· On 2nd August 2005 the head of transport and planning strategy wrote to the developer and said that due to the site being over 0.5 hectare and for waste use an EIA was necessary.
· On 3rd August 2005 the planning officer wrote to the developer indicating that as the site was 50 meters away from housing and the mobile homes were to be removed, and following an assessment of the proposed development, a comprehensive Environmental Impact Assessment would not be required to be submitted with the Planning Application.
· The application actually filed was for a location moved significantly to the north and leaving the mobile homes in place.
· The mobile homes are within 25 meters of the site where West Berkshire guidance is 30 meters. The top east of the site was only just in line with the bottom south of a large new housing development. This move to the north has meant the whole site is now directly facing the housing development about 30 meters away.
· Submitted plans by the applicant omitted to show the new housing development directly opposite the proposed site. WLP31 (i) makes it clear submitted plans have to show surrounding areas in relation to application areas. It says "Each application must be accompanied by a written statement, drawings and plans which: describe the existing conditions of the site and surroundings".
· A plan has just been put in the public file (after the application was approved on 21st February 2007) showing the very close proximity of Newbury College to the HWRC (copy enclosed) it also shows a new 139 Bedroom Conference Centre, including sports and leisure facilities which have current planning permission, and are awaiting construction.
· No revised screening was done to review the requirement for an EIA despite the fact there would now be a direct impact on housing.
· Odour, Dust and Litter are to be controlled by a waste management License which is yet to be submitted. PPS10 states, pollution should not be controlled by a condition. We therefore believe this also should have been included in an EIA.
· The new proposal requires the destruction of 183 meters of very high and established hedgerow which if removed will be contrary to WLP29 (iv).
· WLP27, which asks for justification for need, then describes impact issues including (vi) historic parks and gardens and (xi) character, setting or amenities of individual settlements and the separation of settlements as does WLP29 (v).
· Little consideration has been given to the point at 10.14 of the WLPB about living conditions. 6.13 discusses buffer zones between schools and houses.
· Only 20% of the new proposed site takes in part of the farm curtillage while the remaining 80% takes in green field land which is contrary to many policies and plans, The attached objections from GVA Grimley on behalf of the Hilton Hotel Group makes this clear.
· No detailed designs exist for the buildings to enable their impact to be understood. The absence of the required Waste Management Licence at this stage means it is not possible to determine this impact.
· The site is surrounded by areas of significance including a Grade I Listed Priory building, a listed walled garden, extensive parkland of Special Landscape Interest.
· Lighting and other environmental impact from the site will damage a wide area of visual appeal and sensitivity.
· The site is within an area which was previously the subject of a Public Enquiry, which resulted in its rejection for development by the Government Planning Inspector who, in 2000, described it as-an Important green gap and gateway to Newbury'.
· Waste use is allowed on land formerly developed or ‘disturbed’, as caused by mineral extraction. The existing balancing pond on this site has become absorbed into the landscape and thus should not be considered a site acceptable for redevelopment according to waste policy defined in the committee report item 11.1.3.
· To make matters worse, the application proposes to locate the balancing ponds onto virgin Greenfield, thus setting a worrying precedent for further encroachment onto Greenfield if that land can subsequently be described as ‘disturbed’..
· The old site has a current through put of 20,000 tonnes.
· The new site is designed to have a capacity of 21,000 tonnes with future proofing for 25 years of about a 10% increase making 23,000 tonnes. The license for the new site is therefore likely to be for 23,000 tonnes.
· The old site is actually licensed for 25,000 tonnes so the old site has greater capacity than the new site and is protected well into the future.
· The claimed recycling level for the old site is 27% compared to a target of 35%. The portfolio member for waste recently stated publicly the site is achieving 39% which is hard to believe given the previous year was only 22%. The Amenity site only sees a small fraction of the total waste. Good waste strategy also dictates that waste transfer stations are placed by or very close to amenity sites to avoid unnecessary HGV movements but this is being ignored. This is especially important to consider as the application 06/00736 would wipe away all local waste transfer stations. What is being overlooked is that all the benefits claimed for the new site can be achieved at the old location, which has greater planned capacity than the new site as well as being adjacent to allocated waste sites.
· There are many environmental issues that are of great concern which are well documented. A major concern is the access to the site on the busy A339 which recently featured in the National Press as being the third most congested section of road, in school term time, in the Country. Due to limited space an appropriate access is Impossible. Good practice will necessitate a no right turn access. This will require a double traverse of the A339 between the two roundabouts near the site resulting in an environmentally unfriendly additional 190,000 miles per annum (20,000 miles more than Tesco first calculated, due to a new traffic study being carried out at the existing site) compared with access to the current site all of which will have a significant impact on the air quality in this area and be contrary to paragraph 11 of PPG13. The resulting compromise is further moderated by the developer not owning enough land for an ideal access and confirmed by the perceived need for traffic calming measures including intrusive measure such as flashing signs and coloured road surfaces.
· The council highway's officer agrees the new site will increase congestion at both roundabouts and at times will exceed the capacity causing traffic to back up.
· The Police have expressed general public protection issues including the inability to monitor traffic backing up onto the fast and busy A339.
· No 106 money at all is being required of this application.
P.S. Point:
The 3 hectares of land set aside for waste at New Greenham Park as preferred area 3 of WLPB also protected in policy WLP21 has already had an extension for a food manufacturing factory built on it, as has the Slater Centre which is part used for non-waste related uses, and a car dealership storage operation takes up the remainder. The JSPU are aware that NGP are resisting waste use but are unaware that there is no space left of the 3 hectares set aside for waste reducing further West Berkshires committed waste provision.
Another application by Grundon for waste use in West Berkshire has been hampered and consequently withdrawn which is the opposite of the handling of this application.
Copies of JSPU and Hilton International objections and college plan will be sent under separate cover with a hard copy of this letter.
Yours sincerely
T B M Gatward
