SP5 – Climate Change

This section should be more specific. Considering this is the section on climate change - the biggest challenge to waste management there is almost no mention of greenhouse gases. No specific targets or specific plans to achieve these targets.

Support Policy SP5.

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 explicitly 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”.

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

Please find attached Newark and Sherwood District Council’s consultation response to the Draft Waste Local Plan. Our response was
approved by the Council’s Economic Development Committee on the 23 March 2022.

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.

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.

Thank you for consulting Mansfield District Council on the above document which when adopted will provide the planning policy framework against which all proposals for new waste development will be assessed.
The council has the following comments:

VIA East Midlands Submission in respect of 'Contaminated Land'.

Representation on behalf of Mick George Ltd to the Nottingham and Nottinghamshire Draft Waste Local Plan.
See Representations.

These representations are submitted by Mick George Ltd (MGL), which is one of the largest waste
and aggregates companies in the East of England and in the East Midlands. This representation is
designed to support the promotion of Dorket Head as an inert landfill site and to make more general
comments about the strategy proposed to be adopted in the Waste Local Plan. The company has
been unable to participate in the local Plan process before now as it has only recently acquired the
rights to develop the site.

Submission on behalf of Environment Agency.

Thank you for your consultation on the above dated 28 January 2022 which was received by Natural England on 28 January 2022.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Sites of least environmental value
In accordance with the NPPF, the plan should allocate land with the least environmental or amenity value. Natural England expects sufficient evidence to be provided to justify the site selection process and to ensure sites of least environmental value are selected, e.g. land allocations should avoid designated sites and landscapes and significant areas of best and most versatile agricultural land and should consider the direct and indirect effects of development, including on land outside designated boundaries and within the setting of protected landscapes.
Designated sites
The Local Plan should set criteria based policies to ensure the protection of designated biodiversity and geological sites. Such policies should clearly distinguish between international, national and local sites1. Natural England advises that all relevant Sites of Special Scientific Interest (SSSIs), European sites (Special Areas of Conservation and Special Protect Areas) and Ramsar sites2 should be included on the proposals map for the area so they can be clearly identified in the context of proposed development allocations and policies for development. Designated sites should be protected and, where possible, enhanced.
The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can inform key decision making on strategic options and development sites. It may be necessary to outline avoidance and/or mitigation measures at the plan level, which will usually need to be considered as part of an Appropriate Assessment, including a clear direction for project level HRA work to ensure no adverse effect on the integrity of internationally designated sites. It may also be necessary for plans to provide policies for strategic or cross boundary approaches, particularly in areas where designated sites cover more than one Local Planning Authority boundary.
1 International sites include: Special Protection Areas (SPAs); Special Areas of Conservation (SACs) and Ramsar sites1. National sites include Sites of Special Scientific Interest (SSSIs) and National Nature Reserves (NNRs) Local sites include wildlife Sites or geological sites (a variety of terms are in use for local sites).
2 The following wildlife sites should also be given the same protection as European sites: potential SPAs, possible SACs, listed or proposed Ramsar sites and sites identified, or required, as compensatory measures for adverse effects on European sites

Natural England would welcome early discussion on the Habitats Regulations Assessment (HRA) of
the plan and can offer further advice as policy options are progressed.
Biodiversity and Geodiversity
The Plan should set out a strategic approach, planning positively for the creation, protection,
enhancement and management of networks of biodiversity. There should be consideration of
geodiversity conservation in terms of any geological sites and features in the wider environment.
A strategic approach for networks of biodiversity should support a similar approach for green
infrastructure (outlined below). Planning policies and decisions should contribute and enhance the
natural and local environment, as outlined in the NPPF. Plans should set out the approach to
delivering net gains for biodiversity. Net gain for biodiversity should be considered for all aspects of
the plan and development types, including transport proposals, housing and community infrastructure.
Priority habitats, ecological networks and priority and/or legally protected species
populations
The Local Plan should be underpinned by up to date environmental evidence. This should include an
assessment of existing and potential components of local ecological networks. This assessment
should inform the Sustainability Appraisal, ensure that land of least environment value is chosen for
development, and that the mitigation hierarchy is followed and inform opportunities for enhancement
as well as development requirements for particular sites.
Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural
Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Further information is available
here: Habitats and species of principal importance in England. Local Biodiversity Action Plans
(LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also
identify targets for other habitats and species of local importance and can provide a useful blueprint
for biodiversity enhancement in any particular area.
Protected species are those species protected under domestic or European law. Further information
can be found here Standing advice for protected species. Sites containing watercourses, old buildings,
significant hedgerows and substantial trees are possible habitats for protected species.
Ecological networks are coherent systems of natural habitats organised across whole landscapes so
as to maintain ecological functions. A key principle is to maintain connectivity - to enable free
movement and dispersal of wildlife e.g. badger routes, river corridors for the migration of fish and
staging posts for migratory birds. Local ecological networks will form a key part of the wider Nature
Recovery Network proposed in the 25 Year Environment Plan. Where development is proposed,
opportunities should be explored to contribute to the enhancement of ecological networks.
Planning positively for ecological networks will also contribute towards a strategic approach for the
creation, protection, enhancement and management of green infrastructure, as identified in the NPPF.
Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran
trees, there should be appropriate policies to ensure their protection. Natural England and the Forestry
Commission have produced standing advice on ancient woodland, ancient and veteran trees.
Access and Rights of Way
Natural England advises that the Plan should include policies to ensure protection and enhancement
of public rights of way and National Trails, as outlined in the NPPF. Recognition should be given to
the value of rights of way and access to the natural environment in relation to health and wellbeing
and links to the wider green infrastructure network. The plan should seek to link existing rights of way
where possible, and provides for new access opportunities. The plan should avoid building on open
space of public value as outlined in the NPPF.

Climate change adaptation
The Local Plan should consider climate change adaption and recognise the role of the natural
environment to deliver measures to reduce the effects of climate change, for example tree planting to
moderate heat island effects. In addition factors which may lead to exacerbate climate change
(through more greenhouse gases) should be avoided (e.g. pollution, habitat fragmentation, loss of
biodiversity) and the natural environment’s resilience to change should be protected. Green
Infrastructure and resilient ecological networks play an important role in aiding climate change
adaptation.
We would be happy to comment further should the need arise but if in the meantime you have any
queries please do not hesitate to contact us.
For any queries regarding this letter, for new consultations, or to provide further information on this
consultation please send your correspondences to consultations@naturalengland.org.uk.