HERTFORDSHIRE COUNTY COUNCIL Agenda No. DEVELOPMENT CONTROL COMMITTEE TUESDAY, 12th JULY 2005, AT 10.00 A.M. 7 DACORUM BOROUGH APPLICATION TO ERECT A NEW BUILDING FOR DE-POLLUTING VEHICLES AT A G EVANS, LODGE WAY, CHESHAM ROAD, WIGGINTON, NR TRING, HERTFORDSHIRE Report of the Director of Environment Author: Richard Greaves Tel: 01992 556225 Local Member: Nicholas Hollinghurst 1. Purpose of Report 1.1 To consider planning application ref. 4/0932-05 for a new building to depollute vehicles at A G Evans, Lodge Way, Wigginton, Hertfordshire. 2. Summary 2.1 A G Evans is a scrap metal, motor salvage and vehicle dismantling yard that has been operating for approximately 65 years in its current location. In 1993 the operation was given lawful use rights to operate as a scrap metal yard incorporating waste transfer activities. 2.2 From 1 January 2005, each car the applicant dismantles must be drained of all fluids by law. Such legislation is contained within the End-of-life Vehicles Directive 2003 (ELV). The applicant proposes to erect a purpose built single storey building to de-pollute all scrap vehicles before they are dismantled or crushed for scrap. 2.3 The principal issues to be taken into account in determining this application are: development in the Green Belt; development within the Chilterns Area of Outstanding Natural Beauty, and; any associated environmental impact. 3. Conclusion 3.1 This report concludes that, for the reasons set out in the report, the Director of Environment should be authorised to grant planning application ref. 4/0942-05, subject to conditions relating to: i) ii) iii) time limits (commencement); limiting the use of the building to that specified in the application; hours of construction work; 533548169 4/0932-05 1 iv) v) vi) details of materials/colours; submission of a contamination investigation; submission of drainage details. 533548169 4/0932-05 2 1. Description of the site and proposed development 1.1 The A G Evans site lies within the Metropolitan Green Belt and Chilterns Area of Outstanding Natural Beauty (AONB). The 4 hectare site is located south of Wigginton within an area of land off Chesham Road. Access to the site is gained via Lodge Way directly of the Chesham Road. The site is relatively well screened and enclosed and is bounded to the north by mature woodland and to the east by open farmland. To the west and south are a number of residential properties fronting Chesham Road which is designated as a rural, local distributor road in the Herts County Council road hierarchy. Running parallel from west to east beyond the northern boundary of the site is public footpath 2. The site is largely self-contained by earth mounding, established vegetation and wire and metal palisade fencing. 1.2 A G Evans is a scrap metal, motor salvage and vehicle dismantling yard that has been operating for approximately 65 years in its current location. In 1993 the operation was given lawful use rights to operate as a scrap metal yard incorporating waste transfer activities. From 1 January 2005, each car the applicant dismantles must be drained of all fluids by law. Such legislation is derived from the End-of-life Vehicles (ELV) Directive 2003. 1.3 The applicant proposes to erect a purpose built single storey building to depollute all scrap vehicles before they are dismantled or crushed for scrap. The application site is located within the existing metal recycling site of A G Evans, Lodge Way, Wigginton. The proposed building would be located within the site and cover a floor area of 162 m2 with a height of 7.6 metres to the pitch of the roof. The applicant has stated that the proposed building is necessary to de-pollute vehicles prior to these vehicles being processed within the site 1.4 The building is proposed to satisfy two main requirements; the need to comply with the ELV Directive and health and safety provisions. The building has been designed to take a large estate car or transit type van. This would require a large open door and enough head room for the vehicle to be lifted up to working height whilst still leaving room to manoeuvre the de-pollution equipment around it. Vehicles would be taken inside the building on a forklift. 1.5 The treatment of ELV needs to be done to a high standard with electric/pneumatic machinery which needs to be kept dry to work properly. The building would also keep the operators in dry conditions to ensure a clean environment and contain any spillages and vapours within the building. 1.6 At present the applicant has an average of 105 vehicles per week and is seeking to attain a throughput of around 2.1 vehicles per hour within the building. 533548169 4/0932-05 3 1.7 The location of the building has been chosen to maintain a straight route of production, so that cars would come onto the site, be weighed, then moved to the de-pollution building where all fluids would be drained and finally on to the crusher to be cubed and loaded for off site transportation. 1.8 The applicant has stated that without the proposed building the operation could not properly comply with the end-of-life vehicle legislation. 2. Consultations 2.1 Dacorum Borough Council (Planning) consider that there are very special circumstances to justify the development and accordingly has no objection subject to the building being constructed in appropriate materials and limiting its use to the specific purpose. 2.2 Dacorum Borough Council (Environmental Health) has no objection. 2.3 The County Council as Highway Authority has no objection. 2.4 The Environment Agency has no objection subject to conditions requiring advance site investigation works being carried out, advance details drainage and foundation works and prevention of pollution of the water environment. 2.5 Thames Water recommends that petrol/oil interceptors be fitted in all car parking/washing/repair facilities. 2.6 Energis and National Grid have no objection. 2.7 Wigginton Parish Council strongly supports the application as it will be of benefit to the local economy. 2.8 Chilterns Conservation Board has no comments. 2.9 Neighbours / Publicity: A total of 12 properties were consulted and two site notices were erected publicising the application. A press advert was also published. Two individual responses have been received, both of which object to the application. Both objections refer to the use of the site generally, being inappropriate within the Green Belt and AONB. Also the environmental impact of the existing use is raised with concern in particular over noise, pollution and traffic. A further increase in activity may also arise which would increase traffic as well as compound the use of the site for waste disposal which is not appropriate for the area. 3. Planning Considerations 3.1 Under the End-of-life Vehicles (ELV) Regulations 2003, end-of-life vehicles are now classified as waste, and the dismantling and de-polluting of cars must therefore be seen as an activity dealing with waste. Consequently, although not all activities occurring on the site are related to waste, the 533548169 4/0932-05 4 planning application falls to the County Council for determination as Waste Planning Authority, rather than the District Council, who have historically determined applications for other built development at the site. 3.2 The relevant development plan policies are: Hertfordshire Structure Plan Review, 1991 – 2011 (Adopted April 1998) Hertfordshire Waste Local Plan 1995 – 2005 (Adopted January 1999) Dacorum Borough Local Plan (April 2004) Appendix One contains a full description of the primary policies relating to the development. 3.3 Green Belt: The application site lies within the Metropolitan Green Belt as defined in the Dacorum Borough Local Plan. Policy 5 of the Hertfordshire Structure Plan Review 1991 – 2011 states that there is a presumption against inappropriate development in the Green Belt, except in very special circumstances, for purposes other than those detailed in PPG2 ‘Green Belts’. The District Local Plan contains a similar policy, Policy 4. 3.4 Paragraph 3.12 of PPG2 states that: ‘The statutory definition of development includes engineering and other operations, and the making of any material change in the use of land. The carrying out of such operations and the making of material changes in the use of the land are inappropriate development unless they maintain openness and do not conflict with the purposes of including land in the Green Belt.’ 3.5 Paragraph 1.5 of PPG2 lists the purposes of including land within the Green Belt, which are: to prevent the unrestricted sprawl of built up areas to prevent neighbouring towns from merging into one another to assist in safeguarding the countryside from encroachment to preserve the setting and special character of historic towns, and to assist in urban regeneration, by encouraging the recycling of derelict or other urban land 3.6 As specified at paragraph 3.4 of PPG2, the construction of new buildings (of the type proposed in the application) in the Green Belt is inappropriate development. Furthermore, the proposed building would not maintain openness and does not accord with the purposes of including land within the Green Belt. It is therefore considered that the development constitutes inappropriate development. 3.7 Paragraph 3.2 of PPG2 states that inappropriate development is by definition harmful to the Green Belt and very special circumstances to justify inappropriate development will not exist unless the harm caused by reason of inappropriateness, or any other harm, is clearly outweighed by other 533548169 4/0932-05 5 considerations. In addition, Policy 16 of the Waste Local Plan 1995 - 2005 states that the use of land in the Green Belt for the re-use, recovery, recycling and storage of waste will not be permitted unless it maintains openness and does not conflict with the purposes of including land in the Green Belt. It continues to state that the construction of new buildings in the Green Belt for such purposes will not be permitted except in very special circumstances. Very special circumstances therefore need to be demonstrated to permit inappropriate development within the Green Belt. 3.8 Very Special Circumstances: It is accepted that there is a need for recycling facilities for end-of-life vehicles. The Government’s Waste Strategy 2000 states that each year over 1.5 million vehicles reach the end of their lives, however latest DTI information puts this figure at around 2 million vehicles. At present about 75% of the weight of an individual vehicle is recycled. The European Commission set up a Priority Waste Stream Working Group in 1991 to look at ways of reducing waste from end-of-life vehicles. It aims to meet its environmental objectives by increasing reuse and recovery rates to 85% by 2006 and 95% by 2015. 3.9 End-of-life vehicles are to be classified as hazardous waste from 16 July 2005 and will need to be de-polluted as a consequence of European legislation prior to dismantling, crushing or shredding. All facilities treating ELVs, including the site at Lodge Way, will be affected. 3.10 Legislation: The relevant European legislation that has been transposed into national statute are: The European End-of-life Vehicles (ELV) Directive (2000/53/EC), and; The updated versions of both the European Waste Catalogue (EWC) and Hazardous Waste List (2000/532/EC) and its subsequent amendments. 3.11 The ELV Directive introduces measures to promote and increase recycling and to further protect the environment by requiring adequate de-pollution (e.g. draining of fluids such as engine oil) and sets minimum technical requirements for the treatment of ELVs. Following the introduction of the End-of-Life Vehicles Regulations 2003 (Statutory Instrument 2003, No.2635), ELV treatment facilities carrying out de-pollution need to be licensed as “authorised treatment facilities” (ATFs) by the Environment Agency. The de-pollution requirements of the ELV Directive are given below. 3.12 Treatment operations for the de-pollution of end-of-life vehicles include: removal of batteries and liquefied gas tanks, removal or neutralisation of potential explosive components, (e.g. air bags), removal and separate collection and storage of fuel, motor oil, transmission oil, gearbox oil, hydraulic oil, cooling liquids, antifreeze, brake fluids, air-conditioning system fluids and any other fluid contained 533548169 4/0932-05 6 in the end-of-life vehicle, unless they are necessary for the re-use of the parts concerned, removal, as far as feasible, of all components identified as containing mercury. 3.13 The individual hazardous components and materials removed during depollution should be kept separate. 3.14 The European Waste Catalogue (EWC) and Hazardous Waste List (HWL) were first published in 1994. These are used for the classification of all wastes and hazardous wastes and are designed to form a consistent waste classification system across the EU. They form the basis for all national and international waste reporting obligations, such as those associated with waste licenses and permits, and the transport of waste. They were implemented in the UK by the Special Waste Regulations (1996). 3.15 Updated versions of both the European Waste Catalogue and Hazardous Waste List were published as a homogeneous list of hazardous and nonhazardous wastes in 2001, and came into force on 1 January 2002. 3.16 The updated EWC now includes ELVs (Category 16 01) and lists a number of hazardous wastes in this category. This list is more comprehensive than that in the ELV Directive, and also applies to all vehicles whereas the ELV Directive only applies to a specified range of vehicles. 3.17 The proposed building would therefore allow the applicants to comply with the relevant legislation for de-polluting ELVs, as well as contribute to the achievement of national targets for the recycling of end of life vehicles. 3.18 Provided there is a need for such facilities, Policy 2 of the Hertfordshire Waste Local Plan 1995 – 2005 gives qualified support for waste management facilities that out weigh any material agricultural, landscape, conservation or environmental interest affected. This is also supported by Policy 55 of the Hertfordshire Structure Plan Review 1991-2011 3.19 It is therefore considered that the harm caused to the Green Belt or other harm by reason of inappropriate development is outweighed by the need for the applicant to comply with stringent environmental standards as well as contribute to achieving national recycling targets within an existing long established salvage site. It is considered that this need warrants the very special circumstances required to justify a departure against Green Belt Policy. The proposed development would take place within the existing boundaries of the site, would allow the continuation of an existing activity to operate and would not lead to an intensification of use, as has been feared locally. The proposed de-pollution building would complement the existing use rather than promote an overall increase in activity at the site. 3.20 Area of Outstanding Natural Beauty: Policy 97 of the Dacorum Borough Local Plan 1991 – 2011 states, inter-alia, that in the Chilterns Area of Outstanding Natural Beauty the prime planning consideration will be the 533548169 4/0932-05 7 conservation of the beauty of the area and that the economic and social well being of the area and its communities will be taken into account. Wherever development is permitted it will be on the basis of its satisfactory assimilation into the landscape. Particularly relevant for this application are guidelines for new buildings and other development which states, inter-alia, that: development must not be intrusive in terms of noise, disturbance, light pollution, traffic generation and parking; building, plant and structures must be sympathetically sited and designed, and; colours and materials used for a development must fit into the traditional character of the area. 3.21 Policy 32 of the Hertfordshire Waste Local Plan (1995 – 2005), states, interalia, that applications for major waste management development will be inconsistent with the aims of an AONB unless it can be demonstrated that: there is a proven national interest; and no alternative site is available. 3.22 Policy 33 of the Hertfordshire Waste Local Plan (1995 – 2005), states that the impact of all applications for waste management facilities on the landscape will be considered and planning permission may be refused on the grounds of significant landscape intrusion and loss of important landscapes should also be taken into account. 3.23 The proposed building would be 7.6m in height to the pitch of the roof which is in keeping with the height of the existing office and reception buildings and the workshop to the west. The siting of the building is some way into the site and, although limited views of the roof pitch may be visible from the nearby footpath, the building would be relatively well screened from external views. 3.24 The proposed building is to be steel framed with metal cladding sheet to the wall, with block cladding of a similar appearance to the existing buildings on site. Guidance for building design in the AONB is contained within the Chilterns Design Guide. This guidance however is limited in advice for industrial style buildings, such as proposed. Nevertheless, it is considered that the fabric of the proposed building is acceptable within the site context and, subject to conditions being imposed to approve block and metal colours in advance, the design of the building is considered acceptable. 3.25 Although the use of the land as a vehicle dismantling yard and waste site is not wholly compatible with AONB Policy, the proposed building is considered to be a necessary requirement for the operator to run the business to modern environmental standards. Also, in view of the fact that the site is well enclosed with no external views from the frontage to the proposed building’s position, the general ‘beauty’ of the area would not be spoilt. Furthermore, the proposal would assist in continuing an economic activity that is needed in the area. For these reasons, and the fact that the 533548169 4/0932-05 8 new building would not intensify the existing use of the site, the proposal does not wholly conflict with AONB policy. 3.26 Environmental Impacts: Operations at the site are controlled by a Waste Management Licence regulated by the Environment Agency. The purpose of the Licence is to control any potential pollution and minimise any air or ground pollution risk posed by the operation in relation to the immediate and wider environment. Should planning permission be granted, the Waste Management Licence would remain extant. The proposed building would enable de-pollution operation to be carried out indoors, thereby assisting in the protection of the wider environment from pollution risk. Should permission be granted, the Environment Agency recommend that conditions are imposed requiring advance site investigation works being carried out, advance details drainage and foundation works and prevention of pollution of the water environment. 3.27 Highways Impact: Although the Highway Authority does not object to the proposed development, local concerns have been raised on the grounds of increased vehicle movements resulting from the proposed development. The existing Certificate of Lawful Use specifies the level of vehicle movements, when the site was given lawful use rights. The proposed building would not give rise to additional vehicle movements at the site. Should vehicle movements at the site increase, such issues would require consideration independently. 3.28 Overall Use of Site: The planning application for consideration relates to a specialist building for de-polluting vehicles. It is not appropriate to consider the activities on the site as a whole as part of this application. If the proposed development were to have led to an intensification of use of sufficient level that the overall operations of the site could be deemed to have materially changed, then it may have been appropriate to consider the activities of the site overall. However, this is not the case, and this course of action is therefore not appropriate. 4. Conclusions 4.1 The function of the proposed building is to de-pollute end-of-life vehicles to comply with emerging environmental legislation. This activity contributes towards government aims to increase recycling rates from end-of-life vehicles. The function of the site is to receive end-of-life vehicles for storage, crushing and removal as scrap. The proposed building would assist in such an operation becoming more environmentally acceptable and sustainable. It is considered there are considered to be very special circumstances to justify the development as a departure from Green Belt and AONB policy. However, given the existing operations, it is not considered that the proposal represents a significant departure that would require referral to the First Secretary of State. 4.2 It is considered that any potential adverse impacts the building may have upon the local landscape can be controlled through the sensitive use of 533548169 4/0932-05 9 colours and materials. Overall it is considered that the benefit to be gained from allowing the applicant to operate to improved environmental standards outweighs any material wider landscape interests. 4.3 It is therefore considered that the Director of Environment should be authorised to grant permission for the proposal, subject to conditions to include: i) ii) iii) iv) v) vi) time limits (commencement); limiting the use of the building to that specified in the application; hours of construction work; details of materials/colours; submission of a contamination investigation; submission of drainage details. 5 Financial Implications 5.1 Planning applications should be determined on the basis of material planning considerations, and not on the basis of their financial implications for the County Council. However, it is a requirement of the County Council to advise all Committees of the financial implications that may arise from their decisions. 5.2 If a planning application is refused or is not determined within a specific period, the applicant has a right of appeal. Any appeal would result in additional costs, which in part can be met from existing budget provisions. However, a major public inquiry may give rise to significant costs for which there is no specific budget provision. If the County Council refuses an application without reasonable planning grounds on which to base its decision, it may be liable to pay the costs of the applicant in contesting the appeal. Background information used by the author in compiling this report Planning application reference 4/0932-05, and additional supporting correspondence Consultation responses and representations received in response to planning application ref. 4/0932-05 Hertfordshire Structure Plan Review 1991-2011 (adopted April 1998) Dacorum Borough Local Plan 1991-2011 April 2004 Hertfordshire Waste Local Plan 1995-2005 (January 1999) Waste Strategy 2000: England and Wales ‘De-polluting End-of-Life Vehicles’ Guidance for Authorised Treatment facilities (DEFRA & DTI publication) Chilterns Buildings Design Guide 1999 533548169 4/0932-05 10 DEVELOPMENT PLAN POLICY Appendix 1 Hertfordshire Structure Plan Review 1991 – 2011 (Adopted April 1998) Policy 1 - Sustainable Development: ‘The policies of this Plan, together with those of local plans, will seek to enable activities and development in Hertfordshire to be carried out consistently with the principles of sustainable development.’ Policy 2 - Design and Provisions of Development: ‘The design and provisions of development will be expected to help achieve the sustainability aims and objectives of this Plan.’ Policy 5 - Green Belt: ‘In the Green Belt there is a presumption against inappropriate development and permission will not be given, except in very special circumstances. Policy 43 - Landscape Conservation Areas ‘Particular regard is to be given to the setting, siting, design and external appearance of such development as is permitted in these areas.’ Policy 55 - Waste Management: ‘The establishment of facilities for the handling, transfer, treatment and disposal of waste will be supported, subject to the other policies of this Plan, particularly those relating to the environmental and other effects of development, sufficient to make an appropriate contribution to meeting the region’s needs.’ Hertfordshire Waste Local Plan 1995 – 2005 (Adopted January 1999) Policy 1 – ‘In … considering proposals for waste management development, the County Council will have regard to the extent to which the development is sustainable in form and location, and minimises traffic congestion, travel distances, waste generation and pollution. The County Council in dealing with waste management will give preference to the location of waste recycling, handling, reduction and disposal facilities as close as practical to the origin of the waste.’ Policy 2 - ‘The establishment of facilities for handling, transfer, treatment and disposal of waste will be supported provided that in order to accommodate the equivalent of Hertfordshire’s own waste arisings, there is a clearly established need for additional capacity and facilities of the kind that the proposed development would provide, which outweighs any material agricultural, landscape, conservation or environmental interest affected by the proposal. ‘ Policy 16 - ‘The use of land in the Green Belt for the re-use, recovery and storage of waste will not be permitted unless it maintains openness and does not conflict with the purposes of including land in the Green Belt.’‘ 533548169 4/0932-05 11 Policy 32: Within the Chilterns Area of Outstanding Natural Beauty (AONB) there will be a presumption against applications for major waste management development which would adversely affect the special character, appearance and conservation of the AONB. applications for such development will be inconsistent with the aims of the area of outstanding natural beauty unless it can be demonstrated that :i) there is a proven national interest; and ii) no alternative site is available. Policy 33 – ‘The impact of all applications for waste management facilities on the landscape will be considered and planning permission may be refused on the grounds of significant landscape intrusion and loss of important landscapes.’ Dacorum Borough Local Plan 1991 – 2011 (Adopted April 2004) Policy 4 – Green Belt: Within the Green Belt, there is a presumption against inappropriate development. New buildings will therefore only be acceptable where they are for the following purposes: (a) agriculture; (b) forestry; (c) essential facilities for outdoor sport and outdoor recreation, for cemeteries and for other uses which preserve the openness of the Green Belt and which do not conflict with its purposes; (d) the limited extension of existing houses in accordance with Policy 22; (e) the replacement of existing houses in accordance with Policy 23; (f) limited infilling in selected small villages in accordance with Policy 6; and (g) limited infilling or redevelopment of major existing developed sites in accordance with Policy 5. The reuse of an existing building will be permitted provided that: (i) it does not have a greater impact on the Green Belt than the present use; and (ii) it complies with the criteria in either Policy 69, 92 or 110. Engineering or other operations, including mineral extraction, and material changes in the use of land will only be acceptable where they maintain openness and do not conflict with the purposes of including land in the Green Belt. Inappropriate development will only be allowed where it can be demonstrated that very special circumstances exist which clearly outweigh the harm to the Green Belt. Any development that would injure the visual amenities of the Green Belt will not be permitted. All development should seek to make a contribution to fulfilling the Green Belt objectives set out in paragraph 1.6 of PPG2. Policy 97 – Chilterns AONB: In the Chilterns Area of Outstanding Natural Beauty the prime planning consideration will be the conservation of the beauty of the area; the economic and social well-being of the area and its communities will also be taken into account. Any development proposal which would seriously detract from this will be refused. Wherever development is permitted it will be on the basis of its satisfactory assimilation into the landscape. 533548169 4/0932-05 12 Every effort will be made to discourage development and operations that would adversely affect the beauty of the area. Landowners are encouraged to adopt the following planning guidelines which will contribute to the preservation and enhancement of the area. The Council will adhere to the guidelines whenever considering planning applications: (a) New Buildings and Other Development • Development must not be intrusive in terms of noise, disturbance, light pollution, traffic generation and parking. • Building, plant and structures must be sympathetically sited and designed, having regard to natural contours, landscape, planting and other buildings; there should be no adverse effect on skyline views. • Colours and materials used for a development must fit in with the traditional character of the area. (b) Open Air Recreation • Large urban-style parks and sports facilities are not acceptable. • Extensive recreational facilities such as golf courses (see Policy 78) and country parks must be carefully integrated with the landscape, natural vegetation and natural ground contours. • Intrusive fencing and illumination are not acceptable. • Informal outdoor recreation allowing the quiet enjoyment of the countryside is encouraged, but careful attention will be paid to the provision of associated ancillary facilities such as car parks and toilets in order to minimise their impact on the local scene. (c) Mineral Extraction • No further chalk quarrying will be supported, with the exception of registered Interim Development Order (IDO) sites which have the benefit of consent from the County Council as mineral planning authority for the area. Other mineral extraction may be supported if justified in the national interest, if there are no other reasonable sites and if the impact on the area is kept to a minimum. (d) Agriculture • The intensity of farming practices should not be detrimental to landscape quality and nature conservation interests. • Activities requiring new building should be avoided if possible. Where new building is necessary, it should be sited unobtrusively and designed to maintain the character and quality of the countryside: siting close to, and integrated with, existing complexes of farm buildings is normally preferred. • Land filling is not acceptable. • Individual trees, copses and hedgerows should be retained and new planting carried out in appropriate locations (in co-operation with relevant agencies and groups) in order to enhance the landscape quality and nature conservation interests of the area (Policy 100). (e) Forestry and Landscaping • The retention of existing, and planting of new woodlands on hill tops and ridges, other than on chalk downland or other grassland of nature conservation interest, is encouraged. • The active management of woodlands is encouraged (Policy 101). • Broad-leaved tree species which are native to the particular soil and location should be used in all planting and landscaping schemes. 533548169 4/0932-05 13 • Conifers should only be used as a nurse crop in forestry. (f) Nature Conservation • High priority should be given to maintaining and enhancing the interests of nature conservation and, in particular, acknowledged sites of importance to nature conservation (Policy 102). • Changes in land use or farming practices which would adversely affect the interests of nature conservation should not be pursued. (g) Redundant Buildings • Redundant buildings which are considered to be detrimental to the high landscape value of the area and are not suitable for appropriate reuse under Policy 110 should be removed. 533548169 4/0932-05 14