SP1 – Waste prevention and re-use

Comment

Representation ID: 601

Received: 28/03/2022

Respondent: Susan Edwards

A focus on re-use/repair/hire as an option. Using community areas such as libraries as an area not only to hire books but to hire garden/decorating equipment/ power tools etc so that people do not need to buy equipment they only use once a year. The equipment can be properly maintained so that there is less of the "cheaper to buy a new one rather than repair an old one" option. Installation of water fountains/taps to enable refill of drinking vessels rather than buying plastic bottles. There are lots of ideas around to easily cut waste in a positive way.

Comment

Representation ID: 684

Received: 04/04/2022

Respondent: Newark and Sherwood District Council

Policy SP1 Waste Prevention and Re-Use
Comment:
Whilst the intentions of this policy are welcomed, it is unclear how it could be applied in
practice in the determination of planning applications. It is recommended that additional text
is added to the policy setting out how its aims will be achieved and assessed in the
determination of applications for planning permission.
Recommended Change:
Additional text should be added to the policy setting out how its aims will be achieved and
assessed in the determination of applications for planning permission, for example, stating
what information planning applications should include to demonstrate compliance with the
policy.

Comment

Representation ID: 760

Received: 30/03/2022

Respondent: Mansfield District Council

Strategic Policy 1 – Waste prevention and re-use: The council supports this policy which ensures that the waste hierarchy is considered in all development proposals and would be read alongside Policy P5 of the adopted Mansfield District Local Plan 2013-33.

Comment

Representation ID: 773

Received: 31/03/2022

Respondent: Rushcliffe Borough Council

Policy SP1 – Waste prevention and re-use
Policy SP1 states that all new developments should be designed, constructed, and operated to minimise the creation of waste, maximise the use of recycled materials, and assist with the collection, separation, sorting, recycling and recovery of waste arising from development during its use.
The supporting text makes clear that this policy will apply to proposals for non-waste development and should be considered by the local planning authority responsible for determining the application. Planning Practice Guidance on plan making states that specialist plans, such as waste plans, provide a framework for decisions involving these uses.1 It does not extend to non-waste proposals.
Whilst RBC does not object to the reduction of waste generation from non-waste developments, we question whether this development plan, which is intended to manage waste proposals, can be applied to other non-waste developments that should, instead, be determined in accordance with the development plan for the local planning authority.
Policies within these district or borough local plans should address waste generation from non-waste developments and Policy 2 (Climate Change) within RBC’s Local Plan Part 1 requires development minimise waste.

Comment

Representation ID: 788

Received: 04/04/2022

Respondent: Mick George Ltd

SP1
We support Strategic Policy SP1: Waste Prevention and Re‐use. We generally support Strategic
Policy SP2 but as set out above, we do not consider that the assessment of disposal capacity for
inert wastes has been assessed realistically. Although we accept that consideration of further capacity rests on a need to demonstrate the extent to which residual waste that cannot be recycled or recovered (part c) we consider that careful attention should be paid to the limitations of inert waste recovery sites as set out above.

Comment

Representation ID: 825

Received: 27/04/2022

Respondent: The Environment Agency

SP1 – Waste prevention and re-use
Para 7.8. “This can include measures such as using recycled materials in construction or re-using suitable construction waste on site for engineering or landscape purposes.”

The Environment Agency has legislation (permits/exemptions) for this process including Recovery Permits and U1 exemption. There is also the CL: AIRE Code of Practice (CoP) which allows the reuse of excavated materials on-site or their transfer between sites, without being classified as waste. The CoP therefore provides an alternative to the use of Permits or exemptions. However with them all the suitability of the material should always be considered.

With that in mind if materials that are potentially waste are to be used on-site, the applicant will need to ensure they can comply with the following exclusion from the Waste Framework Directive (WFD) (article 2(1) (c)) for the use of, ‘uncontaminated soil and other naturally occurring material excavated in the course of construction activities, etc.…’ Meeting these criteria will mean waste permitting requirements do not apply.
Where the applicant cannot meet the criteria, they will be required to obtain the appropriate waste permit or exemption from us.

A deposit of waste to land will either be a disposal or a recovery activity. The legal test for recovery is set out in Article 3(15) of WFD as:

• any operation the principal result of which is waste serving a useful purpose by replacing other materials which would otherwise have been used to fulfil a particular function, or waste being prepared to fulfil that function, in the plant or in the wider economy.
• We have produced guidance on the recovery test which can be viewed at https://www.gov.uk/government/publications/deposit-for-recovery-operators-environmental-permits/waste-recovery-plans-and-deposit-for-recovery-permits#how-to-apply-for-an-environmental-permit-to-permanently-deposit-waste-on-land-as-a-recovery-activity
More information on the use of waste in exempt activities can be found here: https://www.gov.uk/government/collections/waste-exemptions-using-waste
Non-waste activities are not regulated by us (i.e. activities carried out under the CL:ARE Code of Practice), however the applicant would need to decide if materials meet End of Waste or By-products criteria (as defined by the Waste Framework Directive).
The ‘Is it waste’ tool, allows you to make an assessment and can be found here: https://www.gov.uk/government/publications/isitwaste-tool-for-advice-on-the-by-products-and-end-of-waste-tests

Comment

Representation ID: 826

Received: 27/04/2022

Respondent: The Environment Agency

Para 7.9. “… where there is scope for recovery and use of heat”.

We believe that recovering energy from (residual) waste can contribute to a balanced energy policy. The recovery activities should not undermine preventing or minimising waste. The recovery activities should form part of a properly considered and appraised strategy. We consider that energy generated by incineration should be recovered as far as is practicable, for example using Combined Heat and Power (CHP) schemes. You may find the following document useful:
https://www.gov.uk/government/publications/energy-from-waste-a-guide-to-the-debate.