Waste Issues and Options

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Comment

Waste Issues and Options

Question 13

Representation ID: 539

Received: 07/05/2020

Respondent: Nottinghamshire Wildlife Trust

Representation Summary:

Objective 4. Community, Health and Wellbeing. The availability of wildlife-rich greenspace on people’s doorsteps is a significant factor in good physical and mental health and wellbeing , so NWT would suggest the following addition: – “to ensure any new waste facilities do not adversely impact on local amenities and quality of life from impacts such as dust, traffic, noise, odour and visual impact, and any loss of local greenspace upon which people rely for their good health and wellbeing and address local health concerns.”

Comment

Waste Issues and Options

Question 13

Representation ID: 540

Received: 07/05/2020

Respondent: Nottinghamshire Wildlife Trust

Representation Summary:

Objective 5. Meet our future needs. It is essential to emphasise that any sites should be allocated on the basis of both robust SA and EIA, so that proper comparative assessments are made at the plan-making stage. Hence NWT would suggest the following addition to the wording: “Ensuring that there is a mix of site types, sizes and locations to help us manage waste sustainably wherever possible. Meet current and future targets for recycling our waste. Safeguarding existing and/or potential future sites where appropriate and where robust SA and EIA have been undertaken to allocate those sites. Locate new waste facilities to support new residential, commercial and industrial development across the plan area.”

Comment

Waste Issues and Options

Question 14

Representation ID: 541

Received: 07/05/2020

Respondent: Nottinghamshire Wildlife Trust

Representation Summary:

NWT broadly agree with these locational priorities, but all decisions on location should always be subject to robust science based decision-making, tested through SA and EIA, so that the full range of impacts, including long distance ones such as NOx, can be properly assessed.

Comment

Waste Issues and Options

Question 15

Representation ID: 542

Received: 07/05/2020

Respondent: Nottinghamshire Wildlife Trust

Representation Summary:

In NWT’s view, using a criteria-based approach would be insufficiently robust. It is essential that a proper comparative SA of possible sites is undertaken at the same time and in a consistent manner, to ensure that the level of assessment is equal. Otherwise there is a risk of judging sites against variable criteria and contexts in the future. It is also essential to screen out unsustainable sites at an early stage, to prevent uncertainty, local concerns and potentially poor decision-making later.

Comment

Waste Issues and Options

Question 16

Representation ID: 543

Received: 07/05/2020

Respondent: Nottinghamshire Wildlife Trust

Representation Summary:

Of the scope listed, NWT would highlight the need for the follow changes and additions:

“Highways and transport • Air quality (for both human health and impacts on habitats and species)
• Green Belt • Landscape protection • Habitat and species protection and conservation.
Archaeology. Greenhouse Gas impacts • Heritage • Pollution • Noise • Flooding and water
resources • Health and wellbeing • Public rights of Way. Visual impact. Restoration and aftercare
to maximise the contribution to UK and County biodiversity targets.”

It is important to be aware of the issue of NOx and NH3 emissions from certain types of waste
facilities potentially impacting habitats. Nitrogen deposition on habitats has been identified as
the most serious pollutant of habitats across the UK and Europe and these emissions can be particularly problematic for the heathlands and calcareous grasslands found in Nottinghamshire.

Nottinghamshire has Biodiversity Opportunity Maps, (which will inform the development of a NRN map
for the County over the next 12 months), they are held by the County Council through the Biodiversity Action Group, and is it is essential that these documents are taken into account in the development of the Waste Local Plan, both to protect key areas of the network and to ensure that the location of waste sites may also contribute the Network in the long term when they are
decommissioned and restored.

NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared
to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape- scale conservation in Nottinghamshire, in line with the Lawton Review and the 25 Year Environment Plan, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not
comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.

Comment

Waste Issues and Options

Question 17

Representation ID: 544

Received: 07/05/2020

Respondent: Nottinghamshire Wildlife Trust

Representation Summary:

It is essential that up to date biodiversity information at the necessary level of detail is used to help the preparation of the Plan, both with regard to data from the NGBRC and the Biodiversity Opportunity Maps.

NWT would expect the WPAs to embed the restoration and re-creation of biodiversity into the WLP, in accordance with the requirements of the 25 Year Environment Plan and the NPPF. It is particularly important, therefore, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a waste scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Nottinghamshire in the past. So these requirements should be secured through robust planning obligations and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

For potential larger footprint waste sites NWT would expect the use of site restoration briefs at an allocation stage, as has been undertaken for the MLP. This is an exemplary and constructive approach and should be replicated in this Waste Local Plan, with the creation of priority biodiversity habitats as the primary restoration aim for all allocations and extensions.

The restoration of waste sites can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable waste sites where the substrate is acidic, and has low nutrient status. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector waste industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.

The site allocation restoration briefs should list the target priority habitats using the existing NE Natural Character Area (NCA) approach and the Biodiversity Opportunity Map, the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which may be achieved through waste site restoration, as described above:

Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows

Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches

Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.

Trent Valley and Rises:rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.

Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.

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