5.26

Adopt Option A, or an alternative which better reflects Government recycling and waste reduction targets.

As set out in response to 2.3 and 5.24, the WNA failed to account for measures and targets that can be expected to boost recycling and reduce residual waste arisings from both household and non-household waste. When this is taken into account it is clear that Option A is the most realistic option.

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.

I'd like this part of the plan to base its calculation on a fall in waste produced per capita, purely on the basis of government schemes to cut waste at source by requiring producers to reduce packaging and implement return schemes. To predict similar very small reductions in waste per person, similar to the previous few years, is to ignore major changes in producer responsibility to reduce waste and will result in the calculations exaggerating the amount of waste needing to be dealt with.

I know that local government cannot do much to stop producer waste at source but surely in order to take account of government changes to producers' responsibility then waste arisings should be predicted to fall? Not predicting any fall in waste produced per person does not take into account forthcoming government legislation to cut packaging waste/return schemes/ re-use etc.

Thank you for consulting Rushcliffe Borough Council (RBC) on the Pre-Submission Draft Waste Local Plan and supporting Sustainability Appraisal Pre-Submission Draft. Having read the documents, please accept the following responses.

Policy SP1 – Waste prevention and re-use

We acknowledge that you have reviewed our previous comments, which raised concerns regarding the supporting text of Policy SP1 which suggested that Policy SP1 of the Waste Local Plan should be applied to non-waste developments which we believe should, instead, be determined in accordance with the development plan for the local planning authority.

We note that you are progressing with the same approach. We therefore wish to reiterate our previous comments.
The supporting text of Policy SP1 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 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 – such as Policy 2 (Climate Change) within RBC’s Local Plan Part 1 which requires development to minimise waste.

Forecasting future waste arising in the Plan area
We reiterate our previous comments, which question the conclusions on pages 30-32 that household waste will decrease (Scenario B (Low rate of decline)) as any decline in household residual waste (which cannot be recycled) may be off-set by the rise in the number of residents working from home. RBC are not seeing a decrease (just a smaller drop now some are returning to a mix of both office and remote).

Sustainability Appraisal Pre-Submission Draft
Having read the SA pre-submission draft, RBC has no concerns regarding the methodology and the appraisal of the vision, strategic objectives, policies and its conclusions.

If you would like to discuss our comments on the emerging plan, please feel free to contact me.

Yours sincerely