Environmental permit Willemansweg

The company IMC Crossborder wants to house expats on the Willemansweg in Oostvoorne for a period of up to three years before the construction of refineries and other industry on the Maasvlakte. The initiator submitted an application for an environmental permit on August 1, 2023. This can be done by any resident or entrepreneur. 

The municipality has decided that the permit application and draft decision are ready for public inspection. This means that, in principle, the college intends to grant the environmental permit. The next step is to make the draft decision available for public inspection. The draft decision is expected to be published on December 18, 2024 via our municipal website and www.overheid.nl. Anyone can submit an official opinion against this draft decision within six weeks. The submitted views will then be summarized and answered before the final decision is made. The final decision is subject to objection and appeal. 

Questions about IMC Crossborder's plan are also coming to the municipality. On this page you will find a number of questions and their answers. The municipality cannot inform you about the content and background of the plan.

You can contact them by phone or email at 020-3120501 or info@imc-crossborder.com.

Can't find the answer to your question to the municipality in the information on this page? Then you can send your question by e-mailnl andnl to the Spatial Development Department of the Municipality of Voorne aan Zee.

The permit (application)

What is the status of the permit application?

The plan to establish a temporary campus for expats does not fit within the current zoning plan. The promoter is therefore applying for a permit to deviate from the zoning plan. Because the permit was applied for in 2023, it is still being processed according to the laws and regulations in force at the time. In recent months, the relevant information has been provided by the initiator. Various external advisors, including the DCMR and the Province of South Holland, have been approached to check supplied studies.

After reviewing all the documents, the college has decided that the permit application and draft decision are ready for public inspection. This means that, in principle, the college intends to grant the environmental permit. The next step is to make the draft decision available for public inspection. The draft decision is expected to be published on December 18, 2024 via our municipal website and www.overheid.nl. Anyone can submit an official opinion against this draft decision within six weeks. The submitted views will then be summarized and answered before the final decision is made. The final decision is subject to objection and appeal. 

What has the initiator applied for an environmental permit for?

The initiator has submitted an application for an environmental permit for the realization of a temporary compound on the Willemansweg in Oostvoorne. A total of 228 units will be placed on the site to house 170 expats. These will remain for a maximum of 36 months, including assembly and disassembly.

How can I communicate my reaction or objection to IMC Crossborder's plan to the municipality?

When the municipality makes the draft decision available for inspection (this will happen from December 18, 2024), anyone can submit an official view to the municipality. The submitted views will then be summarized and answered before a final decision is made. The decision on this environmental permit will be made by the Municipal Executive. The final decision is open to appeal.

How can I view the environmental permit application?

If you would like to see the application for an environmental permit and related documents, you can request these documents from the municipality; you can find the contacts at the top of this page. You will then receive the documents by e-mail. 

What Requirements must the permit application meet? How are these reviewed and by whom?

An application that comes in must comply with good spatial planning. Traffic, environmental, flora and fauna and other aspects are considered. Various studies have been requested for this. In addition, as already known, several external advisors are involved who assess the documents provided. These include the VRR (Rotterdam-Rijnmond Safety Region), the DCMR (Rijnmond Environmental Protection Agency) and the Hollandse Delta Water Board. From the municipality, the application has been assessed by a licensing officer and the employees dealing with the other fields.

How will it be ensured that this situation does not set a precedent?

Looking at this decision, no precedent is set. Naturally, any new initiative must meet the applicable Requirements and the requirements in the field of good spatial planning, other legislation and the adopted policy memorandum on housing labor migrants. 

If a permit extension is requested, how could it be denied if it were granted now?

Extending the current permit is not possible. If a new application is submitted after the expiration of the term, the desirability of cooperating with the initiative again must be assessed. One of the college's rationale for cooperating with the initiative concerns the temporary nature of up to 36 months.

What happens to the views already submitted last year?

Some of the local residents have already submitted views against the submitted application for an environmental permit in 2023. These were submitted before the extensive procedure was followed. Now the extensive procedure is finally being followed, which includes a formal period for submitting views. This means that we cannot deal with the views submitted in 2023 against the application for an environmental permit. If this applies to you, and you do want to respond to the application for an environmental permit, it is therefore necessary for you to submit a view again.

The draft decision will be published via our municipal website and nl. Thus, after the publication of the draft decision, there is a time to submit an official view. Previously submitted views are therefore not included as officially submitted views. 

Position and role of municipality

What is the municipality's position on this promoter's plan to house expats at this location?

We indicated in 2023 that we could in principle, under Requirements, cooperate with the request for the temporary housing of the needed workers at the Willemansweg in Oostvoorne. Locations are needed where foreign workers working for the construction of various projects on the Maasvlakte can live. By allowing a central location, ordinary housing can remain available for our own residents. 

After reviewing all the documents, the college has decided that the permit application and draft decision are ready for public inspection. This means that, in principle, the college intends to grant the environmental permit. 

Last year it was clear that there is a lot of opposition to the plan. So why does the municipality want to (continue to) cooperate with it?

The realization of an expatriate housing location can ensure that ordinary housing is not bought up for expatriate housing so that it remains available for our own residents. The realization of a central housing location thus serves a public interest. That there is resistance from the surrounding area is also clear to the municipality. Based on the arguments presented, the initiator's plans have been modified. 

What is the role of the municipality? When will a decision be made?

The municipality has the role of verifying that the application for an environmental permit meets all necessary spatial planning requirements. It assesses compliance with relevant laws and regulations in the field of spatial planning (such as soil, nitrogen, environment, building safety, etc.). It also takes into account how communication with the environment has been handled. On this basis, a decision is made on the application for an environmental permit. In its decision, the municipality considers the general interest of the development desired by the initiator. 

After reviewing all the documents, the college has decided that the permit application and draft decision are ready for public inspection. This means that, in principle, the college intends to grant the environmental permit. The next step is to make the draft decision available for public inspection. The draft decision will be published on December 18, 2024 via our municipal website and www.overheid.nl. Anyone can submit an official opinion against this draft decision within six weeks. The submitted views will then be summarized and provided with a response before the final decision is made. The final decision is subject to objection and appeal. 

What is the City Council's role in deciding whether or not to allow this initiative?

Often decision-making on an extended procedure is a council competence. The rules of the former municipality of Westvoorne still apply to this application. That municipality had established (in a general declaration of no objections) that the college is authorized to deviate from zoning plans that are older than two years. The parcel on Willemansweg falls within the Buitengebied Westvoorne zoning plan. This zoning plan was adopted on January 22, 2020 and came into effect on April 24, 2020. This means that as of April 24, 2022, the college is authorized to depart from the zoning plan with the application of the extensive procedure.

How is the City Council involved in the decision by the College of B&W on the permit application?

It is true that the decision-making authority on the permit rests with the college. However, the city council is involved in the issue by informing them of the process at appropriate times.

With a new application, the situation will be more or less the same. What procedure will then apply? Is it then again only the College of B&W that makes the decision?

The college must make a decision on a future new application under the new legislation. Depending on the scope of the initiative, the college will observe the City Council's binding advisory right in doing so.

How does this initiative fit into the policies of the Municipality of Voorne aan Zee?

Both the Environment Vision and the Housing Welfare Health state that the municipality has the task of providing suitable housing for specific target groups. This includes the housing of labor migrants. The realization of a housing location within our municipality therefore fits within the policy of the Municipality of Voorne aan Zee. In addition, the submitted initiative also complies with the already established policy on labor migrant housing.

The municipality indicated that the DCMR sees this development as an "urban development project. Why do you think an urban development project is appropriate on this site?

The realization of the housing qualifies as an urban development. For this reason, compliance with the Ladder for Sustainable Urbanization is required by law. Therefore, a justification is required as to why this need cannot be met within the existing urban area.
The justification that the need of the present development cannot be met within the existing urban area lies in the fact that there is a great shortage of housing within the municipalities and in the entire region. Occupying these homes would exacerbate the shortage in the regular housing market. The homes used by the projects' temporary workers would no longer be available for the regular housing market. The housing shortage in the municipality of Voorne aan Zee and the Rotterdam region is severe. There is a great shortage of housing, especially rental housing, the type of housing that is now being used to house temporary workers. It is important to keep housing in the villages available for the regular housing market.

Target group and duration of initiative

How do we know that the housing site will disappear again after those three years?

The application is about temporary housing units for the duration of up to 36 months. If it is decided to grant the necessary environmental permit, this temporariness will be recorded in the Requirements of the environmental permit. A few months before the term of the environmental permit expires, the municipality (as usual) alerts the initiator that the end date is approaching. Should the initiator not remove the units after the expiration date, the municipality will take enforcement action.

After these 36 months, can other target groups, such as refugees or migrant workers, move into the housing units?

No, this is not an issue. The housing units must be removed after this period. If the owner of the land wants to use the land for other groups in the future, an initiator will have to go through the same process and submit a new application for an environmental permit. At that time, the municipality will again weigh in on the submitted initiative.

How will it be enforced that only expats come?

The environmental permit application clearly states the target group of the applicant (IMC Crossborder). This is to house expats and no other groups. If it is found that the target group it contains differs from the yet to be granted permit, the applicant will be held accountable. The applicant will be enjoined to cease the current use and resume the use in accordance with the issued environmental permit.  

How is it verified that a maximum of 170 expats are housed? What are the consequences if this is not met?

The number of 170 people is indeed the maximum. It is checked by determining whether the layout of the site corresponds to the drawing accompanying the environmental permit. If more people live there, the owner is called to account and the number must be reduced to 170 people. In addition, once the violation is found, we may impose a fine. 

What is the difference between a migrant worker and an expat? What definition does the municipality keep for expat?

Within the municipality there is no separate definition for expats within the zoning plans. However, the initiative at Willemansweg does refer to employees with a high level of knowledge working at the Maasvlakte.

How is it monitored or enforced that houses in the villages do not go to expats or migrant workers?

When someone submits an enforcement request as an interested party, enforcement action is taken on that basis. In addition, we as a municipality take enforcement action when we ourselves observe such a situation. It is not possible to take action in places where it was permitted within the previous zoning plan to live here as a migrant worker. The comment is also made that the fact that something is permitted does not immediately mean that it is no longer happening. As indicated above, enforcement action is taken the moment the municipality finds that it is acting contrary to established rules. 

How will the municipality take enforcement action if the units are not removed after 36 months?

If the units are not removed after 36 months, this leads to the imposition of an order under penalty. If the owner does not end the violation by imposing the order under penalty, the college can use administrative coercion to have the residential units removed itself.

The site and other locations

Why is housing for these workers not taking place at the Maasvlakte?

There are several refineries and other risk-sensitive objects on the Maasvlakte. Considering the health risks, the storage and transport of hazardous materials within this area, fire safety requirements of (temporary) housing and other laws and regulations on housing and external safety, it is not possible to realize housing within the Maasvlakte. Moreover, this is a specific permit application for this location, which requires a decision by the municipality. 

Why didn't the municipality offer another site to the promoter?

An initiator is free to apply for a specific piece of land at any time. The initiator has chosen the location on Willemansweg. The reason he stated to the municipality for this is the proximity of the construction site and its location directly on various N-roads, and the fact that no workers are allowed to be housed at the Maasvlakte due to safety reasons.

The application was first submitted last year and at that time these workers were already urgently needed. Is it known where they were housed in the last year?

The municipality does not know where these workers are currently housed.

How do we know that this location will ensure that housing remains available for the mainstream housing market. How do we know that this is the case?

On May 30, 2024, the City Council adopted the policy memorandum on housing labor migrants. This adopted policy includes the need for housing migrant workers. Due to the growth of the economy and the change in the labor force, there is more and more work for labor migrants, which also means that more and more housing locations for these workers must be realized. One consequence of this is the purchase of regular housing for rental to labor migrants. This creates additional pressure on the housing market with the result that, for example, other target groups such as starters find it even harder to get their first home. New housing initiatives that comply with the frameworks set out in this policy memorandum will contribute to more and better housing of labor migrants. When the resulting supply is attractive enough (more appropriate, also in pricing and independent of the employer), we can enable a movement.

Why is renting out housing seen as a threat to availability to residents when it is not allowed under the new regulations anyway?

The purchase of a home by a business is not prohibited, but its use is if it is rented by the room. In many cases, as a municipality, we only find out afterwards that a property is being used in violation of applicable regulations. And if there is no nuisance, we may not know at all.

Why must there be central housing? Why not use bed and breakfasts or hotels? These are already set up to house people.

Hotels and B&Bs serve a recreational interest. A period of three years is too long for housing people in hotels and B&Bs. This can no longer be considered recreational. By focusing on centralized housing, it is possible for the municipality to make good agreements on the way of furnishing and setting house rules.

Has the municipality also set itself the goal of housing migrant workers for other municipalities? Surely the Maasvlakte falls under the municipality of Rotterdam?

The Municipality of Voorne aan Zee only decides on housing based on applications received within its own municipality. Housing foreign workers on behalf of other municipalities is not an issue. 
 

Communication and participation

Why is there no participation?

The initiative was submitted to the municipality in August 2023, before the effective date of the Omgevingswet. This means that the municipality must also process the permit application under the old legislation. Under that legislation, the initiator is not required to have people participate prior to applying for the permit. However, the initiator did make adjustments to the plan based on residents' responses. 

What are the prerequisites for good communication by the promoter with the environment? Did the communication from a year ago meet these criteria?

Because the submitted application for an environmental permit was submitted before the Omgevingswet was enacted, there is no mandatory participation. However, as a college, we do believe it is important for such a development to properly involve the surrounding area. We ask the initiator to indicate with the documents for the permit how communication took place and how reactions were dealt with. Last year, in our opinion, communication with the surrounding area was not properly completed. The initiator did adjust the plan on a number of points based on the reactions given at that time. Instead of 250 people, a maximum of 170 people will be accommodated. The fencing of the site has also been adjusted from fences with cloth to a green fence of trees and bushes.
The promoter informed the surrounding area in October 2024 about the adjustments to his plan and organized a walk-in evening on Tuesday, Nov. 5, 2024, where about 60 local residents attended. They are concerned about the size and impact of this initiative despite the adjustments. The promoter has prepared a summary of the responses, and attached them to the documents.