SP6 - Minimising the movement of Waste

Comment

Representation ID: 606

Received: 30/03/2022

Respondent: Canal & River Trust

The Canal & River Trust considers that the requirement within Policy SP6 for proposals to consider alternatives to road such as water for transport of waste to be appropriate. As Navigation Authority, the Trust is happy to discuss any proposals to use the River Trent as a sustainable transport option, including consideration of the provision of wharf facilities for loading/unloading in order to establish the feasibility of such proposals and to ensure that they meet all of our requirements as Navigation Authority. We recommend early contact with the Trust to investigate any such proposals.

Comment

Representation ID: 612

Received: 01/04/2022

Respondent: Graeme Foster

Support Policy SP6.

Comment

Representation ID: 674

Received: 31/03/2022

Respondent: Mr Christopher Taylor

Agent: Mr Andrew Barton

Para 7.48 This para is broadly supported, but it should also recognise that as the drive to divert the
remaining waste from landfill progresses across the UK, and as the EfW market matures, there
will be a requirement for more centralised EfW facilities serving relatively wide catchments
and several WPA areas. The WLP should not preclude such facilities where appropriately
sited, notwithstanding that quite possibly the majority of waste they may treat may not arise
within the WLP area.
We also note that whilst the WLP itself deals with the proximity principle in, we believe, a fair
and balanced way, para 6.1 of the WNA gets the definition of the principle and, more
significantly, the related self-sufficiency principle (as defined in the WFD), hopelessly wrong.
The self-sufficiency principle does not, as the WNA claims, relate to regionality. As para 152
of Defra’s ‘Energy-from-Waste: A Guide to the debate’ states: “ The proximity principle arises
from Article 16, “Principles of self-sufficiency and proximity”, of the revised Waste Framework
Directive (2008/98/EC), the EU legislation that governs waste management. The principle is
often over-interpreted to mean that all waste has to be managed as close to its source as
possible to the exclusion of other considerations, and that local authorities individually need
the infrastructure required to do so. This is not the case. Indeed the final part of the Article itself states, “The principles of proximity and self-sufficiency shall not mean that each Member
State has to possess the full range of final recovery facilities within that Member State”. Clearly
if not even the entire country needs to have the full range of facilities, a specific local authority
does not have to. While there is an underlying principle of waste being managed close to its
source, there is no implication of local authorities needing to be self-sufficient in handling
waste from their own area”.

Comment

Representation ID: 675

Received: 31/03/2022

Respondent: Mr Christopher Taylor

Agent: Mr Andrew Barton

Policy SP6 The first sentence of the Policy ignores the reality of transporting waste from wholly
decentralised points of arisings i.e. from households and businesses spread across the country
and county. It also does not properly reflect the wording of Strategic Objective 7, which
encourages alternatives to transport by road ‘where practical’.
It is suggested it is redrafted as follows: All waste management proposals should seek to
minimise the distances waste needs to travel and maximise the use of non-road based
transportation if and where practical.

Comment

Representation ID: 689

Received: 04/04/2022

Respondent: Newark and Sherwood District Council

Policy SP6 Minimising the Movement of Waste
Comment:
The first sentence of Policy SP6 needs to be clear that the distance waste travels from source
to the relevant waste management facility needs to be minimised, in accordance with the
proximity principle.
The second sentence of this policy sits somewhat at odds with the first sentence and it should
make clear that where more sustainable modes of transporting waste are not available, or are
not viable, proposals should seek to make the best use of the existing transport network, to
ensure that sustainable modes of transport are promoted as a first priority.
In order to not encourage the importation of waste, it is suggested that the third sentence of
this policy is worded in a negative manner.
Recommended Changes:
It is recommended that the words “from source to waste management facility, in accordance
with the proximity principle” are added after the word “travel” in the first sentence of this
policy.
It is recommended that the second sentence of this policy is amended to start with the words
“Where more sustainable modes of transport are not available, or are demonstrated to not be
viable, proposals should seek to make the best use of …”.
The word “only” should be added to the third sentence of this policy such that it states “will
only be permitted”.

Comment

Representation ID: 792

Received: 04/04/2022

Respondent: Mick George Ltd

SP8
We support Strategic Policy SP5: Climate Change. We also support Strategic Policy SP6: Minimising
the Movement of Waste. We understand the requirements to limit the movement across
administrative boundaries unnecessarily. We also support Strategic Policy SP7: Green Belt and
Strategic Policy SP8: Safeguarding Waste Management Sites.

Comment

Representation ID: 813

Received: 12/04/2022

Respondent: Shlomo Dowen

Strategic Policy SP6 should be amended to ensure that: “Waste management proposals which are likely to treat or dispose of waste from areas outside Nottinghamshire and Nottingham will only be permitted where they demonstrate that: a) the facility makes a significant contribution to the movement of waste up the waste hierarchy, and b) there are no facilities or potential sites in more sustainable locations in relation to the anticipated source of the identified waste stream, and c) there are wider social, economic or environmental sustainability
benefits that clearly support the proposal”.