9. Monitoring and Implementation
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 645
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Monitoring DM5 – Protecting and Enhancing Biodiversity
Key outcomes/Strategic Objectives
To protect biodiversity from adverse impacts from waste proposals and enhance biodiversity to
achieve net gain (SO3 – The environment, SO4 – Community, Health and Wellbeing
2167m,
Significant adverse change in biodiversity assets in the County Number of planning applications
granted contrary to Natural England advice
NE do not comment on all applications, so the accuracy or the ability to measure this is
in question, and should be checked with NE.
Area of habitat loss, gain and net-gain/loss (including Habitats of Principal Importance, LBAP
habitats and designated sites)
Monitoring Method Natural England, Local Biodiversity Action Plans
Neither NE or the LBAP can monitor the figures described above. This has to be recorded
for each application in a robust way through the EcIA process and the Defra Metric.
Planning permissions decision notices and delegated or committee reports Constraints/Risks
Difficult to measure and monitor environmental quality and lack of available data
Target No planning permissions result in adverse impact on biodiversity
All planning permissions secure maximum BNG .
Trigger Point Significant number of applications approved contrary to advice from Natural
England (more than 10%)
NE do not respond to all applications, so this is not a relevant measure.
On the basis of the above, NWT require all the areas identified as of concern to be addressed,
in order to be able to support this Plan. Please do not hesitate to contact me to discuss these
matters further.
Thank you for consulting the Nottinghamshire Wildlife Trust (NWT) on the above. I apologise
for using this format of response, but the OPUS format is not straightforward to use for
responses to multiple sections and the insertion or highlighting of text. I have used bold italics
to suggest insertions of text and italics for your original text.
Overall NWT supports the principles of the Plan and we welcome the clear reiteration of the
need to move waste management urgently up the waste hierarchy. We would hope, however,
to see a stronger aim for further waste reduction and the obligation for each Local
Authority to secure ambitious waste reductions across all their work and areas of
influence.
Detailed comments in representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 733
Received: 04/04/2022
Respondent: Historic England (Midlands)
Monitoring indicators We further consider that separate objectives for the natural and historic environment would assist when coming to assessing appropriate monitoring indicators for the Plan. We consider that additional heritage indicators could be included within the Local Plan that would enable the Councils to assess if Policy DM6 is appropriate. Another indicator could be change in the number of heritage assets at risk for example.
Many thanks for consulting Historic England on the above consultation.
Please find our comments attached in Table 1; we look forward to working with the Council’s as they progress their Waste Local Plan.
We commented on this document at an earlier stage in the process, 6 May 2020, and raised several general points and signposted a range of Historic England advice on our website. Please utilise this earlier response alongside our additional comments made within this response, to allow you to have a range of advice.
We are available to offer further advice on Development Management Policy 6: Historic Environment, if you would like to take us up on this offer please contact me using the above details.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 750
Received: 05/04/2022
Respondent: Kristian Ravnkilde
Appendix 1 – Monitoring and Implementation Framework, SP2: Monitoring for Future Waste Management Provision should include monitoring waste composition because this will be important for planning the balance of waste management facilities.
I welcome the opportunity to comment on the draft plan. I am doing so in the form of an email because I find the online process cumbersome and hard to use – even though I as a rule prefer the online approach.
In general, I find the document short sighted and lacking in ambition, as well as hard to read and extract the key points from. It seems to be written and laid out specifically to discourage engagement and comments. However, I have some specific points to make:
1) I am particularly interested in anaerobic digestion of food waste in combination with sewage sludge and other suitable waste materials. The current gas price crisis highlights the opportunity to solve at least two problems at the same time, and makes it a good investment for the Pension Fund in place of fossil fuel companies. I am strongly against incineration in general, and for food waste in particular.
2) Reduction of greenhouse gases should be a key policy
3) Recycling rates should be more ambitious and specific measures should be put in place to promote waste reduction
On some of the individual parts of the document:
Circular economy, para 3.3: I support the principle of using waste as a resource, as above.
Waste hierarchy, para 3.6: Government policy requires anaerobic digestion of food waste to be considered higher in the hierarchy than incineration (and AD should be included under “recycling” not “other recovery”)
Recycling scenarios for local authority collected waste, para 5.40, Table 7: The Waste Framework Directive target of 65% by 2030 should be the minimum and the plan should aim to provide recycling facilities to at least achieve this.
Strategic Objective 1 – Acting on climate Change: (This refers to “avoiding damage to air quality, water or soil” but makes no makes no reference to limiting greenhouse gas emissions.) Representations on the previous round of consultation “suggested greenhouse gas emissions should be explicitly referenced and this objective should be connected with delivering more innovative waste solutions to meet climate change commitments”. This Strategic Objective should aim to minimise greenhouse gas emissions.
Policy SP2 – Future Waste Management Provision: Support “Priority will be given to the development of new or extended recycling, composting and anaerobic digestion facilities”. Priority should also be given to re-use and repair facilities.
Policy SP5 – Climate Change: (As with Strategic Objective 1 the policy makes no reference to greenhouse gas emissions.) Para 7.47 does say this could include “Minimise greenhouse gas emissions . . .” but this should also be included in Policy SP5. Any reference to supporting “low carbon energy” should note that incineration of waste typically emits around a tonne of CO2 for every tonne of waste and cannot be considered to be “low carbon”.
Appendix 1 – Monitoring and Implementation Framework, SP2: Monitoring for Future Waste Management Provision should include monitoring waste composition because this will be important for planning the balance of waste management facilities.
Appendix 1 – Monitoring and Implementation Framework, SP5: Monitoring for the Climate Change policy should include monitoring greenhouse gas emissions, including from landfill and incinerators.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 751
Received: 05/04/2022
Respondent: Kristian Ravnkilde
Appendix 1 – Monitoring and Implementation Framework, SP5: Monitoring for the Climate Change policy should include monitoring greenhouse gas emissions, including from landfill and incinerators.
I welcome the opportunity to comment on the draft plan. I am doing so in the form of an email because I find the online process cumbersome and hard to use – even though I as a rule prefer the online approach.
In general, I find the document short sighted and lacking in ambition, as well as hard to read and extract the key points from. It seems to be written and laid out specifically to discourage engagement and comments. However, I have some specific points to make:
1) I am particularly interested in anaerobic digestion of food waste in combination with sewage sludge and other suitable waste materials. The current gas price crisis highlights the opportunity to solve at least two problems at the same time, and makes it a good investment for the Pension Fund in place of fossil fuel companies. I am strongly against incineration in general, and for food waste in particular.
2) Reduction of greenhouse gases should be a key policy
3) Recycling rates should be more ambitious and specific measures should be put in place to promote waste reduction
On some of the individual parts of the document:
Circular economy, para 3.3: I support the principle of using waste as a resource, as above.
Waste hierarchy, para 3.6: Government policy requires anaerobic digestion of food waste to be considered higher in the hierarchy than incineration (and AD should be included under “recycling” not “other recovery”)
Recycling scenarios for local authority collected waste, para 5.40, Table 7: The Waste Framework Directive target of 65% by 2030 should be the minimum and the plan should aim to provide recycling facilities to at least achieve this.
Strategic Objective 1 – Acting on climate Change: (This refers to “avoiding damage to air quality, water or soil” but makes no makes no reference to limiting greenhouse gas emissions.) Representations on the previous round of consultation “suggested greenhouse gas emissions should be explicitly referenced and this objective should be connected with delivering more innovative waste solutions to meet climate change commitments”. This Strategic Objective should aim to minimise greenhouse gas emissions.
Policy SP2 – Future Waste Management Provision: Support “Priority will be given to the development of new or extended recycling, composting and anaerobic digestion facilities”. Priority should also be given to re-use and repair facilities.
Policy SP5 – Climate Change: (As with Strategic Objective 1 the policy makes no reference to greenhouse gas emissions.) Para 7.47 does say this could include “Minimise greenhouse gas emissions . . .” but this should also be included in Policy SP5. Any reference to supporting “low carbon energy” should note that incineration of waste typically emits around a tonne of CO2 for every tonne of waste and cannot be considered to be “low carbon”.
Appendix 1 – Monitoring and Implementation Framework, SP2: Monitoring for Future Waste Management Provision should include monitoring waste composition because this will be important for planning the balance of waste management facilities.
Appendix 1 – Monitoring and Implementation Framework, SP5: Monitoring for the Climate Change policy should include monitoring greenhouse gas emissions, including from landfill and incinerators.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 843
Received: 27/04/2022
Respondent: The Environment Agency
DM5 – Protecting and Enhancing Biodiversity
We consider that the 2nd stated target could and should be improved to read as follows:
All planning permissions bring about enhancements to biodiversity/ (20% target, 10% minimum).
Submission on behalf of Environment Agency.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 844
Received: 27/04/2022
Respondent: The Environment Agency
DM7 – Flood risk and Water Resources
We consider that the target should be amended to read as follows:
No planning permissions have detrimental impact on water resources; planning permissions enhance the status and prevent deterioration of freshwater bodies and groundwater. No planning permissions have an unacceptable impact on flooding.
Submission on behalf of Environment Agency.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 857
Received: 12/04/2022
Respondent: Shlomo Dowen
Monitoring
110. In terms of monitoring SP1 (‘Waste Prevention and re-use’), “Tonnage of
Waste arisings across all waste streams” should make it clear that each waste
stream should be monitored. It is relatively easy to monitor the LACW waste
stream.
Only Solutions LLP’s Submission to
the Nottinghamshire and Nottingham
Waste Local Plan Consultation.
See accompanying Representations for details.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 862
Received: 12/04/2022
Respondent: Shlomo Dowen
"111. In terms of monitoring SP2 (‘Future Waste Management Provision’) and SP4
(‘Managing Residual Waste’), regular compositional analysis of the residual waste
stream should be conducted in line with the methodology used to inform Defra’s
Resources and Waste Strategy Monitoring Report (as set out above) which
identified the levels of readily recyclable (including compostable), potentially
recyclable, and substitutable material within the residual waste stream. This is
useful for ensuring that future residual waste provision is suitable the generally
residual waste which would remain after recyclable is maximised, and to help
inform the need for additional recycling/composting/sorting capacity."
Only Solutions LLP’s Submission to
the Nottinghamshire and Nottingham
Waste Local Plan Consultation.
See accompanying Representations for details.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 863
Received: 12/04/2022
Respondent: Shlomo Dowen
"112. In terms of monitoring SP5 (‘Climate Change’), this should include monitoring
of all greenhouse gas (GHG) emissions reported by operators of waste sites in the
Plan Area as recording in the Environment Agency’s Pollution Inventory.50 Direct
CO2 emissions would primarily arise from waste incineration facilities."
Only Solutions LLP’s Submission to
the Nottinghamshire and Nottingham
Waste Local Plan Consultation.
See accompanying Representations for details.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 864
Received: 12/04/2022
Respondent: Shlomo Dowen
"113. We also note that the draft includes a typo, whereby ‘2167m’ is repeatedly
used in place of ‘Performance Indicator’ for the various monitoring entries"
Only Solutions LLP’s Submission to
the Nottinghamshire and Nottingham
Waste Local Plan Consultation.
See accompanying Representations for details.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 865
Received: 04/04/2022
Respondent: Nottingham Friends of the Earth
"Monitoring and Implementation Framework, SP5: Monitoring for the Climate Change policy
Monitoring should include greenhouse gas emissions, particularly from landfill and incinerators"
Monitoring and Implementation Framework, SP2: Monitoring for Future Waste Management Provision
Tonnage of waste arisings should include data required for monitoring waste composition because this will be important for planning the balance of waste management facilities.
Monitoring and Implementation Framework, SP5: Monitoring for the Climate Change policy
Monitoring should include greenhouse gas emissions, particularly from landfill and incinerators.