DM2 – Health, Wellbeing and Amenity
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 591
Received: 25/03/2022
Respondent: Coddington Parish Council
There should be transparent objective/criteria for the term ‘adequately mitigated and acceptable level’
There should be transparent objective/criteria for the term ‘adequately mitigated and acceptable level’
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 616
Received: 01/04/2022
Respondent: Graeme Foster
Support Policy DM2.
Support Policy DM2.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 655
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Paragraph 8.23
All waste related development should take account of its surroundings and be located,
designed, and operated to minimise any potentially harmful impacts, especially to air, water
and soil.
NWT disagrees with the listing of these 3 areas of natural capital, and the use of “especially”
which implies these are more important than other natural capital, such as biodiversity. It
paragraph should either have a longer and fully inclusive list of natural capital or not list any.
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: 656
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Paras 8.24 to 8.25
These paragraphs omit to mention BNG at all. It should be clear that BNG should be
maximised, and also that the biodiversity mitigation hierarchy should be rigorously
followed in all applications.
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: 657
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Paragraph 8.27
Ensuring a good standard of health, wellbeing and amenity for all existing and future occupants
of land and buildings is a core planning principle of the National Planning Policy Framework.
New and existing development should not contribute to, or be put at risk from, pollution or other
sources of nuisance or intrusion which could adversely affect health, wellbeing and local
amenity, particularly in relation to sensitive human or wildlife receptors.
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: 659
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Paragraph 8.3.
It should be noted that whilst the impacts of waste development proposals on amenity and
the environment will be considered when determining applications, the Councils will have to
assume that control processes, particularly in relation to pollution, that are the function
of other regulatory bodies will be effective. For example, it is the role of the Environmental
Permit which is issued by the Environment Agency that ensures processes and standards are
in place to prevent air and water pollution, thus protecting human health and the environment
from any potential impacts from proposals. It is therefore also recommended that applicants
seek advice from relevant regulatory bodies early on within the application process so that any
impacts and concerns can be addressed through the appropriate regulatory regimes.
NWT have serious concerns about the phrase in bold and believe it should be challenged. Whilst
this is the correct position of the WPA, we know that this is not the reality of what happens on
the ground Environment Agency downgrading 93% of prosecutions for serious pollution |
Environment Agency | The Guardian. Therefore, NWT believe the WPA should now question
whether this approach is still valid and what other measures should be taken to address the
serious risk of lack of regulation and consequent pollution events.
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: 694
Received: 04/04/2022
Respondent: Newark and Sherwood District Council
Policy DM2 Health, Wellbeing and Amenity
Comment:
Policy DM2 needs to provide clarity that it relates to both new and extended waste
management facilities and additional text should be added to achieve this.
Whilst it is accepted that the list of issues cited within the policy is not exhaustive, it is
important that consideration of the potential for migration of contamination is included
within the criteria of the policy, as set out in paragraph 8.23, and it is suggested that a further
bullet point is added in this regard.
It is also suggested that transport impacts are included within the policy as a bullet point,
rather than within the introductory text, to give all of the issues highlighted equal weight.
Recommended Change:
It is recommended that the words “and extensions to existing …” are added after “Proposals
for new …” at the start of this policy.
It is recommended that “Potential for migration of contamination” is added as a bullet point.
It is recommended that “Transport impacts” is moved from the opening paragraph of the
policy to be a bullet point.
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.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 705
Received: 07/04/2022
Respondent: Via East Midlands
DM2 - Health, Wellbeing and Amenity
Paragraph 8.23 - add the following amendments: -
‘Development should be located away from areas of important landscape character, cultural associations, heritage and nature conservation value.’
‘Facilities should be designed to fit in with their surrounding landscape or townscape and built and operated to the highest standards to minimise possible impacts such as landscape and visual impacts, noise, dust, mud, vibration, litter, odour, traffic nuisance and light pollution in order to protect local amenity.’
Comments on behalf of VIA East Midlands Landscape Team - see representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 706
Received: 07/04/2022
Respondent: Via East Midlands
DM2 - Paragraph 8.24 – amend as follows
‘Opportunities for environmental enhancement should also be informed by Local Landscape Character Assessments’
Change to:
‘Opportunities for environmental enhancement should also be informed by National, Regional and Local Landscape Character Assessments, taking note of the associated species lists’
Comments on behalf of VIA East Midlands Landscape Team - see representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 713
Received: 07/04/2022
Respondent: Via East Midlands
Paragraph 8.29 – add missing word
‘Many forms of waste management facilities are likely to require an Environmental Impact Assessment (EIA) to examine the likely significant environmental effects of what is being proposed.’
Comments on behalf of VIA East Midlands Landscape Team - see representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 725
Received: 04/04/2022
Respondent: Historic England (Midlands)
Policy DM2 Health and wellbeing
We would welcome a separate bullet point specifically relating to the need to conserve and enhance the historic environment, heritage assets and their setting. Additionally, we do not consider that the justification is sufficient for the historic environment; there is a brief mention of heritage within paragraph 8.41 but we consider that there should be a separate paragraph linking to each of the bullet points and expanding upon the policy and what is expected. We would then be able to offer advice on the specific wording for the historic environment and offer any improvements, if necessary.
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: 796
Received: 04/04/2022
Respondent: Mick George Ltd
DM2
We also support policy DM2 – Health, Wellbeing and Amenity, policy DM3 – Design of New and
Extended Waste Management Facilities, policy DM4 – Landscape Protection, policy DM5 –
Protecting and Enhancing Biodiversity, policy DM6 – Historic Environment, policy DM7 ‐ Water
resources and Flood Risk, policy DM8 – Public Access, policy DM10 – Cumulative Impacts of
Development, policy DM11 – Airfield Safeguarding, and policy DM12 ‐ Highway Safety and Vehicle
Movements/Routeing.
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.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 815
Received: 12/04/2022
Respondent: Shlomo Dowen
It is unclear why DM2 only seems focusses on amenity impacts of new facilities when impacts can also occur from the extension of existing facilities. It seems
that “Proposals for new waste management facilities” should simply be shortened to “Proposals for waste management facilities”.
The need for this change is highlighted by the supporting text for this policy, which states that: “All waste related development should take account of its surroundings and be located, designed, and operated to minimise any potentially harmful impacts, especially to air, water and soil” (emphasis added).
The need to control extended facilities is recognised in the existing Policy WCS13 which states that: “New or extended waste treatment or disposal facilities will be
supported only where it can be demonstrated that there would be no unacceptable impact on any element of environmental quality or the quality of life of those living or working nearby and where this would not result in an
unacceptable cumulative impact. All waste proposals should seek to maximise opportunities to enhance the local environment through the provision of landscape, habitat or community facilities”.
Policy DM2 should be tweaked to state: “Proposals for new waste management facilities will only be supported where…” (new word added).
This would bring it into line with the supporting text at 8.23 which states that: “All waste related development should take account of its surroundings and be
located, designed, and operated to minimise any potentially harmful impacts, specially to air, water and soil.” (emphasis added) This would also be in line with the existing policy WCS13 which states: “New or
extended waste treatment or disposal facilities will be supported only where it can be…” (emphasis added).
Only Solutions LLP’s Submission to
the Nottinghamshire and Nottingham
Waste Local Plan Consultation.
See accompanying Representations for details.