Annex B
WASTE STORAGE RECYCLING IN NEW DEVELOPMENTS CONSULTATION COMMENTS – 30TH AUGUST 2006
Organisation / Comments / Comments from Planning / Incorporation into the SPDSt Stephen in Brannel Parish Council (St Austell) / 3.2.2 – Good to see that transport of waste is to be kept to a minimum. It would be nice if Cornwall County Council adopted the same principles. / Comments will be forwarded to Cornwall County Council. / Not applicable
Perranazbuloe Parish Council / Recycling has proven to be very popular. Only comment would be lack of storage space for recycled items and the fortnightly collections. If collections were weekly it could be alleviate the storage problem.
The facilities shown on Appendix 2 – pictures 3.10 would be ideal for flats and housing estates providing they were secure. / Noted – comments to be passed to Waste Service. / No changes proposed
St Newlyn East Parish Council / All ok providing people can make their own decisions as to best place to store containers. / These proposals will not necessarily change arrangements for established properties in the area. It is logical to provide communal areas as and when waste management practices and procedures allow. / No changes proposed
South West RSL Planning Consortium /
- Concerned about the level of detail required to accompany planning applications for housing, much is unnecessary and will lead to enforceability problems. It will be expensive in terms of resources and manpower to administer.
- We support the provision of waste bins/recycling facilities within new developments – space restrictions may limit the scope of this. Many households successfully rely on kerbside collections as well as accessible off site facilities in the absence of any designated area for such facilities. Any additional guidance should supplement existing practice and not seek to replace it.
- We object to WPR 3. We do not accept that it is reasonable for the Council to seek contributions from developers to cover costs associated with extended and additional kerbside waste collections together with further recycling initiatives.
- We consider that the encouragement of recycling is part of the Council’s statutory duty. Communal bins/recycling facilities easily become dumping grounds and there is usually no estate manager there to keep washing it down/picking up glass/disposing of mattresses.
Noted – need to work with housebuilders on modifying their standard house type.
A development will increase population which require existing services to be expanded and related infrastructure – WPR3 does not seek to address ongoing revenue costs of the existing population.
Whilst there are clearly practical issues for communal areas, these are not insurmountable if adequate management arrangements are put in place. / See Note 2
No changes proposed
No changes proposed
See Note 3
Organisation / Comments / Comments from Planning / Incorporation into the SPD
- If this is to be retained we consider it important that special provision is made for affordable housing and consider that affordable housing units should be exempt from these planning contributions. Affordable housing should not be expected to contribute to the fulfilment of other objectives which are better met through the Councils’ existing capital spending programme.
Cornwall County Council – Spatial Planning Service and Waste Management Service / It provides clear and detailed guidance. The best practice section is considered helpful. The document should be promoted to other borough and district councils as a model for all to implement particularly in respect of the growth in housing between now and 2026. It is recommended the document is presented at future meetings of the Cornwall Waste Management forum and Planning forum to spread the message across all authorities.
It would be helpful if the roles and responsibilities of the various organisations responsible for waste management could be made clear.
In paragraph 2.4.3 – it would be useful to refer to Policy S1 in the Cornwall Waste Local Plan which seeks to achieve an increase in recycling in the County.
No mention is made of the emerging Cornwall Waste Development Framework – this will eventually replace the Cornwall Waste Local Plan and it contains much to support the philosophy behind the SPG. Visit and in particular preferred options 6, 18, 19 and 20.
Paragraph 2.5.2 – could include a reference to the Waste and Emissions Trading Act 2003, the Household Waste Recycling Act 2003, the Clean Neighbourhoods and Environment Act 2005, British Standards BS5906 (Code of practice for storage and on-site treatment of solid waste from buildings) and a recent ODPM consultation “Proposals for including a code for sustainable homes” Dec 2005. The companion guide to Policy Statement 10 Nov 2005 is also clear that non waste development might incorporate recycling facilities such as banks, provide dedicated facilities to enable the collection of recycling materials, or contribute toward community waste management facilities such as green waste composting sites or civic amenity sites.
No mention is made in the document regarding the role of home composting. It would be very helpful if this document could provide a paragraph of guidance to developers on the provision for a home composter in individual gardens.
It would be useful where relevant to include reference to the usage of signage whether directional or more pertinently the use of appropriate signs. It would be helpful if clear guidance was available on what materials went in what containers in order to reduce confusion resulting in contamination of materials and extra costs to contractors. The CCC working in conjunction with district councils is currently considering the use of common symbols and signage available form the Waste Resources Action Programme. / A welcome comment.
Agreed.
Agreed.
Agreed.
Agreed.
Principle of better signage agreed however the issue of signage is much broader and the ability to deliver this through the planning system. / A separate section to be incorporated into the SPD.
It is agreed that the document needs to be amended to reflect both the existing and emerging policy frameworks of the County and District Council.
2.5.2 to be modified.
Note to be included.
No changes proposed.
Organisation / Comments / Comments from Planning / Incorporation into the SPD
St Erme Parish Council / Concerns over communal areas as the parish experiences huge problems when using refuge bays, such as flytipping and rodents. If bays are to be used a bond should be taken from the developer to make sure the authorities are held responsible for the upkeep and use of communal areas.
We felt the length of the document was unnecessary and not easy to read. / In many ways the issues raised are similar to concerns that are expressed about the management and upkeep of communal open spaces – it is therefore important that if communal areas are to be provided then the arrangements for the maintenance and upkeep of such areas should be agreed before any units are occupied and could be achieved through a planning condition. / See Note 2.
A summary document is to be provided
Environment Agency / The Environment Agency supports the objectives of the document and the mechanisms for delivery. It responds to the aims and intentions of policy documents such as the Waste Local Plan and the preferred issues and Options waste development framework. The document addresses our previous comments suggesting a need to ensure all waste collection and recycling facilities are well located and designed to reduce potential environmental impacts. / Comments welcome. / No changes proposed.
David Read Project Officer / Any scheme must ensure that it does not negatively impact our disabled and elderly population. This will include taking waste to a central point ensuring that communal waste facility is accessible even for wheelchair users and those with sight issues. Such areas must be safe, clean and well managed. Any system used must allow for refuse officers to collect from individuals as per present arrangements. Failure to comply with equalities legislation will result in serious legislative issues for the Council. Any proposed scheme should be subject to consultation with a disability groups to ensure compliance. / Agreed – should be dealt with through the design and access statement. / Reference to access issues should be included in the document.
Organisation / Comments / Comments from Planning / Incorporation into SPD
Home Builders Federation / The SPG is inconsistent with national planning policy. PPS 12 identifies that it must be clearly cross referenced to the relevant development plan document policy which it supplements (or, before a relevant development plan document has been adopted, a saved policy).
The HBF objects to the inclusion of waste storage recycling policies within a planning document. PPS 12 clearly illustrates in paragraph 1.8 that planning policies should not replicate cut across or detrimentally affect matters within the scope of other legislative requirements. It is considered that the waste storage recycling policies would fit more appropriately as part of H6 Solid Waste Storage of the Building Regulations. Experience has shown that the established system of building control in England and Wales provides a reliable framework for the control of health, safety and energy efficiency matters within buildings. With very few exceptions, national rules are applied consistently. The Federation on behalf of the industr6y works closely with Government BRAC, BRE and others, regarding Building regulation changes in order to agree changes that can be achieved without unduly constraining design or introducing unacceptable technical risks. Changes to standards/requirements in construction need to be made with detailed consideration so that the cost of achieving the requirement does not outweigh the benefit obtained by the change.
For this reasons we would ask that the requirement for dwellings be to provide adequate provision for recycling and waste disposal without stipulating a specific criteria to be met. The HBF would like to point out that the existing housing stock also requires provision for storing waste for recycling and disposal which annually accounts for 99% of the housing stock. Therefore the council should also look towards providing smarter ways to store waste for recycling and disposal which benefit both existing and new developments in order to get a better return.
The HBF wholly agree that homes must be built to high environmental standards to manage their energy usage, water consumption, recycling and waste disposal. Methods for doing so must be robust, consumer friendly and cost efficient. / See Note 4.
It is agreed that the document should be used as a tool for promoting solutions to the problems within the existing housing stock.
Agreed. / The wording of the document needs to be amended to reflect these national objectives and the spatial nature of the new planning system.
Text to be amended.
Text to be amended (if necessary).
Organisation / Comments / Comments from Planning / Incorporation into SPD
WPC J Thomson, Architectural Liaison Officer, West Cornwall / 4.2.2 – Include adequate secured and screened space within or close to the curtilage of the development for source-separated dry and green waste.
There must be a definition of secure and preferably the space built into the dwelling as per Photo 3.5 – combined use of garages for waste storage.
Or as in terraced dwelling space built in as part of the building adjacent to the door. But this must be secure (lockable).
Rear access collections – appropriate fencing around the parking court – note Photo 3.4 – this is not quite correct as the fencing has vertical slats thus climbable. Suggest vertical hit n miss fencing to 1.8 and or to 1.2 with 600ml trellis topping.
It is essential that the area is unclimbable or access is gained into the dwelling and/or the curtilage of it.
I note item 4.4.2 flats.
I note item 4.4.3 Groups of Dwellings and item 4.4.4 – you will not be able to secure a collection site with up to 50 dwellings waste! – I suggest you note my comments above. /
Agreed in principle.
Comments noted. Often a balance between various issues is required.
Wording needs to be clarified to indicate the ideal number of units served by each communal area. / Text to be amended.
Change photograph.
Text to be amended.
Waste Services / General Comment that the SPD is thoroughly supported, the first that has been produced across Cornwall. There are a number of issues that need addressing:
- Any reference to communal areas must be removed in relation to unmanaged housing estates – this is due to known and experienced problems of general dumping, mess and vermin.
- Pg ii – 11, this point should be emphasised to explain what a commuted sum is. It is recommended that the Principal Waste Officer is involved at the pre-application discussion stage of any application to ensure storage of waste is taken into account.
- Pg 14 – 4.3.3, remove sentence, This should be provided within the development or as close to it as possible – add and provided within each property.
- Pg 14 – 4.3.4, remove sentence, TV’s, computer screens, etc.
- Pg, 15 – 4.3.5, remove wheeled bins and replace with moveable containers – any reference to wheeled bins should be replaced with moveable containers throughout the document.
- Pg 15 – 4.3.7, WPR 3 – Add a sentence that emphasises that the money is not used for the provision of recycling containers.
- Pg 25 - 5.2.2, add and specific consultation with the Waste service
Agreed.
Do not agree.
Modify sentence to reflect adopted practice.
Modify sentence.
Agreed.
Agreed. / Text to be amended.
Text to be amended to reflect current practice.
Text to be amended.
Text to be amended.
Text to be amended.
Organisation / Comments / Comments from Planning / Incorporation into SPD
CDC Officer / It needs updating to ensure that it represents the current Carrick Policy/practice and best practice nationally.
If it is meant to be supplementary to the Design Guide perhaps it could take the DG as a model – it is not very user friendly.
The examples seem pedestrian and uninformative. The layouts don’t seem to be very clear – perhaps it’s the reproduction.
I think a major issue will be securing longer term maintenance and management of any facilities. There seems little in the document that would help guide this aspect.
Is there a need for provision to monitor and review the success/failure of schemes.
Is there a need for a section defining terms, providing contact points for further information on recycling explaining the different materials that can be recycled.
There seems to be nothing about designing the interior of houses to accommodate space for holding recycling material – bottles/paper, cardboard etc many of these items cannot/ should not be stored outside.
Recycling should be fun – this is a very dull document.
i – point 5 change which to that
i – points 8,9, 10 should be bullet points
1 – 1.1.2 – needs unpicking
2 – 1.2.5 – good idea – monitored – how/when?
1.3.4/5 – is this still the case?
4 – 2.1.1 – is this the lastest advice?
5 – 2.2.5/6 – update year from 2005
2.2.7 – irrelevant
2.2.8 – is this still the case
2.3.1 – is this still the case
6 – 2.3.2 – is this still the case
7 – 2.4.4 – LDF?
2.4.6 – update
9 – change planning consents to permission throughout document
12 – 4.2.2. – make clearer
14 – 4.3.1 – should include pre-application advice
WPG1 – Is this likely to be covered in our validation checklist
4.3.3/4 – confusing can it be clarified as to what happens at what scale of development
15 – wpr 3 – why these thresholds why not every dwelling – update
Amend cost of completion to administration
15 – 4.3.8 – Reflect – I hope that the evidence is there to back this up may need at appeal
16 – 4.3.10/11 – this needs further work will this be achieved through condition or planning obligation
19 – wpr 7 –5 is a low threshold and a high cost for small development – 20 metres is a large area for a small scheme
20 – wpr 8 – would this be subject to survey of area/agreement of community
26 – 5.3 – whilst interesting is this relevant to DC
27 – 5.3.7 – County Council matter / Agreed.
Noted – the document is complimentary to the DG.
Noted – will seek to improve the visuals.
Agreed.
Agreed.
Agreed.
Section 4.4.1 covers this point. However the text can be amended to make the point clearer.
Whilst agree in principle, this document is aimed at developers, not residents.
Agreed.
Agreed.
WPG1 should compliment validation checklist.
Agreed.
Agreed.
Agreed.
Noted. See Note 7.
Agreed.
Agreed.
See Note 9.
Should be retained as it shows the linkages on ‘waste matters’ between authorities.
Agreed. Need to change to reflect current policy position.
General point see note 10. / Text to be amended to reflect current Carrick practice.
No change proposed.
Section added regarding this aspect.
See Note 5.
See Note 6.
Text to be amended.
Text to be amended.
Text to be amended.
Text to be amended.
Text to be amended.
Text to be amended.
Text to be amended.
See Note 8.
Text to be amended.
NOTES
Note 1 – Paragraph 35 and 36 of Planning Policy 10 – Planning for Sustainable Waste Management states ‘Good design and layout in new development can help to secure opportunities for sustainable waste management, including for kerbside collection and community recycling as well as for larger waste facilities. Planning authorities should ensure that new development makes sufficient provision for waste management and promote designs and layouts that secure integration of waste management facilities without adverse impact on the street scene or in less developed areas, the local landscape. Waste management facilities in themselves should be well designed so that they contribute positively to the character and quality of the area in which they are located. Poor design is in itself undesirable, undermines community acceptance of waste facilities and should be rejected’.
Note 2–Guidance needs to stress that the management arrangements for each communal area must be agreed prior to the occupation of any units. This can be secured via condition.