5.24
Object
Pre- Submission Draft Waste Local Plan
Representation ID: 889
Received: 26/09/2023
Respondent: Shlomo Dowen
Legally compliant? No
Sound? No
Duty to co-operate? No
The Plan should consider reuse parks. The Draft Plan’s failure to consider reuse parks renders the Plan unsound due to not being positively prepared because it does not meet the area’s objectively assessed need to support the circular economy though the provision of waste management facilities to promote reuse in accordance with the top tiers of the waste hierarchy in line with the proposed draft SO1, SO2, and SO3.
Include references to promoting the siting of reuse parks within the Plan area, including Strategic Policies covering how we will provide for new reuse facilities, including safeguarding suitable sites for this purpose.
Assuming “that there will be no change in the most recent non-household LACW generation rate” fails to reflect relevant legal obligations and targets, as set out in our comments on Paragraph 5.23.
The Government has announced the inclusion of incineration in the UK Emissions Trading Scheme (ETS) from 2028, which can be expected to significantly reduce the quantity of residual waste produced by businesses (non-household LACW) within the Plan period.
As the UK Government put it in ‘Developing the UK Emissions Trading Scheme: Main Response’ (June 2023): “In the Call for Evidence, we proposed exploring expansion of the UK ETS to waste incineration and EfW by the mid-to-late 2020s. This was on the basis that this would align with wider reforms to resources and waste policies later this decade and would help to achieve the UK Government’s target to halve residual waste arisings (excluding major mineral wastes) on a kilogramme per capita basis by 2042 from 2019 levels”
Note: Only Solutions LLP is challenging the soundness relating to this consultation point. We have no position on legal compliance or the duty to co-operate, but there is no option to indicate this in the interactive online consultation system.
Object
Pre- Submission Draft Waste Local Plan
Representation ID: 890
Received: 26/09/2023
Respondent: Shlomo Dowen
Legally compliant? No
Sound? No
Duty to co-operate? No
Assuming “ there will be no change in the most recent non-household LACW generation rate” fails to reflect legal obligations and targets (see comments on Paragraph 5.23).
Government announced inclusion of incineration in the UK Emissions Trading Scheme (ETS) from 2028, on the basis that this would align with wider reforms to resources and waste policies and help achieve the UK Government’s target to halve residual waste arisings on a kilogramme per capita basis by 2042 from 2019 levels”, which can be expected to significantly reduce the quantity of residual waste produced by businesses (non-household LACW) within the Plan period.
The Plan should be updated to reflect the statutory target to halve residual waste per capita by 2042 relative to a 2019 base year (see comments on Paragraph 2.3) and the EIP 2023 interim targets to reduce residual waste per person by 24% by 2027 and to reduce residual municipal waste per person by 29% by 2027 (including both household waste and waste that is of similar composition to household waste), and the inclusion of incineration within the UK Emissions Trading Scheme.
Assuming “that there will be no change in the most recent non-household LACW generation rate” fails to reflect relevant legal obligations and targets, as set out in our comments on Paragraph 5.23.
The Government has announced the inclusion of incineration in the UK Emissions Trading Scheme (ETS) from 2028, which can be expected to significantly reduce the quantity of residual waste produced by businesses (non-household LACW) within the Plan period.
As the UK Government put it in ‘Developing the UK Emissions Trading Scheme: Main Response’ (June 2023): “In the Call for Evidence, we proposed exploring expansion of the UK ETS to waste incineration and EfW by the mid-to-late 2020s. This was on the basis that this would align with wider reforms to resources and waste policies later this decade and would help to achieve the UK Government’s target to halve residual waste arisings (excluding major mineral wastes) on a kilogramme per capita basis by 2042 from 2019 levels”.
Note: Only Solutions LLP is challenging the soundness and legal compliance relating to this consultation point. We have no position on the duty to co-operate, but there is no option to indicate this in the interactive online consultation system.
Note: This submission should replace our previous submission on consultation point 5.24 (ID:889).