4 Impacts of projects
33. The largest section in the draft NPS sets out
the generic impacts of waste water infrastructure, itemising "significant"
impacts which the IPC should consider, such as odour, flood-risk,
biodiversity, noise, landscape and visual impacts.[59]
The draft NPS states that the IPC will "wish to consider
where they determine that the impact is relevant and important
to their decision".[60]
This section also provides guidance as to how the IPC must satisfy
itself as to the acceptability of impacts or mitigating measures
it can impose. However, the draft NPS does not guarantee that
this section is fully comprehensive and states that exclusion
of a factor is not "in itself a reason for giving less weight
to that impact".[61]
34. The draft NPS does not provide guidance as to
the relative weight which should be given by decision makers to
any of the listed impacts, although the Planning Act allows for
"relative weights" to be allocated to "specified
criteria".[62] Additionally,
as many giving evidence to us noted, the draft NPS does not advise
decision makers as to how they should balance short-term impacts
with longer-term benefits. Thames Water considered that the relative
weights of short-term and long-term impacts should be set out
explicitly in the NPS.[63]
The company was also concerned that "very localised and short-term
adverse impacts" of projects should be "seen in the
broader policy context of providing essential waste water infrastructure".[64]
However, some bodies such as the GLA took the opposite view, believing
that "local impacts will be overlooked" with the draft
NPS doing little to provide re-assurance.[65]
London Councils considered that the draft NPS did not "constitute
a practical framework" as it did not include any consideration
of "local disbenefits which would normally be considered
through the planning process, such as increased traffic".[66]
However, the Minister told us that applicants would be expected
to provide the IPC with further information but the document does
not spell out exactly what this should constitute.[67]
35. We recommend that the NPS be revised to provide
clearer guidance for decision makers as to how they should balance
the relative weights of different impacts and that it set out
the criteria for making judgements on the extent to which short-term,
local impacts should be tolerated in order to deliver long-term,
wider gains.
36. The draft NPS states that the re-use of previously
developed land can reduce the amount of undeveloped greenfield
land that needs to be used but notes that this may not be possible
for some forms of infrastructure.[68]
We received evidence from community groups such as the Save King's
Stairs Gardens Action Group who noted that some of the planned
construction sites for the Thames Tunnel are on amenity sites,
such as parks near to the river. The group argued that guidance
in the NPS should be strengthened to direct decision makers to
require developers to consider brownfield sites wherever possible.
Planning law includes protection of open spaces such as public
gardens and recreation grounds.[69]
However, the draft NPS specifies that its provisions will apply
to "all open space of public value," including areas
of water.[70]
37. The wording of the NPS must fully reflect
existing statutory provisions which decision makers would be expected
to take into account in order to protect greenfield spaces.
59 Draft NPS, Chapter 6. Back
60
Draft NPS, p 37, para 6.1.2. Back
61
As above. Back
62
Planning Act 2008, Section 5 (2). Back
63
Ev 53 Back
64
As above. Back
65
Ev 54 Back
66
Ev 59 Back
67
Q 185 Back
68
Draft NPS, p 57, para 6.8.3. Back
69
Town and Country Planning Act 1990. Back
70
Draft NPS, p 57. Back
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