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Minerals and Waste Core Strategies Preferred Options

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					Minerals and Waste Core Strategies : Preferred Options Consultation Response Comments submitted by Cheltenham Borough Council to Gloucestershire County Council MINERALS CORE STRATEGY
Section/Policy General Cheltenham Borough Council comment Cheltenham Borough Council welcomes the approach and layout adopted in the Preferred Options Report. The Context section is generally informative and useful. However, it would be useful to clarify how the Minerals and Waste Development Framework fits in with Local Development Frameworks and which documents will form the statutory development plan with respect to minerals and waste applications. These diagrams are useful but could be improved by the inclusion of further details outside the county boundary. Policy options put forward in the remainder of the document refer to broader crossboundary issues and strategies and this should be reflected in the spatial diagram. The vision is supported, particularly the reference to increasing the reuse of materials and the recycling of demolition waste. The strategic objectives are broadly supported. It would be beneficial to see an analysis of the relationships between the Strategic Objectives in the Core Strategy and the Sustainability Objectives outlined in the Sustainability Appraisal. This would provide an indication of how the Sustainability Appraisal process has influenced the production of the Core Strategy. Internal Supply Opportunities 2 – Consideration needs to be given to the need to minimise heavy goods vehicle movements through the centre of Cheltenham on the A40. No preference. All the policy options would ensure a consistent supply of materials. No preference. All the policy options would ensure a consistent supply of materials. No preference. All the policy options would ensure a consistent supply of materials. Supported. All 3 policy options are supported. However, MP07c is preferred as it provides more certainty as to the future supply of local natural building and roofing stone and will, therefore, assist in maintaining local distinctiveness. Supported. Supported. Supported.

Context

Diagrams 1 and 2 – Spatial Portraits

Vision

Strategic Objectives

Spatial Strategy

Crushed Rock MP03 Sand and Gravel Provision MP04 Sand and Gravel Locations MP05 Clay MP06 Natural Building and Roofing Stone MP07 Coal MP08 Reuse and Recycling MP09 The Environment

MP010 People MP011 Reclamation MP012 Resource Management MP013 Transport MP014

Supported No preference. Supported.

Sustainability Appraisal

The Preferred Option is generally supported, however, it would be improved by recognition of the importance of removing heavy goods vehicles from built up areas. The policy suggests that the haulage routes with “least environmental impact” will be utilised where possible. This should be amended to “least environmental and social impact” to reflect the importance of removing road haulage from built up areas and improving quality of life for residents? The Sustainability Appraisal is comprehensive and informative. However, it would be useful to utilise its judgements within the main body of the Core Strategy. This can be achieved by scoring each policy option from a sustainability perspective – possibly using a traffic light approach. Such a approach would allow the reader to make an informed decision as to their policy preference without having to continually refer to the sustainability appraisal.

WASTE CORE STRATEGY
Section/Policy General Context Cheltenham Borough Council comment Cheltenham Borough Council welcomes the approach and layout adopted in the Preferred Options Report. The Context section is generally informative and useful. However, it would be useful to clarify how the Minerals and Waste Development Framework fits in with Local Development Frameworks and which documents will form the statutory development plan with respect to minerals and waste applications. Strong support for the preferred vision. In particular the distinction between major strategic waste sites, which should be in strategic accessible locations, from smaller local sites that should be positioned close to waste arisings. The suite of Strategic Objectives is generally supported. However, it would be beneficial to see how these objectives relate to those outlined in the Sustainability Appraisal. The principle of dealing with strategic sites separately from local sites is supported. Support for policy option WP03c as it provides greater certainty to developers. The question of the potential redundancy of this policy as national guidance is developed is noted. However, national or regional policy would only cause this policy to be redundant if it were more stringent. Adopting this policy option would provide a minimum standard that developers would have to adhere to in Gloucestershire, irrespective of national and regional guidance. It would be beneficial if this policy also required developers to provide refuse storage facilities within their developments and the equipment required for sorting and recycling waste.

Vision WP01

Strategic Objectives Spatial Strategy Waste Reduction WP03

Recycling and Composting WP04

Markets for Recyclates WP05 Recovery WP06

Locational Strategy WP07

Environmental Acceptability WP08 Waste Infrastructure WP09 Safeguarding WP010

Policy option WP04c is most strongly supported. It would be beneficial for strategic sites to be allocated, as this provides certainty for local residents. Local sites, however, should be accommodated close to waste arisings and should be dealt with on a case by case basis. Clarification is required as to whether the policy includes community composting schemes and whether this would be dealt with by the criteria for “local” facilities. Support for both policy options. However, there is a preference for policy option WP05b as it reflects the importance of working in partnership with other bodies. Support for policy option WP06c as it would provide greater certainty for the public as to the location of future strategic sites. This policy retains the criteria based approach for local sites and this is also supported. Support for policy option WP07d as it provides a clear sequential test against which applications can be determined. This policy option provides for a degree of certainty of the potential location of strategic waste sites while retaining flexibility if sites do not come forward. This policy option will have to be carefully worded to provide certainty as to the evidence required to be submitted to prove that sequentially preferable sites are unavailable or not viable. No preference. Both policy options are contingent on the definition of “significant adverse impact”, which is not made explicit within either policy option. No preference. Both policy options seek to address the provision of waste water infrastructure.

Support for policy option WP010a. Option WP010b suggests an increasing role for local planning authorities in the planning of waste sites, which local planning authorities would not necessarily have the relevant skills to perform. Cumulative No preference. Both options seek to consider the effects of Impacts WP011 cumulative impacts on local communities. Landscape No preference. But the policy should not repeat policies in WP012 Planning Policy Statement 7 and should only be included where it goes above and beyond national policy in order to reflect local circumstances. Archaeology No preference, a policy should only be included if it exceeds WP013 national policy. Green Belt WP014 No preference, a policy should only be included if it exceeds national policy. Biodiversity/Nature No preference, a policy should only be included if it exceeds Conservation national policy. WP015 Sustainability The Sustainability Appraisal is comprehensive and informative. Appraisal However, it would be useful to utilise its judgements within the main body of the Core Strategy. This can be achieved by scoring each policy option from a sustainability perspective – possibly using a traffic light approach. Such a approach would allow the reader to make an informed decision as to their policy preference without having to continually refer to the sustainability appraisal.


				
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Description: Minerals and Waste Core Strategies Preferred Options