LONDON BOROUGH OF SUTTON
PLANNING ADVISORY GROUP
TUESDAY, 8TH DECEMBER, 2009
7.30 pm at the
Civic Offices, St Nicholas Way, Sutton
To all members of the Planning Advisory Group:-
Chair: Councillor Lyn Gleeson Councillors: Richard Butt, Colin Hall, John Leach and Graham Whitham
Substitute Councillor Paddy Kane, Councillor Janet Lowne and Councillor Tony Members: Shields
Paul Martin Chief Executive Civic Offices St Nicholas Way SUTTON SM1 1EA
27 November 2009
Enquiries to: Sue Sheppard, Principal Committee Manager Tel. 020 8770 5116 Email [email protected]
Copies of reports are available in large print on request
CIVIC OFFICES, SUTTON GROUND FLOOR MEETING ROOMS
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2 Reminder – Declaration of Interests
Members should consider the following interests and whether they have any they should declare.
Personal interests :
Where it might reasonably be regarded that a matter will affect the well-being or financial position of you, a member of your family, any person with whom you have a close association, or any person or body with which you or they are involved or in which they have a relevant beneficial interest, to a greater extent than the majority of people affected by the decision.
In this case you should declare the interest and state the nature of it.
Personal and Prejudicial Interests :
Where a personal interest is thought to be so significant that a member of the public, with knowledge of the facts, would consider it likely to prejudice the member’s judgment of the public interest.
In this case you should declare the interest, state the nature of it, and leave the meeting room.
Further information can be found in the Council's Code of Conduct. If you are in any doubt as to whether you have an interest you should seek advice before the Committee meeting from either Richard Shortman or Sanjay Prashar.
If, during the course of the Committee meeting, you consider you may have an interest you should always declare it.
AGENDA
1. APOLOGIES FOR ABSENCE & NOTIFICATION OF SUBSTITUTES
2. MINUTES OF THE PREVIOUS MEETING (Pages 1 - 4)
Held on 6 October 2009
3. JOINT WASTE DEVELOPMENT PLAN DOCUMENT - REPORT ON CONSULTATION ON PREFERRED SITES & POLICIES AND NEXT STEPS (Pages 5 - 266)
Report of Executive Head of Planning &Transportation
4. SUTTON TOWN CENTRE HEALTH CHECK
3 Report of Executive Head of Planning & Transportation
5. CONSULTATION RESPONSE TO MAYOR'S REPLACEMENT STRATEGIES - DRAFT LONDON PLAN; DRAFT TRANSPORT STRATEGY; DRAFT ECONOMIC DEVELOPMENT STRATEGY (Pages 267 - 274)
Report of Executive Head of Planning & Transportation
6. THE 2009 FIVE-YEAR HOUSING LAND SUPPLY ASSESSMENT (Pages 275 - 294)
Executive Head of Planning & Transportation
7. ANNUAL MONITORING REPORT 2008/09 - SUMMARY LEAFLET (Pages 295 - 298)
Report of Executive Head of Planning & Transportation
8. DATE OF NEXT MEETING - 7:30PM ON TUESDAY, 19 JANUARY 2010
9. ANY URGENT ITEMS BROUGHT FORWARD AT THE DIRECTION OF THE CHAIR, WHO HAS AGREED THE REASON FOR URGENCY
4 Page 1 Agenda Item 2 Planning Advisory Group 6 October 2009
PLANNING ADVISORY GROUP
6 October 2009 at 7.30 pm
MEMBERS Councillor Lyn Gleeson (Chair), and Councillors Richard Butt, (ALL Colin Hall, John Leach and Graham Whitham PRESENT):
ALSO Sally Blomfield, Duncan Clarke, Keith Fraser, Darren Richards, Sue ATTENDING: Sheppard, Patrick Whitter and Jeff Wilson.
46. APOLOGIES
Apologies for lateness were received from Cllr Richard Butt.
47. MINUTES OF THE PREVIOUS MEETING
The Minutes of the meeting held on 15 September 2009 were agreed as a correct record, and signed by the Chair.
48. CORE PLANNING STRATEGY - ADOPTION
Further to Minute 44/09, a final draft of the Core Planning Strategy was presented for approval for adoption. The document now incorporated the recommendations in the Inspector’s Report, which were binding.
The Inspector had concluded that, overall, the Strategy was sound, subject to a number of changes. The key change was the deletion of references to the de- designation and development of Metropolitan Open Land (MOL) in the Beddington, Hackbridge and Kimpton areas. Other key headline conclusions included:
• Agreement over the proposed distribution of housing across the Borough in accordance with Policy PMP1 of the Strategy and that this should be capable of delivery; • That Sutton’s approach to housing density set out in BP1 is sound and based on evidence set out in the Characterisation Report of Studies and the Proposed Character of Proposed Sustainable Residential Quality Areas; • That, subject to making explicit cross references to the policy considerations on negotiating affordable housing set out in the London Plan, the overall targets and thresholds for affordable housing are viable and satisfactory and therefore Policy BP2 is sound; • That the employment policies of the Strategy are sound and the Borough’s employment allocations should continue to be safeguarded against inappropriate development; • Agreement that the Strategy sets out a framework for improving Sutton Town Centre which deals adequately with the objective of seeking to address existing problems of leakage to other centres; • Supporting the Strategy’s approach towards the hierarchy of retail centres; • Agreement that it is appropriate and ‘sensible’ for the Strategy to continue to safeguard the Tramlink route; • That the Strategy’s approach towards the development of Hackbridge as a District Centre is an appropriate and achievable part of the area’s regeneration package; • That the Council’s approach towards achieving environmental sustainability, as set out in Policy BP6 on ‘One Planet Living’ and the supporting text explaining its application are not prescriptive, is sufficiently flexible and is therefore sound; and • Agreement that BIBRA should be identified as a Major Developed Site in the Metropolitan Green Belt.
1 Agenda Item 2 Page 2 Planning Advisory Group 6 October 2009
Also tabled were a series of inset maps showing the associated changes to be made to the UDP Proposals Map.
As soon as possible after it was adopted formally by the council, the Strategy and Proposals Map, an Adoption Statement and a revised Sustainability Appraisal had to be made available for inspection at libraries, main council offices and on the web.
Members congratulated officers on their achievement and thanked them for their hard work. Sutton was only the 4 th authority in London to reach this stage of the LDF process and it was noted that the Planning Inspectorate were citing Sutton as an exemplar of best practice in a number of areas.
The Chair also thanked Members for their hard work and residents and other stakeholders who had participated in preparing the Strategy. Their input had been much appreciated.
At the discretion of the Chair, members of the public Gavin Ridewood and Kevin Stanley, who had been regular attenders of the Advisory Group meetings, also expressed their gratitude to the officers for the work they had done to help maintain the residential quality of the borough.
Resolved: To RECOMMEND The Executive Recommends full Council to adopt the Core Planning Strategy, now submitted.
49. LOCALLY LISTED BUILDINGS
Further to the discussion at the previous meeting, proposals were submitted for dealing with the suggestions received through the consultation on the Site Development Policies (SDP) DPD Preferred Options Report for identification of additional buildings to be added to Sutton’s Local List. Rather than have a piecemeal approach, officers proposed to carry out a comprehensive review of potential buildings and structures across the borough to identify the best features that met the criteria for Local Listing. This had been discussed with the council’s Heritage Manager, and a proposed timetable had been worked out for carrying out this work, outside of the DPD process.
Whilst it was possible to add to the Local List at any time, officers would discuss with GOL whether any additional buildings can be included in the final draft of the SDP DPD at the Examination stage.
An initial list of nominations was appended to the circulated report. To try to streamline the process, officers would seek nominations for other potentially suitable structures for inclusion from the CAACG and local historians. It was acknowledged that ward councillors would also have some good ideas about which buildings might be appropriate to List. For example, Cllr Gleeson and Cllr Leach suggested buildings in Cedar Road and Rosehill Parade, which they felt could meet the criteria for Listing. Following discussion, it was thought that the best way of obtaining this information would be to send out a nominations form for ward councillors to complete, with a reminder about the criteria for Listing and examples of suitable buildings.
Cllr Graham Whitham welcomed the report and thanked the Chair and the officers for coming forward with these proposals, which went a long way to addressing his written objection to the SDP Preferred Options document.
Sally Blomfield advised that it would be a good idea to also review Conservation Areas and Areas of Special Local Character in the future, to identify buildings within those areas that should be included on the Local List. However, given the resource issues, the immediate review would concentrate on buildings with no protection.
2 Page 3 Agenda Item 2 Planning Advisory Group 6 October 2009
Resolved: To note and welcome the work programme to be undertaken to identify additional buildings suitable to include on the Local List.
50. SITE DEVELOPMENT POLICIES DPD - PROPOSED SUBMISSION
Further to Minutes 42/09 and 43/09, the draft Site Development Policies DPD – Proposed Submission document, setting out the policies to manage new development and the sites allocated for future development in the borough, was presented for comment and approval. The draft document had been amended following consideration of the responses received to the consultation on the Preferred Options report, further discussions with various stakeholders, including the GLA, and the Inspector’s recommendations following the Examination in Public into the Core Planning Strategy. It was proposed to publish the document in January, subject to receiving the necessary committee approvals, and submit it to the Secretary of State for examination in May 2010.
Keith Fraser highlighted the key changes in the document and the main outstanding issues. Changes had been made to policies DM15 Green Belt, DM19 Promoting Sustainable Transport, DM22 Parking, DM23 Loss of Housing (revised title), DM26 Housing Mix, DM27 Communal Accommodation (revised title), DM34 Other Land in Industrial Use and DM35 Development in Town and Local Centres. Keith went through these changes and the reasons for them.
The most significant policy changes made related to policies DM5, 6, 7 and 8, Achieving Environmental Sustainability. These had been substantially re-written on the basis of the representations received and Patrick Whitter took Members through these revisions. For clarity, he tabled a schedule that showed the representations received and how they had been dealt with.
There was still some work to do to finish the document, including further discussions with GOL and the GLA to get their views on the changes that had been made. Written confirmation would be sought that the GLA would only maintain objections to the wording of Policy DM23 and the inclusion of Sheen Way as a Site Allocation. However, it was understood that these objections were not likely to be considered fundamental to the soundness of the DPD and would be left to the EIP Planning Inspector to determine.
In addition, the context to the document and other supporting information needed to be provided, including any schedules/appendices and maps to support the development management policies. It was proposed that these changes should be delegated to the Executive Head of Planning & Transportation, in consultation with the Chair, to enable the timetable for preparing the DPD to be achieved.
Cllr Graham Whitham referred to the Preferred Use for site A3: Cheam Leisure Centre. He wanted to record that, whilst he acknowledged the revised, additional wording, this was still too vague and would not meet Tory Group or the residents’ aspirations to retain leisure facilities on that site. This was endorsed by Cllr Richard Butt.
Resolved: (i) To RECOMMEND The Executive recommends full Council to approve the Site Development Policies DPD Proposed Submission document for publication, prior to it being submitted to the Secretary of State for Examination;
(ii) The Executive Head of Planning & Transportation to make the further necessary amendments to the document, as discussed, in consultation with the Chair, prior to its consideration by The Executive on 1 December 2009.
51. DATE OF NEXT MEETING
Resolved: To note that the next meeting is on Tuesday, 10 November 2009 at 7:30m.
3 Agenda Item 2 Page 4 Planning Advisory Group 6 October 2009
The meeting ended at 9.00 pm
Chair: Date:
4 Page 5 Agenda Item 3
London Borough of Sutton
Planning Advisory Group – 8 December 2009
Report of the Executive Head of Planning and Transportation
JOINT WASTE DEVELOPMENT PLAN DOCUMENT REPORT ON CONSULTATION ON PREFERRED SITES AND POLICIES AND NEXT STEPS
Ward Location: All Author: Philip James (x6255) Area Served: All Lead Councillor: Lyn Gleeson
Key Decision Report
Summary
Consultation across south London on the Preferred Sites and Policies Consultation Report has been substantially completed. This report, sets out the progress with consultation and the consultation responses and identifies some emerging key issues. This includes the need for a further six weeks of supplementary consultation specifically on a limited number of additional sites which have arisen as suggestions from the public, operators etc over the main consultation period. This has implications for the published timetable for the drafting of the final version of the Plan and when the Plan will be publicised and then submitted to the Secretary of State for independent Inquiry in 2010.
Recommendations
I recommend that the Planning Advisory Group considers this covering report and attachments including the responses on the South London Joint Waste Plan draft Preferred Sites and Policies consultation document, and forward their views and recommendations to The Executive for consideration.
I recommend The Executive :
(1) To note the consultation responses on the Joint Waste Plan draft Preferred Sites and Policies document (2) To authorise the preparation of a publicity document and further consultation period of six weeks to publicise the additional sites which have been raised through consultation; (3) To note the revised timetable (4) To delegate powers to approve the timing and publicity arrangements for this additional six week consultation to the Executive Head of Planning and Transportation in consultation with the Lead Councillor for Planning. Agenda Item 3 Page 6
1. Background
1.1To meet European and Government targets for reducing the amount of waste sent to landfill and increasing recycling and composting rates, there is a pressing need for a network of new and expanded waste treatment facilities across the UK to compost, recycle and extract energy from waste. The European Waste Framework Directive requires Member States to have plans in place as soon as possible and DCLG have been pressing local planning authorities to made substantial progress with Waste Plans which is due for reassessment in July 2010.
1.2 In December 2007, The Executive agreed to the setting up of a Members’ Working Group with Croydon, Kingston and Merton to oversee the preparation of the Joint Waste Development Plan Document. The boroughs of Croydon, Kingston, Merton and Sutton are working together to develop the south London Joint Waste DPD to identify sites within their own boundaries and policies to guide and secure suitable future waste management facilities in accordance with a clear and coherent spatial strategy. The period of second stage public consultation on potential sites and draft policies, approved by The Executive on 9 June 2009, took place over the Summer 2009 (late June until mid October) and is now ending. This Report is to be considered by the Joint Waste Plan Members Group before the respective Executives/Cabinets of the four partnership councils under the joint working arrangements.
2. Consultation
2.1 From 20 July to 16 October 2009 an extensive and wide ranging second public consultation exercise has been carried out across the south London waste plan area which has been very successful in encouraging public engagement and considerably exceeded that achieved at the first stage consultation in 2008. Members will be aware that there has been considerable interest and this has been included much local press comment. Over 1,200 respondents commenting on the Draft Plan have been received with more still arriving. Over 200 people have attended Workshops during the period. A video recording of people’s responses to the issues at the Workshops has been prepared and a copy is available for Members to view. Additionally face to face discussions facilitated with all local groups and organisations in response to all those who have requested. Additionally meetings have been held with officers from GOL, GLA and other key stakeholders including from the Waste Management Industry. This is set out in more detail in the attached Annexes 1 Report on Public Consultation and 2 Report on public workshops.
2.2 A schedule of the consultation responses for the four boroughs which have been processed so far is attached as Annex 3 to this report. A number of Page 7 Agenda Item 3
organisations and residents etc have requested additional time to respond outside of the consultation period and these will be added to the schedule. An update will be provided for the Meeting. The Joint Waste Members Group are scheduled to be meeting on 26 November to consider the consultation response and their comments will be reported on.
New Sites
2.3 As well as asking for comments on sites which the Waste Plan Group’s consultants had identified in accordance with the London Plan requirements to firstly consider existing waste sites and industrial areas generally the consultation invited observations on any other sites which could be considered suitable for waste purposes. A number of hitherto unpublicised sites have now surfaced as representations but upon which other interested stakeholders, residents etc will not be aware or not have had the opportunity to comment.
2.4 Members will be familiar with this situation under the new Local Development Framework provisions which is similar to that encountered with progressing Sutton’s Sites DPD. A further supplementary consultation specifically on the new sites which only emerged as suggested sites during the main consultation period became necessary for that draft DPD.
2.5 The list of these new sites identified so far is shown in Table 1. These have not been previously picked up by the Waste Group’s consultants who were guided by the London Plan policy 4A.27 (Broad locations suitable for recycling and waste treatment facilities) which identifies existing waste sites and industrial estates as suitable sites for waste facilities. Members will note that at this stage that the JWP Group are adopting a precautionary approach where sites are likely to require further discussion through to the enquiry. Members will recall that at the previous consultation stage, the Waste Group’s consultants assessed a long list of almost 140 sites. This ‘long list’ consisted of industrial estates and existing waste sites across the four partner boroughs as well as sites which were suggested during the issues and options consultation (which took place in September and October 2008). All sites in the long list were assessed against a number of criteria (such as proximity to nature conservation areas, floodrisk and many more). Of the 140 sites on the ‘long list,’ 28 were identified in the recent consultation as ‘potentially suitable sites.’ To ensure consistency with the Stage 2 consultation process, the JWP Group now recommend undertaking a similar assessment on the new sites which have been identified and consulting on this. This would have the effect of adding the sites in Table 1 to the ‘long list ‘of sites. Not all will be put identified as ‘potential suitable sites.’ Members should note that this consultation will be on the new sites which have come forwards in the consultation only. It is advised that the proposed consultation on ” new sites” Agenda Item 3 Page 8
will not re-open the Stage 2 consultation on potential sites and policies now being concluded.
2.6It is emphasised that this supplementary consultation is necessary not because the merits of including these new sites in preference to others as this clearly has not been “agreed”. Only after the boroughs have collectively and individually decided on a preferred Plan, having satisfied themselves of its soundness, will this become clear. Then the councils will be required to publicise for a statutory consultation period to allow any objections to what will then be the council’s preferred plan for submission. Those objections will have to be passed onto the Secretary of State together with the submitted plan to be considered by the Independent Inspector.
2.7 The way ahead and the selection of final sites and preferred policies has not yet been discussed or agreed between or within each of the four South London councils. But it is necessary that the councils can be satisfied that all parties with an interest in the Plan and/or all sites discussed have had an opportunity to comment on each and any site which has been put forward as a realistic possibility by one or more stakeholder or other interested party. In due course the Inquiry Inspector will want to be satisfied that the councils have done this.
2.8 Table 1 sets out a list of the “additional sites” which are in Kingston, Merton and Sutton based on analysed responses received to date. A specific six week public consultation on these additional sites (only) is being advised.
Table 1: Additional sites identified so far from the Stage 2 consultation Site Borough Supporter Key reasons for support description Former gravel Sutton Viridor Site is brownfield, adjacent to existing waste extraction operations on Beddington Farmlands, not within works sites any national/international policy designation, not (the old within Flood Zone 3b, development would be set Cemex site) back from Beddington lane (so less likely to cause Beddington visual intrusion), site is in proximity to the proposed Farmlands Mitcham Low-Carbon Zone in Merton and also the proposed Hackbridge Sustainable Suburb and has potential to deliver a Combined Heat and Power (CHP) solution to support for such developments (which is in accordance with the London Mayor's aspirations to enhance locally generated energy across the capita)l, site is central to the source of waste arisings. Wandle Valley Sutton CMA Site is currently designated for employment Trading estate, planning uses in the Adopted Sutton UDP, a number of the Hackbridge (agents for existing buildings are coming towards the end of land owner) their economic life and a significant amount of floorspace is vacant or only suitable for ad hoc Page 9 Agenda Item 3
storage, proposed facility (pyrolysis) would supply low carbon electricity (and heat) in a manner that would fully respond to guidance contained in the recently published draft London Plan (October 2009) by achieving 'self-sufficiency' in the South London Waste Plan area, whilst also offering a significant opportunity to realise the vision of Hackbridge becoming a 'zero-carbon' suburb. Land to the Sutton London The lack of openness of the MOL at the site by North West of remade (on virtue of the topography, bund, screening and Jessop’s Way, behalf of land natural tree cover screening; the historic use of the Beddington owners) site for mineral extraction and as sewage sludge beds; the existing permitted use on the site; · the ability of the owner to mitigate environmental problems; · the importance of the proposed use in helping meet the Government’s aims for sustainable use of natural resources and energy generation; the potential to allocate a significant area of the south and west boundaries of the site to landscaping that would provide a natural and sympathetic transition from the MOL to the waste facility. Wimbledon Merton Local None given Greyhound resident stadium Land west of Croydon Landowner Suitable for a composting facility which would be Hawkhirst screened by the surrounding woodland. It is away Road, another from densely populated areas and close to the of Longwood strategic road network (A24, M25, A22) Road, Kenley Land at the Kingston Thames The wider site already has an established waste Hogsmill Water water treatment use, close to Villiers Road, Valley Kingston’s emerging Core Strategy proposes to identify the Hogsmill Sewage Treatment Works as an existing Major Developed Site in MOL. Open area of Kingston Resident None given land adjacent to Chessington Garden centre Land south of Kingston Landowner Possible extension opportunity to the existing Silverglade Silverglade site Business Park
3. Timetable considerations
3.1The timetable for the Joint Waste Plan previously reported to PAG and The Executive anticipated that, subject to the public consultation response Agenda Item 3 Page 10
received over the summer, the publication of the Waste Plan could be achieved in February 2010 prior to submission to the Secretary of State in July 2010
3.2 The Joint Planning Officer Working Group advise that it is not now feasible for the Joint Waste Members Group to have considered and agreed a full draft submission version of a sound Waste Plan in this timescale. This will be discussed by the Joint Waste DPD Member Working Group on 26 November. This is because: v It is recommended that the boroughs carry out additional consultation on a number of sites which have been raised during the consultation which have not previously been considered. v A number of issues and concerns have been raised in the consultation (notably traffic impact, impact on air quality and impact on nature conservation areas) requires further consideration and further work; v guidance from the Planning Inspectorate on additional work around the issue of ‘deliverability’ which needs to be undertaken to avoid withdrawal of submitted Waste Plans because of inadequate evidence or consultation or other soundness aspects.
3.3Officers are mindful having been told by the that across the UK and over the last few years no Waste Plan in the UK has proceeded smoothly through to adoption without substantive changes and additional evidence gathering and that the majority have been delayed and or withdrawn due to criticism from Inspectors once the Plans are submitted. It is prudent therefore to factor in additional time to consult on additional sites on the precautionary basis explained in this report and to carry out the additional evidence gathering to better ensure the South London Waste Plan is developed in a sound manner. After Submission of the Plan, we need to anticipate that the Inspector could require additional evidence which would require additional time and resources
Meeting the Waste Framework Directive
3.4 Officers have previously reported on to Members a concern over any potential slippage in the Plan production expressed by the Government Office for London in relation to meeting the Waste Framework Directive timetable. Most recently GOL have been asked for their informal reaction to the prospect of the South London Joint Waste Plan having to consider an additional supplementary consultation period which would mean the submission of the Plan later in 2010. At a meeting on 9 October GOL did not raised concerns on this as substantial progress will have been demonstrated. They have re- confirmed that once submitted the Planning Inspectorate (PINs) will prioritise the appointment of an Inspector to conduct the Independent Inquiry. Indications suggest at this stage that the proposed supplementary consultations need not delay the final adoption date of the plan.
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3.5 Officers are advising that re-scheduling the submission will give a better opportunity to accomplish further necessary work on the evidence base which the Planning Inspectorate and GOL have recently advised are necessary to reduce the risk of the Plan being found unsound at the Inquiry or alternatively reducing the risk of delay once the Hearing is opened. Members will wish to know that across London the four south London Boroughs have, in satisfying GOL on a timescale, made significantly more progress towards producing a Waste Plan to meet the requirements of the London Plan than all other areas apart from the East London borough Group.
3.6 The Joint Waste Management Procurement Group for the four boroughs are currently progressing through the selection of a suitable tender for a waste management operator partner to handle a future Municipal Waste Contract. The Procurement Group have been keen that the Joint Waste Plan be in place as soon as possible so that the ultimate partner will have a secure development plan basis against which planning applications can be submitted. The Joint Waste Plan Planning Officers Group have been advising the Procurement Partnership as the potential tender partners have met with the Joint Procurement Officers Group to seek to refine/improve their submissions and provide more certainty.
3.7 A revised timetable with indicative dates for publication, submission and Inquiry is set out below. There remain risks attached to this revised timescale which are identified in para 3.3 above.
3.8 Members are asked to note that once the South London Waste Plan is submitted to the Secretary of State, the timetable will be set by the Planning Inspectorate. The latter stage of the timetable is based on advice received thus far from the Inspectorate and officers will seek further confirmation as we progress
Table 2: Timetable to adoption of the Joint Waste DPD DPD Stage Existing New timetable timescale Consultation on Issues and Options Sept to Oct 2008 Sept to Oct 2008 Sites and Policies consultation July to Oct 2009 July to Oct 2009
Consultation on additional sites February 2010
Pre-submission publication of the Waste February 2010 October/Nov 2010 Plan
Submission of the Waste Plan to the July 2010 February 2011 Secretary of State Inspector receives Plan and poses initial August 2010 March – April questions / LPA response 2011 Agenda Item 3 Page 12
Pre-hearing meeting where the September 2010 April - May 2011 Inspector details any further evidence required Public hearing begin, including an December 2010 May - Aug 2011 Examination in Public Receipt of Inspector’s report April 2011 Aug – Nov 2011 (fact-check) Receipt of Inspector’s report (binding) June 2011 Sept – Dec 2011 Adoption of the Waste Plan by the four September 2011 Nov 2011 – Feb Councils within the Plan’s area 2011
4. Other key issues from consultation
4. 1 Respondents have expressed concern during the consultation exercise that specific information about the type of waste facility envisaged for sites has not been made available to help inform comment. Members will be aware that some technologies are particularly controversial and have been advised that Planning Guidance requires that Waste Plans do not direct or constrain certain waste processing technologies which Government considers could stifle emerging new technologies. Additionally The Joint Municipal Waste Procurement Group are, it is understood, required, when selecting a suitable tender, to be “technology neutral” and are unlikely to be providing detailed information on technology preferences in the intended Municipal Waste Strategy to inform the Joint Waste Plan or as part of the selection of a development partner.
4.2The Planning Inspectorate have asked that Waste Plans coming forward at submission match all preferred sites with explicit development partners who can confirm the delivery of suitable waste management facilities to meet the timescale, location and volumes required by the Plan’s strategy. At the previous Plan Stage it would have been inappropriate and misleading to have sought to identify specific delivery mechanisms and thus planning impacts but further work on Plan delivery will now be needed prior to plan submission and sufficient information made available to allow for a full assessment of traffic, air quality, noise, visuals, and other relevant planning impacts. These will need to be specified in greater detail to come forward for the councils and then for the Inspectorate to satisfy themselves as to the suitability of proposals. The exact approach to be adopted on this matter is to be considered further under the Joint Waste Plan arrangements before reporting to Members.
4.3 The majority of objections over possible sites from Sutton residents, analysed at the time of writing this report, has related to concerns over existing waste sites and other industrial sites in Beddington Lane and view that it is inappropriate the there be further intensification of this type of activity in this Page 13 Agenda Item 3
location. Objectors submit that further waste related activity is inappropriate for traffic, air quality, noise, health, smells and other quality of life matters such as proximity of potential nuisances to residential, heritage and nature conservation areas. Mention is made of the need for improvements to Beddington Lane. There is also reference to the compatibility of proposals with the Hackbridge sustainable suburb initiative.
4.4 Other respondents have raised objections over the possible use of sites close to Beddington Lane on current open land as well as the Viridor facility which is currently approved and is a licensed waste management facility. These are also of current/potential nature conservation value and the compatibility of theses with the future plans for the Wandle Valley Park has been raised.
4.5 As also set out in the Annex 3 there have been a much smaller number of representations relating to proposed sites or locations elsewhere in Sutton borough including Kimpton Road . Members will also wish to generally note the comments being made on other sites elsewhere in the Plan area.
4.6 Some key sites which have received positive responses (as well as objections) including from potential delivery partners are set out in Annex 3. Members will note that the capacity of these sites to contribute to meeting the London Plan targets and the draft strategy for the Waste Plan will need to be assessed as part of the preparation of the draft submission version of the Joint Plan. This annex includes the “new” sites not previously having been assessed.
4.7 In consultation the Mayor of London has supported some aspects of the consultation version of the Waste Plan, and provided additional support but has also raised concerns over some aspects of the Joint Plan including matters relating to a potential sites in the area of Metropolitan Open Land west of Beddington Lane as not being in general conformity with the London Plans objectives. Members will recall that these sites had previously been included in Sutton’s Core Strategy as a potential MOL de-designation for industry, commerce and waste purposes and which the Core Strategy Inspector had, for the purposes of the Core Strategy, not been convinced should be accepted. Whilst expressing concerns over MOL precedents, nature conservation etc that Inspector referred the waste operation issues on for consideration as appropriate in the Joint Waste Plan. The joint Waste Plan will need to reflect, in due course, consideration of this issue which has emerged in Sutton and Kingston, on whether there is adequate evidence of need including capacity calculations to justify re-designation for waste purposes as an exceptional case for setting aside restrictive MOL policies.
4.8The Inspectorate will ultimately adjudicate on whether the test of soundness of general conformity with the London Plan is being met by the emerging Joint Waste Plan. The GLA have offered further discussion to seek to resolve this Agenda Item 3 Page 14
potential matter of conflict between the Mayor and the south London councils before the Joint Waste Plan is submitted to the Secretary of State.
4.9 The comments of the Government Office for London on the consultation document are attached in Annex 3
4.10 Several respondents have commented that the emphasis of the Plan should be directed towards Waste prevention and re-use/recycling. The joint Waste DPD is primarily directed towards setting out the spatial planning and land use implications of dealing sustainably with solid waste however further emphasis and the linkages between the Waste Plan and the intended Municipal Waste Strategy can be made more explicit. The levels of recycling likely to be achieved are built into the GLA’s forecasts of residual waste which the Joint Waste Plan Group consider may be unduly pessimistic. Joint Waste Plan Group will be considering this matter further. This is a matter which the Inspectorate have also asked be attended to in the submission version of the Joint Waste Plan.
4.11 All representations made on the joint Waste Plan are being published on the south London Waste Plan Website as these are received and processed.
5. Financial Implications
5.1 The costs of preparing and approving the Joint Waste DPD are being shared equally between the four members of the South London Joint Waste Plan Group.
5.2 To accommodate the recommended additional technical work and consultation on additional sites outlined in this report, the anticipated year end cost is £55k per borough. This will be contained within existing budget estimates.
5.3 The partnership budget of £230k is projected for 2010/11 (Sutton share £57.5k) and £39k for 2011/12 (Sutton share £10k.) These can be contained within existing projected budgets . There will be greater clarity on the likely costs once we move forward with the Plan’s development and all responses and issues raised from this current consultation have been considered. This may result in additional costs.
5.4 Members are advised that the Inspector costs and Programme Officer costs for the Examination in Public are likely to be substantial; in the region of £120k (£30k per borough). In addition, the Inspector may ask for extra work following the Submission of the Plan which might result in additional cost. It is also anticipated that further technical input will be needed for the Hearing sessions. This has yet to be assessed and may require the retention of new Page 15 Agenda Item 3
technical consultants. Provision will need to be made within budgets to accommodate these costs.
5.5 The additional consultation will involve some delay to the planning process. Care will need to be taken so that any delays are kept to a minimum so that contractors bidding to the Joint Waste Management Group under the independent procurement process will not withdraw or increase their bids to accommodate planning uncertainties.
6. Influence on the Council’s Core Values
6.1 Producing and making available the draft Joint Waste DPD policies and sites for consultation with the local community and all stakeholders is helping to contribute to working in partnership with people living and working within the Borough, to ensure that they are fully involved in the decisions affecting their homes and community and making the Council’s services open and accessible and encouraging innovative approaches to provide better, more cost efficient waste related services including waste minimisation.
6.2 Supporting increasing recycling levels, giving people more opportunity to deal sustainably with their own waste including emphasising the primacy of waste prevention and re-use, recycling and processing waste locally (the proximity principal), diversion of waste away from landfill disposal, maximising the opportunities for providing local sustainable energy recovery responsibility and taking steps locally to reduce atmospheric emissions including C02 will assist with supporting One Planet Living principles and the Sustainability Action Plan as well as contributing to achieving a sustainable Municipal Waste Strategy.
7. Contribution to the Achievement of Council’s Policy Aims
7.1 The action we are proposing will accord with the Council’s policy objectives of promoting economic and community well-being, and promoting a prudent and well-managed Council.
8. Equalities Impact Assessment
8.1 The draft Joint Waste DPD consultation report has a number of priorities for reducing landfill and encouraging waste prevention, re-use/re-cycling and composting. When the Joint Waste DPD is approved it will be part of the development plan for the Borough and consequently its implementation will secure the council’s objectives of creating strong, active and inclusive communities.
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Background Papers
• The South London Waste Plan: Draft Sites and Policies Consultation Report • The Sites and Policies Technical Report prepared by Mouchel Environmental Consultants • The South London Interim Sustainability Appraisal Report • The South London Joint Waste Development Plan Document: Building the Evidence Base for Issues and Options, May 2008 with an added Appendix to update the report in May 2009 • The South London Waste Plan Issues and Options Consultation Report • Report on the analysis of the Issues and Options Consultation feedback • Report on the Waste Seminars Summer 2009 CAG consultants • Inspectors Report on the Sutton Core Strategy 2009 • Sutton’s Site Development Policies Preferred Options Consultation Draft • Sutton’s Site Development Policies Additional Sites Consultation 2009 • The London Plan with alterations February 2008 • The London Plan consultation draft replacement plan October 2009 • Inspectors initial observations (Front Loaded meeting) on SLJWP • Planning Advisory Service Conference Waste Plans 29 September 2009
Annexes
Annex 1 Draft Stage 2 Report on Public Consultation
Annex 2 Schedule of representations reported to South London Joint Waste Members Group 26 November 2009
Annex 3 Consultation letters from Mayor of London, Government Office for London and the Environment Agency
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DRAFT Stage 2 Consultation Report
A summary of the response received to the Stage 2 consultation for the South London Waste Plan: Potential sites and draft policies held between 20 th July and 16 th October, 2009.
November 2009
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Purpose 1. This report sets out how the boroughs of Croydon, Kingston, Merton and Sutton have engaged with the local community and key stakeholders throughout the development of the Waste Development Plan Document we are jointly preparing.
2. The report sets out the findings of the second stage of consultation which took place over 13 weeks between 20 th July and 16 th October 2009 (though a large number of responses were received and considered after this date).
3. The second consultation stage identified a number of potential sites and draft policies about which we sought comment from residents, local businesses, the waste management industry, site owners and occupiers, statutory and government bodies.
4. This report provides a high level summary of the comments received. All comments and initial officer responses are available as an appendix. A similar report was published following the completion of the first consultation stage on ‘issues and options’ which took place in September and October 2008. 1
The requirement to consult 5. Section 25 of the Town and Country Planning (Local Development) (England) Regulations 2004 (Regulation 25) requires local planning authorities to ensure that development plan documents (DPDs) are genuinely front-loaded by informally involving communities in the development of issues and alternative options. The regulations state that a variety of community involvement measures should be used in order to encourage a meaningful response based upon a genuine choice of options.
6. Boroughs are also required to ensure that consultation arrangements are in accordance with their adopted Statements of Community Involvement (SCI). Each partner borough involved in the development of the Joint Waste DPD has its own adopted SCI. To ensure a common approach across all boroughs, the greatest requirements in any one SCI have been applied to all boroughs.
7. When the South London Waste Plan is submitted, a Statement of Compliance will be prepared. This will explain how the preparation of the DPD has met the Regulation 25 requirements as well as the requirements of the Statements of Community Involvement. This Statement of Compliance will also need to show how all issues raised by stakeholders have been addressed. This report should be read as an ‘interim’ statement.
Background to the South London Waste Plan 8. The South London Waste Plan will provide a planning framework for the management of all waste produced in the partner boroughs. It will form part of each borough’s Local Development Framework (LDF) and will:
• Contain policies which will be used to assess applications for future waste management facilities within the Plan’s area;
• Allocate land to waste management, to guide the future development of waste management facilities, and;
• Specify how delivery of the Waste Plan will be monitored annually.
9. When approved, the Waste Plan will replace the saved waste policies within the partner boroughs’ Unitary Development Plan’s (UDP).
1 This report is available online via http://southlondonwasteplan.limehouse.co.uk
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How we have consulted on the development of the South London Waste Plan 10. In preparing the South London Waste Plan, the partner boroughs must ensure they are in general conformity with the Regional Spatial Strategy (in this case the Mayor’s London Plan) and National Policy. To this end, regular meetings have taken place, and will continue to take place throughout the Plan’s development with the Greater London Authority (GLA) and Government Office for London (GOL).
11. In addition, formal consultation activities have taken place to seek views from local residents, businesses, the waste industry, site owners and occupiers and other stakeholders. The first, known as the ‘issues and options consultation’ took place over a 6 week period in September and October 2008. The second, known as the ‘potential sites and policies consultation’ took place over a 13 week period from July to October 2009.
The first consultation: ‘Issues and Options’ September – October 2008 12. The first consultation stage sought comment on a range of issues and options for dealing with these. In line with each borough’s Statement of Community Involvement, the consultation was advertised in the following ways:
• In the local press and in borough magazines • On all boroughs’ websites • Display of posters, leaflets and consultation materials (questionnaires) in council main receptions and all libraries • Direct mail to all contacts on each planning department’s Local Development Framework database (i.e. all local residents who have previously shown interest in the development of their borough’s strategic planning documents)
13. An Issues and Options consultation document was prepared containing a questionnaire 2. A leaflet containing a shortened version of the questionnaire and less technical information was also prepared to appeal to a wider audience 3. These, together with background technical documents 4 were available electronically via the waste planning pages of each borough’s websites. 5 Each webpage directed users to a Joint consultation portal where users could read documents and respond using the online questionnaires.
14. One evening public workshop was held in each borough during September and October 2008. We also encouraged local community groups to invite us to attend their meetings. Meetings of the following groups were attended by Planning Officers to discuss the Waste Plan: • The Mitcham Society, Merton • Kingston’s Ecofootprint group • The Hawkes Road Residents Association, Kingston • The Chessington District Residents Association, Kingston • The Sutton and Croydon Green Party • The Mitcham Partnership, Merton
2 ‘Issues and Options Consultation Document,’ September 2008 published jointly by the boroughs of Croydon, Kingston, Merton and Sutton. Available to view via http://southlondonwasteplan.limehouse.co.uk 3 ‘Consultation on moving away from landfill,’ September 2008 published jointly by the boroughs of Croydon, Kingston, Merton and Sutton. Available to view via http://southlondonwasteplan.limehouse.co.uk 4 The South London Waste Plan Technical Report, The Habitats Directive Assessment, The South London Waste Plan Interim Sustainability Appraisal. Available to view via http://southlondonwasteplan.limehouse.co.uk 5 www.croydon.gov.uk/wasteplan ; www.kingston.gov.uk/wasteplan ; www.merton.gov.uk/wasteplan ; www.sutton.gov.uk/wasteplan
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15. Over 100 stakeholders provided written response to the Issues and Options consultation and in addition, 87 people attended the workshops and provided their views in group discussions. These were captured in a full write-up of the workshops which was made available online following the consultation close. 6
Consultation stage 2: ‘Potential sites and Policies’ – July to October 2009 16. The second stage of consultation identified a list of potential sites and a set of draft policies which will be used to assess future applications for waste facilities.
17. The second consultation stage was advertised in the same way as the first; using local press and in borough magazines; all boroughs’ websites, display of posters, leaflets and consultation materials (questionnaires) in council main receptions and all libraries. All residents, businesses and other parties on each planning department’s Local Development Framework database, as well as those who responded to the issues and options consultation were notified by direct mail.
18. In addition, all boroughs wrote to businesses and residents on and surrounding all potential sites identified in the Stage 2 consultation materials. Unfortunately, the distribution of letters and consultation materials by post was hindered during the consultation period by unplanned strikes by Royal Mail workers which affected most of the country for a number of days. However, residents were able to pick documents up from their local libraries and council main receptions.
19. This second consultation stage received wider coverage in the local press which also helped to ensure residents were aware of the consultation and how they could get involved.
20. Each borough also held an evening drop-in workshop during September 2009 to enable residents to find out more about the development of the Waste Plan, provide feedback about the potential sites and draft policies and ask specific questions. The workshops were well attended, with 214 attendees across the Plan area. A full write- up of these workshops is available as Appendix 1 to this report.
21. As for the first stage of consultation, all consultation materials and press releases encouraged community groups to invite us to attend their meetings to talk further about the Plan. Planning officers attended all meetings we were invited to and a list of these is shown in Table 1.
Table 1: List of local meetings which were attended by waste planning officers during the potential sites and policies consultation Croydon: • Selsdon Residents Association • Sanderstead , Croham, Selsdon and Ballards Neighbourhood Meeting • The Addiscombe, Woodside and Ashburton Neighbourhood Meeting • The Broad Green and Waddon Neighbourhood Meeting • Addington Residents’ Association Committee
Kingston: • Chessington District Residents Association • The Hawkes Road Residents Association • The Maldens and Coombes Neighbourhood Meeting • The Surbiton Neighbourhood Meeting • The Kingston Town Centre Neighbourhood Meeting • The South of the Borough Neighbourhood Forum • Transition Town Kingston • The Malden Rushett Residents Association • Three meetings with local residents in the south of the borough in Tolworth and Chessington
6 This report is available to view via http://southlondonwasteplan.limehouse.co.uk
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Merton: • The Willow Lane Industrial Estate BID group, • Wimbledon Park Residents Association • The Mitcham Society • The Morden Community Forum • The Raynes Park Community Forum • The Wimbledon Community Forum • The Mitcham Community Forum • Colliers Wood Community Forum • The Mitcham Partnership • The Wimbledon Society • The Raynes Park Association • Merton Sustainable Communities and Transport Partnership and the Environment sub- group of this Partnership • Morden Industrial Area (South Wimbledon Business Area BID Group) • Longthornton Redevelopment Working Party
Sutton: • Information provided at the Carshalton Environment Fair • KIPPA BID (Business group on the Kimpton Industrial Estate) • Beddington and Wallington Local Committee • Local Authorities Along the Wandle • Beddington Farm Bird Group
22. Over 1200 responses have been received to the potential sites and policies consultation from a wide range of stakeholders. Some responses were individual’s views, whilst some represent much larger organisations such as residents groups and local environmental organisations including local Friends of the Earth and Green Party groups. Responses were also received from government bodies (e.g. the Environment Agency, the Greater London Authority, the Highways Authority, English Heritage, Government Office for London). A number of responses were also received from waste management companies. Full details of all respondents and their comments can be found at Appendix 2, alongside initial officer comments.
23. It is important to note that organisations and individuals responded to the consultation in different ways. Some filled in all or part of a questionnaire, others wrote letters or e-mails covering some or all of the questions raised. Additionally, a number of responses were made at the four public workshops held.
24. The remainder of this report presents an analysis of the response to the consultation questionnaire. Feedback received through written comments or points made at the workshops are incorporated throughout this report. Two appendices are available to this report:
• Appendix 1 is the write up from the four public workshops held during the consultation period, and; • Appendix 2 contains all comments received in response to the potential sites and policies consultation, along with initial officer comments.
Thanks to all of you who responded to the Stage 2 consultation on potential sites and policies for the South London Waste Plan.
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Comments on potential sites
Q) Do you have any comments about any of the potential sites? This question was asked in both the full and short questionnaire and at workshops. Views were also provided by letter and Email. Comments received are discussed below
25. This report summarises the main objections and support received for the various potential sites consulted on. All detailed responses to the consultation can be found in Appendix 2.
Feedback from Government bodies 26. All industrial estates and existing waste sites are supported by the Greater London Authority (GLA), because these are consistent with London Plan Policy 4A.27 (Broad locations suitable for recycling and waste treatment facilities) which identifies strategic employment locations, local employment areas and existing waste management sites as the broad locations suitable for recycling and waste treatment facilities. On this basis, the GLA has objected to a number of potential sites which fall outside of these categories of land.
27. The EA has identified a number of sites which would benefit from improvements, which, in some cases could be incorporated into the development of sites. They also identify development constraints for particular sites and potential mitigation, e.g. “ a drain runs adjacent to [Chessington Industrial Estate, Kingston] so there should be no development within 5m of the top of its bank .” In their response, the EA has also identified those sites which are particularly important species habitats and where mitigation measures must be included in any site redevelopment.
28. The EA has also objected to potential sites which fall within flood zone 3b (sites within the functional floodplain). Some industrial estates and existing waste sites fall within this flood zone. In developing the South London Waste Plan, it was considered that redevelopment of these sites could provide opportunities for improvements to surface water drainage and sustainable drainage systems. Further discussion on this issue will be needed with the EA.
29. Objections to sites from statutory bodies are listed below: Sit Site Borough Objector Main reasons for objections e description 99 Purley Oaks Croydon EA The site has a large pond and recorded Highways Depot populations of stag beetle (a protected species) as well as Kingfisher and common frog 47 Land at the Kingston GLA The borough’s Unitary Development Plan junction of (UDP) identifies this as suitable for hotel or Kingston Road / recreation use and the consideration of this Jubilee Way site is contrary to London Plan Policy 4A.27 (Broad locations suitable for recycling and waste treatment facilities) 124 Former Kingston GLA The borough’s UDP identifies this as suitable Government for housing and is acknowledged by the GLA Offices, Hook to be an important housing site for the Rise South borough. Consideration of this site is also contrary to London Plan Policy 4A.27 (Broad locations suitable for recycling and waste treatment facilities) 41 Kingston Road, Kingston Surrey This rail aggregate depots serves an Tolworth County important function for the import of Aggregates Council construction materials into London and parts
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depot south of of Surrey. The continuation of this site as an the railway aggregates depot is supported 7
22/ Willow Lane Merton EA The site is in flood zone 3b 69 Industrial Estate, (including the B Nebbett & Son site) 651 Part of the Merton EA Site is in flood zone 3b Plough Lane Industrial Estate 75 Burlington Road Merton EA Site is in flood zone 3b 8 west site junction with A3 57 Land to the Sutton GLA It is designated Metropolitan Open Land West of which is protected by London Plan policies Beddington 3D.10 (‘Metropolitan Open Land’) which Lane states that boroughs should maintain a presumption against inappropriate development of MOL and that essential facilities for appropriate uses will only be acceptable where they do not have an adverse impact on the openness of MOL; and Policy 3D.14 (‘Biodiversity and nature conservation’) which expects London boroughs to give strong protection to Sites of Metropolitan Importance (SMI) for nature conservation). The GLA states that further reasoning and justification demonstrating why this is required will be needed if it is to be considered further
30. The Highways Agency did not provide site-specific comments in their consultation response, but in general seek to promote strategies and land allocations which support alternatives to the private car. However, they note that whilst desirable, the transport of waste by rail is often not feasible due to costs associated with providing access to the waste site and source by rail.
31. The HA supports the consideration of the proximity to the strategic road network which was included in the site assessment work carried out to date. However, they feel that at present, there is insufficient information relating to each site for them to be able to provide guidance as to whether they are suitable or not.
Feedback from residents 32. Local stakeholders objected to and supported a number of sites (though with greater numbers objecting to sites than supporting them). These are summarised in Tables 1 and 2, found at the end of this section on sites comments. All comments received can be viewed in Appendix 2.
7 This site is identified in the consultation document as a site with possible delivery constraints (the site is unavailable within the lifetime of the Plan: it is occupied by London Buses, London Concrete and Day Aggregates who are on 25 year leases).
8 This site is identified in the consultation document as a site with possible delivery constraints (the site is no longer available; a B&Q retail outlet has recently been built onsite).
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33. Although residents and some local businesses objected to a wide range of the potential sites, the reasons cited were very common. The key concerns raised by local residents in objection to sites were: • Additional traffic on already congested roads • Traffic impact on residential amenity • Traffic impact on air quality • Traffic impact on road safety (particularly where schools, playing fields, residential areas are located close by • Close proximity to residential properties • Fear of air pollution from any facility • Fear of water pollution from any facility (e.g. on the Wandle River and Hogsmill Rivers) • Fear of increased noise from any facility • Fear of smells from any facility • Fear of visual intrusion and a general reduction in residential amenity • Fear of what might be built onsite • Fear of health impacts (particularly for those who suffer from respiratory problems e.g. asthma) • Concern about the loss of jobs • Some concern about impact of development on existing businesses
34. A small number of residents did indicate support for some sites. The key reasons given by local stakeholders in support of the consideration of sites for waste management facilities are: • The site is already in waste use • The site is not too close to residents • In accepting that we need to move from landfill and treat waste more sustainably, some residents have identified sites which they consider the ‘least worst’ • Support energy from waste where it would bring local benefits (of heat and power)
35. As Table 2 shows (found at the end of this section on potential sites comments), much of the support for particular sites comes from residents in other boroughs. This ‘Not In My Backyard’ (NIMBY) attitude is common when planning new development sites and is played out at a neighbourhood level as well as a borough level.
36. It is clear from the consultation responses that whilst most residents can understand the need for new waste management facilities, the majority do not recognise any benefits for them individually, or for their local community. As one Merton resident noted, “It will undermine the community and be a potential hazard to users of the town and residents whilst bringing almost nothing positive in return.” A common concern amongst residents across all boroughs was also the perceived negative impact on property values.
37. Most residents feel that the development of waste facilities should be away from residential areas, schools, playing fields and most supported the principle of developing existing sites rather than new sites near residents, “ In principle I would suggest you consider improving or enlarging existing sites first.” (Kingston resident). “Viewed in context with the other proposals…I feel that it would be far more appropriate to utilise fully the existing larger industrial sites and sites that already carry out significant waste disposal…” (Merton resident). “It is appreciated that finding a suitable site must be a difficult problem to solve, but I am hoping one could be located which would note have such a big environmental impact for everybody.” (Merton resident). 38. The lack of information about what will be built on site was a common complaint at the workshops, residents’ meetings and in written responses. Some residents found it difficult to comment on the suitability of sites without knowing what was going to be developed on the site. As one residents’ group noted in their response, “ As we are, as yet, unaware of the nature of waste management processes being considered for individual sites it is a little difficult to spell out why the meeting felt the sites were inappropriate.” (Neighbourhood Partnership, Croydon).
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39. On this issue, the GLA stated in their response that, “ the GLA does not expect Borough’s to specify specific technologies within their Waste Development Plan Documents. The GLA’s position is moving towards being technology neutral and is more concerned with carbon outcomes.” The Government Office for London consider the approach (of not identifying what will be built on sites) as being consistent with policy requirements. The NHS also supports the consideration of technologies on specific sites on a case by case basis. Further consideration on this matter will be needed.
Feedback from the industry 40. The industry and some site owners responded in support of a number of sites: Site Site Boroug Supporter Main reasons for support description h 1 Factory Croydon RPS In existing waste use, preliminary studies (on Lane waste Planning utilities, ecology, transport opportunities and transfer constraints, contaminated land, visual intrusion, station SLWP (site air quality and bio-aerosol risk and flood risk) owner) 9 have show there to be no barriers to the development of this site. 116 Highways Croydon Veolia This should be included with the adjacent site Depot and 125 (Factory Lane – south side). Offices 10 6 Villiers Road Kingston RPS In existing waste use, consistent with London waste Planning Plan policies, good access to the strategic road transfer network, consistent with London Plan policies, station SLWP (site preliminary studies (on utilities, ecology, transport owner) opportunities and constraints, contaminated land, visual intrusion, air quality and bio-aerosol risk and flood risk) have show there to be no barriers to the development of this site. 9 Garth Road Merton SLWP (site In existing waste use, consistent with London civic amenity owner) Plan policies, preliminary studies (on utilities, sites & ecology, transport opportunities and constraints, transfer contaminated land, visual intrusion, air quality station and bio-aerosol risk and flood risk) have show there to be no barriers to the development of this site. 126 Benedicts Merton SITA (site In existing waste use, not being used to its Wharf operator) maximum potential, consistent with London Plan policies, adjacent to a proposed low carbon zone which will provide 1000 dwellings, potential to provide heat and power 60 Rainbow Merton Rolfe Judd Supported in principle by key stakeholders Park (on behalf Industrial of site Estate owner) 98 Waste Sutton Veolia Site is in existing waste use and is within the Transfer Beddington Farmlands Industrial area Station site, Endeavour
9 The South London Waste Partnership (SLWP) is the joint body comprising the waste disposal functions of the boroughs of Croydon, Kingston, Merton and Sutton.
10 This site is identified in Appendix 8 of the Potential Sites Technical Report published alongside the Stage 2 consultation documents.
11 This site is identified in Appendix 8 of the Potential Sites Technical Report published alongside the Stage 2 consultation documents. It was not identified as a key consultation site because it is less than 1 ha in size.
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Way 11 18 Existing Sutton Viridor (site In existing waste use, close to the A236, potential waste site, operator) to be connected to the rail network Beddington Farmlands 57 Land west of Sutton Sterecycle Suitably large site size, single ownership, support Beddington from the site owner, central location Lane London Remade (on behalf of site owner)
John Laing 491 Land to the Sutton Valad The site is zoned for industrial use and may have north of Property potential. Valad has identified that some parts of Minden Group (on this site would not be suitable because of existing Road, behalf of premises onsite. Kimpton site owner) Industrial Estate
New sites Q) Do you know of any other sites which could be suitable for the development of waste management facilities? This was asked in both the full and short questionnaires
41. In the consultation documents, stakeholders were asked whether there are any further sites which should be considered in the development of the Waste DPD.
42. A number of new sites were suggested from a range of stakeholders. Some suggestions (e.g. the former government offices at Tolworth, Kingston) were also raised at the previous Issues and Options consultation stage and have already been investigated. 12 Other suggestions were not site-specific e.g. “ any surplus Thames Water land at the Hogsmill and Beddington Farmlands…” (John Laing, waste operator).
43. However, a number of specific sites, which have not previously been considered in the development of the South London Waste Plan were suggested. These are identified below: Site Borough Supporter Key reasons for support (full details can be description found in Appendix 2) Land west of Croydon Landowner Suitable for a composting facility which would be Hawkhirst Road, screened by the surrounding woodland. It is another of away from densely populated areas and close to Longwood the strategic road network (A24, M25, A22) Road, Kenley Open area of Kingston Resident None given land adjacent to Chessington Garden centre
Land to the Kingston Site owner Possible extension opportunity to the existing south of Silverglade site Silverglade
12 In the case of the former Government offices, Kingston, this site was identified in the consultation documentation as having deliverability constraints (it is recognised as a key housing site in the borough’s Unitary Development Plan). The GLA also recognises this site as important for delivering housing.
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Business Park
Land at the Kingston Thames The wider site already has an established waste Hogsmill Valley Water water treatment use, close to Villiers Road, Kingston’s emerging Core Strategy proposes to identify the Hogsmill Sewage Treatment Works as an existing Major Developed Site in MOL. Former gravel Sutton Viridor Site is brownfield, adjacent to existing waste extraction works operations on Beddington Farmlands, not within sites (the old any national/international policy designation, not Cemex site) within Flood Zone 3b, development would be set Beddington back from Beddington lane (so less likely to Farmlands cause visual intrusion), site is in proximity to the proposed Mitcham Low-Carbon Zone in Merton and also the proposed Hackbridge Sustainable Suburb and has potential to deliver a Combined Heat and Power (CHP) solution to support for such developments (which is in accordance with the London Mayor's aspirations to enhance locally generated energy across the capita)l, site is central to the source of waste arisings. Wimbledon Merton Local None given Greyhound resident stadium Wandle Valley Sutton CMA Site is currently designated for employment Trading estate, planning uses in the Adopted Sutton UDP, a number of Hackbridge (agents for the existing buildings are coming towards the land owner) end of their economic life and a significant amount of floorspace is vacant or only suitable for ad hoc storage, proposed facility (pyrolysis) would supply low carbon electricity (and heat) in a manner that would fully respond to guidance contained in the recently published draft London Plan (October 2009) by achieving 'self- sufficiency' in the South London Waste Plan area, whilst also offering a significant opportunity to realise the vision of Hackbridge becoming a 'zero-carbon' suburb. Land to the Sutton London The lack of openness of the MOL at the site by North West of remade (on virtue of the topography, bund, screening and Jessop’s Way, behalf of natural tree cover screening; the historic use of Beddington land the site for mineral extraction and as sewage owners) sludge beds; the existing permitted use on the site; · the ability of the owner to mitigate environmental problems; · the importance of the proposed use in helping meet the Government’s aims for sustainable use of natural resources and energy generation; the potential to allocate a significant area of the south and west boundaries of the site to landscaping that would provide a natural and sympathetic transition from the MOL to the waste facility.
Main areas of conflict and consensus 44. There is little consensus on the suitability of sites at this stage of the Plan’s development.
45. There is also a conflict in opinion between local stakeholders and government bodies on the issue of identifying activities taking place on site. Whilst local residents wish to have greater
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certainty about what will be built on each site, GOL, the GLA and the NHS support the Plan’s approach to date which is not to identify specific technologies on sites. Although they haven’t commented on the approach to describing (or not) the activities to take place on site, in their response, the EA has identified particular opportunities and constraints for a number of sites e.g. “The Hogsmill River runs adjacent to [site 6, Villiers Road] giving the potential for improvement works….improvements to the buffer zone could be incorporated to improve the river corridor.” This issue of how far the South London Waste Plan should describe the activity to take place on each site was previously raised with stakeholders during the issues and options consultation. At that time, whilst local stakeholders are generally keen to identify what sort of development is suitable for the sites eventually identified, the waste management industry desired flexibility and believes that the most appropriate place to discuss the detail of proposals is at the planning application stage. This is an issue which needs further consideration.
46. There is, however, consensus across most stakeholders that further work must be completed to identify the most suitable sites for locating waste management facilities. Traffic impact is key issue which has been raised by residents as well as the Highways Agency and will certainly need further investigation.
47. There is also consensus amongst local stakeholders on a range of issues and potential impacts which need greater consideration.
12 Table 2: Summary of objections to sites . Note: All responses can be viewed in Appendix 2 Site Site Borough Nos. of Main reasons for objections description objections at time of publication* 102 Purley Way Croydon 5 Concerns about: water pollution, air pollution, traffic increases on already congested roads, close proximity to residents
1, Factory Lane Croydon 28 Concerned about water and air pollution, traffic increases on already congested roads, road safety issues, close 105, sites proximity to residents, noise pollution, the site is also next to the Wandle Valley Park and there would be negative 125 impacts for local wildlife and people enjoying the park
99 Purley Oaks Croydon 10 Want to retain the sites' current use to enable residents to bring their waste and recyclables, high density residential Highways area, the existing site has dangerous traffic access problems at peak times, too small for redevelopment and Depot constrained by high ground to the east, the large pond onsite has recorded populations of stag beetle (protected
species), Kingfisher and common frog. Page 29
104 Purley Park, Croydon 3 Being used to a good purpose already - agree with deliverability constraints identified, Purley way sites are all Lombard contaminated Business Park
5 Pear Tree Croydon 2 Current operations are outside current permissions and causing nuisance, unsuitable access road Farm
6 Villiers Road Kingston 26 Concerns about: water pollution (on Hogsmill), air pollution, traffic impact on residential streets, noise impact, local road are unsuitable for heavy vehicles and are too narrow; Villiers Road is already being damaged, vibrations from vehicles damaging homes, traffic safety, smell, close proximity to residents, site is small, in the heart of a residential area, close to two primary schools and a secondary school, bordered by Metropolitan Open Land, considered unsuitable even for its existing use
th * These figures summarise the written responses received by 25 November 2009 Agenda Item3
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351, Chessington Kingston 446 Concerns about creating traffic problems in Malden Rushett, this is a industrial estate not compatible with heavier 352, uses , close to residents, school, close to playgounds, close to health clinic, close to shops, Tolworth roundabout is 353 already gridlocked, health hazard for local community, highly residential area, recent Tesco application highlighted traffic congestion problems here, concerns about vermin, substantial increase in HGVs, HGVs getting lost/stuck on unsuitable roads, additional housing on the former government site (which is considered inevitable) will increase traffic further, residential roads and schools surround the estate and would suffer from increased noise, smell, pollution and traffic, concerned about loss of employment on the site (which currently employs several hundred people), already high levels of pollution at the Tolworth roundabout and Hook Rise South, Hook Rise South is very narrow and unsuitable for HGVs, site occupier (Eskmuir Properties ltd) objects
47 Land at Kingston 416 Concerns about creating traffic problems in Malden Rushett, concerns about the loss of the community bike project junction of (a unique facility for local young people), next to a nature reserve, next to a new play area which the Council has Kingston built (encouraging young people to play there), problems with air pollution (caused by traffic on the A3) would be Road / Jubilee made worse, recent Tesco application highlighted traffic congestion problems here, it's not a previously developed Way site, it's a small area of land, at weekends during football season there is parking all along the roads and will create Page 30 problems for access, concerns about smells in summer from the facility, a school has just been built at Garrison lane, site is identified in the UDP as suitable for hotel and recreation
124 Former Kingston 1 This is an important site for housing (note: this is identified as having deliverability constraints in the consultation Government document because the borough acknowledges its importance as a site for new housing). Offices, Hook Rise South
41 Kingston Kingston 1 This is an important site for the import of aggregates into London and Surrey (note: this is identified as having Road, deliverability constraints in the consultation document because the borough acknowledges that the site is not Tolworth available: the existing occupiers are on long leases). Aggregates
45 Barwell Kingston 1 Surrey CC concerned about increased traffic through Epsom Town Centre where HGV traffic is already an issue. Business Park
14 36 Area South of Kingston 1 Surrey CC doesn’t support a loss of Green Belt or encroachment into the Chessington/Epsom/Leatherhead/Oxshott Malden Gap. Also concerned about increased HGVs through Epsom Town Centre, proximity to Epsom Common SSSI and Rushett Local Nature Reserve in Surrey, and more importantly the Ashtead Common SSSI and National Nature Reserve in Surrey which contains over 2,300 rare pollarded oaks which are of great conservation importance.
46 Coal depot, Kingston 53 Concerns about traffic problems in Malden Rushett, congestion on already congested roads (e.g. Leatherhead Road Garrison Lane already congested, site is next to 2 primary schools and a secondary school, close to residential properties, access road is narrow, safety concerns from increased HGVs, planning permission has already recently been given to three schemes on Leatherhead Road which will increase congestion, concerned about impact (smells, pollution and traffic) on the adjacent open space and Sir Francis Barker Ground (used by the Chessington cricket and sports club), concerned about the additional noise of rail if waste were to be moved by rail, Reisdents in Chessington, Hook, Malden Rushett already suffer from extremely poor air quality caused by excessive traffic on the A243 and resident notes that it is documented that Chessington and Malden Rushett has one of the highest instances of asthma, chest complaints and breathing problems caused by pollution. Concerned about more pollution and damaging health effects, site is directly opposite Chessington South Railway Station and adjacent to the newly Page 31 constructed Chessington Community College and densely populated housing estate in Garrison Lane, memories of illegal landfill and high volumes of trucks going into Rushett Farm, driving at dangerous speeds, spraying mud all up over the verges and parked vehicles, concerned about the monitoring and control of such facilities, highly congested roads in the summer because of Chessington World of Adventures; people might be put off visiting this theme park because of waste development, plants may be affected in the Chessington Garden centre,
60 Rainbow Park Merton 135 Close proximity to residential areas, primary school, playing fields, mainline station (Raynes Park), site is within a town centre and residential area. Concerns about: visual intrusion, sound vibrations, traffic impact on already congested area and town centre, access to the station, road safety, air quality, health impacts, loss of jobs onsite, Residents feel it is a small site with poor vehicle access. It is viewed as a negative development which would impair efforts to improve the town centre which the council has recently invested in (e.g. the Lantern Theatre, improvements to the station, several plans for new housing in the town centre, new housing development/supermarket on the other side of the rail tracks from the site)
9 Garth Road Merton 4 Additional traffic on already congested roads, access road is narrow and not designed for heavy vehicles, vibrations in homes from passing heavy traffic, concerned about pollution, it’s a residential area, query the scoring on proximity Agenda Item3 to the strategic road network
15 Agenda Item3
136 Deer Park Merton 31 Visual intrusion, traffic congestion, next to Dean City Farm (a facility for children), concerned about loss of Road employment - this site currently provides c. 50-80 jobs, too close to housing, too close to a school, the area has really improved and this will harm the area, close to morden park, traffic calming was needed on Liberty avenue, concerned about noise and additional traffic, concerned about increase noise for the animals of Dean City Farm, increased vehicles in surrounding residential roads, health concerns, adjacent to the River Wandle which should be an asset to the area and improved as a nature / scenic walk; Objection from CTL Components PLC (an occupier) who state that the site encompasses live businesses with surrounding roads being heavily used by the existing traffic. Additional traffic with large rubbish trucks would congest the area even further, observation that Merton Council has been engaged in improving the area (e.g. “Lombard Road – Streets for People” project) and the idea of a waste site seems to go against these efforts
73 Bushey Road Merton 3 This site is identified in the consultation document as having deliverability constraints. The respondents agree with industrial area deliverability constraints identified
751 Burlington Merton 5 This site is identified in the consultation document as having deliverability constraints. The respondents agree with Page 32 Road deliverability constraints identified
22 Willow Lane B Merton 27 Adjacent to residential properties on Carshalton Road, gardens back onto the site, Environmental Health are already Nebbett site in dispute with Nebbett & Sons due to relentless high levels of noise from the onsite crusher, traffic is already heavily congested particularly on Carshalton and Goat Roads, safety issue (accidents are already an issue), access roads are unsuitable for HGVs and recently on Drake Road, an HGV knocked down a lamppost, large number of elderly residents, only 0.5 miles from the Hackbridge landfill site which smells in warm weather, this is a deprived area of Merton,
126 Benedicts Merton 9 Concerns about traffic, conservation areas surrounding the site, too close to residential areas Wharf
69/12 Willow Lane Merton 7 Concerned about loss of employment on this site which must be safeguarded, the site is in flood zone 3b (the 7 functional floodplain)
16 642 Dunsford Merton 19 Mostly occupied, residential properties close by, roads are already congested Road, area east of Weir Road
702 Garth Road Merton 10 Residential properties close by, whole are
651 Plough Lane Merton 85 Low score, traffic impact, visual intrusion, very close to new buildings on corner of Weir Road and Plough Lane, (area of) concerned about loss of employment - this site currently provides c. 50-80 jobs, <100m from residents on Chaucer Way, Plough Lane, Kingsley Road, Kohat Road and Havelock Road (technical report is incorrect on the scoring for proximity to residential properties), site is within 200m of Garfield Primary School and Priory School in Queens Road is close by, concerns about potential smells, concerns about additional noise, within 40m of Wandle Meadows Nature Park, the Wandle River and Wandle Trail which have been designated a Local Nature Reserve and would be compromised, Technical report is incorrect to state that it is not close to open areas (it is close to the allotments at Havelock Rd and Garfield Rec, Lambeth cemetery is close by, site is within 400m of St. George's hospital, Page 33 surrounding roads already suffer from extreme congestion at almost all times of the day and especially at peak hours, the Council has spent alot of money improving the wider area (Abbey Mills, Dean City Farm etc), surely this is contrary to that? Herons and Kingfisher now live by the river and fish stocks have improved, have had problems in the past with chemicals being washed into the river, close proximity of a waste site to the river would surely increase the risk of river pollution, health impacts (also compounding existing problems such as allergies, asthma ), site occupier (Manheim Auctions Limited - car auctions co) objects to the site being considered since it would negatively impact on the amenity of their business, which is attended by the public, possible noise from the facility disrupting teaching in the school during the day, possible odours, dust and other waste being distributed from the facility across the open space and coming into the school grounds, concerns about increased traffic, Plough Lane is already a very busy road and junction, and could not easily sustain more traffic. Moreover, the knock-on effect of more traffic and congestion in Plough Lane would mean more traffic diverting nearer the school, the Wandle Trail is a major cycle route (National Cycle Network 20) and amenity of this would be negatively affected by waste development, the NCN route has a crossing at Plough Lane which already is a risk to cyclists. More heavy vehicles would make this worse and is not consistent with national policy on increasing accessibility and safety of cycling, the site is in flood zone 3b Agenda Item3 (the functional floodplain)
17 Agenda Item3
75 Burlington Merton 1 This site is in flood zone 3b (the functional floodplain) (note: this is identified as unavailable in the consultation Road, west document: a B&Q retail outlet has recently been built onsite). side junction with A3
641 Dunsford Merton 11 Concerns about development resulting in unacceptable traffic congestion in the area, too close to residential areas, Road, area inconsistent with Merton's strategic aim to develop the Wandle Valley Park and the existing wildlife and recreational east of Weir sanctuary around the River Wandle.Traffic, Plough Lane (B235) and Durnsford Road (A218) already suffer from Road heavy traffic volumes, except at certain times of the day, resulting in lengthy tailbacks. This heavy traffic was central to the rejection of the Safeway application for a superstore on the old Plough Lane football ground site and the subsequent approval for high density housing was conditional on the junction being widened; something that can not be repeated.
96 George Merton 1 Site is too close to homes, congestion is already an issues and concerned about potential noise and litter. Killoughery Page 34 Ltd
17 Country Skip Sutton 2* The Beddington Lane area is already over industrialised. There are too many heavy goods vehicles accessing this area on a daily basis. The area is filthy and the smell from the existing landfill site and the sewage treatment works that can travel quite far is horrendous. Also see the notes for all Beddington Lane / Farmland sites below. * This site was also raised by a numerous residents in the Sutton workshop held in September 09 as being unsuitable.
491 Kimpton Sutton 5 Schools are nearby, screening would be needed Industrial Estate, Land North of Minden Road
18 492 Kimpton Sutton 1 None given Industrial Estate, Land East of Kimpton Road
Beddington Sutton 73 Beddington and Mitcham area of opportunity identifies this area as needing more lakes, concerned about water and Lane / air pollution, traffic increases on already congested roads, the wider area is primarily residential, concerns that Farmland Beddington has become a dumping ground, Beddington Lane is already suffering from congestion, air pollution sites (residents note that it went over the WHO safe limits on 288 days in 2008), concerns about the increase of respiratory problems over recent years and this would be exacerbated, noise, the road itself is not suitable for heavy vehicles and is damaged (was never designed as a major road), volume of traffic is a danger for cyclists and pedestrians, already smells from the sewage works and this would increase, impact on local ecology, area of national importance for Tree Sparrows and at least 150 bird species (including migrating raptors and nationally scarce species such as Honey Buzzards), sea rise puts all low lying areas (including wandle valley) at risk of Page 35 flooding in future, negative impact on existing businesses in the area
18 Viridor site Sutton 9 This is an area of wet grassland, Metropolitan Open land and a Site of Nature Conservation Importance, although it is recognised that some of this land has already been built on. These designations should be respected and their review should be undertaken through biodiversity planning procedures and not degraded by proposed development through other planning mechanisms. In addition, there is a very real possibility that future development of Beddington Sewage Treatment Works will be necessary to better process effluent to comply with new water quality standards which will be required under the Water Framework Directive and so, as part of a strategic and holistic approach to planning in this area, Site 18 should not be included amongst the proposed waste sites.
21 777 Sutton 1 No reasons provided Demolition Agenda Item3
19 Agenda Item3
57 Land west of Sutton 13 57: As for Site 18, development of site 57 (land west of Beddington Lane) would be wholly unacceptable. This area Beddington also includes Metropolitan Open Land and Site of Nature Conservation Importance designations (which are Lane protected by the London Plan) and which we strongly think should be respected and reviewed through biodiversity planning procedures and not degraded by proposed development through other planning mechanisms. Again, there is a very real possibility that future development of Beddington Sewage Treatment Works will be necessary to better process effluent to comply with new water quality standards which will be required under the Water Framework Directive and so, as part of a strategic and holistic approach to planning in this area, this site should not be included amongst the proposed waste sites.
97 Severnside Sutton 3 Concerned about water and air pollution, traffic increases on already congested roads, the wider area is primarily waste paper residential, Purley way sites are all contaminated,
100 EMR, Sutton 3 Concerned about water and air pollution, traffic increases on already congested roads, the wider area is primarily Beddington residential, Purley way sites are all contaminated, Lane Page 36
20 Table 3: Numbers of supporters for each site and key reason. All responses can be viewed in Appendix 2 Site Site description Borough Nos. of Main reasons for support supporters at time of publication* 102 Purley Way Croydon 8 It is important not to take land that is currently recreational open space; this site follows this principle. Sites seem reasonable as its already used for industry or waste disposal, site is located away from residents, site is large 99 Purley Oaks Croydon 5 Some parts appear to have potential, not much residential nearby, perhaps a possibility to access the Highways Depot site by rail?
1 Factory Lane Croydon 12 Existing industrial site, has a high score and shows potential for redevelopment, little housing or recreation areas within the immediate vicinty, proximity to waste arisings, good access to the strategic road network, the fact that it is in existing waste use and is available and consistent with London Plan Policy 4A.23 which describes the broad locations suitable for the development waste facilities on London
105 Factory Lane Croydon 9 Suitable because it has a high score and shows potential for redevelopment, potential for expansion Page 37 from Site 1, suitably wide access roads (though some residential nearby), it’s a large site 125 Factory Lane Croydon 9 Existing industrial area, has a high score and shows potential for redevelopment, rail access potentially possible (though near a park). 116 Highways Depot and Croydon 1 Part of the Factory Lane industrial estate and adjacent to a larger site being considered (site no. 125) Offices 6 Villiers Road Kingston 23 Existing waste site, though only suitable if there is no increase in traffic, feel that its location near to the busiest economic hub of the borough will encourage responsible disposal of recycling materials and residual waste, might be more appropriate (than Chessington Industrial Estate), proximity to waste arisings, good access to the strategic road network, the fact that it is in existing waste use and is available and consistent with London Plan Policy 4A.23 which describes the broad locations suitable for the development waste facilities on London.
46 Coal depot Kingston 12 Not too close to residential areas, better access than Villiers Road, is the furthest site from residents, only suitable if there is no increase in traffic, might be more appropriate than Chessington Industrial Estate Agenda Item3 351/ Chessington Kingston 12 Show some potential in parts, better access than Villiers Road 352/
* These figures summarise the written responses received by 25 th November 2009 21 Agenda Item3
Site Site description Borough Nos. of Main reasons for support supporters at time of publication* 353
47 Land at junction of Kingston 13 Not close to resident, better access than Villiers Road, is the furthest site from residents, only suitable if Kingston Road / there is no increase in traffic, it would lead to loss of a community bike facility (negative comment), entry Jubilee Way could be in Jubilee Way 123 Kingston Waste Kingston 3 Potential synergies with the waste water treatment site, this site together with the existing waste site Water Treatment would provide an opportunity to treat the waste collected at the Villiers Road site next door without Works additional vehicle movements (Chessington resident) 22 Willow Lane B Merton 9 Existing waste site, existing waste site/industrial land. Nebbett site 126 Benedicts Wharf Merton 8 Already a waste site, the site is not being used to its maximum potential, it can be redeveloped to use
the land more efficiently, move the management of wastes up the waste hierarchy and has sufficient Page 38 area to allow for the co-location of different types of waste facilities, development can reduce the traffic flows to a site, it is understood that a low carbon zone is to be established adjacent to the site (approximately 1,000 buildings). The proximity of this to the site should be considered positively in terms of regeneration because of the potential for renewable energy and heat off take from more sustainable waste management proposals.
69 Willow Lane Merton 10 Not close to residents, existing waste site/industrial land.
127 Willow Lane Merton 10 Not many houses nearby
60 Rainbow Park Merton 6 Suitable and appropriate within this urban area (on amenity, health & safety and highways grounds), benefits include energy, heat and hot water provided directly to the local network, redevelopment will be an improvement on the existing site
9 Garth Road Merton 13 Extending the existing Garth Road facility which is a true industrial estate is a better option (than Rainbow Park), it is away from residential areas, existing waste site/industrial land. 136 Deer Park Road Merton 1 Few houses in close proximity 641 Dunsford Road, area Merton 10 Not many houses nearby, develop existing facilities on this site, existing waste site/industrial land. east of Weir Road
22 Site Site description Borough Nos. of Main reasons for support supporters at time of publication* 642 Dunsford Road, area Merton 8 Partly suitable (the northern half: the southern half is too close to residential properties) east of Weir Road
702 Garth Road whole Merton 6 No reasons given are 651 Plough Lane (area Merton 3 Not many houses nearby, existing waste site/industrial land of) 17 Country Skip Sutton 6 its already used, seems well-run, not much residential nearby
491 Kimpton Industrial Sutton 6 Some parts appear to have potential, it is largely undeveloped and meets the following criteria: Minimum Estate, Land North of site area of 2Ha (5 acres), suitable planning use, good road access and proximity to trunk road network; Minden Road absence of (or adequate separation from) sensitive receptors (in particular residential housing), adjacent Page 39 land uses offering opportunities for CHP off-take Beddington Lane / Farmland 8 Agree, but the road systems needs attention, redevelopment is an opportunity to create a very pleasant sites area for the people of Beddington rather than the awful condition that much of the area is in at the moment; no housing nearby 18 Viridor site Sutton 7 Existing waste use, not much residential nearby, close to strategic road network, the potential to be connected by rail 21 777 Demolition Sutton 5 Not much residential nearby, already in waste use
57 Land west of Sutton 9 not much residential nearby, already in waste use, there is interest from developers (it is deliverable), Beddington Lane The site forms a natural extension of the existing developed area to the south, the proposed use with associated landscaping would form an appropriate transition from the existing industrial development to the south and the MOL land to the north; the existing appearance of the site, which is contained within a palisade fence and has the appearance of an industrial site awaiting development; the importance of the proposed use in helping meet the Government’s aims for sustainable use of natural resources and energy generation; the site is bounded by busy Beddington Lane to the east, an access road to the north and an existing commercial property on the south. Development of this site would enable a landscaped
screen to be planted on the north and west boundaries that would provide a more appropriate border for Agenda Item3 the rest of the MOL, synergies with waste water treatment sites .
23 Agenda Item3
Site Site description Borough Nos. of Main reasons for support supporters at time of publication* 97 Severnside waste Sutton 6 not much residential nearby, already in waste use, it’s a large site paper 100 EMR, Beddington Sutton 5 not much residential nearby, already in waste use Lane 5312 Beddington Lane Sutton 3 Some parts appear to have potential
534 Beddington Lane Sutton 4 Some parts appear to have potential
535 Beddington Lane Sutton 3 Some parts appear to have potential
539 Beddington Lane Sutton 4 Some parts appear to have potential Page 40
98 Waste transfer site, Sutton 1 In existing waste use and in the Beddington Industrial Area Endeavour Way
24 Page 41 Agenda Item 3
Comments on the Proposed Policies 48. In considering the evidence base accumulated so far (including responses to the issues and options consultation, regional and national policy), seven proposed policies have been developed. It is the policies which set out the requirements which all future proposals for waste development facilities must meet and comments were sought on the following proposed policies during the Stage 2 consultation.
WP1: The strategic approach WP2 : Encouraging waste minimisation WP3: Safeguarding existing waste management facilities WP4: Identifying proposed waste management sites WP5: Managing the development of waste management facilities on unallocated sites WP6: Development criteria WP7: Sustainable, modern energy recovery
49. Generally, the number of respondents providing specific comments on policies was low, with most respondents, particularly local residents, more focused on providing feedback on sites.
50. Specific comments on policies were received from the following government bodies: the Government Office for London (GOL), Greater London Authority (GLA), Transport for London (TfL), the Highways Authority (HA), Environment Agency (EA), the National Health Service Healthy Urban Development Unit (NHS HUDU) and the South East England Partnership Board.
51. Regional bodies responding to policies to note are Surrey County Council (the adjoining local authority) and the Local Authorities Along the Wandle (group of local authorities responsible for development along the Wandle).
52. Although very few individual residents and local businesses made specific comments on the proposed policies, a number of local residents associations (which can represent large numbers of residents) did provide comments. These include the Raynes Park and West Barnes Residents Association (Merton), the Chessington District Residents Association (Kingston) and the Residents Association of West Wimbledon (Merton), Mitcham Village Residents Association (Merton), the Apostles Residents Association (Kingston), Garth Road Residents Association (Merton), The Sutton and Cheam Society (Sutton), Ecolocal (Sutton), the Sutton Group Wildlife Trust, Beddington Bird Farm Group (Sutton), Sustainable Merton, Kingston Friends of the Earth and Kingston Against Incineration Network and Croydon Friends of the Earth. A number of comments were also received from residents at the four public workshops and in meetings with local residents groups. As shown in the previous section, residents also raised a number of issues of concern in their discussion of sites. Key issues raised in these forums are included in this section of the report, to provide a holistic view of all comments received.
53. As the principle delivery agents of waste management facilities, the waste industry’s comments on policies are also important. Responses were received from Viridor (waste operator), SITA (waste operator), Veolia (waste operator), RPS (on behalf of Waste Resources Group, waste operator), CMA Planning (on behalf of City and Provincial, waste operator and local landowner), London Remade (on behalf of Cappagh and Ferndown Properties, waste operator and local landowner) and the partner boroughs themselves under their waste disposal function, operating as South London Waste Partnership
25 Agenda Item 3 Page 42
Proposed Policy WP1: The strategic approach:
Do you agree with Proposed Policy WP1? This question was only asked in the full questionnaire. Options: Yes or No
Response: Only 16 respondents answered this question. 10 agree with the policy, 6 do not (for the reasons set out below).
Do you have any comments on the proposed policy, supporting text of monitoring regime? This question was asked in both the full and short questionnaire and at workshops. Views were also provided by letter and Email. Comments received are discussed below
Views from government bodies 54. All government bodies support the principle of the proposed policy, with the following suggestions for amendments / improvements: • Make the policy more locally distinctive, robust and measurable (this applies to all policies and is not repeated throughout the report) • In the accompanying evidence base, identify the sites which currently manage hazardous waste in the partner boroughs and their current capacity • Update the waste forecasts for all waste streams 13 • Update the existing capacity to treat waste within the Plan area • Identify the existing landfill capacity within the Plan area in the accompanying evidence base • Consider the implications of the EA’s current permitting review on the Plan area’s existing capacity 14 • Give greater consideration to the cross boundary movement of waste • Identify what currently occurs with the treatment of clinical waste
Views from residents and local businesses 55. Residents’ comments on this proposed policy covered a wide range of issues which are listed below. • Re-use and the reduction of waste should be a key component of the Plan – linked to questioning the Plan’s current Vision and Objectives view, “ waste as a resource ” • Welcome the Plan’s flexible approach. However, the Plan must be sufficiently flexible to respond to decreasing levels of waste production
13 As part of the current review of the London Plan, the GLA will publish new waste forecasts for C&I and MSW wastes. The EA also has updated waste arisings figures for hazardous waste.
14 The EA anticipates that their permitting review will be published in March 2010.
26 Page 43 Agenda Item 3
• Welcome the wording around “safeguarding communities and the environment” • Request for stronger controls in this policy to ensure that waste is managed as high up the waste hierarchy as possible • Make sure the most efficient facilities possible are built • Question the language used which is very positive. Request that consideration should be given to moderating the language of the policies e.g. favourably consider proposals for this additional waste management capacity …” (this applies to all policies and is not repeated throughout this report) • Request to clarify what agricultural waste means • Request to make links to other policies and particularly highlight the need for proposals to also satisfy proposed policies WP4, WP6 and if the facility is a thermal treatment facility, WP7 • Concerns about where the waste will be coming from; don’t want to import waste from long distances. • Croydon should seek to have the principles on waste which it set out in its Croydon Environment and Climate Change Strategy 2009-11
56. A frequent concern cited from residents is that they feel the Plan is currently weak on addressing waste minimisation. The waste forecasts were questioned (i.e. shouldn’t they be going down?) and residents repeated concerns about the proliferation of plastic bags (a concern raised previously during the issues and options consultation).
57. Residents are concerned that, once facilities are built, there is an incentive for the waste industry to encourage waste production (to maintain their facility and profits). Fears of long terms contracts creating a dis-incentive to reduce waste and the role of thermal treatment facilities crowding out recycling were raised. Some felt the Plan ought to identify binding targets on waste minimisation. There was also concern that all partner boroughs must be making equal efforts to recycle and minimise waste; residents’ pride in borough recycling rates was raised at meetings and residents thought it unfair to have to be supporting other boroughs who weren’t making progress on recycling and waste minimisation.
58. On the issue of recycling and of some technologies (e.g. some thermal treatment processes) residents requested a stronger commitment to managing waste as far up the waste hierarchy as possible. Although a commitment to managing waste in line with the waste hierarchy is identified in the Plan’s Objective 2 and Proposed Policy 1, some residents identified a concern with the language of the Proposed Policy 1 (which requests waste to be managed, “ as high up the waste hierarchy as practically possible..”) and the lack of drivers to ensure that waste is managed up the hierarchy. Some residents commented that the current financial drivers to reduce the amount of waste going to landfill (the landfill tax 15 and landfill allowance trading schemes) only seek to reduce the amount of waste sent to landfill and don’t necessarily address the need to recycle waste above thermal treatment. It is also thought that these schemes will stop at some point.
Views from the Industry 59. The industry is generally supportive of this policy. Comments are listed below. • Support the ambition of going beyond the apportionment and aiming for self-sufficiency. However, this needs to be further clarified in the policy and supporting text. • The issue of the cross-boundary movement of waste (which is inevitable) needs to be clarified
15 To encourage the diversion of waste from landfill and increase recycling, the Government has imposed a tax on active wastes (those that give off emissions) going to landfill. This is a tax which waste producers pay, on top of the usual disposal costs of waste. In his 2007 Budget, the Chancellor announced that landfill tax would rise by £8 per tonne until at least 2010/11. Landfill tax is currently £32 per tonne, set to rise to £40 per tonne in 2009/10 and £48 per tonne in 2010/11. Find out from DEFRA at http://www.defra.gov.uk/environment/waste/strategy/factsheets/landfilltax.htm
27 Agenda Item 3 Page 44
• Request to remove the word, ‘sufficient’ from the beginning of policy which currently reads, “Sufficient planning permissions to meet the apportionment requirements of the London Plan and go beyond this and seek to maximise self-sufficiency in managing the waste generated by the four boroughs .” (on the basis that more applications need to be lodged and not all will get permission). • Specifically identify wood as a waste stream which is identified as a priority material for action in the Waste Strategy for England 2007 • Review the assumed land requirements identified in Table 1.3 of the consultation document which is used in the calculation to identify how much land needs to be allocated to waste management facilities • The policy states that development will be encouraged on the most suitable sites which will be eventually identified in proposed policy WP4. However, this precludes existing waste sites which will be identified in proposed policy WP3. This needs clarification. • The phrase “manage waste as high up the waste hierarchy as practically possible” may inhibit the development of otherwise accepted waste treatment facilities and it should be reviewed.
Main areas of conflict and consensus 60. All agreed that greater clarity is needed on the issue of cross-boundary movement of waste. Whilst some residents seemed to instinctively dislike the notion of waste being imported from surrounding areas and treated within the partner boroughs, it is recognised by the industry that this is a natural feature of waste management.
61. There is also agreement across local stakeholders and government bodies that the waste forecasts for waste streams needs to be reviewed.
Proposed Policy 2: Waste minimisation Do you agree with Proposed Policy WP2? This question was only asked in the full questionnaire. Options: Yes or No
Response: Only 24 respondents answered this question. 12 agree with the policy, 12 do not (for the reasons set out below).
Do you have any comments on the proposed policy, supporting text of monitoring regime? This question was asked in both the full and short questionnaire and at workshops. Views were also provided by letter and Email. Comments received are discussed below
Views from government bodies 62. All government bodies support the principle of the proposed policy, with the following suggestions for amendments / improvements: • Welcome the reference to movements of construction materials and wastes by non-road (e.g. rail or water) and this should be a key selection criteria
28 Page 45 Agenda Item 3
• Note that the policy focuses on the construction industry, but there are also other initiatives to support waste reduction e.g. the London Mayor’s Green Procurement Code and the Waste Resources Action Programme’s (WRAP’s) ‘Love food, hate waste’ consumer campaign.
Views from residents and local businesses 63. Local stakeholders’ comments on this policy are set out below: • The policy is weak on promoting waste minimisation and should actively encourage greater waste minimisation. More consideration should be given to this policy and its monitoring regime • The policy should make it clear whether all 7 criteria listed need to be satisfied by any proposal (this applies to all policies and is not repeated throughout this report) • The same standards should apply as for other construction projects • The re-use of existing buildings and its fixtures and fittings, rather than their demolition and scrap should be an initial priority • Request that consideration is given to conserving the use of water in construction projects and in whichever process is used. • Request that the point made (in the text of the consultation document) to secure space in new dwellings for storage of recyclables is picked up in the policies • No mention of asbestos in construction wastes • Strengthen the language e.g. phrases like “wherever possible” are too vague should be more positive. There ought to be more “sticks” and less “carrots” in the policies (general point to be applied to all policies and is not repeated throughout this report)
64. A strong view, (as previously identified) is local residents’ views that waste minimisation should be central to the Plan and is not yet adequately addressed in the Plan’s emerging polices. Although the consultation document identifies that the reduction of packaging wastes is being dealt with at a national scale and that the boroughs’ emerging joint Municipal Waste Management Strategy is best placed to tackle this issue, some respondents that this is not adequate justification for not tackling this issue in the Waste DPD. “An attempt to shrug-off a primary responsibility to narrowly focussed national agencies like WRAP and BREEAM is not acceptable.” (Sustainable Merton).
65. Residents see local authorities as leaders for reducing waste locally and encourage local authorities to use their wide range of powers to reduce waste produced in the first instance. Ideas suggested include lobbying central government bodies to tackle this issue, implementing local plastic bag tax, reduce packaging through the work of Trading Standards teams 16 . However, others do recognise the difficulties of addressing waste minimisation within the Waste Plan, “ This is an area which needs to be addressed, although by government rather than local authorities” (Croydon resident”).
Views from the Industry 66. industry comments on this policy are set out below: • The requirement to meet BREEAM ‘excellent’ rating proposed in Policy WP2 is unduly stringent and may be unrealistic for all waste facilities. The proposed policy already requires developers to meet the London Mayor’s Sustainable Design and Construction Supplementary Planning Guidance which requires a design and access statement which is considered sufficient. Meeting BREEAM will lead to additional costs and care must be taken not to stifle the development of new facilities (and to encourage their use). • The ‘waste minimisation’ policy deals with other aspects (e.g. movement of waste by non- road means) which is confusing. • Bullet 1) refers to a development meeting ‘best practice’ guidance. This is considered too ambiguous and needs clarifying.
16 Under the Sustainable Communities Act, local authorities now have the power to put pressure on Government to require companies (particularly those who local authorities procure goods from), to reduce packaging.
29 Agenda Item 3 Page 46
• The points made at bullets 3), 4) and 5) are very similar (all support the minimisation and sustainable management of waste during construction) and could be condensed. • At bullet point 7) it is identified that it may not be possible for all resources in the development of waste management facilities to be used efficiently for their lifecycle impacts to be reduced. It will depend on the material and it is suggested that the words, “wherever practicable” are added. • Clarification is needed on what ‘major developments’ are (identified in the justifying text)
Main areas of conflict and consensus 67. A wide range of very different issues have been identified, principally by the waste industry respondents and local stakeholders. One issue of conflict identified in the responses to this policy is that whilst residents would like to see stronger wording of the policies, the industry, presumably from experience, have identified areas within the policies where they would like to see caveats introduced in the wording. This is an inevitable conflict in the development of policies to guide development which is delivered primarily by the private sector. It is the role of the local authorities, with guidance from government bodies, to ensure that right balance of interests is maintained in the policies.
Proposed Policy 3: Safeguarding existing waste sites Do you agree with Proposed Policy WP3? This question was only asked in the full questionnaire. Options: Yes or No
Response: Only 11 respondents answered this question. 9 agree with the policy, 2 do not (for the reasons set out below).
Do you have any comments on the proposed policy, supporting text of monitoring regime? This question was asked in both the full and short questionnaire and at workshops. Views were also provided by letter and Email. Comments received are discussed below
Views from government bodies 68. All government bodies support the principle of the proposed policy, with the following suggestions for amendments / improvements: • A plan of existing waste sites will is needed in the next version of the Plan • Identify that any compensatory site will be required to deal with at least the equivalent quantity of waste, to ensure conformity with the Mayor’s London Plan • The NHS suggests that a specific reference should be made to the need to safeguard clinical waste facilities • The EA comments that understanding throughput of facilities is extremely difficult, and suggests that in monitoring the Plan, there may be opportunities to improve data collection and understanding of existing treatment throughput
Views from residents and local businesses 69. Local stakeholders’ comments on this policy are set out below:
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• The policy should identify that any development on compensatory sites must meet the policies within the Plan • By safeguarding existing waste sites and requiring compensatory provision if any are lost, the policy doesn’t cater for any reduction in waste arisings and a reduction in the number of waste sites actually needed to manage the Plan area’s waste • Some existing waste sites are not suitably located in modern society and shouldn’t be safeguarded • The wording seems to allow uncontrolled development on the sites which will be listed. The language should be altered to reflect the fact that policy tests will need to be met.
Views from the Industry 70. The industry supports this policy, with the additional comments set out below: • For clarity, a list of existing sites and a plan of these should be included • Clarification is needed on whether these sites are preferred for development ahead of new sites • Clarity is needed on the suitability of existing sites to contribute to the sustainable waste management strategy • Clarification is needed on what is meant by ‘existing permitted level of use’ • Consideration should be given in this policy to the London Plan requirement to ensure that sites are not prejudiced by nearby development
Main areas of conflict and consensus 71. It was generally agreed that a list and plan of existing waste sites to be safeguarded will be needed in the final version of the Plan.
Proposed Policy 4: Proposed sites for new waste management facilities Do you agree with Proposed Policy WP4? This question was only asked in the full questionnaire. Options: Yes or No
Response: Only 16 respondents answered this question. 9 agree with the policy, 7 do not (for the reasons set out below).
Do you have any comments on the proposed policy, supporting text of monitoring regime? This question was asked in both the full and short questionnaire and at workshops. Views were also provided by letter and Email. Comments received are discussed below
Views from government bodies
72. All government bodies support the principle of the proposed policy, with the following suggestions for amendments / improvements:
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• A plan of allocated waste sites will is needed in the next version of the Plan. If wider areas of search are also included in the final plan, these should also be shown on a map base. • The GLA would support these criteria identified in Policy WP5 being re-iterated in Policy WP4 to identify that the proposed sites which will eventually be identified in this policy have already been considered against a broad range of criteria. • Suggestion that the policy also refers to ensuring that existing recovery rates are not compromised when an existing waste site is re-developed for waste management use • Suggestion that the policy may benefit from clarification on how compensatory sites will be provided if an existing waste facility use is lost. • Suggestion that the policy would benefit from identifying that any proposals must also meet tests within the other policies within the Plan. • The EA identify that in some cases, the redevelopment of existing waste sites (where waste is treated further up the waste hierarchy) will result in a lower throughput onsite. The EA suggests this needs consideration. • The EA suggests that further clarification is needed in respect to flood risk, groundwater protection and local nature conservation
Views from residents and local businesses 73. Local stakeholders’ comments on this policy are set out below: • The justifying text should identify the process by which sites have been selected • Clarification is needed on where the compensatory site provision would be. It is suggested that the Plan should allocate sufficient sites that additional compensatory sites are not needed. • The plan should identify constraints for each site • The wording seems to allow uncontrolled development on the sites which will be listed. The language should be altered to reflect the fact that policy tests will need to be met.
Views from the Industry 74. The industry supports this policy, with the additional comments set out below: • Add reference in this policy to Metropolitan Open Land (MOL) and Planning Policy Statement 10 which states that in developing waste plans, local authorities should :“ protect green belts but recognise the particular locational needs of some types of waste management facilities when defining detailed green belt boundaries and, in determining planning applications, that these locational needs, together with the wider environmental and economic benefits of sustainable waste management, are material considerations that should be given significant weight in determining whether proposals should be given planning permission” 17 • A suggestion that it would provide greater clarity if Proposed Policy WP3 deals with existing waste sites (and identifies their developmental potential), whilst Proposed policy WP4 to deal with new sites. • Clarity is needed on the term, ‘ ”waste management facilities” and should be clarified for the avoidance of doubt • The redevelopment of waste transfer stations to waste treatment facilities may actually lead to a decrease in the quantity of waste being dealt with. The respondent requests that consideration should be given to making an exception for sites being redeveloped from transfer to treatment. • The policy should identify that the other policy tests within the Waste DPD need to be met
Main areas of conflict and consensus 75. The EA and some industry representatives have identified that further consideration should be given to the redevelopment of some existing waste sites, perhaps existing waste sites in particular.
17 Insert paragraph reference to PPS10 here
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Proposed Policy 5: Waste related development on unallocated sites Do you agree with Proposed Policy WP5? This question was only asked in the full questionnaire. Options: Yes or No
Response: Only 16 respondents answered this question. 11 agree with the policy, 5 do not (for the reasons set out below).
Do you have any comments on the proposed policy, supporting text of monitoring regime? This question was asked in both the full and short questionnaire and at workshops. Views were also provided by letter and Email. Comments received are discussed below
Views from government bodies 76. All government bodies support the principle of the proposed policy, with the following suggestions for amendments / improvements: • TfL welcome the priority given to sites where materials entering / leaving the site can be transported by rail or other sustainable means • TfL and the HA recommend the inclusion of a criteria which supports sites which staff can easily access by cycling and walking • The NHS welcomes the supporting text which states that the development of waste facilities should not endanger human health and encourage strengthening the wording in bullet 3) of this policy • The NHS recommend ensuring that all development are based on need
Views from residents and local businesses 77. Local stakeholders’ comments on this policy are set out below: • Protection should be given to sites of metropolitan importance and other locally important nature conservation areas • Protection should also be extended to protect any location which supports locally, nationally or internationally protected species (e.g. land around nature conservation areas which is often very important to species). • More detailed monitoring indicators are needed to assess impacts of development of people, the environment and natural resources. • The list of criteria within this policy needs to be extended to cover all the issues which have been considered in identifying suitable sites e.g. include proximity to residential areas, impact on visual amenity, distance from local nature conservation areas • The policy should states that the views of local people will be taken into consideration • The policy should ensure that development is not close to where people live and work • The policy should give greater protection for green belt, open land • Greater consideration is needed about traffic impacts; the suitability of the roads / road safety issues as well as the proximity to the strategic road network • The policy should consider the risk of flooding in future as well as current flood risk
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• Clarification of the term, “ sustainable transport ” is needed
78. Whilst comments were received in support of greater protection to local nature conservation areas, green belt, open land protected, comments were also received to ensure that development is further from local people which tend to be in such open areas.
Views from the Industry 79. The industry supports this policy, with the additional comments set out below: • Welcome the flexibility which this policy provides • Request that the policy should be amended to require developers to demonstrate that existing sites are not available / suitable for redevelopment, but not to extend this to new ‘preferred’ sites. It’s not considered necessary as long as the site being proposed meets the development criteria in the policies.
Main areas of conflict and consensus 80. Stakeholders have commented on a wide range of issues relating to this proposed policy.
Proposed Policy 6: Development criteria Do you agree with Proposed Policy WP6? This question was only asked in the full questionnaire. Options: Yes or No
Response: Only 19 respondents answered this question. 11 agree with the policy, 8 do not (for the reasons set out below).
Do you have any comments on the proposed policy, supporting text of monitoring regime? This question was asked in both the full and short questionnaire and at workshops. Views were also provided by letter and Email. Comments received are discussed below
Views from government bodies 81. All government bodies support the principle of the proposed policy, with the following suggestions for amendments / improvements: • TfL welcome the priority given to sites where materials entering / leaving the site can be transported by rail or other sustainable means • TfL and the HA recommend the inclusion of a criteria which supports sites which staff can easily access by cycling and walking • TfL requests that the highways impacts of proposals must be fully modelled in line with TfL guidance and should include a Construction Logistics Plan and a Delivery Servicing Plan to help reduce the impacts on the TLRN and SRN • Suggestion that monitoring indicators around vehicle movements / numbers should be expanded and applied throughout the policies • It will be important to consider the impact of proposed sites and policies on existing UDP policies and emerging LDFs which, for example, may not allow development in particular
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locations or may require consideration of particular issues. This is likely to be particularly important for sites which are located near to sites of importance for nature conservation • The NHS welcomes the reference to protecting human health and recommend this is strengthened in the policies. The EA also welcome greater recognition of the impacts of particulate matter and bio-aerosols in this policy. • The EA requests that this policy is strengthened to recognise the role of consulting with the local community, deliver environmental enhancements (e.g. green roofs, river and watercourse restoration/improvements, sustainable drainage, sustainable construction) as well as greater environmental protection. They suggest the following wording should be added, “ Development will be expected to improve the local environment and early consultation with local communities is essential.” • The EA would welcome strengthening the wording around encouraging developers to engage with relevant authorities before submitting an application. They suggest adding the following wording, “Developers are encouraged to contact the appropriate partner borough and the Environment Agency prior to submission of a planning application to discuss all relevant matters.” Local communities should be central to the decision making process and consulted early where any new waste sites or upgrades to existing facilities are proposed .”
Views from residents and local businesses 82. Local stakeholders’ comments on this policy are set out below: • Protection should be given to sites of metropolitan importance and other locally important nature conservation areas • Protection should also be extended to protect any location which supports locally, nationally or internationally protected species (e.g. land around nature conservation areas which is often very important to species). • Additional consideration should be given to the impact of waste development on the proposed Wandle Regional Park. Consideration of the environmental impacts, particularly noise, visual impact, emissions and odour on the proposed Wandle Park must be ensured. • The consideration around air quality impact should be strengthened • The consideration of impacts of habitats should not be limited to land adjoining sites. Impact assessments must recognise that different species use landscapes in different ways and it may not just be the adjacent land which is important to their survival. • The Wandle Trust request that this policy should include an assessment of the development on heat and evapotranspiration from the site, which is related to the urban heat island effect • Consideration is needed in this policy of the impacts of hours of operation, particularly night working, 24/7 working which will disturb local residents • Request to improve the monitoring indicators for this policy to identify the numbers of permissions granted contrary to advice from statutory stakeholders (and identify who those are) • Under the issue of design, consideration needs to be given to the layout of the site to ensure that impacts on residents (particularly noise) are reduced as much as possible • The policy should state that proper engagement with local people is needed in the planning process • Concerns about how local authorities will monitor the impacts of development, particularly air quality (when most boroughs have few air quality monitoring stations) and health impacts • Consequences of exceeding permitted levels of traffic, air quality etc need to be stated • The policy needs to address impacts from increased traffic; not just air quality, but also residential amenity, road safety, the suitability of the roads themselves, leakage from vehicles travelling to/from the site, mud spray, damage to cars • In terms of monitoring, it is suggested that this identifies compensatory measures to be taken if monitoring demonstrates levels of pollution etc in excess of permitted levels • Concerns about loss of employment
83. The issue of the enforcement of facilities once they are operational was found to be a key concern for residents and was raised at most residents meetings. On this issue, national
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planning guidance (PPS10) advises local authorities that, “ planning authorities should concern themselves with implementing the planning strategy in the development plan and not with the control of processes which area matter for the pollution control authorities.“ And furthermore that, “Waste planning authorities should work on the assumption that the relevant pollution control regime will be properly applied and enforced.” 18 However, residents are very keen for greater certainty on the control of facilities. At meetings, residents cited recent examples of pollution incidents within the Plan area (e.g. a chemical spill from Thames Water’s operations at Beddington Farmlands into the River Wandle in 2007). Residents were also aware of ongoing disputes between the local authority and existing waste operators. From the comments received, there appears to be general and wide-spread mis-trust of waste operators complying with planning conditions or controls of, for example, traffic levels and emissions. There also appears to be dissatisfaction of the ability of enforcement officers / the Environment Agency to monitor and regulate waste facilities.
84. Other residents are concerned about the safety of modern waste management facilities. Residents living around the Rainbow Park Industrial Estate (one of many sites which were identified in the consultation materials as a potential waste site) were concerned about the risk of explosion of biogas which is produced from some waste processes (e.g. anaerobic digestion).
Views from the Industry 85. The industry supports this policy, with the additional comments set out below: • Welcome the flexibility which this policy provides • Request that the policy should be amended to require developers to demonstrate that existing sites are not available / suitable for redevelopment, but that this should not be extended new sites. • Clarification is needed on the term, “for the entire operation of the facility.” Does this refer to the process from beginning to end, or to the cumulative effects of additional development, for example, where facilities are being extended / intensified? • Suggestion that the monitoring role identified in the justifying text is a duplication of the role of the environment agency and should not be required • Recognition should be given to the fact that in redeveloping a site, traffic could be reduced • Recognition should be given to the benefits of providing renewable energy and heat • The requirement for developments to provide renewable energy in its design is not referenced • Clarification is needed on what would be needed to satisfy criteria 4, “ an assessment of the impact of greenhouse gases produced .” • Clarification is needed on what constitutes, “ the best design standards ” available; this is considered vague and reference should be made to policy governing design (design issues are also raised in proposed policy WP2 and this could be confusing) • Criteria 5), “ the impact of development the biological diversity of flora and fauna ” is open to interpretation and needs to be clarified. Does this apply to all sites or just those which are of recognised nature conservation importance?
Main areas of conflict and consensus 86. There is consensus across government bodies and residents that greater consideration needs to be given in this policy to the traffic impacts of development; and as highlighted by the industry, recognition should also be given to the fact that some redevelopments may lead to a decrease in traffic movements.
87. There is also consensus across some government bodies and local stakeholders of the need for potential developers to engage local communities, the EA and the relevant local authority early.
88. There were several views raised by the EA, local residents and local environmental groups around the need to strengthen the policy requirements around safeguarding local nature conservation sites and biodiversity and providing opportunities for improvements.
18 Paragraphs 26-27 of Planning Policy Statement 10: Sustainable Waste Management
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89. There is further consensus across the EA and local residents on the need to strengthen the policy wording around the control and monitoring of new waste facilities; though this is not shared by some industry respondents.
Proposed Policy 7: Sustainable, modern energy recovery Do you agree with Proposed Policy WP7? This question was only asked in the full questionnaire. Options: Yes or No
Response: Only 17 respondents answered this question. 13 agree with the policy, 4 do not (for the reasons set out below).
Do you have any comments on the proposed policy, supporting text of monitoring regime? This question was asked in both the full and short questionnaire and at workshops. Views were also provided by letter and Email. Comments received are discussed below
Views from government bodies 90. All government bodies support the principle of the proposed policy, with the following suggestions for amendments / improvements: • The NHS supports the encouragement of cleaner technologies, and would support this policy as long as it represents no additional adverse health impacts when compared to other technologies. • The EA notes the preference for gasification, pyrolysis and anaerobic digestion and recommends that consideration is also given to energy from waste, where it can meet all waste hierarchy criteria and the proposed efficiency criteria which may require the production of both electricity as well as heat output via high quality steam use or district heating and cooling.
Views from residents and local businesses 91. Local stakeholders’ comments on this policy are set out below: • Thermal treatment must ensure that combined heat and power are provided for the local community to have maximum benefit • Ensure that recyclables / biodegradable material isn’t thermally treated (concern that thermal treatment discourages recycling) • Ensure that material is sourced locally • The policy should only encourage modern technologies • Concerns about emissions and pollution from thermal treatment facilities • Reference needs to be made to the reuse of materials in the first instance • The policy must ensure that waste treatment has a neutral carbon footprint, or better • Opposition to incineration of waste
Views from the Industry 92. The industry supports this policy, with the additional comments set out below:
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• Support the preference for proposals with a lower carbon output to ensure the best environmental outcomes and believe this should be strengthened • Request that specific technologies should not be mentioned in the policies since the DPD is technology neutral in all other respects and the focus should be on outcomes • One respondent identifies that the first criterion, which states that planning permission will be granted where 'the waste identified for treatment cannot practically or reasonably be managed further up the waste hierarchy' is already set out in national policy (PPS10) and is therefore unnecessary to repeat it as part of the DPD. • The policy implies that an assessment of the waste streams is need for each application which would come forward, which is unreasonable and unnecessary • The second point of the policy requires for provision to be made for the facility to 'produce electricity and heat or electricity, heat and cooling.' Although this should be considered as part of the planning application process, we believe it should not be embedded in Policy, as it may not be possible or indeed practical. • The third point of the Policy requires that heat and power be available to local users, proximate to the source of the energy production, unless the applicant can demonstrate there is no current or prospective demand. However, even where there is a demand, there may be other factors such as third partly land ownership, which prevent the delivery. This statement should therefore not be embedded in Policy.
Main areas of conflict and consensus 93. There is general support across all stakeholders that the most modern thermal treatment facilities, with the lowest carbon output should be encouraged. There is some agreement amongst local stakeholders that thermal treatment facilities should provide heat and power for local use to enable maximum benefit, though the industry observes that there are often practical difficulties with achieving this.
Summary 94. It is clear from the responses received to the Stage 2 consultation that a number of issues need further discussion and agreement including traffic impact (in its widest sense), air quality impacts, noise, visuals and other relevant planning impacts.
95. Further consideration also needs to be given to residents’ concerns about what will be built on each of the sites identified and how this fits with statutory bodies’ and the industry’s general view that the Waste DPD should focus on the impacts of development, rather than specifying in detail what should be built on each site.
96. There is also the need to give greater consideration to the deliverability of the South London Waste Plan. The Planning Inspectorate has asked that sites identified in the final Waste Plan are deliverable and to satisfy this, we have been advised that the Plan must identify potential delivery partners. Further work is required with the industry to achieve this.
2.3 As identified in this report, a number of additional sites, not previously considered in the Plan’s development have been identified. Further consideration of these sites is needed internally which may lead to additional public consultation on these sites.
The next stage of the Plan’s development 97. The next formal stage in the Plan’s development is the publication of what the four partner boroughs consider to be the final plan. Once agreed, this will be published for a period of 6 weeks only and stakeholders will be able to submit comments on the way the Plan has been developed and agreed.
Appendix 1: Write up from the four public workshops held during September 2009
Appendix 2: All responses received and initial officer response
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Appendix 1
Proceedings of the Sites and Policies Consultation stage of the South London Waste Plan 2009
Croydon, Merton, Sutton ad Kingston Events - September/October 2009
FINAL DRAFT
October 2009
Agenda Item 3 Page 56
Proceedings of the Sites and Policies Consultation stage of the South London Waste Plan 2009
Croydon, Merton, Sutton ad Kingston Events - September/October 2009
FINAL DRAFT
Prepared by CAG Consultants
October 2009
CAG CONSULTANTS Gordon House 6 Lissenden Gardens London NW5 1LX Tel/fax 020 7482 8882 [email protected] www.cagconsultants.co.uk
For direct enquiries about this document please contact: Name: Dr Susan Parham CAG Consultants tel 020 7704 0018 email [email protected]
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Contents
Contents 41
Summary of points made 42
Introduction 46 Background 46 About the consultation events 46 Number of people attending events 49 The range of participants 49 Structure of these Proceedings 49
Croydon comments 51 Overall points 51 Comments in relation to Policies 51 Comments on sites 54
Merton comments 57 Overall points 57 Comments on Policies 57 Comments on Sites 58
Kingston comments 62 Overall points 62 Comments on policies 62 Comments on sites 63
Sutton comments 68 Overall points 68 Comments on policies 68 Comments on sites 71
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Summary of points made
About the waste plan and its policies A large number of comments made linked the waste plan to improvements in recycling, with for example suggestions of pushing the recycling rate up to 90%. A considerable number of participants wanted to make sure that recycling policies were able to reduce the amount of waste the plan would need to deal with. A typical view was “If policies to reduce waste are successful will the plan be able to reflect the lower quantities of waste? We don’t want contractors “encouraging” waste in order to keep plants working. How is the plan going to anticipate this “problem”?”
A number linked such improvements to avoiding the need to build facilities especially incinerators. “We need to recycle more. Avoid an incinerator at all costs. No contract for the incinerator company to have to give them a certain amount of rubbish to burn – absurd!”
Some participants were keen to know more about, or were concerned about, the relationship between procurement of waste facilities now taking place and the longer-term process of developing the waste plan. A few said the procurement should wait until the plan was completed.
A considerable number of comments were made about unacceptable behaviour of existing waste operators (see more below) and the need for the plan to have ‘real teeth’ to deal with private sector operators in future.
A number of participants said they wanted more information about the waste technologies that might be used waste sites. A few said it was hard to comment without know more specifics. “When can local people have a say on the specifics – what technologies are proposed at which sites?” Others were more concerned to ensure the best technologies were employed. “The policies should ensure that developers follow best international practice so that any modern facilities which are built are using the latest technologies and methods.”
A number asked about emissions and wanted more information about whether any noxious emissions, dust or smells would be generated on any sites. “I want a cast
iron assurance that any incinerator will capture CO2 emissions to the max with no dust or smells.” Another said “Can you give a categorical assurance that public health will not be compromised by exposure to emissions?”
A number said that they wanted to make sure sites generally were both attractive and well run so that there were no adverse impacts on surrounding areas. “Facility must look good, blend in, well-managed, clean, well run, don’t want any rubbish impacting on local residents.”
A number of participants raised issues about the transport of waste. This was about the problem of lorry movements (noted below) but also about making sure in future that waste was moved in a more sustainable way such as by rail and water,
Page 59 Agenda Item 3 with a related point that site location should help ensure this was possible. “In policy WP2 however, there is no reference to rail/water transport – only ‘sustainable’ transport. What does this mean? Rail? Water? If yes, this needs to be made more clear in the actual policy”.
A number of participants asked for assurance in the plan that there would be no waste incineration facilities built. “Is it definite that mass burn incineration of waste will not occur on any of the sites?”
Conversely, a number of participants said that clean incineration was a good idea especially if it generated energy to be used locally. “People’s images of incineration (e.g. SELCHP) are two generations of technology behind. For instance, Denmark has very clean incinerators in residential areas, which do not even require a high stack (chimney) because emissions are so clean.”
A related question was “If district heating is to be one of the benefits of burning waste - how are residents who are not local to these parts going to benefit? Will this not be unfair? Should the solution be a much more radical spread of the waste burning plants? Can they be smaller and more local?”
A number wanted various policies’ wordings to be clarified such as the meaning of ‘significant impacts’, ‘wherever possible’ or ‘thermal treatment’. A few made comments about waste being described in the policies as a resource, feeling it implied wrongly that more would be welcomed rather than waste minimisation being the aim. Others suggested policy monitoring needed more attention and results should be made public.
About the sites Participants had many questions about identified sites including about the criteria used in the assessment process, including the weighting given to different sites. A few said sites should not be placed in their borough at all, and others wondered whether the spread of sites was fair, or whether their borough was being expected to take a disproportionate amount of waste. Some wondered whether the sites reflected the best locations in terms of transport access and keeping way from densely populated areas, shops, residents, schools, green space and nature conservation areas etc.
The problem of loud, dirty lorry movements was an issue across a number of sites and people living close to existing sites felt they were particularly having to bear a heavy burden from these. Many complained about councils failing to enforce operating conditions on particular businesses. There were many comments about Beddington Lane in this regard. Another example was near Site 6 (Villiers Lane), where among other concerns, lorries were a substantial issue. “Hawks Road has had to put up with these heavy lorries for the last 7-10 years. It is time to consider the residents after all this time and let some other roads take their share”.
A few potential sites received a number of positive comments about their possible use for waste facilities, such as Site 47 and Site 351/352 although constraints such as traffic congestion were also mentioned.
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Some current waste sites and/or areas round were clearly causing significant problems to a number of participants. These included Beddington Lane, Villiers Road, Garth Road, Benedict’s Wharf, and Site 353 - Oakcroft Estate, among others.
In this area, a number of residents from Beddington were extremely concerned about their current situation with comments including the following: “This whole consultation process is just one big con! Beddington Lane has already been identified as the victims - the only sites where there are no deliverability constraints. For once think of the problems! We already suffer and consider those living in this already blighted area thanks to decisions made in the past!!”
Participants saw a number of likely problems with various of the identified sites being used for waste facilities including increases in pollution; health risks including cancer and respiratory problems; traffic congestion; noisy, disruptive heavy lorry movements; danger to pedestrians including school children; contamination of waterways; flooding risks; land contamination; a bad neighbour to housing (new and existing); adverse effects on property values; smells and dust; undermining nature conservation and habitats; not in line with the waste plan policies proposed.
Sites that might be used (or extended from their current use) were also thought by some participants to be potentially problematic, including Rainbow Park Industrial Area, Factory Lane/Purley Way, Land at Kingston Road/Jubilee Way junction, Willow Lane Industrial Area, and Durnsford Road, Plough Lane, among others.
Participants had a number of suggestions about how waste facilities could be more sustainable and better run. Examples from mainland Europe were cited and included clean incineration (producing energy) and methane capture technologies. “European countries are way ahead of the UK on energy recovery and waste disposal”.
About the process A substantial majority of participants liked the drop-in format, which they said allowed them to get information, speak to council staff and make their views know in an unthreatening environment. “This was a much better way of doing it, other types of events can get dominated by three of four people ”.
Feedback received from a much smaller number of people said they would have preferred a traditional public meeting in order to have a more group presentation and discussion of issues. “I would have preferred a Q & A session so that people’s views could have been heard by everyone and that officers’ explanations were not repeated by everyone”.
A number of people suggested minor improvements to the drop-in process they felt would make it better in future, such as having an initial introductory talk from council officers and clearer name badges.
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There was concern from some participants that their views would not be taken seriously. “Will the policy makers actually take any account of residents’ views, or, as with traffic issues, just implement their own plans anyway?”
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Introduction
Background Four London boroughs of Croydon, Kingston, Merton and Sutton have formed a partnership to prepare a Joint Waste Development Plan Document (DPD), known as the South London Waste Plan. The South London Waste Plan will set out a planning strategy for sustainable waste management for the four boroughs. It will identify sites suitable across the four boroughs for locating future waste management facilities as well as a set of policies against which future applications will be assessed.
The first stage of consultation on the Waste Plan took place in September and October 2008. At this stage, the consultation materials sought feedback on a range of issues, including the very broad area of search for sites which was identified as industrial land plus existing waste management sites. Importantly, they also sought feedback on a range of criteria which need to be considered in locating suitable sites (e.g. proximity to residents, conservation areas etc).
Since that time, the Plan has progressed. The second stage of consultation for the Plan is underway. A list of potential sites has been identified and the boroughs are seeking feedback on these during a consultation period, which runs until 16 th October 2009. The boroughs have also drafted a set of policies, which will be used to assess future applications for waste facilities. Again, the boroughs have been seeking feedback on these during the consultation period.
CAG Consultants was commissioned by the four partner boroughs involved in the South London Waste Plan to provide specialist support for these consultation activities. This included designing and running consultative events in Merton, Sutton Croydon and Kingston.
About the consultation events Four events were held:
• Monday 7 th Sept, Croydon Clocktower, 7pm - 9pm
• Wednesday 9 th Sept, Merton Civic Centre, Morden, 7pm - 9pm
• Wednesday 16 th Sept, The Guildhall, Kingston, 7pm - 9pm
• Monday 28 th Sept, Civic Offices, Sutton, 7pm - 9pm.
These events were intended to provide local residents the opportunity to find out more about and make comments on the potential sites and policies, which had been identified as part of the development of the Waste Plan. The boroughs described the purpose of the events in the following way:
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“to seek feedback from local people on the potential sites and policies identified in the consultation documents. The events also provide an opportunity for local stakeholders to voice concerns and for us to listen and address their concerns. We intend to secure experienced facilitators to plan and facilitate these workshops to help fulfil the meeting purpose and make them as productive as possible”.
These events were run as ‘drop in’ sessions in which a number of council staff, some councilors and waste plan technical consultants were available to discuss the policies and sites and these policies and sites were shown on large display panels and maps. CAG staff acted as facilitators to help this process occur and make sure concerns and ideas were documented as far as possible. Participants were encouraged to record their points of view. This was done in a number of ways:
• Through participants writing up comments on maps and policies boards;
• Through facilitators noting down participants’ verbal comments;
• Through participants filling in South London Waste Plan questionnaires; and
• Through some participants recording a short video on a video booth provided at each drop in event (10 people made a short video message on their views about the waste plan for the boroughs to view).
The written comments are documented here, while the videos and transcripts have been forwarded to the boroughs.
The events were designed as ‘drop ins’ with a lot of information provided on boards, and individual officers and experts to speak to, rather than as traditional meetings with presentations and question and answer sessions. This was to maximize the amount of information provision and opportunities to comment on policies and possible sites. CAG ran an ‘exit poll’ at the end of each event to receive feedback on the process. This was to see whether participants felt that it had worked for them in finding out more about the waste plan and making their views know, and to suggest any improvements. Overall the feedback was largely positive. Typical comments were that:
• Our views were captured much better this way, rather than a public Q & A, through the post-it notes etc;
• The meeting wasn’t ‘taken over’ by more vocal participants ;
• This was a much better way of doing it, other types of events can get dominated by three of four people ;
• A chance to meet other locals and discuss views with them;
• I was free to wander around. This format had much more impact for me than a traditional Q & A session ;
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• I learned more here than at an ordinary meeting, although not sure whether I will be listened to;
• I got to give my views in the video booth;
• I was able to tell officers what I thought;
• It was better than being talked at .
However some participants did not feel that aspects of or the whole format worked so well for them and some would have preferred a more traditional meeting structure. Typical comments were:
• It wasn’t possible to speak to all of the officers and consultants as some of them were ‘hogged’ for a long time by other residents;
• I would have preferred a Q & A session so that people’s views could have been heard by everyone and that officers’ explanations were not repeated by everyone;
• I was expecting a public meeting;
• I came away with more questions than answers ;
• The meeting didn’t facilitate public discussion or group working – I would have preferred small group facilitation followed by plenary discussion.
Participants suggested a number of improvements could be made. These included having some kind of introduction or initial plenary, better signposting of staff/experts, techniques to make sure everyone got to speak to staff, information about technologies, and suggestions for circulating Proceedings:
• A 5-10 minute introductory talk would have been very helpful to help give everyone an overview of the issues;
• An introduction to the format at the beginning of the event would have been helpful, to help people navigate through the evening and identify who to speak to;
• I liked the format, but would have preferred a plenary session at the beginning;
• I would have liked more information about the technologies that could be used;
• It was hard to identify officers and consultants. Some didn’t have name badges on and even those that did weren’t obvious. Bright t-shirts would have helped.
• I wanted more councillors there .
Page 65 Agenda Item 3
• A copy of proceedings should be sent directly to all participants, rather than being an appendix to the consultation report only found on the Internet .
Number of people attending events Overall 214 people attended the events (based on numbers registering for each at the door), and the numbers were broken down as follows:
• 50 at Croydon;
• 47 at Merton;
• 45 at Kingston; and
• 72 at Sutton.
The range of participants There was a wide range of people at the four drop in events, including:
• Local residents;
• Representatives from the waste industry;
• Transition Towns;
• Conservation Groups;
• Residents Associations;
• Faith groups;
• Political party representatives;
• Local Friends of the Earth groups; and
• Local press.
Structure of these Proceedings This Proceedings documents in as much detail as possible the comments made by those attending the events. These have been written up directly from comments left by participants. It also provides a summary of key issues raised. It is structured as follows
• Summary of issues raised;
Agenda Item 3 Page 66
• Introduction;
• Croydon comments - in general, on waste plan policies and on possible sites;
• Merton comments - in general, on waste plan policies and on possible sites;
• Kingston comments - in general, on waste plan policies and on possible sites;
• Sutton comments - in general, on waste plan policies and on possible sites.
Page 67 Agenda Item 3
Croydon comments
Overall points How does the procurement process work - will the four councils procure together or separately?
What links are being made with Defra’s consultation on the waste strategy?
Why does the process take so long when developers in Scandinavia or Manila can propose the latest high tech efficient technologies and can get them set up without the delay of the planning process that we have in the UK?
Why was a drop in session chosen, when a questions and answer session would have given people the opportunity to hear other people’s questions and have an audience discussion?
How else can people input during this stage? And future stages?
When can local people have a say on the specifics – what technologies are proposed at which sites?
Where can I get more technical information?
Comments in relation to Policies Encourage recycling of a large range of items and reduce non-recyclable packaging.
Why no levels of noxious emissions?
Re use, recycle, reduce.
I want a cast iron assurance that any incinerator will capture CO 2 emissions to the max with no dust or smells.
I am concerned about the huge impact of plastics on the environment. It needs government intervention to change production – one type of plastic only that can be recycled. Whenever possible, alternative containers to be used.
Emissions – will there be any? What will they contain? What is the fall out area? What tests have been done on health implications?
Supermarket bag recycling across the 4 boroughs.
Agenda Item 3 Page 68
Sites should be ‘bunded’ because geology around here is sandstone.
Policies should be very focussed on what comes out of facilities to make sure there is no environmental damage.
I am concerned that recycling should come before incineration. That where viable energy be produced from waste. If this can be locally produced so much the better to minimise transport. Waste sites should have adequate access.
How can we choose a site when we don’t know which facility will be placed there?
What happens to disposable nappies?
Clarify that hazardous waste not involved in this process/scenario.
Can you give a categorical assurance that public health will not be compromised by exposure to emissions?
When will details of new technology be available?
Will councils pressure supermarkets on excess packaging?
Can you trust business to use science and technology properly?
No landfills no incinerators. Closed loop system to breakdown to inert reusable substances, creating down energy use.
If this process will decide the waste management processes for processing the waste, how will collection processes e.g. black bin bag collections/kerbside recycling be decided?
Why does the document say that the procurement process for black bin bag collections ‘began in May 2010’? Is this a typo, and why is a procurement process being conducted before the strategy is agreed?
Will the policies make any different – or will the councils do what they want anyway?
Which technologies are the councils biased towards?
The policies should ensure that developers follow best international practice so that any modern facilities which are built are using the latest technologies and methods;
In WP1, the policy should ensure that the most efficient facilities are built to ensure we take advantage of international advances in processes and technology. Facilities will improve as time goes on and we need to build this into the policies so that we’re always ensuring the best, most efficient and modern facilities are built. E.g. as time goes on, advances will be made to ensure facilities are less smelly, less noisy, process waste more efficiently etc.
Page 69 Agenda Item 3
In WP2, the policy should require local authorities to lobby central government to do more about packaging waste. Under the Sustainable Communities Act, local authorities now have the power to put pressure on Government to require companies (particularly those who local authorities procure goods from), to reduce packaging. This should be done.
In policy WP2, ‘re-use’ needs to be more explicit. We need to look at the building first; can the building be re-used as it is? What about fixtures and fittings? The policy as it stands seems to imply that the building materials e.g. bricks will be re- used, but the policy needs to go further and encourage the salvaging of any other parts e.g. windows, lighting fixtures, radiators etc.
In the supporting text to policy WP2, I really support the idea of movement of waste by rail/water.
In policy WP2 however, there is no reference to rail/water transport – only ‘sustainable’ transport. What does this mean? Rail? Water? If yes, this needs to be made more clear in the actual policy.
Policy WP2 (point 5) also fails to refer to the dismantling and reuse of components of buildings e.g. windows, radiators etc. This needs to be in the policy.
Policy WP6 – what does ‘significant’ adverse effects mean? What constitutes ‘significant’?
Policy WP6 talks about traffic impacts but how do you measure the transport impacts of using rail/water? This needs to be considered because it may require the building of wharfs/additional rail lines etc and this isn’t currently considered under the policies.
The tables on monitoring need to be made clearer. How is the monitoring information going to be made public? This should be stated. Also, why not make this available every 6 months? Why only annually?
Table 3.19 of the A4 consultation document refers to a Sutton borough target. Will this apply to all boroughs? If yes, this needs to be made more clear.
Table 3.22 of the A4 consultation document talks about the number of planning permissions given despite EA advice to the contrary on air quality issues. Does this mean that planning permissions can be given despite the EA objecting on air quality grounds? What are the local authorities doing about this?
Para 3.33 of the A4 consultation document needs to continue to also say that people will be consulted about changes to existing facilities (i.e. they won’t only be consulted if it’s about new facilities but also consulted about changes to existing facilities where planning permission is needed);
The table of policies to be superseded – in the next iteration, you should make it clear which policy is taking over the old policy. At the moment, this isn’t stated in the table, so no direct correlation can be made.
Agenda Item 3 Page 70
Comments on sites Could waste sites incorporate methane capture into sewage sites already not near housing areas?
Have new technologies in other countries been studied to find out what works and potential problems?
We need to recycle more. Avoid an incinerator at all costs. No contract for the incinerator company to have to give them a certain amount of rubbish to burn – absurd!
Make it safe sustainable for all of us. Get agreement of the residents of the boroughs.
Why are these sites in Croydon anyway? Why not another incineration area: London Bridge, Belvedere, Heathrow?
Why have it near residential area and school?
Access to sites should bring waste in a manner to cause minimal environmental impact. Traffic chaos could be caused by large lorries in narrow roads like Bushy Lane. Could tramlines be used for transportation?
I’m interested to know more about how additional sites have been assessed, in particular the first additional Croydon site. This would be suitable for small-scale composting and recycling but not, in my view, other uses – has this type of issue been considered in the site assessment?
This consultation is linked to the current Defra consultation on waste processing methods, isn’t it? [Facilitator attempted to clarify that it was not linked.]
The biggest issue is the need for more doorstep recycling – to reduce volumes of waste for disposal. The council needs to invest more in this.
Should there be a recycling hub for waste you can’t put into your boxes?
Need staffed neighbourhood recycling facilities. Greater doorstep collection.
Municipal waste should be 70% recycled – not 45% like in London Plan.
Find out where people are from.
In the stage 1 consultation, there was talk of having a centralised system of waste management sites for all boroughs: for example, 1 big plastics recycling centre, 1 big metal recycling facility, 1 big composting facility. I am concerned that this would generate too much transport across the boroughs and hope it is not being taken forward.
European countries are way ahead of the UK on energy recovery and waste disposal. They get on and do it while the UK takes years and years to consult (e.g.
Page 71 Agenda Item 3 first on plans and then on planning applications). People’s images of incineration (e.g. SELCHP) are two generations of technology behind. For instance, Denmark has very clean incinerators in residential areas, which do not even require a high stack (chimney) because emissions are so clean. People do not understand that there are far more molecules of dioxin in a normal cubic meter of air than in the scrubbed emissions from a modern incineration plant.
The Waste Plan must have real teeth to deal with private sector interests, which tend to win out in the borough of Croydon. Stipulations must be made clear and then monitored and enforced, otherwise private companies will find ways round them and not deliver what the document says.
Why not have an incinerator? This could solve waste problems and energy problems at one stroke.
The map suggests that major recycling sites (i.e. civic amenity sites) would be too far apart. They need to be more local within each borough to reduce resident’s travel to these sites. [Facilitator explained that not all current recycling sites are shown on the preferred sites map]
Why are all the proposed sites in the more densely populated parts of the borough, rather than in the south? For instance, the Factory Lane site is near residential areas and schools.
What happens to industrial companies already operating non-waste businesses on proposed waste sites?
Would existing firms being displaced by a waste facility result in a net loss of jobs?
The first consultation round identified nature conservation as a key issue. Yet the sites in Stage 2 are all in close proximity to nature conservation areas.
Purley Way sites could be used and suitable. Factory Lane has accessible roads.
Re Purley Oaks Recycling Centre: The pond, trees around are a green lung. This site is on a busy road which cannot deal with it at all at present. If it was extended for more recycling containers, traffic would be able to get off road more quickly. If the site was used for a scheme which involved more heavy vehicles congestion would be worse.
Factory Lane/Purley Way – The works could cause a smell nuisance, lorry journeys, particulates. Amenity impact may be less in Merton.
There is an estate down the whole of Purley Way South. Purley Way is already overloaded with traffic.
So where’s the incinerator going then? If only 15% of waste is going to landfill, then there may have to be some form of incinerator. You would not want an incinerator to be put near residential areas or schools. So an incinerator will end up in Beddington Lane, won’t it? [Participant talked in detail to technical expert about site 532.]
Agenda Item 3 Page 72
2 preferred sites are next to the Beddington Farmlands site, or adjacent to it. Both raise nature conservation issues. This goes against the principles set out in the consultation document. Beddington Farmlands is home to the tree sparrow. There is a large concentration but it is difficult to keep them there. Development on these sites could have disastrous results.
I’m concerned about site 641 in Wimbledon as I’ve just bought a flat next to it and am concerned about the impact on its value.
Page 73 Agenda Item 3
Merton comments
Overall points Have big maps of all 4 boroughs – some participants could have commented on sites in other boroughs.
Room too small.
Do brief presentation at the beginning, explaining process, status, who’s who, then wander about.
This meeting not a good way to capture everyone’s views – need people sitting down and listening to each other and minutes taken. [Firstway resident]
Technical reports ought to be available at public libraries.
Will the policy makers actually take any account of residents’ views, or, as with traffic issues, just implement their own plans anyway?
Many residents not happy with the format for this evening. Questionnaire in consultation report is too complicated (e.g. p33 shows sites not being prioritised, but will people grasp this?). And p60 ‘Q4a’ not easy to answer. Consultation should be much simpler. More general questions, e.g. do you agree with the SLWP? Where do you live? How would it affect you? Weighting is flawed: findings on traffic and residential proximity were doubled – is this right? [comment by Councillor]
Comments on Policies A priority should be a reduction in the amount of non-recyclable waste – plastics and non-biodegradable waste then additional sites would not be needed.
There has been talk for too many years. It is time to push recycling to 90% and force everyone to do it using existing sites. Children and schools should be at the forefront.
Policy makers will find it hard to implement [policy] No.6 as inevitably existing waste management sites already impact on the local population and environment.
Schools should teach more about reuse/recycling and the land you live on. People who don’t recycle should be fined.
Agenda Item 3 Page 74
Council should aim for more than 50% recycling. Should aim for 90% recycling – look at this in policies.
More should be done about waste packaging – we should still try to do something locally – start local. Teach this in schools.
Should be looking for sites on green, open spaces.
Don’t want to take too much of our green spaces – I think it would be better to use existing industrial sites rather than taking away our green spaces.
Composting/recycling is good.
Facility must look good, blend in, well-managed, clean, well run, don’t want any rubbish impacting on local residents.
Worried about taking away employment. Can we say there must be no loss of jobs in the policies?
More materials should be re-used e.g. bottles.
More company responsibility for the products they produce at end of their life.
Comments on Sites Very concerned about air emissions. Any facility must not release harmful gases.
What you do in Merton will affect me in Sutton very much – I live near the boundary.
Concerned about facilities running through the night – should be dealt with.
A lot of responsibility goes to central government to put pressure on supermarkets to reduce packaging.
Why not introduce American system of micro chipping bins and incentives for recycling?
Sites must be well managed and well run and clean and tidy. Waste sites should not be by housing – noise and traffic, vibrations from heavy traffic in early morning, dust, noise, should not be allowed to operate all night. Council site runs all night – too noisy.
100% weighting process seems very strange – a score of 3 becomes 6 (makes a site more suitable).
Would a riverside site be more practical to keep lorries off congested roads? And a riverside site may be away from residential housing.
Page 75 Agenda Item 3
Mitcham and N.W Croydon have the biggest proposed sites with the common separating them. Both areas are densely populated and are subject to heavy traffic.
Is identifying the sites without knowing what kind of waste will be processed addressing the problem the wrong way round?
Will recycling on these sites be rigorously followed so that ‘dirty’ waste is kept to a minimum?
Is it definite that mass burn incineration of waste will not occur on any of the sites?
How big are the buildings on these sites going to be? Tall towers for burning waste? Smells? Level of traffic to and from the sites, noise.
People have started burning their own rubbish and fly tipping because they can’t get into the dump (e.g. private vans not allowed)
Site 6 Villiers Road (Kingston) - More traffic going past King Althestan School. More accidents.
Site 9: Garth Road - Traffic around Garth Road is already bad. Don’t want any increase in traffic.
Site 9 - Has been getting worse and worse. Lorries from 5.30 a.m. Would traffic increase? Smell has improved since waste facilities have been covered
Site 22 - Willow Lane Industrial Area - The Willow Lane site is massive, backs on to housing (Carshalton Road). Traffic on this road is already heavy into Goat Road where the access is.
Site 47 Land at Kingston Road/Jubilee Way junction, Tolworth (Kingston) - Tolworth Roundabout already an accident black spot, this will make it worse.
Site 60: Rainbow Park Industrial Area - In the middle of residential area!
Site 60 - Firstway is missing from assessment of residential proximity (51 houses in total, 25-26 on roadside nearest Rainbow Park).
Site 60 - Technical Report contains mistakes, most probably deliberate, when scoring potential sites. Site 60 omitted a whole street when scoring proximity to residential areas [Firstway].
Site 60 - Very important that this sewer is not polluted and that no one tries to re route it (effectively part of Thames flood plain).
Site 60 - Should be classed as having flood risk.
Site 60 - Surface water sewer runs across the site, every 2-3 months the access pit turns into a fountain when rain is excessive. Flows north towards Hogsmill River then straight into the Thames.
Agenda Item 3 Page 76
Site 60 - This site is too small and enclosed by residential areas – the extra traffic caused will impact adversely on the local area. This is currently not a waste management site.
Site 60 - Not at all suitable. There’s already too much traffic to it right at the train station. Environmentally damaging (flooding potential, vermin) to residents.
Site 60 - Strange assessment re co-location – surely all units would need to relocate?
Site 60 - Firstway residents were not even mentioned – so close to this site – already affected by traffic into/out of industrial sites – traffic already dangerous by station.
Site 60 - Archaeological interest (close to pre medieval farm), wildlife (bats) and respiratory risks.
Site 60 - Owned by Workspace Glebe. Want to bring waste from all over London. Put on list late in the day after someone ringing Kingston BC.
Site 60 - Lots of people here from Rainbow Park because of Workspace Glebe emerging application for anaerobic digester (2 public meetings already over past year).
Site 60 - The site is now industrial use. This anaerobic digester has to be built. This will cause years more traffic noise pollution and disruption to a heavily populated area.
Site 60 - Rainbow Park is right next to Raynes Park shopping centre – dangerous traffic junction by station, turning into the site.
Site 60 - The daily traffic is almost at a standstill during the day along Grand Drive. How can this site help traffic and air quality?
Site 126: Benedict’s Wharf - Lorries should be closed but are open. 3 schools in the area, lots of housing. Smell nuisance from existing site.
Site 126 - Rubbish gets dumped at entrance to Deer Park Gardens.
Site 126 - Site is in a heavily populated area with a school and only narrow church road for access. The roads would not take heavy traffic and would affect foundations of houses.
Site 126 - Sita owned – most lorries come down Morden Road from west loop around east and north to enter site. Lorries huge and smelly. This site is only bit of industrial estate in a sea of residential.
Site 127 - Willow Lane area by River Wandle - Contamination of the River Wandle
Site 136: Deer Park Road site - Will it affect the value of my property?
Page 77 Agenda Item 3
Site 136 - Are they ‘sites’ known to increase infestation?
Site 136 - Do you have any feedback from residents living close to existing sites?
Site 136 - Will these sites increase traffic congestion even add new bus routes?
Sites 641, 642 and 651 - Durnsford Road, Plough Lane - Durnsford Road: traffic problems and that was the main reason that a supermarket (Safeway) was recently turned down there. The traffic survey was done at 3pm. Hayden Park Rd, Plough Lane and Durnsford Road – all always blocked.
Sites 641, 642 and 651 - We should take into account Wandle Valley Regional Park – Durnsford Road should be scored a ‘1’ for nature conservation because of this, Wimbledon Park.
Sites 641, 642 and 651 -[these 3 sites] Don’t satisfy [policy] WP6 [development criteria]?
Sites 641, 642 and 651 - None of these sites satisfy WP6!
Sites 641, 642 and 651 - Garratt Lane near Durnsford Industrial Estate is a strategic road but it’s blocked completely!
Sites 641, 642 and 651 - Why so highly rated? Traffic black spots.
Sites 641, 642 and 651 - All 3 sites are in the flood plain.
Sites 641, 642 and 651 - All 3 sites are in proposed regional park.
Site 642 – Durnsford Road is already full of traffic.
Site 651 – Plough Lane is a traffic black spot – new housing makes it totally full (570 flats Plough Lane development).
651 – Plough Lane is the only road to St. George’s Hospital for some distance and is already blocked.
Site 651 currently used for employment (Wickes) – potential loss of jobs.
Site 651 - New housing (570 flats) in area shown as blank on this map.
Agenda Item 3 Page 78
Kingston comments
Overall points Future consultations need to write to all ratepayers.
Throwaway milk cartons are not a good example to set in a meeting on waste!
Comments on policies It is good the plan is now referring to composting and recycling but whoever has put the compost ideas in assumes it’s on a centralised scale.
To allay residents’ fears put something in policies re enforcement (eg planning conditions and Section 106 to fund enforcement issues).
Policies - don’t really seem like policies - more like procedures (ie Policy 4) would be very surprised if taken literally - ie harm related policy.
If policies to reduce waste are successful will the plan be able to reflect the lower quantities of waste? We don’t want contractors “encouraging” waste in order to keep plants working. How is the plan going to anticipate this “problem”?
I accept there will probably have to be some form of incineration, but as the plan advocates this heat must be turned to useful purposes.
It is a pity that the plan cannot address waste minimisation as an essential part of the overall problem ie mitigation of all waste - commercial, domestic etc.
If district heating is to be one of the benefits of burning waste - how are residents who are not local to these parts going to benefit? Will this not be unfair? Should the solution be a much more radical spread of the waste burning plants? Can they be smaller and more local?
Policy 2: Phrases like “wherever possible” are too vague and meaningless - be more positive/assertive. There ought to be more “sticks” and less “carrots” in these policies.
Please consider the use of the existing rail network as well as roads.
What does significant impact mean? Eg 10% increase in traffic or 50%? Please define this phrase.
Concerned that waste contracts are too long. Can we build in flexibility to respond to changing types of waste/amounts of waste (which should reduce)?
Page 79 Agenda Item 3
A243 will be a nightmare and we don’t want waste lorries using the road in the middle of the night and clogging up the roads. Waste should be moved by rail if possible. Traffic is going to be the main issue.
Why can’t the origin of plastics for industrial/retail use be controlled by law, such that only recyclable plastics can be used?
Comments on sites The sites should have been publically identified earlier, and precisely where. Sure they’re known where they were going for months.
Is the emphasis on “cutting edge” technology realistic given recession etc?
Why not have more composting sites? If composting is to be done in an efficient way need large number of smaller sites across the borough.
Things have not moved in 20 years. Surrey looked at incinerator 20 years ago but dropped because too difficult. Concern that process is too long - decisions get put off. Just need to get on with it.
There is not an even geographical spread of potential sites - heavy concentration on Croydon Mitcham area. On the grounds that the “polluter should pay” should these sites be more evenly spread? Accepting that some will have to be small “local/low key”.
Why are there great gaps in the distribution of potential sites? Eg North Kingston (affluent) has none - poorer areas get most of the pain. But affluent households probably produce more rubbish. (Should follow ‘polluter pays’ principles eg compost site, on every estate).
Is it better to spread the facilities out a bit rather than concentrate them all on Beddington Lane.
Site 6 - When Hanks Road shut for Thames Water works, lorries found other routes. Why not one in through Hanks Road and leave via Surbiton - not wide enough for 2 way lorries. Lorries have to swing out to turn in/out of Villiers Road - sometimes mount pavements and damage pavements. Have raised this with Crossrail (2 community meetings). No one wants the lorries but question is how to share the pain. All lorries from Villiers site come in and out. Narrow Victorian road. Have already discussed with council back in 2003 whether they could be routed via wider roads in Surbiton. Start before 7am. Actually start at 5am (despite protests) - Hanks Road resident.
Site 6 is in a good place, away from housing.
Site 6 - The Villiers Road site is constrained by the Hogsmill River, A playing field and school opposite, as well as other schools quite near, and the Felper(?) Roads, Hawks Road in particular are quite narrow and the houses are very near the
Agenda Item 3 Page 80
carriageway, whereas other more industrial sites have better access and less adjacent housing etc.
Site 6 - Far too many lorry movements on Hawks Road (on their way to Villiers Road).
Site 6 - Hawks Road has had to put up with these heavy lorries for the last 7-10 years. It is time to consider the residents after all this time and let some other roads take their share.
Site 6 - The lorries should come in one route and go out the other. I agree!
Site 6 - 4 schools on Villiers Road - would be used by lorries (3 primary and 1 secondary).
Site 6 - We must protect MoL in the Hogsmill Valley and keep it for wildlife, the communities living there and safe from pollution, heavy traffic and lorries that flout HGV bans that we can do nothing about.
Site 6 - Hogsmill River - higher pollution downstream from adjacent sewage works. Would be vulnerable to further pollution. Pollution levels should be monitored - Athelata St Josephs and The Mount.
Site 6 - Good site - there would be hardly any visual impact. (A second comment made on same post-it: Disagree!!).
Site 6 - The lorries are too large to go in and out on one route. They need to go in one way and out another so I agree.
Site 6 - Talk to Thames Water about the availability of their land.
Site 6 - Residents of Hawks Road and Albert Road will object strongly to any more lorries driving through their Roads. Already these small Victorian roads take all the traffic.
Site 6 - Loads of students are moving in to Hawks Road. Will they care? Won’t like early morning lorries.
Site 6 - Villiers Road is well managed currently. It should remain a waste site as people are used to it. And it is conveniently located. The technology needs to be considered.
Site 6 - Resident of Villiers Avenue - to locate a transfer site. Not ideal site in middle of residential areas lorry access not well policed (eg shouldn’t use Villiers Ave but they do). If this becomes a waste site, would waste come from other boroughs as well? Concerned that degree of control is lost with private sector. Where do driving targets come from? Feel that Kingston might be asked to take a disproportionate amount of waste.
Page 81 Agenda Item 3
Site 6 - We need to consider that there is no way of creating a good environment in the Villiers Road/Hawks Road area while we allow vast lorries to fill our roads at totally unsocial hours.
Site 6 - Whilst use of the site is reasonable the majority of materials there are heavy and need to be transferred should go to site 47 or 352/353.
Site 46 - A243 is already too congested. Site 46 should be serviced by rail not by road. It may also be used by Surrey residents - not south London as it is so near the county border.
Site 46 - Access in not good enough. Traffic is already bad. This will make it even worse!
Site 46 - This is an ‘up market’ industrial estate adjacent to green belt and housing - totally unsuited. A243 is also inadequate for increasing traffic.
Site 47 - potential civil amenity site - good transport links including signalised junction.
Site 47 - why was current batching plant (between site 47 and railway) not considered? (Mouchel noted that was considered but had deliverability constraints).
Site 47 - We need to think about other siding at the Tolworth Railhead. We can share the rail track.
Site 47 is a suitable site (more than site 6) - because already industrial and has good transport links.
Site 47 and 352/353 are ideally placed to relieve the congestion, pollution and threat to wild life, in the Hogsmill Valley. They are on main roads and will leave green spaces for our communities.
Site 47 and 352, 353 are ideally places for taking mass transfer waste/recycling for the whole of Kingston Borough. Their value is that they are already on major main roads.
Site 47 is quite small - the Tesco site alongside the A3 is much bigger with excellent road and rail access.
Site 47 - should provide the same facilities as Villiers WTS that LSD that the amount of traffic going down Villiers could be reduced.
Site 47 - Tesco land. This scheme needs to have more clout and take priority over the housing sites. Commonsense is needed. Think bigger! Eg move the housing requirement from the Tesco site to other areas eg Red Gan (?) Road Industrial Estate. There needs to be a negotiation between housing and waste needs. Would prefer to have concentrated sites and as few sites as possible.
Agenda Item 3 Page 82
Site 351/352 land and Kingston Road/Jubilee Way has by far the best transport links and should incorporate the old government offices (Tesco land) as one block, with the advantage of Chessington industrial estate as a near by add on.
Sites 351/352/353 are currently underutilised but traffic access is difficult. Please consider a new junction on the A3 to serve these sites and Tolworth Girls School.
Sites 351/352/353 - traffic congestion major issue - A3 and Kingston - Epson A240. Emissions, [word unreadable], gridlock. Moving from residential to heavy industrial environment, urban wasteland scenario is that RBK’s, Longrange. Planning policy for this part of the borough? What [word unreadable] does the road system have to be seriously considered? Too little is known of the [word unreadable], infrastructure objectives in terms of: operations, process, volumes. Many roads too narrow for 351, 352, 353.
Site 351/352/353 is the aim to have lots of smaller sites or one big ‘wasteland’ like Willesden Junction?
Sites 351/352/353 - After spending millions on Chessington Community College, you plan to (?) a (?) plant next to it!
Sites 351/352/353 - How many jobs will be lost on the Chessington industrial estate?
Site 351 - It is important not to push out existing businesses. Disused sites should be looked at first.
Site 351 - Has already tended to be heavier industry than around 353. Better access via Jubilee Way as well.
Site 351 - Office and production building on the corner of Cox Lane/Davis Road “Chelwood House”, finished at the end of 2004, on the King George trading estate. Our concerns are the CPO of our site. Concerned about value of land. We have built a high quality building and need to maintain value of the charity’s assets, preservation of our asset. Traffic will be a consideration and general environmental effects. Third concern would be smell and dirt. (Bible and Gospel Trust).
What about the Old Coal depot site? It already has rail connections (ie site 46) and railway.
Site 353 - Problem is not trucks and lorries, but change in nature of industry/units of a site.
Site 353 - Concerned about odour and nuisance. People next to site will be very hostile (Oakcroft Estate as a whole - Ashcroft, Kirkcroft, [word unreadable] etc). Oakcroft Road resident.
Site 353 - Currently clean business park eg software manufacture). Should be very concerned if they had heavy lorries coming here. Oakcroft Road resident.
Page 83 Agenda Item 3
Site 353 - Oakcroft Estate - small 2/3 bed houses with lost of young children is vulnerable to any impacts.
Site 353 - Chessington Road estate should be looked at along with Kingston Road/Jubilee Way and the Tesco site.
Agenda Item 3 Page 84
Sutton comments
Overall points I don’t feel that information has gone out widely enough - 50-80 people at this event is not a lot eg have leaflets in reception area in Council offices.
Did boroughs share the costs of this exercise equally - given concentration if sites in Sutton?
Impossible for people to formulate opinion on the use of sites with undisclosed proposed development.
Wanted presentation and debate. This is a waste of my time.
Nobody in Wallington got a letter/leaflet. In libraries - documents ‘hidden away’; not clearly on display.
Resident (also working in waste industry) hasn’t had any notification of this process until 4 days ago.
If co-mingled collection, boroughs likely only to want 1 MRF across 4 boroughs?
How will rates be equitably decided if Sutton is taking waste from other boroughs? How would Sutton residents be compensated?
Comments on policies Concerned about how height of waste alleged to be stored outside as county ships piles [of waste]. Pyrolysis/gasification should only be using non-recyclable waste. Can they operate technically without paper, plastics? FoE are saying they need to have a mix of recyclable/non-recyclable waste.
Can the council please everyone? What plastics can be recycled? It would reduce landfill.
Why is Croydon tendering for an incinerator before consultation is completed?
Difficult to make proper judgements until we know what is proposed for each site ie “thermal treatment” means an incinerator?
How will sites at Beddington affect the country park?
Will there be facilities to recycle energy efficient light bulbs?
All waste should be handled on disposal sites in enclosed buildings to contain dust and pollution.
Page 85 Agenda Item 3
Nature conservation should be a priority.
Croydon are asking bids for: 9051330 =incineration. 9051390 = sludge disposal, 905200000 = radioactive, toxic medical and hazardous waste services, 9052400 = clinical waste, 45252300 = incinerator construction.
Incinerators only 30% less CO2 than coal!
NO BURNING (Pyrolysis or gasification) or land filling of radioactive waste which should be contained safely till radiation subsides. Could be a long time.
What will happen to “sustainable Hackbridge” if Beddington gets the go ahead for an incinerator?
Whatever happened to the proposed park in Beddington?
PFI is not the way to run things - will lock you in to contracts.
Local composting sites for green waste. Garden shredders shared communally.
Pyrolosis etc in China, processes don’t actually run at high temps.
Waste minimisation should be enforced: eg tax on packaging, obligations on supermarkets to take back packaging waste.
Less packaging and do away with as much machinery which creates packaging.
Waste minimisation needs to be the first priority - would dramatically reduce the volume of rubbish produced.
(Policy 1) What does it mean to manage waste as far as possible up the hierarchy as possible? Surely we should be stronger. This is a get out clause. Q: What will happen when the landfill tax runs out? The driver will disappear. How will the waste plan drive waste up the hierarchy when we run out of landfill and there is no longer a financial incentive to drive waste up the hierarchy? It will just all be buried.
(Policy 1) The supportive text says ‘waste is a resource’ the word research implies it’s a good thing and we want more of it. Surely we want to reduce it. Its dangerous wording, for example a CHP will say they’ve met the policy because it’s a ‘resource’.
(Policy 1) Waste minimisation should be the ideal.
(Policy 1) Projected waste increase 16% by 2021 but population increases only 6%. This does not make sense.
(Policy 2 Bullet 3) If we classify waste as a resource ie to produce energy, it will discourage recycling/reuse/composting.
(Policy 1) What about oil and other fossil fuels declining so less rubbish/recycling?
Agenda Item 3 Page 86
(Policy 1) Less materials produced because of less oil eg clothing utensils and a lower standard quality of life.
(Policy 1) Re use, repair, make do and mend behavioural change shift to make a look cool.
(Policy 1 Bullet 2) Recycling the only answer.
(Policy 1 Bullet 3) Distance from residential - what is the legal requirement? North Beddington - ? station. Health and noise risks lorries.
(Policy 1 Bullet 3) Cumulative impact of potential sites adding to noise and dust from.
How much space you need where depends on which methods of processing you use. Which do you decide first?
Recycling still has disadvantages eg noise from traffic.
(Policy 2 Bullet 3) Recycling facilities create jobs and don’t COST THE EARTH!
(Policy 2 Bullet 3) One incinerator for Croydon, Sutton, Kingston and Merton + truck pollution BIG TIME.
(Policy 2) Waste minimisation should be priority No 1 - not just applying to construction.
Will depend on the cost of developing each site - cost effectiveness is key factor.
Cost (lifetime) of types of waste treatment need to be considered.
We should move away from economies based on growth of production, to growth of happiness/well being. Incentives/subsidies given to repairing. Training in skills for this. Space should be allocated for people to help themselves to reusable things which others have to dispose of.
Introduce a day a month when one can leave out any useful item not wanted by you, to be available for anyone to help themselves to.
(Policy 4 Bullet 5) Concerned about radioactive waste - we need to address this in policies. We should link up with bioregional and CIRIA to look at policies.
(Policy 6) Crucial that Transport of Waste involves much tighter control of vehicles - to ensure access roads are clear of droppings. This is what upsets residents.
(Policy 6) Shouldn’t the places look smelly and ugly so people waste and use less so they have to close down?
(Policy 6) Policy OK if you can make them keep to it.
(Policy 6) CO2 emissions are important.
Page 87 Agenda Item 3
(Policy 6) Should be aiming for a CO2 neutral processes and carbon neutral.
“Thermal treatment” = (in most cases) an incinerator. A properly sustainable waste management strategy should NOT include ANY incineration! Incineration: (1) inhibits recycling by locking councils into long term contracts to feed the burners. (2) Burning waste does not produce “green” electricity - CO2. Emissions put it well down the league. (3) There are serious threats to human health especially from commercial and hazardous waste streams.
(Policy 7 Bullet 1) This statement is obvious of course nobody chooses a poor performing technology.
(Policy 7 Bullet 1) Mass incineration is not ‘mass’ as it only burns 99.8%.
(Policy 7 Bullet 2) Re-use - not just recycling.
Comments on sites Want to know what’s really happening with the Plan. How can I suggest a site when I don’t know what’s going on it?
Sutton Council have undermined the consultation by stating their preferred choice of sites already!!
Sutton takes waste from other boroughs already and makes money from it.
Sutton - Council biased towards recycling. Recycling buildings put up without planning permission.
Why is council (Sutton magazine - 3 months ago) offering relocation of residents to Cornwall/Devon?
What technology will deal with the transport impacts? Moving waste from eg Kingston to Sutton has significant impacts.
Energy from waste has potential but only if done in the right way (clean emissions).
Landfill has to go - methane is worse than CO2 as green house gas and not absorbed by ecosystem.
Thackeray Lane (Croydon) near supermarket (ASDA), dwellings, big shopping centre, not at all a suitable site.
Need one emphasis on rail alternatives for transport of waste (eg bulk up in Kingston and transport by rail to Sutton).
Each borough should deal with its own waste.
Agenda Item 3 Page 88
Site 122 is opposite a school - this is no good for a waste facility.
Issue: how will these facilities be policed? EA can’t seem to do anything. Problem.
The amount of waste should be reduced - spend money on reuse and recycling.
Site of old cement works around 21/97/100 - contaminated - used to burn rubbish at high temperatures.
Corby judgement laid serious responsibilities in councils to check re contamination of land. Concerned that contamination issues are being ignored. Sites with contamination problems/ Croydon had 2 iron smelters - affects site 102 (and north of it). Croydon gasworks and Naphtha plant around site 1/5/125/105/5312.
Japanese cancer stats have doubled since 1945. Don’t follow this path. Known as the “cancer era’ in Japan. 1945 to 2005 is a public health phenomenon. [Sheet shows graph of incidence of colo-rectal cancer Japan/age related incidence in 2005. Age related incidence in rate in 1975 in 70-80 year olds. Something happened in the environment to cause this increase].
[A diagram drawn by a participant shows neo-natal deaths decreasing from 1974 to 2003, with the development of Croydon gasworks site at around the late 1990s mark].
Where can we put waste facilities? Mitcham suppliers (building suppliers) - its out of the way, can’t see it, in the middle of nature, not near houses.
Other British people already accumulated dioxins from fires etc during WWII - danger of overload/disease if dosage increases.
Where should they go? The most sensible place would be existing waste sites.
Why can’t we use the existing landfill site once it’s filled?
There is no place for any form of incinerator in a truly green area waste plan!!
Site 17 - County skip hire - concerns are mountains of rubbish, dust, odours. Concerned about what waste is dealt with here.
Site 17 - badly managed - smell from County Skip Hire is dreadful. Waste spray used to keep dust down but it doesn’t work. Went up in flames 2 weeks ago.
Site 17 - Traffic is dangerous, noise is bad, dust for those with breathing conditions.
Site 17 - Rubbish must be around 40ft high, should it is not be covered as it is rotting.
Site 17 - Children’s school is in one village and more traffic would be very dangerous.
Page 89 Agenda Item 3
Site 18 is a good site - far away from the road, residents.
Site 18 - Look at the Cemex site - we should consider this - it’s next to the Viridor site.
Site 46 - Be a bit ridiculous to build something in south London eg site 46 because it’s out on a limb. Move business waste is probably produced in central/east of the plan, so perhaps better to have sites in this area.
Site 57 - Wall chart not consistent with main document. Is this part included? [drawing of site area showing southern portion shaded].
Site 100 - Don’t want modern, untested technology at Kimpton Way. I agree with it provided the modern treatments are safe.
Site 122 - Beddington Lane (HS Warles?) Next door to Wicks and ASDA. Proposal here to crush concrete. Don’t want any concrete crushing here or any waste facilities here - dust, noise, close to houses, more traffic. It’s being used now and it shouldn’t be.
Wind dispersal areas of energy from waste plant assuming 100ft chimney would encompass Dulwich. Depends on wind direction.
Have you checked roads are suitable for heavy lorries?
Site 491 - Kimpton - good site for waste management facilities, good transport links, it’s the most central location for household waste.
Site 491 - Can’t understand how you can comment on sites if you don’t know what’s going on them? For instance site 491 - MRF would be acceptable; incinerator might not be (depending on emissions).
Site 491 - Resident - did get a letter with maps etc (living near 491).
Site 533 - Within 37m of residents 1234 ( Bree/Marg Rd?) Dust and operation would affect tram track platforms. Council is already in consultation on this site for use of waste from Kampton Road c/a site.
Site 533 - In allowing these sites the council is guilty of public nuisance and in breach of its duty of care under the environmental protection act.
Anything on the application for 112 Beddington Lane? Nothing here about added traffic impacts.
Prevailing winds take fumes from Beddington area across residential areas to NE of sites (sewage and waste smells).
Have ASDA etc between Factory Lane and Beddington Lane. Both would be affected by the potential sites.
100 to 1 odds on Beddington being closed.
Agenda Item 3 Page 90
Beddington not an industrial area to us - ASDA etc it where we go to eat!
What are the alternatives to Beddington Lane? Sutton has great bulk of sites across the 4 boroughs.
Beddington area used to be wetlands - where does the rain go now? [second comment on sheet says: drains into Wandle into the Thames].
Beddington is an industrial area not a dumping ground.
This whole consultation process is just one big con! Beddington Lane has already been identified as the victims - the only sites where there are no deliverability constraints. For once think of the problems! We already suffer and consider those living in this already blighted area thanks to decisions made in the past!!
Beddington has got enough - take it elsewhere.
Beddington Farm Bird Group - site of metropolitan importance so opposed original recycling site (18). Initial permission given to Thames Waste said site 18 would be wet grassland. But has been turned into recycling plant - impact on birds. Viridor dragging their feet on area to west of site 18. Site 57 - metropolitan open land. Nationally important bird species - tree sparrow - 95% decline. According to RSPB. Other important species - reed w. Site 18 has permission to 2023 initially, but likely to be extended late.
Beddington Farm Bird Group vision (see website) see wildlife protected site in this area, to be a resource for local schools etc as already done in Barnes.
Beddington Lane is not only an industrial area. There are people living here as well. Everyone seems to forget that people live here.
Beddington sites already safeguarded as waste sites. Sites have already expanded. Viridor donate money to council to get their way.
Beddington - concerned that existing sites will be given ‘carte blanche’ to do what they want.
Beddington - Viridor landfill sites has already killed poplars on the edge of Beddington Park. Nuisance from flies and seagulls.
Beddington - Houses between 533 and 534 are just surrounded - how much will these houses be worth?
Beddington - County Skip Hire, Viridor, 77 Demolition have moved in since 2003, everything focussed on Sutton.
Beddington looks bound to go ahead because everything is in place here already. Feel powerless to oppose it. Would prefer to see fair spread across all the boroughs.
Beddington - Voices from 80 houses in Beddington just won’t be heard.
Page 91 Agenda Item 3
Beddington - Sutton, Merton and Croydon already use Viridor in Beddington Lane. All that will happen is adding Kingston in.
Beddington village is a conservation area - should be protected.
Beddington Lane is suffering saturation already from traffic and recycling sites.
Beddington village can be saved if all nominated sites adjacent to Beddington Lane use Coomber Way specifically built for HGV traffic (not at present being used).
Beddington - Are there any plans for incinerators in Beddington Lane?
Beddington - London Road - Planning permission for landfill (1996) for Thames Waste promised site would be level. Now have planning permission to go up to 160 feet - why? (next to Beddington Park).
On Beddington Lane - sites are poorly regulated on Beddington Lane such as County Skips and I cannot see that any new facilities will also be properly regulated.
Existing planning permission Beddington Lane landfill: Why have we allowed waste from all the other boroughs to landfill in Beddington Lane? Cell 1, Cell 2 already used - Cell 3 excavation is just starting.
Beddington - The duty of care to residents on Beddington Lane is as good as neglected by Sutton Council.
Beddington - Waste not being covered properly - smell, nuisance on Beddington Lane.
Beddington - More concerned about traffic than fumes from incinerator - there’s been enough in Beddington Lane.
Sites 532 etc - Beddington Lane - Enough waste management in this area already. Coomber Way built to take the heavy traffic, instead Beddington Lane. County Skips are the worst using Beddington Lane. But trucks still use Beddington Lane (residents on Mt Pleasant) concerned that sites are coming closer to residents.
Beddington - no more lorries through the village. Enough is enough (Beddington). We have a right to a quality life and to breathe clean air.
Spark Farm Primary School - children at risk from Beddington Lane traffic (child killed some years ago).
Beddington Lane - Resident with respiratory problem. Concerned about site 17 type dust problems could come closer to him.
Beddington Lane too narrow for the traffic.
Beddington - Concerned about potential compulsory purchase of houses in Beddington Lane?
Agenda Item 3 Page 92
Beddington - Whole Beddington Lane area too congested!
Beddington - Existing waste facilities out of control and causing nuisance.
Beddington Residents Association - have a report from London Air Quality - already over council limits at particular times of day. Very against any further proposals for Beddington Lane.
Beddington - Landfill planning consent stipulated that lorries should use Coomber Way - but they don’t. They come down Beddington Lane (even at 5pm).
Beddington - Need better enforcement of planning conditions.
Site 533 - Brockmead Road residents - site very close to these houses. Southern portion of 533 (south of railway) is very close.
Sites 533, 534 - smell! dust!
Sites 533, 534, 532 - Brockmead Residents and Oakmead Road would be surrounded by sites.
Sites 5312 and 538 - are very close to primary school which has just been extended to a children’s’ centre. Also close to residents in Beddington village.
South London Waste Plan Stage 2 - Schedule Croydon Consultee ID: 328276 Full Name: Dr Jacqueline Card Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD11 Is Site Suitable? Site Number: Site comment: Methane capture from landfill? OK for combustion for power generation, but also for chemical conversion to products currently made from coal and oil. Officer's Initial Comment: The points raised are noted. Consultee ID: 354055 Full Name: Ms Sheila Kemble Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL138 Is Site Suitable? Site Number: Site comment: The areas around Factory Lane seem most suitable as Purley Oaks is already very congested. It is difficult to assess suitability without knowing what type of facility. There are a cluster of sites around Beddington area, I suggest minimise transport/ sorting/ delivery to appropriate facility using best technology. Officer's Initial Comment: The points raised are noted. Consultee ID: 354546 Full Name: Mr D.T.R Evans Organisation: Agent ID: Agent Name: Agent Organisation: Page 93 Comment ID: PSPSL191 Is Site Suitable? Site Number: Site comment: The outer areas of Croydon appears to be the most suitable , i.e. where local residents are least likely to be harmed by any potential hazards. Officer's Initial Comment: The points raised are noted. Consultee ID: 329589 Full Name: Mr Jeremy Board Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL33 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: My initial concerns are as follows. I don't think they are surprising ones. I live east of Factory Lane, and on a few days in the year the smell from sewage is very noticeable and pretty awful. As a house owner, I would not want the number of days to increase, nor the smells to intensify. I have not noticed any problems currently from traffic of waste, but I would not want these to increase. Imagine if I were selling my house, and potential buyers were met with the high probability of smell due to increased waste processing - it could be a major obstacle. Not to mention the increased unpleasantness to me living here. JB. 13/08/09. Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and are proposed to be considered again
at planning application through proposed policy WP6. Agenda Item 3 Consultee ID: 330415 Full Name: Miss Alison Tong Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 1 of 142 Croydon Agenda Item 3 Consultee ID: 330415 Full Name: Miss Alison Tong Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL35 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Purley would not be the right place for expansion on waste management industry. the current use of the recycle centre causes large traffic jams on a daily basis. Introducing more heavy lorries into the area would only have an even more negative impact having a high impact on traffic congestion and Purley would grind to a halt. To build and expand further on an already overcrowded area would have a huge detrimental effect on the environment. Noise pollution would increase and would turn Purley into an industrial zone, destroying the environmental character further. There is already too much building development in Purley and Croydon and it is already like living in an inner city area. To increase this further would be completely detrimental to the original character that is lef Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6. Consultee ID: 141505 Full Name: Mrs M. F. Davis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL352 Is Site Suitable? Site Number: Site comment: Lack of recycling facilities in Croydon, lack of litter bins in Croydon, poor street cleansing in the town centres.
Officer's Initial Comment: The points raised asre noted. Page 94 Consultee ID: 331426 Full Name: Mr Taylor Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL39 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I don't think the Croydon Council Highways depot at Purley Oaks is a good site, it's too small and is better kept as a local recycling centre. Officer's Initial Comment: The points raised are noted. The London Plan and the policies being proposed require existing waste management sites to be retained and where possible improved. However, only development proposals in accordance with the proposed policies would be supported. Consultee ID: 137178 Full Name: Mr Peter Jarman Organisation: Addington Residents' Association Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL390 Is Site Suitable? Site Number: Site comment: Our residents will be delighted to learn that the South London Waste Plan Organisation has decided not to include Pear Tree Farm, Croydon, in its future plans. I understand and we all agree, that the site is totally unsuitable for purpose, being located in Green Belt area of natural beauty. The traffic generated is unacceptable for the narrow local roads and a nightmare to residents as is the blight of buildings, scaffold storage, crane hire, coach, bus and commercial vehicle parking etc. Thank you for your suggestion that we should contact the Environment Agency, as Croydon Council seem incapable of controlling the activities and unauthorised expansion of this site. We are taking this matter up with the Campaign to Protect Rural England and other organisations who may be able to help. If you or your colleagues have any comments or advice that might help us encourage the closure of the site, it would be greatly appreciated. Officer's Initial Comment: The references to green belt, residential areas and traffic generation are noted. The London Plan and the draft policies being proposed require existing waste management sites to be retained unless sites are unsuitable and alternatives can be found. In the event of a planning application, only development proposals in accordance with the draft policies would be supported and developers would normally be required to submit technical reports and evidence to address the issues and material planning considerations.
26 November 2009 Page 2 of 142 Croydon Consultee ID: 33887 Full Name: R.J Bourton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL395 Is Site Suitable? The site is not suitable Site Number: Site comment: All Croydon sites appear too close to residential properties, so would not be suitable for heat/power utilisation. Officer's Initial Comment: A comprehensive list of issues were considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Consultee ID: 33887 Full Name: R.J Bourton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL402 Is Site Suitable? The site is not suitable Site Number: Site comment: The Purley site is too small and constrained by high ground to east. Officer's Initial Comment: The points you raise are noted. Consultee ID: 206179 Full Name: Dr. Stanislaw Prokop Organisation: Agent ID: Agent Name: Agent Organisation: Page 95 Agenda Item 3
26 November 2009 Page 3 of 142 Croydon Agenda Item 3 Consultee ID: 206179 Full Name: Dr. Stanislaw Prokop Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL421 Is Site Suitable? Site Number: Site comment: The format of the consultation document so fails to allow a discussion of very important general issues that I have decided to write a separate letter, copied to interested parties, in addition to filling in the online form. It would be important not to let this feedback be "lost" amongst the formula replies. Croydon has a long history of industrial development. Scattered along the length of Purley Way are many potentially very toxic sites. A 75 year old gentleman, who had lived all his life near Beddington station, was at the Sutton consultation. He was able to show us where Croydon power stations A and B were, The Gasworks and naphtha plant (currently being developed for a second time), The Trojan Smelter, The Vespa Works, The cement plant and another smelter. The 2007 child health report provides very worrying indications of a possibility that developments at Ikea (81), Sainsbury's (87-88) and the new gas power station (95 onwards) could have affected pregnancy outcomes in Croydon. It would be important to reduce the risks of any new development, so that an absence of "contaminated land" as an assessment criterion for sites is astonishing. The representative of the technical assessment firm confessed to not knowing anything about Croydon's industrial past and felt it should not come into the current consultation. Given that Corby Council faces a bill of about 18 million for its negligence, I would have hoped, as a council tax payer, that minds would have been a little more focussed. The Wandle Valley group of sites, potentially containing the very toxic incinerator residues (accumulating at a rate of some 100,000+ tons a year) in landfill, will be prone to both fluvial and pluvial flooding and leaching. All up to date scientific opinion is pointing to a much faster rate of polar melt, and therefore sea-level rise, than even a few years ago. The many intense downpours and flooding over the UK, let alone the rest of Europe, recently, is another pointer to dangerous conditions. The fact that on page 57 the SLWP even contemplates building on floodplains against EA advice is disturbing, given these new , changed, climatic conditions. The Corby Judgement, on July 29th, has changed the legal framework for all brownfield development. I was mildly shocked to find Sutton planning officers apparently ignorant of it, and I Page 96 am not sure any dissimulation wasn't even worse, at a public meeting. I take the liberty of enclosing the following statement in full, in case its seriousness has not quite sunk in. Paula Jefferson, head of Beachcroft LLP's Disease Group, said: "Any organisation involved in any activity in the future, where there is the potential for release of harmful substances in to the atmosphere, should ensure that they have taken all necessary steps to identify the potential contamination and to then ensure that they either employ, or have themselves the necessary skills, to deal with that contamination. The principles in the judgment apply not just when there is demolition in progress, but to any activity where there is potential for exposure in to the atmosphere. Where there is any known potential for such exposure, then regard should be had to not just the onsite workforce but also to those living and working in the surrounding area. In the Corby case the area of risk was 4km from the demolition site. The area for potential exposure will clearly vary depending on the circumstances of each case. In essence, the message remains the same - proper risk assessment is key and must include identifying the appropriate people to do the job and not cutting corners, which, as has been proved for Corby Borough Council, is likely to be false economy."[21] The full judgemnt is avilable on line. Of particular interest are the extent of potential pollution,paras 849-868, the effects on the embryo paras, 869 -883 the conclusons about the reclamation 679 and the review of issues of law,paras 680-697. Coming onto the questions of monitoring.The notion that you can adequately measure air pollution by a yearly report is so laughable that it seriously draws into question the adeqacy of the writers. Colnbrook produces graphs of 24 hourly emissions of a variety of polutants available online, and I would suggest that such a regime is adopted here. PM10 measurement is totally inadequate, as incinerators and lorries produce toxicities at sizes of PM 2.5 - PM0.18, where heavy metal vapours condense. Failing to measure such pollution may now have become illegal,given the Corby judgment.The omission of heavy metal monitoring is a serious error. As only one dioxin measuring site in London exists, and has no norms, how can dioxins and furans be measured,or promises made. Government reports suggest that there will be no measurmenst of either heavy metals or dioxins, so why pretend to make promises that won't be kept. The plumes for these toxins have been proved to be very extensive (Hull and Avonnmouth) and toxicities experienced at exquisitely small amounts. I would echo the Italian view that it is irresponsible to set up new waste facilities without embarking on a public health monitoring programme in the locality.Not only should baseline values be collected for a few years before,but active study,particularly of pregnancy outocmes should be attempted.The SAHSU unit at Imperial College and the ONS already collect the necessary statistics...the collation of which is simple and cheap.Not to do so could be classed as negligent in the light of recent rulings. Lastly I would like to come to the very seriously flawed basis of both parts of the consultation itself, the first part omitting any mention of the issue of incineration ("enclosed facilities with a chimney").This is a serious democratic deficit. I would hope that it will be challenged by objectors at a judicial review. The first one seemed merely to fulfil the rule for procurement, the second, is being undermined as we speak, by the secret procurement process and the choices made by the contractors, whatever the public says. The judgement given against Veolia recently, making it open its accounts to local tax payers, suggests that the hidden procurement negotiations will be made public eventually. The document itself even details that
26 November 2009 Page 4 of 142 Croydon Consultee ID: 206179 Full Name: Dr. Stanislaw Prokop Organisation: Agent ID: Agent Name: Agent Organisation: any other site can be chosen.....even the ones not currently identified! Discussion is being led away from the irreducible residual waste, now made even more toxic by the new waste streams and the way they will need to be burned by "old" (grate burning technology) new incinerators disguised by the name of Combined Heat and Power or Energy from Waste. Because only 6% of waste is actually domestic, the process distorts public perception by not emphasising that what is being planned is actually industrial waste processing. This is not only being subsidised by Council Tax, but is also exposing the population to new waste streams which include hazardous waste, electricals (full of dioxins and heavy metals) and radioactivity. Officer's Initial Comment: The point raised is an important consideration. The Mouchel criteria based assessment identified those sites that it is anticipated have land contamination. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised. Consultee ID: 358197 Full Name: Peter Howick Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL422 Is Site Suitable? Site Number: Site comment: Hi Emma, regarding the forthcoming consultation on potential sites for waste management facilities in South London, I can only comment on the Croydon ones being a Croydon resident. In my opinion, sites 99 and 102 would not be suitable due to the fact that they on very busy 'A' roads and also very close to residential areas. I therefore consider that the only possible site in Croydon would be in the Factory Lane areas. Preferably I would prefer none of this to be in Croydon as this is the largest London Borough and highly populated. Page 97 Officer's Initial Comment: The references to residential areas and traffic generation are noted. A comprehensive list of issues were considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Only development proposals in accordance with the draft policies would be supported. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised in draft policy WP6. Consultee ID: 359002 Full Name: Michael Howard Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL532 Is Site Suitable? Site Number: Site comment: As a Croydon resident my input relates partly to the waste-related policies and pronouncements of Croydon Council. As a member of the SLWP Croydon should seek to have the principles on waste which it set out in its Croydon Environment and Climate Change Strategy 2009-11' applied in all member Boroughs. I believe the consultation process to be rather flawed in its design (see section 2 below). I hope that the SLWP is able to recognise this and that the (flawed) consultation phase design will not be used as a pretext for excluding my comments on technologies. I would greatly appreciate written clarification on this point. 1. Comment on sites Facilities should not be placed by default in areas which already have large numbers of industrial and/or waste facilities, for example Beddington. Such areas are often relatively poor, and the fact that their residents are generally less empowered, and less able to finance expensive actions to fight developments, can mean that it is easier to put facilities in such places.
Officer's Initial Comment: The points you raise are noted. However, the consultation process has been extensive and has been benchmarked with other waste plan Agenda Item 3 authorities and in conjunction with advice from Government Office for London, Greater London Authority and The Planning Inspectorate. Consultee ID: 359002 Full Name: Michael Howard Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 5 of 142 Croydon Agenda Item 3 Consultee ID: 359002 Full Name: Michael Howard Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL534 Is Site Suitable? Site Number: Site comment: 2. Comment on the scope of this phase of the Consultation The consultation is limited only to sites, and does not allow comment on technologies. How can people comment on where they want waste facilities if they do not know what those facilities are? The nature of different technologies is very different, and people are likely to feel very differently about having different technologies on their doorstep. Officer's Initial Comment: The points you raise are noted. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised in draft policy WP6 as well as the other policies. Consultee ID: 359002 Full Name: Michael Howard Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL536 Is Site Suitable? Site Number: Site comment: 3. Comments on technologies 3.1 Incineration We have been promised in writing by Croydon Council that there will be 'no incinerator in Croydon'. This does not preclude the possibility that an incinerator will be built in one of the three other boroughs which form the SLWP. As a Croydon resident I do not want my waste to be incinerated, wherever it is done, because its effects in terms of climate change and wasting natural resources are global. I believe that the use of incineration is not consistent with the EU waste hierarchy, which I believe the SLWP Boroughs are legally obliged to apply, and which is contained in the Croydon Environment and Climate Change Strategy 2009-11: Taking Croydon Beyond Carbon' document. It says that: "A key priority will be reducing waste in Page 98 line with the waste hierarchy: 1) prevent waste, 2) re-use, 3) recycle/ compost, 4) energy recovery, 5) disposal. This will include increasing recycling and composting services for residents and businesses and greater promotional work with schools, community groups and businesses." I fully support these aims. I would like to point out that under any rational analysis the waste hierarchy precludes the use of incineration. Incineration falls under level 4) - energy recovery'. Because incinerators require high volumes of waste to burn, and must be operated over long timescales to pay back their high capital costs, their existence discourages waste prevention, re-use and recycling. With energy recovery being lower in the hierarchy, it cannot take place to the detriment of the higher levels. Incinerators are large and inflexible and the high capital costs require very long-term, large scale investments, ensuring that the facility will be in place for decades. In a fast-changing field such as waste management it does not make sense to have very expensive, inflexible, long-term arrangements in place. Over recent years more and more materials have been become recyclable, or products have been redesigned to be made from recyclable materials. This trend is likely to continue - and possibly accelerate as a result of ever increasing investment in low carbon strategies - in the future. Having a facility which needs large volumes of waste in order to function, when future waste streams are unknown, and when the Council's own strategy is to prevent waste, and increase recycling and reuse, is counter-logical. Incinerators can also be inefficient because they need to be operated at the burning temperature of the least- easily combustible of the mixed materials that they contain (ie the material with the highest burning temperature). This can severely compromise the amount of net energy they are able to produce, and further increase the carbon emissions associated with incineration. The use of incineration is a knee-jerk, and quite possibly untended at the EU level, reaction to European Union strategy to reduce landfill. I would also like to draw attention to the subtitle of the Croydon Strategy: Taking Croydon Beyond Carbon'. With the exception of the biomass component of the waste, incineration produces non-renewable energy, and burns fossil fuel-derived materials such as plastic, producing greenhouse gases. (Energy from waste is not classified as renewable under the UK Government's Renewables Obligation, except for biomass derived components, which I believe could be better generated through Anaerobic Digestion (see below). The same applies to newer technologies such as gasification, which, like traditional incineration can also crowd-out the 3 Rs.) Use of incineration will not take Croydon (or any of the other SLWP boroughs) beyond carbon' (just as tar-sands exploration does not take BP Beyond Petroleum'). Officer's Initial Comment: The points you raise are noted. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised in draft policy WP6 as well as the other policies. Consultee ID: 359002 Full Name: Michael Howard Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 6 of 142 Croydon Consultee ID: 359002 Full Name: Michael Howard Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL538 Is Site Suitable? Site Number: Site comment: 3.2 Suggested methods for waste management I would like to suggest the following methods of preventing and dealing with waste: Reduce, reuse and recycle I know that waste prevention is to an extent outside the control of Local Authorities, but there are still actions which can be taken, such as gain-share agreements with contractors. I believe that Croydon could do a lot more on reuse. Flanders in Belgium has 6 million inhabitants and 100 reuse shops, which clean, repair and resell used goods (Friends of the Earth 'Taking out the Rubbish' conference report, April 2009). This means that Flanders has a ratio of 1 shop to every 60,000 inhabitants, which is around six times better than Croydon's ratio (Croydon only has one true reuse facility - ARC). Flanders has shown that it should be possible for Croydon to have several more reuse centres. Anaerobic digestion Anaerobic digestion produces a biogas this could be burnt to generate heat or electricity and could be used as vehicle fuel. It also produces a liquid residue called digestate which can be used as a soil conditioner. A recent report by the National Grid has suggested that in the longer term there is the potential for renewable gas, mostly produced through AD, to provide up to 50% of UK residential gas demand (National Grid, 2009). Croydon could thus profit by selling AD-produced gas, while also knowing that the electricity generated from it is basically carbon-neutral, unlike that produced through incineration. Mechanical and Biological Treatment This produces a biologically inert substance which can be disposed of. It is not classified as landfilling under the landfill allowance trading scheme. AD and MBT units can be smaller and more flexible than incinerators, meaning that if properly designed they can be removed and replaced as technology, and the nature of the waste they have to deal with, moves on. I hope that my comments will be taken into consideration. Many thanks for reading. Officer's Initial Comment: The points you raise are noted. In the event that a planning application were to be submitted a developer would be required to provide technical
reports and evidence to address the issues raised in draft policy WP6 as well as the other policies. Page 99 Consultee ID: 361711 Full Name: Paul Shaw Organisation: Selsdon Residents Association Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL673 Is Site Suitable? Site Number: Site comment: I am sorry it has taken your final reminder e-mail to elicit a response from me on behalf of Selsdon Residents' Association. I apologise too for not writing to thank you and Andy Day for taking the time to come to talk to us in Selsdon on 14th September. We have found this part of the consultation exercise rather difficult on which to form any useful opinion; and to that extent this note is almost like a NIL return. As far as the four potential waste management sites for Croydon are concerned, since they have been selected as the most suitable locations of the five looked at, or offered, by Croydon, without any specialist knowledge or experience on our part, providing they are environmentally acceptable, we have no preference or other riders to add. In discussion, we kept coming back to the question of what activity was to be carried out on any chosen site ? If that were known, a specific choice or meaningful questions as to suitability or otherwise, may have been more identifiable. Similarly, we have no constructive comments to offer on your seven Draft policies. They appear to us to cover all the salient points we could think of. Officer's Initial Comment: The points you raise are noted. Consultee ID: 354743 Full Name: Paul Pickering Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 7 of 142 Croydon Agenda Item 3 Consultee ID: 354743 Full Name: Paul Pickering Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD150 Is Site Suitable? Site Number: Site 1: Factory Lane Transfer Station Site comment: Despite the fact that Factory Lane is already a waste transfer site the likely development of a "waste for energy" plant within such close proximity to a large housing estate and primary school (Kingsley Primary School) is very worrying. The new technologies likely to be used remain unproven. There are certainly concerns over the output of pollution during startup and shutdown procedures and during routine plant maintenance. This area already suffers from very high levels of lorry traffic which would only increase under any further development. The whole idea of a "waste for energy" plant is an extremely short-sighted way of dealing with our waste problem. Officer's Initial Comment: The references to residential areas, pollution, schools and traffic generation are noted. The London Plan and the draft policies being proposed require existing waste management sites to be retained and where possible improved. A comprehensive list of issues were considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Only development proposals in accordance with the draft policies would be supported. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised in draft policy WP6. Consultee ID: 206782 Full Name: Mr Mark Leivers Organisation: Sterecycle Agent ID: Agent Name: Agent Organisation: Page 100 Comment ID: PSPCD230 Is Site Suitable? Site Number: Site 1: Factory Lane Transfer Station Site comment: Two factors are relevant in relation to the existing sites identified in Table 2.2; –« The sites are already in waste use and hence it is imperative that in allocating sites for future use only the additional capacity to which sites might give rise is taken into account. The potential for these sites to contribute towards meeting the additional requirement for land is therefore very limited. –« With the exception of Sites 18, 26, 125 and 126 all the sites identified are under 2.5 hectares and are therefore of inadequate size to accommodate a strategic waste use. If a range of such sites are not allocated then the strategy becomes severely constrained and may not be capable of delivering the most sustainable and cost effective solution. In relation to those sites over 2.5 hectares; Officer's Initial Comment: The point raised is an important consideration and will require further evaluation and evidence. Consultee ID: 199186 Full Name: Mr Peter Watson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD30 Is Site Suitable? Site Number: Site 1: Factory Lane Transfer Station Site comment: Site is also closest to residential area Officer's Initial Comment: The points raised are noted. Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD66 Is Site Suitable? Site Number: Site 1: Factory Lane Transfer Station Site comment: Sites I consider suitable are existing disposal sites not too close to residential areas Officer's Initial Comment: Site 1 at Factory Lane is an existing Household Recycling Centre. The London Plan and the policies being proposed require existing waste management sites to be retained and where possible improved. The points raised are noted. Consultee ID: 354108 Full Name: Mr Christopher Rimell Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 8 of 142 Croydon Consultee ID: 354108 Full Name: Mr Christopher Rimell Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL162 Is Site Suitable? Site Number: Site 1: Factory Lane Transfer Station Site comment: Factory Lane sites 1, 105, and 125 logical development of existing sites. Officer's Initial Comment: The points raised are noted although of the three sites referred to only Site 1 is an existing site. Consultee ID: 354117 Full Name: Ms Anne Middlemiss Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL165 Is Site Suitable? Site Number: Sites 1 & 105 Site comment: Sites 1 & 105 are accessible to major roads and also they appear to have access to rail. Ditto for site 99. It occurs to me that rail access could take the pressure of roads and cause less environmental harm. Don't know the areas so can't comment on any impact on residents nearby Officer's Initial Comment: The points raised are noted. Consultee ID: 323725 Full Name: Mrs Katy Nicol-Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL20 Is Site Suitable? Site Number: Site 1: Factory Lane Transfer Station Page 101 Site comment: While I feel that we are making a head way with alternative recycling and I do agree with how we are supposedly taking action against saving our world, I feel strongly opposed to having even more factories and depots in the Beddington Lane area, as this area is already over run with factories and depots which cause untold havoc with lorries and roads which are destroyed, extremely muddy and dangerous for all residents. Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6. Consultee ID: 357632 Full Name: A.E Harper Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL361 Is Site Suitable? Site Number: Site 1: Factory Lane Transfer Station Site comment: Not enough information as to exactly what kind of waste disposal unit is going to be i.e.is it going to be the incineration plant spoken of a while ago.If so we do not want it in the factory lane site.More info please. Officer's Initial Comment: A comprehensive list of issues were considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Consultee ID: 357756 Full Name: A Douthwaite Organisation:
Agent ID: Agent Name: Agent Organisation: Agenda Item 3 Comment ID: PSPSL375 Is Site Suitable? Site Number: Sites 1, 105 and 125 Site comment: As they are central to the 4 boroughs, the Beddington Lane and Factory Lane areas (i.e the whole industrial area bewteen the A236 and A232) lend themselves as potential sites provided they are as far as possible from residential areas and do not infringe on streams like the Wandle Officer's Initial Comment: The points you raise are noted.
26 November 2009 Page 9 of 142 Croydon Agenda Item 3 Consultee ID: 332207 Full Name: Mr Terry Osborn Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL47 Is Site Suitable? Site Number: Site 18: Viridor Recycling Centre, Beddington Farmlands Site comment: The Viridor Recycling Centre (Site 18) is on land which is earmarked for a major urban nature reserve and part of Beddington Farmlands which is a "designated Site of Metropolitan Importance for Nature Conservation" and must be wholly retained as such. Beddington Farmlands holds the largest population of Tree Sparrows in the SE and therefore of huge importance. Further large scale Waste initiatives on or around this site will undoubtedly threaten the existence of this species at the site and others that breed at and use the site. Similarly the Land West of Beddington Lane adjacent to existing Waste Management facilities site 57) which is Metropolitan Open Land helps support important bird species to survive and is considered an integral part of Beddington Farmlands. Officer's Initial Comment: The points raised are noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 346655 Full Name: Mr John Parish Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL62 Is Site Suitable? Site Number: Site 18: Viridor Recycling Centre, Beddington Farmlands Site comment: Ref site numbers 18 and 57 . Both sites are unsuitable . As any informed ornithologist will confirm, Beddington Farm is the most important breeding site in South London for threatened bird species and is also home to many important wintering migrant birds. The SLWP Supporting Documents inform us that the Page 102 Farm is identified as a Centre of Metropolitan Interest for Nature Conservation and is safeguarded for the creation of the proposed Wandle Valley Country Park following the completion of landfill and site restoration. Other supporting documents make frequent references to inclusion of sustainability objectives 'to enhance priority habitats and protect species and biodiversity within Sth London'. Existing planning consent requires the temporary waste processing facilites sited on the Farm to be removed at the end of the landfill process. The Metropolitan Open Land status of both sites ought also to afford them protection especially as many alternative suitable non-MOL sites for the proposed developments have been identified. It is therefore quite astounding that Sites 18 and 57 have been placed on your shortlist for further consideration as sites for waste management facilities . Study of the Supporting Documents reveals another worrying issue for Sutton residents, namely flood risk . In the Flood Risk Assessments detailed in Appendix 5 of the Stage 2 Sustainability Appraisal, the analyses used to commence the Sequential Tests have located Site 57 in Flood Zone 1 (ie low probability of flood risk) whereas Site 18, located only some 50m away, with no discernible difference in surface level between, has been placed in Flood Zone 3(b) (ie high probability of flood risk). Assuming they are accurate, these assessments suggest a very sensitive flood risk balance in this vicinity and, in that case, the ongoing deposition of huge mounds of waste and soil above original ground levels in the adjacent extensive landfill workings could exert a significant influence by constricting the flood plain. The base 'Flood Risk Assessment' map used in the analyses will almost certainly have been prepared prior to commencement of the landfill and therefore, if these Flood Risk Analyses are to provide a realistic safeguard rather than being a 'box-ticking' exercise only, the analyses should be revisited (including reappraisal of the base map data). Officer's Initial Comment: The points raised are noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 346655 Full Name: Mr John Parish Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 10 of 142 Croydon Consultee ID: 346655 Full Name: Mr John Parish Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL61 Is Site Suitable? Site Number: Site 57: Land west of Beddington Lane adjacent to industrial areas and existing waste management facilities Site comment: Ref site numbers 57 and 18. Both sites are unsuitable. As any informed ornithologist will confirm, Beddington Farm is the most important breeding site in South London for threatened bird species and is also home to many important wintering migrant birds. The SLWP Supporting Documents inform us that the Farm is identified as a Centre of Metropolitan Interest for Nature Conservation and is safeguarded for the creation of the proposed Wandle Valley Country Park following the completion of landfill and site restoration. Other supporting documents make frequent references to inclusion of sustainability objectives 'to enhance priority habitats and protect species and biodiversity within Sth London'. Existing planning consent requires the temporary waste processing facilites sited on the Farm to be removed at the end of the landfill process. The Metropolitan Open Land status of both sites ought also to afford them protection especially as many alternative suitable non-MOL sites for the proposed developments have been identified. It is therefore quite astounding that Sites 18 and 57 have been placed on your shortlist for further consideration as sites for waste management facilities . Study of the Supporting Documents reveals another worrying issue for Sutton residents, namely flood risk . In the Flood Risk Assessments detailed in Appendix 5 of the Stage 2 Sustainability Appraisal), the analyses used to commence the Sequential Tests have located Site 57 in Flood Zone 1 (ie low probability of flood risk) whereas Site 18, located only some 50m away, with no discernible difference in surface level between, has been placed in Flood Zone 3(b) (ie high probability of flood risk). Assuming they are accurate, these assessments suggest a very sensitive flood risk balance in this vicinity and, in that case, the ongoing deposition of huge mounds of waste and soil above original ground levels in the adjacent extensive landfill workings could exert a significant influence by constricting the flood plain. The base 'Flood Risk Assessment' map used in the analyses will almost certainly have been prepared prior to commencement of the landfill and therefore, if these Flood Risk Analyses are to provide a realistic safeguard rather than being a 'box-ticking' exercise only, the analyses should be revisited (including reappraisal of the base Page 103 map data) before development on these sites is considered further. Officer's Initial Comment: The points raised are noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 328276 Full Name: Dr Jacqueline Card Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD10 Is Site Suitable? Site Number: Site 99: Purley Oaks Highways Depot Site comment: I had always hoped, and still do, that the lake area next to the Depot would be developed as a pleasant park - lake area with wildfowl etc. and perhaps a few little boats. (Maybe special plants can remove any current toxicity). Officer's Initial Comment: The points raised are noted, however, the "lake" lies outside of Site 99. Consultee ID: 343647 Full Name: Mr Padraig Sheerin Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD14 Is Site Suitable? Site Number: 99 Site comment: The Purley Oaks Highway Depot site ('the Depot') whilst near the A235 Brighton Road, remains in a very residential area with also a number of schools in its proximity. The impact of the lorries etc necessary to transport the waste from the boroughs to Purley Oaks would have a marked impact on road safety, Agenda Item 3 especially for children, and would increase the congestion caused by the woeful Purley Cross gyratory system. Moreover even were the lorries etc to be banned from using local roads as short cuts, the lorries' addition to the existing congestion would inevitably and significantly increase the number of private motorists etc using these roads around the Depot as short cuts, thus further aggravating the issues outlined above. Any other sites which are away from residential areas. Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6.
26 November 2009 Page 11 of 142 Croydon Agenda Item 3 Consultee ID: 326499 Full Name: Mr Jonathan Weller Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD9 Is Site Suitable? Site Number: 99 Site comment: The map below refers and I have given my reasons as to why I feel this site is suitable for a waste management facility above. Site 99: Purley Oaks Highway Depot, Croydon Officer's Initial Comment: The points raised are noted. Consultee ID: 355322 Full Name: Mr John Brighten Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL268 Is Site Suitable? Site Number: Site 99: Purley Oaks Highway Depot Site comment: I note the proposed rationalisation of waste management facilities in south London. I live close to the site 99 in Croydon i.e. the Cuoncil Highways Depot at Purley Oaks and would like to make my representation for its retention in its present form for the following reasons: 1. It is the only facility close by that I can get to with waste as neighter my wife of I drive; that applies to quite a few people living in our neighbourhood that can [unreadable] or barrow to this particular facility. 2. It is well run and the staff are obliging and friendly. 3. Expansion would not be feasible, I think, unless the pond is filled in as the site is surrounded by houses, road and railway. 4. Nevertheless it is an extremely useful facility for this area of South Croydon where there are quite a number of elderly people and enables local residents to follow the spirited waste recycling thus enabling green/climate change worries to be enhanced. Page 104 Officer's Initial Comment: Site 99 is adjacent to the Household Recycling Centre. Subject to the requirements of proposed policy WP6, Site 99 offers the opportunity to improve on the existing facilities. Consultee ID: 357883 Full Name: Mr John Massie Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL389 Is Site Suitable? The site is not suitable Site Number: Site 99: Purley Oaks Highway Depot Site comment: I have read your consultation documents and have the following comments. Potential Sites I live near to the Purley Oaks Highway Depot (Site No. 99) identified as "Has potential" in Table 2.4. This is a high density residential area and the existing site has dangerous traffic access problems at peak times. Officer's Initial Comment: The references to residential areas and traffic generation are noted. Site 99 is next to an existing Household Recycling Centre. The London Plan and the draft policies being proposed require existing waste management sites to be retained and where possible improved. A comprehensive list of issues were considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Only development proposals in accordance with the draft policies would be supported. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised in draft policy WP6. Consultee ID: 357900 Full Name: Mr Robert Jones Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 12 of 142 Croydon Consultee ID: 357900 Full Name: Mr Robert Jones Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL391 Is Site Suitable? The site is not suitable Site Number: Site 99: Purley Oaks Highway Depot Site comment: I received a letter from Croydon Council dated 24 July, advising me of a number of potential sites for a new waste management facility. I looked on the Counci website and found additional information. Unfortunately I was unable to access the online questionnaire so was unable to pass on my comments. I live very close to the Council's Highways depot at Purley Oaks. As such I know the area very well and do not think that it is suitable for a new waste management centre. We already have the Purley Oaks recycling centre which is always very busy at weekends with traffic stretching along the Brighton Road as people queue to enter the site. I feel that having an additional facility or even extending the existing one will only add to the congestion and disruption for local residents in the area. Instead I would favour building the new facility next to the existing site in Factory lane. This area is not as heavily populated as Purley Oaks and so is likely to cause much less inconvenience for local residents. The access via the dual carriageway would also make it easily accessible for potential users from any of the four boroughs. I look forward to seeing the results of this round of consultations. Officer's Initial Comment: The references to residential areas and traffic generation are noted. Site 99 is next to an existing Household Recycling Centre. The London Plan and the draft policies being proposed require existing waste management sites to be retained and where possible improved. A comprehensive list of issues were considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Only development proposals in accordance with the draft policies would be supported. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised in draft policy WP6.
Consultee ID: 358646 Full Name: Mr Ian Goodwin Organisation: Page 105 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL491 Is Site Suitable? The site is suitable Site Number: Site 99: Purley Oaks Highway Depot Site comment: A personal comment on my local Facility - Croydon's Purley Oaks Site - Excellent Site with wide variety of recycling considering the small area, however longer opening hours would be a bonus, too small area for general waste though. Officer's Initial Comment: The points you raise are noted. Consultee ID: 137456 Full Name: Mr Guy Salt Organisation: Sanderstead Residents' Association Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL539 Is Site Suitable? Site Number: Site 99: Purley Oaks Highway Depot Site comment: cannot comment on the sites chosen because you do not explain how you intend to use them. The policies proposed all appear reasonable but they are in a vacuum until specific proposals are produced. Croydon's Purley Oaks depot, for example, causes congestion in Brighton Road on a Sunday because it does not have enough capacity to accommodate the demand for car unloading within the depot. Officer's Initial Comment: The references to traffic issues are noted. Site 99 is next to an existing Household Recycling Centre. The London Plan and the draft policies
being proposed require existing waste management sites to be retained and where possible improved. A comprehensive list of issues were Agenda Item 3 considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Only development proposals in accordance with the draft policies would be supported. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised in draft policy WP6. Consultee ID: 206179 Full Name: Dr. Stanislaw Prokop Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 13 of 142 Croydon Agenda Item 3 Consultee ID: 206179 Full Name: Dr. Stanislaw Prokop Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD218 Is Site Suitable? Site Number: Site 102: Purley Way, Lysander Road and Imperial Way Industrial Area Site comment: Contaminated land group Officer's Initial Comment: The point raised is an important consideration. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised. Consultee ID: 206782 Full Name: Mr Mark Leivers Organisation: Sterecycle Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD236 Is Site Suitable? Site Number: Site 102: Purley Way, Lysander Road and Imperial Way Industrial Area Site comment: Whilst suitable areas may exist within the industrial areas set out in Table 2.6, the absence of specific identification and the likely requirement for land assembly calls into question the deliverability of such sites, specifically to meet a requirement for strategic facilities. Where it is chosen to identify such estates as having the potential to accommodate waste management uses, this should be on the basis of a criteria based approach and should not count towards the land requirement that is identified as necessary to deliver a sustainable strategy (see section 4 of the main representations).
Officer's Initial Comment: The London Plan and the draft policies being proposed require strategic industrial locations and employment areas to be a part of the area of Page 106 search when trying to identify potential sites for waste management facilities. A comprehensive list of issues were considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Consultee ID: 32844 Full Name: Claire Craig Organisation: English Heritage Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL668 Is Site Suitable? Site Number: site 102: Purley Way, Lysander Road and Imperial Way Industrial Area Site comment: English Heritage must question the inclusion of Site 102 in the South Beddington Industrial Area when the Appendix 4 table lists it as a site that contains a site of international or national historic importance in the "showstopper" column. While we acknowledge that the site is included as one which may have some deliverable areas, English Heritage would welcome more explicit treatment of proposals for this site as, on the face of it, it would seem that this site should be precluded for reasons of historic environment significance. Officer's Initial Comment: The land incorporating the Listed Building at Airport House was removed Site 102. Only development proposals in accordance with the draft policies would be supported. In the event that a planning application were to be submitted a developer would be required to take account of heritage issues, the draft policies of the Waste Plan DPD and other mainstream planning control considerations. Consultee ID: 354743 Full Name: Paul Pickering Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD160 Is Site Suitable? Site Number: Site 104: Purley Way Lombard Business Park Site comment: As highlighted in your text this area has recently been re-developed. Traffic congestion around the Lombard Roundabout and the surrounding roads can be horrendous. An increase in traffic could affect the emergency services ability to access Mayday Hospital. Officer's Initial Comment: The new development and traffic points raised are an important consideration. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address these issues. Consultee ID: 354743 Full Name: Paul Pickering Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 14 of 142 Croydon Consultee ID: 354743 Full Name: Paul Pickering Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD154 Is Site Suitable? Site Number: Site 105: Factory Lane Industrial Estate Site comment: Despite the fact that Factory Lane is already has a waste transfer site the likely development of a "waste for energy" plant within such close proximity to a large housing estate and primary school (Kingsley Primary School) is very worrying. The new technologies likely to be used remain unproven. There are certainly concerns over the output of pollution during startup and shutdown procedures and during routine plantmaintenance. This area already suffers from very high levels of lorry traffic which would only increase under any further development. The whole idea of a "waste for energy" plant is an extremely short- sighted way of dealing with our waste problem. Officer's Initial Comment: The references to residential areas, pollution, schools and traffic generation are noted. A comprehensive list of issues were considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Only development proposals in accordance with the draft policies would be supported. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised in draft policy WP6. Consultee ID: 323725 Full Name: Mrs Katy Nicol-Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL21 Is Site Suitable? Site Number: Site 105: Factory Lane Industrial Estate Site comment: While I feel that we are making a head way with alternative recycling and I do agree with how we are supposedly taking action against saving our world, I feel strongly opposed to having even more factories and depots in the Beddington Lane area, as this area is already over run with factories and depots which Page 107 cause untold havoc with lorries and roads which are destroyed, extremely muddy and dangerous for all residents. Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6. Consultee ID: 355532 Full Name: Mr Mark Netts Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL279 Is Site Suitable? The site is not suitable Site Number: Site 105: Factory Lane Industrial Estate Site comment: The site is unsuitable for a number of reasons. Firstly, the existing Croydon recycling centre in Factory Lane creates a very large volume of traffic at the moment. This would obviously increase significantly. Secondly, the area is already far too residential to place such a huge industrial development. Wandle Park is not far away and has received various grants to redevelop the park and make it a more attractive place for people to visit, at least that's what the plan was. I can't see many people wanting to visit the area with a huge waste centre 2 mins away!! Thirdly, why be so lazy about the areas to be considered where facilities already are. This plan is so vast that a re-think would probably be best, rather than a lazy solution to "grow" existing facilities just because they are already there. Adding to the Factory Lane site will cause misery to many local residents, but I doubt very much that the views of us mere mortals will really be taken into consideration anyway. Maybe we should have been notified in the first place, not about potential sites already proposed, but what sites all of us would consider being a good idea. Agenda Item 3 Officer's Initial Comment: The references to residential areas and traffic generation are noted. The London Plan and the draft policies being proposed require existing waste management sites to be retained and where possible improved. A comprehensive list of issues were considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Only development proposals in accordance with the draft policies would be supported and Wandle Park would be a material consideration. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised in draft policy WP6.
26 November 2009 Page 15 of 142 Croydon Agenda Item 3 Consultee ID: 357632 Full Name: A.E Harper Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL363 Is Site Suitable? Neutral Site Number: Site 105: Factory Lane Industrial Estate Site comment: Also I cannot place the possible whereabouts of the location of proposed site no; 105. Officer's Initial Comment: Site 105 lies to the north side of Factory Lane, between Mitcham Road, Grafton Road and Euston Road. Consultee ID: 330548 Full Name: Miss Helen Coulton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL37 Is Site Suitable? Site Number: Site 105: Factory Lane Industrial Estate Site comment: insufficient lanes for an already busy traffic area, further developments are already pending which will already place extreme pressure on the surrounding roads. The surrounding area is too residential for a development such as this Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6. Consultee ID: 137101 Full Name: Revd L Richards Organisation: The Glory Mission Agent ID: Agent Name: Agent Organisation: Page 108 Comment ID: PSPSL383 Is Site Suitable? The site is suitable Site Number: Site 105: Factory Lane Industrial Estate Site comment: I strongly agree with the site in Factory Lane 105 to 125 Officer's Initial Comment: The points you raise are noted. Consultee ID: 361662 Full Name: Austin Mackie Organisation: Austin Mackie Associates Ltf Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL657 Is Site Suitable? The site is not suitable Site Number: Site 105: Factory Lane Industrial Estate Site comment: I am out of the Office, so unable to log-in to your on-line system, but would ask that you accept this email as an objection to site 105. Our clients own land within area 105 highlighted green on the attached plan. The draft consultation refers to area 105 as a top scoring' location for potential waste facilities. On behalf of our client, we object to the inclusion of the above site and recommend that it be identified as being unsuitable for consideration for a number of reasons: In summary: Area 105 shares significant boundaries with residential properties on its west, northern and eastern boundaries. At present, a great deal of commercial traffic uses otherwise residential roads such as Grafton and Euston Road as a shortcut. This interface between commercial and residential needs to be managed more positively to alleviate such impacts and to improve the environmental quality of the area and associated amenity issues. The impact of introducing waste uses in this area would be highly detrimental to surrounding residential amenity in terms of not only traffic, but also other negative impacts of waste related uses and would prejudice any ability to enhance the area No waste related activities should be promoted north of Factory Lane. LB Croydon should be encourage to introduce proposals to mange the existing transition between commercial and residential properties and to consider and promote environmental enhancement measures that are necessary Any proposal to introduce waste related proposals in this area will have a highly negative impact on necessary regeneration and environmental enhancement and should be rejected. Thank you for asking for our opinions. Please advise us of any other comments that you receive in relation to this area and also keep us informed of future progress. Officer's Initial Comment: The references to residential areas, traffic generation and environmental enhacements are noted. A comprehensive list of issues were considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Only development proposals in accordance with the draft policies would be supported. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised in draft policy WP6.
26 November 2009 Page 16 of 142 Croydon Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD121 Is Site Suitable? Site Number: Site 125: Factory Lane (South side) Site comment: Factory Lane (south side) is immediately adjacent to Wandle Park, Croydon. Firstly, the Wandle Trust questions the wisdom of developing potentially noisy activities, particularly involving heavy transport movements, in an area immediately adjacent to a public park. Secondly, the Wandle Trust would not support redevelopment if it were to have any negative impact on the wildlife of this area, particularly in relation to the planned deculverting of the River Wandle through this park. Officer's Initial Comment: The effects on Wandle Park and the River Wandle would be material planning considerations were a proposal to come forward at Factory Lane at a later stage. Issues including smell, traffic, noise and wider amenity would be considered again through proposed policy WP6. Consultee ID: 354743 Full Name: Paul Pickering Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD156 Is Site Suitable? Site Number: Site 125: Factory Lane (South side) Site comment: Despite the fact that Factory Lane is already has a waste transfer site the likely development of a "waste for energy" plant within such close proximity to a large housing estate and primary school (Kingsley Primary School) is very worrying. The new technologies likely to be used remain unproven. There are certainly concerns over the output of pollution during startup and shutdown procedures and during routine plantmaintenance. This area already suffers from very high levels of lorry traffic which would only increase under any further development. The whole idea of a "waste for energy" plant is an extremely short- sighted way of dealing with our waste problem. Page 109 Officer's Initial Comment: The references to residential areas, pollution, schools and traffic generation are noted. A comprehensive list of issues were considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Only development proposals in accordance with the draft policies would be supported. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised in draft policy WP6. Consultee ID: 206782 Full Name: Mr Mark Leivers Organisation: Sterecycle Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD233 Is Site Suitable? Site Number: Site 125: Factory Lane (South side) Site comment: Site 125: The site is currently in distribution use and Sterecycle is not aware of its availability and hence its deliverability. The Mouchel report recommends limiting the height of any development to 18 metres which would serve to preclude a wide range of waste management uses, including Autoclave and EfW, and hence the site is not generally suitable to accommodate the full range of strategic waste management uses even if it becomes available. Officer's Initial Comment: The point made about deliverability is noted. A comprehensive list of issues were considered when identifying the potential sites and are proposed to be considered again through draft policy WP6 if a planning application were to be submitted. Only development proposals in accordance with the draft policies would be supported. In the event that a planning application were to be submitted a developer would be
required to provide technical reports and evidence to address the issues raised in draft policy WP6. Agenda Item 3 Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 17 of 142 Croydon Agenda Item 3 Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD73 Is Site Suitable? Site Number: Site 125: Factory Lane (South side) Site comment: Sites I consider suitable are existing disposal sites not too close to residential areas. Sites not numbered I consider unsuitable, particularly site 127 by the Wandle river. Officer's Initial Comment: The points raised are noted. Consultee ID: 323725 Full Name: Mrs Katy Nicol-Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL19 Is Site Suitable? Site Number: Site 125: Factory Lane (South side) Site comment: While I feel that we are making a head way with alternative recycling and I do agree with how we are supposedly taking action against saving our world, I feel strongly opposed to having even more factories and depots in the Beddington Lane area, as this area is already over run with factories and depots which cause untold havoc with lorries and roads which are destroyed, extremely muddy and dangerous for all residents. Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be
received, they would be considered again through proposed policy WP6. Page 110 Consultee ID: 330548 Full Name: Miss Helen Coulton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL36 Is Site Suitable? Site Number: Site 125: Factory Lane (South side) Site comment: We have a smell from the water plant already where we live. The area is already very congested with weekend traffic for IKEA etc, this will just add o the congestion and make our living conditions worsen. Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6. Kingston Consultee ID: 323366 Full Name: Dr C Winstanley Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD7 Is Site Suitable? Site Number: land alongside the A3 away from residential areas should be investigated Site comment: Site noted above is disused land and should be considered. (link to sites did not function) The old B&Q and Comet site on the boundary with Merton - unsuitable due to dreadful traffic increase as a result of new B&Q and poor layout of Shannon's Corner roundabout Officer's Initial Comment: Noted. Traffic is an issue of acknowledged importance which will require further evaluation Consultee ID: 350729 Full Name: Mr Stewart Keating Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 18 of 142 Kingston Consultee ID: 350729 Full Name: Mr Stewart Keating Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL125 Is Site Suitable? Site Number: Site comment: None of the sites in Kingston is suitable for a major waste processing plant - inadequate roads, too much residential/commercial activity in each. in addition none of the sites seems to suitable for an incinerator type plant. Go to Millwall football club in SE London and you will see the parking of dust on the ground, and taste the ash inn the air, yet the flue emissions are clear. Officer's Initial Comment: Noted. Objection to any site in Kingston being used for a major site because of inadequate roads, compatibility with residential and commercial land uses, air quality, dust and pollution. Consultee ID: 354042 Full Name: Mintz Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL136 Is Site Suitable? Site Number: Site comment: Site number 6 Villiers Road - already operating at capacity as far as I can see whenever I visit have to queue. Future expansion or changes could have detrimental effect on public's health, not only from the plant itself but also due to increased traffic congestion which is already high. Site number 47 Jubilee way - too close to residential area. Main point though is that it will be on a road that is already horrendously congested. These facilities should be built away from towns.
Officer's Initial Comment: Noted. Objections to Villiers Road based on capacity, public health and traffic congestion. Jubilee Way proximity to residential and traffic Page 111 congestion. Prefer to see a facility built away from towns. Consultee ID: 354043 Full Name: Mrs KATHLEEN JANKOWSKI Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL137 Is Site Suitable? Site Number: Site comment: For this plan to be environmentally pro-active, it really need each borough to have it's own site to reduce the environmental damage done by lorries transporting the waste. If this plan is not acceptable, then the facility needs to be centrally located in order to reduce the effects of further pollution. The proposed site at Tolworth is unsuitable due to heavy pollution in the area already caused by the A3. Air monitoring equipment shows very high levels of pollution. Officer's Initial Comment: Noted. Prefer to see spread of new facilities across area (1 per borough) to reduce HGV movements and pollution. Otherwise one centrally located facility not at Tolworth because of existing high levels of air pollution Consultee ID: 354064 Full Name: Mrs J Davis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL152 Is Site Suitable? Site Number: Site comment: Would appear a good idea Agenda Item 3 Officer's Initial Comment: Noted support Consultee ID: 354369 Full Name: Mrs. Aniela qayyum Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 19 of 142 Kingston Agenda Item 3 Consultee ID: 354369 Full Name: Mrs. Aniela qayyum Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL181 Is Site Suitable? Site Number: Site comment: I don't think it is good idea to have waste management facility sites on SITE 47, 351, 352, 353 as these are very close to residential areas. Also site 47 is right next to Tolworth roundabout which already very heavily used and does not need further congestion that waste facilities would bring, not only further congestion but the additional pollution. It is also going to be situated very close to Tolworth Broadway which is used by a lot of local residents. Tolworth roundabout and the broadway is used extensively as a 'through commute' to get into Kingston and London (along the A3) - it really does not need large waste facilities on its doorstop. Sites 352, 351, and 353 not only are close to residentail areas but also near primary schools. Out of all the sites proposed for Kingston, the only one that possibly makes any sense is where the curentwaste site is - surely it would make more sense to develop or adapt that one to meet the needs required. I seriously hope that proper thought is given to this proposal and the very real effect it would have on local residents before any decisions are made. Officer's Initial Comment: Noted possible support for existing waste site (Villiers) and objection to others on various grounds - proximity to residential and schools, road congestion. Consultee ID: 354651 Full Name: Mr William Watson Organisation: Agent ID: Agent Name: Agent Organisation:
Comment ID: PSPSL202 Is Site Suitable? Site Number: Page 112 Site comment: How come only one small site Officer's Initial Comment: Noted Consultee ID: 355171 Full Name: Mrs E Gray E.B.E Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL238 Is Site Suitable? Site Number: Site comment: The site in Raeburn Ave/ Alexander Drive is useful especially for locals, elderly. No transport would need tight management. Officer's Initial Comment: Noted support for site Consultee ID: 355174 Full Name: Mr Ian Callander Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 20 of 142 Kingston Consultee ID: 355174 Full Name: Mr Ian Callander Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL243 Is Site Suitable? Site Number: Site comment: We accept and acknowledge that something has to be done to improve provision for waste management and recycling - not just locally, but nationally, and indeed, internationally - and do not wish to be seen as NIMBYs (not-in-my-back-yard's) so hope that our comments are seen to be fair and balanced. We can only really comment on the proposed sites in our immediate area, as these are the only sites on which we have a good understanding of the potential effect of any developments of this nature. Site 6 - Villiers Road: In favour - it is an existing facility, so will have less of an overall impact on the surrounding area. Against - the surrounding (residential) roads are already clogged with traffic using the site and any development would make the situation even worse. Site 46 - Coal Depot, Leatherhead Road: In favour - it is an existing (derelict) commercial site and not adjacent to any large housing developments. It also has potential for the rail link to be reinstated to remove waste, reducing the impact on the local roads. (This potential development could also be linked to a possible extension of the existing network rail line behind the Barwell Estate along the existing rail formation to provide a passenger station at Chessington World of Adventures, thus saving the travelling public from having to walk along the busy Leatherhead Road from Chessington South Station to the WoA.) Against - it is very close to Chessington Community College and the Leatherhead Road is already choked with traffic approaching the World of Adventures. Kingston council has also recently granted permission for a Lidl supermarket nearby which will make the traffic situation worse still. Site 47 - Jubilee Way, Tolworth: In favour - the site has had no specific use for a number of years and is close to main road links. Against - Hilton Hotels have been granted permission to build a hotel on part of this site, and this may not make for the best of neighbours. Also, the access road (A240) is already choked with traffic, and any increase may bring the area to a complete standstill. Sites 351/352/353 - Chessington Industrial Estate: In favour - There are pieces of land within this site that are vacant and could potentially be used. Against - it is to be assumed that any development on this estate would involve some degree of compulsory purchase and relocation of a number of existing businesses, so may prove to be the most expensive option. Also, the existing access road to the site (Jubilee Page 113 Way) is already badly congested. The option of accessing this site via the Chessington residential estate should be considered as a non-starter. Although restrictions are currently in place to prohibit goods vehicles from using this access, some large vehicles clearly flout this already, and this would be worsened by the arrival of any waste recycling facility. Site 353 in particular is close to residential areas, and the easiest access to this site would appear to be along the A3 service road (Hook Rise South) which, again, would have to be considered as a non-starter. Any site selected for development as a waste handling facility has to consider the impact both of traffic bringing waste to the site and of traffic removing waste from the site. Accordingly, in our opinion, it makes most sense to consider sites that offer the opportunity for materials to be removed from the site by rail, whether using existing formations or creating new railheads. Thus, in the Chessington area, the most logical options would appear to be site 46, which could be reinstated to the national network to enable outgoing traffic to be handled by rail. (The possiblility of creating new rail access to the Chessington Industrial Estate also exists, but would be a more expensive option.) In Kingston, Site 6 (Villiers Road) seems the most logical option, as it is an existing facility and has room to expand, although the concerns of residents about the capacity of local roads to handle any increase in traffic should be considered. Again, is there any possibility of linking this site to the rail network near Berrylands station to handle outgoing flows? Officer's Initial Comment: Noted some support for Villiers Road as existing facility but concern over traffic and some support for Site 46 coal depot as possibility of rail link, an existing commercial site and not so close to residential but concern over traffic and impact on other nearby land uses Consultee ID: 322381 Full Name: roy Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3 Comment ID: PSPSL4 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I think Croydon would be the ideal place for London Waste, it could almost have been created for that purpose. I don't see why putting rubbish in landfill is such a bad thing anyway. I don't believe that what is collected via the recycling service is actually recycled. I think it is collected, and then stored. It is costing us loads of money to organise, and is a complete waste of time. All that's happening is that we're self imposing fines, setting ridiculous targets, and then just charging taxpayers a ton of money for the pleasure of it. Completely ridiculous. Officer's Initial Comment: Disagree. The Plan is based on a requirement to reduce waste disposal to landfill.
26 November 2009 Page 21 of 142 Kingston Agenda Item 3 Consultee ID: 322531 Full Name: Miss Kate Vivian Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL5 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Do not want new waste site on Chessington industrial estate. The traffic through the residential roads leading to it, namely Roebuck and Mount Road, is heavy and very fast (a danger to children) already, and this would make it much worse. I don't think it can or should support more people whizzing through it. I support the idea of a site in Barwell. Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6. Consultee ID: 322778 Full Name: Mr Mike Gravatt Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL6 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I consider the locations at Tolworth and Chessington industrial estate to be inherently unsuitable. Both are right in the middle of heavily populated residential areas. It is essential that such facilities are located away from centres of population Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be
Officer's Initial Comment: Page 114 received, they would be considered again through proposed policy WP6. Consultee ID: 346149 Full Name: Miss Joanna Campbell Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL60 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: As a resident living close the Villiers Road Waste Transfer Station in Kingston, I am extremely worried by the prospect of potentially more waste not least because of the resulting increase in traffic going to and from the site, especially since most of the heavy lorries carrying all the waste travel along Hawks Road where I live. This is a residential road which was not designed to cope with such a volume of heavy traffic. On a frequent basis we have to cope with large lorries rumbling along the road which shake the houses (on some occasions the windows rattle), some of which leave a strong smell of rotting rubbish in their wake. Their size means that when they turn from Hawks Road to Villiers Road at the junction they have to swing round right across to the other side of the road and nearly overlap the pavement so they are a hazard to cyclists, pedestrians and the many schoolchildren who use this crossing on the way to and from the numerous local schools. Also, as a parent I am horrified to think that if this were to become the site for the South London Waste Plan, the volume of waste would increase since the location of this particular Waste Transfer Station is next to a children's playing field and playground, opposite a school and close to numerous other schools in the area. I think any parent or local resident would feel very strongly about not wanting to have an incinerator or other stepped-up waste disposal facility so close to where local children play and live. I appreciate that there are bound to be pros and cons for each of the proposed sites, but I just wanted to make the point that the Villiers Road site is right at the heart of a residential area with the routes to it struggling to cope with the existing volume of traffic. While I applaud any way of improving waste disposal or recycling, I think it is vital to weigh up the cost to the local area and surrounding environment when settling on a site. Officer's Initial Comment: The points raised are noted. The London Plan and the policies being proposed require existing waste management sites to be retained and where possible improved. However, only development proposals in accordance with the proposed policies would be supported. Consultee ID: 347299 Full Name: Mr Richard Hunt Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 22 of 142 Kingston Consultee ID: 347299 Full Name: Mr Richard Hunt Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL65 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: We also feel that the Chessington Industrial Estate site is too close to primary schools, a major park and a children's centre and would greatly increase the traffic in the surrounding residential roads which are already overcrowded Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6. Further assessment of traffic impacts is required to assess these concerns. Consultee ID: 322912 Full Name: Mrs Charlotte Watson Organisation: Castle Hill Primary School Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL7 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: We feel that the Chessington Industrial Estate site is too close to primary schools and a children's centre and would greatly increase the traffic in the surrounding residential roads which are already overcrowded Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6.
Consultee ID: 349771 Full Name: Dr Emma Whicher Organisation: Page 115 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL88 Is Site Suitable? Site Number: Site comment: I am extremely concerned that the Villiers Rd waste site is being proposed as an incinerator site. The site is opposite a school and there could be a significant health impact on the children there. Secondly at weekends there are huge volumes of cars entering the site and causing traffic jams on an already busy road. In addition this is a highly residential area and incineration of rubbish could increase respiratory problems of residents in the area. Officer's Initial Comment: Noted objection over use of site for incineration on air quality pollution and health grounds, incompatibility with residential and school uses nearby, traffic volumes and congestion Consultee ID: 350602 Full Name: Cllr Penny Shelton Organisation: Royal Borough of Kingston-upon-Thames Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 23 of 142 Kingston Agenda Item 3 Consultee ID: 350602 Full Name: Cllr Penny Shelton Organisation: Royal Borough of Kingston-upon-Thames Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL96 Is Site Suitable? Site Number: Site comment: I am glad to see that proximity to residents, to nature conservation areas, flood risk and traffic impacts are important policy issues in site selection for the future of the South London Waste Plan. This is absolutely imperative. Site number 6 is virtually in the town centre of Kingston, amidst many narrow, older roads that are already suffering from severe traffic congestion, homes that are being shaken to bits, pollution and HGVs flouting lorry bans and ignoring London-wide restrictions on hours of use of the roads. These lorries can sometimes being seen driving through our streets at 4 and 5 o'clock in the morning, giving residents no peace. Residents justifiably complain of Kingston's inability to enforce the lorry bans and are upset that at Kingston Town Neighbourhood meeting on 9 September the Police Inspector present said that the police are not responsible for enforcement of lorry bans. RBK seems to be a toothless tiger on the matter as are London Councils. Site No 6 is also cldse to/adjoining the Hogsmill Valley where Metropolitan Open Land is not currently available as a recreational area for Kingston's communities as it should be, so there are no opportunities for public enjoyment of the land, as there is along the Wandle in Merton. Thames Water make some use of the area as filter beds etc but have been the source of very unwelcome foul odours in hot Summers. As a Thames tributary the Hogsmill attracts a variety of wildlife including bats and some more shy birds and wildlife - it would be good to see water voles there as well and have the whole site for community enjoyment. It is very close to two primary schools whose catchment area includes Kingston's most deprived areas. The very presence of the Villiers Road site right up to Hogsmill's South bank is denying the people of Kingston a great opportunity for recreation. The SL Waste consultation is a chance to reduce, but not to stop, the presence of waste and recycling activities at \Iilliers Road, to reduce the impact on the town centre and to reprovide in areas where there is already a good infrastructure with more appropriate access. There will be no relief for residents local to Villiers Road if Page 116 there is no opening on to the Kingston Road further towards the Borough boundary as set out in the recent Local Development Framework consultation. It is not that I think there should be no recycling opportunities at Villiers Road (No 6) but I do think that is is a golden opportunity to get heavy vehicles onto the A3 and other major and to use sites 47, 352 or 353 for the heavy lorries. I also want us to have the new incinerator/energy creation plants that will result in us consuming our own waste to cut landfill. I fully realise that sending Heavy lorries to sites like Nos 47, 352 and 353 will not be popular around these sites but the South London Waste Plans are a golden opportunity to do good by everyone in the Borough and where presence and activity will disturb fewer lives. The hectares available in 352 and 353 are massive in comparison to site 6 (and 47) but would enable less unobtrusive activity. Officer's Initial Comment: Noted support for inclusion of site selection criteria including proximity to residents, to nature conservation areas, flood risk and traffic impacts. Concern over nature conservation, ecology, hours of operation of HGVs in residential areas and public access to Hogsmill and wishes to see a reduction not an intensification in use of Villiers Road Consultee ID: 354369 Full Name: Mrs. Aniela Gayyum Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD109 Is Site Suitable? Site Number: Site 6: Villiers Road Waste Transfer Station Site comment: this seems the most suitable site out of all the ones proposed in Kingston because there already exists a waste facility on that site. It would make more sense - economically and otherwise to adapt or develop that site into what is required. Officer's Initial Comment: Noted - preference for this existing site Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 24 of 142 Kingston Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD120 Is Site Suitable? Site Number: Site 6: Villiers Road Waste Transfer Station Site comment: Site 6 borders the River Hogsmill and activities at the site should not impact on the river environment, particularly by increasing ambient levels of light, heat, noise or litter. Officer's Initial Comment: Noted - possible impact on River environment and habitat including light, heat, noise and litter are matters of acknowledged importance which require further consideration Consultee ID: 349370 Full Name: Mrs Sharon Fletcher Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD28 Is Site Suitable? Site Number: Site 6: Villiers Road Waste Transfer Station Site comment: Villiers Avenue is in a high density residential area. The access to the site would cause a serious amount of disruption as this is already an issue, adding additional use will make this worse. There are several schools close to the site, to increase traffic to the area would put more of the children at risk from traffic, including many who use this as a cycle route, in addition many adult cyclists use the route to access Kingston town centre. Putting anything that would be remotely classified as toxic or anything that involves burning would make no sense and would impact the local residents and the schools. Officer's Initial Comment: Noted - traffic issues, air quality and possible incompatibility with nearby land use activities are matters of acknowledged importance which
require further consideration. Page 117 Consultee ID: 349370 Full Name: Mrs Sharon Fletcher Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD29 Is Site Suitable? Site Number: Site 6: Villiers Road Waste Transfer Station Site comment: Located in a residential area, makes it unsuitable. Many children and adults use this as a route from Kingston to Surbiton & Tolworth. There are schools in the area and many children use Villiers Avenue in the mornings and afternoon, any increase in traffic would add risk to the children's travel. also many adults use this route as well. The traffic in the areas is already subject to much congestion, any increase in traffic will make this worse. Any burning or additional toxic waste you would add much risk in a residential area and close to schools. Officer's Initial Comment: Noted - traffic issues, air quality and possible incompatibility with nearby land use activities are matters of acknowledged importance which require further consideration. Consultee ID: 327319 Full Name: Mr Roman Schwitter Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD32 Is Site Suitable? Site Number: Site 6: Villiers Road Waste Transfer Station Site comment: To propose to build a waste incinerator in the middle of a residential area is devoid of any logic and common sense, considering that many other sites allocated in industrial areas and would not infringe the quality of life of residents living in the south of London. Agenda Item 3 Officer's Initial Comment: Noted - preference for other sites allocated in industrial areas. Traffic issues, air quality and possible incompatibility with nearby land use activities are matters of acknowledged importance which require further consideration. Consultee ID: 349864 Full Name: P Maskell Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 25 of 142 Kingston Agenda Item 3 Consultee ID: 349864 Full Name: P Maskell Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD36 Is Site Suitable? Site Number: Site 6: Villiers Road Waste Transfer Station Site comment: I b believe that this could be too near to the centre of Kingston to be practical on a large scale as is required for the plan. There would certainly be traffic problems. Officer's Initial Comment: Noted - Traffic issues and possible incompatibility with nearby land use activities are matters of acknowledged importance which require further consideration. Consultee ID: 322794 Full Name: Mr John Harrison Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD6 Is Site Suitable? Site Number: Site 6 Site comment: Site 6 (Villiers Road) is located in a residential area and my primary concern, as a home owner in a recssion with already falling property prices, is that building a waste treatment facility here will have a detrimental affect on the value of houses in the area. On further investigation I believe the site is also unsuitable for a number of reasons: current transport infrastructure - Villiers Road is a busy residential road with many traffic calming measures such as speed bumps and mini-roundabouts on the nearby roads. This would make it unsuitable for numerous heavy waste wagons to be continually using these routes as they converge from or diverge to, their various collection rounds around the borough. It would also cost the highways more in road repairs as those speed bumps Page 118 and mini-roundbaouts aren't designed to be driven over constantly, 6 days a week, by large waste wagons. Lots of cars are parked on both sides of Villiers Road large wagons travelling down here will damage them (grazed wings, broken wing mirrors) and residents will not hesitate to go after the council straight away for compensation. At the end of Chapel Mill Road there is also a Post Office depot that is a busy hub for mail rounds this would add to congestion There is a primary school located almost opposite the exit to the proposed. School drop off and collection times and lots of children in the vicinty would not mix well with large wagons transporting waste! This is an accident waiting to happen - if a waste wagon hits a child!!! Flooding - according to the EAs "what's in my back yard site" the Hogsmill is a potential flood risk. Flooding from the Hogsmill could cause the site to be inaccessible there is also the subsequent problems of waste entering the water course as well. With the Villiers Road site already being a waste transfer station you can actually follow a "trail of breadcrumbs" to it! Through nobody's fault litter/waste does often come off the wagons and provides an unsightly trail down Villiers Road to the existing site. Sites 351, 352 and 353 appear to better sites for the waste management facility; the facility would be potentially constructed in area that is already used to light / medium industry transport infrastrcuture is good - it doesn't involved the final converging / initial diverging of waste wagons coming to and from their rounds into a residential area. therw is a service road that gives access to the site (Jubilee Way) which has no surrounding residential areas in the immediate vicinity. Jubilee Way is also accesible off a dual carriage way (A240) that could support the size of wagons required for waste disposal rounds. Alterations to the road layouts etc. could be made much more easily here than on Villiers Road. The A240 is also on a junction with the A3 - again this road would be capbale of handling the numbers of waste wagons and would, as it is a large roundabout, be suitable as a dispersal point for the wagons to head off to or return from their rounds. Officer's Initial Comment: Disagree. The Plan cannot take account of supposed changes in residential property values. Agree - traffic including infrastructure considerations and access to road network are important matters which require further evidence and evaluation. Consultee ID: 354343 Full Name: Mr Chris Walker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD95 Is Site Suitable? Site Number: Site 6: Villiers Road Waste Transfer Station Site comment: This is a flawed question as the specific use and technology for any of these sites needs to be part of any consideration. Officer's Initial Comment: Noted - concern that consultation doesn’t include information about specific use and technology . Further information on type of proposal coming forward at next stage of plan will be available where this is clear.
26 November 2009 Page 26 of 142 Kingston Consultee ID: 350729 Full Name: Mr Stewart Keating Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL124 Is Site Suitable? Site Number: Site 6, 46, 351, 352, 353 Site comment: Site 6, 46, 351, 352, 353 are all surrounded by residential/light commercial properties. None has adequate access/infrastructure roads for its volume of heavy vehicles. Site 6 could avoid this if the Hogsmill River were covered and carried waste transport lorries. Officer's Initial Comment: Noted. Opposed to sites on access and infrastructure grounds and incompatibility with surrounding uses. Proposed alternative access to site 6 over Hogsmill. Consultee ID: 350903 Full Name: Ms Alice Rutt Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL132 Is Site Suitable? Site Number: Site 6: Villiers Road, Althestan Road Site comment: Site 6 - Villiers Road is unsuitable because: Too residential Surrounding roads unsuitable Kingston roads already congested Site too small Site close to schools and playground Officer's Initial Comment: Noted - concerns over road capacity, traffic congestion and compatibility with adjacent land uses which are matters of acknowledged importance Consultee ID: 354060 Full Name: Ms Janice Graham Organisation: Agent ID: Agent Name: Agent Organisation: Page 119 Comment ID: PSPSL145 Is Site Suitable? Site Number: Site 6: Villiers Road, Althestan Road Site comment: Villiers Road would not be a suitable site, as it is very near King Althestan School and having more traffic on this road may lead to more traffic accidents with the school children and members of the public. Officer's Initial Comment: Noted concern over proximity to school and to traffic safety Consultee ID: 354071 Full Name: Dr Christopher Hamilton Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 27 of 142 Kingston Agenda Item 3 Consultee ID: 354071 Full Name: Dr Christopher Hamilton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL158 Is Site Suitable? Site Number: Site 6: Villiers Road, Althestan Road Site comment: I believe this site to be unsuitable for at least the following reasons: - in general, the waste disposal site in Villiers Road already generates a great deal of noise and heavy traffic, and these should not be increased in an area which has a lots of dense residential housing; - there are at least two schools in close proximity to the site and children and parents going to and from these schools are already exposed to a very heavy traffic, including traffic to and from the existing site. In addition, the waste disposal juggernauts servicing the site emit extremely unpleasant odours and generate a great deal of noise in passing; - Kingston University is also immediately next to the proposed site - and, indeed, to the site that already exists. It can hardly be claimed that the students have a very peaceful environment in which to study at the moment, given the location of the university, and any development of the waste disposal site could only increase this burden. (I write, incidentally, as a teacher at another university in the London area and feel very strongly that, if, as the government wishes, more pupils from school go on to higher education, they should be provided with the best possible conditions in which they can study effectively and efficiently.) - there is already a sewage works in the immediate area of the proposed site, and there is a long-standing and, as yet, unresolved problem concenring powerfu odours that are not infrequently emitted by these works: to add to the waste disposal facilities in this area without even solving this problem simply adds to the burden of local people; - the crematorium right next to the proposed site already generates traffic and air pollution which should not be increased through the locating of increased waste disposal facilities in the local area; the same can be said with respect to the large postal sorting office in Villers Road, right next to the existing site; - Kingston already has a large hospital not far from the proposed site, and this puts burdens on the local road network in all the usual ways (noise and air pollution etc.); - there is at least one park/recreation area close to the proposed site where children play; - Villers road is narrow and very heavily Page 120 congested as it is at the moment: this could only be worsened by further developing the waste disposal facilities in the area. Officer's Initial Comment: Noted. Opposed on grounds of noise, traffic levels, road capacity, compatibility with adjoining uses, air quality and pollution. Consultee ID: 354117 Full Name: Ms Anne Middlemiss Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL166 Is Site Suitable? Site Number: Site 6: Villiers Road, Althestan Road Site comment: Site 6 is not far from where I live, and has recently been vastly improved as regards to noise pollution by changing the workflow procedures. As long as it did not regress, it could be a suitable site. Have doubts though about the impact of more heavy lorries. Officer's Initial Comment: Noted. Some support for site following noise mediation measures but concern over HGVs. Consultee ID: 329112 Full Name: Mr Robert Baker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL173 Is Site Suitable? Site Number: Site 6: Villiers Road, Althestan Road Site comment: The Villiers Road site is in a residential area on a busy road that often gets congested. Often the queue for the tip spills out on to Villiers Road which causes traffic mayhem!! The new site should have better access and should be away from a busy residential area! Officer's Initial Comment: Noted objection on traffic congestion and proximity to residential grounds Consultee ID: 354092 Full Name: Mrs Margaret Igoe Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 28 of 142 Kingston Consultee ID: 354092 Full Name: Mrs Margaret Igoe Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL175 Is Site Suitable? Site Number: Site 6: Villiers Road, Althestan Road Site comment: Site 6 Villiers Road Athelstan Road The site is particularly unsuitable because 1. There are two primary schools within metres of the site. 2. Athelstan park with a children's play is adjacent to the site. 3. The sewage plant is nearby and from time to time emits unpleasant odours. 4. The Crematorium is also nearby. Furthermore, Villiers Road is already heavily congested with large trucks transporting waste to the existing site and vehicles to and from the Post Office sorting depot. Officer's Initial Comment: Noted. Objection on grounds of adjacent uses (school and children's play area, crematorium), smells from adjacent sewage works,) and traffic congestion Consultee ID: 355091 Full Name: Mr Martin Radcliffe Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL224 Is Site Suitable? Site Number: Site 6: Villiers Road, Althestan Road Site comment: It already exists and has scope for improvement and expansion without major disruption to residents. Officer's Initial Comment: Noted. Support Consultee ID: 355118 Full Name: ms carole hickmott Organisation: Page 121 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL231 Is Site Suitable? Site Number: Site 6 and 46 Site comment: The existing site No. 6 King Athelstan is the best place as this already has been developed and provides the basis for extended use. Site 46 is the next best option for the actual site area is 'out of the way' but access is close to a main road. However, the big negative for this site is that it is near to a newly developed large school. All access would have to be past this school entrance as the surrounding roads are too small for lorries. The other areas in Chessington are not suitable as access is also limited and although they on industrial estate they are also near built up residential areas. The main road (Tolworth/Tolworth roundabout) servicing the entrances to these sites is already very congested and suffers from high pollution rates so more heavy lorries/traffic would not be welcome. Officer's Initial Comment: Noted support but concern over access traffic safety pollution and congestion Consultee ID: 355171 Full Name: Mrs E Gray E.B.E Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL234 Is Site Suitable? Site Number: Site 6: Villiers Road, Althestan Road Site comment: Villiers Road does a good job
Officer's Initial Comment: Noted. Support for Villiers Road site Agenda Item 3 Consultee ID: 324861 Full Name: Ms K Mayer Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 29 of 142 Kingston Agenda Item 3 Consultee ID: 324861 Full Name: Ms K Mayer Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL25 Is Site Suitable? Site Number: Site 6: Villiers Road, Athelstan Road Site comment: I think the site at Villiers Road is too close to the town centre. Such sites, if they are necessary, should be located in more industrialized areas such as Tolworth. Officer's Initial Comment: The points raised are noted. The London Plan and the policies being proposed require existing waste management sites to be retained and where possible improved. However, only development proposals in accordance with the proposed policies would be supported. Consultee ID: 349370 Full Name: Mrs Sharon Fletcher Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL80 Is Site Suitable? Site Number: Site 6: Villiers Road, Althestan Road Site comment: The site is in a residential area, close to schools and the road is subject to heavy use already, additional use will make it unsuitable for school children who use the road on foot and bike and those accessing Kingston Town centre. Burning of toxic waste would have an equally negative impact. It is totally unsuitable for further development. Noted - traffic, emissions and air quality and compatibility with adjacent uses are matters of acknowledged importance which require further
Officer's Initial Comment: Page 122 consideration. More information on facilities proposed will be set out in next stage where this is known Consultee ID: 349705 Full Name: Mrs Katherine Ruff Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL82 Is Site Suitable? Site Number: Site 6: Villiers Road, Althestan Road Site comment: I think that further development of this site would be impractical, the site which is virtually in the centre of Kingston has already had impact on traffic in the area. At times Villiers Road is virtually at a standstill increasing traffic in this already congested area could only extend the times when this is the case. The whole idea of this type of waste facility is to decrease our impact on the environment how much of this positive benefit will be lost to the increased use of fuel from engines idling and increased airborne pollution. There are locally two primary schools and a park increased traffic would lead to greater pollution both noise and air. This site is in a predominantly residential area and impact on the quality of life of local residents MUST be taken into consideration. Officer's Initial Comment: Noted - traffic, emissions and air quality, quality of life and compatibility with adjacent uses are matters of acknowledged importance which require further consideration. More information on facilities proposed will be set out in next stage where this is known Consultee ID: 350556 Full Name: Mr Karol Jakubczyk Organisation: Epsom & Ewell Borough Council Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 30 of 142 Kingston Consultee ID: 350556 Full Name: Mr Karol Jakubczyk Organisation: Epsom & Ewell Borough Council Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD90 Is Site Suitable? Site Number: 9, 46, 47, 351, 352, 353, 491 and 702 Site comment: General Comments The Council notes the approach taken by the Joint Waste DPD in relation to the selection of potential sites. We note that these sites are broadly acceptable for consideration as waste management facilities in principle. Namely, it is considered generally appropriate that theConsultation Documentidentify active employment areas and/ or derelict/ vacant located in close proximity to the strategic highway network. However,the Councilnotes that theConsultation Documentfails to identify the types of waste management facilities (whether strategic, householder or otherwise) that will be considered for the potential sites. This is disappointing as it restricts meaningful discussion of site suitability. For example, Site 491 may be considered an appropriate location, in principle,for a householder waste management facilityas it is surroundedby large residential hinterland, which would allow short (potentially linked) trips for local residents. However, such a locationcould beinappropriate for a strategic facility, withassociated frequent heavy vehicle movements through predominantly residential areas. In conclusion, it is the Council's view that the Consultation Document would have benefited by identifying a basic range of waste uses that could be considered (at a future date) for each potential site. Comments on Specific Sites The Council draws the Joint Waste Authorities' attention to the Epsom & Ewell Local Development Framework and Community Strategy, with specific reference to the Epsom Town Centre Vision and the emerging Town Centre Area Action Plan (Plan E). These statutory documents seek to 'regenerate' Epsom Town Centre's commercial vitality adn viability. A key aspect of our approach is addressing traffic congestion andvolumes along the A24 through the town centre. The Council is seeking to make the town centre a pleasant environment for shoppers, visitors and businesses. We are seeking to remove unecessary heavy vehicle movements form the town centre by utilising strategic signage, physical changes to the highway and by working in partnership (through the Surrey Freight Quality Partnership) with operators. The removal of heavy vehicles transporting waste materials (whether domestic or commercial) has been identified as aspecific objective - this includes the movement of our own waste materials. The Joint Waste Authoritiesneed to be aware that access to the above referenced sites along the A24 via Epsom Page 123 Town Centre will be actively discouraged. The Council hopes that an active partnership arrangement can be agreed with the Joint Waste Authorities to ensure that all of our objectives can be met. Site 47 The Council notes that thislocation is in close proximity to acouple of sites that have either been subject tositeallocation(for a mixed use commerical and residential scheme) or a speculative planning application(for a hotel). The latter proposal is immediately adjacent to the potential site. The Council suggests that the type of waste management facility proposed for this site will need careful consideration in order to ensure that it is compatible with the uses that will regenerate thewider site area (to the south of the A3 Tolworth jucntion). The Council also highlights the accessproblems associated with the development of this site. Future access arrangements onto the site, particularly for vehicular traffic travelling to the site from the A3 junction at Tolworth are unclear. Our particular concern is thatsite traffic coming from the A3 junction will be forced to travel further south, into Epsom & Ewell Borough, before being able to gain access onto the site. If this site is to be redeveloped as a potnetial waste site it should be doen so as part of a more comprehensive approach that would achieve better integration with transport networks including the nearby railway station. We suggest that any scheme to access and redevelop this site should be considered in association with the comprehensive redevelopment of the wider (former MoD) land, located to the north. This could also provide an opportunity (at a future date) to consider optiosn for the generation of energy from waste, such as CHP, which could serve the wider site and community. Sites 351, 352 and 353 The Council is acutely aware that it currently has limited opportunities for new employment sites within it's own borough boundary. We understand that the London Borough of Kingston faces similar constraints in relation to its potential future sources of employment land supply. Consequently, the future DPD will need to take great care to ensure that future waste facility options do not prejudice the ability to deliver sustainable economic growth. This particular cluster provides a accessible future employment opportunity, which if developed to a high density could make a considerable contribution towards reducing unsustainable commuting patterns in both Kingston and Epsom & Ewell Borough. Agenda Item 3 Officer's Initial Comment: Noted - Epsom and Ewell BC as adjoining LPA express concerns about lack of information on types of waste facilities proposed and about possible traffic implications for roads in adjoining borough. Supports a comprehensive approach towards integration of suitable waste facilities, CHP etc but not a strategic facility on site 491if resulting in frequent heavy vehicle movements. Consultee ID: 350162 Full Name: Mrs Caroline Constable Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 31 of 142 Kingston Agenda Item 3 Consultee ID: 350162 Full Name: Mrs Caroline Constable Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD55 Is Site Suitable? Site Number: Site 45: Leatherhead Road, Chessington, Barwell Business Park Site comment: The school is a massive constraint to the Coal Depot it is not suitable to have that kind of facility near a school and on what is ultimately a residential area. Also Silvergldae Business park, is on a terribly busy road as it is and to increase the traffic on the road is irresponsible especially as the traffic lights are a black sport for accidents. Officer's Initial Comment: Noted - traffic, residential amenity and possible incompatibility with nearby land use activities are matters of acknowledged importance which require further consideration. Consultee ID: 343812 Full Name: Mr Nigel Randall Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD15 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal Depot adjacent to Barwell Business Park Site comment: Increased traffic would be unacceptable Noted - traffic is an important consideration which requires further investigation.
Officer's Initial Comment: Page 124 Consultee ID: 344294 Full Name: Mr Andrew Withers Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD20 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal Depot adjacent to Barwell Business Park Site comment: 1. The A24 and Garrison Lane are already congested. It is a major route to / from the M25 and Kingston. Garrison Lane is congested by parked cars in the 1950s estate, by traffic to/from the railway station, the coal depot, golf course and school. It is on a frequent bus route (5-10 mins) and the buses already have difficulty. 2. It is close to an airfield at Malden Rushett. The approach is directly over the proposed site. 3. It is close to a landmark new school - Chessington Community College. It is also close to Ellington Primary School. Any form of waste disposal is undesirable where children are concerned. 4. It is close to the Chessington Garden Centre - plants may be affected, visitors may be put off - business may suffer with knock-on effects to the local economy. 5. It is close to Chessington World of Adventures - visitors may be put off - business may suffer with knock-on effects to the regional economy. 6. It is close to the boundary of Horton Country Park - waste disposal is undesirable in this context. 7. It is close to the boundary with Surrey local authorities - it is unacceptable to place a disposal unit for four London boroughs right up against another authority's boundaries. Officer's Initial Comment: Agree- traffic, health and environmental considerations are important factors which require further investigation. Disagree - No evidence of adverse economic impact is available and proximity to surrey county Boundary is not in itself a material consideration. Noted - comments relating to airfield Consultee ID: 349756 Full Name: Mrs Pam Sinfield Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 32 of 142 Kingston Consultee ID: 349756 Full Name: Mrs Pam Sinfield Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD34 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal Depot adjacent to Barwell Business Park Site comment: As a parent of children who attend Chessington Community College I am concerned at the close proximity of the proposed site to the college, it does not seem very healthy to have a facility so close to the school, and also Elllingham School which is very close by. This is also on a very busy bus route, with buses that pass approximately every 10 minutes, so there could be congestion problems and also on the main road which leads to the M25, past Chessington World of Adventures, this is a very busy stretch of road which suffers from a lot of traffic congestion already. Officer's Initial Comment: Noted - traffic issues and possible incompatibility with nearby land use activities are matters of acknowledged importance which require further consideration. Consultee ID: 322679 Full Name: Mr. ken Giles Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD5 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal Depot adjacent to Barwell Business Park Site comment: The traffic in this area is already bad enough due to Chessington world of adventures and the development of this site would only make this worse, probably grinding it to a halt and therefore increasing the amount of pollution. Also i feel that putting a wast management site so close to a School is a terrible idea.
Chessington community college would be incredibly close, in fact the school children would be walking past the location. Does the Borough of Kingston upon Page 125 Thames really not care about the health, and safety of children going to school? Or may be you are hoping that this will wipe out a few of them and therefore reduce the population thereby reducing the amount of wast that is produced in this area? If that is the case that is indeed some clever planing! Also a wast management site would inevitably increase the number of Rats in the area which I'm sure the School would be most pleased about, as would the industrial estate. Officer's Initial Comment: Noted - traffic and air quality/emissions are matters of acknowledged importance which require further consideration. Disagree - comments about young person deaths and rodent infestations. Consultee ID: 350162 Full Name: Mrs Caroline Constable Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD52 Is Site Suitable? Site Number: 46 Site comment: The site (Coal depot) is directly opposite a school, station (where plenty of commuters and tourists for Chessington World of Adventure are always around) and bus stops it wouldn't help road safety, and the noise that would come from the site would affect the local school and those who will be living 100 yards or less from the site. The roads leading into the site are a local road which is used as a rat run as it is and are bad enough with the buses and rubbish trucks and the main road that leads in is horrendous in the rush hour as well especially in the holidays when CWOA is open. Officer's Initial Comment: Noted - traffic and noise are matters of acknowledged importance which require further consideration. Agenda Item 3 Consultee ID: 350162 Full Name: Mrs Caroline Constable Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 33 of 142 Kingston Agenda Item 3 Consultee ID: 350162 Full Name: Mrs Caroline Constable Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD54 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal Depot adjacent to Barwell Business Park Site comment: Site 46 is opposite a school and has major public transport links next to it. There are large numbers of people, particularly children around and it will not be safe for them in the area. The road is not suitable for the number of trucks that would come down and there would be congestion with the buses that can be difficult enough when you are in a car. A new crossing has been put in up the way from the depot and the station however I have never witnessed anyone use it in the year or so its been in as they all cross outside the station. The area is to residential of this kind of facility and it would cause damage to property prices in an already sensitive market. Officer's Initial Comment: Noted - traffic, residential amenity and possible incompatibility with nearby land use activities are matters of acknowledged importance which require further consideration. Disagree - possible affects on residential prices are not material to a DPD Consultee ID: 350213 Full Name: MRS FAITH ALLEN Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD57 Is Site Suitable? Site Number: 46
Site comment: WHILE THIS SITE WOULD BE SUITABLE FOR AND ENCLOSED RECYCLING FACILITY, THE ROAD'S TO THE SITE ARE ALREADY VERY BUSY AND Page 126 THE BRIDGE THAT WILL NEED TO BE CROSSED TO GET TO THIS SITE NEEDS TO BE UPGRADED FOR HEAVY USE. AN OPEN WASTE MANAGEMENT SITE IS NOT SUITABLE FOR THIS SITE AS IT IS ADJACENT TO A LARGE COMMUNITY SCHOOL, HOUSING AND RAILWAY ENTRANCE THAT BRINGS LOT'S OF PEOPLE TO WORLD OF ADVENTURES. MANY TOURIST'S WOULD BE PUT OFF GOING TO THIS VENUE IF THEY HAD TO WALK OR WAIT FOR A BUS OUTSIDE AN OPEN WASTE SITE. Officer's Initial Comment: Noted - support for possible enclosed recycling facility only (no open use) and concern over traffic and infrastructure. Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD75 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal Depot adjacent to Barwell Business Park Site comment: Sites I consider suitable are existing disposal sites not too close to residential areas. Sites not numbered I consider unsuitable, particularly site 127 by the Wandle river. Officer's Initial Comment: Noted. Consultee ID: 350873 Full Name: Zarayna G Pradyer Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 34 of 142 Kingston Consultee ID: 350873 Full Name: Zarayna G Pradyer Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL128 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal depot adjacent to Barwell Business Park Site comment: Its entrance greets Chessington South Station and hence those on the way to Chessington world of Adventures and ramblers exploring the rural walks nearby The area is still managing to be sylvan and friendly towards wildlife, adjacent to a golf course and railway embankments. The traffic is already a problem in this area School and college in the vicinity would not be enhanced by the proposed facility. We moved specifically to one of the high points in the borough, because the air is cleaner - my mother has impaired lung function and increased pollution would not be beneficial. Site 46 would be better served as a garden centre/ nursery, outdoor sports facility. Officer's Initial Comment: Noted. Opposed to site 46 as incompatible with area and should be used for alternative purposes. Concerns over air quality and pollution. Consultee ID: 354058 Full Name: R A Austin Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL141 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal depot adjacent to Barwell Business Park Site comment: Location near to rail head for despatch of arisings rather than use road transport.
Officer's Initial Comment: Noted. Support for site near to rail head for dispatch of waste arisings Page 127 Consultee ID: 354064 Full Name: Mrs J Davis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL151 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal depot adjacent to Barwell Business Park Site comment: Would appear a good idea Officer's Initial Comment: Noted support Consultee ID: 354117 Full Name: Ms Anne Middlemiss Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL167 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal depot adjacent to Barwell Business Park Site comment: Site 46 is a no-no, as that area has too much traffic already. Officer's Initial Comment: Noted. Objection on traffic grounds. Consultee ID: 354359 Full Name: Dr Kim Sloan Organisation: Agenda Item 3 Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 35 of 142 Kingston Agenda Item 3 Consultee ID: 354359 Full Name: Dr Kim Sloan Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL183 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal depot adjacent to Barwell Business Park Site comment: We have lived in Chessington for nearly fifty years and are active members of our local residents' association (St Mary's, Lees Close, etc at bottom of Chessington South) but the first we heard of these plans was a leaflet and map dated 'September 2009' dropped through the door last week. The free papers where you have published your consultation documents are no longer delivered here. This is probably why no one else in the area has commented on this particular proposed site. I find it very difficult in the short time available to discover exactly what type of waste management facilities you plan for each of these sites - the only type anyone knows locally is the dump facility at Villiers Road, for which you have to queue for a long time on weekends to use which must cause problems for the local residents. We have no idea what type of noise or smell might emanate from the site, apart from the presumed traffic problems. If Site 46 on the old coal depot required lorries and deliveries and queues it would create chaos. The only approach we are aware of is the one the coal lorries have used - they are infrequent and have never caused a problem. But within 100 yards of that entrance are the following: Chessington Community College entrance, also used by people attending sports facilties when the school is closed, and a Korean church whose attendees park on Garrison Lane on Saturday mornings a golf course and social club parking for the hundreds of local residents in the ajacent blocks of flats and any communter using the Chessington South Railway station directly opposite which also has a take away and shop its a terminal for many local communters who drive there and are dropped off for the half hour trains and for the thousands who use the train to get to Chessington World of Adventures open most of the year two bus stops which do not have
lanes for the buses to pull over in a two way road down which buses and cars can only travel in one direction at a time because cars are parked on the other Page 128 side and there isn't room for cars to pass in the section leading to the Leatherhead Road, large lorries park when the drivers are eating in the cafe on the Leatherhead Road, as they can't park on the Road itself so park on Garrison Lane the entire access road, Garrison Lane, is humped! Never mind the foot traffic to and from the school and train station and bus stops and World of Adventures and hundreds of residents in the flats around the area and the dangers that this traffic would creat to these pedestrians, many of whom are children as there is also a primary school behind CCC. Officer's Initial Comment: Noted. Concern over lack of detail of proposed waste facilities and likely traffic congestion and environmental disruption. Information on proposed future activates on selected sites will be provided at final stage of plan when this is clear. Consultee ID: 354694 Full Name: Mr Bernard P Meade Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL215 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal depot adjacent to Barwell Business Park Site comment: Site 46 should be the only site for Kingston, all other sites are in built up areas. Officer's Initial Comment: Noted preference for site over others in Kingston Consultee ID: 355091 Full Name: Mr Martin Radcliffe Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL226 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal depot adjacent to Barwell Business Park Site comment: Unsuitable due to proximity to housing and access roads (Garrison Lane) are too narrow, also it is too close to the College in Garrison Road and would be a hazard to pupils. Officer's Initial Comment: Noted Object on traffic access and proximity to residential and educational land uses Consultee ID: 355171 Full Name: Mrs E Gray E.B.E Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 36 of 142 Kingston Consultee ID: 355171 Full Name: Mrs E Gray E.B.E Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL236 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal depot adjacent to Barwell Business Park Site comment: Site 46 Coal Depot would serve that side of the Royal Borough of Kingston Officer's Initial Comment: Noted support for site Consultee ID: 355209 Full Name: Mr. Leonard sooner Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL250 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal depot adjacent to Barwell Business Park Site comment: This is the most westerly of suggested sites and as the prevailing winds throughout the year are from the west any airborne pollution will be carried over a vast urban population The local road system would not support the heavy truck volume. therefore rat runs would develop through the Copt Guilders estate adding danger and pollution to many thousands of residents Officer's Initial Comment: Noted concern over air quality and pollution and traffic congestion and safety Consultee ID: 349358 Full Name: Miss Tanya Farbrother Organisation: Agent ID: Agent Name: Agent Organisation: Page 129 Comment ID: PSPSL79 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal depot adjacent to Barwell Business Park Site comment: If one of the sites has to be in the Chessington area (yet again, we poor relations of the Borough have 3 sites on the list out of 4, obviously the council thinks we'll stand for what the wealthier areas won't - wrong!) then this would be the least bad option in my opinion as it is close to fairly flat, open farmland to the south of the site, which means that any fumes or odours could disperse more easily. Officer's Initial Comment: Noted - air quality and emissions are important matters which require further consideration. Consultee ID: 349705 Full Name: Mrs Katherine Ruff Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL81 Is Site Suitable? Site Number: Site 46: Leatherhead Road, Chessington, Coal depot adjacent to Barwell Business Park Site comment: The proposed site at the coal depot is I feel unsuitable for various reasons the first being that access to the site would have to be along the already congested Leatherhead Road (Garrison Lane being too narrow to take a continuous stream of heavy vehicles). Local business such as the Golf Course and the World of Adventures could be impacted by peoples negative perceptions of spending their leisure time so close to what many will see as a dump or potentially hazardous plant. Also the development of this site could severly affect the newly rebuilt Chessisngton Community College, however lovely their 27,000,000 Agenda Item 3 building may be, parents will be reluctant to send their children to a school where there is a constant stream of heavy traffic passing outside and where a recycling plant (whos nature is yet to be deceided)is virtually accross the road.I feel that the presence of such a site so close to the school will undermine the efforts of the school to improve educational standards and attract students.In addition to the above reasons I feel that the site so close to a large residential area will have a negative impact on the lives of the people who live there, and potentially impact on the value of their homes. Officer's Initial Comment: Noted - traffic, emissions and air quality, quality of life and compatibility with adjacent uses are matters of acknowledged importance which require further consideration. More information on facilities proposed will be set out in next stage where this is known
26 November 2009 Page 37 of 142 Kingston Agenda Item 3 Consultee ID: 349741 Full Name: Christie Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL86 Is Site Suitable? Site Number: 46, 351,352,353, 47 Site comment: 351.352.353, these proposed sites, in an area already surrounded by houses, will add considerably to the traffic and pollution problems in the area. The use o any of the proposed sites would mean that businesses will have to be closed. Not good for jobs. And there would be major access issues. 47, a site here on a busy junction on a very busy road would be a disaster. Already I have been told that the traffic pollution at Tolworth roundabout has broken or is near to breaking, current EU pollution regulations - and a waste site here would increase the traffic exponentially. In any case, after the fiasco regarding the building of the cement works at Tolworth, I do not trust the council to ensure that a developer would stick to the agreed plans. But most importantly, this site is currently used by youth groups. There are precious few of these types of sites available in Kingston, and the proposal is to turn it into a waste disposal site? Not really join-up thinking 46, would seem to be the best site if there has to be one in Kingston. There will still be access issues and the A243 is already a very busy road. But it's interesting that the majority of the 'Kingston' sites are in fact in Chessington. The residents of Chessington are forgotten most of the time when the money's handed out by the council, until of course there's the need for a waste site or other development that nobody in Kingston wants in their backyard, and then it's foisted on Chessington. . Officer's Initial Comment: Noted - support for site 46 subject to access issues and opposition to other sites in Kingston borough on grounds of traffic, pollution, economic disbenefits and preferred alternative uses..
Consultee ID: 354369 Full Name: Mrs. Aniela Gayyum Organisation: Page 130 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD108 Is Site Suitable? Site Number: Site 47: Land at Kingston Road / Jubilee Way junction, Tolworth. Site comment: It is still too close to residential areas and a publicly used Tolworth Broadway. Also the existing traffic congestion around Tolworth roundabout is quite severe, it will only get worse if waste facilities are built on this site. Tolworth roundabout is extensively used as although commute' to Kingston but also because of the A3 lot of traffic also uses a lot to get into London. It is not viable the increased traffic caused and extra pollution is too much. Officer's Initial Comment: Noted - traffic issues, air quality and possible incompatibility with nearby land use activities are matters of acknowledged importance which require further consideration. Consultee ID: 343812 Full Name: Mr Nigel Randall Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD16 Is Site Suitable? Site Number: Site 47: Land at Kingston Road / Jubilee Way junction, Tolworth. Site comment: Location not suitable due to traffic congestion at present Officer's Initial Comment: Noted - traffic is an important consideration which requires further investigation. Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD74 Is Site Suitable? Site Number: Site 47: Land at Kingston Road / Jubilee Way junction, Tolworth. Site comment: Sites I consider suitable are existing disposal sites not too close to residential areas. Sites not numbered I consider unsuitable, particularly site 127 by the Wandle river. Officer's Initial Comment: Noted
26 November 2009 Page 38 of 142 Kingston Consultee ID: 354343 Full Name: Mr Chris Walker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD96 Is Site Suitable? Site Number: Site 47: Land at Kingston Road / Jubilee Way junction, Tolworth. Site comment: Development of new waste facilities should only be a last resort after all waste reduction (and ideally zero waste) strategies have been exhausted and this consultation completely fails to address this fundamental point before leaping to the easier option of burning waste instead. Officer's Initial Comment: Agree -support for aspects of waste plan strategy. Disagree - the Waste Plan is not the Municipal Waste Strategy Consultee ID: 350893 Full Name: B J Woolgar Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL130 Is Site Suitable? Site Number: Jubilee Way Site comment: Jubilee way site, very near a very busy junction of the A3 and bus garage. traffic pollution already heavy, extra traffic and potential fumes from this and whatever heat treatment etc would be a very unwelcome addition to already existing problems. There is a proposal to put a 'green strip' centrally down the Broadway to encourage cyclists and pedestrians plus creating a large waste site a few hundred or so yards away from the main shopping area would certainly cancel out any benefits! Officer's Initial Comment: Noted Concerns relating to pollution/air quality and traffic and capability with adjacent land uses which are matters of acknowledged importance. Consultee ID: 354060 Full Name: Ms Janice Graham Organisation: Page 131 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL146 Is Site Suitable? Site Number: Site 47: Land at Kingston Road / Jubilee Way junction, Tolworth Site comment: This is a very busy junction plus the Tolworth roundabout forcing more traffic into the very dangerous and congested area. Officer's Initial Comment: Noted concern over access to main road network and traffic safety/congestion Consultee ID: 354064 Full Name: Mrs J Davis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL153 Is Site Suitable? Site Number: Site 47: Land at Kingston Road / Jubilee Way junction, Tolworth Site comment: Too near to busy main road. Officer's Initial Comment: Noted. Opposed because of proximity to main road and congestion Consultee ID: 354369 Full Name: mrs Aniela Gayyum Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 39 of 142 Kingston Agenda Item 3 Consultee ID: 354369 Full Name: mrs Aniela Gayyum Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL182 Is Site Suitable? Site Number: Site 47and 6 Site comment: It is still too close to residential areas and a publicly used Tolworth Broadway. Also the existing traffic congestion around Tolworth roundabout is quite severe, it will only get worse if waste facilities are built on this site. Tolworth roundabout is extensively used as although commute' to Kingston but also because of the A3 lot of traffic also uses a lot to get into London. It is not viable the increased traffic caused and extra pollution is too much. The site on Villiers road, where the existing waste facilities are would seem to be a better site to develop or adapt for use. It would make more economic sense and cause the least congestion and disruption to local residents. Officer's Initial Comment: Noted. Objection to Tolworth site due to proximity to residential and shopping area, access and traffic congestion, air quality and pollution. Support for Villiers Road as would cause less congestion and disruption to residents. Consultee ID: 354400 Full Name: Mr Brian Skelton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL185 Is Site Suitable? Site Number: Site 47 and 353,352,351 Site comment: Will cause further traffic congestion on the Ewell by pass. Jubilee way is not large enough to take allot of refuse vehicles. The sites in Chessington Industrial Estate would also cause traffic congestion on the estate's roads which already have a lot of commercial vehicles. Page 132 Officer's Initial Comment: Noted concern over traffic congestion Consultee ID: 354694 Full Name: Mr Bernard P Meade Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL216 Is Site Suitable? Site Number: Site 47: Land at Kingston Road / Jubilee Way junction, Tolworth Site comment: Site 47 will shortly be over developed with housing. Officer's Initial Comment: Noted. Future use to be housing Consultee ID: 355091 Full Name: Mr Martin Radcliffe Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL225 Is Site Suitable? Site Number: Site 47: Land at Kingston Road / Jubilee Way junction, Tolworth Site comment: This site is not near housing, and has direct access onto Kingston Road. If it is to be used I hope somewhere else can be provided for the motorcyclists using it. Officer's Initial Comment: Noted Support Consultee ID: 349358 Full Name: Miss Tanya Farbrother Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL78 Is Site Suitable? Site Number: Site 47: Land at Kingston Road / Jubilee Way junction, Tolworth Site comment: Too close to existing housing, traffic already congested. Officer's Initial Comment: Noted - traffic and compatibility with adjacent uses are matters of acknowledged importance which require further consideration.
26 November 2009 Page 40 of 142 Kingston Consultee ID: 349705 Full Name: Mrs Katherine Ruff Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL83 Is Site Suitable? Site Number: Site 47: Land at Kingston Road / Jubilee Way junction, Tolworth Site comment: Of the sites proposed I feel that this may be the one with the least impact on on local residents. The site is in a slightly more central position within the borough which could reduce the length of journeys to and from the site. The site is situated by a main road in a part of Tolworth that is already quite industrialized and is some way from the residential areas within Tolworth. I appreciate that even with this site there will be increased traffic. If the proposed Tesco development goes ahead this could become a major problem for the area. Also on a negative side how would the development of this site impact on the use of local leisure facilities such as Tolworth Farm Court, Charrington Bowl, and the local recreation and sports grounds along Jubilee way Officer's Initial Comment: Noted support for site development subject to consideration of traffic , deliverability and compatibility with adjacent existing uses Consultee ID: 350585 Full Name: MR Dennis Baker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL95 Is Site Suitable? Site Number: 47 351 352 353 Site comment: The A3 is the highest polluted road in Kingston, when I chose to purchase my house I did it in the knowledge that the A3 fronted my property and the train line run along the rear. Since 1995 a bus depot and a concrete batching plant have appeared on the same site as the station resulting in more pollution and traffic. I feel it would be totally inappropriate to subject residents living along Hook Rise South to further pollution than we already suffer.Kingston council campaigned heavily not to allow Tesco's to build close to the Tolworth roundabout but appear to be doing a U turn regarding sites for their waste strategy. Residents in the South of the Borough already have to cope with the volume of lost lorries and large HGV's in residential roads. We have the added volume of traffic from the Page 133 M25 and accidents regularly bring the entire routes to a standstill. Why don't you look at the North of the Borough where residents do not want a school built. It appears to be total discrimination against those residents living in the south of the borough who are more vulnerable. Hook has the highest number of elderly residents living in Kingston. There are a higher number of disabled children living in Chessington and people on lower incomes tend to live in South of the borough. Officer's Initial Comment: Noted Concerns relating to pollution/air quality and traffic which are matters of acknowledged importance.. Consultee ID: 354369 Full Name: Mrs. Aniela Gayyum Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD107 Is Site Suitable? Site Number: Site 124: Former Government Offices, Hook Rise South, adjoining sites fronting Kingston Road and Tolworth Station. Tolworth Site comment: The site where the former government offices were is not suitable because it lies very close to residential areas and also publicly used Tolworth Broadway. Furthermore, it is very close to the A3 and Tolworth roundabout is already very heavily used, as a through route to Kingston and also to get into London, and is therefore quite congested at certain times. It would not be wise to introduce waste facilities that will put extra strain on the existing roundabout and roads around it.
Officer's Initial Comment: Noted - traffic and amenity are matters of acknowledged importance which require further consideration. Agenda Item 3 Consultee ID: 344294 Full Name: Mr Andrew Withers Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 41 of 142 Kingston Agenda Item 3 Consultee ID: 344294 Full Name: Mr Andrew Withers Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD18 Is Site Suitable? Site Number: Site 126: Benedict Wharf Whole Site Site comment: Any of these sites with rail access has an advantage. Waste can be shipped in from transfer stations avoiding road congestion. Road movements to the transfer stations and rail movements to the waste incinerator site do not have to take place simultaneously - they can both be timed to avoid to avoid peak hours and to minimise inconvenience. Officer's Initial Comment: Noted - rail access can provide distinct advantages where possible to achieve. Consultee ID: 343812 Full Name: Mr Nigel Randall Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD17 Is Site Suitable? Site Number: Site 127: Willow Lane area by Wandle River Site comment: Roads cannot cope with the extra traffic and facility would make working conditions for those who work there unbearable. Existing small waste transfer station causes chaos and pollutes the area. Officer's Initial Comment: Noted - traffic and air quality/emissions are important considerations which requires further investigation.
Consultee ID: 354380 Full Name: MR Mark Rice Organisation: Page 134 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD110 Is Site Suitable? Site Number: 351 and 352 Site comment: This site is well used and occupied business district which sits well with the local residential area. This area employees over a thousand people from the local area. At a time when jobs are scarce, why threaten these businesses with closure? Why run the risk of these companies moving out of the area? This plan should only target existing, disused brown field sites. It is a great opportunity to create jobs where currently none exist. Officer's Initial Comment: Noted. Selection of possible sites is in accordance with London Plan for consultation purposes. Consultee ID: 355258 Full Name: Ms Fung yee Lee Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD118 Is Site Suitable? Site Number: Site 351, 352 and 353: Moor Lane, Chessington. Chessington Industrial Estate Site comment: Site 351 is not suitable because it literally backs on to a primary school (Castle Hill). Also, Moor Lane, is where junior school is located. Within the site of the junior school is a day care nursery for children aged up to 5 years. Directly across the road from the junior school is another day care nursery for children aged up to 5 years. Site 351 is within too close proximity to two schools and two nurseries and is not a suitable location for a waste management site where many small children will be spending most of their waking day. Also, there is already a lot of traffic resulting from school pick ups and drop offs. To have a waste management site located in this area would further increase the congested roads. Site 352 and 353, being part of the Chessington Industrial is not suitable because it is too close to the schools and nurseries mentioned above. Officer's Initial Comment: Noted - traffic and possible incompatibility with nearby land use activities are matters of acknowledged importance which require further consideration. Consultee ID: 334033 Full Name: Miss Clare Mannall Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 42 of 142 Kingston Consultee ID: 334033 Full Name: Miss Clare Mannall Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD12 Is Site Suitable? Site Number: 351/352/353 Site comment: I do have concerns in regard to the Chessington Industrial Estate. The views expressed are those of myself and my neighbours. As a community we fought off Tesco coming to the currently unused site near the station, but now we are being told it could become a Waste Disposal area instead. It feels like we have to chooses 'the lesser of two evils'! In addition to this you are adding traffic to an already built up and over-traffic'd area with no proposals for managing the increased flow of traffic to the area. Overall I think the policy is very thorough and realistic. Officer's Initial Comment: Agree- support for the approach for the plan. Noted comments relating to alternative development proposals. Noted. Traffic is an issue of acknowledged importance which will require further evaluation Consultee ID: 349750 Full Name: Mrs Sheila Hyson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD33 Is Site Suitable? Site Number: Site 351, 352 and 353: Moor Lane, Chessington. Chessington Industrial Estate Site comment: The feeder roads into this area are poor and at one time many HGVs tried to avoid the inevitable jams and extra journey times by using the residential roads. Local drivers have learnt to live with the extraordinary puzzle of road layouts built to keep the lorries out. There is now only one way in and one way out of the Industrial Estate; Jubilee Way. Huge waste lorries or even lots of smaller ones, trundling relentlessly up and down, past the playing fields and the recently built adventure playground will add to an already constant stream of traffic which, because cars are allowed to park in sections of Jubilee Way, make it too Page 135 narrow for an HGV and car to pass and at times cause great problems. Also everything will have to access and leave at the Kingston Road junction. We don't know the waste or how it will be managed, so how can we identify a site which is not empty nor derelict and with challenging vehicular access. In our rush to manage our waste are we forgetting to manage our pollution? A plan which sets out to increase traffic flow significntly over a long term future, should be sure that that traffic flow can be managed safely, sensibly and still keep flowing . It isn't enough to have a wait and see policy and should be discussed in conjunction with the acceptability of a site. Officer's Initial Comment: Noted - issues raised over local road congestion and suitability amenity and potential pollution concerns are matters of acknowledged importance which require further detailed investigation. Consultee ID: 350178 Full Name: Mrs Patricia Prieto Maturana Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD56 Is Site Suitable? Site Number: Site 351, 352 and 353: Moor Lane, Chessington. Chessington Industrial Estate Site comment: This is NOT a suitable location for waste management for several logical reasons: It is within very close proximity of primary AND secondary schools in the area. It is within a residential road and near a green belt area. Most importantly: Leatherhead road is over congested due to traffic off the M25, A3, Chessington World of Adventures, Chessington Garden Centre, etc. . It is a public transport nightmare as it is; putting more vehicles on the road, especially
more large trucks and HGVs will only worsen the traffic conditions. Agenda Item 3 Officer's Initial Comment: Noted - traffic, noise and possible disturbance and compatibility with nearby land uses are matters of acknowledged importance which require further consideration. Consultee ID: 350514 Full Name: R Bolton Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 43 of 142 Kingston Agenda Item 3 Consultee ID: 350514 Full Name: R Bolton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD61 Is Site Suitable? Site Number: Site 351, 352 and 353: Moor Lane, Chessington. Chessington Industrial Estate Site comment: 351: Problem of proximity of school site. 352: Again a strong possibility. Officer's Initial Comment: Noted - possible incompatibility with nearby land uses is a matter of acknowledged importance which requires further consideration. Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD78 Is Site Suitable? Site Number: Site 351, 352 and 353: Moor Lane, Chessington. Chessington Industrial Estate Site comment: Sites 351 and 352 are the only ones I consider suitable. Officer's Initial Comment: Noted - support for sites 351 and 352 Consultee ID: 354343 Full Name: Mr Chris Walker Organisation: Agent ID: Agent Name: Agent Organisation: Page 136 Comment ID: PSPCD98 Is Site Suitable? Site Number: Site 351, 352 and 353: Moor Lane, Chessington. Chessington Industrial Estate Site comment: It is not possible to comment on deliverability without knowing the specific use and technology intended for any of the sites. Given the analysis in the Plan, it is clear that incineration of some form is intended to play a major part of waste management in South London going forward and on that basis none of these sites are suitable. Officer's Initial Comment: Noted - concern that consultation doesn’t include information about specific use and technology and that incineration is unsuitable for any of proposed sites. Further information on type of proposal coming forward at next stage of plan will be available where this is clear. Consultee ID: 350873 Full Name: Zarayna G Pradyer Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL129 Is Site Suitable? Site Number: Sites 351, 352, 353 Site comment: These sites already have a suitable infrastructure. Are not wildlife/ horticulturally sensitive. Are not in close proximity to residential areas. Are not in close proximity to schools/ colleges. Are not part of the boroughs tourist attractions. Officer's Initial Comment: Noted. Support for sites as having adequate infrastructure and away from other sensitive uses. Consultee ID: 350786 Full Name: Mr Keith Bolling Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL135 Is Site Suitable? Site Number: Site 351and 46 Site comment: This site is clearly not suitable for a waste management facility. First, the northern boundary of the site is extremely close to both a secondary and primary school. Second, the site would be accessed via the A243 Leatherhead Road, which is already one of the busiest, most congested roads in the borough. Clearly 'comment sense' is not one of the criteria that has been used in judging suitable sites. Officer's Initial Comment: Noted. Concerns over proximity to schools and access from main road network.
26 November 2009 Page 44 of 142 Kingston Consultee ID: 354064 Full Name: Mrs J Davis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL154 Is Site Suitable? Site Number: Site 351: Chessington Industrial Estate Site comment: Rather near to properties. Officer's Initial Comment: Noted. Opposed due to proximity to residential. Consultee ID: 354117 Full Name: Ms Anne Middlemiss Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL168 Is Site Suitable? Site Number: Site 351 - 353 Site comment: Sites 351 -353 would be possible - do I see a rail link? Officer's Initial Comment: Noted support for site and for possible rail link Consultee ID: 354505 Full Name: Dr Anders Karlsson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL188 Is Site Suitable? Site Number: 351
Site comment: The residential areas surrounding the Chessington Industrial Estate are already suffering from very heavy traffic. Area 351 is furthermore very close to Caste Page 137 Hill Primary school. This seems to me a very ill-suited location for a waste management facility. Officer's Initial Comment: Noted. Concern over site 351 - traffic and proximity to school Consultee ID: 355091 Full Name: Mr Martin Radcliffe Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL227 Is Site Suitable? Site Number: Site 351: Chessington Industrial Estate Site comment: Too close to housing. Too close to a primary school. Access is difficult and continuous use would be too disruptive to local residents and other users of the Industrial Estate. Jubilee Way is not suitable, or wide enough, for such access and the increased traffic would be a threat to children using the new play ground in Jubilee Way. Officer's Initial Comment: Noted Object on traffic access, safety and proximity to residential and educational land uses Consultee ID: 355171 Full Name: Mrs E Gray E.B.E Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL235 Is Site Suitable? Site Number: Sites 351 -353
Site comment: Retain and improve unloading procedure. Agenda Item 3 Officer's Initial Comment: Noted support for retention and improvement Consultee ID: 349358 Full Name: Miss Tanya Farbrother Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 45 of 142 Kingston Agenda Item 3 Consultee ID: 349358 Full Name: Miss Tanya Farbrother Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL75 Is Site Suitable? Site Number: Site 351: Chessington Industrial Estate Site comment: Although Chessington Industrial Estate is just that, an industrial estate, it is almost completely surrounded by close density housing. We don't know yet what sort of facility is planned for any of these sites, but any odours and fumes would drift up the hill to the houses that surround it. Officer's Initial Comment: Noted - emissions and air quality and compatibility with adjacent uses are matters of acknowledged importance which require further consideration. More information on facilities proposed will be set out in next stage where this is known Consultee ID: 330742 Full Name: Mr Dennis Tilley Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL85 Is Site Suitable? Site Number: 351 and 352 Site comment: Although these site are on the industrial estate there is already significant traffic problems in the area with large HGVs and other similar vehicles. Given the various width restrictions the larger lorries are often getting lost and block the area whilst trying to find their destination or even get away from the area. This is usually during the working day and a little respite is available in the evening. If the facilities are to be 24 hour this would make the area a traffic nightmare. This would impact not only on vehicular movement but also pedestrians who even now find it difficult to walk around the industrial estate due to the dangerous nature of the traffic. Also it is worth bearing in mind that although this is a light residential area it shares very close boundaries with residential areas. There are Page 138 other more obvious out of town sites wher the impact would be significantly less on residents Officer's Initial Comment: Noted - traffic, emissions and air quality, quality of life and compatibility with adjacent uses, including hours of operation are matters of acknowledged importance which require further consideration. More information on facilities proposed will be set out in next stage where this is known Consultee ID: 350178 Full Name: Mrs Patricia Prieto Maturana Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 46 of 142 Kingston Consultee ID: 350178 Full Name: Mrs Patricia Prieto Maturana Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL90 Is Site Suitable? Site Number: Site 351: Chessington Industrial Estate Site comment: This site is not suitable. It is too close to primary and secondary schools. There is already too much traffic on Leatherhead road and a waste management facility would only aggravate and worsen driving conditions, not only posing a safety issue for residents and commuters but also pollution and ill effects to public transport. Leatherhead road has too high a volume of traffic as it is for the size and type of road; it connects the M25 and A3, it has Chessington World of Adventures and the garden centre, ect. Adding more regular volume of traffic (such as HGVs and trucks and lorries) will put a strain on the already dire conditions. The industrial estate is meant to be just that 'industrial', which it has been for the last 20-30 years, putting a waste management site there will change its nature entirely and thus severly affect the community. I always have felt that recycling and the environment and ethical waste disposal is something that should be taken very seriously. I do not, however, understand why it should be the general public that has to sacrifice and be taxed for the inneficiency of the retail industry. That is, instead of coming up with all these bright ideas on how to manage more waste, why not look at the source of the problem and fine and impose laws and regulations for manufacturers, retailers, and large packageing companies? As a consumer I have very little choice when it comes to food shopping (for instance) in that 99% of items are packaged in ridiculous amounts of card, plastic, paper, and other materials which as soon as I get home will end up in the bin and then unfortunately in landfills (in the case of the vast amount of non recycleable materials). Surely the answer is (apart from further developing waste facilities) to impose laws and regulations that stipulate that the manufacturers not be allowed to package food in this manner? Or at least to make their packageing 100% recycleable? What ever happened to buying fruit and vegetables loose? More and more supermarkets are now only selling bagged items (both inconvenient and a recycling nightmare). Surely it is the supermarkets and other large manufacturers who should also be held acountable for the amount of waste and be made responsible for improving the conditions we are sadly creating? Page 139 Officer's Initial Comment: Noted - concern that more effort should go into waste minimisation. Opposed to Chessington site on traffic grounds and economic/social impacts Consultee ID: 350639 Full Name: Gill Locke Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL101 Is Site Suitable? Site Number: Sites 352/353 Site comment: Kingston site 352/353 would appear suitable but am not sure of access infrastructure. Traffic potential should be considered. Officer's Initial Comment: Noted support for sites 352/353 subject to access and traffic issues. There are matters which require further investigation. Consultee ID: 354064 Full Name: Mrs J Davis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL155 Is Site Suitable? Site Number: Site 352: Chessington Industrial Estate Site comment: Too near to playing fields Officer's Initial Comment: Noted. Opposed due to proximity to playing fields Agenda Item 3 Consultee ID: 355091 Full Name: Mr Martin Radcliffe Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 47 of 142 Kingston Agenda Item 3 Consultee ID: 355091 Full Name: Mr Martin Radcliffe Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL228 Is Site Suitable? Site Number: Site 352: Chessington Industrial Estate Site comment: As with site 351 this is too close to housing. Also too close to a primary school. Access is difficult and continuous use would be too disruptive to local residents and other users of the Industrial Estate. Jubilee Way is not suitable, or wide enough, for such access and the increased traffic would be a threat to children using the new play ground in Jubilee Way. Officer's Initial Comment: Noted Object on traffic access, safety and proximity to residential and educational land uses Consultee ID: 349115 Full Name: Mr. Anthony steward Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL72 Is Site Suitable? Site Number: Site 352: Chessington Industrial Estate Site comment: This site is in a residential area. This area already suffers from high traffic volumes, especially HGVs and delivery vehicle to the busy industrial estate. The surrounding roads are a nightmare for local people especially since the width restrictions were imposed on us in order to "alleviate" heavy and wide vehicle. Adding a waste management site here with all the additional problems is unfair on local residents and should not be passed.
Officer's Initial Comment: Noted - traffic and compatibility with adjacent uses are matters of acknowledged importance which require further consideration. Page 140 Consultee ID: 349115 Full Name: Mr. Anthony steward Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL73 Is Site Suitable? Site Number: Site 352: Chessington Industrial Estate Site comment: This site is in a residential area. This area already suffers from high traffic volumes, especially HGVs and delivery vehicle to the busy industrial estate. The surrounding roads are a nightmare for local people especially since the width restrictions were imposed on us in order to "alleviate" heavy and wide vehicle. Adding a waste management site here with all the additional problems is unfair on local residents and should not be passed. Officer's Initial Comment: Noted - traffic and compatibility with adjacent uses are matters of acknowledged importance which require further consideration. Consultee ID: 349358 Full Name: Miss Tanya Farbrother Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL76 Is Site Suitable? Site Number: Site 352: Chessington Industrial Estate Site comment: Although Chessington Industrial Estate is just that, an industrial estate, it is almost completely surrounded by close density housing. We don't know yet what sort of facility is planned for any of these sites, but any odours and fumes would drift up the hill to the houses that surround it. Officer's Initial Comment: Noted - emissions and air quality and compatibility with adjacent uses are matters of acknowledged importance which require further consideration. More information on facilities proposed will be set out in next stage where this is known Consultee ID: 350178 Full Name: Mrs Patricia Prieto Maturana Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 48 of 142 Kingston Consultee ID: 350178 Full Name: Mrs Patricia Prieto Maturana Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL91 Is Site Suitable? Site Number: Site 352: Chessington Industrial Estate Site comment: This site is not suitable. It is too close to primary and secondary schools. There is already too much traffic on Leatherhead road and a waste management facility would only aggravate and worsen driving conditions, not only posing a safety issue for residents and commuters but also pollution and ill effects to public transport. Leatherhead road has too high a volume of traffic as it is for the size and type of road; it connects the M25 and A3, it has Chessington World of Adventures and the garden centre, etc. . Adding more regular volume of traffic (such as HGVs and trucks and lorries) will put a strain on the already dire conditions. The industrial estate is meant to be just that 'industrial', which it has been for the last 20-30 years, putting a waste management site there will change its nature entirely and thus severely affect the community. Officer's Initial Comment: Noted opposed to Chessington site on traffic grounds and economic/social/community impacts Consultee ID: 354064 Full Name: Mrs J Davis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL156 Is Site Suitable? Site Number: Site 353: Chessington Industrial Estate Site comment: A possibility perhaps? Officer's Initial Comment: Noted Consultee ID: 355091 Full Name: Mr Martin Radcliffe Organisation: Page 141 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL229 Is Site Suitable? Site Number: Site 353: Chessington Industrial Estate Site comment: This site is on a residential road. As width 351 and 352 access is difficult and continuous use would be too disruptive to local residents and other users of the Industrial Estate. Jubilee Way and Cox Lane are not suitable, or wide enough, for such access and the increased traffic would be too much. Officer's Initial Comment: Noted Object on traffic access, congestion and proximity to residential and industrial land uses Consultee ID: 344720 Full Name: Mr David Booth Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 49 of 142 Kingston Agenda Item 3 Consultee ID: 344720 Full Name: Mr David Booth Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL54 Is Site Suitable? Site Number: Site 353: Chessington Industrial Estate Site comment: 1. If existing access from Jubilee Way is used, the railway bridge is 15' 3'', I believe this would be too low for some high sided or long wheelbase lorries. There is already a slight depression in the road to increase bridge height. This is the single method of access to 353 and if it is blocked the site would be inaccessible. Have RailTrack been consulted? 2. The site would form part of the Oakcroft Estate which is an estate of 6 roads of small one and two bedroom houses. These are usually homes for young families and these families move on as they grow leaving the houses to be reoccupied by new young families. We have already had one death of a child on a bicycle and there are traffic calming measures throughout the estate. 3. The "industrial" designation refers to the pre and immediately post war period. The estate has been a "business" estate for the last 20-30 years. The change of use to waste management would be a huge change not the small change implied by the "industrial" designation. 4. The selected site would be most effective if run 24 hours a day to handle the commercial and industrial waste which forms the majority of waste, without filling the site with piles of waste awaiting processing. Site 353, as it is in a residential area, would be exposed to vehicles moving to and from the site 24 hours a day and the noise from any equipment using any technology would certainly harm the environment in the sense outlined in policy 1. 5. Composting or recycling will both require processing, washing or storing and produce smells which it will be impossible to contain. 6. I attended one of the open evenings and gained the impression that insufficient reference had been made to existing facilities already working in other EU countries. The policies seem to be cut and paste from other projects within the UK, none of which have reached the implementation stage. It seems that similar sites to 353 which will directly involve settled residential areas with a preponderance of young children, must have been considered in other places in the UK or within the EU and have been rejected. Has this site been offered by the owner who has been unable to Page 142 dispose of it due to the downturn in demand for business premises? If so surely the site would better be re zoned as a residential brown field site to complete the Oakcroft Estate as a residential area? 5. So, access, inappropriateness and health hazard are all objections before a single plan is proposed by a waste management company. Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6. Further assessment of traffic impacts is required to assess these concerns. Consultee ID: 346309 Full Name: Mrs. Ann Crane Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL59 Is Site Suitable? Site Number: Site 353: Chessington Industrial Estate Site comment: although listed as chessington industrial estate site 353 in particular faces onto a residential area.the impact to standard of life for residents would be unacceptable. site 351 and 352 are also neighbouring houses. as an oakcroft road resident i strongly object!! there is limited access to industrial estate, with only one road in and out congestion will increase having a knock on effect.tolworth roundabout is at a stand still most of the time as it is and can't cope with increased traffic flow. there is already a problem to the surronding residential roads of HGV traffic passing through either lost on route to the industrial area or trying to take a short cut to the A3, this problem will only get worse. there would also be an increase in pollution and noise levels to residents in these family houses and to the local schools.this industrial park is designated as light industry and business use only when we bought this house only 2years ago we were assured by the council that the empty office block opposite us (part of site353) would always remain an office block. site 47 is currently being used as an off the road bike track a valuble and well attended resource to local teenagers and is also next to a nature reserve. barwell business park although maybe not as close to residential area is next to a newly developed college and primary school surely putting such developments near children is unsuitable. i think the only option if this facility has to be in kingston is the villiers waste site Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6. Further assessment of traffic impacts is required to assess these concerns.
26 November 2009 Page 50 of 142 Kingston Consultee ID: 346309 Full Name: Mrs. Ann Crane Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL64 Is Site Suitable? Site Number: Site 353: Chessington Industrial Estate Site comment: as an oakcroft road resident i strongly object and think sites 353, 351,352,47 are unsuitable. chessington industrial estate is light industry and business use only,a waste facility will completly change the nature of the estate.very few of the business's are 24/7 and if they are they ensure traaffic does not travel on the residential part of oakcroft road the council is addressing the problem of HGV traffic illegall overnight parking as it is, this problem would only be made worse. with limited access to the estate we have to put up with HGV traffic cutting through residential roads, getting lost and turning at inappropriate places. site 353 in particular is on a residential road.site 351,352 are also close to residential areas including primary schools. the increased traffic especially HGV traffic, the increase of pollution/smell/noise and possible vermin would have an unacceptable impact on residents in such a close proximity. tolworth roundabout is already at a standstill most of the time,with a housing development planned for the nearaby government/tesco grounds,this junction cannot cope with any more added congestion. site 47 is currently a well utilised off road bike site a much valued community venture.it is also adjacent to tolworth court farm a metropolitan open land, grade 1 nature reserve.the potential impact on invaluble green land is unacceptable. i think further facilities should be made available at an already exsisting waste site such as villiers road rather than develop on new sites. southlondonwasteplan should look at extending facilities at exsisting waste sites rather than develop on new sites Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6. Further assessment of traffic impacts is required to assess these concerns.
Consultee ID: 349115 Full Name: Mr. Anthony steward Organisation: Page 143 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL74 Is Site Suitable? Site Number: Site 353: Chessington Industrial Estate Site comment: This site is in a residential area. This area already suffers from high traffic volumes, especially HGVs and delivery vehicle to the busy industrial estate. The surrounding roads are a nightmare for local people especially since the width restrictions were imposed on us in order to "alleviate" heavy and wide vehicle. Adding a waste management site here with all the additional problems is unfair on local residents and should not be passed. Officer's Initial Comment: Noted - traffic and compatibility with adjacent uses are matters of acknowledged importance which require further consideration. Consultee ID: 349358 Full Name: Miss Tanya Farbrother Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL77 Is Site Suitable? Site Number: Site 353: Chessington Industrial Estate Site comment: Although Chessington Industrial Estate is just that, an industrial estate, it is almost completely surrounded by close density housing. We don't know yet what sort of facility is planned for any of these sites, but any odours and fumes would drift up the hill to the houses that surround it. Officer's Initial Comment: Noted - emissions and air quality and compatibility with adjacent uses are matters of acknowledged importance which require further
consideration. More information on facilities proposed will be set out in next stage where this is known Agenda Item 3 Consultee ID: 350178 Full Name: Mrs Patricia Prieto Maturana Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 51 of 142 Kingston Agenda Item 3 Consultee ID: 350178 Full Name: Mrs Patricia Prieto Maturana Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL92 Is Site Suitable? Site Number: Site 353: Chessington Industrial Estate Site comment: This site is not suitable. It is too close to primary and secondary schools. There is already too much traffic on Leatherhead road and a waste management facility would only aggravate and worsen driving conditions, not only posing a safety issue for residents and commuters but also pollution and ill effects to public transport. Leatherhead road has too high a volume of traffic as it is for the size and type of road; it connects the M25 and A3, it has Chessington World of Adventures and the garden centre, etc. . Adding more regular volume of traffic (such as HGVs and trucks and lorries) will put a strain on the already dire conditions. The industrial estate is meant to be just that 'industrial', which it has been for the last 20-30 years, putting a waste management site there will change its nature entirely and thus severely affect the community. Officer's Initial Comment: Noted opposed to Chessington site on traffic grounds and economic/social/community impacts Consultee ID: 344294 Full Name: Mr Andrew Withers Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD21 Is Site Suitable? Site Number: Site 642: Durnsford Road Industrial Area Site comment: Originally the site of a coal fired power station. This has good rail connections. The former carriage sidings on the Tooting loop are unused and could become the site of a waste disposal facility. This is not part of Network Rail's strategic site which is on the opposite side of the main line. Page 144 Officer's Initial Comment: Noted - support for the site and reference to possible rail connection. Merton Consultee ID: 346714 Full Name: Mr J. White Organisation: Sustainable Merton Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD25 Is Site Suitable? Site Number: Site comment: The priorities of the Waste Hierarchy (fig.1.4) and Key Policy Issue 2 (3.2) are waste prevention and re-use. Consultations have consistantly shown that these are also the publics' priorities. Yet the plan fails to seriously address them. An attempt to shrug-off a primary responsibility to narrowly focussed national agencies like WRAPand BREEAM is not acceptable. It shows a lack of vision in this Plan and a failure to understand the need for holistic solutions. This failure of vision is one thing; even more worrying is the failure to even acknowledge the current duties and powers of local authorities to reduce packaging through Trading Standards. And although there are some grounds for saying that some aspects of waste prevention should be first addressed through national legislation, this is not true of waste re-use. Refurbishment and redistribution of serviceable goods that might otherwise be thrown away is necessarily going to be locally based. There are already charitable schemes that do this - the ambition should be to make this a mainstream activity. Yet sadly, the Plan does not address this supposedly 'Key Issue' at all. Those responsible for the Waste Plan need raise their game - listen to the public and read their own list of objectives. Try again, please. (J.W. for Sustainable Merton) Officer's Initial Comment: Agree -support for aspects of waste plan strategy. However the Waste Plan is not the Municipal Waste Strategy Consultee ID: 346714 Full Name: Mr J. White Organisation: Sustainable Merton Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 52 of 142 Merton Consultee ID: 346714 Full Name: Mr J. White Organisation: Sustainable Merton Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD26 Is Site Suitable? Site Number: Site comment: During the public consultations, it was often pointed out that the basic process is flawed. It makes no sense to identify sites - or even the criteria for sites - as though all waste plants were the same. This document attempts to address (and thereafter avoid) this issue under the heading 'Why won't the South London Waste Plan specify what's going to be built?' (Background 1.20). The arguement seems to be that because there may have been changes in the waste stream and technologies over the next ten years therefore it is impossible to know what waste facilities will be required. The obvious response is: Then why is the Plan so confident about the figures included in 'Need for Change', 'waste stream', 'targets', 'the strategic approach' and other sections? Of course there will be some incremental changes - but those changes will not stop in 2021. By that arguement, we will never be able to plan anything. Here is just one example of why this approach is unsatisfactory: Elsewhere in the plan, use of waste in various types of CHP plants is noted with approval. But if this is to happen, they must be at sites where the heat can be put to productive use. If we select sites in the abtract, without taking into account the needs of a process like CHP, we are effectively ruling it out as an option - or at least, not optimising its full potential. Yes, it is a more difficult task - but needs must! The basic problem here is that we still do not have a real plan for dealing with waste. If there was a plan, then we could consider which sites would meet its requirements. But meanwhile, the public is right to to be suspicious of this consultation process. Officer's Initial Comment: Agree - Locations to make best use of local heat and power generation are important considerations. Disagree that Plan is flawed. Agree- Next stage of Plan to give further consideration of activities where this is clear. Consultee ID: 354117 Full Name: Ms Anne Middlemiss Organisation: Agent ID: Agent Name: Agent Organisation: Page 145 Comment ID: PSPSL169 Is Site Suitable? Site Number: Site comment: Most of Merton sites could be suitable, as they already industrialised, but if a large increase in traffic resulted, I could see this already congested area grinding to a halt. Officer's Initial Comment: Noted. Issues including traffic are important considerations and will require further evaluation and evidence. Consultee ID: 354546 Full Name: Mr D.T.R Evans Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL190 Is Site Suitable? Site Number: Site comment: I support strongly the concept of the waste management policies(1-7) as outlined in your document. I do not however feel that any recycling plants should be located within the more densely populated residential areas, i.e. Raynes Park, London SW20 Officer's Initial Comment: Noted. Support for proposed policies. Objection to recycling plants in densely populated areas such as Raynes Park Consultee ID: 354651 Full Name: Mr William Watson Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3 Comment ID: PSPSL204 Is Site Suitable? Site Number: Site comment: Merton Councils way of collecting recycling from residents is a joke! please at least provide bins with lids so that the materials to be recycled do not blow away before collection! Officer's Initial Comment: Disagree - SLWP is not covering the Municipal Waste Strategy and detailed complaints about levels of service in refuse collection
26 November 2009 Page 53 of 142 Merton Agenda Item 3 Consultee ID: 324637 Full Name: Mr. Brian (No Suggestions) Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL22 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I think that any future expansion sites should only be in industrial sites and far away from any housing areas. Officer's Initial Comment: Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6. Consultee ID: 355250 Full Name: Mr John Shayler Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL257 Is Site Suitable? Site Number: Site comment: The stretch of road between station and mini roundabout is already known to locals as the 'Home Straight' (Brands Hatch). The speeds along this stretch of road at off peak times especially at early weekends have to be seen to be believed! Merton Council spent a lot of money on road calming tarmac. Might as well of dumped the money in local tip! Why no speed cameras, facing both ways? self financing, and guilty pay the fines, this might actually slow the traffic. But Council Tax paying pedestrians don't seem to count. The last we need is more speeding lorries.
Officer's Initial Comment: The points raised are noted. The issues raised including impacts on local amenity are important considerations and will require further evaluation Page 146 and evidence. (officer notes: this relates to sites 66 and 22 Willow Lane) Consultee ID: 324947 Full Name: Mrs Pauline Davis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL27 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I believe there should be a plan, but that site must not be chosen for commercial gain, but for best sites in respect of least disruption to local communities and with no danger to local communities. Officer's Initial Comment: The consultation and research are seeking to create a plan with the most appropriate sites in terms of minimising impact on surrounding areas. Impact on local communities is also being addressed through draft policy WP6 Consultee ID: 331223 Full Name: Mr Mark Watson Organisation: Silvercrest House Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL38 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I write as a director of Silvercrest House Management Limited, the management company for the flats (nos. 2-68 evens) at Gresham Way SW19 8ED. I also own flat number 4. Of the three potential sites 641, 642 and 651 I consider site 651 as the best option as it is the least intrusive to nearby residential areas. By the same token site 642 is the worst option . Whatever site's) are chosen the buildings should be low-rise and with a guarantee of no emissions of gas due to composting or other waste treatment processes. Officer's Initial Comment: Noted. The issues raised have been considered in identifying potential sites and are proposed to be considered again at planning application through proposed policy WP6. Consultee ID: 347510 Full Name: Mr Ken Richman Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 54 of 142 Merton Consultee ID: 347510 Full Name: Mr Ken Richman Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL66 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Is there a north London waste plan for example and what steps if any are being taken to integrate the two in order to avoid hauling waste unnecessarily far when more local facilities may exist in another borough, and to ensure that waste facilities in adjacent boroughs are not duplicated? In other words is there any thinking outside the south London box? Officer's Initial Comment: The South London Waste Planning group is in contact with the other London waste planning regions and with the Mayor of London to ensure an efficient selection of sites in order to process London's waste. Consultee ID: 348672 Full Name: MR FRANK PRATER Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL71 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I object to the South London Waste Plan using site 18 & 57 which are at Beddington farmlands. Temporary recycling facilities there are already causing the decline of nationally important bird species at this designated site of metropolitan importance for nature conservation. Further development and disturbance there will destroy the nationally important wildlife , for what should become a major urban nature reserve. Sutton council are responsible for the Conservation Management Plan for this site and its time they fully implemented it.
Officer's Initial Comment: Noted. These are important considerations which require further investigation and evidence gathering Page 147 Consultee ID: 349762 Full Name: Mr Rudolph Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL87 Is Site Suitable? Site Number: Site comment: I, along with a dozen or so neighbours, strongly object to the South London Waste Plan using site 60 in Raynes Park which is bang in the middle of a heavily populated area. This is already suffering from frequent traffic congestion (not just at rush hour), air pollution because of its proximity to the A3 and overcrowding. Sites such as the Beddington Industrial Estate or several of the Croydon sites are far more suitable for a waste recycling plant as they are NOT in a residential area, have excellent transport links and are already located in or near industrial estates. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including traffic, pollution, and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 350694 Full Name: R Hills Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL115 Is Site Suitable? Site Number: Site 9: Garth Road civic amenity site Site comment: Garth Road would be suitable for expansion. Agenda Item 3 Officer's Initial Comment: Noted Consultee ID: 354059 Full Name: Mr & Mrs M.G & M Tulloch Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 55 of 142 Merton Agenda Item 3 Consultee ID: 354059 Full Name: Mr & Mrs M.G & M Tulloch Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL143 Is Site Suitable? Site Number: Site 9: Garth Road civic amenity site Site comment: Obvious choice, existing site, long established, designed to cope with large lorries. Officer's Initial Comment: Noted Consultee ID: 354129 Full Name: Ms Vivien Taylor Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL172 Is Site Suitable? Site Number: Site 9: Garth Road civic amenity site Site comment: Site 9 Traffic noice, pollution unbearable now. Big trucks from Sloanes(Skip Hire Recycling) and amenity centre and industrial centre gets worse daily. I have lived here for 30 years, it is a council property and i have no chaance of moving from it. we aslo have double decker buses in the last year. 10 big trucks which pass every 5 mins shaking the foundations of this house and even with double glazing is incredibly noisy. An amenity centre should be linked straight to a motorway exit and not going through residential streets. We have a traffic accident hotspot at the end of Garth Road, where the road goes into Stonecote Hill which is the main road out of London to Surrey which is busy all day, especiallyin rush hour. i will be getting together with my neighbours to oppose this with a petition etc. I cannot belive this site can even be considered for expansion. instead of consulting like this it would be a good idea if somebody sensible came down here and had a look about to assess this and talk to people. We pay the same council taxes as the rest of Merton, but this would not even be considered Page 148 in areas like Wimbledon Hill and wealthier areas. If so, would never happen. Because the people who live on the hill wwould be listened to, but we seem to be Mertons dumping area. People who live in this neighbourhood are working class and most of there time is pent working hard to pay there taxes etc. I welcome the cahnce to represent my street if someone would like to contact me. I wonder if you will. Officer's Initial Comment: The points raised are noted. Issues such as traffic, noise and residential amenity are important considerations and will require further evaluation and evidence. The purpose of the consultation is to find out what people think about the proposed sites and policies. If you would like to find out about community groups in your local area, you could contact Merton Voluntary Services Council on 020 8685 1771 who may be able to help. Consultee ID: 354651 Full Name: Mr William Watson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL201 Is Site Suitable? Site Number: Sites 9 and 702 Site comment: Garth Road works very well as Merton's main tip and should not be changed Officer's Initial Comment: Noted Consultee ID: 354671 Full Name: D Nanson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL209 Is Site Suitable? Site Number: Sites 9, 702 Site comment: Too near residential Officer's Initial Comment: Noted Consultee ID: 355227 Full Name: Ms Suzie Graham Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 56 of 142 Merton Consultee ID: 355227 Full Name: Ms Suzie Graham Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL246 Is Site Suitable? Site Number: Sites 9, 702, 641, 642 Site comment: There are a number of sites more suited than Site 60, for example site 9, 702, 641, 642 where there are already recycle areas which could be expanded. Officer's Initial Comment: Noted Consultee ID: 355329 Full Name: C.L Massey Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL270 Is Site Suitable? Site Number: Sites 9, 702 and 60 Site comment: I am writing to object to your plan to build an Eco Park Waste Processing unit on the Rainbow Industrial Estate (60) and existing civic amenity site on Garth Road (9, 702). Firstly in respect of site 60, I do not believe a town centre, close to a main railway line, within a residential area and the close proximity of local primary schools, is a suitable site for such a plant. I do not believe that the Council is in a position to give the residents a 100% guarantee that an explosion, pollution and contamination will not occur at the site in its lifetime. No one can predict an Act of God. I object to having waste, along with the possibility of pollution and contamination, being brought to my doorstep, in the middle of a residential area with schools and close to a railway line, for processing. There would be an increase in traffic in the area. The volume of traffic on Grand Drive is already unacceptably high and the Eco Park development will only add to this problem. The development of the new B&Q has increased the traffic congestion on Grand Drive to the extent that I find it almost impossible to exit my
drive to get onto the main road now. The development of the waste management facility on Sites 9, 702 and 60 will contribute to further congestion on Grand Page 149 Drive. From the proposals, it would appear that the structure would tower above the houses in the immediate area. I do not consider such a view to be acceptable. The Eco Park Waste Processing unit would devalue the properties in the vicinity, including my own property. It would therefore make sense to have this facility on an existing waste site. There are various safety and health issues such as gas leaks and accidents that could happen that you would not be able to predict. I have two young children and their health and safety is my priority. I do not want their health or safety being put at risk by the Council. Finally, I did attend the Work Glebe exhibition at Raynes Park Library last year and raised the above matters but their verbal assurances did nothing to allay my concerns. I would like you to take into consideration my views as a local resident, living in close proximity to sites 9, 702 and particularly 60. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including impacts on local amenity are important considerations and will require further evaluation and evidence. Please note that the South London Waste Plan consulted on Site 60, and all other sites including 9 and 702, for the principle of waste management usage and is not related to the specific proposals released in 2008 by a company called Workspace Glebe, known as the "Rainbow Eco Park". Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD67 Is Site Suitable? Site Number: Site 22: Willow Lane Industrial Estate, B Nebbett & Son Ltd Site comment: Sites I consider suitable are existing disposal sites not too close to residential areas
Officer's Initial Comment: The points raised are noted Agenda Item 3 Consultee ID: 350639 Full Name: Gill Locke Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 57 of 142 Merton Agenda Item 3 Consultee ID: 350639 Full Name: Gill Locke Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL103 Is Site Suitable? Site Number: 22, 247, 136 Site comment: The most suitable sites would appear to be 22,127 and 136 as already designated industrial sites and quite central for Croydon and Sutton Officer's Initial Comment: Noted Consultee ID: 354671 Full Name: D Nanson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL205 Is Site Suitable? Site Number: Sites 22 and 69 Site comment: Good communication and away from residents. Officer's Initial Comment: Noted Consultee ID: 354671 Full Name: D Nanson Organisation: Agent ID: Agent Name: Agent Organisation:
Comment ID: PSPSL211 Is Site Suitable? Site Number: Sites 22, 69 Page 150 Site comment: Sites 22 and 69 would seem to be the sites being central to Sutton, Croydon and Merton. Officer's Initial Comment: Noted Consultee ID: 322082 Full Name: Miss Michelle Gracie Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD1 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial Estate Site comment: insufficient lanes for an already busy traffic area, further developments are already pending which will already place extreme pressure on the surrounding roads. The surrounding area is too residential for a development such as this. Officer's Initial Comment: Noted - concern over traffic related issues. These are important considerations which require further evidence gathering and consideration. Consultee ID: 355114 Full Name: Mr Ragip Luta Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 58 of 142 Merton Consultee ID: 355114 Full Name: Mr Ragip Luta Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD116 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial Estate Site comment: I was deeply disappointed with the Workshop that I attended on 9th september at Merton Civic Centre. We did not have a chance to talk to the person who was representing Mouchel, the company that have prepared the Technical Report on the suitability of sites. I was promised that I will be sent a copy of the report and to this day - more than a month later - I still have not received it. The Site 60 Rainbow Park Industrial Estate is not at all suitable to be included in the Waste Plan, because it is very close to residential areas, and this very fact has been left out in the Technical Report. The Report mentions the residential areas on two sides of the site, stressing that one of them is separated by the railway and to the south, it mentions apartment blocks but it fails to register the existence of a whole street, Firstway, which puts the whole Report in question as to how serious was the work done on it. Apart from other issues, such as flooding potential, danger to the residents, one very concerning fact to me is that the Site has got the entrance near the Railway Station which is extremely busy all the time. Even at present, as it is, cars, trucks and buses that access the Industrial Park pose a great danger to the public, the school children in particular. Officer's Initial Comment: The points raised are noted. The issues raised above relating to Site 60 are important considerations and will require further evaluation and evidence. We are sorry that you found the workshop unsatisfactory Consultee ID: 326952 Full Name: Miss Rachel Perrins Organisation: Agent ID: Agent Name: Agent Organisation:
Comment ID: PSPCD117 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial Estate Page 151 Site comment: I am concerned about access from Grand Drive by the station at Raynes Park. This could make entry to the station more dangerous. Also about the effect on other traffic using Grand Drive. The site is also too close to residential accommodation. Officer's Initial Comment: The points raised are noted. The issues raised above relating to Site 60 are important considerations and will require further evaluation and evidence. Consultee ID: 337588 Full Name: Mr Steven Haran Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD31 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial Estate Site comment: Site 60 is too close to residential areas and schools Officer's Initial Comment: The points raised are noted. Consultee ID: 349659 Full Name: Dr Peter West Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 59 of 142 Merton Agenda Item 3 Consultee ID: 349659 Full Name: Dr Peter West Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD91 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial Estate Site comment: The Rainbow Park industrial estate is not a suitable site for waste collection and processing. It is in many ways mis-labelled as an industrial estate as this implies a level of current development which does not seem to match the bus storage and maintenance and other activities on the ground. There is little obvious "industry". But more importantly, this site is close to busy "town centre" roads in Raynes Park, has relatively poor access for vehicles from Bushey Road, due to the tightness of the turn and is too close to residential areas to be suitable for waste processing or waste collection. The traffic, the problems due to the build up of waste and other factors make this very tight site closely surrounded by housing a most unsuitable site. Other industrial estates in the area are more clearly segregated from residential areas and should be seen as the priority areas for waste management of all kinds. Officer's Initial Comment: The points raised are noted. The issues raised above relating to Site 60 are important considerations and will require further evaluation and evidence. Consultee ID: 321864 Full Name: Mr Tom Goose Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL1 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area
Site comment: The site is too small and is very close to the town centre and a large residential area. The roads struggle already to cope with existing traffic and the noise and Page 152 visual impact would be damaging to local people's quality of life. Officer's Initial Comment: The points raised are noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 350639 Full Name: Gill Locke Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL102 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Site 60 is totally unsuitable - very congested area already access for proposed transport is too restricted traffic level in area is already causing problems for all local residents site is too close to residential properties, local supermarket (under development) and primary school Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including noise, traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 350647 Full Name: Mrs E Brewer Organisation: Raynes Park Townswomens Guild Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL106 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Too close to housing and the railway space too small for the proposed lorry traffic into and out of entrance. very worried regarding proposed waste disposal. the roads within the area are already very heavily congested and with proposals for future house building off Grand Drive and turning from Bushey Road into Grand Drive would make the road almost dead locked permanently. The bus routes especially relied upon by OAPs! Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including noise, traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 350694 Full Name: R Hills Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 60 of 142 Merton Consultee ID: 350694 Full Name: R Hills Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL114 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: This site would be unsuitable because: It is in the middle of a residential area and near the town centre It will increase traffic which is already busy in the town with lorries going in and out. It will cause increased noise and smells It will impact on property values in the area The current industrial estate is useful to the local population. The site is too small for an effective waste disposal unit. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including noise, traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 354059 Full Name: Mr & Mrs M.G & M Tulloch Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL142 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: This is completely unsuitable: closer to residential areas including tram currently under construction heavy traffic areas restricted width roads destroy amenity of town centre awkward access to site already used by non-nuisance occupation should be ruled out now Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including noise, traffic and impacts on local amenity are important considerations and will require further evaluation and evidence.
Consultee ID: 354062 Full Name: V Canty Organisation: Page 153 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL149 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: I believe site 60 is unsuitable as it is too close to residential houses and there would be a big increase in heavy traffic in an already busy area. Officer's Initial Comment: Issues including noise, pollution, ecology, have been considered in identifying sites and, were a planning application to be received, would be considered again through proposed policy WP.6 Consultee ID: 354063 Full Name: Mrs R Hodgins Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL150 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Totally unsuitable site as this is a very residential area and would increase traffic, noise, pollution and pests. There is a local opposition to the site being developed for this purpose. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including noise, traffic and impacts on local amenity are important considerations and will require further evaluation and evidence.
Consultee ID: Full Name: Organisation: Agenda Item 3 Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 61 of 142 Merton Agenda Item 3 Consultee ID: Full Name: Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL157 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Have seen proposals for Eco Park - agree with it but concerns regarding traffic on entrance, need to think about traffic management at Grand Drive Cross roads and through Raynes Park traffic light management) to increase speed of traffic flow especially peak times! Officer's Initial Comment: The points raised are noted. Issues such as traffic are important considerations and will require further evaluation and evidence. Please note that the specific proposals called "Rainbow Eco-Park" are unconnected to the South London Waste Plan. Consultee ID: 354103 Full Name: Miss R Dunbavand Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL159 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: This site although next to railway line, is in the middle of a residential area swarming with people to-ing and fro-ing to station, especially with school children. The proposed (and only) entrance/ exit is on a bend on an extremely busy road leading to major highways. the traffic situation could not handle the proposed number of vehicle visits( one every three minutes - in/out) and the extra pollution in this residential area would be catastrophic. The points raised are noted. The issues raised relating to Site 60 including noise, traffic and impacts on local amenity are important
Officer's Initial Comment: Page 154 considerations and will require further evaluation and evidence. Please note that the South London Waste Plan is asking about the principle of Site 60 for any form of waste management and is unconnected to specific proposals made in 2008 by a company for this site (which may specify a certain number of vehicle visits). Consultee ID: 354332 Full Name: Mrs Nicolle Anderson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL176 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: I find Rainbow Park wholly unsuitable as a waste management site. It is in the centre of Raynes Park, next to the station and shopping area. This is a residential area and the local roads are already busy enough without waste trucks adding to the traffic. I do not wish to have a waste site in the centre of my local community in proximity of schools. An out of town waste site should be chosen instead of one which will create an eyesore and unpleasant odours in a residential area. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including noise, traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 354412 Full Name: Mr & Mrs Gareth & Emer Bradley Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 62 of 142 Merton Consultee ID: 354412 Full Name: Mr & Mrs Gareth & Emer Bradley Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL186 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: RE: Proposed Development of the Rainbow Industrial Estate, Raynes Park I am very concerned about the Rainbow Industrial estate being redeveloped into a waste disposal site. As a resident of the area, I strongly object to such a proposal in this busy residential area. The traffic on Grand Drive is already at a standstill for most of the day as it is and any increase in traffic would be disastrous. On a rainy day there are even worse problems as the tunnel under the bridge floods and causes massive tailbacks. How lorries could negotiate the turns onto Grand Drive I can't imagine. As a pedestrian I've often seen lorries turning from Bushey Road onto Grand Drive unable to do so because of the traffic lights and narrowness of the road. Turning into and out of the industrial site itself also poses a problem for lorries as these turns were just not built with their size in mind. It is completely inappropriate to dispose of waste on such a scale in such close proximity to people's homes. It is unacceptable to take such a risk which could affect the health of many. This could manifest itself not just physically were a serious accident to occur but also mentally to those who find their homes are worthless and unsalable as well as having to suffer looking out onto a rubbish dump. There will inevitably be mass disruption to the area while the site is being developed. I understand that some alternatives are needed to dispose of our rubbish and what the Eco Park entails to do is very interesting, but surely you can see that this is not a suitable site for it. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including noise, traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Please note that the South London Waste Plan is consulting on the principle of Site 60 for any form of waste management and is not connected to the specific proposals known as the "Rainbow Eco Park". Consultee ID: 354546 Full Name: Mr D.T.R Evans Organisation: Agent ID: Agent Name: Agent Organisation: Page 155 Comment ID: PSPSL189 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: As a local resident of Raynes Park, I consider this to be a totally unsuitable area for future waste management facilities. It is within a built residential area which is currently being redeveloped to a high standard. My objections are on environmental grounds and the potential hazards caused by the proposed Glebe Eco Plant. I would much rather see this area redeveloped as a new school, much needed by the local community. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including impacts on local amenity are important considerations and will require further evaluation and evidence. Please note that the South London Waste Plan is consulting on the principle of Site 60 for any form of waste management and is not related to the specific proposals released in 2008 by a company called Workspace Glebe, known as the "Rainbow Eco Park". Consultee ID: 354616 Full Name: Mr Peter Haynes Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL193 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Site 60 is unsuitable because it is in the middle of a residential area. The site would be much better used for a car park and a school to cater for the increasing population. Without a large car park Raynes Park will die! Agenda Item 3 Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including impacts on local amenity are important considerations and will require further evaluation and evidence. Consideration of the site for a car park would increase traffic flows to the centre of Raynes Park. Consultee ID: 354651 Full Name: Mr William Watson Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 63 of 142 Merton Agenda Item 3 Consultee ID: 354651 Full Name: Mr William Watson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL200 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Site 60 is in a very built up area with already very congested roads thus not suitable. Officer's Initial Comment: Noted Consultee ID: 354671 Full Name: D Nanson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL208 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Site 60 not suitable, poor road system new residential. Officer's Initial Comment: Noted Consultee ID: 354686 Full Name: E.M Nanson Organisation: Agent ID: Agent Name: Agent Organisation:
Comment ID: PSPSL213 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Page 156 Site comment: This site is unsuitable for the increased traffic flow that would result from it becoming a waste management facility. There is a poor road system and the access point is immediately adjacent to the entrance/ exit from Raynes Park Station - a busy commuter station. Using the pedestrian crossing there is already dangerous. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 324858 Full Name: Mr Peter Oliver Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL23 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: I object to a waste management facility being built in Merton on site 60 (The Rainbow Park industrial area.) Traffic is already terrible in this area and lorries delivering waste will make a bad situation even worse for local residents. Surely a location in a less central area can be found? This site is right by the main train station and shopping area for Raynes Park, as well as a number of primary schools. Officer's Initial Comment: The points raised are noted. The issues raised regarding Site 60 are important considerations and will require further evaluation and evidence. Consultee ID: 355129 Full Name: Mrs Maureen Ellis Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 64 of 142 Merton Consultee ID: 355129 Full Name: Mrs Maureen Ellis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL232 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: I have studied the the above-captioned plan and wish to present the issues in relation to the Rainbow Industrial Estate in Raynes Park. The criteria for identifying this site are flawed. The site has a high flood risk (3). It totally ignores its proximity to residential housing in Firstway. As the lorries which would need to access the site are too big to get under the railway arch in the centre of Raynes Park, access from Coombe Lane will be impossible. Access from Grand Drive will cause massive hold-ups in an already congested section of road - one lane of traffic in each direction. Huge potential for conflict with pedestrians: children walking to and from school or entering and exiting the station at that location, similarly commuters using the station, others using the cattle arch which is the key access point in Raynes Park to get from one side of the railway to the other. Either lorries will have to stop in the middle of Grand Drive before turning left into the site, leaving long queues of traffic behind, or pedestrians will be put at risk as they attempt to safely cross the road going to and from the station. We are seeing some little hope for the future of Raynes Park as a "living" town centre, bringing in this additional heavy traffic will have a negative effect on its accessibility given the cattle arch is located right beside the access to the site and its importance as an access route through Raynes Park for pedestrians and cyclists (dismounting to get back on the road at Grand Drive) Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. According to the most recent Environment Agency flood maps and the Strategic Flood Risk Assessment covering Merton the site does not have a high flood risk, although current access to the site from the south could be restricted by a flooding event.
Consultee ID: 355146 Full Name: Mr Paolo Sotgiu Organisation: Page 157 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL233 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: I agree in many ways with other people that the nature of South London waste partnership would lead us to fight for our turf against each other on who is going to get recycling plants and waste maagement facilities. So, maybe more thoughts should be placed on how to reduce the amount of waste produced and not simply on how to dispose of it more cheaply, i.e. locally. Said that, there seems to be a waste issue. I am commenting on the Rainbow Park Industrial Estate. The site unsuitable for a waste management plant given its central location to Raynes Park high street, residential area and schools. The area can be easily congested and adding any more pressure (i.e. lorries) would bring the tarffic to a standstill in peak time plus pollution etc. Raynes PArk is slowly improving and growing. A large scale recycling facility would just destroy any progress done so far. Locals have been scared by Workglebe, a private business who came to our town with a proposal to build an organic waste management facility for 100,000 tonnes per year that is fiercely opposed by locals! If that is what we have to benchmark any future plant, the Rainbow Industrial Estate is not suitable. Regards, Paolo Officer's Initial Comment: The points raised are noted. The vision and objectives for the South London Waste Plan promote waste minimisation and re-use as far as is possible through the planning system. This is taken further through proposed policy WP.2 "Waste Minimisation". The issues raised relating to Site 60 including traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Please note that the South London Waste Plan consulted on site 60 (and all other sites) for the principle of waste management developments and is not
related to the specific proposals released in 2008 by a company called Workspace Glebe, known as the "Rainbow Eco Park" Agenda Item 3 Consultee ID: 355189 Full Name: Mr & Mrs F Hodgins Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 65 of 142 Merton Agenda Item 3 Consultee ID: 355189 Full Name: Mr & Mrs F Hodgins Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL239 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Site too close to housing, causing increase in noise and possible pollution. Traffic at that point is almost always extremely heavy during the day, with constant congestion caused by entrance and exit from current site. Even supposing the entrance is widened the increases usage would cause more problems with traffic flow. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 324858 Full Name: Mr Peter Oliver Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL24 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: I object to a waste management facility being built in Merton on site 60 (The Rainbow Park industrial area.) Traffic is already terrible in this area and lorries delivering waste will make a bad situation even worse for local residents. Surely a location in a less central area can be found? This site is right by the main train station and shopping area for Raynes Park, as well as a number of primary schools. Does anyone know the formal process to object? Page 158 Officer's Initial Comment: The points raised are noted. The issues raised regarding Site 60 are important considerations and will require further evaluation and evidence. Consultee ID: 355200 Full Name: Mr J.F.T Hoole Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL241 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: I do think that the site proposed at Raynes Park Station area (old industrial site) No.60 in the plan, is firstly badly placed for access and an already congested approach and public access to station and the shops in Old Kingston Road is bad and the near residential roads first/second etc will be in close proximity to Echo Centre proposed here. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 355227 Full Name: Ms Suzie Graham Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL245 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Site 60 Rainbow Park, I strongly object to the use of this site a s it is totally unsuitable as a waste recycle site. This is a residential area and the surrounding roads would not support the traffic made by a waste site. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 355327 Full Name: Ms Minnie Brueggemann Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 66 of 142 Merton Consultee ID: 355327 Full Name: Ms Minnie Brueggemann Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL269 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: You may not get many replies in writing, but be assured, that there is not a single person in Raynes Park who favours such a development at their doorstep. It is therefore imperative that the residents wishes are respected and not the policy makers, who fail in so many ways and would not dream of having such development at their doorstep in a residential area. Commercial interests must not come first anymore and a radical rethinking should take place and priorities set for a better life for all the citizens. Let us plant trees, not a waste development! I would also advise to observe the traffic around Raynes Park Station, where in the morning and evening your have to wait for 10 minutes to cross Bushey Road/Grand Drive junction. That suffices as a problem in this area. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 355343 Full Name: Mr John Joyce Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL272 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Please note that as a Raynes Park resident, I object most strongly to the Rainbow Park site, Raynes Park (site 60 on your map) being included as a potential site for waste management facilities. The site is in a residential area, and waste management would be a completely inappropriate use for it . I support the group of Merton Councillors who are calling for the Rainbow Park site to be considered as the location for a new school. Page 159 Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 324947 Full Name: Mrs Pauline Davis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL28 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: SIte 60 is an inappropriate site because of its proximity to local railways, housing and schools. Should there be any accident in the operation of the proposed plant there is the potential to create a disaster, with potential release of toxins over a heavily populated area. the level of traffic would swamp local roads adding to a dailycurrent, near gridlock situation . This site is proposed as a 'commercial operation' not a borough initiative and therefore would mostly process commercial waste, and I feel most strongly that the local population should not have to suffer further for something that does not benefit the community. Garth road site already has the space and road system to cope with the additional traffic and building required. The area is not heavily populated and is not in close proximity to main line railway or high numbers of schools. teh Deersite proposal also fulfils similar criteria. Officer's Initial Comment: The points raised are noted and the issues raised relating to Site 60 are important considerations and will require further evaluation and evidence. Commercial waste management facilities can process both household and commercial waste. Consultee ID: 326694 Full Name: Mrs Ann Dolphin Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 67 of 142 Merton Agenda Item 3 Consultee ID: 326694 Full Name: Mrs Ann Dolphin Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL29 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: This site is unsuitable because it is not located with or in association with existing waste disposal site (as laid down in Government Guidelines). Further it is very close to residential property and there are potential access problems to and from the site, with a risk of traffic congestion resulting from the use of the Rainbow site for waste disposal. Officer's Initial Comment: The points raised are noted. The issues raised regarding Site 60 are important considerations and will require further evaluation and evidence. Government guidance states that designated industrial areas should be assessed when searching for sites for future waste management facilities; Rainbow industrial estate is a designated industrial area. Consultee ID: 328866 Full Name: Mr Peter Sykes Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL32 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: The industrial estate is a blight on the area, any new use for it should be approved. Given the largely positive environmental benefits this site should be developed. Given its proximity to the railway station it should also have some publicly accessible element so that people can come and see how small solutions can make a big difference. This would help bring money into Raynes Park. The old LESSA playing field in Raynes Park would also be a suitable site Page 160 Currently it is sighted for development of posh houses - nobody wants that. Preserve some of the green area, open it up and use it for environmental or community purposes. Officer's Initial Comment: The points raised are noted. Consultee ID: 333213 Full Name: Mr Adam Stanislas Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL49 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: I think this site is unsuitable for a couple of reasons. A) there are not sufficient roads to carry additional large scale transport on a regular basis. B) The site is to close to Raynes park town centre. Future recycling/waste disposal systems might prove to have other impacts i.e. smells, noise etc.. and as we are trying to future proof the sites I do not believe the rainbow site is a good choice. Officer's Initial Comment: The points raised are noted and the issues raised relating to Site 60 are important considerations and will require further evaluation and evidence. Issues including smell, traffic and residential amenity have been considered in identifying potential sites and, were a planning application to be received, they would be considered again through proposed policy WP6 Consultee ID: 332373 Full Name: Mr Philip Bickerstaffe Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 68 of 142 Merton Consultee ID: 332373 Full Name: Mr Philip Bickerstaffe Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL50 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: The proposed site would significanlty increase traffic in an already busy area (with likely increase due to the construction of a supermarket on adjoining plot). This would include an the lorries bringing waste and leaving, staff transport, servicing for the facility (all the utilities and support services) etc. The entrance to the site is next to the entrance to a busy commuter train station (a busy interchange with many local bus services); there are several primary schools near by with many parents and children crossing at the entrance to the location; there is a public library within 50 metres of the entrance with a large number of pre- school users; there are a significant number of playschemes in the locality (Raynes Park Methodist Church, St Matthew's Church, Dundonald Church on the A238) etc) there is a busy shopping area near by. Many of the roads in this area are already congested at peak times (especially the A238 leading to the A298). Officer's Initial Comment: The points raised are noted and the issues raised relating to Site 60 are important considerations and will require further evaluation and evidence. Consultee ID: 339860 Full Name: Mr Kevin McCullagh Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL51 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: I believe this site is unsuitable for the following reasons; 1. It is within Raynes Park Town Centre and surrounded by residential properties. The development of a waste treatment facility, with the accompanying increase in HGV movements, noise, dust, smells would undoubtedly have a serious adverse affect the long Page 161 term future viability of this important local shopping centre. 2. The only access to the site is immediately adjacent to Raynes Park station entrance. This is a major transport interchange with high volumes of pedestrian and vehicle movements throughout the day and particularly at peak hours. The current limited movement of HGV's into the site cause major traffic disruption and serious safety risks for all road users. A development of this nature will cause a significant increase in the number of HGV's accessing the site and because the scope for access improvement is very limited the traffic and safety impact will be significant. 3. Intuatively, the development of a major waste treatment facility (which is intended to serve the future needs of four boroughs) within a town centre where businesses are already struggling to survive and close to a major transport interchange would appear to be non-sensical. It is therefore difficult to understand why this site, which has poor access, no capacity for expansion and an already conjested network has been retained on the list of potential sites Officer's Initial Comment: The points raised are noted and the issues raised relating to Site 60 are important considerations and will require further evaluation and evidence. This plan does not propose that any one site would serve the needs of waste arisings from all of the four boroughs. Consultee ID: 200329 Full Name: Mrs. Jill Truman Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL52 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Site 60 - Rainbow Industrial Estate is wholly unsuitable for inclusion in the final shortlist of sites for the South London Waste Plan . It is far to close to the Raynes Park Town Centre, and to residential properties. It will generate far too much traffic via an already restricted access. Of particular concern is the proposal that it should be used as an Eco Park for a bio digestion plant private development). The proposals for this indicate that - apart from all the other Agenda Item 3 factors - the visual impact on adjacent residential properties would be horrendous. Officer's Initial Comment: The points raised are noted. The issues raised above are important considerations and will require further evaluation and evidence. The specific proposals for the Rainbow Estate to be used as an Eco-park are separate from this consultation and were put forward by an organisation that has, to date (October 2009), not submitted a planning application Consultee ID: 345463 Full Name: Howes Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 69 of 142 Merton Agenda Item 3 Consultee ID: 345463 Full Name: Howes Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL55 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: This is not suitable (a) because it is adjacent to and surrounded by residential areas and it is therefore totally unsuitable for development as a waste site as it would impact on air quality and on quality of life in general (b) because access is by a heavily used thoroughfare and would inevitably cause traffic chaos Officer's Initial Comment: The issues raised relating to Site 60 are important considerations and will require further evaluation and evidence. Consultee ID: 346714 Full Name: Mr J. White Organisation: Sustainable Merton Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL63 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: This is a classic exercise of playing off one area in Merton against another. It distracts us from the failure of this strategy to look at the big questions - for example how we can minimise and re-use 'waste'. And it is absurd to expect us to comment on the suitability of local sites, as though all waste treatment methods are the same. For example, are we commenting on Workspace Glebes' plan for the Rainbow Industrial Estate? Or some other waste use? And if it is Workspace Glebes', then any sensible response is 'I don't know - that it all depends - on the size (re traffic, appearance etc.) and the benefits (cut price heating for local homes). Don't let them play us off against each other. We should reject the process until we get a plan with some real vision that will be good for the whole borough. Page 162 Officer's Initial Comment: Waste minimisation is a priority for the four boroughs and as such is set out in the Waste Plan's proposed vision and objectives. Proposed Policy WP.2 "Waste minimisation" sets out how the four boroughs will promote waste minimisation through the planning system. The four boroughs are also involved in other initiatives to encourage householders and businesses to minimise and recycle waste. We are seeking comments around the sites' suitability for waste management facilities in general and possible impacts they may have (such as traffic, impact on residential amenity, ecology etc) Consultee ID: 347830 Full Name: Mrs Charlotte Bennett Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL68 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: The site is located in a mainly residential area, so that access to the site for, presumably, large vehicles would be through residential streets which are completely inadequate to cope with the volumes of traffic. The air quality in the area is already unacceptably poor and use of this site as a waste facility would add to this problem. The site is much too close to two or three schools. Officer's Initial Comment: The points raised are noted and the issues raised relating to Site 60 are important considerations and will require further evaluation and evidence. Consultee ID: 350454 Full Name: Mr Paolo Sotgiu Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL94 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: I agree with some of the other Officer's Initial Comment: Consultee ID: 206191 Full Name: MS Giovanna Bernini Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 70 of 142 Merton Consultee ID: 206191 Full Name: MS Giovanna Bernini Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL97 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Site 60 is totally unsuitable because of too close to residential and schools, plus traffic congestion is already causing difficulties - pollution, noise; danger of explosion near a town centre. Raynes Park is an important train junction, the operation of which could be jeopardised by any problems ensuing on the site. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 are important considerations and will require further evaluation and evidence. Consultee ID: 211690 Full Name: R Bernini Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL99 Is Site Suitable? Site Number: Site 60: Rainbow Park industrial area Site comment: Site 60, Totally unsuitable for the following reasons, too close to residential and schools. Pollution of air, traffic chaos as Raynnes Park is already gridlocked at Approach Road/Grand Drive fro much of the morning and evening. Access to site - how are 2 waste trucks going to pass safely given the width restriction of railway bridge arch? Major upheaval to Raynes Park rail 'hub' should a problem occur with the site affecting the railway. Raynes Park 'Industrial Estate' was never more than a railway siding which was occupied by local firms in the main. It was reasonably organised but the owners have let it become so run down and used by waste trucks which have turned it slummy! It was deemed unsuitable for Tone Scaffolding to expand due to noise, traffic problems, etc so this company moved to Beddington Lane. How can it now be suitable for a company which will cause chaos? Merton rate payers pay the councils wges and as their employers should be entitled to direct the future of the environment, not be dictated to by people who will not be affected by the changes proposed. Page 163 Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 60 including noise, traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD127 Is Site Suitable? Site Number: Site 69: Willow Lane Industrial Estate Site comment: If site 69 (Willow Lane Industrial Estate) were redeveloped, all construction and operational activities should be kept at least 30 m from the River Wandle and noise, light and heat from the site should not increase above (and should endeavour to decrease) current levels. This also applies to parts of site 642. Officer's Initial Comment: The points raised are noted. The issues raised are important considerations and will require further evaluation and evidence, especially regarding sites 69, 642 and other sites bordering the Wandle. Consultee ID: 350514 Full Name: R Bolton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD62 Is Site Suitable? Site Number: Site 69: Willow Lane Industrial Estate Site comment: This looks a strong contender, care to be taken over placing of waste site Agenda Item 3 Officer's Initial Comment: Consultee ID: 355250 Full Name: Mr John Shayler Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 71 of 142 Merton Agenda Item 3 Consultee ID: 355250 Full Name: Mr John Shayler Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL251 Is Site Suitable? Site Number: Site 69 and 22 Willow Lane Site comment: Access lorries, small two lane road (Goat Road) poor access to and from Carshalton Road, danger to public already trying to get to bus stops especially for old, and those with children. Noise and dust pollution. Merton has already allowed plant hire company to make excessive noise, they have received complaints but is still as bad, 6 days a week. moon 17/08/2009 from 7am till 5pm cannot have back door or windows open because of noise (I have been in my house in Carshalton Road for 50 years and it has never been so bad). if we have noise and dust from waste station on top of already bad noise what of our quality of life? The only positive for Merton Council if this goes ahead, would be that they will be able to twin Carshalton Road with Helmand Province. Although they would probably say be quieter there!! Officer's Initial Comment: The points raised are noted. The issues raised relating to Sites 69 and 22 including traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Proposals for any developments of waste management facilities would require a licence from the Environment Agency and the operations of the premises would be monitored in order to keep the licence. Planning permission from the local authority would also be required. Consultee ID: 345096 Full Name: Ms Gwendoline Martin Organisation: Agent ID: Agent Name: Agent Organisation: Page 164 Comment ID: PSPCD22 Is Site Suitable? Site Number: Site 126: Benedict Wharf Whole Site Site comment: Site 22. This is a massive site and backs directly on to the houses on Carshalton Road and Aspen Gardens. The Carshalton Road is a very busy road with lorries entering the Willow Lane Estate from Goat Road and also from Drake Road where it is even difficult for residents to park their cars. Both Goat Road and Carshalton Road have frequent traffic jams - this would lead to more jams and would be dangerous for people wishing to cross the Goat Road and Carshalton Road and even Drake Road. Site 126. This is in close proximity to the Willow Lane Site and also the Deer Park Road Site. There are too many sites in the Mitcham area, making Mitcham a place just for large lorries to come to. There are two schools near the Benedict Wharf Site. The roads are narrow and it will be extremely dangerous for people with their children. Also the pollution from these lorries would be extensive. It is interesting to see there are very few potential sites marked in the Kingston Area or the WImbledon area or South Croydon and most of Sutton. Is Mitcham and the Beddington Park area to be the dumping ground for the waste from other boroughs? Do we all pay the same council tax? Officer's Initial Comment: Noted - concern over traffic related issues including air quality. These are important considerations which require further evidence gathering and consideration. Disagree with point about council tax differentials as this is not relevant. Consultee ID: 324872 Full Name: Mrs Vanessa Malepa Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 72 of 142 Merton Consultee ID: 324872 Full Name: Mrs Vanessa Malepa Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD8 Is Site Suitable? Site Number: 126 Site comment: This site is currently used for waste transfer, the need for which will obviously be reduced in the near future, however the current plans for expansion at this site have not taken into consideration the needs of local residents. The site is located off the road which runs behind our houses, the reasons for our objection are many - set out below: The road in which we live is a small cul-de-sac, apparently in a Conservation Area , which has seen mass development since we moved to the location over twenty years ago. We have already seen development on all sides, the houses to our rear being knocked down to make way for Hallowfield Way, leaving the rear of our properties open to the pollution and noise caused by current levels of HGV traffic; new housing being built to our rear (across Hallowfield Way), and to the front of us in what was previously the vicarage garden; the development of land across Hallowfield Way into a car pound, which has all led to strains on the local infrastructure, noise and light pollution. We are a young family - our children aged one and four - and as such we feel the planned development will be detrimental to our physical and mental health. The noise and pollutants generated during development and subsequent working of the "Eco Park" will be sufficient that we will feel unable to relax in our own home, to open windows, use our back garden (which backs directly onto the proposed new car park!) or to use the playing fields situated at the end of our cul-de-sac, due to this also bordering the former Mitchanol site and from where the entire eco park is visible. The current levels of noise are bad enough, with work often waking us well before 5am - banging, shouting, HGV noise and vibration. The development can only add to this, even when "closed" the gas engine generators will be working and there will be workers slamming car doors right behind our sons' bedroom window. The levels of pollutants emitted into the atmosphere will, we feel, be sufficient for us to question the effect on our children's development. We will feel unable to use any outdoor space locally, also fearing for our health on the walk to school. The local infrastructure cannot cope with the amount of traffic we have at current levels, let alone even more. There are stretches of Church Road where two HGVs or buses cannot pass, and widening the road is not an option; there are stretches of pavement along this area where two people cannot pass, the HGV wing mirrors narrowly Page 165 missing anyone game enough to use them! It will be highly dangerous for our local children if traffic is increased . The nearest primary school has an entrance on what will be the busiest part of Hallowfield Way (the only access road to the site) - its entrance/exit onto Church Road. Hundreds of children enter and exit by this gate, if it is not bad enough that the pollution will increase, there is a great danger when crossing the road. There will be a privacy issue from the roof garden of the visitors centre as this will look directly onto our gardens. Last but by no means least will be the towers needed for the anaerobic digestion process . We feel we do not need to comment to a great extent on these, at 10 storeys high it is so obvious they will make life less desirable in the local area; we will not want to live near such monstrosities, neither will any prospective buyers in what is already a volatile market! The moment anyone enters the road they will see the towers looming and turn around before even viewing the house. If by some miracle we were to achieve a sale it will be for a great deal less than before the plans were submitted, even once the housing market recovers. We are not ignorant to the need to recycle more and "do our bit" to improve the world environment. We also realise a scheme like this looks extremely attractive on paper, the figures seeming impressive. Indeed the park would be an excellent idea - in a completely different location such as an industrial estate or away from densely populated areas where there are a great deal of children. In its current location, SITA needs to scale down - not expand. We feel, as a family, a site in a less predominantly residential area would be favourable - specifically Beddington Lane, Garth Road, or Willow Lane Industrial Park ( sites 9, 702, 22, 69, 127, 100, 17, 21, 97, 18, 57, 532, 533, 534, 5312, 535, 539) - although there is bound to be resistance in any area, these are mainly in areas where waste is already processed and where the sites are larger and have easier access - not situated off a small road with one access point, struggling to cope with current levels. Officer's Initial Comment: Noted - support for sites in certain established locations whilst expressing concern for existing site. Existing and additional traffic, conservation
area issues, quality of existing environment, pollution, noise, privacy, quality of life, health concerns, fumes and emissions, visual impact and Agenda Item 3 other planning issues raised by respondent are important considerations which require further investigation. Consultee ID: 354671 Full Name: D Nanson Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 73 of 142 Merton Agenda Item 3 Consultee ID: 354671 Full Name: D Nanson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL206 Is Site Suitable? Site Number: Site 126: Benedict's Wharf Site comment: Difficult access? Saxon burial ground. Officer's Initial Comment: Noted Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD124 Is Site Suitable? Site Number: Site 127: Willow Lane area by Wandle River Site comment: 641, 651, 127: East of Weir Road, Durnsford Road Industrial Area, Plough Lane industrial estate, Willow Lane area by the river Wandle. The Wandle Trust would only support redevelopment of these sites if it does not degrade the integrity of the River Wandle and its adjacent habitats. In particularly, this means no land take from the River Wandle corridor (and if possible, increasing the width of the land bordering the river which is crucial for the effective ecological functioning of the river), no increase to noise, light pollution, or ambient temperature which will all impact on wildlife and biodiversity. The Wandle Trust would not support development of these sites if they increased the amount of litter in the area, particular falling off recycling collection vehicles: the WT has worked hard for ten years to remove litter from the river and discourage people from discarding rubbish in the river and along the Wandle Trail and, during this time, we have found that the presence of litter encourages fly tipping. In addition, we would like to encourage the local authorities to ensure that all development Page 166 adjacent to the River Wandle creates a positive and safe sense of place, which is achieved through low-rise development fronting onto the river and not turning its back' behind high walls, which contribute to negative space and are associated with feelings of being unsafe and higher crime rates. Officer's Initial Comment: The points raised are noted. Issues including noise, pollution, ecology, have been considered in identifying sites and, were a planning application to be received, would be considered again through proposed policy WP.6. All boroughs seek to ensure safe and inclusive design for developments across their plan areas; this issue is relevant to developments fronting the Wandle Trail and proposed Wandle Valley Regional Park and will also be considered further. Consultee ID: 354060 Full Name: Ms Janice Graham Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL147 Is Site Suitable? Site Number: Site 127: Willow lane area by the Wandle River Site comment: This does not seem a safe place as the Wandle could become contaminated. Officer's Initial Comment: Your comment has been noted. Many of the existing industrial areas within south London are found along the river Wandle, due to its industrial heritage. Issues including pollution have bee considered in identifying sites and, were a planning application to be received, would be considered again through proposed policy WP.6. Any waste management business would also have to be granted a licence to operate by the Environment Agency and would be monitored for pollution and other issues under the terms of the licence. Consultee ID: 349748 Full Name: Miss Hayley Ager Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 74 of 142 Merton Consultee ID: 349748 Full Name: Miss Hayley Ager Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD106 Is Site Suitable? Site Number: Site 136: Deer Park Road site Site comment: As already mentioned, this site is very close to a children's farm and activity centre, the river Wandle and national trust land. In a city such as London, there are few places as tranquil and full of nature and wildlife as Morden Hall Park and to put a site so close to this and Deen City Farm and Merton Abbey Mills would discourage visitors and ruin local's enjoyment of the area, not to mention pollution affecting the wildlife. As a homeowner my prime concern is the value of my house, especially in the current climate, coupled with the fact we bought the house specifically due to the surrounding areas and this would directly affect them. Officer's Initial Comment: The points raised are noted. Issues including ecology and noise pollution have been considered in identifying sites and, were a planning application to be received, would be considered again through proposed policy WP.6. Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD125 Is Site Suitable? Site Number: Site 136: Deer Park Road site Site comment: 136: Development of this site should not take place if it has no impact (not minimal impact) on Deen City Farm and Morden Hall Park, both in terms of disturbing wildlife and the animals at Deen City Farm and traffic safety risks posed to people visiting these resources.
Officer's Initial Comment: The points raised are noted. Issues including ecology, traffic and noise pollution have been considered in identifying sites and, were a planning Page 167 application to be received, would be considered again through proposed policy WP.6. The proposed site is part of the designated industrial area ~(South Wimbledon Business Area) and would remain entirely separate from the park and Deen City Farm. Consultee ID: 347867 Full Name: Mr michael Stubbs Organisation: National Trust Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD27 Is Site Suitable? Site Number: Site 136: Deer Park Road site Site comment: The site at Deer Park Road Industrial estate adjoins National Trust land to the immediate east (the Deen City Farm site) and south, across the tram-line, to Morden Hall Park which is Metropolitan Open Land, Conservation Area and Nature Reserve. We would not in any way seek to oppose the nature of waste facilities as are set out in table 1.3 (i.e. involving composting, biological treatment and anaerobic/pyrolysis) providing that these are compatible with children's activities in the adjoining farm, which provides a valuable local amenity. These detailed assurances may follow on at the detailed planning stage but we would like to draw attention to the Children's Farm use and allotments when deliverability is considered. Officer's Initial Comment: Noted - support for plan approach . Air quality and emissions and local amenity issues are important considerations which require further evaluation at Plan and at application stage and consideration given to possible mitigation. Consultee ID: 349804 Full Name: Mr Denis Bilas Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 75 of 142 Merton Agenda Item 3 Consultee ID: 349804 Full Name: Mr Denis Bilas Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD35 Is Site Suitable? Site Number: 136 (Deer Park Road) Site comment: I object to site number 136 (Deer Park Road) because it is close to my home and I'm not told what exactly this site will contain. I'm not comfortable giving my consent to the future use of this site for any waste management purpose. The plan, overall, looks like an attempt to avoid tackling the waste problem by allocating more landfills throughout the area. Few suggestions as to what a better plan should contain: Ban non-biodegradable packaging in food stores. Minimum price for 1 plastic bag is £1. Huge fines for taking supermarket trolleys out. Big shops must be obliged to accept back the packaging of the items they had sold. Officer's Initial Comment: The purpose of the proposals, as set out in the vision and objectives, is to dispose of less waste in landfill. None of the sites proposed will be used for landfill. The South London Waste Plan focuses on the effects that the planning system can have in managing waste Consultee ID: 354671 Full Name: D Nanson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL210 Is Site Suitable? Site Number: Site 136: Deer Park road site Site comment: Site 136 good communication but too small. Page 168 Officer's Initial Comment: Noted Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD122 Is Site Suitable? Site Number: Site 641: Area east Weir Road, Durnsford Road Industrial Area Site comment: 641, 651, 127: East of Weir Road, Durnsford Road Industrial Area, Plough Lane industrial estate, Willow Lane area by the river Wandle. The Wandle Trust would only support redevelopment of these sites if it does not degrade the integrity of the River Wandle and its adjacent habitats. In particularly, this means no land take from the River Wandle corridor (and if possible, increasing the width of the land bordering the river which is crucial for the effective ecological functioning of the river), no increase to noise, light pollution, or ambient temperature which will all impact on wildlife and biodiversity. The Wandle Trust would not support development of these sites if they increased the amount of litter in the area, particular falling off recycling collection vehicles: the WT has worked hard for ten years to remove litter from the river and discourage people from discarding rubbish in the river and along the Wandle Trail and, during this time, we have found that the presence of litter encourages fly tipping. In addition, we would like to encourage the local authorities to ensure that all development adjacent to the River Wandle creates a positive and safe sense of place, which is achieved through low-rise development fronting onto the river and not turning its back' behind high walls, which contribute to negative space and are associated with feelings of being unsafe and higher crime rates. Officer's Initial Comment: The points raised are noted. Issues including noise, pollution, ecology, have been considered in identifying sites and, were a planning application to be received, would be considered again through proposed policy WP.6. All boroughs seek to ensure safe and inclusive design for developments across their plan areas; this issue is relevant to developments fronting the Wandle Trail and proposed Wandle Valley Regional Park and will also be considered further. Consultee ID: 354103 Full Name: Miss R Dunbavand Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL160 Is Site Suitable? Site Number: Sites 641 and 642 Site comment: much more suitable Officer's Initial Comment: Noted
26 November 2009 Page 76 of 142 Merton Consultee ID: 354638 Full Name: Mr Ian Christie Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL198 Is Site Suitable? Site Number: Sites 641, 642, 651 Site comment: I do not think these sites are suitable as they are located right at the edge of the relevant area, therefore waste transport vehicles will have to (on average) travel further to reach them, with adverse environmental (pollution) impacts. I'm also aware that traffic is particularly bad in the area immediately south of these sites (around Wimbledon/ South Wimbledon/ Culvers Wood) which will result in the waste transport vehicles either sitting in traffic or diverting down quiet residential streets to reach the rest of the South London area. Officer's Initial Comment: The points raised are noted. The issues raised relating to Sites 641,642 and 651 including environmental pollution, traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Consultee ID: 354671 Full Name: D Nanson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL207 Is Site Suitable? Site Number: Sites 641, 642, 651 Site comment: Sites 641, 642, 651 Industrial area but restricted site Officer's Initial Comment: Noted Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Page 169 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD123 Is Site Suitable? Site Number: Site 651: Plough Lane Industrial Area A Site comment: 641, 651, 127: East of Weir Road, Durnsford Road Industrial Area, Plough Lane industrial estate, Willow Lane area by the river Wandle. The Wandle Trust would only support redevelopment of these sites if it does not degrade the integrity of the River Wandle and its adjacent habitats. In particularly, this means no land take from the River Wandle corridor (and if possible, increasing the width of the land bordering the river which is crucial for the effective ecological functioning of the river), no increase to noise, light pollution, or ambient temperature which will all impact on wildlife and biodiversity. The Wandle Trust would not support development of these sites if they increased the amount of litter in the area, particular falling off recycling collection vehicles: the WT has worked hard for ten years to remove litter from the river and discourage people from discarding rubbish in the river and along the Wandle Trail and, during this time, we have found that the presence of litter encourages fly tipping. In addition, we would like to encourage the local authorities to ensure that all development adjacent to the River Wandle creates a positive and safe sense of place, which is achieved through low-rise development fronting onto the river and not turning its back' behind high walls, which contribute to negative space and are associated with feelings of being unsafe and higher crime rates. Officer's Initial Comment: The points raised are noted. Issues including noise, pollution, ecology, have been considered in identifying sites and, were a planning application to be received, would be considered again through proposed policy WP.6. All boroughs seek to ensure safe and inclusive design for developments across their plan areas; this issue is relevant to developments fronting the Wandle Trail and proposed Wandle Valley Regional Park and will also be considered further. Consultee ID: 338855 Full Name: Mrs Ingrid Pastl-Dickenson Organisation: Agenda Item 3 Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 77 of 142 Merton Agenda Item 3 Consultee ID: 338855 Full Name: Mrs Ingrid Pastl-Dickenson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD13 Is Site Suitable? Site Number: Site 651: Plough Lane Industrial Area A Site comment: My comments concern site Numbers 651 AND 641 and 642. It seems impossible to enter more than one site in box Q3c which is not helpful! The recent huge development of 570 flats on Plough Lane have added to congestion in what already was a pollution blackspot. Due to its high residential density this area can no longer be identified as `industrial'. A huge waste depot would bring traffic in Plough Lane and Durnsford Road (an important thoroughfare to St George's Hospital and town) to a complete standstill. Although I broadly welcome a plan to minimise waste and finding an alternative to landfill, an already heavily congested area so close to high density residential developments is not a place for such a waste disposal plant. Officer's Initial Comment: Agree- support for the approach for the plan. Noted comments relating to concerns over traffic and impact on residential quality/character. These are matters of acknowledged importance which will require further evaluation. Consultee ID: 354391 Full Name: Miss Kajal Patel Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL184 Is Site Suitable? Site Number: Site 651: An area of the Plough Lane industrial estate Site comment: Area 651 is totally unsuitable for this waste facility. Since the development of the new apartments at Plough Lane/Durnsford Road, traffic in this area has already increased significantly over the last three years since I have lived here. The last thing we need is extra trucks adding to this already congested area. Page 170 Also, the boundary of this area is very close to many residential areas (not just the new apartments mentioned, but nearer than those are properties on Havelock Road, Kingsley Road and Kohat Road. The Southern boundary of area 651 is also very close to the Mead Park estate, including Chaucer Way and Kipling Drive which looking at the plans I would say are a LOT LESS than 100 metres away. Add to this the primary school on Garfield Road, and the railway line that sits alongside the southern boundary, I really cannot understand why this area is even being suggested. There is also the Garfield Road recreation ground nearby which being an open space should also be taken into account. I totally object to this new waste facility being placed in this area. If this is to go ahead the properties in the immediate area would fall in value, not to mention a deterioration in the quality of life, due to unpleasant smells in the area, increased vermin, and increased pollution. There is also the Wandle Park area to consider as this would be only metres away from this facility. Officer's Initial Comment: The points raised are noted. The issues raised relating to Site 651 including noise, traffic and impacts on local amenity are important considerations and will require further evaluation and evidence. Issues of pollution would also be considered in greater detail by the Environment Agency in the granting and monitoring of a waste management licence and by the local authority via proposed policy WP.6 were a planning application to be received (this applies to all of the sites) Sutton Consultee ID: 206179 Full Name: Dr. Stanislaw Prokop Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD216 Is Site Suitable? Site Number: Site 57: Land west of Beddington Lane adjacent to industrial areas and existing waste management facilities Site comment: Contaminated land group Officer's Initial Comment: Noted. Concern relating to proposal on contaminated land. This requires further investigation. Consultee ID: 206782 Full Name: Mr Mark Leivers Organisation: Sterecycle Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 78 of 142 Sutton Consultee ID: 206782 Full Name: Mr Mark Leivers Organisation: Sterecycle Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD235 Is Site Suitable? Site Number: Site 57: Land west of Beddington Lane adjacent to industrial areas and existing waste management facilities Site comment: Sterecycle supports the specific allocation of Site 57 for the reasons set out within the main body of the representations at Sections 3, 4 and 6.The remaining sites are either; –« within multiple ownership and therefore incapable of providing the requisite degree of certainty regarding future release contrary to national guidance; –« constrained in terms of their deliverability by issues of land value; the requirement for long leases and/or landowner concerns about prejudicing the future use and value of their wider ownership; and/or –« too small to accommodate a strategic waste use and will therefore unnecessarily constrain future options for the delivery of a sustainable waste strategy within South London. Officer's Initial Comment: Noted. Support on behalf of operator for site 57 and concerns raised that other sites do not meet deliverability criteria and therfore cannot contribute to meeting SLWP objectives. Consultee ID: 350729 Full Name: Mr Stewart Keating Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL127 Is Site Suitable? Site Number: Site comment: Underground build? old caves/mine working (i.e. where noise to outside can be controlled and exhaust fumes totally controlled
Officer's Initial Comment: Noted. The Plan seeks to achieve greater proximity of waste treatment from sources of waste. There are no known underground workings in Page 171 the Plan area which meet the locational criteria set out in the London Plan. Consultee ID: 107816 Full Name: Mr Keith Percy Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL174 Is Site Suitable? Site Number: Site comment: I have no problem with the sites proposed bu they are not sufficient for recycling to work well in Sutton, a much more central site is needed. Reasons: There is a serious traffic problem on the A232, which makes journeys to Beddington Lane very difficult at certain times of day. There is a need to reduce traffic through Carshalton. This policy can only exacerbate it. There is a lready a problem with the Kimpton Industrial Estate site. It is that there is a conflict between TFL's wish to keep traffic moving on the A217 and the lack of adequate traffci light time for turning into and out of Kimpton Industrial Estate the current imbecilic policy of operating single file for left and right turns out of the Kimpton Industrial Estate On to the A217 is an example of the lack of attention currently paid to the A217 traffic problem. The sites at Kimpton Industrial Estate and Beddington Lane are to peripheral and result in a great deal of motoring miles, whcih is not a sustainable policy. Officer's Initial Comment: Noted. No additional "more central" site in Sutton has been identified. Consultee ID: 354002 Full Name: MR KEITH MILLAR Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 79 of 142 Sutton Agenda Item 3 Consultee ID: 354002 Full Name: MR KEITH MILLAR Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL179 Is Site Suitable? Site Number: Site comment: VIRIDOR RECYCLING CENTRE: LAND WEST OF BEDDINGTON LANE (SITES 18 & 57) The GLA’s London Plan affords Metropolitan Open Land the same level of protection as Green Belt and maintains its protection from inappropriate development (policy 3D.9).In this regard any proposal that includes MOL should be deemed inappropriate.The SLWP policy objectives reflect this, but the inclusion of Sites 18 & 57 is doubly confusing, given that it is also land designated for the Wandle Valley Regional Park.It is not only incongruous that the proposed sites abut South London’s proposed green lung, but it will also overshadow the much-heralded, sustainable Hackbridge initiative, and is inconsistent with the local community’s belief that Hackbridge will be the ‘greenest place to live in the UK’.The spectre of an enhanced industrial complex will rather shatter that pastoral vision. Under current permissions, when restoration o Beddington Farmlands is complete and there will be public access to the Regional Park all temporary buildings placed on these sites will be removed.However, the four councils will still need to dispose of solid waste and the ability to then do so elsewhere within the boroughs will be extremely limited.Outside, it may be impossible, except at a premium that councils (and ratepayers) will be reluctant, or unable, to pay.Therefore, we should perhaps presume a certain permanency, not apparent in the documentation, as a more realistic option for this development. Beddington Farmlands is a key metropolitan wildlife site; plots 18 and 57 are an integral part of the key strategic framework for biodiversity, as described in the London Plan.Overall, the site is of exceptional importance for birds with nationally important populations of several key species and one of the longest species lists in London.Current bird populations are however already under stress.Implementing further development, in addition to having extended the waste disposal operation on site, from 2015 to 2023, is likely to hasten the on-site demise of several species. The potential harm to the strategic open space and biodiversity objectives in relation Page 172 to the Wandle Valley Country Park proposals mean that inclusion of Sites 18 and 57 is inconsistent with strategic spatial planning objectives.It also underplays their importance as compensation areas.As on-going landfill operations render certain core areas essentially uninhabitable, so these ‘peripheral’ havens have gained in ecological significance; sanctuaries for birds ‘pushed’ from the on-going landfill operations and thereby helping to mitigate the scale of potential losses from the site. The wider consideration for the unsuitability of these sites is that in addition to placing the waste facility on one boundary of the Regional Park; the vision for a sustainable Hackbridge includes the construction of 1,000 new homes.Metropolitan Open Land to the west of the railway line, along London Road, is a prime candidate for such a major development.This is relevant in that the first step in maintaining a true strategic vision for our borough must be to protect what we have now.The removal of sites 18 and 57 from this proposal will add weight to the conviction that our Metropolitan Open Land should be protected – in tact - for future generations. In summary, neither of these sites appears to meet the SLWP’s own planning criteria, as defined against the following SA Objectives: 3. Pollution and Natural Resources; 6. Local Environment and Quality; 7. Open Environment; 8. Biodiversity and Habitats or, indeed, 11. Population, Human Health and Quality of Life.Beddington Farmlands is designated as a Site of Metropolitan Importance for Nature Conservation.Development here, combined with the subsequent loss of Metropolitan Open Land designated for the Wandle Valley Regional Park should be deemed unacceptable. Officer's Initial Comment: Noted. Viridor site is a current managed waste site which if not to continue will require a compensatory allocation in the Waste Plan elsewhere in accordance with the London Plan. Agreed. The Plan needs to better reflect spatial considerations in south L Consultee ID: 354485 Full Name: Mr Mervyn Weston Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL187 Is Site Suitable? Site Number: Site comment: I think that Beddington Lane is the ideal place to site the facility. The further away from populated areas the better. Officer's Initial Comment: Noted Consultee ID: 355200 Full Name: Mr J.F.T Hoole Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 80 of 142 Sutton Consultee ID: 355200 Full Name: Mr J.F.T Hoole Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL242 Is Site Suitable? Site Number: Site comment: Recently I walked the Beddington Trail i.e. Beddington tram stop to Beddington Park and do appreciate the public access hereabouts, on seeing the changing appearance of the Mile Road (now gone) area. I came to no conclusion that this would be the best area for the proposed centre and waste management site in Sutton area, at a later time this are could become a local open space in the Beddington Park area with lagoon and footpath access and landscaped to compliment the immediate area. Sad to notice the Polar Grove at Hackbridge is slowly dting? Officer's Initial Comment: Noted. Consultee ID: 355278 Full Name: Mrs S Nivei Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL258 Is Site Suitable? Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plant that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality.due to dust particles in the air from the plant and also while being transported Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste transfer lorries was Page 173 much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM1O air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35 ... that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential homes whose lives are already blighted by the developments that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area an talk so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Officer's Initial Comment: Noted. Proposals for new waste related development will need to take into account likely traffic, air quality etc issues and mitigation measures. Consultee ID: 355282 Full Name: Mr & Mrs H Palmer Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 81 of 142 Sutton Agenda Item 3 Consultee ID: 355282 Full Name: Mr & Mrs H Palmer Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL259 Is Site Suitable? Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plant that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality due to dust particles in the air from the plant and also while being transported Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste transfer lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35...that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential homes whose lives are already blighted by the developments that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area an talk so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Page 174 Officer's Initial Comment: Noted. Proposals for new waste related development will need to take into account likely traffic, air quality etc issues and mitigation measures. Consultee ID: 355284 Full Name: Philpott Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL260 Is Site Suitable? Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plant that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality due to dust particles in the air from the plant and also while being transported Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste transfer lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35...that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential homes whose lives are already blighted by the developments that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area an talk so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Officer's Initial Comment: Noted. Proposals for new waste related development will need to take into account likely traffic, air quality etc issues and mitigation measures. Consultee ID: 355286 Full Name: Mrs E Corps Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 82 of 142 Sutton Consultee ID: 355286 Full Name: Mrs E Corps Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL261 Is Site Suitable? Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plant that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality, due to dust particles in the air from the plant and also while being transported. Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste .transfer lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35...that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential homes whose lives are already blighted by the developments that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area an talk so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Officer's Initial Comment: Noted. Proposals for new waste related development will need to take into account likely traffic, air quality etc issues and mitigation measures.
Consultee ID: 355288 Full Name: B Corps Organisation: Page 175 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL262 Is Site Suitable? Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plant that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality, due to dust particles in the air from the plant and also while being transported. Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste .transfer lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35...that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential homes whose lives are already blighted by the developments that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area an talk so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Agenda Item 3 Officer's Initial Comment: Noted. Proposals for new waste related development will need to take into account likely traffic, air quality etc issues and mitigation measures. Consultee ID: 355274 Full Name: Mr Colin Newton Organisation: KIPPA BID LTD Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 83 of 142 Sutton Agenda Item 3 Consultee ID: 355274 Full Name: Mr Colin Newton Organisation: KIPPA BID LTD Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL263 Is Site Suitable? Site Number: Site comment: Industrial Waste? Business's spend a lot of money on waste,,what will you do for Business's What consideration is being given to scientific research? The systems employed at the moment are dickensian. As business's have no help with recycling and that is your aim why not work with us? Colin Newton KIPPA BID LTD Kimpton Industrial Park Sutton Officer's Initial Comment: Noted Consultee ID: 355307 Full Name: Mr Alan Kenway Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL265 Is Site Suitable? Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plants that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality due to dust particles in the air Page 176 from the plants and also while being transported Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste transfer lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35.that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential homes whose lives are already blighted by the developments that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area and take so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Officer's Initial Comment: Noted. Proposals for new waste related development will need to take into account likely traffic, air quality etc issues and mitigation measures. Consultee ID: 355313 Full Name: Ms Margaret Ayres Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 84 of 142 Sutton Consultee ID: 355313 Full Name: Ms Margaret Ayres Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL266 Is Site Suitable? Site Number: Site comment: I am writing concerning the location 5312 and others (532, 533, 534, 535, and 539) identified within the LB of Sutton which are specific to the Beddington Industrial Area. The Beddington Industrial Area is directly next to the residential area of Beddington Village, both situated off the Beddington Lane. As you will already be aware the area around Beddington Lane is already suffering from over saturation of recycling and waste facilities. There is currently a second application before the council for a recycling centre of material from road excavations to be situated at 112 Beddington Lane. Looking at your map this would appear to be neighbouring or very near location 5312. The introduction of more waste facilities will mean a further reduction in local air quality for residents. The current recycling plants, sewage treatment plants and general waste management sites already emit strong, overpowering, unhealthy smells, along with, and more dangerously air pollution. The increase in trucks delivering to the sites will also add to the poor air quality within Beddington Village. Not only will there be further exhaust fumes but also dust particles from the loads being carried. This increase in heavy traffic will also be a safety hazard for local residents. The facts are that Beddington is already monitored as an area of poor air quality (WHO Safety Limit of 20 over breached on 288 days within 2008 - as recorded by Beddington Monitoring Station PM10). On consideration of locations for further waste facilities I would urge the appropriate authorities to take account of the health and safety of residents of Beddington Village and remove the Beddington Industrial Area from their list of potential sites. Officer's Initial Comment: Noted. Proposals for new waste related development will need to take into account likely traffic, air quality etc issues and mitigation measures. Consultee ID: 355319 Full Name: G.V Watkinson Organisation: Agent ID: Agent Name: Agent Organisation: Page 177 Comment ID: PSPSL267 Is Site Suitable? Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plants that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality due to dust particles in the air from the plant and also while being transported Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste transfer lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35... that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential homes whose lives are already blighted by the developments that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area and taIk so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Officer's Initial Comment: Noted. Proposals for new waste related development will need to take into account likely traffic, air quality etc issues and mitigation measures.
Consultee ID: 355333 Full Name: C Arnold Organisation: Agenda Item 3 Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 85 of 142 Sutton Agenda Item 3 Consultee ID: 355333 Full Name: C Arnold Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL271 Is Site Suitable? Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plant that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality due to dust particles in the air from the plant and also while being transported Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste transfer lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35... that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential home whose lives are already bliqhted by the developments that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area an talk so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Page 178 Officer's Initial Comment: Noted. Proposals for new waste related development will need to take into account likely traffic, air quality etc issues and mitigation measures. Consultee ID: 355346 Full Name: Mrs D Branch Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL273 Is Site Suitable? Site Number: Site comment: I am writing to protest against the planning in Beddington Lane. My family have lived here for twenty years and over the time we have seen a large increase in pollution, traffic and noise. The Anchor Business Park is behind my house and I have had to call out environment staff to come and hear the noise we suffer from this park, also the pollution that is sent into our garden. As i'm sure you are aware, there was a fire recently there and we have to be evacuated, as there were dangerous goods sotred that could explode. If any other planning is to get the go ahead in Beddington Lane we will suffer more lorry noise, pollution and smells, as my daughter also went to Beddington Park Primary School, we dound she could not go to school on her own due to the amount of lorries driving down Beddington Lane and sometimes not even stopping at the traffic lights. When the roads are went the lorries also throw mud up the curbs and tend to drop lots more stones and objects which affect us other drivers. I understand there is a weight limit to some parts of Beddington Lane and wonder who is checking this on any of the traffic. The amount of traffic we have at the moment and the weight of the lorries are also causing lots of pot holes and dents in the road which could cause accidents. The areas that were highlighted should not get the go ahead for all the reasons I have mentioned. Officer's Initial Comment: Noted. Proposals for new waste related development will need to take into account likely traffic, air quality etc issues and mitigation measures. Consultee ID: 355354 Full Name: Mr H.J Foreman Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 86 of 142 Sutton Consultee ID: 355354 Full Name: Mr H.J Foreman Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL274 Is Site Suitable? Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plant that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality due to dust particles in the air from the plant and also while being transported Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste transfer lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35...that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential homes whose lives are already blighted by the development that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area an talk so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Officer's Initial Comment: Noted. Proposals for new waste related development will need to take into account likely traffic, air quality etc issues and mitigation measures.
Consultee ID: 355491 Full Name: Mr Neil Stocks Organisation: Page 179 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL277 Is Site Suitable? The site is not suitable Site Number: Site comment: I object to the land at Beddington farmlands being used for the South London Waste Plan. The area is an important site in South London for several scarce species of birds which are seriously declining in the London area as a whole.It is alsohas anationally important breeding population of Tree Sparrows. To use this area for the South London Waste Plan would contradict the fact that Sutton Council have recognised the site as important for nature conservation in that they are responsible for theConservation Management Plan for this site.Further the area is designated as a site of Metropolitan Importance for Nature Conservation and is being considered for a SSSI. Temporary recycling facilities at the site have already contributed to a destruction of habitat which together with the attendant disturbance to the area have resulted in a decline of breeding bird species as aforementioned. a permanent facility would hasten this decline. The area presents an opportunity to create a nature reserve which would enhance the wildlife in the area and give an opportunity for local residentsno only to enjoy the amenity but also to provide education in nature conservation to schools in the area etc. Witness the fist class amenity at Barnes Wetlands.It would be a cause for considerable regret if the opportunity is missed in this area of London. Officer's Initial Comment: Noted. Objection to sites in Beddington Farmlands on nature conservation and local amenity grounds. These matters require further investigation. Consultee ID: 355921 Full Name: Mr Roy Dennis Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 87 of 142 Sutton Agenda Item 3 Consultee ID: 355921 Full Name: Mr Roy Dennis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL294 Is Site Suitable? Sites 18 and 57 Site Number: Site comment: I would like to add my objection to the inclusion of sites 18 and 57 at Beddington Farmlands as a potential site into the South London Waste Plan. This land is designated as a site of Metropolitan Importance for Nature Conservation and should be protected as such. It is a site that contains a nationally important breeding colony of tree sparrows, a red data species. A Conservation Management Plan is already in place for the site to protect them along with many other important species. Sutton Council should be taking their responsibility to ensure that not only is this plan implemented in its entirety to protect the site but stop any further encroachment that will degrade it. This site is already under severe pressure and breeding species such as yellow wagtails have already been lost.Beddington Farmlandsis situated within the proposed Wandle Valley Regional Park and would be an ideal site for a flagship urban nature reserve, any further development of the site or Metropolitan Open Land sites adjacent to it should not be considered. We have a one off opportunity to provide this superb local resource in an area of population density equal if not greater than anywhere in the country. Let us not lose this opportunity by further development a site that is already suffering from over development. Officer's Initial Comment: Noted. Objection to sites in Beddington Farmlands on nature conservation, MOL and Wandle Valley Country Park grounds. These matters require further investigation. Consultee ID: 326983 Full Name: Mrs Penny Simeone Organisation:
Agent ID: Agent Name: Agent Organisation: Page 180 Comment ID: PSPSL30 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: To support this, new facilities must be provided. Croydon, Kingston, Merton and Sutton are working together to meet this challenge by developing the South London Waste Plan. Beddington and the surrounding areas are already overloaded with an unreasonable number ofheavy vehicles. The air is polluted; unpleasant smells, dust and noise are the bane of residents in this 'conservation' residential area. Where re-development takes place on existing waste sites, the policy will require the new or enhanced facility to manage the same amount, or more waste than the original facility. The area is over used already. Residents do not want existing waste sites developed, or an existing site to to manage the same amount or more waste. The policy identifies that: Developers will need to show that any proposed waste facility has no significant impacts on local people or the environment. Developers will need to consider a comprehensive list of issues including traffic impact, visual intrusion, impact on open land, air quality, dust, noise, the impact of nature conservation areas, archaeological sites, conservation areas, ground and surface water and the impact of any climate-changing gases produced. Where are the studies that show this? Any thing adding to the industrial activity in Beddington is bound to have an impact on local people and the environment. Officer's Initial Comment: A comprehensive list of issues (including those listed) have been considered at the identification of potential sites and will require further work. Planning authorities will require developers to submit technical reports and evidence to address the issues raised (see draft Policy WP6) Consultee ID: 354743 Full Name: Ms Sandra Pickering Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 88 of 142 Sutton Consultee ID: 354743 Full Name: Ms Sandra Pickering Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL304 Is Site Suitable? The site is not suitable Site Number: Site comment: I would like to state that none of the sites within the Sutton/Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to these plants causes an adverse effect on our enjoyment of life in the area, and to our health. We believe that there would be a serious reduction in our air quality. We already have a number of plants that emit terrible smells, from recycling, sewage treatment and general waste management. The increase would add to the poor air quality due to dust particles from the delivering trucks and the extra plant. Research presented at the Cranford University Annual meeting in 2008 showed that dust on waste transfer Lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35, which is 15 over the WHO limit, and could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness. There would be an over development of industrial plants in close proximity to residential homes, whose lives are already blighted by the developments that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area and take so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Officer's Initial Comment: Noted. Objection to existing and proposed sites in Sutton and Beddington for further development on overconcentration, traffic, health and
quality of life, air quality and nature conservation grounds. These matters require further investigation. Page 181 Consultee ID: 356189 Full Name: Mr & Mrs P Harris Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL306 Is Site Suitable? The site is suitable Site Number: Site comment: We would like to propose the potential site to be in the existing grounds in Beddington Lane Croydon (57, 535, 17, 539). Officer's Initial Comment: Noted. Support for sites in Beddington Lane. Consultee ID: 355925 Full Name: Mr Duncan Thompson Organisation: Newsquest Pension Fund Trustees Ltd Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL310 Is Site Suitable? The site is not suitable Site Number: Site comment: It is considered that 'Site 539 Beddington Industrial Area Zone 9' is an inappropriate location for waste facilities and there is insufficient evidence to support this proposed designation. The siting of waste facilities in this location would impact upon our client's operations and is incompatible with other surrounding land uses. Our client reserves the right to submit further detailed representations in due course. Officer's Initial Comment: Noted. Objection to site as incompatible with surrounding land uses and adverse impact on existing business. This requires further investigation Consultee ID: 356264 Full Name: Ms S Barnes Organisation: Agenda Item 3 Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 89 of 142 Sutton Agenda Item 3 Consultee ID: 356264 Full Name: Ms S Barnes Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL328 Is Site Suitable? The site is not suitable Site Number: Site comment: I object to the land at Beddington farmlands being used for the South London Waste Plan. I understand that Recycling is important but it cannot be used an excuse to destroy a Metropolitan Importance for Nature Conservation. This site is nationally important for Tree Sparrows and Lapwings also breed there, it is also important as a stop over for migrating birds. A number of unusual invertebrates alsorely on this site. It is certainly the best site south of London for wildlife and so should not be destroyed. The area is an important site in South London for several scarce species of birds which are seriously declining in the London area as a whole.It is alsohas anationally important breeding population of Tree Sparrows. To use this area for the South London Waste Plan would contradict the fact that Sutton Council have recognised the site as important for nature conservation in that they are responsible for theConservation Management Plan for this site.Further the area is designated as a site of Metropolitan Importance for Nature Conservation and is being considered for a SSSI. Temporary recycling facilities at the site have already contributed to a destruction of habitat which together with the attendant disturbance to the area have resulted in a decline of breeding bird species as aforementioned. a permanent facility would hasten this decline. The area presents an opportunity to create a nature reserve which would enhance the wildlife in the area and give an opportunity for local residentsnot only to enjoy the amenity but also to provide education in nature conservation to schools in the area etc. Witness the fist class amenity at Barnes Wetlands.It would be a cause for considerable regret if the opportunity is missed in this area of London. Noted. Objection to proposed sites within Beddington Farmlands on nature conservation/ecology grounds.
Officer's Initial Comment: Page 182 Consultee ID: 356341 Full Name: Mr Jefcoate Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL330 Is Site Suitable? Site Number: Site comment: I am contacting you concerning the potential sites for waste management facilities.I live in Beddington Village and my family and i are strongly against any area in beddington being used owing to the fact we have enough in this area. We currently have land fill country skips etc all theses are making the area noisy lots of very large hgv lorries using a little road at all hours day and night. We also have to put up with awful smells and all of theses make the whole area really dirty.I stress again this is a village and a conservation area which no one seems to care about and we all wonder what they are trying to conserve as all these applications that are passed are destroying this little village and nobody seems to care. We all do our bit and recycle but enough is enough in one little area we have more than our fair share on our doorstep and strongly believe this should be put somewhere else. Officer's Initial Comment: Noted. Objection to existing and proposed sites in Beddington for further development on overconcentration, traffic, quality of place, air quality, smells and nature conservation grounds. These matters require further investigation. Consultee ID: 356362 Full Name: Mrs P Simone Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 90 of 142 Sutton Consultee ID: 356362 Full Name: Mrs P Simone Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL333 Is Site Suitable? The site is not suitable Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plant that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality due to dust particles in the air from the plant and also while being transported Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste transfer lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35...that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential homes whose lives are already blighted by the development that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area an talk so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Officer's Initial Comment: Noted. Objection to existing and proposed sites in Sutton and Beddington for further development on overconcentration, traffic, health and
quality of life, air quality and nature conservation grounds. These matters require further investigation. Page 183 Consultee ID: 356367 Full Name: C Higgs Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL335 Is Site Suitable? The site is not suitable Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plant that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality due to dust particles in the air from the plant and also while being transported Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste transfer lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35...that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential homes whose lives are already blighted by the development that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area an talk so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Agenda Item 3 Officer's Initial Comment: Noted. Objection to existing and proposed sites in Sutton and Beddington for further development on overconcentration, traffic, health and quality of life, air quality and nature conservation grounds. These matters require further investigation. Consultee ID: 356384 Full Name: Mr L Page Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 91 of 142 Sutton Agenda Item 3 Consultee ID: 356384 Full Name: Mr L Page Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL338 Is Site Suitable? The site is not suitable Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plant that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality due to dust particles in the air from the plant and also while being transported Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste transfer lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35...that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential homes whose lives are already blighted by the development that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area an talk so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Page 184 Officer's Initial Comment: Noted. Objection to existing and proposed sites in Sutton and Beddington for further development on overconcentration, traffic, health and quality of life, air quality and nature conservation grounds. These matters require further investigation. Consultee ID: 330136 Full Name: Mr. Brian Stanton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL34 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: with reference to the possible site in the Kimpton Road area I am concerned that , as this area has already , and is still being , redeveloped with the planned Linear Park, there will be even more disruption and noise for residents in the area. A new waste site would largely increase the amount of traffic coming into the area and would surely negate the benefits of the linear park when it has been completed. For these reasons I am not in support of Kimpton Road plan. I would hope to attend the relevant L.B.Sutton meeting in September. Officer's Initial Comment: A comprehensive list of issues have been considered in identifying potential sites and are proposed to be considered again at planning application through proposed policy WP6. We note the objection relating to intensification of the existing industrial area and concerns about noise and traffic. The Linear Park will a material consideration at site selection and planning. Consultee ID: 356390 Full Name: Miss C Unknown Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 92 of 142 Sutton Consultee ID: 356390 Full Name: Miss C Unknown Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL341 Is Site Suitable? The site is not suitable Site Number: Site comment: I would like to state that none of the sites within the Sutton and Beddington Lane area should be considered for further development for waste management facilities. The area is already suffering from over saturation of recycling and waste facilities. The increase in traffic along Beddington Lane from trucks transporting the raw material to the plants causes an adverse effect on our enjoyment of life in the area and to our health. We believe that there would be a serious reduction in air quality. We already have a number of plant that emit terrible smells, from recycling plants, sewage treatment plants and general waste management, any more would make life unbearable. The increase of trucks delivering would add to the poor air quality due to dust particles in the air from the plant and also while being transported Research presented at the Cranfield University annual meeting in 2008 showed that dust on waste transfer lorries was much more highly reactive than normal dust and would cause oxidative stress in the lungs when inhaled. Beddington monitoring station PM10 air went over its annual mean World Health Organisation (WHO) safety limits (20) on 288 days of last year (2008). Its annual mean PM10's were 35...that is 15 over the WHO limit, which could cause serious respiratory problems. A number of residents are complaining of serious respiratory problems that are getting worse. Studies have shown that those who live in the vicinity of an incinerator are more likely to give birth to children with defects and illness There would be an over development of industrial plants in close proximity to residential homes whose lives are already blighted by the development that have increased in the area. We believe that there would be an impact to the ecology from the increase of waste treatment facilities that add little to the area an talk so much from it. I urge you to remove the areas around Beddington Lane from your plans on the reasons I have given above. Officer's Initial Comment: Noted. Objection to existing and proposed sites in Sutton and Beddington for further development on overconcentration, traffic, health and
quality of life, air quality and nature conservation grounds. These matters require further investigation. Page 185 Consultee ID: 357617 Full Name: Rev David Wolford Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL355 Is Site Suitable? Site Number: Site comment: I believe a major factor must be adequate road access to any new/extended site. As you are probably aware, at present transport on the road between Wallington and Mitcham is already often at a standstill. It represents a major access route in and out of south London, yet is already a problem area and hardly needs any more heavy and frequent transport added to it.Furthermore, it cannot be widened. I do hope you will take this into consideration when presenting cases for and against each possible site. Officer's Initial Comment: Noted. Traffic issues are relevant to choice of suitable locations for facilities. Consultee ID: 33765 Full Name: Mr Stephen Hart Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL357 Is Site Suitable? The site is not suitable Site Number: Site comment: Beddington Lane may not be Hackbridge, but it is very close. A sustainable suburb shouldn't reqiure incineration. I am concerned about any incinerator and what will be burnt and emitted into the air we breathe. In particular, as part of the South London Waste Plan is it inteneded that rubbish will be brought for incineration from other areas? If so. Why? Agenda Item 3 Officer's Initial Comment: Noted. Further information on waste management site proposals will be included the next stage of the Plan where available. SLWP is required to deal with waste arisings predicted for the SLWP area. Consultee ID: 357630 Full Name: Mr & Mrs Braine Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 93 of 142 Sutton Agenda Item 3 Consultee ID: 357630 Full Name: Mr & Mrs Braine Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL360 Is Site Suitable? The site is not suitable Site Number: Site comment: We were very concerned to receive your letter regarding the forthcoming consultation on potential sites for waste management. Our own Borough, Sutton, has a fairly good history as regards its waste disposal, but this proposed amalgamation of Boroughs seems to us, to be an excuse for Kingston, Merton and Croydon, to dump THEIR waste in OUR Borough. The map you enclosed, shows very clearly, where you all want your waste to end up. A pretty obvious NIMBY situation! (Not In My Back Yard). Beddington Lane already has more waste disposal sites than it needs. WE have to live with the obnoxious smells which invade our homes, the dust and dirt and general rubbish, which make the area an eyesore. The large number of vehicles using the sites do not help the congestion in this very busy area. The insidious growth of such sites is becoming intolerable. We do not want any more, neither do feel the area can accomodate any more. ENOUGH IS ENOUGH ! Officer's Initial Comment: Disagree. Beddington sites have been identified through accepted methodology applied to London Plan criteria. Noted. Objection to proposed sites in Beddington on grounds of smells, dust and dirt, visual quality, traffic and overconcentration of waste facilities.. These require further investigation. Consultee ID: 34218 Full Name: Mr Ray Hilldrup Organisation: Kimpton Residents' Action Group Agent ID: Agent Name: Agent Organisation: Page 186 Comment ID: PSPSL370 Is Site Suitable? The site is not suitable Site Number: Site comment: With reference to the proposed extension to exisiting rrc on kimpton industrial estate in sutton. on refering to the information shown on the website in the local librarythere is no indication where this new extension would be located. the existing RRC is already to small and in the wrong location. it is adjacent to local housing. the only vacant plot is adjacent to the infants school in ridge rd.if access is to be made to this plot the new footpath would no longer be viable. the residents of hamilton ave along with those in ridge rd. think that enough damge has been done within a residentail area. noise levels have been monitored and at present are onlyjuse acceptable. what will this be like when the whole estate is up and running. however residents do not know what the plan consists of. perhaps there will be a further rrc. the letter suggest that these plans have already been drawn up. where can these plans be reviewed. Officer's Initial Comment: Noted. Further information on type of facilities with be set out in next stage of plan where available. Objection to exisitng RRC site being close to residential area and too small. Concern at proximity to school, residential quality and noise. These require further investigation. Consultee ID: 347590 Full Name: Mr Gareth Lewis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL388 Is Site Suitable? Site Number: Site comment: I would like to voice my opposition to the inclusion of sites 18 and 57 as potential for the building of waste management facilities. Both sites are within the Beddington Farm area which is important for both migrating and breeding birds. Such devopment would prove detrimental for the protection of habitat for scarce and declining species such as Tree Sparrow, Yellow Wagtail and Little Ringed Plover. Officer's Initial Comment: Noted. Objection to proposed sites within Beddington Farmlands on nature conservation/ecology grounds. Consultee ID: 33887 Full Name: R.J Bourton Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 94 of 142 Sutton Consultee ID: 33887 Full Name: R.J Bourton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL398 Is Site Suitable? The site is not suitable Site Number: Site comment: As a Beddington resident it is inevitable that with a large amount of industry in this area it would be a popular site. However, prevailing winds would take any potential 'fallout' away from us and towards West Thornton residents. There would be ample opportunity for heat/power customers to be found. Officer's Initial Comment: Noted. Comments relating to Beddington and wind carried polution and opportunities for heat/power in locality Consultee ID: 332048 Full Name: Mr Johnny Allan Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL40 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: The Viridor Recycling Centre (VRC) and the Land West of Beddington Lane Adjacent to Existing Waste Management Facilities (LWBL), should NOT be considered in relation to the South London Waste Plan. The VRC (which will no longer exist in 2023), is on land which is earmarked for a major urban nature reserve and part of the Beddington Farmlands (BF), which is a designated Site of Metropolitan Importance for Nature Conservation and a potential SSSI. The VRC is already having a detrimental effect on the locally, regionally and nationally important bird species which breed at and use the site. The LWBL, which is Metropolitan Open Land, plays an integral part in ensuring that the important bird species on the rest of BF survive. These species use the whole of BF including the LWBL I would draw your attention to the Conservation Management Plan for BF: The objective of the Conservation Management Plan is to retain the important breeding populations on site through the development at BF. Several of the species are unlikely to re-colonise if lost from the site. The most important species were selected as target species that are monitored during the course of the development. Since the development, one species (Yellow Page 187 Wagtail), has been lost, two have not bred since 2005 (Redshank and Little Ringed Plover), two show large declines (Sedge Warbler, Reed Bunting), one that has declined in the last two years (Tree Sparrow), leaving only two that are faring reasonably well (Lapwing and Reed Warbler). All will be lost should further disturbance occur. I would remind the London Borough of Sutton of their responsibility to fully carry out their obligations with regard to the Conservation Management Plan. Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 332055 Full Name: Mr Kevin Guest Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL41 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: The Viridor Recycling Centre and the Land West of Beddington Lane Adjacent to Existing Waste Management Facilities. I do NOT think this area should be considered in relation to the South London Waste Plan. The site is on land which could develope a major urban nature reserve. Beddington Farmlands is a designated site of Metropolitan Importance for Nature Conservation and a potential SSSI. The area does not have a nature reserve which would act as an educational facility for future generations. Beddington Farm is ideally situated between Mitcham Common and Beddington Park which are open spaces for general access to the public. The land reffered to is Metropolitan Open Land which acts as a buffer zone which allows important bird species on Beddington Farmlands to survive. There is a Conservation Management Plan for Beddington Farmlands which monitors a select list of breeding populations of target Agenda Item 3 species. Some of these species have already been lost on the farm and have not returned to breed. eg Yellow Wagtail. This will happen to other species if a recycling unit exists. Beddington Farmlands is famous for its Tree Sparrow population, which is an isolated population. The existance of this and other species would be threatened as a result. Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 358051 Full Name: Lonny Prescott Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 95 of 142 Sutton Agenda Item 3 Consultee ID: 358051 Full Name: Lonny Prescott Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL412 Is Site Suitable? The site is suitable Site Number: Site comment: Any site in Suttton is o.k with me, as long as recovery of energy is beneficial for the local people. Officer's Initial Comment: Noted. Support for sites in Sutton where benefits for local people in energy recovery. Consultee ID: 332056 Full Name: Mr Paul Walker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL42 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: The area west of Beddington Lane adjacent to the existing waste facilities should on no account be the site of the recycling plant for the South London Waste Plan. This area is designated as a site of Metropolitan Importance for Nature Conservation and is indeed being considered for a SSSI. Urban nature reserves are a vital ingedient of the conservation environment, and the area of Beddington Farm is the most important site in South London, arguably London. The farm supports breeding Lapwings, Reed Buntings and, most importantly, Tree Sparrow. Indeed it is now one of the major sites in the country for Tree Sparrow, a species that has declined by more than 90% in the last 30 years. The London Borough of Sutton has an obligation to meet the criteria defined by the Conservation Management Plan. I accept the need for recycling, but the area to the west of Beddington Lane remains a vital open space for many of the UK's breeding birds that are under so much pressure nationally. I urge the consultation process to reject this area most strongly. Page 188 Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 332057 Full Name: Mr Nicholas Gardner Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL43 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: The following is what I wrote:- I object to the Viridor Recycling Centre (VRC) and the Land West of Beddington Lane Adjacent to Existing Waste Management Facilities (LWBL) being considered for the South London Waste Plan. The fact that both these sites are being considered underlines the lack of commitment of the present Liberal Democrat dominated council to meeting its own biodiversity action plan. LWBL is an area of Metroplitan Open Land (MOL), while even more alarming is the fact that the VRC is supposedly meant to be restored to wet grassland. In this context I would urge London Borough of Sutton (LBS) to show the necessary visionary leadership to respect the Conservation Management Plan and give the citizens of South London the urban nature reserve they deserve. It is interesting to see that in the more affluent borough of Kingston, the necessary foresight has been shown in creating an urban nature reserve at the Barnes London Wildfowl and Wetland Centre. Should the citizens of the more impoverished boroughs of Croydon, Sutton and Merton draw the conclusion that their lot is to have to a giant recycling centre and the opportunity to educate local school children in field-based learning has been squandered? To date the lack of direction from the LBS in terms of meeting its commitments to the Conservation Management Plan is having a negative impact on the site's biodiversity. Key target species that were previously considered crucial for sustaining are either extinct (Yellow Wagtail) or on the verge of extinction (Sedge Warbler, Reed Bunting etc). Initiatives introduced by LBS such as the development of adjoining MOL (eg BEDZED), the construction of a large recycling centre and the apathy shown to the illegal clearfelling of a mature woodland are all contributing to a significant decline in the site's biodiversity. Now is the time for LBS to give citizens of South London what they desrve - an urban nature reserve that can be treasured by future generations. Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 332048 Full Name: Mr Johnny Allan Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 96 of 142 Sutton Consultee ID: 332048 Full Name: Mr Johnny Allan Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL44 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: The Viridor Recycling Centre (VRC) and the Land West of Beddington Lane Adjacent to Existing Waste Management Facilities (LWBL), should NOT be considered in relation to the South London Waste Plan. The VRC (which will no longer exist in 2023), is on land which is earmarked for a major urban nature reserve and part of the Beddington Farmlands (BF), which is a designated Site of Metropolitan Importance for Nature Conservation and a potential SSSI. The VRC is already having a detrimental effect on the locally, regionally and nationally important bird species which breed at and use the site. The LWBL, which is Metropolitan Open Land, plays an integral partin ensuring that the important bird species on the rest of BF survive. These species use the whole of BF including the LWBL I would draw your attention to the Conservation Management Plan for BF: The objective of the Conservation Management Plan is to retain the important breeding populations on site through the development at BF. Several of the species are unlikely to re-colonise if lost from the site. The most important species were selected as target species that are monitored during the course of the development. Since the development, one species (Yellow Wagtail), has been lost, two have not bred since 2005 (Redshank and Little Ringed Plover), two show large declines (Sedge Warbler, Reed Bunting), one that has declined in the last two years (Tree Sparrow), leaving only two that are faring reasonably well (Lapwing and Reed Warbler). All will be lost should further disturbance occur. I would remind the London Borough of Sutton of their responsibility to fully carry out their obligations with regard to the Conservation Management Plan. Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 332054 Full Name: Mr Peter Alfrey Organisation: Agent ID: Agent Name: Agent Organisation: Page 189 Comment ID: PSPSL440 Is Site Suitable? Site Number: Site comment: I have had a problem using your website to leave a comment about future sites for the SLWP. I hope it is okay if I send the comment here. Beddington Farmlands is Metropolitan Open Land and is currently undergoing restoration to a major urban nature reserve. The site has a current and historical rich ecosystem which includes 250 bird species of which over 150 utilise the site annually- for breeding, wintering and migration. Due to current quarrying and landfill activities this rich avifauna is experiencing a lot of pressure and has contracted consequently. These losses over recent years have been tolerated, seen as a necessary part of process in the establishment of a permanent and managed premier urban nature reserve- a vision which was laid out as part of the planning permission resulting from the public enquiry. Therefore I strongly object to Beddington Farmlands as being considered as site for any waste facilites in the SLWP. The public enquiry conclusion was that the ultimate land use for Beddington Farmlands was that of a nature reserve and is important that vision is upheld. All waste facilites at Beddington Farmlands at present are temporary and will be decommissioned following the quarrying and landfill operations. Officer's Initial Comment: Noted. Objection to proposed sites in Beddington Farmlands as incompatible with vision for area and nature conservation objectives. These matters require further consideration. Consultee ID: 358364 Full Name: Mr and Mrs Rob and Barbara Robb Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 97 of 142 Sutton Agenda Item 3 Consultee ID: 358364 Full Name: Mr and Mrs Rob and Barbara Robb Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL448 Is Site Suitable? The site is suitable Site Number: Site comment: My wife and I would like to place on record our thoughts on the siting of the new Waste Incinerator. Firstly we agree that there needs to be an alternative to Land Fill and technology now allows an Incinerator to be one of the answers. We have seriously thought about it rather than having just a NIMBY attitude. The idea for the incinerator is for the Group of Councils to go green. Adding to this theory, you would want the waste from all four Boroughs to cumulatively keep the pollution to a minimum. We assume large vehicles will be transporting waste to the central point, as they don't have rail access between the waste sites. Looking at keeping road miles to a minimum, the number of trips (taking into account population sizes for each Borough) and the associated pollution exhaust and noise. Plus the site to be placed where it would cause the least visual pollution to existing surroundings. Taking the above points into mind we feel the best place for the site would be the existing site at Beddington Industrial Area. The Beddington Industrial Estate would not suffer from an Industrial building and already has large chimney stacks in the vicinity. It is close to a large class A road i.e. A23. Accumulatively it would give the lowest road miles for the waste to travel from all Boroughs. Officer's Initial Comment: Noted. Further information on type of facilities with be set out in next stage of plan where available. support for reduction in landfill. Support for proposal in Beddington for central facilitiy for four boroughs to reduce driven distances, access to p Consultee ID: 358381 Full Name: Mr Robin Lathey Organisation:
Agent ID: Agent Name: Agent Organisation: Page 190 Comment ID: PSPSL453 Is Site Suitable? Site Number: Site comment: It is my view that the best location for a waste planet would be Beddington Lane as this already has a number of recycling points and possible road improvement opportunities. Church Road MItcham is not a good location as it is close to schools and residential areas. A more suited location would be off Sutton by pass where there is a lot of open space where the council also has a recycling centre used to be a waste centre (tip). other options could be riverside locations utilising the Thames. Officer's Initial Comment: Noted. Objection to Church Road site due to proximity with incompatible land uses (residential and education). Support for sites in Beddington (with road improvements), Kimpton and for riverside locations close to River Thames. Consultee ID: 332809 Full Name: MR MICHAEL SPICER Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 98 of 142 Sutton Consultee ID: 332809 Full Name: MR MICHAEL SPICER Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL48 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: The Viridor Recycling Centre (VRC) and the Land West of Beddington Lane Adjacent to Existing Waste Management Facilities (LWBL), should NOT be considered in relation to the South London Waste Plan. The VRC (which will no longer exist in 2023), is on land which is earmarked for a major urban nature reserve and part of the Beddington Farmlands (BF), which is a designated Site of Metropolitan Importance for Nature Conservation and a potential SSSI. The VRC is already having a detrimental effect on the locally, regionally and nationally important bird species which breed at and use the site. The LWBL, which is Metropolitan Open Land, plays an integral part in ensuring that the important bird species on the rest of BF survive. These species use the whole of BF including the LWBL I would draw your attention to the Conservation Management Plan for BF: "The objective of the Conservation Management Plan is to retain the important breeding populations on site through the development at BF. Several of the species are unlikely to re-colonise if lost from the site. The most important species were selected as target species that are monitored during the course of the development. Since the development, one species (Yellow Wagtail), has been lost, two have not bred since 2005 (Redshank and Little Ringed Plover), two show large declines (Sedge Warbler, Reed Bunting), one that has declined in the last two years (Tree Sparrow), leaving only two that are faring reasonably well (Lapwing and Reed Warbler). All will be lost should further disturbance occur." I would remind the London Borough of Sutton of their responsibility to fully carry out their obligations with regard to the Conservation Management Plan and respectfully request that these siters be deleted from those currently being considered. Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 343487 Full Name: Miss Dawn Robinson Organisation: Agent ID: Agent Name: Agent Organisation: Page 191 Comment ID: PSPSL53 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I cannot understand how the land west of Beddington Lane can even be considered to have more development. This land has already shown a massive decline in the amount of species resident and used on passage migration. If this land is developed then an opportunity for an open green space / nature reserve for the local area will be lost. Already there has been the felling of a mature area of oak woodland close to the proposed site, this was done illegally and we have lost a bat breeding colony which should have been protected. I think that the proposal of this land shows the local councils disregard for nature, the environment and the local residents. Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 33627 Full Name: Mr Andrew Banfield OBE Organisation: Mitcham Common Conservators Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL547 Is Site Suitable? Site Number: Site comment: I write on behalf of MITCHAM COMMON CONSERVATRS who own and manage Mitcham Common. The Board have considerd the SL Waste Plan aad have the follwing comments. Site 57 - Beddington Sewage Works. The Board oppse thet re-designation of the Metroplitam Open Land (MOL) in particular, and indeed the re-designating of any MOL for wasre relted purpses. Agenda Item 3 Officer's Initial Comment: Noted. Objection to proposed sites within Beddington Farmlands on MOL grounds. Consultee ID: 346042 Full Name: Mr Des McKenzie Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 99 of 142 Sutton Agenda Item 3 Consultee ID: 346042 Full Name: Mr Des McKenzie Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL56 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I strongly object to the proposals that involve Beddington SF. This is an exceedingly important site for breeding Tree Sparrows and any development is likely to impact negatively upon the future breeding success of this species. Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 346137 Full Name: Smart Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL57 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I am amazed that Beddington SF is on the list of potential sites within the South London Plan. I urge you to take note of this land as a designated site of Metropolitan Impotance for Nature Conservation and is a potential SSSI. This is an impotant breeding area for several bird species - I would like to draw you attention to the conservation Management Plan for BF. The objective of the Conservation Management Plan is to retain the important breeding populations on site through the development at BF. Several of the species are unlikely to re-colonise if lost from the site. The most important species were selected as target species that are monitored during the course of the development. Since the development, one species (Yellow Wagtail), has been lost, two have not bred since 2005 (Redshank and Little Ringed Plover), two show large declines (Sedge Warbler, Reed Bunting), one that has declined in the last two years (Tree Page 192 Sparrow), leaving only two that are faring reasonably well (Lapwing and Reed Warbler). All will be lost should further disturbance occur. I would remind the London Borough of Sutton of their responsibility to fully carry out their obligations with regard to the Conservation Management Plan This is a very important site within the Borough and one that the Borough should be proud to be associated with as many people come from other areas of West London to visit. Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 346302 Full Name: Mr. Grant Prater Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL58 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I object to the South London Waste Plan using site 18 and site 57 which are Beddington Farmlands because any more development there will destroy the nationally important wildlife. It is time Sutton Council fully implemented the Conservation Management Plan for this site. Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 33383 Full Name: Mr Tom Brake MP Organisation: Constituency Office Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL590 Is Site Suitable? The site is suitable Site Number: Site comment: With regards to the sites identified in the consultation document, it is my view that any site identified as suitable for a waste management facility should be located as far from residential and business premises as possible. Of the sites identified in the consultation plan, site 18, the Viridor site, would appear to be the most suitable. Officer's Initial Comment: Noted. Preference for sites distanced from residential and business premises and support for an existing site (Viridor) Consultee ID: 361473 Full Name: Mr Keith Miller Organisation: Beddington Bird Farm Group Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 100 of 142 Sutton Consultee ID: 361473 Full Name: Mr Keith Miller Organisation: Beddington Bird Farm Group Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL592 Is Site Suitable? The site is not suitable Site Number: Site comment: Site 57: Develoment Encroachment As stated, Beddington Farmlands is a MOL, SMI and will form an integral part of the Wandle Valley Regional Park. Site 57 falls within these designations. The Farmlands are surrounded by urban development and the peripheral areas are particularly valuable, forming a buffer zone around its core. Development in the past has led to loss of land and we consider that further attempts at development will further, critically, impact on the site's ability to provide sufficient compensation areas for wildlife ejected from the core by landfill operations. As these operations render certain core areas essentially uninhabitable, so peripheral havens have gained in ecological significance, mitigating the scale of potential losses from the Farmlands. De- designation of MOL The Core Planning Strategy proposed that Site 57, amongst others, should be de-designated as MOL has, I understand, not been upheld by the Inspector's Report on the Core Planning Strategy, published in September. In building the evidence base for the Core Planning Strategy, the Council commissioned an ecological appraisal by MKA Ecology Ltd on the parcels of land along Beddington Lane, including Site 57. It considered the value of the land in isolation and that the impact on the rest of the SMI if it were to be developed. Having studied the appraisal, the BFBG would strongly support the consultant's assessment and conclusions. MKA Ecology's evidence concludes that the loss of this land (even given its current unmanaged' status), would negatively affect the integrity of the MOL/[SMI]'. The negative impacts can be grouped into three categories: sludge management, construction/ operation of industrial buildings and loss of foraging/breeding habitat for birds and bats. Within each category there is a negative impact rating of very high'. Objective 1 of the London Plan is to accommodate London's growth within its boundaries without encroaching on open space. Beddington Farmlands is recognised as a SM of Metropolitan Importance in the London Plan and is accordingly protected under Policy 3D.14. The Inspector's Report rejected the Council's reasons to justify de-designation of MOL since if the reasons were to be treated as exceptional circumstances, the same or similar arguments could be applied too frequently to other areas of MOL or open space across Greater London and so undermine Green Belt/MOL policy' (3.28): A consequence of the Inspector's Page 193 retention of MOL means that the de-designation of SMIs' has no basis and cannot be supported' (3.36). Site Assessment Process The site assessment process identified a long list of sites in the first consultation exercise. We note that the assessment scored the top 12 sites that are likely to be developed for waste management facilities (Table 8.7 in the Sustainability Appraisal). Site 57 was amongst these 12 sites, but we would challenge this site being considered so strongly for the following reasons: Metropolitan Open Land (MOL): We are pleased and strongly endorse MOL being one of the criteria in the site assessment process. We note that Site 57 has been treated as de-designated Metropolitan Open Land in accordance with Sutton's Core Strategy' (Appendix 4). Now that the Inspector's Report on the Core Planning Strategy has been published and found against the de-designation of MOL, the score should be recalculated treating the land as MOL. Nature Conservation: We are pleased and strongly endorse nature conservation being one of the criterion in the site assessment process. There are two criteria used: national and locally important sites. Beddington Farmlands has a low score for the national criteria (of which there but a few eligible sites) but a high score for local criteria. Beddington is of regional importance yet it receives the same score as a site of local importance? This requires re-evaluation. We consider that the scoring system should accurately reflect the site's importance. We also consider that it should reflect the size of the site. It may be argued that large sites could accommodate some loss in area, however, it is large sites, such as Beddington Farmlands, that act as reservoirs for species to colonise smaller sites. Without the large sites, small sites are likely to have less biodiversity. The relative scale of Beddington Farmlands means it is more worthy of protection than a smaller area. As the Chief Executive of the RSPB commented in the editorial of the September issue of Birds: "Nature needs a network of sites to help species survive and allow them to shift distribution in the face of climate change...but the current network of protected areas is too small and may not be up to the job of meeting nature's needs in the future". We need more sites, bigger sites and better managed sites". Open Space and Public Rights of Way Beddington is a large open space that currently has no public rights of way and so the scoring system gave a high score for both criteria. However, the site will become part of the Wandle Valley Regional Park and open to the public. If the scoring system Agenda Item 3 had looked longer term, then Beddington would have had a lower score. In summary, we consider that the assessment process is severely flawed for this site. Had the criteria been applied more appropriately, then the score would have been much lower and Site 57 would not have appeared amongst the top 12 scoring sites. The site is identified as having no deliverability constraints and early deliverability opportunities have been identified' (Table 5.7 Sustainability Appraisal). This statement was made before the Inspector ruled that MOL has to be maintained. Presumably there now would be delivery constraints. We recognise that development can be permitted on MOL but it does have to meet more stringent criteria and would be an obstacle to development. This should be reflected. We consider that the sites proposed on the Beddington Industrial Estate are much better candidates than Site 57 and would like to see waste management facilities developed on these sites. We do not able feel able to comment about the sites outside the Borough of Sutton.
26 November 2009 Page 101 of 142 Sutton Agenda Item 3 Consultee ID: 361473 Full Name: Mr Keith Miller Organisation: Beddington Bird Farm Group Agent ID: Agent Name: Agent Organisation: Officer's Initial Comment: Noted. Supplementary comments to lodged objection to sites in Beddington Farmlands and request for reassessment of site scores. Consultee ID: 361473 Full Name: Mr Keith Miller Organisation: Beddington Bird Farm Group Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL593 Is Site Suitable? The site is not suitable Site Number: Site comment: The Viridor Recyling Centre at Beddington Farmlands is one of the existing waste management sites with no delivery constraints yet identified' (Table 2.2). The Plan regards the centre as permanent and the London Plan and the proposed policy WP3 seek to protect existing waste management sites. It is perhaps notable that the four councils involved in the SLWP partnership will continue to need access to affordable facilities to dispose of solid waste and their ability to do so without this centre will be severely constrained, both in the identification of alternative sites, especially outside the boroughs and on cost. However, that should not be sufficient grounds to assume even a degree of permanency in relation to the recycling centre. In the initial planning application for the recycling schemes at Beddington and every subsequent application, there have been planning conditions imposed that the recycling schemes are temporary and will be removed at the end of the landfill development. Beddington Farmlands has a planning consent to be restored for wildlife and people after the gravel extraction and landfill. Much of where the recycling schemes are sited should become wet grassland, a very important habitat in the final restoration. Although we accept that this does not preclude planning applications being made in the future for extensions of the current consent, we believe that the Plan must properly reflect planning law, rather than a future, hypothetical situation. A recycling centre in the heart of MOL, SMI and Regional Park would appear highly incongruous, (not Page 194 only for the people of Hackbridge!), and threatens our vision of a major urban nature reserve. Officer's Initial Comment: Noted. Supplementary comments to lodged objection to Viridor sites in Beddington Farmlands and request for reassessment of site scores. Consultee ID: 361608 Full Name: Mr John Davis Organisation: RSPB Croydon Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 102 of 142 Sutton Consultee ID: 361608 Full Name: Mr John Davis Organisation: RSPB Croydon Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL614 Is Site Suitable? The site is not suitable Site Number: Site comment: We should like to register our concerns as to the prominence given to the Beddington sites in the document. As our group has pointed out at your various roadshows, Beddington Farm is an area of national importance for Tree Sparrows. The plight of a few hundred birds may seem insignificant to planners budgeting for such important processes, but these birds represent the largest breeding flock of Tree Sparrows in the UK. Ongoing research into the habits, fledging and dispersal of this highly endangered species is ongoing at Beddington Farmlands. It is vital to protect not only the site where breeding nest boxes are situated, but also the peripheral sites that offer protection and a natural food source. As a result of the previous consultation, it became policy to "consider the impact of facilities on local nature conservation areas, as well as nationally important areas. We included this in the site assessment process." Yet 8 of the 28 identified sites are at Beddington, with a further 5 in the vicinity. In the August edition of the BBC "Wildlife" magazine, there appeared an article headed "Go Wild in the Capital - A Wild Weekend in London" compiled by David Lindo, that identified 10 sites around London that were hotspots for wildlife. Number 10 on his list was Beddington Farm. He wrote "The final stop on our tour this weekend was briefly my local patch back in the 1980s when it was a sludgy, smelly sewage works, with restricted access, so my return this year to take another look was a real eye-opener. Allied to the futuristic Hackbridge sustainable suburb project, it has an enviable bird list, with at least 150 species recorded every year. Migrating raptors are one of the highlights, with nationally scarce species such as Honey Buzzards passing through in most years; this spring more than 50 Common Buzzards drifted over in 3 days! During late summer expect to see migrants including seabirds such as Arctic Skuas and Kittiwakes. The site also has the honour of hosting Britain's largest breeding population of Tree Sparrows." We should also mention that there were rather vague responses given by a number of planners at the consultation evenings when asked about the extent to which current operators would be used. The equation to assess the areas of land required for waste disposal within the 4 boroughs surely is affected by these current operatives, including Viridor at Beddington [Site 18]. The size of each plant, given the five types of waste disposal identified, was also a Page 195 question left unanswered, other than to say that technology changes daily, so plant sizes diminish'. The answers to these questions would surely dictate the amount of "new" land - whatever the chosen sites - needed to fulfil the requirements. Whilst asking that Beddington Farm sites be flagged as "sensitive", we should also like to know what impact any decision to use the Beddington sites would have of the proposed Wandle Valley Regional Park. The Beddington Farmlands are a cornerstone of this major Park's formation, as it is planned that the land be "returned to nature" once gravel extraction and landfill operations have been completed Officer's Initial Comment: Disagree. Beddington sites have been identified through accepted methodology applied to London Plan criteria. Noted. Objection to proposed sites in Beddington Farmlands on nature conservation, and Wandle Valley Country Park grounds. These require further investigation. Further information on waste management site operations etc will be put forward at the next stage where this is known. Consultee ID: 32862 Full Name: Mr Derek Coleman Organisation: Sutton Group Wildlife Trust Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL636 Is Site Suitable? Site Number: Site comment: The SLWP has a direct effect on what we consider to be the most important wildlife site in the Borough, Beddington Farmlands, so are representations are focussed on this site. Beddington has important breeding, wintering and passage populations of birds t
Officer's Initial Comment: Noted. Objection to proposed and existing sites in Beddington Farmlands on nature conservation, MOL and Wandle Valley Regional Park Agenda Item 3 grounds. These require further investigation. Consultee ID: 32862 Full Name: Mr Derek Coleman Organisation: Sutton Group Wildlife Trust Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 103 of 142 Sutton Agenda Item 3 Consultee ID: 32862 Full Name: Mr Derek Coleman Organisation: Sutton Group Wildlife Trust Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL637 Is Site Suitable? The site is not suitable Site Number: Site comment: ENCROACHMENT BY DEVELOPMENT - SITE 57. De-designation of MOL Beddington Farmlands is MOL, a SMI and part of the Wandle Valley Regional Park and site 57 falls within these designations. Beddington Farmlands is surrounded by development and already has suffered encroachment. The periphera areas are particularly valuable as a buffer zone to the central site such that any more loss of land will be detrimental in itself and have an adverse impact on the wider site. The Core Planning Strategy proposed that site 57 along with others should be de-designated as MOL. In the Core Planning Strategy consultation, we objected to the loss of MOL on the grounds that the evidence of exceptional circumstances was lacking. The de-designation of MOL lacks support from the evidence base provided by the Council for the Core Planning Strategy, the objectives of the London Plan and the Inspector's Report on the Core Planning Strategy that was published in September. In building the evidence base for the Core Planning Strategy, the Council commissioned an ecological appraisal by MKA Ecology Ltd on the parcels of land along Beddington Lane, including site 57. It considered the value of the land in isolation and that the impact on the rest of the SMI if it were to be developed. We have studied the appraisal and strongly support their assessment and conclusions. Their evidence concludes that the loss of this land would negatively affect the integrity of the MOL/SMI. The negative impacts can be grouped into three categories: sludge management, the construction/operation of industrial buildings and loss of foraging/breeding habitat for birds and bats. Within each category there is a negative impact rating of very high. Objective 1 of the London Plan is to accommodate London's growth within its boundaries without encroaching on open space'. One of the key policy directions to achieve this objective is to protect and improve' MOL. Objective 6 of the London Plan is to make London a more attractive, well-designed and green city'. One of the key policy directions to achieve this objective is to protect and enhance' open space recognising their Page 196 increased importance in a compact city'. Neither of these objectives is compatible with the de-designation of MOL and open space. The Inspector's Report rejected the Council's reasons to justify de-designation of MOL since if the reasons were to be treated as exceptional circumstances, the same or similar arguments could be applied too frequently to other areas of MOL or open space across Greater London and so undermine Green Belt/MOL policy' (3.28). A consequence of the Inspector's retention of MOL means that the de-designation of SINCs has no basis and cannot be supported' (3.36). Accordingly, we consider there should be no encroachment of MOL and SMI at Beddington and site 57 should not be developed for waste management facilities. Deliverability constraints The site is identified as having no deliverability constraints and early deliverability opportunities have been identified' (Table 5.7 Sustainability Appraisal). This statement was made before the Inspector's Report had been published. We would assume that the next version of the SLWP would recognise delivery constraints. We recognise that development can be permitted on MOL but it does have to meet more stringent criteria and would be an obstacle to development. Site assessment process We support a site assessment process being applied to a long list of sites that were identified in the first consultation. The assessment scored the top 12 sites that are likely to be developed for waste management facilities (Table 8.7 in the Sustainability Appraisal). Site 57 was amongst these 12 sites. We would challenge the scoring system that has led this site to be considered so strongly for the following reasons. Metropolitan Open Land (MOL) We are pleased and strongly endorse MOL being one of the criteria in the site assessment process. We note that site 57 has been treated as de-designated Metropolitan Open Land in accordance with Sutton's Core Strategy' (Appendix 4). Now that the Inspector's Report on the Core Planning Strategy has been published and found against the de-designation of MOL, the score should be recalculated treating the land as MOL. Nature Conservation We are pleased and strongly endorse nature conservation being one of the criterion in the site assessment process. There are two criteria used: national and locally important sites. Beddington does not fit neatly into this dichotomy, it has a low score for the national criteria and a high score for local criteria. There is a hierarchy of importance from international to national to metropolitan to borough and finally local. There are few sites of national importance in the area covered by the SLWP so these criteria are not very discriminatory. Furthermore, it does not accord with the London Plan that seeks greater protection for sites of metropolitan importance (policy 3D.14). Beddington is of metropolitan importance, however, according to the scoring system it receives the same score as a site of local importance. We consider that the scoring system should reflect where a site lies on the heirarchy of importance. Furthermore, we also consider that it should reflect the size of the site. It could be argued that large sites could accommodate some loss in area, however, it is large sites that act as reservoirs for species to colonise small sites. Without the large sites, small sites are likely to have less biodiversity. Beddington being a large site is more worthy of protection than a small site. Under the current scoring system, a large site of metropolitan importance receives the same score as a small site of local importance. Open Space and Public Rights of Way Beddington is a large open space that currently has no public rights of way and so the scoring system gave a high score for both criteria. We support a scoring system that assigns lower scores for waste management facilities adjacent to open space and public rights of way. However, the site will become part of the Wandle Valley Regional Park and open to the public. If the scoring system had
26 November 2009 Page 104 of 142 Sutton Consultee ID: 32862 Full Name: Mr Derek Coleman Organisation: Sutton Group Wildlife Trust Agent ID: Agent Name: Agent Organisation: looked longer term, then Beddington would have had a lower score. In summary, we consider that the assessment process is severely flawed for this site. Had the scores been more appropriate then the score would have been much lower and would not have appeared amongst the top 12 scoring sites. Officer's Initial Comment: Noted. Supplementary comments to lodged objection to sites in Beddington Farmlands Consultee ID: 32862 Full Name: Mr Derek Coleman Organisation: Sutton Group Wildlife Trust Agent ID: Agent Name: Agent Organisation: Page 197 Agenda Item 3
26 November 2009 Page 105 of 142 Sutton Agenda Item 3 Consultee ID: 32862 Full Name: Mr Derek Coleman Organisation: Sutton Group Wildlife Trust Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL638 Is Site Suitable? The site is not suitable Site Number: Site comment: ENCROACHMENT BY DEVELOPMENT - SITE 57. De-designation of MOL Beddington Farmlands is MOL, a SMI and part of the Wandle Valley Regional Park and site 57 falls within these designations. Beddington Farmlands is surrounded by development and already has suffered encroachment. The periphera areas are particularly valuable as a buffer zone to the central site such that any more loss of land will be detrimental in itself and have an adverse impact on the wider site. The Core Planning Strategy proposed that site 57 along with others should be de-designated as MOL. In the Core Planning Strategy consultation, we objected to the loss of MOL on the grounds that the evidence of exceptional circumstances was lacking. The de-designation of MOL lacks support from the evidence base provided by the Council for the Core Planning Strategy, the objectives of the London Plan and the Inspector's Report on the Core Planning Strategy that was published in September. In building the evidence base for the Core Planning Strategy, the Council commissioned an ecological appraisal by MKA Ecology Ltd on the parcels of land along Beddington Lane, including site 57. It considered the value of the land in isolation and that the impact on the rest of the SMI if it were to be developed. We have studied the appraisal and strongly support their assessment and conclusions. Their evidence concludes that the loss of this land would negatively affect the integrity of the MOL/SMI. The negative impacts can be grouped into three categories: sludge management, the construction/operation of industrial buildings and loss of foraging/breeding habitat for birds and bats. Within each category there is a negative impact rating of very high. Objective 1 of the London Plan is to accommodate London's growth within its boundaries without encroaching on open space'. One of the key policy directions to achieve this objective is to protect and improve' MOL. Objective 6 of the London Plan is to make London a more attractive, well-designed and green city'. One of the key policy directions to achieve this objective is to protect and enhance' open space recognising their Page 198 increased importance in a compact city'. Neither of these objectives is compatible with the de-designation of MOL and open space. The Inspector's Report rejected the Council's reasons to justify de-designation of MOL since if the reasons were to be treated as exceptional circumstances, the same or similar arguments could be applied too frequently to other areas of MOL or open space across Greater London and so undermine Green Belt/MOL policy' (3.28). A consequence of the Inspector's retention of MOL means that the de-designation of SINCs has no basis and cannot be supported' (3.36). Accordingly, we consider there should be no encroachment of MOL and SMI at Beddington and site 57 should not be developed for waste management facilities. Deliverability constraints The site is identified as having no deliverability constraints and early deliverability opportunities have been identified' (Table 5.7 Sustainability Appraisal). This statement was made before the Inspector's Report had been published. We would assume that the next version of the SLWP would recognise delivery constraints. We recognise that development can be permitted on MOL but it does have to meet more stringent criteria and would be an obstacle to development. Site assessment process We support a site assessment process being applied to a long list of sites that were identified in the first consultation. The assessment scored the top 12 sites that are likely to be developed for waste management facilities (Table 8.7 in the Sustainability Appraisal). Site 57 was amongst these 12 sites. We would challenge the scoring system that has led this site to be considered so strongly for the following reasons. Metropolitan Open Land (MOL) We are pleased and strongly endorse MOL being one of the criteria in the site assessment process. We note that site 57 has been treated as de-designated Metropolitan Open Land in accordance with Sutton's Core Strategy' (Appendix 4). Now that the Inspector's Report on the Core Planning Strategy has been published and found against the de-designation of MOL, the score should be recalculated treating the land as MOL. Nature Conservation We are pleased and strongly endorse nature conservation being one of the criterion in the site assessment process. There are two criteria used: national and locally important sites. Beddington does not fit neatly into this dichotomy, it has a low score for the national criteria and a high score for local criteria. There is a hierarchy of importance from international to national to metropolitan to borough and finally local. There are few sites of national importance in the area covered by the SLWP so these criteria are not very discriminatory. Furthermore, it does not accord with the London Plan that seeks greater protection for sites of metropolitan importance (policy 3D.14). Beddington is of metropolitan importance, however, according to the scoring system it receives the same score as a site of local importance. We consider that the scoring system should reflect where a site lies on the heirarchy of importance. Furthermore, we also consider that it should reflect the size of the site. It could be argued that large sites could accommodate some loss in area, however, it is large sites that act as reservoirs for species to colonise small sites. Without the large sites, small sites are likely to have less biodiversity. Beddington being a large site is more worthy of protection than a small site. Under the current scoring system, a large site of metropolitan importance receives the same score as a small site of local importance. Open Space and Public Rights of Way Beddington is a large open space that currently has no public rights of way and so the scoring system gave a high score for both criteria. We support a scoring system that assigns lower scores for waste management facilities adjacent to open space and public rights of way. However, the site will become part of the Wandle Valley Regional Park and open to the public. If the scoring system had
26 November 2009 Page 106 of 142 Sutton Consultee ID: 32862 Full Name: Mr Derek Coleman Organisation: Sutton Group Wildlife Trust Agent ID: Agent Name: Agent Organisation: looked longer term, then Beddington would have had a lower score. In summary, we consider that the assessment process is severely flawed for this site. Had the scores been more appropriate then the score would have been much lower and would not have appeared amongst the top 12 scoring sites. We consider that the sites proposed on the Beddington Industrial Estate are much better candidates than site 57 and would like to see waste management facilities developed on these sites. We do not able feel able to comment about the sites outside the Borough of Sutton. Officer's Initial Comment: Noted. Supplementary comments to lodged objection to sites in Beddington Farmlands Consultee ID: 32862 Full Name: Mr Derek Coleman Organisation: Sutton Group Wildlife Trust Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL639 Is Site Suitable? The site is not suitable Site Number: Site comment: The Viridor Recyling Centre at Beddington Farmlands is one of the existing waste management sites with no delivery constraints yet identified' (Table 2.2). The SWLP regards the centre as permanent and the London Plan and the proposed policy WP3 seek to protect existing waste management sites. A recycling centre in the heart of MOL, SMI and Regional Park seems incongruous and threatens our vision of a major urban nature reserve. In the initial planning application for the recycling schemes at Beddington and every subsequent application, there have been planning conditions imposed that the recycling schemes are temporary and will be removed at the end of the landfill development. In essence, the recycling schemes received planning consent only because they were temporary. Beddington Farmlands has a planning consent to be restored for wildlife and people after the gravel extraction and landfill.
Much of where the recycling schemes are sited should become wet grassland, a very important habitat in the final restoration. Under planning law, the Page 199 recycling centre is temporary, however, that does not preclude planning applications being made in the future for extensions of the current consent. However, we would like to see the Plan reflecting planning law rather than a future, hypothetical situation. Officer's Initial Comment: Noted. Supplementary comments to lodged objection to sites in Beddington Farmlands Consultee ID: 347590 Full Name: Mr Gareth Lewis Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL67 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I thought that in these more enlightened times, the local authorities sought to protect important areas of wildlife habitat such as that at Beddington Farm Lands. The Liberal Democrats like to boast that they are greener than the other two major parties - perhaps now is the chance to prove that they are and thus prevent any further development at Beddington Farm Lands. Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 348672 Full Name: MR FRANK PRATER Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL69 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Agenda Item 3 Site comment: I object to the South London Waste Plan using sites 18 & 57, which are at Beddington Farmlands. Temporary recycling facilities there are already causing the decline of nationally important bird species, at this designated site of metropolitan importance for nature conservation. Further development and disturbance there ,will destroy the nationally important wildlife for what should become a major urban nature reserve. Sutton council are responsible for the conservation management plan for this site and its time they fully implemented it. Officer's Initial Comment: Noted. These are important considerations which require further investigation and evidence gathering
26 November 2009 Page 107 of 142 Sutton Agenda Item 3 Consultee ID: 348672 Full Name: MR FRANK PRATER Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL70 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I which I object to the South London Waste Plan using sites 18 7 57 , which are at Beddington farmlands. Temporary recycling facilities there are already causing the decline of nationally important bird species at this designated site of metropolitan importance for nature conservation. Further development and disturbance there will destroy the nationally important wildlife, for what should become a major urban nature reserve. Sutton council are responsible for the conservation management plan for this site and its time they fully implemented it Officer's Initial Comment: Noted. These are important considerations which require further investigation and evidence gathering Consultee ID: 349791 Full Name: Mr Gordon Shaw Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL89 Is Site Suitable? Site Number: Site comment: I object to the South London Waste Plan using site 18 and site 57 at Beddington Farmlands. This site has already been damaged extensively and any further development there will further damage this nationally important wildlife site. I assumed that we lived in enlightened time regarding the environment, however this has obviously not reached Sutton Council yet. Page 200 Officer's Initial Comment: Noted. Viridor site is a current managed waste site which if not to continue will require a compensatory allocation in the Waste Plan in accordance with the London Plan. Consultee ID: 331017 Full Name: Dr James Noble Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD23 Is Site Suitable? Site Number: 9 Site comment: Site 9: Garth Road Civic Amenity site, Merton The close proximity of three schools: Dorchester Primary School, Aragon Primary School and Green Lane Primary School make site 9 unsuitable for: In-vessel composting - no evidence to suggest the 2 methods to limit airborne microbe emissions are effective (damping down and waiting for limited wind). How efficient is wind monitoring, or damping down at the site and will it ensure that none of the schools are prone to contamination by potentially toxic microbes? AD facility can produce strong odours Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 354718 Full Name: Ms Sarah London Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 108 of 142 Sutton Consultee ID: 354718 Full Name: Ms Sarah London Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD111 Is Site Suitable? Site Number: 17, 21, 100, 97, 18, 57, 5312, 532, 533, 534, 535, 539 Site comment: I hope that the waste plan will take into account current plans to develop the area between Beddington and the London Road, which forms part of the Hackbridge masterplan, a flagship project for making Sutton a sustainable borough (see http://www.sutton.gov.uk/index.aspx?articleid=3990). This area is intended for sustainable housing and community facilities, open recreational space and more. This presents both an opportunity and a danger. The opportunity is to integrate renewable energy systems in new developments, which would be highly desirable. However, the waste plan must also take into account the fact that the area will become more highly populated, with an inevitable increase in the strain on infrastructure, including roads. Further, if facilities producing emissions and toxins were located close to this area, it would put vulnerable people and children at risk, and undermine the status of the area as a flagship project, which is something the BedZed development already suffers from, to a degree, being located near the Beddington sewage farm. It would be a sad mistake to provide new sustainable developments in the area and then put people off living here and intensively (and therefore sustainably) using the loca facilities by increasing the air and noise pollution and congestion the area suffered from. Incineration and advanced thermal technologies are not yet foolproof, though a laudable aim as part of an overall strategy. They may not be suitable near these residential areas. Existing pollution levels from the industrial use of adjoining land and from traffic must also be factored in. If additional developments will increase the pollution present, they need to avoid taking the overall leve for any given area higher than legal standards. Strong requirements and strong monitoring and enforcement would be needed regarding pollution levels, including in regard to the danger of flooding. Officer's Initial Comment: Agreed. The Plan needs to better reflect spatial considerations in south London such as the Hackbridge sustainable suburb project. Suitable
safeguards on emissions traffic etc raised here which might arise from new waste related development should be incorporated. Smells from the Page 201 adjacent sewage treatment works are subject to separate more specific legalisation which is being pursued separately as the Waste Plan deals with solid waste matters. Consultee ID: 323183 Full Name: Mr Warren Jones Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL14 Is Site Suitable? Site Number: Site 17: Beddington Lane, Country Skip Hire Site comment: The Beddington Lane area is already over industrialised. There are too many heavy goods vehicles accessing this area on a daily basis. The area is filthy and the smell from the existing landfill site and the sewage treatment works that can travel quite far is horrendous. I will oppose any plans if any of these sites are selected in the Beddington Lane area. None in Sutton or Croydon Officer's Initial Comment: A comprehensive list of issues (including those listed) have been considered at the identification of potential sites and will require further work. Planning authorities will require developers to submit technical reports and evidence to address the issues raised (see draft Policy WP6) Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 109 of 142 Sutton Agenda Item 3 Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD119 Is Site Suitable? Site Number: Site 18: Viridor Recycling Centre Beddington Farmlands Site comment: The Wandle Trust cannot agree that the proposed sites are broadly suitable' due to the strength with which we disagree with the (further) redevelopment of site 18, which would be wholly unacceptable because this is an area of wet grassland, Metropolitan Open land and a Site of Nature Conservation Importance, although we do recognise that some of this land has already been built on. These designations should be respected and their review should be undertaken through biodiversity planning procedures and not degraded by proposed development through other planning mechanisms. In addition, there is a very real possibility that future development of Beddington Sewage Treatment Works will be necessary to better process effluent to comply with new water quality standards which will be required under the Water Framework Directive and so, as part of a strategic and holistic approach to planning in this area, Site 18 should not be included amongst the proposed waste sites. Officer's Initial Comment: Noted. Viridor site is a current managed waste site which if not to continue will require a compensatory allocation in the Waste Plan in accordance with the London Plan. Consultee ID: 354743 Full Name: Paul Pickering Organisation: Agent ID: Agent Name: Agent Organisation:
Comment ID: PSPCD151 Is Site Suitable? Site Number: Site 18: Viridor Recycling Centre Beddington Farmlands Page 202 Site comment: Despite the fact that this is already a waste transfer site the likely development of a "waste for energy" facility will put at risk plans for a major urban nature reserve for this area. This site is part of the Beddington Farmlands, which is a designated Site of Metropolitan Importance for Nature Conservation and a potential SSSI. The new technologies likely to be used remain unproven. There are certainly concerns over the output of pollution during startup and shutdown procedures and during routine plantmaintenance. This area already suffers from very high levels of lorry traffic which would only increase under any further development. The whole idea of a "waste for energy" plant is an extremely short-sighted way of dealing with our waste problem. Officer's Initial Comment: Noted. Objection to principal of "waste for energy" and existing waste site in Beddington Farmlands on compatibility with nature conservation, nature reserve and hgv traffic. Issues raised require furthe consideration. Consultee ID: 206179 Full Name: Dr. Stanislaw Prokop Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD212 Is Site Suitable? Site Number: Site 18: Viridor Recycling Centre Beddington Farmlands Site comment: WANDLE SITES Beddington Farmlands: 5312,532,533,534,535,539...AND... 18,21,22,17, 57 and 127 (Wandle) The Wandle group of sites are unsuitable (a clue is in their renaming!) for two main reasons. The heavy rains associated with our climate changes increase the risk of pluvial flooding and leaching of dangerous chemicals from the large tonnages of residue, that will need to be landfilled, into the river. Sea level rise, now recognised as occurring much soone than earlier predictions, will affect the Thames and all its tributaries. This puts all Wandleside industries at risk of flooding in the lifetime of incinerator operations.. Officer's Initial Comment: Noted. Objection to sites in Wandle flood plain with possiblity for flooding/saturation assoicated with climate change causing pollution risk from residue. Requires further investigation. Consultee ID: 206782 Full Name: Mr Mark Leivers Organisation: Sterecycle Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 110 of 142 Sutton Consultee ID: 206782 Full Name: Mr Mark Leivers Organisation: Sterecycle Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD231 Is Site Suitable? Site Number: Site 18: Viridor Recycling Centre Beddington Farmlands Site comment: Site 18: This is constrained by the temporary nature of the current planning permissions which require the site to be completed and restored by 2017. This will preclude major redevelopment of the site. Thereafter the restored site is identified as being central to the delivery of the Wandle Valley Regional Park and hence any extension of the time limit would impact the achievement of this important planning objective. Officer's Initial Comment: Noted. Objection to existing waste management site on grounds that only a temporary permission and required for Wandle Valley Regional Park Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD71 Is Site Suitable? Site Number: Site 18: Viridor Recycling Centre Beddington Farmlands Site comment: Sites i consider suitable are existing disposal sites not too close to residential areas Officer's Initial Comment: Noted. Viridor site is a current managed waste site which if not to continue will require a compensatory allocation in the Waste Plan elsewhere in accordance with the London Plan. Consultee ID: 323183 Full Name: Mr Warren Jones Organisation:
Agent ID: Agent Name: Agent Organisation: Page 203 Comment ID: PSPSL15 Is Site Suitable? Site Number: Site 18: Viridor Recycling Centre, Beddington Farmlands Site comment: The Beddington Lane area is already over industrialised. There are too many heavy goods vehicles accessing this area on a daily basis. The area is filthy and the smell from the existing landfill site and the sewage treatment works that can travel quite far is horrendous. I will oppose any plans if any of these sites are selected in the Beddington Lane area. Officer's Initial Comment: A comprehensive list of issues (including those listed) have been considered at the identification of potential sites and will require further work. Planning authorities will require developers to submit technical reports and evidence to address the issues raised (see draft Policy WP6) Consultee ID: 332048 Full Name: Mr Johnny Allan Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 111 of 142 Sutton Agenda Item 3 Consultee ID: 332048 Full Name: Mr Johnny Allan Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL45 Is Site Suitable? Site Number: Site 18: Viridor Recycling Centre, Beddington Farmlands Site comment: Site 18, the Viridor Recycling Centre (VRC) and Site 57, the Land West of Beddington Lane Adjacent to Existing Waste Management Facilities (LWBL), should NOT be considered in relation to the South London Waste Plan. The VRC (which will no longer exist in 2023), is on land which is earmarked for a major urban nature reserve and part of the Beddington Farmlands (BF), which is a designated Site of Metropolitan Importance for Nature Conservation and a potential SSSI. The VRC is already having a detrimental effect on the locally, regionally and nationally important bird species which breed at and use the site. The LWBL, which is Metropolitan Open Land, plays an integral part in ensuring that the important bird species on the rest of BF survive. These species use the whole of BF including the LWBL I would draw your attention to the Conservation Management Plan for BF: The objective of the Conservation Management Plan is to retain the important breeding populations on site through the development at BF. Several of the species are unlikely to re-colonise if lost from the site. The most important species were selected as target species that are monitored during the course of the development. Since the development, one species (Yellow Wagtail), has been lost, two have not bred since 2005 (Redshank and Little Ringed Plover), two show large declines (Sedge Warbler, Reed Bunting), one that has declined in the last two years (Tree Sparrow), leaving only two that are faring reasonably well (Lapwing and Reed Warbler). All will be lost should further disturbance occur. I would remind the London Borough of Sutton of their responsibility to fully carry out their obligations with regard to the Conservation Management Plan. Noted. The issues raised above are important considerations and will require further evaluation and evidence.
Officer's Initial Comment: Page 204 Consultee ID: 361473 Full Name: Mr Keith Miller Organisation: Beddington Bird Farm Group Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 112 of 142 Sutton Consultee ID: 361473 Full Name: Mr Keith Miller Organisation: Beddington Bird Farm Group Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL591 Is Site Suitable? The site is not suitable Site Number: Site comment: Thank you for taking the time to meet with representatives of the Beddington Farm Bird Group (BFBG) at the Sutton Civic Offices on 24th September. I think we are now clearer on the proposals, policies (and processes) governing this consultation, following your and Philip James' helpful advice. We mentioned that we would wish to take this matter forward and I am now writing to you on behalf of the Group, in order to formally record our objection to the inclusion of Sites 18 & 57 as potentially suitable locations for waste management facilities, as specified in the current South London Waste Plan (Stage 2 Consultation). For ease of reference, we shall attempt to address our concerns as they relate to the proposed policies set out in the Consultation documentation. Prior to doing so however, it is essential, in fully understanding our concerns, to place in context the importance of Beddington Farmlands to nature conservation. Beddington Farmlands is designated in the 2003 Sutton Unitary Development Plan as Metropolitan Open Land (MOL), a Metropolitan Site of Importance for Nature Conservation (SMI) (and a potential SSSI) an area safeguarded for the Wandle Valley Regional Park - of which it will form the keystone - and an archaeological priority area. The site is of exceptional priority for birds in London. Wildlife populations have been continuously monitored since the 1950s, particularly the recording and ringing of bird populations. Reports of the resident, migratory, breeding and wintering species have also been published in the form of an annual report since 1992. The Farmlands have an enviable reputation for rarities and the site continues to record some 150 species a year, one of the longest species lists in London. As a Metropolitan wildlife site, it is part of the key strategic framework for biodiversity as described in the GLA London Plan. In an attempt to manage both commercial and wildlife interests at the Farmlands, the Conservation Management Plan (CMP), guarantees' protection for key species and is, theoretically, in force, but a contextual overview would be incomplete were we not to record that waste recycling and landfill operations and delays in restoration continue to have a detrimental effect. Breeding numbers of several red data species have been lost or have fallen. Yellow Wagtails are now extinct as a breeding species; Redshank and Little Ringed Plover have not bred since 2005 and Reed Bunting and Sedge Warbler show large declines. Page 205 The Tree Sparrow, (a UK Biodiversity Action Plan Priority Species) has, at Beddington, one of its largest surviving breeding populations in Britain. It is our flagship species, notwithstanding a worrying reduction in breeding success over the last two years. This illustrates that we simply cannot afford to be complacent and assume that the status of the Farmland's wildlife, which we seek to record - and to encourage - is in equilibrium. It is not. The BFBG, therefore, opposes plans detrimental to the wildlife at Beddington and which are in contradiction to the agreed CMP for the site. The SLWP has two direct threats to our vision of a major urban nature reserve at Beddington Farmlands. Firstly, the attempted re-designation and development for non-wildlife use, of selected, integral parcels of land, which should be reserved for wildlife (Site 57) and the temporary recycling centre becoming permanent (Site 18). Officer's Initial Comment: Noted. Objection to existing and proposed sites in Beddington Farmlands on nature conservation, biodiversity, MOL, Wandle Valley Park and archeological grounds. These matters require further investigation. Consultee ID: 137710 Full Name: Mr Shasha Khan Organisation: Croydon Green Party Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL623 Is Site Suitable? The site is not suitable Site Number: Site comment: Beddington Farmlands, site 18 and site 57 are a "Site of Metropolitan Importance for Nature Conservation". We think they are unsuitable sites for waste management. There are already proposals for this site to become a nature reserve, and we don't want to see any more green spaces lost to development.
Officer's Initial Comment: Noted. Objection to proposed sites in Beddington Farmlands on nature conservation grounds. This requires further investigation. Agenda Item 3 Consultee ID: 32862 Full Name: Mr Derek Coleman Organisation: Sutton Group Wildlife Trust Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 113 of 142 Sutton Agenda Item 3 Consultee ID: 32862 Full Name: Mr Derek Coleman Organisation: Sutton Group Wildlife Trust Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL650 Is Site Suitable? Site Number: Site comment: We ask that sites 18 and 57 are safeguarded for wildlife and people at Beddington Farmlands rather than developed for waste management facilities so that our vision of a major urban nature reserve can achieved. We would also ask that policies are put in place that help us protect Beddington from adverse development. Officer's Initial Comment: Noted. Objection to proposed sites in Beddington Farmlands on nature conservation, accessible open space and quality of place grounds. These require further investigation. Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD68 Is Site Suitable? Site Number: Site 21: Beddington Lane, Coomber Way, 777 Demolition & Haulage Co ltd Site comment: Sites I consider suitable are existing disposal sites not too close to residential areas Noted
Officer's Initial Comment: Page 206 Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD126 Is Site Suitable? Site Number: Site 57: Land west of Beddington Lane adjacent to industrial areas and existing waste management facilities Site comment: 57: As for Site 18, development of site 57 (land west of Beddington Lane) would be wholly unacceptable. This area also includes Metropolitan Open land and Site of Nature Conservation Importance designations, which we strongly think should be respected and reviewed through biodiversity planning procedures and not degraded by proposed development through other planning mechanisms. Again, there is a very real possibility that future development of Beddington Sewage Treatment Works will be necessary to better process effluent to comply with new water quality standards which will be required under the Water Framework Directive and so, as part of a strategic and holistic approach to planning in this area, this site should not be included amongst the proposed waste sites. Officer's Initial Comment: Noted. Arrangements for the treatment of waste which is not solid waste are outside the scope of the Waste Plan. Consultee ID: 354743 Full Name: Paul Pickering Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD158 Is Site Suitable? Site Number: Site 57: Land west of Beddington Lane adjacent to industrial areas and existing waste management facilities Site comment: Despite the fact that Beddington Lane already has a waste transfer site, the likely development of a "waste for energy" facility will put at risk plans for a major urban nature reserve for this area. This site is part of the Beddington Farmlands, which is a designated Site of Metropolitan Importance for Nature Conservation and a potential SSSI. The new technologies likely to be used remain unproven. There are certainly concerns over the output of pollution during startup and shutdown procedures and during routine plantmaintenance. This area already suffers from very high levels of lorry traffic which would only increase under any further development. The whole idea of a "waste for energy" plant is an extremely short-sighted way of dealing with our waste problem. Officer's Initial Comment: Noted. Objection to principal of "waste for energy" and existing waste site in Beddington Farmlands on compatibility with nature conservation, nature reserve and hgv traffic. Issues raised require furthe consideration.
26 November 2009 Page 114 of 142 Sutton Consultee ID: 346075 Full Name: MR DAVID CLARK Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD24 Is Site Suitable? Site Number: 18 / 57 Site comment: 18 = Wet Grassland 57 = Metropolitan Open Land Both these sites are important for breeding and rare species of birdlife. Some of these species are in local and national decline acceleration of which will occur if these sites are used. Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD76 Is Site Suitable? Site Number: Site 57: Land west of Beddington Lane adjacent to industrial areas and existing waste management facilities Site comment: Sites i consider suitable are existing disposal sites not too close to residential areas. Sites not numbered i consider unsuitable, particularly site 127 by the wandle river. Officer's Initial Comment: Noted Consultee ID: 350898 Full Name: Mrs Tracey Lambert Organisation: Agent ID: Agent Name: Agent Organisation: Page 207 Comment ID: PSPSL134 Is Site Suitable? Site Number: Site 57, 18, 532, 533, 534, 535, 539, 5312 Site comment: Beddington Lane is particularly unsuited for the heavy traffic using the road currently . Beddington Lane is narrow, dangerous for pedestrians and cyclists, poorly maintained and is unsuitable for the amount of traffic currently using it. Any increase in traffic, and given the amount of waste likely to be taken to the sites one expects this to be significant, is unacceptable. In addition, the prospect of all the waste produced in South West London being transported via residential local areas is also unacceptable. Local roads are already extremely busy and it is hard to see how the waste from boroughs could be transported through the local area without signficant disruption to the local community, increased pollution, decreased road safety, increased noise and diminished quality of life for local residents. It doesn't seem to sit well with the council's plans to make Hackbridge one of the most environmentally sustainable boroughs in the UK. Hackbridge may be "green" but it will be full of lorries using the local roads to transport waste to Beddington Lane. Wallington and Carshalton are already choked with traffic during the day. It does not make good sense to encourage residents of Wallington to consider alternative ways of travelling to the car - only to fill up the space on the roads that they would otherwise be using by articulated lorries full of domestic and other refuse. I suppose the irony of this is los on the Council. The arguments about wildlife and the importance of maintaining the land for use by threatened bird species etc are already well made by other respondents and I support their views. Officer's Initial Comment: Noted. The Plan will be required to take into account the traffic implications of new waste related development and mitigation. Agreed The Plan needs to better reflect spatial considerations in south London such as the Hackbridge sustainable suburb proj Consultee ID: 323183 Full Name: Mr Warren Jones Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 115 of 142 Sutton Agenda Item 3 Consultee ID: 323183 Full Name: Mr Warren Jones Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL16 Is Site Suitable? Site Number: Site 57: Land west of Beddington Lane adjacent to industrial areas and existing waste management facilities Site comment: The Beddington Lane area is already over industrialised. There are too many heavy goods vehicles accessing this area on a daily basis. The area is filthy and the smell from the existing landfill site and the sewage treatment works that can travel quite far is horrendous. I will oppose any plans if any of these sites are selected in the Beddington Lane area. Officer's Initial Comment: A comprehensive list of issues (including those listed) have been considered at the identification of potential sites and will require further work. Planning authorities will require developers to submit technical reports and evidence to address the issues raised (see draft Policy WP6) Consultee ID: 332048 Full Name: Mr Johnny Allan Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL46 Is Site Suitable? Site Number: Site 57: Land west of Beddington Lane adjacent to industrial areas and existing waste management facilities Site comment: Site 57 the Land West of Beddington Lane Adjacent to Existing Waste Management Facilities (LWBL) and Site 18, the Viridor Recycling Centre (VRC) ,
should NOT be considered in relation to the South London Waste Plan. The VRC (which will no longer exist in 2023), is on land which is earmarked for a Page 208 major urban nature reserve and part of the Beddington Farmlands (BF), which is a designated Site of Metropolitan Importance for Nature Conservation and a potential SSSI. The VRC is already having a detrimental effect on the locally, regionally and nationally important bird species which breed at and use the site. Site 57, the LWBL, which is Metropolitan Open Land, plays an integral part in ensuring that the important bird species on the rest of BF survive. These species use the whole of BF including the LWBL I would draw your attention to the Conservation Management Plan for BF: The objective of the Conservation Management Plan is to retain the important breeding populations on site through the development at BF. Several of the species are unlikely to re-colonise if lost from the site. The most important species were selected as target species that are monitored during the course of the development. Since the development, one species (Yellow Wagtail), has been lost, two have not bred since 2005 (Redshank and Little Ringed Plover), two show large declines (Sedge Warbler, Reed Bunting), one that has declined in the last two years (Tree Sparrow), leaving only two that are faring reasonably well (Lapwing and Reed Warbler). All will be lost should further disturbance occur. I would remind the London Borough of Sutton of their responsibility to fully carry out their obligations with regard to the Conservation Management Plan. Officer's Initial Comment: Noted. The issues raised above are important considerations and will require further evaluation and evidence. Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD69 Is Site Suitable? Site Number: Site 97: Beddington Lane, Severnside Waste Paper Site comment: Sites i consider suitable are existing disposal sites not too close to residential areas Officer's Initial Comment: Noted Consultee ID: 323183 Full Name: Mr Warren Jones Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 116 of 142 Sutton Consultee ID: 323183 Full Name: Mr Warren Jones Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL18 Is Site Suitable? Site Number: Site 97: Beddington Lane, Severnside Waste Paper Site comment: The Beddington Lane area is already over industrialised. There are too many heavy goods vehicles accessing this area on a daily basis. The area is filthy and the smell from the existing landfill site and the sewage treatment works that can travel quite far is horrendous. I will oppose any plans if any of these sites are selected in the Beddington Lane area. Officer's Initial Comment: A comprehensive list of issues (including those listed) have been considered at the identification of potential sites and will require further work. Planning authorities will require developers to submit technical reports and evidence to address the issues raised (see draft Policy WP6) Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD70 Is Site Suitable? Site Number: Site 100: Beddington Lane, Therapia Way, European Metal Recycling (EMR) Limited Site comment: Sites i consider suitable are existing disposal sites not too close to residential areas Officer's Initial Comment: Noted. Consultee ID: 328308 Full Name: MR Matthew Drew Organisation: Agent ID: Agent Name: Agent Organisation: Page 209 Comment ID: PSPSL31 Is Site Suitable? Site Number: Site 100: Beddington Lane, Therapia Way, European Metal Recycling (EMR) Ltd Site comment: I think there is enough waste and dust in Beddington lane. Current levels of pollution are meeting or exceeding the maximum level. The local residents are fed up with dust and pollution that has been increasing over the years and we don't want any more. Officer's Initial Comment: A comprehensive list of issues (including those listed) have been considered at the identification of potential sites and will require further work. Planning authorities will require developers to submit technical reports and evidence to address the issues raised (see draft Policy WP6) Consultee ID: 349864 Full Name: P Maskell Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD144 Is Site Suitable? Site Number: Site 491: Kimpton Industrial Estate, Land North of Minden Road Site comment: Already near recycling centre and surrounded by non-residential areas. Officer's Initial Comment: Noted. Objection to proposals in Kimpton on basis that near to existing re-cycling centre and surrounded by non-residential areas. Consultee ID: 350514 Full Name: R Bolton Organisation: Agenda Item 3 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD63 Is Site Suitable? Site Number: Site 491: Kimpton Industrial Estate, Land North of Minden Road Site comment: Should be strongly considered Officer's Initial Comment: Noted
26 November 2009 Page 117 of 142 Sutton Agenda Item 3 Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD79 Is Site Suitable? Site Number: Site 491: Kimpton Industrial Estate, Land North of Minden Road Site comment: Site 491 is among the only ones I conider suitable. Officer's Initial Comment: Noted Consultee ID: 355240 Full Name: Mrs P.R Smith Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL248 Is Site Suitable? Site Number: Site 491: Kimpton Industrial Estate, Land North of Minden Road Site comment: Site 491 it is less suitable because it is small. Officer's Initial Comment: Noted Consultee ID: 355478 Full Name: Veolia Organisation: Veolia Environmental Services Agent ID: Agent Name: Agent Organisation:
Comment ID: PSPCD135 Is Site Suitable? Site Number: Site 532: Beddington Industrial Area Zone 2 Page 210 Site comment: This comment is not specifically about site 532 but relates to our Waste Transfer Station site at Endeavour Way near Bainbridge Avenue close to this general area and within the Beddington Farmalnds Industrial area. This site should also be identified for potential use redevelopment. Officer's Initial Comment: Noted. Request from operator for existing site to be recognised by SLWP and identified to facilitate redevelopment. Requires further consideration. Consultee ID: 355478 Full Name: Veolia Organisation: Veolia Environmental Services Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD136 Is Site Suitable? Site Number: Site 532: Beddington Industrial Area Zone 2 Site comment: This comment is not specifically about site 532 but relates to our Waste Transfer Station site at Endeavour Way near Bainbridge Avenue close to this general area and within the Beddington Farmalnds Industrial area. This site should also be identified for potential use redevelopment. Officer's Initial Comment: Noted. Request from operator for existing site to be recognised by SLWP and identified to facilitate redevelopment. Requires further consideration. Consultee ID: 350639 Full Name: Gill Locke Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL104 Is Site Suitable? Site Number: Sites 532, 533, 534, 535, 539, 5312: Beddington Farmlands Site comment: Site 532 seems to be very close to residential area and therefore unsuitable Officer's Initial Comment: Noted Consultee ID: 323183 Full Name: Mr Warren Jones Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 118 of 142 Sutton Consultee ID: 323183 Full Name: Mr Warren Jones Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL17 Is Site Suitable? Site Number: Sites 532, 533, 534, 535, 539, 5312: Beddington Farmlands Site comment: The Beddington Lane area is already over industrialised. There are too many heavy goods vehicles accessing this area on a daily basis. The area is filthy and the smell from the existing landfill site and the sewage treatment works that can travel quite far is horrendous. I will oppose any plans if any of these sites are selected in the Beddington Lane area. Officer's Initial Comment: A comprehensive list of issues (including those listed) have been considered at the identification of potential sites and will require further work. Planning authorities will require developers to submit technical reports and evidence to address the issues raised (see draft Policy WP6) Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD80 Is Site Suitable? Site Number: 5312, 532, 533, 534, 535, 539 Site comment: 5312 - Suitably placed on industrial site 532 - Too close to residential properties 533, 534, 535, 539 - All suitably placed Officer's Initial Comment: Noted. Consultee ID: 356333 Full Name: Unknown Organisation:
Agent ID: Agent Name: Agent Organisation: Page 211 Comment ID: PSPSL331 Is Site Suitable? The site is not suitable Site Number: Site comment: The potential 'rubbish dump factory' designated 5312) off Beddington Lane is of grave concern, being to the North of the Richmond Road Residential Area, where a prevailaing North wind often carries air pollution from the local industrial area, including the local sewage site odurs with a slight wind shift. This Proposed Facility will only add greatly, an undetermined, at present, further Environmental Hazard to the Residential Area and should not even be considered. Officer's Initial Comment: Noted. Objection to a proposed site in Beddington for further development on grounds of air quality, smells and compatibility with adjacent residential area. These matters require further investigation. Policy Issue 1: Defining the Strategic Approach Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD43 Is Site Suitable? Site Number: Policy Issue 1: Defining the Strategic Approach Site comment: Re P.42: It would not be appropriate to encourage even 4 boroughs to deal, together, with some hazardous waste such as asbestos and radioactive wastes. Dealing with waste management as high up hierarchy as possible (P41) is good but what about e.g. waste stream from property owners (blocks of rented flats
usually) who strip out and replace electric wiring, plumbing, kitchenettes every 5 years or so? Is there an approval process (e.g. building control) needed to Agenda Item 3 trigger waste monitoring? There is no mention of the waste stream from restaurant, hotel, chip shop premises which generate material recyclable commercially as diesel fuel. Officer's Initial Comment: Disagree - the 4 boroughs are working collaboratively. Construction and Property Waste and Commercial Waste are dealt with and available monitoring information is collected. Consultee ID: 354343 Full Name: Mr Chris Walker Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 119 of 142 Policy Issue 1: Defining the Strategic Approach Agenda Item 3 Consultee ID: 354343 Full Name: Mr Chris Walker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD99 Is Site Suitable? Site Number: Policy Issue 1: Defining the Strategic Approach Site comment: The Policy should not cater for additional capacity and should instead prioritise a zero waste (reduction) strategy. Officer's Initial Comment: Disagree. To be sound the SLWP has to provide for the London Plan allocations. Waste reduction is encouraged. Consultee ID: 350654 Full Name: Ms Anne Keeley Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL108 Is Site Suitable? Site Number: Policy 1: The Strategic Approach Site comment: Aim to totally re-use use of landfill. No use of incineration Officer's Initial Comment: Noted. Support for total reduction in landfill. Object to incineration. Consultee ID: 350694 Full Name: R Hills Organisation: Agent ID: Agent Name: Agent Organisation:
Comment ID: PSPSL116 Is Site Suitable? Site Number: Policy 1: The Strategic Approach Page 212 Site comment: What 'other forms of treatment' are envisaged for the disposal of waste? Should these not be identified first so that a more considered judgement can be made about site suitability? How can you ensure that new waste facilities will not harm local people or environment. It appears that schemes have already been planned for the proposed sites "... new facilities will be encouraged.." How does that accord with public consultation and residents news? Officer's Initial Comment: Noted. Concern over lack of detail of proposed waste facilities and environmental/health effects. Information on proposed future activities on selected sites will be provided at final stage of plan when this is clear. Consultee ID: 354694 Full Name: Mr Bernard P Meade Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL217 Is Site Suitable? Site Number: Policy 1: The Strategic Approach Site comment: Acceptable Officer's Initial Comment: Agreed Consultee ID: 355250 Full Name: Mr John Shayler Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL253 Is Site Suitable? Site Number: Policy 1: The Strategic Approach Site comment: Cause great harm to residents in Carshalton Road. Danger of access more large lorries. Noise (as already stated, people do not object to the factory estate it has been years. but as stated the intolerable noise from new plant hire company is ridiculous. Officer's Initial Comment: Noted. Access, traffic levels and noise are matters of acknowledged importance for further consideration. Policy 2: Waste Minimisation
26 November 2009 Page 120 of 142 Policy 2: Waste Minimisation Consultee ID: 354343 Full Name: Mr Chris Walker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD100 Is Site Suitable? Site Number: Policy Issue 2: Encouraging Waste Minimisation Site comment: This is irresponsibly weak and does not respond to the wishes of local people to reduce waste as expressed during stage one. The consultation fails to address the options available to local authorities in influencing retails and producers of waste and the successes of other areas in adopting 'zero waste' strategies. Deferring to national standards is unacceptable and the policy needs to show more vision and imagination in local waste reduction solutions which draw on all of the local authorities powers. Officer's Initial Comment: Disagree. To be found sound the Plan has to be in conformity with national and regional strategies. Consultee ID: 354718 Full Name: Ms Sarah Lindon Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD112 Is Site Suitable? Site Number: Policy Issue 2: Encouraging Waste Minimisation Site comment: I think the plan should be as ambitious as possible in encouraging waste reduction, recycling and reuse. I think there is room to go further here. The plan must ensure that large facilities are not built that reduce the drivers for waste reduction and improved recycling rates. The plan should aim for the 70% municipal recycling rates achieved in Flanders. Contracts must be designed carefully with this in mind, to allow councils to switch to improved technologies when they become available, rather than being stuck with outdated processing, and to prioritise reuse and recycling above energy recovery. The plan should aim to design out waste that cannot be dealt with sustainably. Page 213 Officer's Initial Comment: Agree Plan should set challenging targets in conjunction with Municipal Waste Strategy. Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD128 Is Site Suitable? Site Number: Policy Issue 2: Encouraging Waste Minimisation Site comment: This policy is exceptionally poor: it barely mentions waste minimisation and is wholly unaspirational. It details more about recycling and general waste management than waste minimisation. Waste minimisation is the top of the waste hierarchy and so should be central to any strategic and holistic waste plan, instead it is sidelined and even apparently misunderstood as demonstrated by the vision which states that, Waste will be regarded as a valuable resource, supplying a growing manufacturing-from-waste industry' - such an industry relies on waste growth not waste minimisation! The monitoring specified in Table 3.19 is very passive: more consideration should be given to active projects which reach large numbers of residents and businesses and inform them about waste minimisation. Officer's Initial Comment: Noted. Draft policies are put forward for public consultation. Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation:
Comment ID: PSPCD44 Is Site Suitable? Site Number: Policy Issue 2: Encouraging Waste Minimisation Agenda Item 3 Site comment: Surely there must be some liaison if not partnership, with both local water companies responsible for energy supply - gas and electricity? The waste management business clearly will have beneficial links with them, for instance in fuel generation. Even are Victorian forebears had some street lighting in London from sewer gas. A de-centralised energy system will be unavoidable as climate change happens. De-centralised waste management in 4 boroughs should connect with that. Officer's Initial Comment: Agree - SLWP is consulting with statutory undertakers. Opportunities for energy from waste are being encouraged.
26 November 2009 Page 121 of 142 Policy 2: Waste Minimisation Agenda Item 3 Consultee ID: 350654 Full Name: Ms Anne Keeley Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL109 Is Site Suitable? Site Number: Policy 2: Waste Minimisation Site comment: Aim to conserve use of water in whatever form of waste treatment used. Officer's Initial Comment: Agree. Consultee ID: 350694 Full Name: R Hills Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL117 Is Site Suitable? Site Number: Policy 2: Waste Minimisation Site comment: Who drew up the "best practice guidelines"? What does "during construction" mean? Officer's Initial Comment: Noted. Best practice advice is available from central Government and The Mayor Consultee ID: 354694 Full Name: Mr Bernard P Meade Organisation: Agent ID: Agent Name: Agent Organisation:
Comment ID: PSPSL218 Is Site Suitable? Site Number: Policy 2: Waste Minimisation Page 214 Site comment: Acceptable Officer's Initial Comment: Agree Policy 3: Safeguarding Existing Waste Sites Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD45 Is Site Suitable? Site Number: Policy Issue 3: Safeguarding existing waste management sites Site comment: I am very anxious about the landfill site (p.45) at Beddington, Sutton. It appears, nowadays, unseemly that domestic waste residues should back fill gravel excavation. This runs the risk of polluting the ground water supply much of South London uses. Justification here and elsewhere, should help change minds and raise awareness of commercial opportunities. For instance long before the arrival of avent waste management principles a North American company secured and patented internationally a process for converting certain types of plastic into the raw material of outdoor clothing! Very lucrative and beneficial I believe. Do not overlook probability that some present site occupiers (e.g. in light industrial areas) may wish to offer new waste management related sites. Officer's Initial Comment: Agree- The Plan seeks to reduce landfill. Beddington Farmlands have the benefit of existing consents since the original principle of landfill was granted on appeal . All suitable potential waste management sites are being examined. Consultee ID: 350694 Full Name: R Hills Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL118 Is Site Suitable? Site Number: Policy 3: Safeguarding Existing Waste Sites Site comment: Does this mean existing sites cannot be increased? Officer's Initial Comment: Noted. Existing sites can only expand where consents are in place.
26 November 2009 Page 122 of 142 Policy 3: Safeguarding Existing Waste Sites Consultee ID: 354694 Full Name: Mr Bernard P Meade Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL219 Is Site Suitable? Site Number: Policy 3: Safeguarding Existing Waste Sites Site comment: Acceptable Officer's Initial Comment: Agree Policy Issue 4: Identifying proposed waste management sites Consultee ID: 354343 Full Name: Mr Chris Walker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD101 Is Site Suitable? Site Number: Policy Issue 4: Identifying proposed waste management sites Site comment: The logic and consultation process which has led to this policy is fundamentally flawed and misleading. First, waste reduction is not adequately addressed in the Plan and second, the likely specific use and technologies for each site must be made part of the consideration. A transfer facility is very different from an incinerator, for example. Given the Plan appears to make incineration inevitable and the local authorities are procuring incinerators in parallel to this consultation process, a proper consultation document would have an in-depth consideration of the issues around incineration and full environmental impact assessments of the sites which must have been earmarked. Officer's Initial Comment: Disagree The second stage consultation refers to waste reduction. Further information on types of facility and environmental impact etc will be Page 215 included in further stage where information is available. Consultee ID: 354718 Full Name: Ms Sarah Lindon Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD113 Is Site Suitable? Site Number: Policy Issue 4: Identifying proposed waste management sites Site comment: I would like to echo the concern expressed by Mr White that the design of the consultation makes it very hard for citizens to respond to the proposals. With so many possible sites under discussion but no particular plans and technologies outlined in relation to each, how are we supposed to think about transport implications, proximity to schools or allotments etc etc? This is a big hindrance to judging the appropriateness of sites. We need much more clarity. Officer's Initial Comment: Noted The second stage consultation is required to consider all possible sites. Information on environmental impact etc will be included in further stage where information is available. Traffic and compatibility with adjacent land uses are acknowledged important matters. Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD46 Is Site Suitable? Site Number: Policy Issue 4: Identifying proposed waste management sites
Site comment: Seems likely to be overtaken by events quite speedily. Agenda Item 3 Officer's Initial Comment: Noted Consultee ID: 350654 Full Name: Ms Anne Keeley Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 123 of 142 Policy Issue 4: Identifying proposed waste management sites Agenda Item 3 Consultee ID: 350654 Full Name: Ms Anne Keeley Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL110 Is Site Suitable? Site Number: Policy 4: Proposed Sites for New Waste Management Facilities Site comment: Consideration to be given to energy use (i.e. fuel) and waste products produced by transporting waste to any new sites. Officer's Initial Comment: Agree. Minimising transport costs is an objective. Consultee ID: 350694 Full Name: R Hills Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL119 Is Site Suitable? Site Number: Policy 4: Proposed Sites for New Waste Management Facilities Site comment: This is fine provided residents news - the consultation process are actually taken into account and this is not just a paper exercise for plans already drawn up. Development of existing sites originally intended for waste disposal would seem to be the most sensible option. Officer's Initial Comment: Noted. Preference for development of existing sites to achieve plans objectives Consultee ID: 354694 Full Name: Mr Bernard P Meade Organisation:
Agent ID: Agent Name: Agent Organisation: Page 216 Comment ID: PSPSL220 Is Site Suitable? Site Number: Policy 4: Proposed Sites for New Waste Management Facilities Site comment: Not specific. To make a considered judgement I would require to know the: the various steps involved between collecting contents of wheelie bins through to final disposal of end product. method of treatment e.g. stage 1 - collect wheelie bins content at house. stage 2 - collect together said contents from all houses. stage 3 - to final product. stage 4 Disposal etc. shown as flowchart. Officer's Initial Comment: Noted. Further information to be provided. Policy 5: Waste Related Development on Unallocated Sites Consultee ID: 354343 Full Name: Mr Chris Walker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD102 Is Site Suitable? Site Number: Policy Issue 5: Managing the development of waste management facilities on unallocated sites Site comment: The standard should be 'zero waste' and that every possible avenue for waste reduction has been explored before any new site is considered. The Plan fails to address this central issue in any meaningful sense. Officer's Initial Comment: Disagree. The Plan seeks to address waste reduction. Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 124 of 142 Policy 5: Waste Related Development on Unallocated Sites Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD129 Is Site Suitable? Site Number: Policy Issue 5: Managing the development of waste management facilities on unallocated sites Site comment: Yes BUT Criteria 6 (the numbers differ between this online version and the pdf version!) should not just include nature conservation areas but also any location which supports protected (local, national or international) or designated species. Officer's Initial Comment: Noted. Nature conservation and ecology are matters of acknowledged importance Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD130 Is Site Suitable? Site Number: Policy Issue 5: Managing the development of waste management facilities on unallocated sites Site comment: No monitoring regime to assess impacts on people, the environment or natural resources is detailed. For Criteria 3 (that a proposed development can demonstrate that there are no significant adverse impacts to people, the environment or natural resources by meeting Policy WP6) to be achieved, monitoring over a duration and time appropriate to the environmental factors in question is critical. Officer's Initial Comment: Noted. Monitoring arrangements are under consultation and require further consideration.
Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Page 217 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD47 Is Site Suitable? Site Number: Policy Issue 5: Managing the development of waste management facilities on unallocated sites Site comment: Flooding : Priority should recognise forward estimates of relative mean sea levels, over say at least 20 years. On the transport aspect there will be a case for moving material by light rail systems to eliminate exceed truck/container movements. Officer's Initial Comment: Agree - Plan should attend to climate change implications. Disagree - potential for moving waste by light rail appears to be very limited. Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD85 Is Site Suitable? Site Number: Policy Issue 5: Managing the development of waste management facilities on unallocated sites Site comment: The criteria set out in supporting text must be strictly adhered to, and never, under any circumstances, departed from. The costs, human and economic, of departing from them are to great to be contemplated. Officer's Initial Comment: Noted Agenda Item 3 Consultee ID: 350654 Full Name: Ms Anne Keeley Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL111 Is Site Suitable? Site Number: Policy 5: Waste Related Development on Unallocated Sites Site comment: No new sites on Green Belt land or establishes 'natural' land sites i.e. woods etc. Officer's Initial Comment: Noted. Preference for "green field" sites to be avoided
26 November 2009 Page 125 of 142 Policy 5: Waste Related Development on Unallocated Sites Agenda Item 3 Consultee ID: 350694 Full Name: R Hills Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL120 Is Site Suitable? Site Number: Policy 5: Waste Related Development on Unallocated Sites Site comment: Development of existing sites originally intended for waste disposal would seem to be the most sensible option. Developers must also take into account residents news. Officer's Initial Comment: Noted. Preference for development of existing sites to achieve plans objectives Consultee ID: 354362 Full Name: Mrs Leigh Terrafranca Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL177 Is Site Suitable? Site Number: Policy 5: Waste Related Development on Unallocated Sites Site comment: If a site is proposed that is unallocated, the views of immediate homeowners and businesses should be given a high level of attention, in the decision about adding a new site. Officer's Initial Comment: Agreed. SLWP committed to full local consultation, Consultee ID: 354616 Full Name: Mr Peter Haynes Organisation: Agent ID: Agent Name: Agent Organisation: Page 218 Comment ID: PSPSL194 Is Site Suitable? Site Number: Policy 5: Waste Related Development on Unallocated Sites Site comment: Re Site 60: The road network is totally unsuited for heavy vehicles to and from this site. Officer's Initial Comment: Noted. Access to road network is an important matter to be investigated further. Consultee ID: 354651 Full Name: Mr William Watson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL203 Is Site Suitable? Site Number: Policy 5: Waste Related Development on Unallocated Sites Site comment: Policy 5: Should include that developers need to consider the noise and small impact in proximity to dense residential areas. Officer's Initial Comment: Noted. Proximity to residential, possible noise and smell issues are matters of acknowledged importance. Consultee ID: 354694 Full Name: Mr Bernard P Meade Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL221 Is Site Suitable? Site Number: Policy 5: Waste Related Development on Unallocated Sites Site comment: Acceptable Officer's Initial Comment: Agreed. Consultee ID: 355250 Full Name: Mr John Shayler Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 126 of 142 Policy 5: Waste Related Development on Unallocated Sites Consultee ID: 355250 Full Name: Mr John Shayler Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL254 Is Site Suitable? Site Number: Policy 5: Waste Related Development on Unallocated Sites Site comment: Traffic impact roads not suitable for even more large lorries (see enclosed drawing) Officer's Initial Comment: Noted. Access to road network and traffic impacts are important matters to be investigated further. Policy 6: Development Criteria Consultee ID: 354343 Full Name: Mr Chris Walker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD103 Is Site Suitable? Site Number: Policy Issue 6: Development criteria which proposals will need to satisfy Site comment: A definition of 'significant' adverse effects on the public needs to be set out as, just as the Plan suggests technology will change over the next decade, so will knowledge about health and environmental impacts of e.g. burning waste. For example, when radioactive material was first used in domestic fire alarms, it was not envisaged that they would be incinerated when disposed of and this has markedly different impacts from disposing to landfill. Given these risks, waste reduction is the only responsible option. Officer's Initial Comment: Noted. Decisions need to be based on best possible information available Page 219 Consultee ID: 354718 Full Name: Ms Sarah Lindon Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD114 Is Site Suitable? Site Number: Policy Issue 6: Development criteria which proposals will need to satisfy Site comment: Strong requirements, monitoring and enforcement must be in place to deal with the potential impacts of new waste management facilities, from all kinds of pollution and congestion. This should be built into contracts. Contracts should also go further and be designed to make it easy for the authorities to upgrade sites to newer, more sustainable technologies as they become available, and to switch away from any irresponsible providers. Officer's Initial Comment: Noted. SLWDP relates to the operation of Planning Acts and therefore cannot directly control contracts. Consultee ID: 273466 Full Name: Dr Bella Davies Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD131 Is Site Suitable? Site Number: Policy Issue 6: Development criteria which proposals will need to satisfy Site comment: Yes BUT Criteria 5 is too restrictive and does not satisfactorily recognise how ecosystems function with an assessment only being required for the site and adjoining land. Different organisms use a landscape differently and it may not always be the adjacent land that is important to their survival. Thus, the policy should better reflect the functioning of ecosystems by requesting no impact on neighbouring land at a scale appropriate to the species under study', rather than just referring to adjacent land'. WP6 needs to include an assessment of the impact of the development on heat and evapotraspiration from the site. Agenda Item 3 This is related to the Urban Heat Island Effect which will be in addition to forecast temperature increase associated with climate change (See Climate Predictions UK 2009) and will amplify many of the impacts experienced in urban areas. Officer's Initial Comment: Noted. Nature conservation and ecology are matters of acknowledged importance Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 127 of 142 Policy 6: Development Criteria Agenda Item 3 Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD48 Is Site Suitable? Site Number: Policy Issue 6: Development criteria which proposals will need to satisfy Site comment: A pity WP6 did not stop landfill at Beddington and the Thames Valley gravel/sand beds! there is considerable reference in the DPD to highway transport. This natural and politically sensitive. please do not omit the possibility of water-ways including the Thames!) and light rail systems. Another reason fro addressing waste management on the 'Whole London Foundation'. Officer's Initial Comment: Noted. Opportunity for non-road based transport of waste is important Consultee ID: 350694 Full Name: R Hills Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL121 Is Site Suitable? Site Number: Policy 6: Development Criteria Site comment: definitely - but will they? Officer's Initial Comment: Noted Consultee ID: 354117 Full Name: Ms Anne Middlemiss Organisation: Page 220 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL171 Is Site Suitable? Site Number: Policy 6: Development Criteria Site comment: I would like to see definitions or examples of significant impact on local people on the environment. My example would be the continuous bleeping from reversing lorries on the Villiers Road site which made our lives a misery from 2000 until relatively recently, when the workflow was redesigned. The Council environment department seemed powerless to get anything done and by implication we were expected to get on with it and stop complaining. I would hate to think of this being inflicted on other residents because it was not considered significant. Officer's Initial Comment: Noted. Attention to measures to reduce local impact such as workflow. Consultee ID: 354616 Full Name: Mr Peter Haynes Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL195 Is Site Suitable? Site Number: Policy 6: Development Criteri Site comment: Re site 60: In order to measure the impact on the environment on this site it is necessary to know about the environment now. e.g. My understanding is that Merton Council do not have current air pollution details for site 60. Heavy lorries will certainly have a detrimental effect in terms of noise, dust and air pollution. Officer's Initial Comment: Noted. Environmental impacts, air quality, noise, dust and pollution and traffic details are matters which require further investigation Consultee ID: 354694 Full Name: Mr Bernard P Meade Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL222 Is Site Suitable? Site Number: Policy 6: Development Criteria Site comment: Acceptable Officer's Initial Comment: Agreed Consultee ID: 355250 Full Name: Mr John Shayler Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 128 of 142 Policy 6: Development Criteria Consultee ID: 355250 Full Name: Mr John Shayler Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL256 Is Site Suitable? Site Number: Policy 6: Development Criteria Site comment: No significant impact on residents Carshalton Road....Impossible Officer's Initial Comment: Noted. Impact on residential amenity is an important factor and further information is required. Policy 7: Sustainable, Modern Energy Recovery Consultee ID: 354343 Full Name: Mr Chris Walker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD104 Is Site Suitable? Site Number: Policy Issue 7: The governance of sustainable, modern energy recovery where appropriate Site comment: Burning waste needs to be avoided at all costs. This policy appears to suggest that there are magical, clean ways of burning waste that will simultaneously address our energy needs. This is patronising, there are no proven, risk free ways of burning waste without incurring significant threats to human health and the environment. A far more efficient way to save energy and not damage life and the environment is to produce less waste in the first place. Officer's Initial Comment: Disagree. Plan consultation seeks views on the range of waste reduction and waste treatment opportunities available. Page 221 Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD49 Is Site Suitable? Site Number: Policy Issue 7: The governance of sustainable, modern energy recovery where appropriate Site comment: (p.51) rightly emphasises the need to useless fossil fuel. we need to ensure that our waste management schemes have a neutral carbon footprint or better. Officer's Initial Comment: Agree Reduction in carbon footprint Consultee ID: 350654 Full Name: Ms Anne Keeley Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL112 Is Site Suitable? Site Number: Policy 7: Sustainable, Modern Energy Recovery Site comment: Up to date systems that are self contained and reduce waste to inert re-usable or recyclable products. Full use of modern science and technology. This is an opportunity to be creative about the use of waste products. Officer's Initial Comment: Noted. The SLWP seeks to encourage best practice.
Consultee ID: 350694 Full Name: R Hills Organisation: Agenda Item 3 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL122 Is Site Suitable? Site Number: Policy 7: Sustainable, Modern Energy Recovery Site comment: But this has not completely ruled out incineration. (bullet point 2) most important but should link with reducing non- biodegradable waste produced locally and nationally. provided the heat generating process is environmentally friendly in the first place Officer's Initial Comment: Noted. Information on proposed future activities on selected sites will be provided at final stage of plan when this is clear.
26 November 2009 Page 129 of 142 Policy 7: Sustainable, Modern Energy Recovery Agenda Item 3 Consultee ID: 354108 Full Name: Mr Christopher Rimell Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL163 Is Site Suitable? Site Number: Policy 7: Sustainable, Modern Energy Recovery Site comment: What method of waste disposal will be used? Officer's Initial Comment: Noted. Information on proposed future activities on selected sites will be provided at final stage of plan when this is clear. Consultee ID: 354362 Full Name: Mrs Leigh Terrafranca Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL180 Is Site Suitable? Site Number: Policy 7: Sustainable, Modern Energy Recovery Site comment: Would it be appropriate to include here a recommendation that direct 'reuse' of any existing waste (i.e. used furniture that could be passed on to a housing association; or old wood and used paving slabs made available to allotment holders) would be required, to achieve the objective of being a truly 'sustainable, modern energy recovery? Officer's Initial Comment: Noted. Further information to be provided. Consultee ID: 354694 Full Name: Mr Bernard P Meade Organisation: Page 222 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL223 Is Site Suitable? Site Number: Policy 7: Sustainable, Modern Energy Recovery Site comment: Acceptable Officer's Initial Comment: Agreed Consultee ID: 355250 Full Name: Mr John Shayler Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL255 Is Site Suitable? Site Number: Policy 7: Sustainable, Modern Energy Recovery Site comment: Good Officer's Initial Comment: Agreed General Consultee ID: 354343 Full Name: Mr Chris Walker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD105 Is Site Suitable? Site Number: Delivery of the South London Waste Plan Site comment: This is a really disappointing document, it appears to be flawed and misleading and lacks any coherent vision regarding waste reduction. Officer's Initial Comment: Disagree. Consultee ID: 206179 Full Name: Dr. Stanislaw Prokop Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 130 of 142 General Consultee ID: 206179 Full Name: Dr. Stanislaw Prokop Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD213 Is Site Suitable? Site Number: Table 2.2: Existing waste sites considered to have potential for re- development as waste management facilities, by borough Site comment: PURLEY WAY group: 1,97,100, 102,104,105,125, The Purley Way group of sites are unsuitable because they will be sited (to various degrees) on land contaminated by previous heavy industry. The fact that Mouchel, the company responsible for the technical assessments, took none of this into account is surprising to say the least. Their representative at the consultation admitted to not knowing about Croydon's industrial pat, but he said, had noticed the gasholder! The cement works, power stations a and b ( and their ash pile leachings) the Gasworks and naphtha plant, Trojan Smelting works, Vespa factory and another smelter seemed to have passed him by. The Corby judgement is popularly known to be about compensation for young people's limb deformities, less well know are the new prescriptive rules on councils and their duty of care in the planning of new developments and including steps to eliminate all forms of damaging pollution. The silence of this consultation in this area, and the apparent ignorance of this area by Sutton planning officers, is a very serious flaw. Officer's Initial Comment: The point raised is an important consideration. The Mouchel criteria based assessment identified that sites 1, 102, 104, 105 and 125 have land contamination. In the event that a planning application were to be submitted a developer would be required to provide technical reports and evidence to address the issues raised. Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation:
Comment ID: PSPCD37 Is Site Suitable? Site Number: Table 2.2: Existing waste sites considered to have potential for re- Page 223 development as waste management facilities, by borough Site comment: To some degree this is impossible to say, with due thought, because: This document has no supporting glossary, or annex of vital information such as the content of (p.17) "Annex E of PPS10, Sustainable Waste Management" part of national policy. The fact that almost all sites identified in this document are in existing heavily polluted by road traffic and adjacent to major housing estates could go down badly in the minds of those voters. The green areas of all 4 boroughs are shown as unaffected by sites, but will doubtless bear more of the cost! Officer's Initial Comment: Agree - Traffic, Environment and Green space and compatibility with adjacent land uses are matters of acknowledged importance. Disagree - Guidance on Plans requires LPAs not to re-state Government Policy. Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD39 Is Site Suitable? Site Number: Table 2.4: Top scoring new sites with opportunity for developing waste management facilities, by borough Site comment: This document has no supporting glossary, or annex of vital information such as the content of (p.17) "Annex E of PPS10, Sustainable Waste Management" part of national policy. The fact that almost all sites identified in this document are in existing heavily polluted by road traffic and adjacent to major housing estates could go down badly in the minds of those voters. The green areas of all 4 boroughs are shown as unaffected by sites, but will doubtless bear more of
the cost! Agenda Item 3 Officer's Initial Comment: Agree - Traffic, Environment and Green space and compatibility with adjacent land uses are matters of acknowledged importance. Disagree - Guidance on Plans requires LPAs not to re-state Government Policy. Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 131 of 142 General Agenda Item 3 Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD40 Is Site Suitable? Site Number: Table 2.5 Top scoring new sites with possible deliverability constraints, by borough Site comment: The document is sparse on information but in general the table accords with my visual impressions. Officer's Initial Comment: Noted. Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD41 Is Site Suitable? Site Number: Table 2.6: Industrial estates which generally score well and are expected to have some deliverable areas, by borough Site comment: seems futile to attempt this, in detail since: Some public companies may acquire sites (with necessary planning consents) to engage in waste collection and disposal/recycling businesses The technologies and techniques and plant sizes are unknown as yet Officer's Initial Comment: Agree - details of technologies, plant etc not known at this stage but more will become available
Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Page 224 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD42 Is Site Suitable? Site Number: Sites Site comment: Some are likely to emerge as the waste management programme gathers momentum and political weight. Some sites will become more interesting for the waste plan as the techniques and equipment develop further. Officer's Initial Comment: Noted Consultee ID: 349878 Full Name: Mr Keith Holt Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD50 Is Site Suitable? Site Number: Delivery of the South London Waste Plan Site comment: The DPD needs to be sold to the council tax payers as part of an under programme for human survival (e.g. reducing our tendency to pollute/poison ourselves and wildlife). This programme involves state public relations (No.7 political point scoring and certainly not (blaming the European Union for Waste Management encouragement!) and attitude changing. I found this larger version of the Stage 2 Consultation Document a touch difficult to follow e.g. a glossary accompanied by location of sources would help readers. My judgement is that too much energy is being diverted by political realities (lovely if coming to work together on this scale) to identifying sites. This is the easy bit! Just wait and see how we move to action on the ground, in a situation of tightening timescales. It seems likely that major change other than planning is the likely in the first 8 to 10 years. Officer's Initial Comment: Noted Consultee ID: 350514 Full Name: R Bolton Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 132 of 142 General Consultee ID: 350514 Full Name: R Bolton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD58 Is Site Suitable? Site Number: Table 2.3: Existing waste sites with possible delivery constraints Site comment: Provided approach road to site is able to cope with extra vehicles, this site has some potential. Not only site owners need to be consulted, but residents. Any site chosen needs to have long time use, otherwise costs will rocket if a change is required to another area. Officer's Initial Comment: Consultee ID: 350514 Full Name: R Bolton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD59 Is Site Suitable? Site Number: Table 2.4: Top scoring new sites with opportunity for developing waste management facilities, by borough Site comment: Not all the sites shown are suitable No.6 and 22 seem likely development sites. The number of sites should be limited to two for the South London Waste Plan. The sites need to be large enough for extra expansion, staff numbers need strict control so as not to have 'idle hands' or place more burden on tax payers through council tax. Officer's Initial Comment: Noted support for sites. Disagree SLWP cannot rely on designating only two sites Consultee ID: 350514 Full Name: R Bolton Organisation: Agent ID: Agent Name: Agent Organisation: Page 225 Comment ID: PSPCD60 Is Site Suitable? Site Number: Table 2.5 Top scoring new sites with possible deliverability constraints, by borough Site comment: The consultants have made their own case for the sites not to be developed. Any site that is overall must not be close to residential housing. Covered areas to be designed to keep down dust, fumes and other smells. Officer's Initial Comment: Noted support for waste treatment in covered areas. Compatibility with adjacent land uses, dust, fumes and smalls are important issues Consultee ID: 350514 Full Name: R Bolton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD64 Is Site Suitable? Site Number: Table 2.6: Industrial estates which generally score well and are expected to have some deliverable areas, by borough Site comment: No mention is made of toxic fumes, gases and spread of other harmful elements to any of these sites. Inspectors must lay down strict conditions of how any new plant is to be operate, or human illnesses could be a result. Officer's Initial Comment: Noted support for restrictive conditions
Consultee ID: 350514 Full Name: R Bolton Organisation: Agenda Item 3 Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 133 of 142 General Agenda Item 3 Consultee ID: 350514 Full Name: R Bolton Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD65 Is Site Suitable? Site Number: Delivery of the South London Waste Plan Site comment: Which ever sites are chosen , must first have a full check on toxic fumes and other harmful substances escaping from the sites. It is no use recycling items that put the public in health dangers. Avoid making new access roads if possible as this will add hugely to costs. Every steps taken in this waste plan must have cost to rate payers at the forefront of the minds of all those involved. There must be doubts about co-ordination of schemes when currently in Kingston Borough, orders placed for canvass replacement sacks due to crumbling) have failed to arrive. Officer's Initial Comment: Noted - emissions and public health related matters and traffic are matters of acknowledged importance. Each council has a responsibility for "best value". Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD77 Is Site Suitable? Site Number: Table 2.5 Top scoring new sites with possible deliverability constraints, by borough Site comment: In general terms, these sites are too close to residential developments and parkland facilities, they also share problems of accessibility. Page 226 Officer's Initial Comment: Disagree- SLWP is charged with finding suitable sites in south London for future waste management needs Consultee ID: 350573 Full Name: Ms Gillian De Veras Organisation: Croydon Friends of the Earth Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD89 Is Site Suitable? Site Number: Delivery of the South London Waste Plan Site comment: All policies in the South London Waste Plan set out criteria that must be followed to protect the environment. As in Q12, I wish to emphasise as strongly as I can that these criteria must never be compromised or departed from in anyway whatsoever. We all have disasters in our memories from Bhopal to the Corby Steel Works, where greed has triumphed over humanity, with unforgivable effects, not only on local populations, but on the environment as a whole. Officer's Initial Comment: Noted Consultee ID: 354343 Full Name: Mr Chris Walker Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPCD94 Is Site Suitable? Site Number: Sites Site comment: This is a flawed consultation as waste reduction / waste hierarchy options have not been fully explored and it is impossible to make judgements on specific sites without knowing the technologies being planned (which must mainly be some form of incineration) and the outcome of individual environmental impact assessments. Officer's Initial Comment: Disagree The second stage consultation relates to the implementation of the waste hierarchy. Further information on environmental impact etc will be included in further stage where information is available. Consultee ID: 211690 Full Name: R Bernini Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 134 of 142 General Consultee ID: 211690 Full Name: R Bernini Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL100 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: All sites should be based at 'landfill' sites already in existence. Recycle what can be re-used/utilised and transport the remainder to existing landfill sites on which processing plants can be erected. Officer's Initial Comment: Noted. Preference for location of waste processing on existing landfill sites. Consultee ID: 350639 Full Name: Gill Locke Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL105 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Very important to make the right choice for foreseeable future developments with waste management - for this reason the site should not be in current residential areas or where traffic flow, including heavy vehicles, is already causing problems Officer's Initial Comment: Noted. Impact on residential amenity and quality of life and traffic impacts are matters of acknowledged importance. Consultee ID: 350647 Full Name: Mrs E Brewer Organisation: Raynes Park Townswomens Guild Agent ID: Agent Name: Agent Organisation:
Comment ID: PSPSL107 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Page 227 Site comment: In our opinion existing sites being expanded is the wisest of the plan. Creating new ones in residential areas we do not agree with. Unfortunately we were unable to attend the workshop in Merton because being an older age group and relying on the 163 bus route due to road work the buses were re-routed from 20:00 - 3:00 resulting that although we could have got to the meeting anyone living within the Grand Drive area would not have been able to return home without along walk and not possible at night when you are between 70 and 87 years of age. Officer's Initial Comment: Noted. Timing of future consultation workshops to be reconsidered to be more accessible by all sections of community. Consultee ID: 350654 Full Name: Ms Anne Keeley Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL113 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Aim for a philosophy that looks at waste as part of a positive feedback cycle, where cheapish) energy and compost is produced from local waste. Officer's Initial Comment: Noted. Consultee ID: 350694 Full Name: R Hills Organisation: Agent ID: Agent Name: Agent Organisation: Agenda Item 3 Comment ID: PSPSL123 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Existing local sites should be able to deal with local waste. Enlargement of these existing sites, if necessary should therefore be the preferred option. The type of waste disposal envisaged should be identified first before sites are considered, as this will determine its effect on the local environment when it is processed. National waste of none-biodegradable items, particularly plastic, has to be reduced. recyclable paper or no packaging (e.g. for fruit and veg.) should become the norm. Officer's Initial Comment: Noted. Preference for further growth in capacity of existing sites. Information on proposed future activities on selected sites will be provided at final stage of plan when this is clear. Respondent wishes to see more emphasis on reduction of waste stream 26 November 2009 Page 135 of 142 General Agenda Item 3 Consultee ID: 350729 Full Name: Mr Stewart Keating Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL126 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: No sort of incinerator plant is appropriate/ suitable for high density residential areas. Sooner or later the filtration system will fail or become overloaded and all sorts of nasty things will be released into the atmosphere. Officer's Initial Comment: Noted. Information on proposed future activities on selected sites will be provided at final stage of plan when this is clear. Consultee ID: 350893 Full Name: B J Woolgar Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL131 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Its very difficult to make sensible comments when the plan is so vague - I think the main query in most peoples minds would be are there plans for any incinerators on the sites an what is the 'heat treatment' mentioned as a possibility. Officer's Initial Comment: Noted. Information on proposed future activities on selected sites will be provided at final stage of plan when this is clear. Consultee ID: 350903 Full Name: Ms Alice Rutt Organisation: Agent ID: Agent Name: Agent Organisation: Page 228 Comment ID: PSPSL133 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Why is one site serving four boroughs? Officer's Initial Comment: Disagree. SLWP does not propose one single site for plan area. Consultee ID: 354055 Full Name: Ms Sheila Kemble Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL139 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Is there a link with government to make necessary changes to packaging which accounts for so much waste? I will write to local supermarket. Officer's Initial Comment: Noted. Respondent wishes to see more emphasis on reduction of waste stream Consultee ID: 354055 Full Name: Ms Sheila Kemble Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 136 of 142 General Consultee ID: 354055 Full Name: Ms Sheila Kemble Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL140 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I heavily endorse the poilicies that we should try and minimise waste and not transport to landfill in countryside. Recycling and composting priority - legislation to reduce packaging and what is used be compostable. Plastics are toxic, when burnt or in ground - types of plastic necessary should be of one or two types, able to be easily recycled. The local environment and people must be protected. Policy 4 & 5 are important that developers do not impose short term interests we do not want an incinerator to burm up material that would be reused or recycled or composted or anaerobic digester.Contracts must be stringent that developers are monitored closely to ensure policies are fully upheld. If waste is managed very effectively then we hope it will be reduced - this will affect use f sites. Any energy from waste is really positive. Compost from waste is really positive. New materials(paper mache), containers from paper instead of plastic is positive. Officer's Initial Comment: Noted. Information on proposed future activities on selected sites will be provided at final stage of plan when this is clear. Respondent wishes to see more emphasis on reduction of waste stream Consultee ID: 354059 Full Name: Mr & Mrs MR. & M Tulloch Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL144 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Welcome attempt to increase recycling and reduce landfill. Page 229 Officer's Initial Comment: Agreed. Consultee ID: 354060 Full Name: Ms Janice Graham Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL148 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Is there an estimate on how much all this will cost? What will happen if this scheme does not work? Officer's Initial Comment: Noted. Information on proposed future activities and costs on selected sites will be provided at final stage of plan when this is clear. Municipal Waste procurement information is in public domain and will be cross referenced Consultee ID: 354103 Full Name: Miss R Dunbavand Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL161 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I agree that we have to do something about all the waste we dispose of (first priority for me is to halt all the packaging around supermarket food), and I think we have to re-use it in some way. The type of disposal units you describe I am in favour of but away from residential areas.
Officer's Initial Comment: Noted. Preference for location of activities away from residential areas. Respondent wishes to see more emphasis on reduction of waste Agenda Item 3 stream Consultee ID: 354108 Full Name: Mr Christopher Rimell Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 137 of 142 General Agenda Item 3 Consultee ID: 354108 Full Name: Mr Christopher Rimell Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL164 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: It all boils down to what method of waste disposal you will use? If you are not going to burn it what will you do? Officer's Initial Comment: Noted. Information on proposed future activities on selected sites will be provided at final stage of plan when this is clear. Consultee ID: 354117 Full Name: Ms Anne Middlemiss Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL170 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Only that I hope that, when more technical details are available for various recycling processes, the public can be informed. Two aspects of this interest me: There are many forms of plastic which are not recyclable at present and there may well be technologies that could be introduced. This would certainly cut my landfill output significantly. Will you be handling any low level radioactive waste and how will this be dealt with? Officer's Initial Comment: Noted. Information on proposed future activities on selected sites will be provided at final stage of plan when this is clear. Information on radioactive waste stream to be included in submission version of plan.
Consultee ID: 354546 Full Name: Mr D.T.R Evans Organisation: Page 230 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL192 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: An excellent concept, but much further thought and consultation needs to be applied regarding the proposed location of these WM sites. Officer's Initial Comment: Noted. Further information gathering to be carried out. Consultee ID: 354613 Full Name: Ms Christine Bradley Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL196 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I would have concerns about the sites in Chessington, particularly Barwell. This is in a residential area, with heavy traffic already off the Leatherhead Road, due to it's proximity to the M25. It is also close to several schools, including the newly redeveloped Chessington Community College. Finally, it would be the first sight to greet the many people who get off the train at Chessington South station to go to Chessington World of Adventures; hardly welcoming, and dangerous to the large number of children using this route. Officer's Initial Comment: Noted. Concern over potential sites identified in Chessington. Issues raised about residential quality, traffic flows, proximity to other land uses such as schools, appearance and traffic safety are matters of acknowledged importance that would require further investigation. Consultee ID: 354616 Full Name: Mr Peter Haynes Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 138 of 142 General Consultee ID: 354616 Full Name: Mr Peter Haynes Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL197 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Developments for increased capacity should be either on existing sites or on sites away from residential areas and common/ park land (areas of natural beauty). If private developers using 'hi tech' methods are interested , then these should be used by the South London Waste Plan. The plan should not compete with private developers. The waste they are interested in is very profitable. Councils, not private developers, should benefit. Officer's Initial Comment: Noted. Preference for development of existing waste sites and away from residential areas and parkland and other areas of natural beauty. SLWP seeks to work with waste operators etc and further work to be done on this. Consultee ID: 354850 Full Name: Jackson Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL230 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Wherever the site is situated it should not be built on or near any wild life site, nor should it be built where lorries have to negotiate residential roads. Access should be on, or just off, major A-roads or motorways where the extra traffic may be more easily assimilated. This site will be for the future and lorries are getting bigger. Officer's Initial Comment: Noted. Preference for locations close to main road network and away from wildlife sites and residential areas/roads.
Consultee ID: 355171 Full Name: Mrs E Gray E.B.E Organisation: Page 231 Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL237 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: With so much help for food waste and cardboard why is gardening waste (compost) so expensive to have removed. Officer's Initial Comment: Disagree. This is a matter for the Municipal Waste Strategy and the policies of individual waste collection authorities not the SLWP Consultee ID: 355240 Full Name: Mrs P.R Smith Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL249 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: I argue we should use modern treatment facilities as reusing and recycling and turning it into useful compost. I am concerned that other types of treatment may not be scientifically proved to be safe. Officer's Initial Comment: Noted. Information on proposed future activities on selected sites will be provided at final stage of plan when this is clear. Consultee ID: 355299 Full Name: Dr Alan Lewis Organisation: South London Freight Quality Partnership
Agent ID: Agent Name: Agent Organisation: Agenda Item 3
26 November 2009 Page 139 of 142 General Agenda Item 3 Consultee ID: 355299 Full Name: Dr Alan Lewis Organisation: South London Freight Quality Partnership Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL264 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: Whilst the plan's policy options address transport impacts in terms of mitigating site access issues, which would also be the subject of transport assessment at development stage, and the minimisation of transport impacts would be an inevitable result of co-location and keeping processing within source Boroughs, we feel that the necessary detailed consideration of the impact that waste transport has within London is missing. This ties in with previous work conducted by the South London Freight Quality Partnership which indicated that this issue is often overlooked and should be considered as a specific strategic consideration in any plan such as this. Officer's Initial Comment: Agree. Further information on transport of waste is necessary as part of additional evidence gathering. Consultee ID: 349714 Full Name: Mrs. Margaret Randall Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL84 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: The traffic problems connected with the Villiers Road site do not seem to have been considered and this would be a major factor in my objections to an incinerator on the civic amenity site in this area. Page 232 Officer's Initial Comment: Noted. Traffic issues are a matter of acknowledged importance for which further evidence will be assembled. Information on proposed future activities on selected sites will be provided at final stage of plan when this is clear. Consultee ID: 340066 Full Name: Francoise Grimshaw Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 140 of 142 General Consultee ID: 340066 Full Name: Francoise Grimshaw Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL93 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: 1. Moving away from landfills is an important aim, esp. using landfills which are a long way away. 2. Comments regarding sites: Having a firm opinion on sites is impossible because: -plans do not show size/hectares -not being able to know what is proposed for each site -not knowing whether small local facilities are being considered (i.e. more sorting & recycling) or a major facility for the 4 boroughs, or a combination of all -not knowing which processes would be sited where. Regarding transport of waste, and its environmental impact, again, without knowing what is planned, it is difficult to have an informed opinion. On account of policy 6, no site is recommendable for thermal technologies due to -health risks to nearby local vulnerable populations, -risks of contamination of the food chain (i.e.allotments), which would be increased if the possibility of flooding is envisaged -increasing existing emission levels which at times are already over the EU recommended limits (i.e. Waddon area). The site near the Purley Way/Croydon Airport would destroy a public walking and cycle lane between the Roundshaw and Waddon estates (with right of way?). The One Planet Living scheme and Bedzed would be seriously affected by developments in the Beddington area, and so would the newly built housing estate and flats in Croydon near the Purley way/Ikea. A Court has recently over-ruled commercia concerns over confidential information, in favour of the public right to information. Consultation which does not inform clearly in not really a consultation, it is white wash. Finally, the 20 hectares potentially needed may be an over-estimate, based on statistics which predict an increase in waste due to increased population. However given that the aim is to introduce measures to decrease the production of waste, through prevention, re-use and recycling, the production of waste should remain constant at worse, and possibly decrease somewhat, despite the increased population. 3. Comments on policies The waste plan is to be commended for its thoroughness, and concerns. However there are specific points which need to be thought through and given more study, leading to improved decision making in time. A. Leading independent experts agree that there are serious health risks linked to the emissions of the toxic by-products of thermal technologies. These are for instance residual heavy metals, CO2 and other gases, dioxins, toxic fly ash. This happens -though Page 233 mishaps/mishandling/cost cutting during the process, pollutants can escape - if they are captured during the process, those toxic elements need to be disposed of somewhere - the subsequent use of the energy produced is in itself polluting, use will result in further greenhouse gases through burning the fuel created. The is not 'green technology' it is more polluting than coal power stations and getting electricity from gas. Thus thermal technologies should be limited or eliminated altogether from the options considered. Local small sites for NBT and anaerobic digestion should be the first options to be tried and tested before planning for anything else. This may be the best cost cutting alternative. B. Contracting issues There is quite a lot of bad experience recorded regarding contracting issues, with councils finding themselves bound by contract which can -be extremely costly and un-negotiatable,binding councils over too many years, to the detriment of tax payers; obviously economically unsound solutions must be avoided, and public scrutiny is essential to help this process. - be environmentally unsound (i.e. having to produce more waste, or bring in more waste to 'feed' large plants) -impose secrecy, thus preventing public enquiry into possible harmful emissions -not be updated as modern technologies improve. The plan mentions being short-term (i.e. 10 years) but does not say anything about the length of contracting, or providing contracts for local green jobs is the area, for preventing, re-using and re-cycling. C. Monitoring of emissions and air quality. This is left to the environmental agency in the plan, but the councils should be wise to implement some of their own independent monitoring, on a very regular basis, and at different times of the day and year, and link this to local health monitoring. Review panels should be establishedinvolving council employees, scientists and members of the public. This implies that contracting should include access to the facilities by an independent monitoring agency, and clear jointly agreed action plans for emergencies and disaster prevention. D. Toxic waste Councils should reassure the public as to their intention regarding local toxic waste, what will happen to it, how much is predicted, how it will travel, etc. This issue is totally ignored in the waste plan. Agenda Item 3 Officer's Initial Comment: Noted. Disagree that consultation is not seeking to inform. Information on proposed future activities on selected sites will be provided at final stage of plan when this is clear. Consultee ID: 206191 Full Name: MS Giovanna Bernini Organisation: Agent ID: Agent Name: Agent Organisation:
26 November 2009 Page 141 of 142 General Agenda Item 3 Consultee ID: 206191 Full Name: MS Giovanna Bernini Organisation: Agent ID: Agent Name: Agent Organisation: Comment ID: PSPSL98 Is Site Suitable? Site Number: Potential Sites and Policies Consultation - Summary Leaflet Site comment: It is unfair for me to comment since I don't know about other areas Officer's Initial Comment: Noted Page 234
26 November 2009 Page 142 of 142 Page 235 Agenda Item 3
planning report PDU/LDF36/LDD01/01 14 October 2009 South London Waste Authority Boroughs (Croydon, Kingston, Merton and Sutton) Joint Waste Development Plan Document Preferred Options Consultation
Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Planning and Compulsory Purchase Act 2004 (as amended); Town and Country Planning (Local Development) (England) Regulations 2004 (as amended).
Recommendation
That the Mayor agrees that the comments set out in this report and attached appendices should be submitted to the South London Waste Authority Boroughs as the GLA response to the South London Waste Development Plan Document Preferred Options consultation.
Purpose
1 To assist the Mayor in making his representations to the South London Waste Authority (SLWA) Borough’s consultation on the Preferred Options for the Joint Waste Development Plan Document (DPD), which form part of each Council’s Local Development Framework.
2 The Mayor of London’s comments on this document will be made available on the GLA website www.london.gov.uk . Background
3 The Planning and Compulsory Purchase Act 2004 (“the Act”) introduced a new system of preparing development plans. This requires Boroughs to progressively replace existing Unitary Development Plans with a portfolio of Local Development Documents (LDDs) that will collectively form the Local Development Framework (LDF) for each of the Boroughs. The LDF together with the London Plan provides the essential framework for planning at the Borough level. The “development plan” in London for the purposes of section 38(6) of the Act is:
• The London Plan (Regional Spatial Strategy), and • DPDs produced by the Boroughs (and saved UDP policies in transitional period).
4 There are two types of Local Development Documents: firstly, Development Plan Documents, those spatial planning documents that are subject to a statutory adoption
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process and Examinations and have development plan status. Examples of DPDs include Core Strategies, Site Allocations, Proposals Map and Development Control Policies, and Area Action Plans.
5 Secondly, there are Supplementary Planning Documents. These provide supplementary guidance on policies and proposals in DPDs. They do not form part of the development plan and are not subject to Examinations.
The Mayor’s role
6 All LDDs must be in general conformity with the London Plan, in accordance with Section 24(1)(b) of the Act. This requirement is also a key test of the soundness of the plan. The Mayor welcomes early engagement with boroughs as LDDs progress through production stages and will formally issue his opinion on general conformity at the submission stage in line with Regulation 30(1) of the Town and Country Planning (Local Development) (England) Regulations 2004 (“the Regulations”) and Section 24(4)(a) of the Act.
7 Regulation 25 of the Regulations requires consultation at the Preferred Options stage of LDD production. The Mayoral representations made to the ELWA boroughs at this stage will not go forward to the Examination. It is envisaged that the Borough Council and GLA officers will meet to take forward the issues raised by the Mayor before the next formal consultation stage, (Submission to the Secretary of State) so that general conformity with the London Plan can be achieved and the DPD is sound before the Examination commences.
Previous consultation
8 Officers acting under delegated authority made representations to the Issues and Options consultation stage on 10 November 2008. The representations advised that changes were needed to bring the document into conformity with the London Plan. In particular, it was requested that the SLWDPD gave greater consideration to minimising green house gas emissions, co-location of waste and energy facilities, noise, air quality and various transport issues. Strategic issues
Summary of South London Waste Development Plan Document (SLWDPD)
9 The purpose of the SLWDPD is to set out a planning strategy for a ten year period from 2011 to 2021 for sustainable waste management which enables the adequate provision of waste management facilities (including disposal) in appropriate locations for municipal and commercial & industrial waste having regard to the London Plan Borough level apportionment and construction, excavation & demolition and hazardous wastes. The SLWDPD will form part of the LDF for each borough and help deliver the relevant elements of the Community Strategy for each borough.
Waste
10 The London Plan sets out strategic waste management policies and targets to meet the national policy of communities taking responsibility for their own waste and provide for adequate waste management facilities (Policy 4A.21). Policy 4A.22 (‘Spatial policies for waste
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management’ ) seeks to ensure that re-use of existing sites is encouraged with Policy 4A.24 (‘Existing provision – capacity, intensification, re-use and protection’ ) further encouraging boroughs to protect and intensify existing waste sites. Policies 4A.23 ( ‘Criteria for the selection of sites for waste management and disposal’ ) and 4A.27 ( ‘Broad locations suitable for recycling and waste treatment facilities’ ) set out criteria for selecting new waste sites primarily within Preferred Industrial Locations or existing waste management locations, emphasising the importance of co-location with CHP / CCHP. Policy 4A.25 ( ‘Borough level apportionment of municipal and commercial / industrial waste to be managed’ ) sets the apportionment of municipal and commercial / industrial waste to be managed by boroughs and Policy 4.A26 (‘Numbers and types of recycling and waste treatment facilities’ ) requires boroughs to identify a range of waste management facilities to meet expected waste arisings. Policies 4A.28 (‘Construction, excavation and demolition waste’ ) and 4A.29 ( ‘Hazardous waste’ ) encourages boroughs to encourage recycling of construction, demolition and excavation (CDE) waste and the safeguarding and provision of new CDE and hazardous waste management facilities to manage expected waste arisings.
11 The SLWDPD is generally consistent with the London Plan policies on waste management, and the general thrust of the document is supported especially the promotion of the waste hierarchy and emphasis on alternatives to mass incineration and landfilling. The SLWDPD provides for the identification and safeguarding of existing waste sites and provision of compensatory sites if any existing sites are lost. The accompanying technical report provides much detail on the methodology used to identify and screen potential waste sites, as well as an inventory of individual sites.
12 Although the land area of existing sites is provided, it was not possible to identify the waste management capacity of individual existing sites. Recycling centres and civic amenity sites can count towards the apportionment but these have been calculated incorrectly, and 100% of existing annual licensed capacity of other waste sites has also been added where the London Plan only allows for annual estimated throughput. These figures will therefore need to be recalculated, wherever possible using tonnage throughput rather than 75% of licensed capacity. Additional detailed comments are provided within appendix one.
General comments
13 The SLWDPD may also wish to take into account the potential locations identified by the London Wind and Biomass Study 1 that could be used for developing a biomass plant. (See section 3.6.2 in particular). The SLWDPD should also take into account the potential for heat usage.
14 The GLA has published a design opportunities for advanced waste facilities report. This is available on: http://www.london.gov.uk/mayor/environment/waste/infrastructure-design.jsp .
Site-specific comments
15 Comments relating to all new proposed waste sites are provided in attached Appendix 2. On the whole the sites selected are largely supported with the large majority
1 Available at: www.lep.org.uk/uploads/Summary%20of%20Wind%20%20Biomass%20FINAL%20200307.pdf further information available at: www.lep.org.uk/projects/energy-demand-and-supply.htm
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being located within strategic industrial and employment locations. However, there are several identified sites that are not supported.
Site 57 - Land west of Beddington Lane
16 This site is designated Metropolitan Open Land (MOL) and Site of Metropolitan Importance (SMI) for nature conservation. The subject site has recently been subject to a MOL and SMI de-designation proposal via the Sutton Core Strategy document. The Secretary of State inspector’s report found that the reasoning provided had no basis and did not support the proposed de-designation. Therefore the existing designations remain.
17 London Plan policy 3D.10 ( ‘Metropolitan Open Land’ ) states boroughs should maintain a presumption against inappropriate development of MOL and that essential facilities for appropriate uses will only be acceptable where they do not have an adverse impact on the openness of MOL. It goes on to inform that appropriate development should minimise any adverse impacts on the open character of MOL through sensitive design and siting and be limited to small-scale structures to support outdoor open space uses. Therefore the proposed use of this site for waste management facilities would be contrary to London Plan policy 3D.10 ( ‘Metropolitan Open Land’ ). In addition London Plan policy 3D.14 (‘Biodiversity and nature conservation’ ) is clear on the expectation of boroughs to strongly protect Sites of Metropolitan Importance (SMI) for nature conservation. The proposed use of this site for waste management facilities is contrary to the intentions of London Plan policy 3D. 14 (‘Biodiversity and nature conservation’ ) and therefore this site is not supported and should be eliminated from the proposed site list.
Site 47 - Land at Kingston Road / Jubilee Way Junction
18 The site is not within a designated strategic industrial or employment area. Furthermore the site is designated within the Kingston UDP with a preferred use of hotel or recreation. Further reasoning and justification should be provided that demonstrates why this site is required.
Site 124 - Former Government Offices, Hook Rise South
19 The site is not within a designated strategic industrial or employment area, and is designated within the Kingston UDP as a proposals site for housing, affordable housing, special needs facilities or community facilities. As this site will contribute towards Kingston’s housing targets the use of it for waste management facilities will compromise the boroughs ability to reach its targets required by London Plan policy 3A.1 ( ‘Increasing London’s supply of housing’ ). Further reasoning and justification should be provided that demonstrates why this site is required including where the additional capacity for housing will be re-provided should the site be lost to a waste management use. Transport for London (TfL)
20 In line with London Plan policy 3C.25 ( ‘Freight Strategy’ ), sites which actively promote sustainable multi-modal methods of transporting freight will be supported by TfL. The location and design of waste management facilities are important factors in minimising adverse transport impacts. TfL recommends that in selecting sites and determining the layout of future waste facilities, the potential to maximise use of water or rail transport should be considered as a key criteria. Reference to these sources has been included in the document and this is welcomed by TfL
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21 Boroughs should aim to discourage the redevelopment of sites where there is direct access onto the TLRN or Strategic Road Network, in line with London Plan policy 3C.18 (‘ Allocation of street space’). This does not discharge the borough’s responsibilities under the Traffic Management Act 2004. Formal notifications and approval may be needed for both the permanent highway schemes and any temporary highway works required during the construction phase of any works or development arising from this document.
22 All transport and freight movements to and from the chosen sites should aim to be out of peak hours to help relieve congestion on the TLRN and SRN, in line with London Plan policy 3C.17 (‘ Tackling congestion and reducing traffic’). TfL welcomes objective 2 of the proposed policies for the South London Waste Plan (SLWP, page 38) and the development criteria supportive text on page 49 to reduce traffic, congestion, air pollution and greenhouse emissions from waste related transport by reducing travel needs and enhancing access.
23 TfL requests that reference is made to TfL’s London Freight Plan (2007), which provides further guidance for the transportation and handling of waste. In particular, the joint management of commercial, industrial and municipal solid wastes could help to reduce road transport impacts, and the potential to treat bio-degradable waste and turn it into a renewable fuel could be investigated. The SLWDPD should take into account the need to safeguard appropriate land for the transportation of waste, as set out in London Plan Policies 3B.10 ( Environmental Industries ) and 4A.22 (Spatial Policies for Waste Management) .
24 Any application submitted for a waste management facility should include a full transport assessment prepared in accordance with TfL’s Transport assessment best practice guidance document (May 2006). The approach to trip generation must be robust enough to determine impacts on the surrounding highways and public transport networks. Furthermore, where appropiate the highways impacts of such proposals must be fully modelled in line with TfL guidance and should include a Construction Logistics Plan and a Delivery Servicing Plan to help reduce the impacts on the TLRN and SRN. The delivery and servicing plan should include the following:
• booking systems. • consolidated or re-timed trips. • secure, off-street loading and drop-off facilities. • possible mode shift away from road. • use of electric or hybrid vehicles. • using operators committed to best practice, demonstrated by membership of TfL’s Freight Operator Recognition Scheme (FORS), or similar. • swept-path analysis demonstrating sufficient access for delivery vehicles.
25 In line with London Plan policies 3C.21 (‘ Improving conditions for walking’) and 3C.22 (‘Improving conditions for walking’) sites that staff can easily access by walking and cycling will be favoured. A travel plan should also be prepared to support sustainable travel behaviour.
26 Finally, where appropiate TfL will seek financial contributions to ensure all transport impacts associated with such developments are fully mitigated.
Conclusion
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27 Many of the comments that the GLA made at Issues and Options stage have been incorporated into the Preferred Options document, which is welcomed and a number of policy areas are supported. However, a number of changes are required to ensure that the Submission document is in general conformity with the London Plan, as set out above.
For further information, contact the Planning Decisions Unit Giles Dolphin, Assistant Director - Planning 020 7983 4271 email [email protected] Martin Scholar, Strategic Planning Manager (Development Plans) 020 7983 5750 email [email protected] Jonathan Brown, case officer 020 7983 6574 email [email protected]
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Appendix 1
Specific Comments Waste
London Plan Policy South London Comment Waste Plan Policy 4A.1 & 4A.21: Climate Objective 2, Support : Preference on reducing the impact of change mitigation Proposed waste management by promoting waste hierarchy, Policy WP7 managing waste close to source and sustainable transport of waste. Emphasis on alternatives to landfilling and mass incineration. 4A.21: Waste policy & Throughout, Support : Overarching vision is achieving self – targets esp. Sections 1 sufficiency and meeting London Plan targets. & Table 3.18 Support : Specific detail on targets and monitoring progress. 4A.22: Spatial policies Objective 3, Support : The SLWDPD will safeguard waste sites a. Safeguard existing Proposed and provide compensatory site if an existing site is sites Policy WP3, lost. Where re-development occurs SLWDPD WP4 provides for equal or increasing waste throughput. Omission : Individual capacity (throughput) of existing sites is not identified in inventory. Omission: Should account for the need to safeguard appropriate land for the transportation of waste. Support : Inventory of existing large industrial sites b. Reconfigure waste Objective 3, has been provided in technical report and Section 2. transfer sites; & Proposed Omission : No specific mention of the type of waste c. Identify new sites in Policies WP4, management facilities that may be built, but a suitable locations WP5 variety of site size provides enough flexibility to mitigate this. Support : The SLWDPD will require new developments to provide space for collection and d. Provision of suitable Objective 3 storage of recyclables. waste & recycling facilities in new Support : SLWDPD will give priority to sites that developments have direct access to strategic road network, rail e. Deal with waste Proposed and other ‘sustainable transport’. locally or good access to Policy WP5 Omission : The SLWDPD does not prioritise rail rail / water and water over other means of transport. The technical report Paragraph 3.3.8 provide for access to railheads, but gives the same weighting as access f. Safeguard sites with Proposed to the road network. Discussions with TfL and waste management Policies WP4, highway authorities will be required to agree potential WP5 preferred locations with regard to transport. Support: The SLWDPD explicitly proposes to safeguard existing and proposed waste management sites, and provide compensation where a site is lost.
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4A.23: Criteria for Proposed Support : Criteria for considering unallocated sites selection of sites Policies WP4, are set out in WP5. WP5, WP7 Omission : These criteria could also be re-stated in WP4 to include sites already identified as suitable. Otherwise there is a requirement to read the technical report to identify criteria used in selecting sites. Support : SLWDPD will give preference to developments where there are opportunities for combined heat and power. Omission : Nothing specific about co-location of manufacturing from waste, though this is provided for in the technical report paragraphs 3.4.3, 3.4.7. 4A.24: Compensatory Proposed Support : Requirement for compensatory site if lost site provision Policy WP4 to non-waste use. 4A.25: Identify land to Section 2, Support : Section 2 summarises the additional 20 meet borough Tables 2.2 – 2.6 hectares of land required to meet apportionment, apportionment with the technical report providing the detail. Additional ‘contingency’ capacity over this will not be identified until publication version of plan. 4A.26: Identification of Section 2, Support : As above. waste management Tables 2.2 Omission : Indicative throughput of individual facilities facilities. Omission : Technical Report Appendix 2 has counted 30% of the CA site capacity towards total current capacity. Recycling centres and civic amenity sites can count towards apportionment, but based on the current throughput of recycling or re-use. Omission : Technical Report Appendix 2 has used 100% of licensed capacity rather than annual estimated throughput (or 75% of licensed capacity where not known) to measure existing capacity. 4A.27: Broad locations Section 2, Table Support : As above. suitable for recycling 2.4, 2.5, 2.6, and waste treatment Proposed Policies WP4, WP5 4A.28: CDEW waste Policy Issue 1: Support : SLWDPD will support measures to other waste manage CDEW waste with remaining residual streams CDEW waste to be managed at the Beddington Landfill site, meeting self – sufficiency targets. 4A.29: Hazardous waste Policy Issue 1: Support: The allocation of more waste management other waste sites than is required provides flexibility to meet streams any additional demands from hazardous waste. Omission : Need to identify current capacity (sites and throughput) to manage hazardous waste
8
Appendix 2
Comments on identified sites
Top scoring new sites with opportunity for developing waste management facilities, which require further investigation by borough. Site # Site Area Borough Description GLA comment 105 7.02 Croydon Factory Lane Industrial Estate. Strategic employment site. Supported. 125 3.11 Croydon Factory Lane (South side). Strategic employment site. Supported. 99 1.68 Croydon Purely Oaks Highway Depot. Local Open Land but currently operates as a waste depot. Supported. 47 1.72 Kingston Land at Kingston Road / Jubilee Way junction, Designated within the Kingston UDP with a preferred use of Tolworth Hotel / Recreation. See detailed comments within report. 46 3.42 Kingston Leatherhead Road, Chessington, Coal Depot adjacent No designation. Supported. to Barwell Business Park. 641 3.39 Merton Area east Weir Road, Durnsford Road Industrial Area. Special Industrial Area, Flood Risk Zone, Green Chains Policy. Page 243 Strategic Employment Site, Area of Opportunity & Regeneration. Supported. 136 1.45 Merton Deer Park Road site. Special Industrial Area, Strategic Employment Site. Supported. 702 5.6 Merton Garth Road Industrial Area. Special Industrial Area. Supported. 651 9.52 Merton Part of the Plough Lane Industrial Area. Special Industrial Area, Flood Risk, Cycle and Walking routes. Supported. 60 3.18 Merton Rainbow Park Industrial Area. Special Industrial Area, Green Corridor Policy Overlay. Supported. 127 1.94 Merton Willow Lane area by Wandle River. Special Industrial Area. Supported. 57 6.76 Sutton Land west of Beddington Lane adjacent to industrial MOL, SINC 7and Strategic Industrial Location – Not supported, areas and existing waste management facilities. see detailed comments within report. Agenda Item3
9 Agenda Item3
Top scoring new sites with possible deliverability constraints, which require further investigation by borough Site # Site Area Borough Description GLA comment 104 1.73 Croydon Purley Way Lombard Business Park. Strategic employment site. Supported. 124 3.24 Kingston Former Government Offices, Hook Rise South, adjoining sitesDesignated within the Kingston UDP with a preferred use of fronting Kingston Road and Tolworth Station. Tolworth. housing, affordable housing, special needs or community facilities. See detailed comments within report. 41 2.85 Kingston Kingston Road, Tolworth Aggregates Depot south of railway.Strategic Freight Site – Rail connection. Supported. 45 7.71 Kingston Leatherhead Road, Chessington, Barwell Business Park. Strategic employment site, Industrial/Warehouse/Business Area. Supported. 36 2.15 Kingston Leatherhead Road, Malden Rushett, Silverglade Business Within the Green Belt but already wholly developed. Industrial / Park. Warehouse / Business Areas. Supported. 33 3.77 Kingston Red Lion, Red Lion Road Estate, Tolworth. Industrial/Warehouse/Business Area. Supported. 751 4.84 Merton Burlington Road west side junction with A3. Special Industrial Area. Supported. 73 3.7 Merton Bushey Road Industrial Area. Special Industrial Area, Flood risk part of site. Supported. Page 244 61 3.69 Merton Dundonald Road Industrial Estate. Special Industrial Area. Supported. 492 7.69 Sutton Kimpton Industrial Estate, Land East of Kimpton Road. Strategic Employment Site, Strategic Industrial Area. Supported.
Industrial estates which generally score well and are expected to have some deliverable areas. Site # Site Area Borough Description GLA comment 102 Croydon Purley Way, Lysander Road and Imperial Way Industrial Strategic Employment Site. Supported. Area. 351, 352 &34.91 Kingston Chessington Industrial Estate. Strategic Employment Site also designated 353 Industrial/Warehouse/Business Areas. Supported. 642 12.64 Merton Durnsford Road Industrial Estate. Strategic Employment Site, Industrial Policy Area. Supported 69 41.45 Merton Willow Lane Industrial Area. Special Industrial Area. Supported. 5312 4.27 Sutton Beddington Industrial Area Zone 12. Strategic Industrial Area, Strategic Employment Site. Supported. 532 8.57 Sutton Beddington Industrial Area Zone 2. Strategic Industrial Area, Strategic Employment Site. Supported. 533 4.53 Sutton Beddington Industrial Area Zone 3. Strategic Industrial Area, Strategic Employment Site. Supported. 534 4.88 Sutton Beddington Industrial Area Zone 4. Strategic Industrial Area, Strategic Employment Site. Supported. 535 4.65 Sutton Beddington Industrial Area Zone 5. Strategic Industrial Area, Strategic Employment Site. Supported. 539 13.48 Sutton Beddington Industrial Area Zone 9. Strategic Industrial Area, Strategic Employment Site. Supported. 491 5.12 Sutton Kimpton Industrial Estate, Land North of Minden Road. Strategic Industrial Area, Strategic Employment Site. Supported.
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South London Waste DPD
GOL Comments on Stage 2 Consultation – Potential Sites and Policies 20 th July-16 th October
GOL met with Emma Smyth (project manager) and officers from Sutton and Croydon on 9 th October 2009 to discuss the Potential Sites and Policies Consultation Document. Much of the material below was discussed at the meeting.
Structure of the document At present the vision and policies are found at the back of the document. It would be helpful to have these upfront in future documents as they set out the Strategy for waste within the four Boroughs.
Vision/Objectives The vision and objectives, as currently set out on p38, should be strengthened to make them more locally distinctive (e.g. include apportionment figure, self-sufficiency aspirations and spatial distribution of facilities). The recent PINS Advisory Visit Report makes reference to this issue and it should be considered further.
Policy content At present Policies WP1, WP2 and WP7 in particular lack local distinctiveness. We would expect to see additional material in these policies to make them more locally distinctive, robust and measurable:
WP1 – reference should be made to the apportionment figure. WP2 – are there any targets that can be included here ? WP7 – are there any locations where it is appropriate to provide energy from waste linking into new development/regeneration initiatives ?
Sites Allocations Sites should be allocated where possible and all sites that are being allocated should be shown on an OS Map base (including existing safeguarded sites). GOL therefore supports the way this has been done in the document. If wider areas of search are also included in the final plan these should also be shown on a map base. Where this broad location approach is followed, additional evidence will be required to show the likelihood of sites coming forward, within the wider area, during the plan period.
Technologies At present the plan identifies a range of technologies (Table 1.3) and sets out the typical land area requirement for each of these. The plan will then seek to identify and allocate sites of different sizes that could accommodate a range of these facilities, rather than specifying particular technologies for each site. This provides for some flexibility in the plan and GOL supports this approach. The information relating to the technology-neutral stance of your waste management strategy will be part of the context for your approach and could be explained in the plan.
However, if further information is known about sites that are to be delivered in the first 5 years of the plan period including the preferred technology (e.g. if there is Agenda Item 3 Page 248
already a planning application or there have been pre-application discussions) then this should be included.
Delivery Information There is currently very little information on delivery in the consultation document (and this is acknowledged in the text). It is important that you seek to provide as much information as possible on how the sites identified will be delivered and who the key partners will be in future versions of the plan. Phasing information for when the sites are likely to come forward/or are required and funding requirements should also be provided.
However, it is acknowledged that detailed delivery information is unlikely to be available for all the sites and particularly not for those that are not expected to come forward in the first 5 years of the plan period. GOL will support the plan if the approach outlined above is followed.
Waste Streams Information on all waste streams should be included in the plan including hazardous waste.
Cross-boundary issues You should ensure that information on waste that is imported and exported from the area is included in the DPD, particularly if these amounts are significant. This area of the plan is weak at present. This was mentioned in the PINS Advisory Visit Report.
Timescales The DPD should cover at least 10 years from the date of adoption and wherever possible should make reference to the likely approach beyond this time period. GOL will support this approach. See PINS Advisory Visit Report.
London Plan Review Reference should be made in future versions of the DPD to the London Plan review and any potential issues that might arise from this. However, you should bear in mind that the Draft London Plan Policies will not gain full weight until the plan is published following the Examination in Public and policy wording should refer to the adopted London Plan.
Monitoring Table at 3.18 helpfully sets out all monitoring information. However, this should be cross-referenced in the body of the text.
Sustainability Appraisal In the current document little reference is made to your Sustainability Appraisal. As this is a core decision making document for the plan it is helpful to include text linking to this piece of evidence.
Alternatives Section 3 sets out proposed policies for the South London Waste Plan. You have taken the approach in this document of only putting forward draft waste policies. Whilst this is acceptable, you will need to show through your evidence base that you Page 249 Agenda Item 3
have considered any realistic alternatives and not closed off other possible options which would have benefited from further consultation.
Timetabling The advice from PINS on the timetable from examination to receipt of the Inspector’s Report is unchanged (i.e. 29 weeks).
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Our ref: SL/2009/105334/PO-01
Date: 3 November 2009 Ms Emma Smyth Royal Borough of Kingston upon Thames Planning Policy, Guildhall 2 High Street Kingston upon Thames Surrey KT1 1EU
Stage 2 Consultation – South London Waste Plan
We support the ongoing partnership approach on managing waste across Kingston, Merton, Sutton and Croydon. We welcome the Stage 2 consultation and the proposed policies. We have reviewed the Stage 2 consultation and our key issues relate to:
• Encouraging early discussions with the Environment Agency and local communities for new or existing waste sites • Strengthening proposed policy to deliver high standards of sustainable design and construction for new / existing waste sites • Maximising protection and enhancement of the river network within the Waste Plan area • Updates to Sustainability Appraisal following last consultation • Detailed feedback on proposed individual sites • Assessing sites using the latest flood risk information from the Strategic Flood Risk Assessments for each borough
We have separated our response into the following sections:
Section 1 – Feedback on proposed policies and supporting text Section 2 – Comments on individual sites Section 3 – Comments on Appendices 1 - 6
I hope our response is helpful and clear. If you would like a meeting to discuss our response please let me know. We look forward to working with you to deliver the South London Waste Plan.
Yours sincerely
Miss Judith Cooke Area Planning Officer
Agenda Item 3 Page 252 DRAFT
Section 1 – Feedback on proposed policies and supporting text
Section 9.3 – The Vision
We are in general agreement with the proposed vision and objectives set out in the South London Waste Plan and these are in line with the new Waste Framework Directive and PPS10 which we see as the driver for these policies. The objectives are sound and we support these.
We support the adoption of the binding principles of the Waste Hierarchy, once transposed, and would further support the use of Life Cycle Analysis/Life Cycle Thinking, to provide some flexibility in the appraisal and selection of options for waste treatment technologies in the handling and treatment of specific materials and waste streams.
We support the objectives and our suggested comments and updates below will assist in delivering the vision through policy and supporting text.
Proposed Policy WP1 Defining the strategic approach
We agree with this policy and offer the following additional comments.
The Waste Strategy for England 2007 identified the construction, demolition and excavation sectors as a priority area for action given that they produce almost a third of all waste in England. The strategy proposed several targets and measures, a number of which were confirmed in the Government‘s Sustainable Construction Strategy, published in partnership with the construction industry, in June 2008. This latter strategy set a headline target of halving the amount of construction, demolition and excavation waste (CD&E waste) going to landfill in England by 2012, against a 2008 baseline. This again emphasises the need for increased capacity for aggregate recycling facilities.
We would ask you to consider the impacts of our current permitting review (due for completion in March 2010), which will change some of the current exemptions for waste to land, used by the construction industry, into standard template permits. This could have the effect of reducing the availability of sites for re-use and recycling that are available under the existing exemptions regime.
The comments on hazardous waste are noted, however, we are not convinced that there will be no need for additional capacity in the future. Again, whilst we also note your comments on needing flexibility in the plan to address any changes in the predicted waste arising, you should note that the amount of hazardous waste produced in 2008 in London was double that of 2007. We are investigating these figures but there does seem to be a significant rise in the SLWP area
The amount of WEEE waste should also not be underestimated. The Waste Framework Directive refers to ‘preparation for reuse’, and boroughs should become far more self-sufficient in dealing with this arising.
Review of Waste Permitting Page 253 Agenda Item 3 DRAFT
The Environment Agency is currently working with Defra and the Welsh Assembly Government (WAG) to review which businesses handling waste can operate under exemptions, and which require a permit. Our proposals may affect any business that recycles, re-uses or disposes of any kind of waste. For more information on this please visit our website: http://www.environment-agency.gov.uk/business/topics/permitting/32158.aspx
Proposed Policy WP2 Encouraging waste minimisation
We strongly support this policy to secure highest standards of sustainable design and construction. We offer the following additional comments.
We note that this waste minimisation policy is directed mainly at the construction and demolition industry and sustainable construction methods and design. We support this: in particular, the requirement for the provision of Site Waste Management Plans. We note that other initiatives to support waste minimisation are not mentioned, for example, The Mayor’s Green Procurement Code and the Waste and Resources Action Programme (WRAP)’s ‘Love Food Hate Waste’ consumer facing campaigns.
The revised Waste Framework Directive and the Hazardous Waste Strategy consultation (Draft) drives waste minimisation across a range of waste streams underpinned by the waste hierarchy. We therefore ask that you consider a more integrated approach to the wider range of waste streams within this policy.
Proposed Policy WP3 Safeguarding existing waste management sites
We support this policy but would make the comment that understanding operational capacities with any accuracy is extremely difficult. There may be an opportunity within the plan monitoring regime to improve data collection and understanding in this area.
Proposed Policy WP4 Identifying proposed waste management sites
We note the ‘no loss to existing capacity’ policy and support this, however there could be circumstances where facilities are upgraded (i.e. waste is treated further up the waste hierarchy) leading to a reduction in overall throughput/capacity. We would ask that you consider this in the context of the overall policy. We feel this policy needs clarifying to address flood risk, groundwater protection and local nature conservation.
Proposed Policy WP5 Managing the development of waste management facilities on unallocated sites
Point 6 should be clarified to protect sites of local conservation value such as Local Biodiversity Action Plan Species or Habitats.
Point 13 should be amended to read:
“Priority will be given to sites outside source protection zones” Agenda Item 3 Page 254 DRAFT
If the Flood Risk Sequential Test work done to inform this plan identifies that there is a sufficient number of allocated sites within a lower Flood Zone there should be a presumption against unallocated waste site within Flood Zones 2 and 3, or other areas identified at risk of flooding from other sources.
We suggest you insert a further point after (7) reading ‘ The site meets the sequential test for flood risk. ’
Under point (18) consideration should be given to ‘combined heat and power where there is district heating and cooling potential’.
Proposed Policy WP6 Development criteria which proposals will need to satisfy
This policy and supporting text seems to be unaspirational and could be strengthened to deliver environmental enhancements as well as environmental protection. We feel the supporting text should be used to promote consultation with local communities and the Environment Agency where waste sites are proposed or upgrades are proposed to existing facilities. This will help deliver the vision of the South London Waste Plan.
PPS1 (2006) requires the planning system to deliver enhancement in addition to environmental protection,
“Planning should seek to maintain and improve the local environment and help to mitigate the effects of declining environmental quality through positive policies on issues such as design, conservation and the provision of public space…………………. Where adequate mitigation measures are not possible, compensatory measures may be appropriate. In line with the UK sustainable development strategy, environmental costs should fall on those who impose them – the “polluter pays” principle.”
In our previous response to Stage 1 consultation we highlighted opportunities for sustainable construction, sustainable drainage, river restoration and green roofs as new and existing waste sites are developed. Policy 6 should be updated to include environmental improvement and local community consultation as a key policy objectives within Policy 6. We suggest the following criteria are added in Policy 6:
The proposed policy WP6: Development criteria Planning permissions for waste related development will be granted where it can be demonstrated that any impacts of the development can be controlled to achieve levels that will not significantly adversely affect people and the environment. Development will be expected to improve the local environment and early consultation with local communities is essential.
Supporting text – requested alterations
The supporting text on page 49 “Although pollution prevention and control is primarily the responsibility of the Environment Agency,” needs deleting and is misleading. Although the Environment Agency is often the regulator of waste sites it is the operator who is ultimately responsible for pollution prevention and control.
We encourage early pre application discussions on all sites and request the wording in bold below is added on page 49, this is also an excellent opportunity to promote Page 255 Agenda Item 3 DRAFT early consultation with local communities. We request the underlined text below is inserted: By updating this policy and supporting it would help deliver Objective 6 in the vision for the South London Waste Plan. (page 36)
“6. Involve local communities and other stakeholders in decision making.”
“Developers are encouraged to contact the appropriate partner borough and the Environment Agency prior to submission of a planning application to discuss all relevant matters . Local communities should be central to decision making process and consulted early where any new waste sites or upgrades to existing facilities are proposed. We appreciate that the list of impacts is not meant to be exhaustive but we consider that the impacts from both particulate matter and bio-aerosols can be significant and should be specifically mentioned in point (1).
We ask that ‘and watercourses’ be added to point (7).
Policy wording – requested alterations
We recommend the following additional criteria in underlined text are included:
• Prior to submission of a planning application the applicant should discuss proposals with the local community and the Environment Agency • Opportunities for river restoration and improvement need to be delivered for any waste site which has a watercourse on, under or adjacent to a proposed or upgraded facility
Ecological enhancement
We note that there is no reference in the Plan to a commitment to environmental improvement of proposed sites. Policies should reflect the aims of national policy (PPS9 and PPS1) to improve the ecological value of both new and existing sites as part of the planning process.
The enhancement of river corridors is encouraged within PPS9, which states that ‘Local authorities should aim to maintain networks (of habitats) by avoiding or repairing the fragmentation and isolation of natural habitats through polices in plans’ PPS9 also states that this ‘ may be done as part of a wider strategy for the protection and extension of open space and access routes such as canals and rivers, such as those within urban areas ’
PPS9 also states that : ‘Government’s objectives for planning are: • to contribute to rural renewal and urban renaissance by:
– enhancing biodiversity in green spaces and among developments so that they are used by wildlife and valued by people, recognising that healthy functional ecosystems can contribute to a better quality of life and to people’s sense of well-being; and – ensuring that developments take account of the role and value of biodiversity in supporting economic diversification and contributing to a high quality environment.’ Agenda Item 3 Page 256 DRAFT
Proposed Policy WP7
The governance of sustainable, modern energy recovery where appropriate
We note from the policy that preference will be given to gasification, pyrolysis and AD plants. We recommend that consideration be given also to EfW, where it can meet all waste hierarchy criteria and proposed efficiency standards. This may however, require the option for use of both the electricity generated and the heat output via high quality steam use or district heating and cooling. Page 257 Agenda Item 3 DRAFT
Section 2 - Comments on individual sites
London Rivers Restoration Action Plan (January 2009)
The Waste Plan should refer to river restoration and enhancement as a key policy objective for all sites with watercourses, adjacent, close by or under sites. Many of the existing and proposed waste sites offer the following major opportunities for river restoration and naturalisation
The mai n aim of the London Rivers Action Plan (LRAP) is to provide a forum for identifying stretches of river that can be brought back to life. This can be done by improving river channel or riparian habitats, by removing or modifying flood defence structures where safe to do so, or by reclaiming 'lost' rivers currently buried under the Capital's surface.
The action plan is available at: http://www.therrc.co.uk/lrap/lplan.pdf The South London Waste Plan falls within the Thames River Basin District and comprises the river catchments of the Hogsmill, Beverley Brook, Wandle and Ravensbourne. Under the Water Framework Directive (WFD) all of these catchments have been identified as being ‘Heavily Modified’ and none of these waterbodies currently have ‘Good’ ecological status or potential. Actions which have been identified to help address these issues including tackling physical modifications and flow pressures including culverts, reinforced banks, closed watercourses, pinch points and in-channel structures and investigating channel restoration projects to improve flow regime and habitat creation.
Therefore where sites are located adjacent to watercourses attempts should be made to address these issues. For further information about the Thames River Basin District of the WFD please follow the link below:
http://wfdconsultation.environment-agency.gov.uk/wfdcms/en/thames/Intro.aspx
Stage 2 Potential Sites and Policies Full Questionnaire
Sites in Flood Zone 3b (i.e. sites 22, 651, 751 and 69) should not be specified as having potential for redevelopment as waste management facilities.
Table 2.2 Existing waste sites considered to have potential for re- development
6 Villiers road, waste transfer station
The Hogsmill River runs adjacent to the site giving potential for improvement works. The river is currently in a heavily engineered state in this area and improvements to the buffer zone could be incorporated to improve the river corridor.
100 Beddington Lane, Therapia Way
A watercourse runs adjacent to this site so there should be not development within 5 metres of the top of its bank.
Agenda Item 3 Page 258 DRAFT
18 Viridor Recycling Centre Beddington Farmlands, Sutton
There are a number of watercourses traversing this site and there should be no loss of length of ditch as part of any redevelopment of this site. In addition a buffer zone of 5 metres would be required between the top of the bank and any adjacent development. If necessary to facilitate site development ditches can be diverted around the edge of the site once there is no loss of overall length and the quality of the ditch and buffer zone is improved. A 5 metre buffer zone adjacent to all ditches should be incorporated.
Table 2.4: Top scoring new sites with opportunity for developing waste management facilities
99 Purely Oaks Highway Depot, Croydon
This site is unsuitable for development. There is a large pond at this site and records of Kingfisher, Common Frog and Stag Beetle. Stag Beetles are a UK BAP Priority species and a London BAP Priority species. There should be no net loss of wetland habitat as part of the SLWP.
641 Area east Weir Road,
This site is adjacent to the River Wandle providing lots of opportunity for habitat enhancement. We have records of many invasive species in this area as well as records of kingfisher, for which bankside habitat improvement should be carried out.
136 Deer Park Road site
A non main river runs adjacent to this site and any redevelopment of the site would need to incorporate measures to improve this channel including incorporating a minimum 5 metre buffer between the top of the bank and any new development. We have records of many invasive species in this area as well as records of kingfisher, for which bankside habitat improvement should be carried out.
702 Garth Road Industrial Area
This site is adjacent to the Pyl Brook providing an important opportunity for habitat improvement and river restoration, such as is being carried out on nearby areas of the Pyl Brook. For example the channel could be realigned through the site and adjacent area of open space to crease a naturalised river corridor. It is currently heavily engineered and straightened through the Industrial area providing little to no habitat for wildlife. At the very least a minimum of 8 metre buffer zone should be incorporated between any development and the top of the bank.
651 Part of the Plough Lane Industrial Area
The site is adjacent to the River Wandle and provides an important opportunity for habitat management and improvement and river restoration. There is currently no buffer zone adjacent to Plough Lane Industrial Area and the river has been heavily engineered in this location and is in need of enhancement works. An 8 metre buffer is standard requirement between main rivers and any new development, hardstanding, access roads or fencing.
127 Merton Willow Lane area by Wandle River
Page 259 Agenda Item 3 DRAFT
The site is adjacent to the River Wandle and provides an important opportunity for habitat management and improvement, buffer zone creation and river restoration, such as is being carried out on nearby areas of the Wandle.
57 Land west of Beddington Lane adjacent to industrial areas
There are a number of watercourses traversing this site and there should not be any net loss of ditch length as part of redevelopment of this site. In addition a buffer zone of 5 metres would be required between the top of the bank and any adjacent development, including access roads or fencing. If necessary to facilitate site use ditches can be diverted around the edge of the site once there is not loss of overall length and the quality of the ditch and buffer zone is improved.
2.5 Top scoring new sites with possible deliverability constraints, which require further investigation
41 Tolworth Aggregates Depot , Kingston Road, Tolworth
An drain runs adjacent to this site so there should be no development within 5 metres of the top of its bank.
36 Silverglade Business Park, Leatherhead Road, Malden Rushett,
A culverted ditch runs underneath this business park which should be deculverted with any redevelopment proposal. The ditch could be diverted around the edge of the business park, with a 5 meter vegetated buffer zone, to avoid bisecting the site if necessary.
751 Burlington Road west side junction with A3
The site is adjacent to the Beverley Brook and provides some opportunity for habitat management and improvement. There is currently no buffer zone to the Beverly Brook in this area and it has been heavily degraded by development right upto its edge. Improvement of this habitat is greatly needed but the opportunity to do this is uncommon.
492 Kimpton Industrial Estate, Sutton
There is a major river restoration scheme being carried out on the adjacent park with river restoration and realignment among other improvements. The Beverley Brook is culverted for a section underneath the section of the Industrial Estate outlined in Site 492 which should be deculverted and restored to a natural channel as part of works to this site.
Table 2.6 Industrial estates which generally score well and are expected to have some deliverable areas.
353 Chessington Industrial Estate, Kingston
An drain runs adjacent to this site so there should be no development within 5 metres of the top of its bank.
69 Willow Lane Industrial Area, Merton Agenda Item 3 Page 260 DRAFT
The site is adjacent to the River Wandle and provides an important opportunity for habitat management and improvement, buffer zone creation and river restoration, such as is being carried out on nearby areas of the Wandle. The trading estate currently comes very close to the edge of the river and the establishment of a natural bank and a buffer zone of at least 8 metres should be carried out as part of any works to this site.
532, 535 Beddington Farmlands, Sutton
We have records of Stag Beetles on this site which is a UK BAP Priority species. Therefore any works to the site should retain suitable habitat such as dead and decaying wood habitat. We also have records of the Common Frog in the vicinity. Any wetland/pond habitat should be retained and ideally the creation of new ponds should be considered as part of habitat enhancement proposals.
Appendix 8
68 Morden Industrial Area
There is a culverted watercourse running underneath this site named Bunce’s river. Any development of this site should seek to restore the culvert to a natural channel with a natural bed and banks. There should also be a minimum 5 metre buffer zone between future site uses and the adjacent ditch to the eastern side of the site.
74 Northroop Grumman site -Malden Way
This site is adjacent to the Pyl Brook providing an important opportunity for habitat improvement and buffer zone creation. The brook is currently heavily engineered and straightened through this section and surrounding Industrial areas and provides very little habitat for wildlife. At the very least a minimum of 8 metre buffer zone between any development and the top of the bank should be established as a wildlife corridor.
96 George Killoughery Ltd
Part of this site abuts the River Wandle and it is one of the few places along this industrial estate where there is absolutely no buffer zone and the industrial site comes right upto the rivers edge. Taking forward this site should include proving a buffer zone, ideally of 8 metres in width consisting of native vegetation, to re- establish the wildlife corridor along the river. There are records of bats along this river corridor. The existence of a linear corridor of habitat and the screening out of light spillage is very important for bats.
103 Industrial Area Latham's Way and Prospects Way
This would be a key site for reuse and redevelopment. The Croydon branch of the River Wandle runs beneath the site to its upstream limit and it is just at the boundary of this site that the Wandle first becomes an open channel. Redevelopment of this site and the deculverting of the Wandle through the lower section of the site would be an enormous gain for the SLWP.
123 Kingston Waste Water Treatment Works
Works to this site would also provide a huge opportunity for enhancement of the Page 261 Agenda Item 3 DRAFT
Hogsmill which is nutrient rich due to discharge from the STW. The river has great potential for wildlife and even has historic records of water voles in the area. Establishment of a more natural bank structure and inchannel features are greatly needed in this area.
131 Old Kingstonian Rugby Pitches
There are non main watercourses on either site of this site therefore any reuse should incorporate a minimum 5 metre buffer zone. In addition there should be no additional light spillage on the adjacent and surrounding natural habitat and the golf course. Loss of green space should be mitigated. For example new buildings should incorporate a green roof to replace lost habitat.
132 Land north of Worcester Park Road Tolworth
This site runs adjacent to the Hogsmill River which is in need tree works to open up the river and the improvements to the buffer zone. The bank is currently overly steep and the river is straight with no inchannel processes. In addition the river suffers from polluted discharges affecting the water quality. Therefore any works to the site would need to take into account these issues and incorporate enhancement measures. There are also records of common frog on the site for which wetland creation would be beneficial.
134 Old Gas works Motspur Park
The Beverley Brook runs adjacent to this site therefore an 8 metre buffer zone should be incorporated between any development and the top of the bank.
135 Mitcham Common
There are records of notable species of birds, reptiles, amphibians and invertebrates on this site which would need to be protected as part of any local composting scheme. Habitat enhancement to create additional wetland habitat, deadwood habitat and log piles would be highly beneficial.
137 Hackbridge - New re-designation area
This site is a Site of Importance for Nature Conservation and any proposal needs to be sensitive to this designation. In addition there a number of watercourses bisecting and surrounding the site and any proposal would need to incorporate a minimum 5 metre buffer zone with no adverse impact on these ditches as a result of the works. However there is significant opportunity for enhancement to these watercourses. There appears to be a large area of woodland on the site which should be retained. Use of this site should replicate loss of Greenfield habitat through the incorporation of green infrastructure.
145 Land to north west of junction of Leatherhead Road and Fair Oak Lane
This is a Greenfield site and inappropriate for use. However any use will require a minimum of 5 metre buffer zone to be created adjacent to the on site watercourses.
146 Land to north east of junction of Leatherhead Road and Rushett Lane
This site is Jubilee Meadows Site of Importance for Nature Conservation and any Agenda Item 3 Page 262 DRAFT
proposal would need to be sensitive to this designation. It is also a Greenfield site and inappropriate for use. However any use will require a minimum of 5 metre buffer zone to all on site watercourses.
493 Kimpton Industrial Estate Land South of Minden Road
There is a major river restoration scheme being carried out on the adjacent park with river restoration and realignment among other improvements. The Beverley Brook is culverted for a section underneath the section of the Industrial Estate outlined in Site 492 which should be deculverted and restored to a natural channel as part of works to this site. A minimum 8 metre buffer zone would be required between the top of the bank and any adjacent development. In addition significant enhancement to the Beverley Brook is needed in this location as it is straightened and lacking in an any channel features of aquatic or marginal vegetation, rendering it very poor wildlife habitat.
511 Wandle Trading Estate Area A
There is a culverted watercourse running underneath this site which should be deculverted and restored to a natural channel as part of any works to this site.
512 Wandle Trading Estate Area B
The area around the site is designated as the Upper Wandle Site of Importance for Nature Conservation while as the Wandle passes through site the adjacent buildings and hard banks sit immediately against the river. This site should incorporate a buffer zone adjacent to the river by replacing hard banks with a natural or semi-natural bank with a vegetated buffer zone for wildlife. Sites such as this which are very constrained with an absence of bankside habitat can act as a blockage to migrating wildlife up and downstream.
513 Wandle Trading Estate Area C
The area around the site is designated as the Upper Wandle Site of Importance for Nature Conservation while as the Wandle passes through site the adjacent buildings and hard banks sit immediately against the river. This site should incorporate a buffer zone adjacent to the river by replacing hard banks with a natural or semi-natural bank with a vegetated buffer zone for wildlife. Sites such as this which are very constrained with an absence of bankside habitat can act as a blockage to migrating wildlife up and downstream.
536 Beddington Industrial Area Zone 6
There are two watercourses on this site. Therefore any works should incorporate a 5 metre buffer zone between the top of the bank of these channels and any adjacent development.
652 Plough Lane Industrial Area B
The site is adjacent to the River Wandle and provides an important opportunity for habitat management and improvement and river restoration. There is currently no buffer zone adjacent to Plough Lane Industrial Area and the river has been heavily engineered in this location and is in need of enhancement works. An 8 metre buffer is standard requirement between main rivers and any new development, hardstanding, access roads or fencing. Page 263 Agenda Item 3 DRAFT
537 Beddington Industrial Area Zone 7
There is an existing watercourse on this site. Therefore any works should incorporate a 5 metre buffer zone between the top of the bank of this channel and any adjacent development.
32 The Old B&Q and Comet Site, Burlington Road, New Malden
The culverted Beverley Brook runs underneath part of this site which should be deculverted and restored into a natural channel as part of any redevelopment. In addition the site provides some opportunity for habitat management and improvement. There is currently no buffer zone to the Beverly Brook in this area and it has been heavily degraded by development right upto its edge. An 8 metre vegetated buffer zone should be incorporated where the site abuts the river.
38 Fairfield Industrial Estate
The Hogsmill River runs adjacent to the site giving potential for improvement works. The river is currently in a heavily engineered state in this area and improvements to the buffer zone should be incorporated. The river is straightened, heavily engineered and has no bankside, marginal or aquatic vegetation. However relatively simple measures such as the use of deflectors and the creation of semi-natural banks would greatly improvement the river corridor.
50 Oldfields Road Trading Estate
The Pyl Brook is culverted underneath a section of the site which should be opened up as part of any redevelopment. In addition a buffer zone between the on-site use and the adjacent channel should be incorporated. The river has been highly degraded and constrained in this through over-development in the past and should be enhanced as part of proposals for redevelopment where possible.
Agenda Item 3 Page 264 DRAFT
Section 3 – Comments on Appendices
Appendix 1
We recommend including in the glossary Waste treatments options in the link below: http://www.environment- agency.gov.uk/static/documents/Business/7_wip_wm_options_2147947.pdf
Appendix 2 - Relevant Strategies Plans and Programmes
The document omits the following:
Countryside and Rights Of Way Act (2000) which placed a new duty on Government Departments to have regard to biodiversity conservation (to further and promote wildlife conservation) and maintain lists of species and habitats for which conservation measures should be taken or promoted.
Natural Environment and Rural Communities Act 2006 which required that all public bodies in England and Wales have a duty to have regard to the conservation of biodiversity in exercising their functions. The duty aims to raise the profile of biodiversity across the public sector and ensure that biodiversity becomes a natural consideration in policy and decision-making. According to the NERC Act ‘Conserving biodiversity includes, in relation to a living organism or type of habitat, restoring or enhancing a population or habitat.’
Appendix 3 - Proposed Sustainability Monitoring Framework 1 for South London Waste Plan
(5) FLOOD RISK & CLIMATE CHANGE ADAPTATION
Data sources should include the Kingston and Richmond Surface Water Management Plan (SWMP) and National Indicator (NI) 189: Flood and Coastal Erosion Risk Management.
8.2 Priority Habitats and Species
We welcome the Indicators and Sustainability Targets included in this Appendix but do not feel these objectives are reflected by the policies on the plan itself.
Please note that River & Streams are a UK BAP Priority Habitat with the exception of heavily degraded reaches. Section of the River Wandle have also been designated as chalk river which is a UK BAP priority Habitat.
Appendix 5 - Sequential Test
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We disagree with the proposal that the Plan should not allocate specific uses to potential development sites but that this should be dealt with at the planning application stage.
As question 3 of Table 5.1 indicates, PPS10 requires planning authorities to identify the type or range of facilities suitable for any chosen site. Our understanding is that this was meant to provide more clarity and certainty to the developers without which decision making at the planning application stage becomes very difficult. Indeed failure of the Plan to be specific on the type and range of facilities will stifle development and not the other way round as the text on question 3 appears to illustrate.
Once specific uses have been specified, the two vulnerability classifications of: - landfill and hazardous waste management facilities (more vulnerable) and - waste treatment (less vulnerable) can be distinguished and the Sequential Test properly applied in line with PPS25.
We do not agree with your approach to the application of the Sequential Test. The sites have been scored to reflect all the relevant constraints with flood risk being given an equal weighting. This alone, however, does not remove the need to independently apply the Sequential Test within PPS25. The purpose of the Sequential Test is to establish that, where sites are proposed in flood risk areas, that there are no reasonably available alternative waste sites with a lower probability of flooding. This test will need to be applied to sites independently from the weighted scoring of sites, and could potentially result in the preference of lower ranked sites above higher ranked sites in Flood Zones 2 or 3.
The Sequential Test information within the Sustainability Appraisal document does not adequately draw any conclusions as to whether it is necessary to develop within flood risk areas. We consider that the critical question for this is: once all of the clearly undeliverable sites have been removed, is there a sufficient number of remaining sites within Flood Zone 1 to accommodate the predicted need? If so, the sites in Flood Zones 2 and 3 should be removed from the allocations, unless they are for an existing waste site, or where a reduction in flood risk could be achieved through redevelopment
The information states there is a need to identify an additional 20 hectares of land for waste sites. It is not clear from the information available as to the actual amount of suitable, reasonably available land found individually within each Flood Zone and therefore whether this could be delivered without needing to further develop within flood risk areas. If, as appears likely, there is more than 20 hectares’ capacity then we recommend the new sites in Flood Zones 2 and 3 be dropped .
Paragraph 1.20 This is not correct. The Environment Agency Flood Map does not indicate the functional floodplain. The extent of flooding should be defined by the flood zones from the strategic flood risk assessments. The strategic flood risk assessments must be kept up to date with the most recent flood extent information available, including changes to our Flood Map.
Paragraph 5.8 & 6.2 These paragraphs are misleading, giving the impression that a site-specific flood risk assessment is required for all sites in Flood Zone 1. As required by PPS 25 (paragraph E9), a flood risk assessment should be produced for sites of 1 hectare or over in Flood Zone 1 or where it has been identified that the site may be at risk of any other non-main river flooding. This will primarily be identified Agenda Item 3 Page 266 DRAFT
using the Strategic Flood Risk Assessment. The site specific assessment would need to be reviewed by the council.
Source Protection Zones do not relate to the risk of groundwater flooding. They show the area of groundwater within which there is a particular sensitivity to pollution risks due to the proximity of a drinking water source and the way the groundwater flows. Just because a site is near a groundwater abstraction point it does not mean it is at greater risk of flooding than a site far away from one. More suitable data for assessing the risk of groundwater flooding would be a collection of geological and topographical maps, the Defra Groundwater Emergence Map and the depth to groundwater.
Table 5.1 – Sequential Test Questions for Potential Waste Sites The questions posed in SA Table 5.1 should be readdressed.
The Sequential Test can be used to help identify the type of facility and should be applied to existing sites in a different way to new sites. New proposals on existing sites should be located in areas within the site at the lowest risk of flooding. New sites should be sequentially tested so that those at the highest risk can be eliminated. · Annex 1.1: Table 1 and 2.1 Table D.1: These are not the local definitions of functional floodplain. You should be using the definition within the partner boroughs’ strategic flood risk assessments.
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London Borough of Sutton Planning Advisory Group – 8 December 2009
Report of the Head of Strategic and Environmental Planning
Consultation Response to the Mayor’s Three Consultation Draft Replacement Strategies for London: • The draft Replacement London Plan; • The draft Transport Strategy; • The draft Economic Development Strategy; and • The draft Revised Interim Housing SPG
Ward Location: Borough Wide. Author: Sally Blomfield (x6253) Area Served: N/A Lead Councillor: Lyn Gleeson Report for Decision Summary The Mayor has published three draft replacement strategies for London: the London Plan; the Transport Strategy; and the Economic Development Strategy. This report highlights the key proposed changes from existing policy and identifies those revised policies that, within the context of Sutton, should be supported, and, those which raise concerns. The report also sets out comments on the Mayor’s draft Revised Interim Housing SPG which has been prepared in order to clarify the Mayor’s approach on backgarden land, affordable housing and housing density prior to the adoption of the replacement London Plan. This report also sets out the stages in the replacement process; the anticipated final adoption dates and the relative weight that can be afforded to emerging policies in terms of both developing Policy for Sutton and in terms of development control. Recommendations I recommend PAG to agree that the Executive Head of Planning and Transport responds to the GLA’s consultation documents on the basis of this report. 1. Background 1.1 On 12 October 2009 the Mayor published his draft Replacement London Plan (the draft Plan). The draft Plan will be the overarching strategic plan for London setting out an integrated economic, environmental, transport and social framework for the development of London. It will be the spatial expression of the Mayor’s other strategies, and, in order to make sure that there is an integrated approach, the Mayor is carrying out a simultaneous consultation on the draft Transport Strategy and the draft Economic Development Strategy. These three documents are available from the Mayor’s website using the following link http://www.london.gov.uk/shaping-london/ . Over a similar timeframe the Mayor is consulting on his draft Revised Interim London Housing SPG. 1.2 The publication of the draft Plan is the third stage in the preparation of the replacement plan: in July 2008 ‘Planning for a Better London’ was published and in April 2009 “The London Plan Initial Proposals” document was launched which set out the Mayor’s Vision for the capital, his planning objectives and a series of policy directions. 1.3 The London Plan is being reviewed for two reasons: firstly to reflect new evidence, in particular regarding housing capacity, town centre health checks, employment
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land reviews and climate change evidence, and, secondly to set a framework which reflects the new Mayor’s policies and priorities. 2. The draft Replacement London Plan 2.1 The draft Plan is slimmer than the current London Plan (284 rather than 500 pages) and has more of a strategic focus which is welcomed. In order to make the plan more spatially specific, the first policy chapter is on London’s Places, which includes sections on Outer London. 2.2 Application of policy has been clarified as policies are divided to clearly address strategic policy, planning decisions and Borough’s LDFs. The draft Plan has taken into account guidance that national and regional policy should not be duplicated at the local level and therefore it now only requires LDFs to contain policy which has a locally specific dimension. The strategic nature of the draft Plan and its new clarity is welcomed. Key Changes and Implications for Sutton London’s Places 2.4 It is disappointing that there is no clear Vision for how Outer London will look or function by 2031 and this is compounded by the fact that there is no clear delivery programme or understanding of infrastructure requirements for the suburbs. 2.5 The Mayor has sought to distinguish between inner and outer London , giving equal importance to both policy areas in line with his election manifesto and with the recommendations of the Outer London Commission. There is recognition of the potential and contribution of Outer London and the differences and complexities of the area (draft Policy 2.6A) and an emphasis on the need to provide policy responses tailored sensitively to address local circumstances (draft Policy 2.6B). There is also recognition of the need to retain the existing high quality of life in Outer London and that good quality design must relate to local context (Paragraph 2.29). Overall these policies are welcomed. However, apart from these headlines, the policies for Outer London add little value and appear to be no more than a useful summary of what the draft Plan’s other Policies can do in this area. 2.6 Draft Policy 2.15 indicates that town centres remain a key strategic priority and should be the continued focus for commercial development and intensification. The importance of regular health checks is emphasised and the implications of the outcome of this work in terms of the role of the centres. Although this statement is supported there are implications for the Council in terms of staff resources. The Council should also explore any discrepancies between the findings of the GLA’s Health Checks and those currently being prepared by the Council. London’s People 2.7 A lower housing target is set for the Borough (draft Policy 3.3 and Table 3.1) for the period 2011 to 2021 in recognition of the uncertainty of future large sites coming forward and the need to protect backgarden land which is welcomed. 2.8 The council has in the past expressed its serious reservations with the density matrix and its application as set out in the adopted London Plan. These concerns appear to have been addressed to some extent and the draft Plan (draft Policy 3.4) now refers to optimising rather than maximising density; that the density matrix should not be rigidly applied; and clarifies that higher density should not be seen as high rise. This is a more sophisticated approach which puts local context at the heart of consideration of applications and is therefore welcomed and supported. However the Mayor has simultaneously produced a “Draft Revised Interim Housing
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Supplementary Planning Guidance (SPG)” document which appears to undermine the qualifications put forward in the draft Plan. 2.9 There is support for the Mayor’s aims of securing housing of the highest quality and enhancing residential neighbourhoods and the introduction of specific minimum internal space standards for all new dwellings (draft Policy 3.5). These space standards appear to be applied to all housing tenures although the council is aware that Sir Simon Milton has indicated that they will only be mandatory for new affordable homes. The application of this Policy needs to be made clear. 2.10 The policy position on the protection of backgardens is not as strong as expected. As currently drafted, Boroughs “may” introduce such a policy but only “where this can be locally justified”. 2.11 The council is concerned that, with the increasing attention being given to intermediate housing, this element of affordable housing is truly affordable to Borough residents. Whilst the last survey of housing need conducted in this borough (2008) showed that many residents in need could afford more than social rents, their incomes fell considerably short of the entry market levels and most existing shared ownership schemes were close to or more expensive than private market accommodation. Whilst it is noted that draft Policy 3.11 makes provision for Boroughs to set their own affordability thresholds in relation to local incomes and house prices, the role of the affordability banding in the draft plan is not clear. 2.12 Whilst the opportunity to set local borough-wide affordability targets is welcomed there should be clarification on how the Mayor will work with Boroughs to set these. In general, the council favours the use of percentage targets as they are more responsive to annual changes in completion rates. In particular, it is not clear as to how the London Plan numerical affordable target of 13,200 per annum will be applied or distributed amongst boroughs. 2.13 The draft Plan, in addition to allocating permanent pitches for gypsies and travellers , states that further transit pitches will need to be distributed to Boroughs through sub-regional partnerships. However the Mayor should note that the location of transit sites should relate to the routes which are most frequently used by gypsies and travellers and this may not result in an even distribution between the 5 housing sub regions. Further evidence may need to be collected on behalf of the GLA to avoid the creation of unwanted transit pitches and further unauthorised encampments. Similarly, the need for travelling show people pitches should be met where the need arises and there may be benefits in seeking to try and provide such provision adjacent to or near existing sites where there is a need to provide for extended families or maintain existing communities. 2.14 The new provision (draft Policy 3.7) that large residential developments (sites over 5ha) should be subject to a planning framework to co-ordinate provision of social, environmental and other infrastructure and to create neighbourhoods with a distinct character is supported. However, this policy will have implications for the Sutton Hospital site and the need to produce a framework will have to be added to the work programme of policy development. In view of the fact that the residential development part of the Felnex site is just under 5ha it adds to the need to complete the SPD for the Hackbridge area in a timely fashion. London’s Economy 2.15 In the South Sub-Region only the Croydon and Vauxhall Opportunity Areas and the Colliers Wood Area of Intensification are identified. These areas had already
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been identified in earlier Plans and as no new areas have been identified as part of this review there are no new implications for Sutton. 2.16 The Mayor has introduced a new concept of Strategic Outer London Development Centres (draft Policy 2.16) which, he indicates, should be developed and promoted as centres with one or more strategic functions of greater than sub- regional significance. Only one directly affects Sutton: the Wandle Valley which has been identified as having a leisure and tourism function of greater than sub-regional significance. The council welcomes the recognition of the strategic importance of recreation and tourism of the Wandle Valley although is disappointed that its employment role is not promoted. 2.17 Within the South sub-region it should be noted that Kingston has also been identified for leisure and tourism; part of Bexley has been identified as a logistics development centre and for industry; Biggin Hill for transport related functions; Croydon for strategic offices; and Kingston and Croydon for Higher Education (although the position regarding Croydon appears uncertain). The draft Plan indicates that this list is not exhaustive. Whilst it would be difficult to justify the inclusion of other areas in Sutton (having reviewed the criteria) the council will have to ensure that there is significant corporate commitment to the business and economic development of Sutton in order to ensure its market share is not damaged by the growth of these other centres. 2.18 The draft Plan classifies town centres and provides strategic guidance on the direction for individual centres including the potential for growth. Of concern is the fact that Kingston, Bexley and Croydon have all been indentified as metropolitan centres with high potential for growth, whereas Sutton has only been identified as having medium potential. It is important that this classification does not limit the Council’s ability to promote commercial development through the Sutton Town Centre AAP and in accordance with the Council’s Economic Development Strategy. This also emphasises the importance of the need to complete the Sutton Town Centre AAP. If the AAP Vision is not achieved, Sutton with lose significant market share and its metropolitan status may be under threat. 2.19 The council has for a long time maintained that Carshalton Village operates as a District Centre and therefore the fact that this has now been accepted is welcomed. However, its reclassification is qualified by a statement that its status is subject to monitoring which is disappointing. 2.20 Table A2.2 indicates that Hackbridge is currently unclassified (in the Sutton UDP it is classified as a Larger Local Centre) but has the potential over the Plan period to be reclassified as a District Centre. In its response to the Mayor the council should emphasise the Inspector’s report into the Core Planning Strategy which acknowledges the reclassification of this centre and its importance to achieving the Strategy of the Hackbridge Sustainable Suburb. Climate Change 2.21 As indicated in the Mayor’s 2008 policy documents there is considerable emphasis in the draft Plan regarding Climate Change. The Mayor wishes London to be the World Leader in tackling climate change and the Mayor’s commitment to this is supported. Transport 2.22 There is little in the way of strategic investment in transport for Outer London and this is dealt with later in this report.
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3. The draft Transport Strategy 3.1 The draft Strategy sets out the Mayor’s policies and priorities for transport in the capital over the next twenty years. Key Changes and Implications for Sutton 3.2 The increased emphasis in the strategy on improving transport in Outer London, the recommendation to develop a ‘hub and spoke’ approach to transport around the Outer London town centres and strategic business locations, and the decision to abandon the proposed ‘super-hub’ approach that would have concentrated activity in a smaller number of large centres such as Croydon is welcomed. However, the ‘hub and spoke’ approach should link outer London hubs orbitally rather than see each hub as independent. The need to provide more detailed proposals for each sub-region through Sub-Regional Transport Plans is also welcomed, as long as cross boundary movement is taken account of. 3.3 However there is concern that a significant proportion of London’s transport budget over the next few years will be tied up in Crossrail, the Olympics and a number of other major infrastructure projects to the detriment of outer London boroughs that will not benefit from these projects. 3.4 The borough is dependent on ‘heavy rail’ for longer public transport journeys in the absence of a tube line. Consequently, the requirement for ‘ London Overground’ style standards at Southern suburban stations as part of the new South Central franchise is supported and the council should seek to secure greater TfL involvement and funding for rail station and service improvements in the borough. 3.5 The council has recently completed the £5m three year Smarter Travel Sutton project in partnership with TfL, and would like to see the Strategy make reference to the success and achievements of Sutton’s project. 4. The draft Economic Development Strategy 4.1 This Strategy sets out the Mayor’s vision and ambitions for the economic development of London. The Mayor considers that the most effective approach is to encourage “consolidation of strength in business services and finances, together with some diversification into other growth sectors”. After exploring alternative assumptions about where economic development might go he has concluded that, while a strategy of enabling the widest possible contribution to growth, particularly in Outer London, is desirable, it is also essential to consolidate the unique strengths of central London. 4.2 While manufacturing sectors are expected to continue their decline, growth is expected in business & financial services, other services, hotels & restaurants, health & education and retail. Key Changes and Implications for Sutton 4.3 While the need to maintain the global importance of the central London economy is recognised, this should not be to the exclusion of the economies of surrounding boroughs. While this is acknowledged in the draft Strategy, it does not contain any specific or concrete proposals that would help improve the strength and viability of London’s dispersed town centres. This comment also applies to the economic content of the London Plan. 4.4 The draft Strategy emphasises the economic opportunities associated with the accelerating transition to the low carbon economy. Developing the expertise and capacity of businesses and technologies to assist adaptation to and mitigation of
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climate change will provide economic opportunities and new jobs for London’s businesses. This is welcomed and the council should seek to secure such development opportunities within the Borough in line with its Vision for One Planet Living. 4.5 If London took a share of the global low carbon economy in line with its 1% share of global GDP, this would lead to £3.7 billion annually of business opportunities. London is said to be in a good position to develop world-leading low carbon industries, including carbon permit trading (in which London is currently the global market leader), financial investment in renewable projects and clean-technology firms, international environmental consultancy and as a global centre for research & development. 4.6 The Mayor is providing funding towards climate change programmes (over £100m over three years) and is considering the establishment of a London Green Fund – a revolving fund making commercial investments in retrofitting and decentralised energy, waste and transport projects. Elsewhere, the draft Strategy states that the LDA is investing in a decentralised energy programme. The Mayor is committed to supporting the development of up to ten low carbon zones. More details regarding this will be included in the Climate Change Mitigation and Energy Strategy . These approaches are welcomed and the council should seek to access this funding for programmes within the borough. 4.7 Small and medium sized enterprises are the bedrock of the Sutton economy and pre-existing schemes of support for these businesses are complicated. The mayor has proposed streamlining these systems of support. Whilst this goal should be commended there is concerned that the amount of this support will be reduced and that it will be directed at higher technology innovative sectors. A good basic level of support for traditional small businesses needs to be maintained in the medium term to support the vitality of the Sutton economy. Similarly the mayor’s intention to streamline and “personalise” skills and employability support must be welcomed, an area notorious for its complex streams of funding and overlapping provision. However, a rigid pan London approach could undermine boroughs in joining up different strands of provision to create the best possible package for their residents. The Mayor should therefore focus on developing skills schemes and packages with flexibility to be tailored to borough circumstances. 5. Cross-cutting Issues 5.1 Accessibility is key to maintaining the attraction and competitiveness of suburban centres. The vast majority of the proposed investment in transport (set out in the Mayor’s draft Transport Strategy) is aimed at improving the accessibility of Central and Inner London. Such investment reflects, in part, the London Plan’s continuing emphasis on employment growth in central London and, in turn, helps to justify that growth. Insofar as accessibility to employment centres in Sutton will not be improved, they will become relatively less accessible and less attractive as business locations. The Mayor should consider whether his transport proposals could exacerbate the peak pressure on radial routes and whether some judicious investment in orbital routes and linkages would bring about a more economically efficient pattern of trips, as well as helping to secure the economic prosperity of outer London centres, thereby providing a better choice of local jobs and reducing the need to travel overall. 5.2 The GLA’s argument is that there is no business case for significant investment in orbital public transport. However, improved orbital transport is arguably key to the success of the outer London economy. In turn, a higher proportion of jobs in outer
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London would help even out the distribution of peak hour trips. Therefore the council considers that whilst accepting the lack of a current business case for a fast orbital rail system, the Mayor should develop an orbital transport strategy for London that seeks to build on existing provision, identifying strategic problems and opportunities and containing proposals to fill in the ‘gaps’ and improve co-ordination between service providers. 5.3 While the case for Crossrail is recognised, the draft Strategy should recognise that its economic benefits will not be felt uniformly across London. Sutton will not be served by Crossrail and Sutton businesses will experience no material benefit although they will be required to pay a supplementary business rate in order to help fund its implementation. Indeed, insofar as other parts of London will become relatively more accessible, Sutton will become relatively less attractive as a business location. It is also noted that the Mayor has recently approved plans to exempt the Battersea regeneration area from the Crossrail levy, with money directed instead to a proposed Northern Line extension. It is suggested that, in the interests of Sutton businesses, the money raised in Sutton from the levy should instead be diverted to the Tramlink extension which could provide a boost to investment and business activity. 6. Draft Housing SPG 6.1 The draft SPG is intended to provide guidance on the application of the current London Plan policies in relation to affordable housing, backgarden land and housing density. Whilst the statements about the first two issues appear to offer clarity, there is concern about the mixed messages regarding housing density. Whilst the Mayor appears to accept that the density matrix should be applied taking into account local considerations, there are references to undue weight being given to local context rather than to location or public transport accessibility (Paragraph 3.5). The Mayor must clarify the application of the density matrix. 7. Next Steps/Weight to be Afforded to Emerging Plans 7.1 Formal consultation period closes on 12 January 2010 and comments received after that date may not be considered. Although this Report is scheduled to go to the Executive on 18 January 2010 provisional comments should be submitted to the GLA on the basis of this report. 7.2 An examination in public, led by an independent panel, will be held in autumn 2010. The panel will produce a report recommending changes to the draft London Plan for the Mayor’s consideration. It is anticipated that the draft Plan will finally be adopted by spring 2011. 7.3 Whilst the draft Plan is being prepared, the adopted London Plan will continue to have legal status as part of the development plan for the Borough. However the draft Replacement London Plan will be a material consideration that can be taken into account when determining planning applications and it will gather weight the further into the replacement process. 7.4 If there are discrepancies between Sutton’s Core Strategy, Site Development Policies DPD and the Replacement London Plan, legal guidance indicates that the latest adopted document prevails. 8. Financial Implications 8.1 There are no direct financial implications as a result of this report. 9. Influences on the Council’s Core Values, Policy Aims and One Planet Living
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9.1 The council’s goals include achieving environmental sustainability, social inclusion, and economic and community well-being. The council’s Core Planning Strategy and other planning documents have to be in general conformity with the London Plan and this will help the council to achieve the four goals listed above. 9.2 Many of the Mayor’s draft Policies will meet the following One Planet Living Principles: Zero Carbon, Zero Waste, Sustainable Transport, Local and Sustainable Materials, Sustainable Waste, Natural Habitats and Wildlife, Culture and Heritage, Health and Happiness. Indirectly, they may also meet the principles of Local and Sustainable Food and Equity and Fair Trade. 10. Equalities Impact Assessment 10.1 The Mayor’s draft Replacement London Plan has a number of priorities: ensuring London’s continued economic success; delivering homes for Londoners; meeting the environmental challenge; and keeping London moving. When the draft Replacement London Plan is adopted it will be part of the development plan for the Borough and consequently its implementation will secure the council’s objectives of creating strong, active and inclusive communities.
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London Borough of Sutton
Planning Advisory Group – 8 December 2009 The Executive – 18 January 2010
Report of the Executive Head of Planning and Transportation
THE 2009 FIVE-YEAR HOUSING LAND SUPPLY ASSESSMENT
Ward Location: Borough wide Author: Duncan Clarke (x6181) Area Served: Borough wide Lead Councillor: Cllr Lyn Gleeson
Report for Decision
Summary Undertaking a Five-Year Housing Land Supply Assessment is a Government requirement and should demonstrate that the Council can identify sufficient developable housing land to exceed its London Plan additional homes targets for the period 1 April 2010 to 31 March 2015. The Assessment shows that the Council can identify sufficient potential housing capacity for the years under review. The evidence of sufficient housing capacity means that planning applications can be determined according to the Development Plan, comprising the London Plan, the Core Planning Strategy and the Saved Policies of the Unitary Development Plan. It is also an important component in the calculation of the Council’s Housing and Planning Delivery Grant.
Recommendations I recommend the Planning Advisory Group: (i) notes that the Council can meet its Planning Policy Statement 3 requirements to demonstrate a five-year land supply (as set out in Appendix 1) which will form part of the Council’s Annual Monitoring Report submitted to the Government Office for London in December 2009; and, (ii) recommends that the Assessment is forwarded to The Executive for approval through DDN for the purposes of Development Services.
1. Planning Policy Background 1.1 Planning Policy Statement 3 – Housing (PPS3) requires the Council to assess and demonstrate the extent to which it can identify and maintain a rolling five-year supply of deliverable land for housing. PPS3 states that where planning authorities cannot demonstrate an up-to-date five-year supply of deliverable housing sites, planning applications should be considered favourably having regard to PPS3 (para 71). In other words, local planning documents, such as the Unitary Development Plan or Core Planning Strategy, are no longer considerations in the determination of planning applications if a five-year supply of housing land is not demonstrated.
1.2 In January 2009, the London Borough of Sutton was one of the local authorities selected by Communities and Local Government (CLG) for a “spot check” of its 2008 Five-Year Housing Land Supply Assessment. The Council’s document was identified as “having elements of good practice”. In May 2009, CLG published the findings of its spot checks and, as a result, the format of the 2009 document has been amended in places to incorporate other elements of good practice.
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2. Document’s Effect on the Housing and Planning Delivery Grant 2.1 The Five-Year Housing Land Supply Assessment has been an important component in the calculation of the Council’s Housing and Planning Delivery Grant (HPDG). As a result of the 2007 Five-Year Housing Land Supply Assessment, the Council received £72,398 (71% of its total HPDG) for demonstrating it had sufficient housing capacity for the years 2007-2012. The allocation following the submission of the 2008 Five-Year Housing Land Supply Assessment is awaited but, once again, the Council was able to demonstrate sufficient capacity to meet its five-year additional homes target.
2.2 Arrangements for the third annual tranche of HPDG are currently being considered by CLG but it seems likely that the demonstration of a five-year housing land supply may now be only one of three components necessary to secure the housing element of the HPDG. The other two elements are likely to be a completed Strategic Housing Land Availability Assessment (SHLAA) and evidence of active involvement in a Housing Market Partnership. The Council participated in the London-wide SHLAA, which has now been completed and which involved house builders, social landlords and property agents, and so it is assumed that the other two probable components of the housing element of the HPDG would be satisfied. The 2009 Five-Year Housing Land Supply Assessment is the third element required to meet the likely CLG requirements.
3. Five-Year Housing Land Supply 3.1 In order to meet the requirements of a five-year housing land supply, the Council needs to identify sufficient sites to exceed the London Plan annual housing target of 345 units per annum for the years running from 1 April 2010 to 31 March 2015 (i.e. more than 1,725 new homes). PPS3 stresses that these sites must be deliverable and to be deliverable PPS3 states that a site must (i) be available – the site has no ownership constraints now; (ii) be suitable – the site offers a suitable location for development now; and (iii) be achievable – there is a reasonable prospect, in economic terms, that housing will be delivered on site within the five- year period.
3.2 The housing land supply is derived from four sources: (i) sites under construction on 1 April 2009 but unlikely to finish construction before 1 April 2010; (ii) sites that had planning permission on 1 April 2009 and where planning permission was likely to be implemented (in the case of small sites this was estimated on the basis of previous completion rates); (iii) sites allocated within the Unitary Development Plan; and (iv) large unallocated brownfield sites. PPS3 states that a windfall sites estimate should not be included in this document.
3.3 (i) Sites under Construction The Council can identify 106 housing units derived from sites under construction that will not be completed before 1 April 2010.
3.4 (ii) Sites with Planning Permission In terms of sites with planning permission, a capacity of 840 additional units was identified from large sites (from discussions with landowners and developers, it was predicted that seven large sites with planning permission would not be implemented) and it was assumed a further 220 additional units with planning permission would come forward from small sites (taking account of previous trends
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of 72% of units on small site permissions being completed). This gives a total capacity of sites with planning permission of 1,060.
3.5 (iii) Allocated Sites With regard to sites allocated in the Unitary Development Plan, 184 units were identified following the granting of permission on appeal of the final phases of The Hamptons development in July 2009.
3.6 (iv) Unallocated Sites In respect of large unallocated brownfield sites, 378 additional units were identified. The deliverability of these units was assured as they comprised either recent planning permissions or estate renewal schemes where the Council is the developer and there is relative certainty of delivery.
3.7 From these four sources, the Council can identify 1,728 deliverable units – slightly more than the London Plan target for the 2009 Five-Year Housing Land Supply Assessment.
4. Next Steps 4.1 The 2009 Five-Year Housing Land Supply Assessment will be submitted, together with the Annual Monitoring Report, to the Government at the end of this month. CLG will then review it and calculate the following year’s HPDG on the basis of Sutton demonstrating sufficient developable housing land.
5. Financial Implications 5.1 The cost of producing this document is provided for within existing revenue estimates. The amount of HPDG for Sutton has yet to be announced by central Government and officers believe that, in all probability, there will be no HPDG paid in either 2009/10 or 2010/11.
6. Influence on the Council’s Core Values 6.1 None.
7. Contribution to the Achievement of the Council’s Policy Aims 7.1 The provision of additional housing, including affordable housing, will help promote social inclusion.
8. One Planet Living 8.1 As these housing units will be delivered within the period 1 April 2010 to 31 March 2015, it is likely that a significant number will be built in accordance with Core Planning Strategy policy BP6 – One Planet Living.
9. Equalities Impact Assessment 9.1 The Five-Year Housing Land Supply will help implement the Core Planning Strategy Strategic Objective: to provide good quality and affordable housing throughout the Borough, including accommodation for people with care and support needs, to meet the needs of all social groups and achieve balanced communities.
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APPENDIX 1
Five-Year Housing Land Supply Assessment for 1 April 2010 to 31 March 2015
Planning and Transportation Environment and Leisure December 2009 Agenda Item 6 Page 280
Contents
Executive Summary 3
Background to the Assessment 4
Five-Year Housing Land Assessment Analysis 7
Assessment Commentary 11
Appendices 12
Five-Year Housing Land Supply 2 Page 281 Agenda Item 6
Executive Summary
Ɣ The London Borough of Sutton has identified 1,728 developable housing units for the five-year period from 1 April 2010 to 31 March 2015.
Ɣ A total of 1,728 units represents 3 units above the London Plan borough target for the period of 1,725 units.
Ɣ The total of 1,728 units comprises: 106 units under construction; 1,060 units on sites with planning permission; 184 units on a site allocated in the Sutton Unitary Development Plan and which now has permission; and, 378 units on significant unallocated brownfield sites.
Ɣ The Council considers these sites meet the PPS tests of deliverability, however, due to the uncertain economic climate, the phasing of delivery is not as clear as in previous years.
Ɣ In the first two years of the current London Plan plan time period, 1,008 housing units were completed. This exceeds the cumulative target of the first two years of the plan by 318 units.
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Background to the Assessment
National Policy Context 1.1 Planning Policy Statement 3: Housing (PPS3) states that planning authorities must assess and demonstrate the extent to which their plans fulfil the requirement to identify and maintain a rolling five-year supply of deliverable land for housing (para 7). To date, the London Borough of Sutton has published three Five-Year Housing Land Supply documents.
1.2 The assessment is part of the “plan, monitor, manage” principles (para 52) to housing provision within PPS3 and it has the potential to affect development control decisions. Para 71 states that “where Local Planning Auuthorities cannot demonstrate an up-to-date five-year supply of deliverable sites…, they should consider favourably planning applications for housing, having regard to the policies in this PPS.” It follows that where an authority can demonstrate a five-year supply of the deliverable sites, it should consider applications having regard to PPS3, existing Development Plan policies as well as other material considerations.
Purpose of this Document 2.1 Therefore, the purpose of this document is twofold: (1) to analyse whether housing can be delivered in accordance with the targets in the 2008 London Plan (Consolidated with Alterations since 2004); and (2) to show that there is sufficient housing for the Development Control committee and officers to be able to determine residential applications with regard to local plans and policies and material considerations.
The FiveYear Housing Land Supply Time Period 3.1 As required in Regional Spatial Strategy and Local Development Core Output Indicators – Update 2/2008 (CLG,2008), the Five-Year Housing Land Supply Assessment commences on 1 April of the year following publication of this document in December. Therefore, this Five-Year Housing Land Supply Assessment runs from 1 April 2010 to 21 March 2015.
Five-Year Time Period 1 April 2010 – 31 March 2015
The Five-Year Housing Land Supply Requirement 4.1 The London Plan sets out revised housing targets for each London borough for the period 2007-08 to 2016-17. In Sutton, the target is to exceed 3,450 additional homes over the ten-year period, equating to an annual monitoring target of a minimum of 345 units per annum. This target has been reiterated in the Council’s Core Planning Strategy, which was found to be sound by a Government Inspector on 4 September 2009.
Five-Year Housing Land Supply 4 Page 283 Agenda Item 6
4.2 Therefore, the Council needs to demonstrate that it can make provision over the five years from April 2010 to March 2015 for an additional 1,725 units (345 x 5 years).
Five-Year Housing Requirement 1,725
Identification of sites 5.1 The sites that have the potential to deliver housing during the following five years come from the following sources: x Sites that are under construction as of 1 April 2009. x Sites that have planning permission (outline or full) as of 1 April 2009. x Large sites that are allocated for housing in the 2003 Sutton Unitary Development Plan (Sutton UDP). x Specific unallocated brownfield sites that have the potential to make a significant contribution to housing delivery during the five-year period.
Deliverability 6.1 However, all sites within a Five-Year Housing Land Supply Assessment have to be “deliverable”. PPS3 states that “to be considered deliverable, sites should: x Be available – the site is available now. x Be suitable – the site offers a suitable location for development now and would contribute to the creation of sustainable, mixed communities x Be achievable – there is a reasonable prospect that housing will be delivered within the first five years” (para 54).
6.2 For the purposes of the Sutton Five-Year Housing Land Supply Assessment, the following rationale has been adopted with regard to deliverablility.
Source of site Assessing Deliverability
Sites under All sites under construction are considered construction deliverable.
However, if it is known that a site has been completed or will be completed before 1 April 2010, it has been excluded from the assessment. Similarly, the small sites under construction unit total has been reduced by 46% to reflect the proportion of small sites likely to be completed before 1 April 2010. The figure of 46% was derived from the proportion of the large site completions before 1 April 2010
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Sites with planning These sites are considered suitable since they permission have been granted planning permission. However, there may be issues regarding availability (due to subsequent sales of land etc) and achievability (strength of the market).
Consequently, the owners (or agents) with sites potentially yielding 10 or more units were contacted, where possible, to ascertain whether the development was likely to proceed within the next five years. Those sites which were unlikely to be delivered have been omitted.
Owners of sites yielding below 10 units were not contacted due to a lack of resources but have been discounted instead. From historic trends, it has been calculated that 72% of units on small site permissions are implemented. This percentage was applied to the current small site planning permission unit total and the discounted figure included in the assessment.
Allocated housing There is one remaining allocation to be built out sites in the Sutton fully. The details of this site appear in the next UDP section.
Significant These sites have been included only when the unallocated Council is aware that a site is available (without brownfield sites ownership problems), it is suitable (has been or is very likely to be granted permission) and achievable (the owners intend to develop, at least part of the site, within the period 1 April 2010- 31 March 2015).
Five-Year Housing Land Supply 6 Page 285 Agenda Item 6
Five-Year Housing Land Supply Assessment Analysis
Source Yield
Sites under Construction 106
Large Sites 2a-8 Brambledown Road, Wallington 38 31-33 Pound Street, Carshalton 13 39-43 West Street, Sutton 11 Side of 93-95 Carshalton Grove, Carshalton 11
Former Youth Centre, Mollison Drive 0 36 units. Likely to complete before April 2010 301-319 Middleton Road, Wandle Valley 0 15 units. Likely to complete before April 2010 29-31 Grove Road, Sutton 0 10 units. Likely to complete before April 2010
Sites with less than 10 units, uncompleted before 1 April 2010 33 62 small sites under construction. 54% of units on large sites will be uncompleted by 1 April 2010. Applying this percentage the small sites total gives a likely uncompleted under construction total of 33.
For a full list of sites, see Appendix 1
Sites with Planning Permission 1,060
Large Sites Azteque, Sutton Court Road, Sutton 254 There are currently viability issues relating the lack of pre-sales. If the housing market begins to improve, there is an intention to start on site in 2010. The scheme has a 2½-year build programme. Therefore, completion is possible by July 2013.
Canon House, Melbourne Road, Wallington 174 The site has recently come into new ownership and the new owners hope to redevelop within two or three years.
Durand Close, The Wrythe Estate renewal scheme with a net increase of 203 units. Phasing has 152 been revised and it is expected that 75% of the development will be completed by March 2015.
Kelvin House, London Road, Hackbridge 96 The site has largely been cleared. Construction is anticipated to start in July 2011 and completion is projected to be in December 2012.
Five-Year Housing Land Supply 7 Agenda Item 6 Page 286
36-46 Mollison Drive, Wallington 48 100% affordable scheme. Owners intend to start on site in September 2009 with completion in December 2010.
229-245 Carshalton Road, Carshalton 41 Market conditions prevented an immediate start on site following the granting of planning permission, however, there is an intention to commence construction in March 2010. Various elements of the original scheme may need to be amended to suit new market requirements.
Rear of 138 Brighton Road, Belmont (Land off Hulverston Close) 16 PCT has a commitment to complete this development before March 2010.
2, 2a, 4 and 4a Rotherfield Road, Carshalton 15 The developer is confident that the scheme will start and expects completion within five years.
33-37 Albion Road, Sutton 12 The scheme is expected to be completed in October 2010.
21-25 Stanley Road, Sutton 11 Construction on site has now started.
127-129 Malden Road, Cheam 11 Scheme is dependent on market conditions and is unlikely to start on site before December 2011. However, it is hopeful that it will be completed before March 2015.
Ashcombe House, The Park, Carshalton 10 PCT has a commitment to complete this development before March 2010.
Eaton Court Hotel, Eaton Road, Sutton 0 Permission is soon to lapse and there has been no start on site (10 units permitted).
Victoria House, London Road, North Cheam 0 Development with the current permission is unlikely to take place and future plans are uncertain for the five-year period (19 units permitted).
Pobjoy Mint House, Oldfields Road, Sutton 0 Site is likely to be redeveloped for storage/warehousing (19 units permitted).
Wynash Gardens, Carshalton Road, Carshalton 0 Delivery is uncertain in current economic climate (18 units permitted).
Five-Year Housing Land Supply 8 Page 287 Agenda Item 6
Stonecot Service Station, 157 Epsom Road, Sutton 0 Permission has lapsed with no start on site. (17 units permitted)
Wallington Court, Stanley Park Road, Wallington 0 Permission has lapsed with no start on site (13 units permitted)
106-108 Grove Road, Sutton 0 Permission has lapsed with no start on site (10 units permitted)
Sites with less than 10 units, discounted for non-implementation of 220 permissions 306 units with planning permission. From historic trends, it has been calculated that 72% of units on small site permissions are implemented. Applying this percentage to the current small site planning permission unit total gives a figure of 220 units.
For a full list of sites, see Appendix 2
Large Sites allocated in the 2003 Sutton Unitary Development 184 Plan
Phases 4b and 5c, The Hamptons, Worcester Park 184 Final two phases of the development, comprising an additional 184 units, were granted planning permission in July 2009. The developers intend to start on site in October 2009 and have estimated a build programme of 2½ years. Therefore the development could be completed by March 2012.
Significant Unallocated Brownfield Sites 378
Orchard Hill, Fountain Drive, Carshalton 123 The site has planning permission for 246 units but other details are being finalised. The site is currently being prepared for redevelopment. The owner intends to bring forward the site in phases but expects to be in full development by 2014. It is expected that 50% of the site will be completed by March 2015.
Sutherland House, Brighton Road, Sutton 96 The site was granted planning permission in September 2009, subject to the completion of a S106 agreement.
*Carshalton War Memorial Hospital, The Park, Carshalton 40 The site comprises the hospital building and Cedar Close but not Ashcombe House which appears in the planning permission section.The owners are keen to proceed with development and have received interest from developers.
Five-Year Housing Land Supply 9 Agenda Item 6 Page 288
*Corbet Close, Hackbridge Road, Hackbridge 45 Estate renewal programme expected to provide a net increase of 90 units, 50% of which is expected to be delivered before March 2015.
48-50 Benhill Avenue, Sutton 26 The site was granted planning permission in September 2009.
49-67 Fellowes Road, The Wrythe 24 The site was granted planning permission in September 2009.
3, 5 and 6 Butter Hill, Carshalton 24 100% affordable scheme. The site was granted planning permission on appeal in August 2009. The developer expects to start on site in November 2009 and complete in December 2010.
* The inclusion of these sites in the list does not imply they will be granted planning permission or be granted planning permission with the number of units shown, the capacity is indicative.
TOTAL 1,728
Five-Year Housing Land Supply 10 Page 289 Agenda Item 6
Assessment Commentary
Delivery over the Five Years 1.1 The schedule in the previous section indicates that the London Borough of Sutton can demonstrate sufficient future housing land supply to meet its London Plan target for the period 1 April 2010 to 31 March 2015.
1.2 The Council has identified: x 106 units on sites which are classified as under construction and which are likely to be delivered after 1 April 2010; x 1,060 deliverable housing units with planning permission; x 184 deliverable units from an allocated site, which now has planning permission; and, x 378 deliverable sites on significant unallocated brownfield sites. These are sites that either have recently been granted planning permission or are sites which are part of short-term public sector redevelopment plans. From these four sources, there are 1,728 housing units, an additional 3 above the current London Plan target.
Risks to Deliverability 2.1 While the Council has made every effort to assess suitability, achievability and availability accurately, there are risks to deliverability due to the current economic climate and consequent uncertainty in the housing market.
2.2 The Council is confident that all the larger sites in this document will be developed, the risk is concerned with when they will be delivered. In discussions with landowners and developers, the Council has noted that some developers have only been able to give vague timescales of development and completion dates, however, the majority are keen to develop within the five year period.
2.3 With regard to the smaller sites, planning permissions have been discounted to reflect the historic permission-to-completion rate of 72%. The smaller sites have been more difficult to assess in the current climate because of the different schemes that constitute small sites (eg sub-division or complete redevelopment) and because of the different types of developers who undertake small schemes (eg small businesses or householders). Therefore, the application of the historic discounting rate was considered appropriate.
Historic Delivery Patterns 3.1 The current London Plan plan period began in 2007-08 and consequently only two years of previous supply have been recorded. In the first year, 612 units were registered as completed, while in 2008-9, 396 units were delivered. Completions over these two years constitute a delivery of 1,008 units and this exceeds the two-year cumultative London Plan target by 318 units.
Five-Year Housing Land Supply 11 Agenda Item 6 Page 290
Appendix 1 – Sites Under Construction as of 1 April 2009
Application Address 1 Address 2 Ward Net D2006/56795 2a-8 Brambledown Road Wallington South 38 B2003/51727 74-108 & 79-113 Sydney Road Sutton Central 5 D2005/55027 Former Youth Centre Mollison Drive Beddington South 36 C2004/53419 301-319 Middleton Road Wandle Valley 15 B2006/56477 39-43 West Street Sutton West 11 C2008/59297 31-33 Pound Street Carshalton Central 13 B2007/57447 29-31 Grove Road Sutton West 10 C2006/55748 Side Of And 93-95 Carshalton Grove Carshalton Central 11 B2007/58681 Land R/O 106-110 Carshalton Road Sutton Central 6 D2007/57653 Roundshaw Regen 5b Incorp Shaw Way Beddington South 5 A2004/52335 Land Adjoining 49 Stonecot Hill Stonecot 4 A2007/58423 25 Park Road Cheam 3 B2003/51721 39a Eaton Road Sutton South 3 B2008/59528 The Victory PH William Road Sutton 3 C2008/59973 Middleton Circle Library Green Wrythe Lane Wandle Valley 4 A2006/55330 Garages At 130 Carshalton Park Road Carshalton Central 2 A2007/58920 1 Huntingdon Gardens Worcester Park 1 B2006/56273 91 Clarence Road Sutton Central 1 B2008/59775 145 Stayton Road Sutton North 1 C2005/53817 Land Adj. 128 Buckhurst Avenue Wandle Valley 2 C2008/59705 43 St James Road The Wrythe 1 D2007/57927 11a Melbourne Road Wallington North 2 D2007/58703 Brunel House, 14a Clifton Road Wallington North 2 A2006/55516 486-488 Sutton Common Road Stonecot -3 A2007/58686 503a London Road Worcester Park 1 A2007/58961 333 Sutton Common Road Stonecot 2 A2008/59156 509a London Road Worcester Park 1 A2008/59429 105 Kingsmead Avenue Nonsuch 1 A2005/54112 Garden Land Of 45 Sandy Lane Cheam 1 A2005/54966 Garden Land Of 176 Henley Avenue Stonecot 1 A2006/55756 180 Sandy Lane Cheam 0 A2006/56889 Hazel Court The Drive Cheam 0 A2007/57887 Blue Cedars The Drive Cheam 0 A2008/60597 83 Walton Avenue Stonecot 1 B2006/56070 11 Beresford Road Belmont 1 B2006/57031 109 Clarence Road Sutton Central 1 C2004/52626 1a York Street Wandle Valley 1 C2004/53133 Rr 117-21 Westmead Rd Front Cowper Avenue Carshalton Central 1 C2005/54272 Land R/O 113-117 Westmead Road Carshalton Central 1 C2006/56793 Garden Land Of 8 Pershore Grove Wandle Valley 1 C2007/57647 Garden Land Adj. 47 Revesby Road Wandle Valley 1 D2006/55852 Garden Land R/O 90 Croydon Road Beddington North 1 D2008/59866 Adj To 2 Birchwood Avenue Wallington North 1
Five-Year Housing Land Supply 12 Page 291 Agenda Item 6
Appendix 2 – Sites with Planning Permission at 1 April 2009
Application Address 1 Address 2 Ward Net C2006/56803 Durand Regeneration Durand Close The Wrythe 203 B2005/55077 Azteque (Southpoint etc) Sutton Court Road Sutton Central 254 D2006/56209 Canon House, 2 Melbourne Road Wallington North 174 C2006/56201 Kelvin House London Road Wandle Valley 96 D2008/59139 36-46 Mollison Drive Beddington South 48 C2007/58101 229-245 Carshalton Road Carshalton Central 41 A2005/55183 Victoria House, 338 London Road Nonsuch 19 C2002/49455 Pobjoy Mint House, 92 Oldfields Road Sutton North 19 C2007/57350 2, 2a, 4 & 4a Rotherfield Road Carshalton Central 15 C2000/46444 Wynash Gardens Carshalton Road Carshalton Central 18 A2002/49508 Stonecot Services, 157 Epsom Road Stonecot 17 B2005/54054 106-108 Grove Road Sutton West 15 B2008/60508 Rear Of 138 Brighton Road Belmont 16 B2007/57721 33-37 Albion Road Sutton South 12 B2007/58997 21-25 Stanley Road Sutton South 11 A2007/58004 127-129 Malden Road Cheam 11 D2008/59080 Wallington Court Stanley Park Road Wallington South 13 B2004/53448 51-55 Thicket Road Sutton Central 9 B2007/58883 46, 46a & 46b Albion Road Sutton South 9 B2003/50969 Eaton Court Hotel, 49 Eaton Road Sutton South 10 B2008/59341 7 Woodside Road Sutton North 2 C2008/59838 Ashcombe House The Park Carshalton Central 10 B2007/59002 127 Cheam Road Sutton West 8 A2007/58310 2 Lindsay Road Worcester Park 8 A2008/60486 Cheam Day Centre Springclose Lane Cheam 8 B2007/59020 7 Northdown Road Belmont 7 B2008/60367 Fmr Texaco Station 155 Reigate Avenue Sutton North 8 B2008/60368 Belmont House, 1 Homeland Drive Belmont 8 C2004/52138 29 Park Hill Carshalton Central 7 A2007/57352 Brian Court, 440 London Road Nonsuch 6 B2007/58106 Southfields Court, 180 Sutton Common Road Sutton North 6 C2008/60271 Pinks Gym, 9-11a High Street Carshalton Central 6 A2007/57458 607 London Road Worcester Park 5 B2005/54752 Garden Hall House Wellesley Road Sutton South 5 B2007/57848 Land R/O 11 Cedar Road Sutton South 5 A2007/57742 Cheam Court Station Way Cheam 2 A2008/60148 13 To 15a Cheam Common Road Nonsuch 4 B2003/50927 200-202 High Street Sutton Central 3 B2006/55449 203-205 High Street Sutton Central 4 B2006/57056 19 Cavendish Road Sutton South 3 B2008/59886 Rowan Lodge, 2a St James Road Sutton West 4 B2008/60320 Land To The R/O 155 Reigate Avenue Sutton North 4 C2007/58364 49 Gordon Road C'halton & C’house 3 A2004/52163 Adj 1-2 Priory Court, 92 Priory Road Nonsuch 3
Five-Year Housing Land Supply 13 Agenda Item 6 Page 292
A2007/58126 591 London Road Worcester Park 3 A2007/58864 18 Malden Road Cheam 3 A2008/60075 64 Brinkley Road Worcester Park 2 B2004/52209 68-70 High Street Sutton Central 3 B2006/55925 66 High Street Sutton Central 2 B2006/56822 186 High Street Sutton Central 3 B2007/57193 94 Mulgrave Road Sutton West 2 C2005/54779 102 Green Wrythe Lane The Wrythe 2 C2007/58339 Hillside, 161-163 Carshalton Road Carshalton Central 3 C2008/59060 118 & 118a Green Wrythe Lane The Wrythe 1 C2008/59489 42b Banstead Road C'halton & C’house 3 C2008/60285 372 Green Wrythe Lane St. Helier 2 D2008/60663 66 Park Lane Wallington North 2 A2005/54280 127 Church Hill Road Nonsuch 2 A2006/55501 18 A Ewell Road Cheam 1 A2006/56243 477 A London Road Nonsuch 1 A2006/56244 487a London Road Nonsuch 1 A2007/57207 Garden Land Adj 126 Church Hill Road Nonsuch 2 A2007/58408 Wylo The Drive Cheam 1 A2008/59465 Broadlands Home, 51 Burdon Lane Cheam 2 A2008/59655 13 Washington Road Worcester Park 1 A2008/59857 Land Forming Part of 235 Stoneleigh Avenue Nonsuch 2 A2008/59972 R/O 25 & 27 Dalmeny Road Nonsuch 2 B2004/52705 Land Adj To Avondale Ct Benhilton Gard Sutton North 2 B2004/53371 260 High Street Sutton Central 2 B2005/54807 37 Lenham Road Sutton Central 1 B2006/55594 162 A High Street Sutton Central 1 B2006/56147 Strathaird Court, 39 Grove Road Sutton West 2 B2006/56149 Stratheden Court, 33 Grove Road Sutton West 2 B2006/56980 60 Oldfields Road Sutton North 1 B2007/57420 Land btn 195-9 & 203-5 High Street Sutton Central 2 B2007/57589 22 Litchfield Road Sutton Central 1 B2007/57945 43 Haddon Road Sutton Central 1 B2007/58284 62 Oldfields Road Sutton North 1 B2007/58689 39 Lower Road Sutton Central 1 B2007/58804 14 Alfred Road Sutton Central 1 B2008/59058 44 Effingham Close Sutton South 1 B2008/59283 126 Carshalton Road Sutton Central 2 B2008/59340 Land R/O 5 Woodside Road Sutton North 2 B2008/59441 13 Stayton Road Sutton North 1 B2008/59568 164 Benhill Road Sutton North 1 B2008/59932 91 Collingwood Road Sutton Central 2 C2004/51984 New Lodge Farm Little Woodcote Lane C'halton & C’house 2 C2006/55804 1 Simms Road The Wrythe 1 C2006/56780 9-11 West Street Lane Carshalton Central 1 C2007/58214 38 Kirksted Road St. Helier 1 C2007/58870 310 Wrythe Lane St. Helier 1
Five-Year Housing Land Supply 14 Page 293 Agenda Item 6
C2008/60284 23 Florian Avenue Carshalton Central 1 D2005/53588 48 Coniston Court Wallington North 1 D2005/53589 18 Coniston Court Harcourt Road Wallington North 1 D2005/53797 6 Coniston Court Wallington North 1 D2005/53798 50 Coniston Court Harcourt Road Wallington North 1 D2006/55700 15 Homemead Road Beddington North 1 D2006/55939 6 Ross Parade Wallington South 1 D2006/56474 183 Stafford Road Beddington South 1 D2007/57396 50 Woodcote Road Wallington South 2 D2007/57454 1b Hawthorn Road Wallington South 1 D2007/57805 Land Rear Of 45-49 Woodcote Avenue Wallington South 2 D2008/59121 8 Link Lane Beddington South 1 D2008/59620 7 Beddington Gardens Wallington South 1 D2008/59649 Land R/O 77a & B Manor Road Wallington North 2 D2008/59650 77c & 77d Manor Road Wallington North 2 D2008/59985 St Elpheges Centre, 118 Stafford Road Wallington South 2 D2008/60229 39-41 Stafford Road Wallington South 2 D2008/60610 237 Stafford Road Beddington South 2 A2005/53826 Garden Land Adj 316 Gander Green Lane Stonecot 1 A2006/56099 Garden Land Adj. To 16 Southwood Close Worcester Park 1 A2006/56157 Downscroft The Drive Cheam 0 A2007/57270 601 London Road Worcester Park 1 A2007/58659 Garden Land Of 80 Windsor Avenue Stonecot 1 A2007/58889 9 Downs Side Cheam 0 A2008/59042 7 Golf Side Cheam 0 A2008/59353 Land Forming Part Of 14 Abbotts Road Cheam 1 A2008/59361 Garden Land Adj, 117 Burdon Lane Cheam 1 A2008/59641 29 Stonecot Hill Stonecot 1 A2008/59882 Garden Land R/O 51 The Avenue Cheam 1 A2008/59931 18 Cheam Common Road Worcester Park 0 A2008/59963 Adj To 469 Gander Green Lane Stonecot 1 A2008/59980 2 Matlock Gardens Cheam 1 A2008/60117 Land Adj. 1 Newbolt Avenue Nonsuch 1 A2008/60390 Garden Land 2 Hampton Road Nonsuch 1 A2009/60764 The Drive Cheam 0 B2005/54449 37 The Highway Belmont 0 B2005/54729 Garden Land Adj. 115 Oakhill Road Sutton North 1 B2005/54884 Land R/O 11-13 Alfred Road Sutton Central 1 B2005/54887 23 (Incl Garden) Bourne Way Sutton West 1 B2006/55487 37 Crossways Belmont 1 B2006/55615 83 Sutton Common Road Sutton North 1 B2006/56772 11-17 Cavendish Road Sutton South 1 B2007/57410 Garden Land R/O 310 Collingwood Road Sutton North 1 B2007/57416 Garden Land R/O 96-98 Worcester Road Sutton West 1 B2007/57526 Sherbourne Court, 46 Cavendish Road Sutton South 0 B2007/58301 Garden Land Adj. 15 Edinburgh Road Sutton North 1 B2007/58385 Land To Rear Of 49-55 Orchard Road Sutton Central 1
Five-Year Housing Land Supply 15 Agenda Item 6 Page 294
B2007/58910 Garden Land At 4 Antrobus Close Sutton West 1 B2008/59055 Garden Land Adj To 1 Denbigh Close Sutton West 0 B2008/59765 Adj To 11 Litchfield Road Sutton Central 1 B2008/59884 1-3 Vernon Road Sutton Central 1 B2008/60453 10 Hillcroome Road Sutton South 1 B2008/60577 Land Forming Part Of 24 Greenhill Sutton North 1 C2003/51438 Garden Land Of, 8 St James Road Sutton West 1 C2004/52069 Garden Land Side Of 22 Wales Avenue Carshalton Central 1 C2005/53553 114 Westmead Road Carshalton Central 1 C2005/54071 25 Robertsbridge Road St. Helier 1 C2007/57309 7 West Street Carshalton Central 1 C2007/57700 15 & 15a The Square Carshalton Central -1 C2007/58072 Garden Land Adj., 27 Wallace Crescent Carshalton Central 1 C2007/58210 Adj To 250 Welbeck Road Wandle Valley 1 C2007/58644 Land Adj 1 Shorts Road Carshalton Central 1 C2007/58787 92 Westmead Road Carshalton Central 1 C2008/59231 11 West Street Carshalton Central 1 C2008/59268 15 The Green Wandle Valley 1 C2008/59731 125 Thornton Road St. Helier -1 C2008/59981 Adj To 6 Whittlebury Close C'halton & C’house 1 C2008/60076 Little Woodcote Est, 10 Woodmansterne Road C'halton & C’house 0 C2008/60192 Adj To 31 Park Hill Carshalton Central 1 C2008/60273 2a Seymour Road Wandle Valley 1 C2008/60291 37 Ruskin Road Carshalton Central 1 C2008/60469 61 Westmead Road Carshalton Central 1 D2004/52232 Land Adjoining 26 Saffron Close Beddington North 1 D2004/52666 8 Manor Road Wallington North 1 D2004/52682 17 A Woodcote Road Wallington South 1 D2004/52920 Garden Land R/O 1-3 Stratton Avenue Beddington South 1 D2005/54543 Garden Land R/O74 Park Hill Road Wallington South 1 D2005/54954 17 Manor Road Wallington North 1 D2005/55192 Garden Land Adj. 4 Aldwick Road Beddington North 1 D2006/55407 Fmr Public Convenience Clarendon Road Wallington South 1 D2006/55986 Torwood The Wood End Wallington South 1 D2006/56031 151 Stafford Road Wallington South 1 D2006/57010 Land R/O 14-16 Boundary Road Wallington South 1 D2007/57616 Land Adj. To 73 Upper Road Beddington North 1 D2007/58677 Garden Land Adj. 97 Sandy Lane South Beddington South 1 D2007/58747 51 Great Woodcote Park Beddington South -1 D2008/59267 Adj To 1 Iberian Avenue Beddington North 1 D2008/59327 Land Adj To 34 Link Lane Beddington South 1 D2008/59420 Land Adj. 76 Upper Road Beddington North 1 D2008/59662 Garage R/O 3 Apeldoorn Drive Beddington South 1 D2008/59743 2a Woodcote Green Beddington South 1 D2008/60049 Land Adj To 24 Demesne Road Wallington South 1 D2008/60382 1a Beddington Gardens Wallington South 1 D2008/60468 Coogee Woodmansterne Lane Beddington South 0
Five-Year Housing Land Supply 16 Page 295 Agenda Item 7
London Borough of Sutton Planning Advisory Group - 8 December 2009 Report of the Executive Head of Planning, Transport and Highways ANNUAL MONITORING REPORT 2008-09: SUMMARY LEAFLET Ward Location: Borough Wide. Author: Patrick Whitter (x6297) Area Served: n/a Lead Councillor: Lyn Gleeson
Report for Decision Summary This Report outlines the proposed scope and format of the Sutton Annual Monitoring Report (AMR) Summary Leaflet for 2008-09 which is being prepared for publication in January 2010. The purpose of the leaflet is to provide a concise and user-friendly summary of the key planning, environmental and demographic indicators for the Borough which will be covered in the main AMR document for submission to the Government Office for London (GOL) by 31 December 2009. It is intended to publish the Summary Leaflet on an annual basis alongside the AMR.
Recommendations I recommend the Planning Advisory Group to: (i) Agree the proposed scope and format of the AMR Summary Leaflet for 2008-09.
1. Background 1.1 Under the Town and Country Planning (Local Development) Regulations 2004, local planning authorities are required to prepare an Annual Monitoring Report (AMR) to review progress against targets for the preparation of LDF documents set out in the adopted Local Development Scheme (LDS) and the effectiveness of planning policies in achieving local, regional and national targets for promoting the long-term environmental, economic and social well-being of the local community.
1.2 Accordingly, the Sutton AMR has been prepared every year since 2004-05 for submission to GOL within the statutory deadline of 31 December. The Sutton AMR 2008-09, which is currently being finalised, will report on: • Government Core Output Indicators as defined in ‘Update 2/2008’ (CLG, July 2008) together with relevant National Indicators; • London Plan indicators and associated Borough targets; • a wide range of local sustainability indicators and targets based on the Council’s LDF Monitoring Framework in the Core Planning Strategy and targets set out in the Sustainable Community Strategy; • development monitoring, land-use and contextual information based on Borough surveys undertaken as part of the LDF evidence base; • an updated demographic and socio-economic profile of the Borough .
1.3 It is now intended to prepare an AMR Summary Leaflet for Members and the public for publication in January 2010 alongside the Sutton AMR 2008-09. 2. Purpose of AMR Summary Leaflet 2.2 The AMR Summary Leaflet will: • provide a convenient ‘pocket-sized’ guide to Borough information on key Agenda Item 7 Page 296
planning, environmental and demographic indicators which can be distributed widely amongst Members, other Council departments and the public; • enhance the level of awareness of the AMR as a useful and reliable source of Borough information, and of the LDF process more generally, by being seen as a ‘marketing tool’ for the planning service; and • avoid the need to print large numbers of the main AMR document (over 200 pages in colour), thus achieving potential financial savings in terms of printing costs. It is intended that the AMR itself will mainly be accessed on- line.
3. Scope and Format 3.1 The AMR Summary Leaflet will be produced in colour as a single A2 sheet designed to fold up (like a map) into a convenient A5-sized ‘booklet’. The following range of information will be set out on a topic by topic basis. • What is the AMR? • Progress on the LDF; • Sutton’s Population; • Meeting Housing Needs; • Local Economy and Town Centres; • Community Facilities; • Open Environment; • Townscape Quality and Character; • Climate Change; • Waste and Pollution; • Sustainable Transport; and • Borough Map showing details of major residential and commercial developments completed within Sutton during 2008-09 and key Proposals Map designations.
4. Next Stages 4.1 It is intended to prepare an AMR Summary Leaflet for Members and the public for publication in January 2010 alongside the Sutton AMR 2008-09. The leaflet will also be made available on-line.
5. Financial Implications 5.1 The costs associated with printing 500 copies of the proposed AMR Summary Leaflet will be £500 (£1 per leaflet x 500). In addition, it is intended to produce 10 or fewer copies of the main AMR 2008-09 document, with an associated cost of £500. The combined costs of producing both the AMR Summary Leaflet and the main AMR document of £1,000 can be contained within the existing 2009-10 Revenue Budget for Strategic Planning.
6. Influences on the Council’s Core Values 6.1 Producing and making the AMR Summary Leaflet widely available to local stakeholders and the public will contribute towards working in partnership with people living and working within the Borough and making the Council’s services open and accessible.
7. Contribution to the Achievement of the Council’s Policy Aims 7.1 Planning policies must respond to the needs, opportunities and constraints Page 297 Agenda Item 7
affecting the area. Monitoring and review are therefore crucial to the successful implementation of LDFs and the delivery of sustainable communities. By enhancing the provision of LDF monitoring information to local stakeholders and the public, the AMR Summary Leaflet will serve to highlight issues of environmental quality and sustainability, thereby contributing to the Council’s aim of “Achieving Environmental Sustainability by protecting our environment now and in the future”.
8. Equality Impact Assessment 8.1 By enhancing the provision of LDF monitoring information to local stakeholders and the public, the AMR Summary Leaflet will contribute to the Council’s aim of “Creating Strong, Active and Inclusive Communities”.
9. One Planet Living 9.1 The AMR Summary Leaflet will report on the extent to which One Planet Living principles, including progress towards ‘zero carbon’, are being achieved year- on-year through the implementation of LDF policies.
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