DEVELOPMENT CONTROL AND REGULATION COMMITTEE 8 December 2017

A report by the Corporate Director Economy and Highways_____________________________________________________________________

Application No: 1/17/9014 District: Carlisle City Council

Parish: Rockcliffe Parish Council

Applicant: Mr Neil Wells - Green Team Partnership8Roe HouseStocksfield StocksfieldReceived: 21 September 2017

PROPOSAL: Erection of a building to house a wood waste boiler and associated walking floor at a waste management site, including the installation of a wood waste boiler and standalone drying unit.

LOCATION: North West Recycling, Unit B & K, Rockcliffe Industrial Estate, Kingmoor Park, Carlisle, CA6 4RW

_____________________________________________________________________

1.0 RECOMMENDATION

1.1 That planning permission is Granted subject to the conditions set out in Appendix 1 to this report.

2.0 THE PROPOSAL

2.1 Planning permission is sought to erect a building to house a waste wood fired boiler and to install a drying plant next to Unit B, Rockcliffe Estate. Heat from the boiler would be used in the drying plant as part of the production of Solid Recovered Fuel (SRF) or Refuse Derived Fuel (RDF) in Unit B.

2.2 North West Recycling Limited (NWRL) is a large independent skip hire and waste management company. Their centre of operations is Unit A Rockcliffe Estate and planning permission was granted in February 2016 for the change of use of Unit B and Site K from B2/ B8 to waste management purposes. There have been notable improvements in operations and compliance over recent years and an application to regularise a number of operational changes at Unit A was approved under delegated powers on 18 July 2017.

2.3 Residual waste from sorting and separation operations in Unit A will be taken to Unit B and further processed into SRF and RDF. The difference between SRF and RDF is that SRF meets a European standard for calorific value (CEN/TC 343) and is therefore more valuable. Part of the production process includes reducing the moisture content of the waste. An enclosed conveyor system will take the material from unit B through the dryer unit before returning it into the building. The finished product will then be baled or otherwise packaged according to the customer’s needs. Processing this waste to produce SRF will result in residual waste from NWRL being diverted from landfill and as such being raised up the waste hierarchy.

2.4 The boiler would be installed in a profiled sheet clad, portal framed building 31m x 16m x 12.5m to the ridge. The flue would be offset from the ridge and protrude to 13m. The boiler would have a nominal 5MW capacity and would be fired using around 9000 tonnes of grade A, B & C waste wood per year. These grades are defined by the Wood Recyclers Association and are grade A, “Clean” wood; grade B, “Industrial feedstock”; grade C, “Fuel” grade and grade D, “Hazardous waste”. This wood is generated by NWRL’s existing waste management activities. None of the SRF or RDF would be used to fuel the boiler.

2.5 The drying plant is a mixture of aluminium and galvanised steel and looks like the sort of plant/ machinery that could be found adjacent to any industrial building. Although it would have a number of short wide flues, emissions would generally not be visible as it is just warm air and evaporated water (not steam). The flues contain an odour filtration system and can accommodate additional filtration systems if required.

2.6 Although the application is for the benefit of NWRL, the application is made by Green Team Partnership as they are a Micro-Generation Certification Scheme (MCS) accredited installer of renewable energy technologies.

3.0 SITE DESCRIPTION

3.1 The application site is located on Rockcliffe Estate, Kingmoor, Carlisle. The site was formerly part of RAF Carlisle and the 14th Maintenance Unit (14MU). 14MU

consisted of various industrial type buildings used for the storage and maintenance of equipment and associated office / administration buildings across a number of sites to the north of Carlisle. After the closure of 14MU, Carlisle City Council granted planning permission for general industrial (B2) and storage & distribution (B8) uses across the sites.

3.2 The Rockcliffe Estate now has a mix of uses including both industrial and office based businesses and includes two other waste management operations. Northwest Recycling operates from 3 linked areas of the estate, units A & B and site K. The company’s head office and staff parking area are also on the estate.

3.3 The proposed boiler building and dryer would be sited along the northern elevation of Unit B, which is at the furthest end of the site from the highway. They would be on an area that is partially existing hardstanding and partially rough grassy ground. Unit B itself is an older style of industrial building measuring 65m wide x 90m long x 8.3m high. It is constructed partially of brick and clad in cement bonded fibre sheets. The cladding is in a variable state of repair. The roof comprises five parallel monitor style clerestory roofs.

3.4 The nearest properties to the south of the proposed development are Bank End Farm 220m and Holme View 480m away. To the north lies Crookdyke, a farm 410m away and Moss View and Meldrun House which are about 500m away. The sign welcoming drivers to Rockcliffe village is 790m to the north west.

4.0 SITE PLANNING HISTORY

4.1 NWRL acquired Unit A in 2009 to relocate their business from a site in Brampton. Planning permission (reference 1/09/9002) was granted in March 2009 for the change of use to use as a Materials Recycling Facility. The business has continued to expand and in February 2016 a partly retrospective planning permission (reference 1/15/9006) was granted for the use of Unit B and Site K for waste management purposes.

4.2 Minor applications have been made to vary conditions and drawings to reflect changes to the working practices at the site, the most recent being granted in July 2017.

5.0 PLANNING POLICY

5.1 Section 38(6) of the Planning & Compulsory Purchase Act 2004 provides that planning applications must be determined in accordance with the development plan unless material considerations indicate otherwise. Government policy is a material consideration that must be given appropriate weight in the decision making process.

5.2 The Cumbria Minerals and Waste Local Plan 2015-2030 (CMWLP) was examined by an independent Inspector and her final Report to the County Council was received on 29 June 2017; this report set out those changes necessary to ensure that the Local Plan is sound and legally compliant. The County Council formally adopted the Local Plan on 6 September 2017 and this replaced the Cumbria Minerals & Waste Development Framework, which was adopted in 2009. The key policies relevant to the determination of this planning application are considered to be:

Policy SP1 - Presumption in Favour of Sustainable Development

Policy SP13 - Climate Change Mitigation and Adaptation Policy SP14 - Economic Benefit Policy DC1 - Traffic and Transport Policy DC2 - General Criteria Policy DC3 - Noise Policy DC5 - Dust Policy DC6 - Cumulative Environmental Impacts Policy DC7 - Energy from Waste Policy DC8 - Renewable Energy Use and Carbon Reduction on Existing

Minerals and Waste Sites Policy DC9 - Criteria for Waste Management Facilities Policy DC17 - Historic Environment Policy DC18 - Landscape and Visual Impact Policy DC19 - Flood Risk Policy DC20 - The Water Environment

5.3 The Carlisle District Local Plan 2015-2030 (CDLP) - adopted 8 November 2016.

Policy SP1 – Sustainable Development Policy SP6 – Securing Good Design Policy SP7 – Valuing our Heritage and Cultural Identity Policy EC2 – Primary Employment Areas Policy IP2 – Transport and Development Policy CC1 – Renewable Energy Policy CC5 – Surface Water Management and Sustainable Drainage

Systems Policy CM5 – Environmental and Amenity Protection Policy HE1 – Hadrian’s Wall World Heritage Site

5.4 The National Planning Policy Framework [NPPF], which was published on 27 March 2012, and the national online Planning Practice Guidance (PPG) suite, which was launched in March 2014, are material considerations in the determination of planning applications.

5.5 The National Planning Policy for Waste (NPPW) was published on 16 October 2014. This sets out the government’s current waste policy to be taken into account by waste planning authorities and forms part of the national waste management plan for the UK. This has also been taken into account.

6.0 CONSULTATIONS AND REPRESENTATIONS

6.1 Carlisle City Council Planning Department: No objections. They comment that the site is within the Hadrian's Wall World Heritage Site Buffer Zone and the views of the Cumbria County Council's Historic Environment Officer should be sought. They also comment that the proposed extension will be located approximately 200 metres south east of the nearest property known as 'Bankend'. This Authority raises no objection to the development subject to no adverse comments from Environmental Services with regard to noise impacts and air emissions

6.2 Rockcliffe Parish Council: Object to the development. The Parish Council alleges that that NWRL have been subject to numerous complaints and that conditions are regularly breached. They object on the grounds:

That the application is for a 24 hour a day operation, which the rest of the site does not have permission for.

The proposal is not for the benefit of the people of Cumbria as only 34% of the waste originates in the County and that the residents of Rockcliffe are disproportionately impacted by traffic, vermin, smells and rubbish

The proposal contradicts emerging planning policy and existing operating hours at the Rockcliffe Estate

The proposal is on the Rockcliffe side of the building so the village would not be screened from noise and fumes. There are no details of the shredding / grinding plant to manage the wood waste.

The proposal should be on the south side of the building so that it can act as a barrier to aid the reduction of noise and fumes from the process.

The proposal should incorporate 8 specified measures to reduce noise.

6.3 The Highway Authority: On the basis that the application will not generate any additional traffic during operation have no objection. They have requested a construction management plan and agreed that this can be conditioned.

6.4 The Lead Local Flood Authority: requested more information in relation to surface-water management. The applicant supplied a copy of the surface-water management plan prepared by NWRL showing the approved sustainable urban drainage system for the whole of the NWRL operations. The LLFA have confirmed that they consider this to be satisfactory.

6.5 Carlisle City Council Environmental Health Department: No objections although recommend conditions in relation to land contamination; noise; construction management; air quality monitoring and odour management.

6.6 CCC Historic Environment Officer: No objections

6.7 Cumbria Fire and Rescue: No objections, although recommend that the applicant considers installing a sprinkler or other automatic fire suppression system. The applicant has confirmed that North West Recycling is in the process of installing an environmentally friendly foam based fire suppression system specifically designed for waste sites in to Unit B and will extend this into the new building.

6.8 Cumbria Constabulary: Does not foresee the business activity taking place at this site to pose a particular crime risk, although suggests that it would be prudent for the applicant to implement a number of security measures. As these are of a general nature and not directly relevant to this specific development, they have been passed on to North West Recycling.

6.9 The Environment Agency note the previous use of the proposed development site as a former Ministry of Defence site presents a medium risk of contamination that could be mobilised during construction to pollute controlled waters and recommend a condition to address this concern.

6.10 The application has been advertised in the local press and by site notice on the site. Neighbouring properties and the local county councillor were also notified.

6.11 Councillor Trevor Allison, in whose electoral division, the application partly lies, commented that he welcomed the creation of jobs and increased security of existing jobs. He also noted that the Planning Statement, Design and Access

Statement and Air Quality Impact Assessment are comprehensive and detailed. He also notes that the application represents a significant reduction in the amount of waste going to landfill. In light of this he fully supports the application.

6.12 One representation has been received. This relates to the impact of transport on cottages at Cargo and the potential for this development to increase the throughput of waste material at the site.

7.0 PLANNING ASSESSMENT

7.1 I consider the main issues with this proposal to be the potential impact on local amenity, economic benefit, the use of low carbon technology, and transport.

WOULD THERE BE HARMFUL IMPACTS ON AMENITY?

7.2 The Parish Council’s response raises concerns about the potential impact on amenity and alleged poor record of compliance of NWRL. Contrary to their response, there is not a significant record of complaints about the site, with only two being received this year. The first related to working over the Easter Bank Holidays and the second to a wagon driving through the village in May. With respect to the working on Bank Holidays the company was reminded that this was not permitted and they claimed that it was a misunderstanding. No complaints have been received over the subsequent Bank Holidays in May and August. The wagon driver claimed to be lost and was not a NWRL employee. Looking further back, following fitting trackers to all company vehicles more than two years ago, no complaints about NWRL skip wagons going through the village have been recorded. NWRL also provide all new customers and (sub-) contract drivers with “Site Instructions”. These request that all vehicles approach from the south and explicitly state that NWRL has a no entry policy for Rockcliffe (except when dropping or collecting a skip in the village) which they expect drivers to respect.

7.3 The Parish Council’s response does not appear to acknowledge that this proposal would manage waste that is already brought to NWRL to be processed. There are currently no restrictions on the machinery used to process waste on the existing permissions and there is no evidence that there is a need to do so. The actual source of waste delivered to the site is a commercial matter and cannot lawfully be subject to planning control.

7.4 MWLP Policy DC2 sets out general criteria for minerals and waste developments. The policy requires proposals to demonstrate that: relevant assessments (relating to amenity) have been carried out; there would be no significant adverse impact on local air quality; public rights of way and the overall carbon footprint of the development has been minimised. The policy also lists considerations necessary for minerals and waste development. Those relevant to the development include:- proximity of sensitive receptors, management of residual waste; the extent to which adverse impacts can be controlled; the use of appropriate equipment; hours of operation and traffic. The proposal fits well with these criteria. There are no footpaths affected by the proposal and it would reduce the overall carbon footprint both of the rest of the waste management facility and potentially that of the end users of the SRF/RDF produced. The boiler unit was specifically chosen to burn the particular grades of waste wood to meet stringent emissions targets. Ash would be disposed of to landfill. Carlisle City Council Environmental Health has indicated that they are content with the air quality study provided. Operationally, the proposal would not generate additional

traffic and it is screened from the nearest residential property by the existing building. Furthermore, operationally, the majority of the NWRL site is managed through an environmental permit regulated by the EA.

7.5 Carlisle City Council Environmental Health are the permitting authority for the boiler unit but not the dryer and have requested that a condition is included requiring emissions monitoring from the boiler’s flue to demonstrate compliance with the Air Quality Assessment provided with the application. Coupled with the concerns of the Parish Council, I think that this is not unreasonable and would comply with CDLP policy SP6. They have also requested that a condition requiring an odour management plan be included. However, this aspect of the development is primarily controlled by the EA and it would be inappropriate to duplicate regulation.

7.6 MWLP Policy DC3 relates to noise. There are no existing specified noise limits relating to operations on the industrial estate. It is not expected that this development would increase noise from the site as the boiler would be in a building and the dryer is a belt driven system. The exhaust air fans will be located between the dryer unit and the building. On this side of the Unit B the nearest residential building is Crookdyke Farm approximately 450m to the north. The Parish Council suggest that the boiler and dryer would be better located on the south side of the building so that it would provide better noise screening to the village. This would bring the proposed development 70m closer to the nearest neighbour (Bank End Farm) which is 200m away and ignores the significant screening provided by Unit D of Rockcliffe Estate, occupied by Reiver Lodges. The specific measures suggested by the Parish Council, which include acoustic cladding of the building, increasing the size to reduce vehicle movements and siting shredding plant in a sound proof container are in my opinion disproportionate and unreasonable considering what can already be lawfully carried out elsewhere on the site.

7.7 MWLP policy DC5 relates to dust. This proposal complies with this policy as any dusty materials (such as wood fuel, ash and the drying waste are fully contained within the building or the dryer unit. I therefore consider that dust is unlikely to be an issue from this proposal.

7.8 The City Council raised an issue about the proximity of the Hadrian’s Wall World Heritage Site (WHS). CDLP policies SP7 & HE1 provide the policy context for considering development in this area. The site is approximately 2.5km from the WHS and falls within the visual impact zone. However, in the context of the existing industrial estate, the proposed development would not be seen from the WHS and would not result in harm or loss of, the Outstanding Universal Value of the WHS, thus complies with CDLP HE1. There is no known archeologically value at the Rockcliffe Estate and the Historic Environment Officer is satisfied that there is no issue. On this basis, I am satisfied that the proposal does not conflict with MWLP policy DC17 or CDLP policy SP7.

7.9 MWLP policy DC6 and CDLP policy CM5 requires the cumulative environmental impacts of developments on amenity to be assessed. In this case as noted above the environmental aspects have been considered and I consider them to be acceptable or manageable by condition. Impacts on transport and on the wider economy are positive. In the context of existing activities that already have permission on Rockcliffe Estate, the impact of processing plant on local amenity in my opinion is likely to be neutral or slightly negative, but certainly not sufficient

to warrant refusing the application.

7.10 The proposal is in Flood Zone 1 and the wider NWRL site has a surface water management plan with a sustainable urban drainage system for managing water. The proposal will result in a minor increase in runoff. The Lead Local Flood Authority is content that sustainable drainage systems are provided. As a consequence there is no conflict with CDLP policy CC5 or CMLP policy DC20

7.11 Finally, MWLP policy DC9 provides criteria for waste management facilities. In this case, the proposal is of a type suitable for an industrial estate and no unacceptable impacts beyond those already permitted on the industrial estate have been identified. However to ensure that this remains the case, I have proposed a condition that requires a complaints investigation scheme to be submitted for approval. This will serve as a catch all for any aspect of the development that does prove to cause a nuisance and will require the operator to propose remedial work to address any problems should they occur.

ECONOMIC BENEFIT

7.12 The proposal would bring economic benefits both to the operator and the wider economy. This would be both in creating and sustaining jobs at NWRL and also in providing SRF /RDF. As noted in the text of the CMWLP, alternative fuels have the potential to reduce energy costs for energy intensive industry or to promote the development of new power generating infrastructure. I consider the creation of new jobs alongside safeguarding of existing jobs at NWLR and the potential to support other industries means that the proposal complies with MWLP policy SP14.

7.13 The site lies within a primary employment area in Carlisle City Council’s Local Plan and thus accords with CDLP policy EC2.

LOW CARBON TECHNOLOGY

7.14 The Proposal is strongly supported by MWLP policy SP13 – Climate change mitigation and adaption and CDLP policy CC1. This is because biomass (wood) is classed as a low carbon technology.

7.15 MWLP policy DC7 relates to energy from waste and DC8 relates to the use of renewable energy and carbon reduction. The use of grade A & B waste wood as fuel is not entirely compatible with DC7 as it misses an opportunity to recycle wood into animal bedding (grade A) or composite products such as chipboard and fibre board (grade B), thus moving waste up the hierarchy. I note that the proposal clearly meets two of the other criteria of DC7 which are the reduction in greenhouse gas emissions compared to feasible alternatives (in this case, a fossil fuel fired dryer) and provision of appropriate storage facilities (within the building). Whilst there is no information to demonstrate that the design maximises opportunities for waste heat utilisation, I understand that NWRL are considering further development using waste heat when money allows.

7.16 However, as (waste) wood biomass is a low carbon / carbon neutral fuel, the proposal is supported by MWLP Policy DC8 which relates to renewable energy and carbon reduction. This policy indicates that applications for low carbon energy installations at existing waste sites will be supported.

7.17 On balance I consider that the policy support for the use of low carbon

technology, significantly outweighs the missed opportunity to manage waste wood higher up the waste hierarchy.

WOULD THE DEVELOPMENT HAVE AN ADVERSE IMPACT ON THE LOCAL HIGHWAY NETWORK?

7.18 The representation received from a resident of Cargo complaints about waste being dropped from passing wagons and the potential for this development to increase traffic. Rockcliffe Parish Council makes a similar point.

7.19 With respect to the first point of the representation (impact of transport on Cargo), there is an existing requirement for all loads of material leaving the site to be sheeted or otherwise contained. I have contacted the representee to explain how to complain so that we can investigate problems when they occur.

7.20 The second point is more arguable. Although the boiler does not create additional traffic beyond that required to construct it and additional staff to operate it, nor does it directly increase the capacity of the business to accept more waste, it may allow the business to grow in the future. However, there are existing limits on the number of vehicle movements on the principal permissions for unit A and Unit B / Site K.

7.21 The wood that would be used to fire the boiler is already separated from the waste delivered to the site. Using this waste stream directly on site would result in a modest reduction of around 450 loads of material leaving the site per year. Similarly, the use of heat from the boiler to dry waste to produce SRF will result in a less easily quantified decrease in the number of loads of material leaving the site. The location on an existing waste site and using waste wood as fuel reduces “waste road miles”. This reduction means that the proposal complies with MWLP Policy DC1 and bullet 6 (which relates to the impact of HGV’s) of CDLP policy IP2

7.22 I am satisfied that with respect to transport there are already adequate controls in place to control traffic associated with the operation of the site.

SUSTAINABLE DEVELOPMENT

7.23 The NPPF, CWMLP policy SP1 and CDLP policy SP1 require sustainable development to be approved without delay. In this case there is significant policy support for the development. Whilst arguably, there is some uncertainty about the impact on residential amenity of the proposal, no other material considerations have been raised that suggest that the proposal is not sustainable development.

Human Rights

7.24 The proposal will have a limited impact on the residential and environmental amenity of the area. Any impacts on the rights of local property owners to a private and family life and peaceful enjoyment of their possessions (Article 8 and Article 1 of Protocol 1 of the Human Rights Act 1998) are minimal and proportionate to the wider social and economic interests of the community.

8.0 CONCLUSION

8.1 Although it is possible that the development could increase nuisance from the

site, this can be addressed by condition. Furthermore, day to day activity at the site and environmental emissions are permitted by the Environment Agency.

8.2 In summary, I believe that the proposed development is in accordance with the development plan. There are no material considerations that indicate the decision should be made otherwise and with the planning conditions proposed, any potential harm would reasonably by mitigated. I therefore recommend that this application be granted subject to conditions.

Dominic DonniniCorporate Director Economy and Highways

Contact: Mr David Hughes, Kendal, Tel: 01539 713422; Email: david.hughes@cumbria.gov.uk

Background Papers: Planning Application File Reference No. 1/17/9014

Electoral Division Identification: Longtown ED - Mrs Val Tarbitt

Dalston & Burgh ED – Trevor Allison

Appendix 1Ref No. 1/17/9014

Development Control and Regulation Committee - 8 December 2017

PROPOSED PLANNING CONDITIONS

Time Limit for Implementation of Permission1. The development hereby permitted shall be begun before the expiration of three

years from the date of this permission.

Reason: To comply with Section 91 of the Town and Country Planning Act 1990 as amended by Section 51 of the Planning and Compulsory Purchase Act 2004.

Approved Scheme

2. The development hereby permitted shall be carried out in accordance with the following:

a. The submitted Application Form – dated 21/9/17 b. Planning Statement – GTP01 dated: 15/9/17c. Design and Access Statement – GTP02 dated: 15/9/17d. Air Quality Assessment – GTP03 dated:15/9/17e. Plans numbered and named:

i) Proposed Site Plan. DWG No. 003 dated 1/9/17ii) Proposed Elevations. DWG No. 004 dated 1/9/17iii) Proposed Extension Layout Plan. DWG No.005 1/9/17

f. The details or schemes approved in accordance with the conditions attached to this permission.

Reason: To ensure the development is carried out to an approved appropriate standard and to avoid confusion as to what comprises the approved scheme.

INVESTIGATION OF COMPLAINTS3. Prior to the commissioning of the boiler, a scheme for the investigation of

complaints shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall include:

A procedure for recording and investigating complaints whether received directly from a member of the public or via a Local Authority. This shall propose timescales for carrying out investigations and reporting back to the complainant and/ or Local Planning Authority.

Provision for written reports to be submitted to the Local Planning Authority following complaint investigation. In the case of a noise complaint, unless a specific problem/ occurrence can be identified and remedied, this will include the use of an independent consultant, to assess the level of noise emissions from the facility at the complainant’s property. This should be carried out in accordance with the most appropriate current standard (such as BS4142:2014).

Where a complaint is justified; provision for remedial actions and a timescale for implementation to be agreed in writing by the Local Planning Authority

When approved, the scheme shall be implemented in full.

Reason: To safeguard the amenity of local residents by ensuring that the development hereby permitted does not cause a nuisance, in accordance with Policy DC 2 of the MWLP

4. Prior to the commissioning of the boiler, a scheme to demonstrate that emissions from the plant do not exceed the levels set out in the Air Quality Assessment shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall include:

A methodology for assessing stack emissions The frequency of testing Submission of reports of testing Provision for the development of an action plan to reduce emission to an

acceptable level should emissions exceed those set out in the Air Quality Assessment

Provision for any action plan to be implemented on an agreed timescale.When approved, the scheme shall be implemented in full.

Reason: To ensure that the proposal would not have an adverse impact on the living conditions of the occupiers of neighbouring properties, in accordance with Policy DC2 of MWLP & Policy SP6 of the CDLP.

5. No development shall take place until a Construction Management Plan has been submitted to and approved in writing by the Local Planning Authority. The scheme shall include and set out:

Construction traffic management plan Construction Hours Material storage / handling plan Use of plant and machinery fitted with white noise type reversing alarms

When approved, the scheme shall be implemented in full for the duration of construction works.

Reason: To ensure that the construction does not have an adverse impact on the living conditions of the occupiers of neighbouring properties.

6. No development shall take place until a remediation strategy to deal with the risks associated with contamination of the site has been submitted to and approved in writing by the Local Planning Authority. The strategy shall include:

1. A preliminary risk assessment which has identified: all previous uses; potential contaminants associated with those uses; a conceptual model of the site indicating sources, pathways and

receptors and; potentially unacceptable risks arising from contamination at the

site.2. A site investigation scheme, based on (1) to provide information for a

detailed assessment of the risk to all receptors that may be affected, including those off site. Site investigations should follow the guidance in

BS10175.3. The results of the site investigation and the detailed risk assessment

referred to in (2) and, based on these, an options appraisal and remediation strategy giving full details of the remediation measures required and how they are to be undertaken.

4. A verification plan providing details of the data that will be collected in order to demonstrate that the works set out in the remediation strategy in (3) are complete and identifying any requirements for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action.

When approved, the scheme shall be implemented in full.

Reason: To ensure that the development is not put at unacceptable risk from, or adversely affected by, unacceptable levels of water pollution in line with paragraph 109 of the National Planning Policy Framework.