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Thanks Ruth. I like the idea of 1 and 2. Like other CLOs I know, I'm loathe to add to planning's workload, so I may try to generate this myself, similar to generating my own weekly list of new planning applications, which used to be circulated by planning before being shelved. 2. Should be eminently do-able. I'll investigate 3. with our IT folks. Cheers, Nicola -----Original Message----- From: Willcox, Ruth <[log in to unmask]> Sent: 11 September 2018 12:31 To: Nicola Slade <[log in to unmask]>; [log in to unmask] Subject: OFFICIAL: RE: RE: Pre-commencement Changes 1st October Hi Nicola Ways to monitor: 1: Ask building control for a list of commenced sites. If you LA uses IDOX they need to start inputting the planning application reference into their side of the system and ask officers to fill out the commencement date field. You can request they give you a weekly or monthly list with the BC Ref, Planning app Ref and the commencement date. 2: Request regular updates from Street Naming and Numbering - developers usually register new street names prior to commencement and new addresses just prior to completion/occupation. 3: Alternative to above - use your GIS system and the National Land and Property Gazeteer - NLPG (BLPU) Layer - to identify above within a planning site boundary. Note my last email on pre-commencement conditions for CL - the Government appears to classify as necessary. Hope this helps :) Kind regards Ruth Ruth Willcox Planning Officer Strategic Planning and Infrastructure Windsor House Tavistock Road Plymouth Devon PL6 5UF T +441752304154 E [log in to unmask] www.plymouth.gov.uk -----Original Message----- From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Nicola Slade Sent: 11 September 2018 12:14 To: [log in to unmask] Subject: Re: OFFICIAL: RE: Pre-commencement Changes 1st October I only wish it were possible to implement what Ruth proposes. I need some tips! I rarely know who the consultant for an applicant is in advance, let alone the Principal Consultant at that organisation. I will likely only know when an application is made to discharge a condition and I download the report(s) provided. Also, the consultant can change between desk study, investigation and remediation stages. My borough's database of sites where ground contamination is suspected runs to ~360 sites* and some are large areas of land with hundreds of properties (e.g. large former sewage works, now covered in housing). Hence, the 360 suspect sites cast a planning shadow over thousands of properties. I pro-actively check ~2500 planning applications each year to see where conditions are warranted (so I'm not waiting for last-minute consultations) and we have a legacy of hundreds of ground contamination and gas related conditions 'out there', ready to come into play when development starts. I am under no illusion that this is a lot of sites/conditions compared to others. Epsom and Ewell Borough does not have a significant industrial history and is consequently, I suspect, cleaner than most (hence why I am the only CLO and work half time). I imagine CLOs for many councils are reading this and saying "only 360 suspect sites, we have thousands" and their workload will be commensurately larger. I have a really good relationship with our planning team and the information flow is good both ways. I see our planning officers working flat out processing applications. Their workload is staggering just on 'live' sites and new applications, without trying to know which might start soon. I just don't think it is possible to know which developments are starting until the developers let us know and it is certainly not practicable for CLOs to know which consultant will be advising each applicant and then make a call to encourage them to provide the information needed to discharge an application. I think changing from 'pre-commencement' to 'pre-occupation' conditions will work well though and avoid some of the Catch 22 situations that can arrive where, say, gas protection measures in new buildings are needed. In my experience, most developers and consultants want to do the right thing and will not abuse the system. Sometimes lack of technical knowledge on the part of the former can cause problems. Ruth has already mentioned how developers may not procure the right services (e.g. commissioning geotechnical investigation and not geo-environmental) and, I would add, often do not share condition wording with their consultants. The few who try to ignore ground contamination/gas conditions or pay for a shoddy job will be a headache whether conditions are pre-commencement or pre-occupation. A Stop Notice brings its own massive can of worms. * no secret and perhaps stating this here will avert some of next year's quota of FOI queries relating to how many sites we have on our database! Regards, Nicola Slade BSc(Hons), MSc, MCIWEM, C.WEM, CEnv, SiLC Contaminated Land Officer Epsom & Ewell Borough Council Tel: 01372 732404 [log in to unmask] Working 2 ½ days over Mondays, Tuesdays and Wednesdays Making Epsom & Ewell an excellent place to live and work Please do not print this e-mail unless absolutely necessary - SAVE PAPER Nicola Slade BSc(Hons), MSc, MCIWEM, C.WEM, CEnv, SiLC Contaminated Land Officer Epsom & Ewell Borough Council Tel: 01372 732404 [log in to unmask] Working 2 ½ days over Mondays, Tuesdays and Wednesdays Making Epsom & Ewell an excellent place to live and work Please do not print this e-mail unless absolutely necessary - SAVE PAPER -----Original Message----- From: Contaminated Land Management Discussion List <[log in to unmask]> On Behalf Of Willcox, Ruth Sent: 11 September 2018 11:04 To: [log in to unmask] Subject: OFFICIAL: RE: Pre-commencement Changes 1st October Planning commencements should be being monitored - by planning and building control departments. The reason for monitoring is financial. Section 106 and/or Community Infrastructure Levy payments due to the local authority are often triggered on commencement. Close CLO liaison with planning case officers and between different local authority departments is possible to ensure that reports are secured in a timely manner. All a CLO often needs to do is give the principal environmental consultant a call and advise awareness of upcoming commencement or start on site and what information is expected/outstanding. Clients can sometimes 'forget' to procure services at particular crucial stages and to be fair, environmental consultants do not always make it clear in planning terms what work is required and when. Kind regards Ruth Ruth Willcox Planning Officer Strategic Planning and Infrastructure T +441752304154 E [log in to unmask] www.plymouth.gov.uk -----Original Message----- From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Phil Mason Sent: 11 September 2018 09:49 To: [log in to unmask] Subject: Re: Pre-commencement Changes 1st October Hi Plenty of developers already treat prior to commencement conditions as prior to occupation. Always an interesting discussion when they submit a phase 2, remediation strategy and validation report in one hit. Especially when they have "forgotten" to undertake a proper validation of gas protection measures. Considering the developers pay good money for competent consultants to write good reports and produce excellent remediation strategies, it staggers me how often the developer neglects to actually read their own report, never min implement the recommended remediation strategy. Pre-commencement conditions requiring (for example) approval of a site investigation and agree a remediation strategy are, in my view often necessary to ensure that the developer sets off in the right direction. As stated below, the developer often cannot do more than a desktop study at the application stage because SI is just not logistically possible. If they are in the position to be able to do the SI and produce a remediation strategy at the application stage then great, I would personally just condition the validation works (prior to occupation). It'll be interesting to see how different planning authorities approach this. Phil Mason MSc, MIEnvSc, MCIEH, AMIOA Environmental Consultant (Air Quality, Noise, Contaminated Land) – Infrastructure Urban Vision Partnership Ltd ######################################################################## To unsubscribe from the CONTAMINATED-LAND-STRATEGIES list, click the following link: https://www.jiscmail.ac.uk/cgi-bin/webadmin?SUBED1=CONTAMINATED-LAND-STRATEGIES&A=1 ******************************************************************************************************************************************** IMPORTANT: This e-mail (including any attachments to it) is strictly confidential and intended solely for the person or organisation to whom it is addressed. It may contain privileged, confidential or sensitive information. If you are not the intended recipient, you must not copy or distribute it to any other person or take any action in reliance. 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