Comment

Representation ID: 55855

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

It is stated in Policy 26 that “the safeguarded Veolia Waste Recycling Transfer Station should be
relocated off-site. This would need to be undertaken in collaboration with the Local Minerals and
Waste Authority and is a pre-requisite to future sensitive development coming forward on
surrounding plots”. It is anticipated in the AAP that the land currently occupied by the Veolia
waste recycling facility would be redeveloped for business and housing uses. However, as
explained below, the adopted and emerging Minerals & Waste Local Plans seek to safeguard the
existing waste recycling transfer facility in its current location, it appears that the policy
requirements for a replacement facility might be difficult to achieve on a suitable alternative site,
and at this stage no alternative site for the relocation of Veolia’s operations have been identified.
The relevant policies of the adopted and emerging Minerals & Waste Local Plan are identified
below, as are the relevant policies of the adopted Cambridge and South Cambridgeshire Local
Plans.
The Veolia site is safeguarded as a waste recycling transfer station in the adopted and emerging
Minerals & Waste Local Plans, and as such it is anticipated that the existing facility would be
retained on site, relocation is not anticipated and no alternative/replacement sites are identified.
Policy CS18: Waste Management Proposals Outside Allocated Areas of the Minerals and Waste
Core Strategy Development Plan Document (adopted July 2011) states:
“Proposals for waste management development outside allocated areas will be considered
favourably where :-
• this is consistent with the spatial strategy for waste management, and
• it can be demonstrated that they will contribute towards sustainable waste management,
moving waste up the waste hierarchy
Waste recovery and recycling facilities may be permitted where they are:
a. for on-site management of waste
b. on land identified for general industrial use
c. co-located with complementary activities (including existing permanent waste management
sites)
d. on previously developed land
e. on farm holdings to facilitate agricultural waste recycling
f. within a medical or research institution which is generating waste (bio-medical, research and
clinical waste only)
g. in strategic development areas
h. at inert landfill sites (inert waste recycling only)
All strategic development will make provision for permanent waste management.”
The existing waste recycling transfer facility operated by Veolia is for general use and is not
related to on-site waste management, agricultural waste, medical/research waste, or inert waste.
Therefore, criteria (a), (e), (f) or (h) are not relevant in terms of potential alternative sites. It is
expected that previously developed land within and on the edge of Cambridge would be
redeveloped for higher value uses or the relocation of other commercial activities, and other
potentially available land would be subject to constraints including impacts on residential amenity.
The employment areas within Cambridge are protected for existing commercial uses or are
subject to redevelopment proposals which excluded general industrial type uses. The
employment areas in South Cambridgeshire are protected for a limited range of employment
uses or are in villages where impacts on residential amenity would restrict a waste recycling use.
The strategic development areas on the edge of Cambridge and in South Cambridgeshire are for
residential and high value commercial uses where a waste recycling transfer facility is not
anticipated or appropriate. Therefore, there are very limited opportunities within or close to
Cambridge for a replacement site for a waste recycling transfer facility.
Policy 4: Providing for Waste Management of the emerging Minerals and Waste Local Plan
(Proposed Submission Draft November 2019) expects existing waste sites to meet identified
needs and so no specific new allocations are proposed. Policy 4 sets out a criteria based policy
for new waste facilities, which in summary must be located on sites within the settlement
boundary of main settlements and in employment areas identified as suitable for B2/B8 uses or
within strategic employment areas. The adopted Cambridge Local Plan 2018 identifies Areas of
Major Change but none are suitable for a relocated waste recycling transfer facility, and there are
no policies that support this type of use within the settlement boundary. It is likely that any
redevelopment opportunities that exist in Cambridge would be brought forward for high value
uses e.g. residential and commercial, rather than a waste recycling transfer facility. The South
Cambridgeshire Local Plan 2018 does include allocations for B1/B2/B8 uses – at Over and
Papworth Everard (see Policy E/5), and Policies E/12 and E/13 support employment uses within
and on edge of villages but subject to no adverse impacts, and Policy E/15 identifies established
employment areas which mostly accommodate office, research and development, manufacturing
and logistics uses. It is likely that the existing employment sites in South Cambridge would not be
suitable for a relocated waste recycling transfer facility because they are too far from Cambridge
and existing and surrounding uses would be incompatible with such a facility.
The Veolia site is identified as a Waste Management Areas (WMA), and Policy 10 of the
emerging Minerals and Waste Local Plan applies. Policy 10 expects such sites to be used for
waste management or compatible facilities. Criteria (c) of Policy 10 states: “proposals which
demonstrate clear wider regeneration benefits which outweigh the harm of discontinued
operation of the site as a WMA, together with a demonstration to the Waste Planning Authority as
to how the existing (or recent) waste stream managed at the site will be (or already is being)
accommodated elsewhere”. Criteria (c) anticipates that if waste management facilities are to be
relocated – as is proposed in the North East Cambridge AAP – that there would be a strategy in
place to manage the existing waste e.g. recycled waste treated at Veolia’s existing operation.
Policy 10 is consistent with the approach advocated in Policy 26 (of the North East Cambridge
AAP) that the relocation of the existing waste recycling transfer facility is a pre-requisite of
redevelopment of the site currently occupied by Veolia.
Therefore, it is considered that there are very limited opportunities within or close to Cambridge
for a replacement site for a waste recycling transfer facility, in that available sites within
Cambridge would be redeveloped for high value uses and that existing employment sites within
Cambridge and South Cambridgeshire would not be suitable for such a use. Veolia is an existing
established business, and a replacement facility must be located within or close to Cambridge in
order to avoid the unnecessary transportation of recycled waste and material. This emphasises
the need to maximise the development value of the Veolia site through this process in order to
facilitate a relocation to ensure that they can compete with land values and ensure that that any
move is financially viable as well as operationally.
As set out in the response to Policy 24b, Veolia would be affected by the redevelopment of its
existing site, and would welcome discussions and assistance from the Council to find a suitable
alternative site from which it can operate a waste recycling transfer facility.