ERECTION OF WASTE RECEPTION HALL AND AMENDED HOURS OF OPERATION

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1 07/00051/MIN And 07/00052/MIN ERECTION OF WASTE RECEPTION HALL AND AMENDED HOURS OF OPERATION VARIATION OF END DATE FOR THE IMPORTATION OF WASTE MATERIALS AT Bletchley Landfill Site, Bletchley Road, Newton Longville FOR Waste Recycling Group Limited 07/00051/MIN AND 07/00052/MIN THE APPLICATIONS Permission is sought for a Waste Reception Hall at Bletchley Landfill Site. This would be a building 90m long by 67.5m wide by 11m high. It would be situated at the Waste Reception Area at the eastern end of Bletchley Landfill Site which was granted permission in 2002 together with the recontouring of the site. The purpose of the building would be to allow waste to be imported from 04.30am, deposited into the building and then removed to be taken to the Landfill Site when it opens at 07.00am. This would enable waste from London, currently tipped in Bedfordshire, to be tipped at the Bletchley site when the applicants site in Bedfordshire reaches capacity next year. The building would have ancillary buildings and works associated with it which would include offices, a workshop, amenity building, weighbridge, wheel washes and parking. The development would be screened to the north and south by existing tree belts. The second application is to extend the life of the site. The current planning application for the Landfill Site extends for a further fifteen years until The applicants state that if they are unable to bring sufficient waste daily into the site, then it will not be possible to complete the site by this time. Therefore, if planning permission for the Waste Reception Hall is not granted then it will be necessary to extend the duration of the tipping operation until 2029 to complete the site in accordance with the existing planning permission. INFORMATION SUBMITTED IN SUPPORT OF THE APPLICATIONS In support of the application for the Waste Reception Hall the applicants state that during the period when the landfill application was being considered it was evident that the site could only be filled by 2022 if there was a substantial increase in waste inputs. The solution to this was seen as transferring waste imports from the Brogborough Landfill Site in Bedfordshire which is scheduled to reach completion in The applicants claim that the provision of a Waste Reception Hall is the third of the preparatory steps toward bringing about the

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3 completion of the Bletchley landfill site by The first two steps were the provision of a significant contribution to the A4146 Stoke Hammond by-pass and the construction of a new access road to the landfill site from this. The applicants also consider that the Waste Reception Hall would bring additional benefits.they detail these benefits as being:- (a) Waste deposits at the Landfill Site will cease by February 2022 which otherwise would not be completed until 2029 or 2056 at the current rates of fill. (b) It will bring about the closure of the existing access from the C9 Bletchley Road to the benefit of local residents. (c) The development will help to bring forward the additional landfill capacity required to meet the impending shortages (in the London area) and the problems of continuing exports to adjoining regions as recognised in the Draft South East Plan and the Regional Waste Strategy. (d) It will bring forward the additional landfill capacity which will be required as a consequence of the growth planned in the Milton Keynes and South Midlands Sub-Regional Strategy. (e) It would help to continue to meet London's waste disposal needs. (f) The development would help to husband scarce non-inert landfill capacity in continuing to ensure that the capacity remains available until If not the site would be only partially filled. (g) Without the Reception Hall, it would not be possible to backfill the southern section of the site within a timetable compatible with the development programme for Newton Leys. In further support of the application, the applicants refer to a number of Regional Planning Policies and Waste Strategies. These are:- (a) The South-East Region Waste Management Strategy which recognises a continuing need for additional landfill capacity including the residues of recovery processes. The Strategy also notes that London is not capable of being selfsufficient in terms of the disposal of residues of non-inert waste and therefore the South East will play a continuing role. (b) The Regional Self-Sufficiency and Assessment of Regional Waste Movement Report of 2004 concluded that London will experience a significant landfill capacity gap because the East of England Regional Assembly and the South East of England Regional Assembly are set to restrict imports to treated waste only. If full advantage is taken of the available landfill to provide for the disposal

4 of waste exported from London, the South East can meet 50% of London's forecasted requirements for every year. (c) Early alterations to the London Plan points out that 40% of 17m tonnes of waste produced in London annually is exported for treatment or disposal. The aim is to ensure that facilities are in place to enable London to manage 75% of its waste by 2010, 80% by 2015 and 85% by (d) East of England Waste Management Strategy points out that:- 1) the requirement for landfilling capacity for waste from the South East will fall from 5.7 million tonnes in 2000 to 2.7 million tonnes by In 2001 the Bedfordshire and Luton landfill capacity was 9.06 million cubic metres but the planning permission life for this stands at only 2.7 years. 2) Capacity for non-inert waste disposal stands at only 3.8 million cubic metres. 3) The landfill sites in the Marston Vale have played a major role in the disposal of waste in the Greater London region. 4) Waste arisings in Bedfordshire and Luton average 3% growth and 90% of the municipal solid waste was landfilled. (e) Apportionment of Waste Capacity needs in East of England 2005 states:- 1) Bedfordshire and Luton in the worst case will need capacity for million tonnes in 2010/11, million tonnes in 2015/16 and million tonnes in 2020/21. 2) Additional landfill capacity to deal with regional and London's waste in Bedfordshire and Luton will be (at least) million tonnes in 2010/11, million tonnes in 2015/16 and million tonnes in 2020/21. (f) The Bedfordshire and Luton Minerals Local Plan concludes that there is a projected shortfall of million cubic metres of void space required during the period until (g) Regional Waste Strategy for the East Midlands concludes that the landfill capacity for the disposal of biodegradable waste is expected to be exhausted by 2009 and there will be no capacity within Northamptonshire by (h) The Milton Keynes and South Midlands Sub-Regional Strategy estimates that additional waste arisings, because of the expansion of towns including Milton Keynes, will be 320,000 tonnes per annum.

5 THE ENVIRONMENTAL STATEMENT The application for the Waste Reception Hall was accompanied by an Environmental Statement. This Statement details the findings of a number of studies carried out on behalf of the applicants of the potential environmental effects. For ease of reference the conclusions of the Environmental Statement are detailed under the environmental effects as listed:- Noise (a) Operation of the Waste Reception Hall during the daytime ( ) hours does not have a significant impact on baseline daytime noise. (b) There would be a moderate impact on Skew Bridge Villa and the proposed travellers site within the Newton Leys development between and 07.00am. Noise at all other receptors during this time is negligible. (c) Mitigation measures proposed in the vicinity of the effected properties will reduce noise levels between 04.30am and 07.00am to minor or negligible levels. Traffic The extra hours will reduce the amount of traffic at peak hours. Odour The development could result in an increase in the level of odour experienced at Garry Close, Doon Way and the proposed Newton Leys development. However, it is not predicted that this increase will exceed assessment criteria for odour annoyance. It is unlikely therefore that residents would experience an increase in odour impacts. Landscape There would be minimal to light adverse landscape effects. The scale and proximity of the proposed building could bring about a moderate impact on the adjacent woodland. A buffer zone would, therefore, be adopted to reduce this to a negligible impact. The Newton Leys development would substantially limit views toward the site. Drainage A balancing pond would be provided to alleviate surface water run-off. There would be no change to the existing water management and drainage system.

6 Ecology and Archaeology There would be no additional ecological or archaeological impacts as the development is within a consented development area. PLANNING POLICY National Policy Mineral Planning Statement 2 (which also applies to landfill sites) states that the impact of sites should be kept to an acceptable minimum. Where adverse environmental effects cannot be adequately controlled or mitigated through the design of proposals or the attachment of conditions, planning permission should be refused. The MPS also states that Mineral (and Waste) Planning Authorities should also ensure that planning conditions are enforceable, being precise and capable of being monitored. Regional Policy Regional planning guidance for the South East RPG 9 has specific chapters relating to waste. Policy W3 states that waste authorities should provide management capacity equivalent to the amount of waste arising within the region's boundaries plus a declining amount of waste from London. Provision for London's exports will usually be limited to landfill in line with the Landfill Directive targets and by 2016, new permissions will only provide for the residues of waste from London that have been subject to recycling or other recovery process. Policy W4 requires waste planning authorities to aim for self-sufficiency and where consistent with W31 capacity should also provide for waste from London and adjoining sub regions. Policies W5 and W6 relate to the targets for diversion from landfill and recycling and compost targets. It is anticipated that by % of waste will have been diverted from landfill and 65% will have been recycled or composted. Policy W7 anticipates Milton Keynes waste amounts which marginally increase every five years reaching 230,000 tonnes of waste per annum by This amount, however, is considerably below that which is already imported annually to the Bletchley site.

7 Policy W13 requires the husbanding of non-inert landfill capacity to provide for the disposal of residual non-inert waste. The South East Plan also has policies specific to waste management. Policy W13 anticipates Milton Keynes dealing with a larger proportion of the South East region's waste amounting to 1.6 million tonnes between 2006 and 2015 and 1 million tonnes between 2016 and Again, however Bletchley Landfill Site already deals with waste in excess of these figures. Policy W4 requires waste planning authorities to become self-sufficient but providing some capacity of waste for London and waste from adjoining subregions. Local Policy The Waste Local Plan for Buckinghamshire currently remains the policy document for waste planning in Milton Keynes. Policy WLP1 seeks to ensure progressive restoration of sites. Policy WLP2 seeks to husband void space for the deposit of residues after recycling. Policy WLP20 requires the effects of development on the environment to be taken into account. The emerging Waste Development Plan Document has similar policies and proposals but reflecting the need for waste to disposed of as close as possible to its source. Policy WA2 of the emerging plan seeks the safeguarding of existing and allocated sites for the disposal of the residues of wastes which have been through recycling and recovery processes. Milton Keynes Local Plan Policy D1 states that planning permission will be refused for development which would generate additional traffic causing undue disturbance and noise, would be an unacceptable visual intrusion and generate unacceptable noise or smell. CONSULTATIONS The South East England Regional Assembly initially responded to the Council's consultation to advise that it was considered that the proposal does materially conflict with or prejudice the implementation of the Regional Spatial Strategy (RPG9 and Alterations and the Draft South East Plan). The Assembly also considered that the Council should be satisfied that the proposals would contribute to meeting its sub-regional self-sufficiency waste management requirements, that it would not adversely affect its landfill capacity requirements so as not to compromise Regional Policy objectives, and that the Transport Assessment had been properly conducted.

8 A further letter from the Assembly advises that waste moving across regional and sub-regional boundaries is also an issue. Regional and sub-regional net selfsufficiency are key aims of RPG9. The Assembly also stated that as the proposal will result in an increased rate of fill without additional treatment to recover materials or recover value from the waste stream, it could be regarded as being inconsistent with the objective of Policy W13 relating to the husbanding of landfill void space. The Environmental Health Officer considers that the bunding adjacent to the access road will mitigate noise sufficiently so that traffic noise will not cause a nuisance to nearby residential property. As a result of the distance of the proposed waste reception hall from sensitive properties, the effect of the development will not be significant. The Highway Engineer has no objection to the proposals. The Countryside and Landscape Manager has concerns about the effects of the proposed waste reception hall on surrounding land, in particular, the Blue Lagoon Country Park. It is considered that the development would have a detrimental impact because of its appearance and the potential noise, dust and odour that it would generate. This could effect plants and animals within the Blue Lagoon and be detrimental to visitor experience. The Environment Agency has no objection subject to appropriate conditions being attached to any grant of planning permission.morning. The Buckingham and River Ouzel Internal Drainage Board require conditions on any planning permission requiring the adequate storm water design and construction proposals. The Bletchley Park Residents Association considers that (1) the proximity principle should be adhered to and other areas should recycle their waste (20the increase in vehicle numbers will add to the congestion on local roads (3) long distance traffic will add to pollution and global warming (4) operations commencing at 4.30 a.m.would make life intolreable for local residents (5) it is innappropriate to locate a large waste handling building close to exisitng and proposed residential areas (6) the proposal to extend the life of the site should be refused Newton Longville Parish Council object to the proposal as a 4.30 a.m. start time would be unfair to local residents. If permission was granted to either of the two proposals, the Parish Council considers that conditions should include (1) access from the Skew Bridge Roundabout (2) closure of the Bletchley Road access (3) waste HGV's to travel only on the A road network (4) no waste vehicles should travel through residential areas (5) operational hours should remain as they are.

9 Dr Phyllis Starkey MP objects strongly to the proposal to extendthe operational hours as it is not acceptable for the level and traffic and noise associated with the waste disposal operations to be permitted so early in the morning. REPRESENTATIONS 334 letters have been received objecting to both proposals on the following grounds:- 1) Importing waste from London would not accord with the proximity principle determined in national, regional and local waste strategies and policies. 2) A 4.30am start would cause disturbance to local residents. 3) The extended operations would cause an increase in fumes. 4) The extended period of operation would prolong the difficulties experienced by local residents. 5) The previous appeal rejected working before 07.30am. 6) Extra vehicles will increase vibrations causing damage to the structure of nearby houses. 7) Cyclists already have difficulties on local roads. 8) Rubbish from vehicles often falls onto local roads. CONSIDERATIONS The main issues relating to the proposals are:- 1) Would the development of the Waste Reception Hall accord with policies in land use terms? 2) Would the development of the Waste Reception Hall accord with policies in terms of national, regional and local strategic waste policies? 3) Would the development of the Waste Reception Hall and proposed extension of operational hours have a detrimental effect on the interests of occupiers of neighbouring properties? 4) The effect of extending the permitted period of the landfill site. Taking each of these issues in turn:-

10 1) Local land use allocation The site of the proposed Waste Reception Hall is allocated for uses associated with waste management in the Milton Keynes Local Plan. Planning permission for a Waste Reception Area, within which it is proposed to locate the Waste Reception Hall, was granted with the recontouring of landfill site in The principle of the reception of waste vehicles at this location has, therefore, been accepted. However, it was not anticipated that this would include a building of some 5,700 square metres in extent. The Countryside and Landscape Manager has concerns about this building in terms of its visual and environmental effects on surrounding land, in particular, the Blue Lagoon Country Park. The applicants have been asked to address these concerns. The applicants have responded principally advising that as the site has been given approval in principle for development associated with the importation of waste, the new proposal should be judged in these terms.. Further assessment should be undertaken to assess what additional effects the development would have on the Blue Lagoon beyond that which has already been granted permission. It is, however, unlikely that any greater effect would be such that it could not be mitigated through additional measures required by condition. The development should not, therefore, be refused on the basis of the effects of the proposal on the land immediatelly surrounding the site. (2) National, Regional and Local Waste Planning Policies and Strategies The operational hours condition attached to the permission for the landfill site, is primarily intended to safeguard the interest of local residents. However, the operational hours constraint also has the effect of limiting the number of vehicles that can practically be brought in from some distance daily because of the time needed to bring waste to the site, dispose of it and return to the source for further loads. This is key to the acceptability of the determination of the proposal as its primary aim is to enable waste from London, currently disposed of in Bedfordshire, to be tipped at Bletchley. A disposal site at Bedfordshire currently used by the applicants for disposing of waste from London operates at similar hours to the proposed hours for the Waste Reception Hall at Bletchley but will reach its capacity next year. The applicants are, therefore, seeking to move the disposal of London's waste to the Bletchley site and the Reception Hall with a start time of 04.30am would facilitate this. The applicants suggest that the Reception Hall represents the third and final stage of developments to bring the transfer of operations about, the first two being the provision of the new road and bridge over the West Coast main line and the provision of a new access and reception area at the eastern end of the site. Whereas it has been suggested in the past that Bletchley would be used to dispose of London's waste when the Bedfordshire site had reached its full

11 capacity, there had not been any suggestion, when commitment to the landfill site and access road was given, that a Waste Reception Hall with an earlier start time was part of the overall scheme. Furthermore, when the planning applications for tipping at the current levels were originally submitted, there was no proposal for a new road. It was only because this authority, and previously Buckinghamshire County Council, stated that additional tipping was unacceptable utilising the existing access, that the previous site owners agreed to provide a new road to the site. The applicants have detailed a number of regional planning policy and guidance documents which they consider supports the extension of the operational hours via the Waste Reception Hall. In particular they refer to the South East Region Waste Management Strategy which recognises the continuing need for additional landfill capacity and that the South East will play a continuing role for the disposal of London's waste. The applicants point out that the Regional Self-Sufficiency and Regional Waste Management Report of 2004 concluded that London will experience a significant landfill capacity gap because the East of England Regional Assembly and the South East of England Regional Assembly are set to restrict imports to treated waste only. Theses restrictions will, however, have been taken into account in the production of the Regional Planning Guidance for the South East. This acknowledges that there is a continuing need for the South East to provide for the disposal of London's waste but specifies, quite clearly, that this is a declining amount. It also states that beyond 2016 provision should only be made for the disposal of treated waste. The applicant's reference to the Regional Self-Sufficiency and Regional Waste Movement Report appears to be suggesting that, notwithstanding the regional policy to constrain imports to treated waste, that permission should be granted contrary to this because of the potential shortfall in capacity that London will experience. The reference to the early alterations to the London Plan whereby London aims to manage 75% of its waste by 2010 and 85% by 2020, suggests that London is, in any event, committed to addressing its problems within the timescale of the proposal. In the circumstances the provision of the Reception Hall which will allow more untreated waste to be transported out of London to the South East Region, rather than providing for a reducing amount, is contrary the provisions of the Regional Planning Guidance. The applicants have referred to the difficulties for the East of England Region and the Bedfordshire and Luton area, in particular, because of the impending lack of void space for waste. These are detailed in the East of England Waste Management Strategy, the Apportionment of Waste Capacity Needs in the East of England and the Bedfordshire and Luton Minerals Local Plan. Whereas there will be a shortfall, none of the documents or guidance and policies relating to the South East Region suggest that the South East, or specifically Milton Keynes, should be responsible for making up the shortfall. Whereas there is inter-regional transport of waste, the expectation in policy

12 documents for both regions is that each region and the sub-regions within them should strive to provide disposal facilities equivalent to their waste arisings. Granting planning permission for a facility which discourages self-sufficiency would not accord with guidance and policies aimed at bringing this about. An appeal decision relating to the Brogborough Landfill Site in Bedfordshire, from December 2006, makes reference to the need for landfill capacity. The Inspector points out that it has been known for ten years that the Brogborough site would reach capacity in He also points out that two other sites near Bedford have a combined capacity of 32 million cubic metres. Whereas the sites are not identified for waste disposal, the Inspector concludes that they are relevant in demonstrating that the potential exists elsewhere in Bedfordshire to meet landfill needs. In the circumstances, a provision which enables more waste to be transported out of Bedfordshire, because of a perceived lack of capacity is not justified. This is particularly the case when considering the Bedfordshire policies relating to waste disposal which are predicated on Bedfordshire and surrounding authorities being self-sufficient for the purposes of waste disposal. There does not, therefore, appear to be any justification for extending the operational hours at Bletchley to facilitate the importation of waste from Bedfordshire. The same issue would relate to the situation in the East Midlands Region, and specifically Northamptonshire referred to by the applicants. Joint arrangements for waste disposal are being made with Northamptonshire and it is anticipated that some reciprocal measure will be provided within Northants. In the circumstances, the conclusions of the Regional Waste Strategy for the East Midlands suggests that it would not be appropriate to facilitate the delivery of waste from this area beyond that for which provision already exists. The Milton Keynes and South Midlands Sub Regional Strategy referred to by the applicants estimates that additional waste arisings due to the expansion of towns including Milton Keynes will be 320,000 tonnes per annum. In the circumstances, it would again be contrary to the Strategy to grant a permission which facilitates additional imports of waste from London and elsewhere. Milton Keynes, as all South East England Waste Planning Authorities, is required to make some contribution to the continuing need for the disposal of waste from London until it has in place facilities for the disposal of the majority of its own waste. Early drafts of the South East Plan did not, however, originally envisage that the Milton Keynes Sub Region would make a contribution prior to 2016 principally because of the distance from the Capital. However, a number of options have been considered by the South East Region's Technical Advisory Body for Waste. None of these envisage Milton Keynes being required to take any of London's waste before After this date the various options envisage Milton Keynes taking approximately 1,000,000 tonnes of waste between 2016 and 2025 which

13 is in the region of 115,000 tonnes per annum. The Council has objected to this change as the criteria used take less account of the distance that Milton Keynes is from London, the small geographical area that Milton Keynes has to address the greater contribution compared to other waste (County) authorities and that Milton Keynes is designated as a major extended area requiring increased capacity for waste disposal in the future. Even if Milton Keynes does not succeed in maintaining its current position in relation to how much waste it is expected to take from London, Bletchley can still accept the apportionment from the London region without the need to facilitate an increased amount by extending the operational hours. There does not, therefore, appear to be any reason to grant permission for the early landfill store contrary to existing and emerging regional and local policy. 3) Local effects of the Reception Hall The vast majority of objections that the Council has received relate to the proposed operational hours. Many consider that the commencement of operations at 4.30am will cause disturbance to adjacent residential areas. The applicants have undertaken an Environmental Assessment which concludes that, due to the distance that the Waste Reception Hall will be from residential areas, that the operation will not be perceived within these. The Environmental Health Officer agrees that the noise of the proposed operation will not be heard above background noise levels within residential properties. However, in the Brogborough Landfill Site appeal referred to earlier, the Planning Inspector had to address similar circumstances. He referred to Mineral Policy Statement 2 which also provides guidance in relation to landfill sites. This states that "planning conditions should be used to apply absolute control on noise emissions and night-time limits should not exceed 42dB (A)". The appellant's who are also the applicants in relation to the proposed Waste Reception Hall, argued that there were higher prevailing background noise levels. The Inspector, however, concluded that account should be taken of the character of the noise. Traffic in this case was heard as a background hum whilst that of the landfill site is of a more intermittent and distinctive character. He did not consider that the background noise was so high as to warrant departing from MPS2. In the Bletchley case, the applicants claim that the operations will not have such characteristics. However, it is not clear from the information provided why this conclusion has been reached. The tipping and transferring of waste will be much the same as the noise generated at a landfill site and the likelihood of bangs, thumps, clatters and scraping noises will be increased because operations will take place on a concrete floor. Whereas these activities will take place within a building, the large access doors will be open during operations. Background noise levels within the nearest residential properties to the

14 application site will be high principally because of the passing trains. However, train noise has regular sound qualities of gradually increasing and decreasing noise. Local residents will have become accustomed to this noise. Intermittent noises are, therefore, likely to cause disturbance in these circumstances. Some of the objections that the Council has received have been made on the basis that vehicles will pass through residential areas. Planning permission is, however, sought on the basis that vehicular access to the Waste Reception Hall would be gained from the east via the northern leg of the Stoke Hammond bypass. No properties would be passed by landfill vehicles approaching or leaving the site other than Skew Bridge Villa. The proposals include specific measures to address vehicle noise as they pass this property and the Environmental Health Officer has advised that these measures would reduce any risk associated with the noise of landfill vehicles to a negligible amount. In the circumstances, refusal of the application on the basis of disturbance because of vehicle noise would be difficult to sustain. 4) Effects of the extension of the life of the site The planning application to extend the life of the site to 2029 is premature. It may well be the case that the applicants currently see difficulties in completing the site without securing additional waste importation from London. However, it is more than likely that over the next fifteen years that additional contracts will be secured. The evidence that the applicants have provided in relation to Northamptonshire and Bedfordshire as well as the expansion of Milton Keynes indicates that there will be considerably more waste within relatively close proximity of the landfill site in future years. Currently, therefore, there is insufficient evidence to conclude that the life should be extended by a further seven years. Therefore, approving the application now would serve only to delay restoration of the site. If the applicants, and their predecessors to whom planning permission for the landfill site was granted, had any concerns that the site would not be completed within the approved timescale, it was open to them to have developed the new site access some years ago and to have increased the rate of fill at Bletchley. Considerable void space remains at this time. However, the planning merits of extending the life of the site can be considered much closer to the completion. In the unlikely event that considerable void space remains at the Bletchley site in fifteen years time, it is very unlikely that permission to complete the site would be refused given the lack of environmental effects brought about by importing waste during normal operational hours. In these circumstances there would not be a loss of void space as suggested by the applicants. CONCLUSIONS

15 Concerns relating to the transport of waste by lorries over considerable distances were not to the fore at the time that commitment to the landfill site was given. The primary planning objective was to complete the satisfactory restoration of sites as quickly as possible. Regional planning policies developed over the last five years, however, have emphasised the need for regions and sub-regions to deal with their own waste. This reduces the need for waste to be transported considerable distances for disposal. London is addressing its waste needs and the emerging waste planning policies reflect this. Waste planning authorities within the Southeast region are expected to take overall, a reducing amount of waste. There is no constraint from where waste, disposed of at the Bletchley site, can be imported. The operational hours constraint has, however, this effect. Planning permission for the Waste Reception Hall would remove this constraint and is not therefore appropriate. Extending the life of the site by fifteen years in advance of the approved end date being reached is premature in the light of the proposed expansion of Milton Keynes which will increase the need for void space. The absence of clear evidence that there are not sufficient sources of waste local to the landfill site would result in the restoration of the site being delayed without any clear reason for doing so. Planning permission for this should, therefore, also be refused. RECOMMENDATION That planning permission for the Waste Reception Hall and amended hours of operation is refused because:- The development proposed would not accord with the provisions of Regional Planning Guidance for the South-East which requires Waste Planning Authorities to provide management capacity for waste arisings plus a declining amount of waste from London and new permissions to be for the residues of treated waste only The development would not accord with the provision of MPS 2 which advises that landfill sites do not commence operations prior to 07.00am to protect the amenities of nearby local residents. The development would not accord with policy WA2 of the emerging Milton Keynes Waste Development Plan Document which seeks to safeguard existing and allocated sites. and That planning permission for the extension of the operational period of the landfill site is refused as there is, at this time, insufficient evidence to conclude that there will not be enough waste generated within Milton Keynes and its immediate

16 surroundings to enable the site to be completed by the date approved. Granting planning permission to extend the life of the site now would, therefore, delay unnecessarily the site restoration. Case officer Maureen Darrie Contact - MDARRIE@ADAMSHENDRY.CO.UK