DM1 – General Site
Object
Pre- Submission Draft Waste Local Plan
Representation ID: 902
Received: 26/09/2023
Respondent: Shlomo Dowen
Legally compliant? No
Sound? No
Duty to co-operate? No
The footnote states: “*Once mineral sites are restored, these are considered green field sites”.
It is when there is an active restoration condition that it is treated as greenfield rather than previously developed land, not simply when there has been actual restoration.
The NPPF defines previously developed land, stating: “...This excludes: …land that has been developed for minerals extraction or waste disposal by landfill, where provision for restoration has been made through development management procedures...”
Note: Only Solutions LLP is challenging soundness and legal compliance.
See also decision in inquiry ref 2102006 relating to the Former Rufford Colliery.
Amend footnote to state: “This excludes land that has been developed for minerals extraction or waste disposal by landfill, where provision for restoration has been made through development management procedures”.
The footnote states: “*Once mineral sites are restored, these are considered green field sites”.
It is when there is an active restoration condition that it is treated as greenfield rather than previously developed land, not simply when there has been actual restoration.
The NPPF defines previously developed land, stating: “...This excludes: …land that has been developed for minerals extraction or waste disposal by landfill, where provision for restoration has been made through development management procedures...”
Note: Only Solutions LLP is challenging soundness and legal compliance.
See also decision in inquiry ref 2102006 relating to the Former Rufford Colliery.
Object
Pre- Submission Draft Waste Local Plan
Representation ID: 925
Received: 04/10/2023
Respondent: East Leake Parish Council
Legally compliant? Yes
Sound? Yes
Duty to co-operate? Yes
Local recycling facilities being permitted in community areas requires clarification that it’s ‘bring sites’ only.
Local recycling facilities being permitted in community areas requires clarification that it’s ‘bring sites’ only.
Grateful to be consulted on the New Waste Local Plan
Positive on:
• Greater emphasis on re-use and recycling
• Carbon Neutral by 2030
Wish to make the following comments:
• No mentions of villages, and nothing south of Clifton.
• Local recycling facilities being permitted in community areas requires clarification that it’s ‘bring sites’ only.
• Plan must be deliverable.
Redevelopment of Ratcliffe-on-Soar Power Station:
DM12
• Transport assessment prior to start 'with particular emphasis on the impact of villages along likely transport routes'
• Use of alternative modes of transport - rail, water, pipeline
• The highway network needs to be suitable to accommodate vehicle movements
• Minimise the traffic impact on local communities
Object
Pre- Submission Draft Waste Local Plan
Representation ID: 946
Received: 06/10/2023
Respondent: Mansfield District Council
Legally compliant? Yes
Sound? Yes
Duty to co-operate? Yes
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.
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”.
Support
Pre- Submission Draft Waste Local Plan
Representation ID: 960
Received: 09/10/2023
Respondent: Gedling Borough Council
No comment on the Policy. Gedling Borough Council does not consider there is any site within Gedling Borough suitable for the landfilling of non-inert waste including both hazardous and non-hazardous waste.
No comment on the Policy. Gedling Borough Council does not consider there is any site within Gedling Borough suitable for the landfilling of non-inert waste including both hazardous and non-hazardous waste.