Waste Issues and Options

Dear Sir/Madam

Nottinghamshire and Nottingham Waste Local Plan – Consultation on Issues and Options

I write with regard to the above consultation, upon which Derbyshire County Council (DCC) and Derby City Council have the following comments to make which you may wish to consider.

Cross Boundary Issues
As you are aware an important element in the preparation of local plans is the requirement to meet the Duty to Co-operate, as established by the Localism Act 2011, and Section 33A of the Planning and Compulsory Purchase Act 2004. Local planning authorities now need to engage, on an ongoing basis, to develop policies in the context of strategic matters that cross administrative boundaries. Evidence of discussions on these matters, and the subsequent outcomes, should be considered to be part of the Test of Soundness which will be considered at the local plan examination.

To demonstrate on-going joint working, the National Planning Policy Framework (NPPF paragraphs 24 - 27), included the requirement for strategic policy-making authorities to prepare and maintain statements of common ground (SOCG). These should document the cross-boundary matters being addressed, and the progress in co-operating in order to address them.
Derbyshire County Council is jointly preparing a Waste Local Plan with Derby City Council. During this process a number of cross-border issues have been identified which require co-operation with your Authority under the duty to co-operate regime.

In 2018 (the most recent figures from the Waste Data Interrogator) 68,733t of waste were received in Derby and Derbyshire (D2) from Nottingham, and 111,896t from Nottinghamshire, making a total of 180,629t. The exports from D2 to Nottingham were 47,105t, and to Nottinghamshire 161,828t, totaling 208,933t (N2)

In contrast to the figure given, in 2018 just under 1,254,105 tonnes of waste was removed outside of N2. The largest quantities being sent to facilities in Derby and Leicestershire. For comparison, D2 exported 1,307,001t in the same year. As might be expected from there being similar areas, the figures are comparable.

It would appear to be beneficial for your authority to re-examine its figures in the light of current data.

With regard to the boundary which both of our authorities share, the preparation of our respective Waste Plans provide the opportunity to fulfil the duty to co-operate. We will need to work closely with each of our neighbouring, and other relevant, Waste Planning Authorities (WPAs). A key focus of this work should be to identify existing waste management capacity, and potential future shortfalls, and to identify significant patterns of waste movement, where these indicate a reliance on waste management facilities within other administrative areas.


N2 Waste Local Plan review documents
With regard to cross border movements of waste, it should be noted that in 2018 in excess of 180,00t (180,269t) was exported from N2 to D2

Waste Needs Assessment Existing Capacity
It is unclear whether or not the figure given for the total capacity makes use of the maximum potential of planning permission or permit. Some smaller sites may have a permit that allows for more than the site could physically deal with. We would like to ensure that the figures refer to the rules that were agreed with DCC regarding nominal capacity. More detail as to how the figures were calculated would be beneficial.




Sustainability Appraisal scoping report
Under “Key Findings - Energy’ there is reference to a new gas-fired station, together with the two remaining power stations. However, the Issues and Options Report (paragraph. 3.9) refers to 4 power stations.
In addition, paragraph 4.24 refers to main river catchments including the Derwent.

Miscellaneous
In Appendix 3: Contextual data mapping the ‘Transportation – railways’ map appears twice.
On page 123, the map ‘Number of HGV’s on road’ requires a time frame for the data.
In the glossary a Green Belt is defined as ‘an area of land surrounding a City.’ However, the Burton Green Belt is a wedge that separates Burton and Swadlincote.

It is hoped that you will find the above comments helpful.

Yours faithfully,

Dear Sir/Madam

Nottinghamshire and Nottingham Waste Local Plan – Consultation on Issues and Options

I write with regard to the above consultation, upon which Derbyshire County Council (DCC) and Derby City Council have the following comments to make which you may wish to consider.

Cross Boundary Issues
As you are aware an important element in the preparation of local plans is the requirement to meet the Duty to Co-operate, as established by the Localism Act 2011, and Section 33A of the Planning and Compulsory Purchase Act 2004. Local planning authorities now need to engage, on an ongoing basis, to develop policies in the context of strategic matters that cross administrative boundaries. Evidence of discussions on these matters, and the subsequent outcomes, should be considered to be part of the Test of Soundness which will be considered at the local plan examination.

To demonstrate on-going joint working, the National Planning Policy Framework (NPPF paragraphs 24 - 27), included the requirement for strategic policy-making authorities to prepare and maintain statements of common ground (SOCG). These should document the cross-boundary matters being addressed, and the progress in co-operating in order to address them.
Derbyshire County Council is jointly preparing a Waste Local Plan with Derby City Council. During this process a number of cross-border issues have been identified which require co-operation with your Authority under the duty to co-operate regime.

In 2018 (the most recent figures from the Waste Data Interrogator) 68,733t of waste were received in Derby and Derbyshire (D2) from Nottingham, and 111,896t from Nottinghamshire, making a total of 180,629t. The exports from D2 to Nottingham were 47,105t, and to Nottinghamshire 161,828t, totaling 208,933t (N2)

In contrast to the figure given, in 2018 just under 1,254,105 tonnes of waste was removed outside of N2. The largest quantities being sent to facilities in Derby and Leicestershire. For comparison, D2 exported 1,307,001t in the same year. As might be expected from there being similar areas, the figures are comparable.

It would appear to be beneficial for your authority to re-examine its figures in the light of current data.

With regard to the boundary which both of our authorities share, the preparation of our respective Waste Plans provide the opportunity to fulfil the duty to co-operate. We will need to work closely with each of our neighbouring, and other relevant, Waste Planning Authorities (WPAs). A key focus of this work should be to identify existing waste management capacity, and potential future shortfalls, and to identify significant patterns of waste movement, where these indicate a reliance on waste management facilities within other administrative areas.


N2 Waste Local Plan review documents
With regard to cross border movements of waste, it should be noted that in 2018 in excess of 180,00t (180,269t) was exported from N2 to D2

Waste Needs Assessment Existing Capacity
It is unclear whether or not the figure given for the total capacity makes use of the maximum potential of planning permission or permit. Some smaller sites may have a permit that allows for more than the site could physically deal with. We would like to ensure that the figures refer to the rules that were agreed with DCC regarding nominal capacity. More detail as to how the figures were calculated would be beneficial.




Sustainability Appraisal scoping report
Under “Key Findings - Energy’ there is reference to a new gas-fired station, together with the two remaining power stations. However, the Issues and Options Report (paragraph. 3.9) refers to 4 power stations.
In addition, paragraph 4.24 refers to main river catchments including the Derwent.

Miscellaneous
In Appendix 3: Contextual data mapping the ‘Transportation – railways’ map appears twice.
On page 123, the map ‘Number of HGV’s on road’ requires a time frame for the data.
In the glossary a Green Belt is defined as ‘an area of land surrounding a City.’ However, the Burton Green Belt is a wedge that separates Burton and Swadlincote.

It is hoped that you will find the above comments helpful.

Yours faithfully,

Dear Sir/Madam

Nottinghamshire and Nottingham Waste Local Plan – Consultation on Issues and Options

I write with regard to the above consultation, upon which Derbyshire County Council (DCC) and Derby City Council have the following comments to make which you may wish to consider.

Cross Boundary Issues
As you are aware an important element in the preparation of local plans is the requirement to meet the Duty to Co-operate, as established by the Localism Act 2011, and Section 33A of the Planning and Compulsory Purchase Act 2004. Local planning authorities now need to engage, on an ongoing basis, to develop policies in the context of strategic matters that cross administrative boundaries. Evidence of discussions on these matters, and the subsequent outcomes, should be considered to be part of the Test of Soundness which will be considered at the local plan examination.

To demonstrate on-going joint working, the National Planning Policy Framework (NPPF paragraphs 24 - 27), included the requirement for strategic policy-making authorities to prepare and maintain statements of common ground (SOCG). These should document the cross-boundary matters being addressed, and the progress in co-operating in order to address them.
Derbyshire County Council is jointly preparing a Waste Local Plan with Derby City Council. During this process a number of cross-border issues have been identified which require co-operation with your Authority under the duty to co-operate regime.

In 2018 (the most recent figures from the Waste Data Interrogator) 68,733t of waste were received in Derby and Derbyshire (D2) from Nottingham, and 111,896t from Nottinghamshire, making a total of 180,629t. The exports from D2 to Nottingham were 47,105t, and to Nottinghamshire 161,828t, totaling 208,933t (N2)

In contrast to the figure given, in 2018 just under 1,254,105 tonnes of waste was removed outside of N2. The largest quantities being sent to facilities in Derby and Leicestershire. For comparison, D2 exported 1,307,001t in the same year. As might be expected from there being similar areas, the figures are comparable.

It would appear to be beneficial for your authority to re-examine its figures in the light of current data.

With regard to the boundary which both of our authorities share, the preparation of our respective Waste Plans provide the opportunity to fulfil the duty to co-operate. We will need to work closely with each of our neighbouring, and other relevant, Waste Planning Authorities (WPAs). A key focus of this work should be to identify existing waste management capacity, and potential future shortfalls, and to identify significant patterns of waste movement, where these indicate a reliance on waste management facilities within other administrative areas.


N2 Waste Local Plan review documents
With regard to cross border movements of waste, it should be noted that in 2018 in excess of 180,00t (180,269t) was exported from N2 to D2

Waste Needs Assessment Existing Capacity
It is unclear whether or not the figure given for the total capacity makes use of the maximum potential of planning permission or permit. Some smaller sites may have a permit that allows for more than the site could physically deal with. We would like to ensure that the figures refer to the rules that were agreed with DCC regarding nominal capacity. More detail as to how the figures were calculated would be beneficial.




Sustainability Appraisal scoping report
Under “Key Findings - Energy’ there is reference to a new gas-fired station, together with the two remaining power stations. However, the Issues and Options Report (paragraph. 3.9) refers to 4 power stations.
In addition, paragraph 4.24 refers to main river catchments including the Derwent.

Miscellaneous
In Appendix 3: Contextual data mapping the ‘Transportation – railways’ map appears twice.
On page 123, the map ‘Number of HGV’s on road’ requires a time frame for the data.
In the glossary a Green Belt is defined as ‘an area of land surrounding a City.’ However, the Burton Green Belt is a wedge that separates Burton and Swadlincote.

It is hoped that you will find the above comments helpful.

Yours faithfully,