JWCS Yate Town Council

Recovery Facilities, Location and Sites146B

Proposal:

Policy 5 Delete 5.3 and

Insert

“A further strategic assessment will be carried out to assess the options for provision of additional sites”.

Policy 7

Delete in total

Insert “A further strategic assessment will be carried out to assess the options for provision of additional sites”.

OR Insert into policy 7

“subject to the conduct of a fill SEA and SA in relation to the proposal and subject to public consultation upon the principle and location as if the scheme had been included as a specific proposal in Policy 5.”

  1. Compliance
  1. We have already set out our concerns about compliance in relation to both Sustainability Appraisals/ SEAs and in relation to the inability for the JWCS to demonstrate community involvement to any meaningful extent: if the authors of the SA conclude they do not have sufficient information to carry out an SA of this Policy how can the public have been expected to participate meaningfully in the consultation.
  1. Drafting too wide
  1. If it is not accepted that the policy is legally flawed, then our second submission is that it is too widely drafted. As drafted it would embrace any technology on any site: not all of the sites within the area of search are equivalent in relation particularly to water, flood, residential amenity issues.
  1. The Area of Search set out in 6.8.10 is an area that is subject to a major strategic reassessment within the Core Strategy as the Western Gateway and major employment site central to delivering the Core Strategy policy for the town as a whole and providing a strategic ‘front window’ to the town. As such the Draft Core Strategy and Draft Strategy for the area involves a major change in the role of the entire zone within the town, to seek to meet local needs for intensification of employment; hotel; retail and other needs. It is currently a zone embracing a mix of B class uses, from office and light industry through to warehousing, industry a small recycling facility. A specific strategy document has been produced for the entire zone by South Gloucestershire Council. This can be appended to the Examination Library list, if required. It is essential that the wider strategic role of the zone, and any proposals in Policy 7 are harmonised. At present, Policy sets a blight across the entire zone, as it is not possible to identify which site might come forward, and therefore draw up a strategic approach for the rest of the zone, without risk of it rendering Policy 7 impossible to deliver. Para 6.8.10 uses this strategic significance as an explanation for not allocating a site – but to set a policy in Policy 7 that requires a site to be found, within that visioning, without any assessment of whether one CAN be found within that visioning is not responding to a need to maintain strategic flexibility it is blighting the entire process.
  1. SITA own one plot of land in the Policy 7 search zone: without speculating about whether other sites may come forward, this one might possibly do so. This is in an area closest to both the river and the massive residential community – and is within sight of them, a matter of yards away. Thus the site most likely to come forward is also one of the most sensitive ones in environmental and amenity terms. We do not at this stage have any material upon which we as a Town Council, or residents cam possibly judge whether it is possible to find a technology which is affordable and appropriate to such a site.
  1. We would welcome the provision of a site somewhere in the Yate area, if there is an appropriate site and technology, because the underlying principle of dealing with waste at source is a good one and we remain open to the idea that there might somewhere be an appropriate site and technology. However we have to object to being sold what may best be described as ‘a pig in a poke’ – in terms of having such a wide area of search and such an open ended technology list. At this stage we are therefore not enabled as residents to comment upon the appropriateness of sites or technology. When a proposal does come forward, we will be only be allowed to comment on whether it complies with Policy 7 – not whether it is the best solution available or the best site. Accordingly we will not have had a proper strategic discussion.
  1. It is not possible at this stage to comment upon whether there MIGHT be a technology and site that would be capable of delivering this Policy – we therefore have to object until the policy is sufficiently precise to be capable of assessment. We object on the basis that no evidence has been provided in the plan to suggest a site CAN be provided in this locality – a line on a map without supporting evidence of a suitable technology and potential site does not provide evidence to show a site CAN be provided that is environmentally satisfactory. It is bad practice environmentally and legally to make a commitment without having ascertained it is possible to deliver it in an acceptable manner.
  1. We understand no proposal is likely to come forward until 2020 – and would therefore suggest that Policies 5 and 7 are rewritten to commit the JWCS Committee to a further strategic assessment of Yate, at a point in time when there is greater clarity about technologies and sites, so there can be a true strategic participation for the public – which is then followed by a developer bringing forward a specific proposal that delivers that strategic approach. This will also enable the strategic assessment of the western gateway to the town to proceed with this issue open and on the table – which may mean the strategic assessment for the Core Strategy is better able to deliver an integrated use of the whole western gateway, including better defining possible sites for this use. The potential need is now on the table in those discussions: tying the hand of those discussions by giving one use a trumping card, rather than an indicative value risks the delivery of a bad technology on a bad site.
  1. The current policy says consent “WILL be granted” on a site within the area of search, which means if only one site comes forward, however poor, there will be considerable pressure to grant consent, subject only to the general JWCS policies, not subject to the stronger SEA/SA assessment and in particular this removes the SEA/SA obligation to evaluate not just the site/technology proposed, but also reasonable alternatives – we will be left with simply the question of does the first developer to come forward have a viable scheme, not what SEA/SA requires, which is an assessment of the best scheme i.e. the consideration of reasonable alternatives.
  1. Policy 7 does not then state that proposals will be considered, against a full range of participation and sustainability criteria. Instead it says proposals “will be permitted where they conform to” …. JWSC policy. That means that proposals on the unallocated sites will be subject to a LESS stringent test environmentally and in terms of participation that the original Policy 5 sites and in particular will not be assessed against alternative approaches. This is not appropriate, particularly given the transportation and environmental issues affecting that site, which adjoins a main residential area. We simply ask that the policy be revised as suggested to ensure that when the West of England Partnership is ready to move towards a specific allocation in Yate and landowners/developers are ready to bring forward a proposal, it is assessed in the same way as the specifically allocated site. We believe our proposed amendment does that. It does not delete Yate as a possible site – it simply retains the status quo of saying that at an appropriate time, there will be a strategic review of the Yate area to assess potential sites and technologies and then make a strategic allocation, from which a detailed proposal can then flow – but in a manner that enables public participation in the question of whether this is the most appropriate site / technology not just whether the proposed site/technology passes a minimal threshold.