6.1

Do not make a plan which is so largely reliant on the input of others to chive. Households using less in the way described is beyond the scope and capabilities of the local concils.

The vision is lovely but will require much wider participation and contribution.

On the whole Mansfield District Council is in support of the Waste Local Plan. The plan’s vision, which seeks to ensure less waste is produced by re-using resources in a circular economy with disposal being the last resort, is welcomed. Ensuring there is capacity over the plan period within appropriately located waste management facilities is important and the council supports the plan’s approach to locate larger facilities towards concentrations of population and employment (such as Mansfield (as well as Nottingham and Ashfield) as the largest town in the county). This is sustainable as it will ensure waste is processed close to where it is produced and keep transportation to a minimum, as well as providing local jobs. The council also welcomes the safeguarding of existing facilities and is encouraged to see the emphasis on wellbeing, protecting and enhancing the environment, and adapting to climate change within the vision and strategic objectives.

The following comments seek to help improve the soundness of the plan.

Following on from the council’s previous comments on the draft Waste Local Plan, our comment regarding Policy SP4 is reiterated. Policy SP4 would be used to control any new development proposals seeking to dispose of residual waste that come forward. This includes the recovery of inert waste used for restoration of mineral workings, landfill, and landraise sites, as well as the disposal of non-hazardous and hazardous waste to landfill. Part c of the policy states that in all cases, the resulting final landform, landscaping and after-uses must be designed to take account of and, where appropriate, enhance the surrounding landscape, topography and natural environment. It is questioned why the phrase “where appropriate” is required rather than the policy seeking enhancements in all cases. This seems to contradict paragraph 8.70 which later on in the document states how waste facilities, particularly disposal sites which require restoration, can enhance biodiversity and should be restored to high environmental standards. Paragraph 8.71 goes on to say that such opportunities should be maximised and biodiversity net gains achieved where possible. Paragraph 8.32 also states how disposal sites where waste is used for restoration can enhance health and wellbeing through provision (among other things) landscape improvements.

From an operational perspective, and in the context of uncertainties around the implementation of the Environment Act 2021, is there sufficient flexibility to ensure the plan remains relevant as more certainty emerges in the DEFRA guidance?

The vision / objectives could mention provision of additional recycling opportunities for households, which is a core part of the Environment Act 2021, including food and a wider range of materials to be collected at the kerbside. Likewise, paragraph 3.35 (regarding the Environment Act 2021) should highlight the targets around food waste and standardisation of recycling material collections which are likely to have major implications.

In relation to paragraph 5.23, we understand that there is a proposal to extend the current Nottinghamshire recycling input specification to that proposed in the Environment Act. If this is confirmed there is likely to be a significant increase in recycling and composting volumes. Should there have been an additional scenario with a target above the national target?

Paragraph 7.10 could be expanded to cover the suitability of private road surfaces for waste vehicles to access properties (particularly for any assisted collections, which may be required in the future).

In relation to the development management section:

• The reference to bottle banks in 8.11 is only relevant to areas without a kerbside collection (which will cover all areas once the Environment Act is rolled out);

• The text that relates to Policy DM1 (and maybe 8.27) ought to make reference to persistent organic pollutants (POPs) and their specific processing and disposal requirements.

Modification
Policy SP4 (Part 3) – remove “where appropriate”.

We would welcome further consideration of how the heritage of the area will be protected and enhanced by 2038 and what the local plan will put in place to ensure that this occurs

Our specific comments are attached in Table 1, appended to this letter.
Many thanks for the opportunity to comment on this Regulation 19 Pre-Submission version of the Nottingham City and Nottinghamshire Waste Plan, October 2023. We would like to refer you back to the comments that Historic England raised during the Regulation 18 consultation in April 2022, as largely they remain relevant.
Unfortunately, we do not consider that the Waste Plan has set out a positive strategy for the historic environment, as required by paragraph 190 of the National Planning Policy Framework (NPPF).
There are a number of questions that we have raised in our consultation response about the potential impacts/harm for the significance of the historic environment, heritage assets and their setting.
Whilst we welcome the inclusion of a specific historic environment policy, and we consider this essential, we have raised a number of concerns about specific wording issues and policy areas that are absent from inclusion.
Further, there are a number of policy areas discussed within the Plan where there is the potential for harm to the historic environment and yet there is little or no detail on how this harm can be avoided or mitigated or what measures are required in order to assess the harm. As such we find that these policy areas are not legally compliant or effective.

We would be happy to discuss these issues with the Council and consider appropriate wording that could be included within the Plan to overcome these issues and are available to enter into a Statement of Common Ground if the Councils consider this is an appropriate way forward.

If you have any questions, please contact us.

(Please see attached for table and full representation).