SPD. The following wording should be added at the end of paragraph 2.22: “….and therefore are not the subject of this SPD.” 3.0 Traffic WLPSPD15 Welwyn Hatfield 08-07-2015 The traffic lights do not provide The purpose of the traffic light Light Ranking Borough any clarity on where certain ranking is to provide a snap shot Council types of waste management of the size, access and facility will not be appropriate groundwater issues that affect and where there would be each ELAS. This is detailed in restrictions on scale. section 3 of the SPD and on p.23 No further detail is given how in the adopted Waste Site the traffic light ranking will work Allocations document. in practice and could be It is considered that section 3 misleading as three green traffic provides sufficient detail into the lights could be construed that purpose of the traffic light ranking there are no major issues. and how they will be used by Further detail needs to be added applicants when assessing the to clarify how the traffic light suitability of proposals and ranking will work and to ensure Development Management in the that other planning issues of determination of relevant equal significance are not planning applications. Paragraph overlooked. 3.15 has been added in order to clarify that other planning issues should that are not covered by the traffic light ranking should also be assessed at the planning application stage. Paragraph 4.2 WLPSPD16 Welwyn Hatfield 08-07-2015 The recognition of the potential Comment noted. No response 7 Borough for adverse cumulative impacts necessary. Council of waste management development on the local area is supported. Paragraph 4.4 WLPSPD17 Welwyn Hatfield 08-07-2015 Objects to the approach that the The Waste Planning Authority Borough SPD does not provide more considers that there is sufficient Council specific information as to the detail within the key planning type of development that would issues sections for each ELAS, be suitable within each and within the Waste Brief for all individual ELAS.