6.1.2 The process whereby Buckinghamshire County Council (BCC) reached this conclusion is summarised in the following paragraphs.

Transcription

1 6 CONSIDERATION OF ALTERNATIVES 6.1 Background The Minerals and Waste Core Strategy DPD sets out two Alternative Preferred Options. Option 1 suggests that two Strategic Waste Complexes (SWC) should be developed with one serving the north of the county and one serving the south of the county. Option 2 suggests only one SWC should be developed, supported by WTSs for more efficient operation. The latter being the option being pursued The process whereby Buckinghamshire County Council (BCC) reached this conclusion is summarised in the following paragraphs During the development of the Local Development Framework (LDF), BCC commissioned independent consultants to review and assess a number of potential sites for waste management development. Stage 1 identified a long list of 191 areas which could have potential for waste management use The next stage involved a more detailed selection exercise to narrow down the long list through the application of an appraisal process. This work identified sixteen areas where more detailed investigation should take place. This detailed appraisal, using a range of national and local planning policy criteria, resulted in nine areas that were judged suitable to accommodate waste management development. The London Road Depot was one of the sites judged to be suitable. These sites were all included in the Waste DPD Preferred Options Consultation Report published in June A supplementary search in north-west Buckinghamshire was carried out in 2007 which identified a further two sites that were also included in the Waste DPD consultation report. The results of this consultation have fed into the preparation of the present Core Strategy document. Following consultation responses an initial list of nine potential sites for strategic treatment of municipal waste was drawn up. The consultants advised that five of these short-listed sites were not suitable for strategic waste treatment facilities, which left four sites: Calvert Landfill Site, Woodham Industrial estate, Wapseys Wood Landfill Site and Springfield Farm Landfill Site During the development of the Waste DPD, BCC decided to select existing landfill sites for its SWCs, and therefore only Calvert, Wapseys Wood and Springfield Farm were listed as Preferred Sites. It was also concluded that applications for SWCs (and therefore any supporting facilities such as WTS) would need to come forward early in the plan period if facilities were to become active by 2016 to allow timely diversion of

2 waste from landfill the main focus of Buckinghamshire s plan for future waste management Woodham was discounted within the Core Strategy on the grounds of deliverability as it was not fully in the control of the waste industry and was not a site favoured by any of the shortlisted bidders under the waste procurement process During the Sustainability Testing, a screening study for Appropriate Assessment was carried out to identify the likely impacts on important nature conservation sites (European Natura 2000 sites). A key protected site in the area includes Burnham Beeches SAC. The screening study identified that EfW or AD at either Springfield Farm or Wapseys Wood is likely to have a significant effect on the conservation objectives of the Burham Beeches SAC. Calvert, on the other hand, being more than 10km from any SAC or SPA, was not considered further in the screening assessment During the assessment of options to derive the preferred option in the Core Strategy, the Council assessed the deliverability of each option in terms of whether they were in the control of the waste industry; likely to be available to meet the need for additional capacity in the short term; and whether they are favoured as a location by one of the short-listed bidders in the Waste Procurement Process. In these terms, Calvert and Wapseys Wood were considered to be the most deliverable, with Springfield therefore being deleted from the process The proposed London Road East WTS is therefore part of a specific residual waste management solution for Buckinghamshire. This solution includes an EfW facility at Calvert (now known as Greatmoor) served by two WTS. The WTS s and EfW are the subject of separate planning applications as each is remote from the other elements of the solution and in Planning and EIA terms are to be considered in isolation As such through the above summarised process of site and strategy selection, the proposal to locate the WTS at Amersham has been rigorously tested, in terms of potential alternative sites, through the extensive work carried out in the development of the various BCC waste strategy reports and consultations including the Buckinghamshire Minerals and Waste Core Strategy (BMWCS) and Buckinghamshire Minerals and Waste Local Plan (BMWLP) supporting documentation.

3 6.2 Alternative Site Assessments undertaken to date Waste Recycling Group (WRG) Site Assessment, May In May 2010 WRG (now FCC) commissioned a search of potentially available commercial premises in the Amersham, High Wycombe and Beaconsfield areas that might be suitable for conversion to a WTS (Appendix 5/A). The search criteria included: Operational site area 1.5 to 3 acres; Existing building area c.2323 sq m; and Existing building minimum height 8m to eaves This search did not identify any suitable premises. Study as part of the BMWLP consultation into alternative transportation methods, Jacobs, January 2009 (commissioned by BCC) BCC commissioned a study as part of the BMWLP consultation into alternative transportation methods to consider further the potential for and viability of transferring the waste traffic from road to rail This study detailed alternative means of transporting the bulked up waste to the final disposal solution It was stated that a complete alternative is to transport the residual waste directly from collection to the final disposal solution. Arguably this is also the do-nothing scenario. The relative viability of this is directly proportional to the distance over which the waste must be transported. The further away the final disposal point is from the source the less viable the transportation of small quantities by road is, and the greater the benefits of bulking it up It was concluded that the partial alternative was preferred i.e. the function of the WTS was still required so as to enable the residual domestic (and C&I waste of a similar nature) to be collected together and bulked up to minimise the numbers of road haulage vehicle trips necessary to transport it to the final disposal point. WRG Study, August As a result of a review of the findings of the Jacobs study, WRG commissioned a further study (August 2010) of the potential in the context of the Greatmoor EfW residual waste management solution.

4 6.2.8 This concluded that given the limited site opportunities generally, the lack of a suitable location relative to the main centres of population and the rail routeing logistics, the movement of waste from southern Buckinghamshire by rail is nonviable as a sustainable operation. RPS Alternative Site Assessment, March RPS was instructed to carry out an up-to-date alternative site search exercise to ensure that no significantly better sites than the London Road East site have come to market since the original exercise was completed in April The purpose of the site search assessment was to provide an up-to-date comparative analysis of potential sites for the development of a WTS within the south eastern part of Buckinghamshire to ensure that no other sites were significantly better than the London Road East site that could provide a more acceptable alternative location for the proposed development taking into account consistency with relevant policy and potential constraints The preliminary consideration in setting the parameters for the alternative site assessment was to set the geographical extent of the area from which alternative sites will be considered. The proposed development is intended to receive waste to be bulked up and transported from both Chiltern District Council and South Bucks District Council areas under contract with Buckinghamshire County Council Within the RPS March 2014 (see appendix 6.1) and subsequent June 2014 addendum study (see appendix 6.2), when considering a suitable site for a WTS, the following parameters were taken into account: Proximity to waste arisings; The need to avoid unacceptable harm to the environment and human health; The availability, if possible, of an industrial setting or similar compatible land-use; Proximity to the primary transport network, including the primary road network with potential to be accessed by rail or waterways; Potential impact on sites designated for nature conservation, landscape or historic interest; Risk of flooding and protection of the water environment; Future growth and need for sustainable waste infrastructure; and If possible, the utilisation of previously developed land.

5 In conclusion and after subsequent site sieving exercises the March 2014 study short listed the following 5 sites: Site No. 2: Open Storage Land, Raans Road (0.97 ha); Site No. 3: Amersham Commercial Park, Raans Road (70,000 sq.ft or 6,500 sq.m); Site No. 36: London Road East, Amersham (2.9 ha); Site No. 41: Land to the west of Beaconsfield HWRC (1.9 ha); and Site No. 52: Hyde End, land adjacent to Jewsons (1.75 acres, 0.7 ha). RPS Alternative Site Assessment addendum, June The addendum study (June 2014) provides an update to the original Alternative Site Assessment, taking into account any new potential sites that have come to the market since the original site search exercise was completed in early March A check on policy / development plan status was also undertaken The assessment followed the same methodology as the initial March 2014 study and concluded that although three new potential sites were identified, the same five sites should be shortlisted as detailed above. 6.3 Further analysis of the five short listed sites The aim of undertaking further analysis of the RPS March 2014 and subsequent June 2014 update study short listed sites is to fully understand what sites could realistically come forward for the development of a WTS In this respect, WA have added further considerations to the ones detailed in the RPS reports and these are intended to further sieve out sites that are: Too small: if a site is of a size that cannot physically accommodate the proposed WTS (2.9ha total site area) as required then there is no basis for short listing for further investigation; Have over-riding constraints: if a site is allocated or has permission for some other incompatible use or is subject to national or international nature conservation designations, then it is unlikely to be found suitable and should not be shortlisted; Are already occupied by other compatible uses, but where the occupier is known to be resistant to selling the site or where site assembly would be required: there is no merit in short listing sites that cannot be guaranteed to be available to FCC

6 in a timescale that is required to provide an operational WTS by 2016 in order to coincide with the commencement of operations at the EfW at Greatmoor, Calvert landfill. Methodology The 19 site assessment criteria are detailed as follows: 1. Size The proposed London Road East WTS has been specifically designed to meet the contract requirements whilst minimising land take. The building footprint has been reduced since the initial 2011 submission, however the WTS proposal still needs to accommodate the necessary buildings, proposed WTS areas and access roads which can be achieved within an area of 1ha (Government Guidance Planning for waste Management Facilities, A Research Study, ODPM, August 2004 suggests that a typical site area required for a WTS can be up to 1 ha) but this does not consider the provision of the required landscape works for example screening. As the provision of landscape appropriate to the site context is also a requirement, the London Road East WTS given the sites context and setting requires bunding and planting around the buildings and hardstanding areas. A pond is also incorporated for a SUDS drainage. This is additional to the 1ha stated above and thus the area in total with landscaping included equates to 2.9 ha. Against this background, a site area of 3 ha is considered to be required to fully accommodate not only the WTS building but the proposed WTS areas, access roads and an allowance for landscape treatments (screening, bunds and SUDs pond / drainage) to be incorporated. Furthermore, sites must be of a suitable configuration that could realistically accommodate the proposed WTS. For example, sites that comprise long thin parcels of land would not be considered practical WTS development sites. 2. Availability Sites will be assessed against their ownership as indication of ease of delivery. Sites in the Council s or other public ownership are preferred to those in private or multiple ownership. This reflects the difficulties and relative complexity of site ownership and land assembly, and ultimately willingness to develop sites for waste management facilities. The presence of occupied buildings on site such that it would not be possible to obtain a 3ha

7 site for the WTS without displacing existing businesses not owned or controlled by FCC or Buckinghamshire County Council. PPS10 requires that waste planning authorities should: avoid unrealistic assumptions on the prospects for the development of waste management facilities, or of particular sites or areas, having regard in particular to any ownership constraint which cannot be readily freed, other than through the use of compulsory purchase powers In this respect it is considered that the need to relocate existing third party businesses would represent such a serious obstacle to the development of the WTS within the required development timescales that this an appropriate absolute constraint to avoid detailed consideration of unviable sites; 3. Allocations Sites considered against existing allocation or status. Incompatible allocation (a compatible allocation, permission or use is deemed to be waste management or industrial), permission or current use on site: these include residential, community use, schools and active wastewater treatment plants. 4. Alignment with the Planning Vision for the Area Sites considered against potential alignment or conflict with other corporate and planning strategic objectives / visions for the area; 5. Land status Sites tested against existing status as either brownfield Previously Developed Land (PDL) or greenfield land; Suitability Criteria 6. Location Preference is given to those locations that are in close proximity to waste arisings in Chiltern District Council and South Bucks District Council areas; 7. Proximity to sensitive users Reflects the immediate adjacency of potential waste management sites to sensitive uses where buffering may be insufficient to mitigate potential negative impacts of waste management development. Sensitive uses are identified to include: environmental and heritage designations, existing schools, higher density housing development, health facilities and community facilities;

8 8. Accessibility to Transport Networks Reflects the need for sites to be adequately accessed from the Strategic Road Network or can be made to do so without excessive new/improved road development. Rail and/or waterway access can also be beneficial. Sites in immediate or close proximity will be preferential to those that are currently and/or in the future likely to remain inaccessible to these movement networks; 9. Site Access Sites to be tested against the likely or anticipated implications of mitigation of multiple physical or access constraints in order to deliver the site for waste management uses; 10. Landscape and Visual Impacts Sites to be tested against potential visual or amenity impact including consideration of whether management or mitigation could eradicate potential negative impact; Deliverability Criteria 11. Physical Development Constraint Sites to be tested against the extent to which on-site physical development constraints make delivery potentially unviable within the plan period. Reflects the need to consider the deliverability of sites in terms of physical development constraints on-site including structures, utilities or transport infrastructure, land subsidence, etc. that would be required to be removed prior to development; 12. Natural Development Constraints Sites to be tested against the extent to which on-site natural development constraints make delivery potentially unviable within the plan period. Reflects the need to consider the deliverability of sites in terms of natural development constraints such as impact on ecology etc. The presence of national or international environmental designations within the site boundary (such as a Site of Special Scientific Interest (SSSI) of National Nature Reserve (NNR); 13. Public Rights of Way Consideration given as to whether a public Right of way would be effected by the development proposals i.e. require diversion or stopping up. This can take up to a year or more to agree and as such could have a significant impact as to whether the proposals could be delivered in line with the commencement of operations at the Greatmoor EfW, Calvert landfill;

9 14. Current Use Sites to be considered in relation to current occupation levels including the challenge likely to be posed in securing vacant possession predevelopment. Sites that are currently occupied for waste management facilities and those that are developed but vacant and unused will be preferential to those in wider B Use Classes and over those that have current conflicting activities or are under construction at the current time; 15. Cultural Heritage Constraints - Reflects the location of the site in relation to the District s historical and/or cultural assets. Sites not immediately adjacent or not in close proximity to cultural or historical assets will be preferential; 16. Rail / Water Transport In line with Government advice, sites are assessed whether there would be any opportunities now or in the future for the movement of waste by rail and water rather than by road; 17. Flood Risk Sites are assessed if they are at risk of flooding and this potential is identified by the Environment Agency within its publications as a material consideration in land use planning; 18. Ground Water Vulnerability Sites are assessed whether water resources may be at risk from potential development, particularly where a vulnerable aquifer is located; and 19. Air Quality Management Areas Sites are assessed whether they are located within or adjacent to an Air Quality Management Areas in line with the NPPF at paragraph 124 which states that planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants taking into account the cumulative impacts on air quality from individual sites in local areas. It requires that planning decisions to ensure that any new development in Air Quality Management Areas is consistent with the local Air Quality Action Plan As well as including the above information, a traffic light system (red, amber and green approach) has been taken. Green indicates strong performance against assessment criteria, amber indicates moderate performance against assessment criteria, and red indicates a material conflict with the assessment criteria. This approach is preferred over a numerical scoring system as it is easier for people to understand, avoids an overly prescriptive judgement being made and supports the ability of sites to be brought forward for waste management facilities in the future

10 using a variety of designs and technologies capable of overcoming constraints or potential negative impacts Taking the above information into consideration, the following site assessment matrix table has been produced which assesses the five shortlisted sites from both the March and June 2014 RPS reports specifically implementing the London Road East WTS proposals to assess each site:

11 London Road WTS Criteria Site 1 (Site No. 2) Open Storage Land, Raans Road 1. Size 0.97 ha the site could accommodate a WTS, building, but not the planned associated infrastructure (the access road, weighbridges, operational yard area and landscaping) at the London Road East site. 2. Availability Appears to be available as being advertised on the open market. However the specific design for a WTS at this site has not been considered. 3. Allocations The site is not allocated as a waste site. It is however allocated as an employment site under Policy E2 of the Chiltern District Local Plan and Policy CS16 of the adopted Core Strategy for Chiltern District. The site is also being put forward as a Strategic and Key Employment Site under Policy SE3 of the emerging Chiltern Delivery Site 2 (Sit No. 3) Amersham Commercial Park, Raans Road 0.65 ha the site being 50% smaller than the London Road East site is not anticipated to be able to accommodate a WTS and associated infrastructure. Appears to be available as being advertised on the open market. However the specific design for a WTS at this site has not been considered. The site is not allocated as a waste site. It is however allocated as an employment site under Policy E2 of the Chiltern District Local Plan and Policy CS16 of the adopted Core Strategy for Chiltern District. The site is also being put forward as a Strategic and Key Employment Site under Policy SE3 of the emerging Chiltern Delivery Site Assessment Matrix Site 3 (Site No. 36) London Road East, Amersham 2.9 ha - the site can accommodate a WTS and all planned associated infrastructure (the access road, weighbridges, operational yard area and landscaping). The land is owned by Chiltern District Council. Allocated as a waste site in the adopted Buckinghamshire Minerals and Waste Core Strategy (BMWCS) as essential infrastructure to support the Strategic Waste Complex at Calvert landfill. The site is located within the Green Belt under Policies GB1, GB2 and GB22A of the adopted Chiltern District Local Plan Site 4 (Site No. 41) Land to the West of Beaconsfield HWRC 1.9 ha developable land, extending to 3 ha if the land across the ditch is added capable of accommodating a WTS and associated infrastructure. The site is owned by Portman Burtly and has been made available for development. However the specific design for a WTS at this site has not been considered. The site is not allocated as a waste site. The site is located within the Green Belt under Policies GB1, GB2 and GB4 of the South Bucks District Local Plan which seek to preserve the character and openness of the Green Belt. The site also lies within an area identified as a Mineral Safeguarding Area in the adopted Site 5 (Site No. 52) Hyde End, Lane adjacent to Jewsons 1.75 ha - the site could accommodate a WTS and associated infrastructure but the landscaping potential and operational yard area is likely to be limited. The site is available to let under a long or short term lease. It is also available for sale freehold with vacant possession. However the specific design for a WTS at this site has not been considered. The site is not allocated as a waste site. The site is located within the Green Belt under Policies GB1, GB2 and GB22A of the adopted Chiltern District Local Plan which seek to preserve the character and openness of the Green Belt. The site is located within the Green Belt under Policies GB1, GB2 and GB22A of the adopted

12 London Road WTS Criteria Site 1 (Site No. 2) Open Storage Land, Raans Road 4. Alignment with Planning Vision for the Area Development Plan Document (not currently adopted but awaiting formal submission by the end of June 2014) Appears to be in line with the planning vision for the area, however as limited employment will be required for the WTS there is a conflict with the allocation of being a future Strategic / key employment site. Site 2 (Sit No. 3) Amersham Commercial Park, Raans Road Development Plan Document (not currently adopted but awaiting formal submission by the end of June 2014) Appears to be in line with the planning vision for the area, however as limited employment will be required for the WTS there is a conflict with the allocation of being a future Strategic / key employment site. Site 3 (Site No. 36) London Road East, Amersham which seek to preserve the character and openness of the Green Belt. The site is located within the Green Belt under Policies GB1, GB2 and GB22A of the adopted Chiltern District Local Plan which seek to preserve the character and openness of the Green Belt. In line with the planning vision for the area - The BMWCS allocation acknowledges that very special circumstances exist in relation to the inappropriate development in the Green Belt and AONB and the need for the facility and the lack of available suitable alternative sites would need to be demonstrated robustly in any planning application. However, there is a requirement for this facility to be built in line with commencement of operations at the Greatmoor EfW, Calvert Landfill. Site 4 (Site No. 41) Land to the West of Beaconsfield HWRC Minerals and Waste Core Strategy under Policy CS1. Given the Green Belt location very special circumstances will have to be demonstrated robustly in any planning application i.e. the need for the facility and the lack of available suitable alternative site. Site 5 (Site No. 52) Hyde End, Lane adjacent to Jewsons Chiltern District Local Plan which seek to preserve the character and openness of the Green Belt. The site also lies within an area identified as a brick clay resource on the adopted Minerals and Waste Core Strategy proposals map. Given the Green Belt location very special circumstances will have to be demonstrated robustly in any planning application i.e. the need for the facility and the lack of available suitable alternative site.

13 London Road WTS Criteria Site 1 (Site No. 2) Open Storage Land, Raans Road 5. Land Status Vacant Previously Developed Land 6. Location Raans Road, Amersham Urban Area 7. Proximity to Sensitive Users Within an industrial area, however within close proximity to sensitive receptors within the nearest residential developments along Raans Road (approximately 100 to the north). A new residential development has been built along Raans Road which would share the access road to the site. Site 2 (Sit No. 3) Amersham Commercial Park, Raans Road PDL currently occupied by industrial / warehouse units. Raans Road, Amersham Urban Area Within an industrial area, however within close proximity to sensitive receptors within the nearest residential developments along Raans Road (approximately 100 to the north). A new residential development is being built along Raans Road which would share the access road to the site. Site 3 (Site No. 36) London Road East, Amersham Vacant previously developed Green Belt site within the Chilterns AONB. 2km South of Amersham fairly rural location, however there is a Household Waste Recycling Centre (HWRC) located directly to the south west of the site and other smaller industrial units are located to the north west. The closest sensitive receptors are a row of residential cottages located along London Road adjacent to the northern boundary of the site. Site 4 (Site No. 41) Land to the West of Beaconsfield HWRC Site 5 (Site No. 52) Hyde End, Lane adjacent to Jewsons Vacant Green Belt site Vacant previously developed Green Belt site within the Chilterns AONB. Fairly rural location. 2km east of Beaconsfield to the south of the A40. The site is located to the west of a HWRC and north of the Wapseys Wood landfill. The closest sensitive receptor is located within the nearest residential developments along Pyebush Lane approximately 300m to the west of the site but these are separated from the site by a woodland belt. Fairly rural location. Located along the B485 adjacent to a Jewsons building merchant and between Great Missenden to the west and Chesham to the east. The nearest sensitive receptors are a row of residential properties on the opposite side of the B485.

14 London Road WTS Criteria Site 1 (Site No. 2) Open Storage Land, Raans Road 8. Accessibility to transport Networks 1km east of Amersham on the Hill and close to its junction with the A404 which provides access to junction 18 of the M25 (8 miles to the east). Site 2 (Sit No. 3) Amersham Commercial Park, Raans Road 1km east of Amersham on the Hill and close to its junction with the A404 which provides access to junction 18 of the M25 (8 miles to the east). Site 3 (Site No. 36) London Road East, Amersham Well located to the main strategic road network 2km south of Amersham just off the A413. Site 4 (Site No. 41) Land to the West of Beaconsfield HWRC Well located to the main strategic road network being just south of the A40. Site 5 (Site No. 52) Hyde End, Lane adjacent to Jewsons Well located to the main strategic road network with the A413 less than 2 miles to the west and Chesham 3 miles to the east. 9. Site Access Site access is in place, however the access road (Raans Road) is used by a number of residential properties including the new estate recently built. The regular use of HGV and RCV vehicles along Raans Road would also encounter issues with parked vehicles and before the site is accessed the vehicles would need to pass under a railway bridge with a height restriction of 14ft 3 inches. Bearing in mind fairly standard artic vehicle heights are 3.6-4m access to this site would be restricted. 10. Landscape and Visual Impact There are no local landscape designations in close proximity to the site. Site access is in place, however the access road (Raans Road) is used by a number of residential properties including the new estate recently built. The regular use of HGV and RCV vehicles along Raans Road would also encounter issues with parked vehicles and before the site is accessed the vehicles would need to pass under a railway bridge with a height restriction of 14ft 3 inches. Bearing in mind fairly standard artic vehicle heights are 3.6-4m access to this site would be restricted. There are no local landscape designations in close proximity to the site. The site itself does not currently benefit from direct access but suitable access can be achieved through the existing access in place for the HWRC. There are no local landscape designations in close proximity to the site. The site itself does not currently benefit from direct access. There are no local landscape designations in close proximity to the site. The site itself does not currently benefit from direct access. The access when in place is likely to be shared with Jewsons. There are no local landscape designations in close proximity to the site.

15 London Road WTS Criteria Site 1 (Site No. 2) Open Storage Land, Raans Road The Chilterns AONB is 11. Physical Development Constraints 12. Natural Development Constraints 13. Public Rights of Way located approximately 350m to the north. The site is located within an existing industrial area. Views into the site are limited due to surrounding landscaping. No buildings on site. No sites of nature conservation interest within 2km of the site. No public Rights of Way are located within / adjacent to the site. 14. Current Use Currently used for car storage (0.97 ha) Site 2 (Sit No. 3) Amersham Commercial Park, Raans Road The Chilterns AONB is located approximately 350m to the north. The site is located within an existing industrial area. Views into the site are limited due to surrounding landscaping. Buildings on site and access would require re-design to enable a WTS to be built. No sites of nature conservation interest within 2km of the site. No public Rights of Way are located within / adjacent to the site. Recently built Amersham Commercial Park consisting of a terrace of industrial / warehouse units from 850 sq m 7,570 sq m. Alterations to the current buildings would be required to accommodate the size and type of building and Site 3 (Site No. 36) London Road East, Amersham Site is not highly visible as the site is screened by woodland surrounding the site. The site lies within the Chilterns AONB and the Green Belt however, Policy CS21 of the BMWCS permits development at this site as long as regard is made to suitable design and layout which respects the character of the AONB. Site 4 (Site No. 41) Land to the West of Beaconsfield HWRC Views into the site are limited due to existing tree vegetation. The Chilterns AONB is located approximately 2km north of the site. Site 5 (Site No. 52) Hyde End, Lane adjacent to Jewsons Views into the site are limited by existing tree vegetation. The site lies within the Chilterns AONB and the Green Belt. No buildings on site. No buildings on site. No buildings on site There are no sites of nature conservation interest within 2km of the site. The nearest Public Rights of Way are located on the opposite side of the river Misbourne. The site is owned by Chiltern District Council and is a restored former landfill site / sewage treatment works. The site currently comprises rough grassland that is not managed. There is woodland screening surrounding the site with There are no sites of nature conservation interest within 2km of the site. There is one Public Right of Way which is located between the site and the existing HWRC. Vacant, Green Belt comprising rough grassland that is unmanaged. There is woodland planting to the north and west and a ditch forms the southern boundary. There are no sites of nature conservation interest within 2km of the site. No public Rights of Way are located within / adjacent to the site. Vacant Green Belt land. The site comprises a secure yard with palisade fencing to the front and high level wire fencing bordering the Jewson site. The site has been used in conjunction with the builders merchant operations for many years

16 London Road WTS Criteria Site 1 (Site No. 2) Open Storage Land, Raans Road 15. Cultural / Heritage Constraints 16. Rail or Water Transport No historic landscape or Scheduled Ancient Monument Designations within 1km of the site. However, there is a listed building (Grade II) approximately 350m to the north east of the site at Raans Farm. Adjacent to railway line, however the siting of the site means that there is no potential for the development of rail access. Site 2 (Sit No. 3) Site 3 (Site No. 36) Amersham Commercial Park, London Road East, Amersham Raans Road vehicles turning areas the river Misbourne located required. on the southern boundary. No historic landscape or No historic landscape or Scheduled Ancient Scheduled Ancient Monument Designations within 1km of the site. However, there is a listed building (Grade II) approximately 350m to the north east of the site at Raans Farm. Adjacent to railway line, however the siting of the site means that there is no potential for the development of rail access. Monument Designations within 1km of the site. However, there is a listed building (Grade II) approximately 250m to the south east of the site at the Ivy House, Public House. The site location does not offer any potential for rail or water transport. Site 4 (Site No. 41) Land to the West of Beaconsfield HWRC No historic landscape or Scheduled Ancient Monument Designations within 1km of the site. However, there are two listed buildings (Grade II) approximately 500m to the south of the site at Hyde Farm. The site location does not offer any potential for rail or water transport. Site 5 (Site No. 52) Hyde End, Lane adjacent to Jewsons and currently undeveloped level packed hardcore. The closest Scheduled Ancient Monument is the moated site and enclosures at Redding Wick, approximately 800m to the north. The nearest listed building is located approximately 500m to the south east. The site location does not offer any potential for rail or water transport. 17. Flood Risk The site is not located in an area liable to flooding. The site is not located in an area liable to flooding. The site is not located in an area liable to flooding. The site is not located in an area liable to flooding. 18. Ground The site lies within the The site lies within the The site lies within total The site lies within total Water Outer Zone (Zone 2) Ground Outer Zone (Zone 2) Ground catchment (Zone 3) Ground catchment (Zone 3) Ground Vulnerability Water Source Protection Water Source Protection Water Source Protection Water Source Protection Zone. Zone. Zone. Zone. 19. Air Quality The site does not lie within The site does not lie within The site does not lie within The site does not The site Management an Air Quality Management an Air Quality Management an Air Quality Management does not lie within an Air Areas Zone. Zone. Zone. Quality Management Zone. Green Count Amber Count Red Count The site is not located in an area liable to flooding. The site lies within the Outer Zone (Zone 2) Ground Water Source Protection Zone. The site does not The site does not lie within an Air Quality Management Zone.

17 London Road WTS Results In ranked order: 1. Site 3 (Site No. 36) - London Road East, Amersham The site achieved green in 14 of the 19 criteria; 2. Site 5 (Site No. 52) - Hyde End, Lane adjacent to Jewsons The site achieved green in 12 of the 19 criteria; 3. Site 4 (Site 41) Land to the West of Beaconsfield HWRC The site achieved green in 11 of the 19 criteria; 4. Site 1 (Site No. 2) - Open Storage Land, Raans Road The site achieved green in 10 of the 19 criteria; and 5. Site 2 (Site No. 3) - Amersham Commercial Park, Raans Road The site achieved green in 7 of the 19 criteria. Summary In ranking order, after undertaking the above detailed assessment of the five shortlisted sites (to be read in conjunction with the Site Assessment Matrix Table) only three of the shortlisted sites are deemed to be acceptable for a WTS as access to both sites 1 and 2 is limited for articulated vehicles due to the height of a bridge in close proximity to the site Taking into consideration the allocation for a waste management facility at the London Road East site, this is further justified as being acceptable for a WTS. The London Road East site not only provides space for all infrastructure but also includes space for attenuation using SuDS, enhanced landscaping adequate and safe access, operational yard, car park, weighbridges and welfare building Although the London Road East site is located within the Green Belt and AONB, Policy CS20 and CS21 of the BMWCS states that exceptionally Waste Transfer Stations will be permitted in order to deliver the County s waste strategy In addition, it should be noted that the London Road East site requires minimal access improvement works or alterations to the highway, and is suitably located in close proximity to strategic highways network.

18 London Road WTS Furthermore, the site is vacant, available and is located adjacent to an existing waste facility and is well screened by wooded vegetation. 6.4 Conclusion This assessment suggests that the use of the London Road East site is reasonable and robust in the context of other potential sites in the study area when taking into account relevant operational, planning and environmental considerations The requirement for a WTS is a fundamental requirement of any final solution involving the transportation of waste away from the Chiltern District to the Greatmoor EfW or an alternative residual waste management solution. The requirement to gather together and bulk up waste locally to minimise the impact of its onward transfer to recycling, recovery or final disposal is an accepted principal of waste management and is fundamental to meeting the spirit of the Proximity Principle (i.e. reducing road miles per tonne of waste) Consideration has been given for the potential for alternative sites in terms of the availability of suitable land and/or buildings in the area The shortlisted sites are limited in size and the proposed design of the London Road East site has been used as a minimum requirement as It makes best use of the surrounding screening vegetation; The building provides an additional acoustic screen to the adjacent properties; It enables all waste handling and storage to be within the WTS building; and It enables a viable traffic management regime to be implemented within the Site The London Road East site has had to undergo a number of design changes and site traffic management solutions in order to get to this second planning application and EIA submission stage and thus, this site is considered most likely to be able to deliver the County s waste strategy in the short term to 2016 when the Greatmoor EfW commences operations A detailed design process has been undertaken for the London Road Estate WTS where alternative designs for the building and layout of the site have been considered. This design evolution is considered and documented in the Design and Access Statement.