Waste Issues and Options

Dear Sir/Madam

Re: Nottinghamshire and Nottingham Waste Local Plan

Thank you for consulting Rushcliffe Borough Council (RBC) on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options and for extending the deadline for comments during this difficult period.

Please consider the following responses to those questions asked.

Q.1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
RBC supports the proposed plan period, this corresponds with the proposed plan period for the emerging Greater Nottingham Strategic Plan (GNSP). There would be clear benefits coordinating the planning of new development and planning the recovery, recycling and disposal of the waste it would generate.

Q.2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
The overview should refer to the proposed High Speed Two railway station at Toton within Broxtowe, this has the potential to bring significant economic benefits to Nottinghamshire, especially in and around Nottingham (including Rushcliffe).

The plan should also cross refer to the Minerals Local Plan and the issues which it is addresses, notably the extraction of sand and gravel within the Trent and Idle Valleys. A reduction in demand from the construction industry for minerals, in accordance with the Waste Hierarchy, and increased recycling of minerals waste (as set in paragraph 204 of the NPPF) may have implications when planning to meet future needs.

Q.3: Do you agree with the current waste estimate? Do you have any other
information which may lead to a different waste estimate?
Table 5 Page 12 of the Preliminary Waste Needs Assessment identifies the household
projections for the Nottinghamshire authorities. Rather than identifying projections, any increase in waste from domestic properties should be based on the final local housing need figure (using the Government’s Standard Method). This applies a ratio of affordability to the household projection and consequently reflects the number of homes that are needed and that will be planned for. For example Rushcliffe has an annual
household projection of 451 (rather than 600) (based on the most recent 2014 figures) and once the 2019 affordability ratio is applied a final housing need figure of 604 homes per annum. This figure is currently being used to inform the Borough’s five year land
supply.

Q.4. Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
No comment.

Q.5. Do you agree with the scenarios set out for Local Authority Collected Waste(LACW)? Which scenario do you consider to be the most suitable on which to
base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. Given the overriding national objective of reducing the generation of waste, in accordance with the waste hierarchy, the plan should not accept and plan for a high growth in waste generation per household. RBC consider a decline in waste generation per household as the most suitable scenario. This continues the overall decline and accords with the Government’s 25 Year Environment Plan and
Waste and Resources Strategy.

Q.6. Do you agree with the scenarios set out for commercial and Industrial (C & I).
Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out for commercial and industrial waste. RBC consider no change as the most suitable scenario, this reflects the Government’s position that there will be some growth, however this growth will be off-set by increases in the production of waste and its recycling.

Q.7. Do you agree with the scenarios set out for Construction, Demolition and Excavation Waste (CDE)? Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. As set out in answer to Q.3 the Government’s Standard Method for calculating housing need indicates Rushcliffe should provide a minimum 604 homes per annum, this equates to 12,080 during the plan period (2018 to 2038). The forthcoming Growth Options consultation will put forward different options which provide some flexibility and future drafts will distribute housing across the Greater Nottingham area. This distribution should inform the Waste Local Plan.

Q.8. Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
No comment

Q.9. Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan? Do you have any evidence to
suggest that different assumptions should be made?
Rushcliffe would agree that recycling rates are likely to increase further with the introduction of separate food waste collections as outlined in the Environment Bill 2020.

Likewise the impact of any future deposit return schemes could have an effect on the kerbside collection schemes for some dry recyclables. To further increase recycling rates across Nottinghamshire further action should be given to expanding the current input specification which places restrictions on what can be delivered and recycled at the current MRF.

Q.10. What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
No comment

Q.11. Do you agree with the need to provide additional disposal capacity within the Plan Area?
Given that the one suitable landfill site is due to close within a year, RBC agree that the County should retain capacity for landfill disposal and that additional disposal capacity is likely to be required (even after reductions, recovery and recycling). The county’s waste should be disposed of as close to where it is generated as possible.

Q.12. Do you agree with the draft vision? Are there other things we should include?
RBC agree with the draft vision.

Q.13. Are the above objectives appropriate? Are there others we should consider?
RBC consider the objectives appropriate.

Q.14. What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
RBC agree with the broad locations proposed for future waste management facilities (locating new facilities close to the main urban areas where most people live with larger facilities within the Nottingham/Mansfield/Ashfield area and smaller/medium sized facilities around Worksop, Retford, and Network). A focus on urban centres can in certain cases leave gaps in provision, however. RBC is of the view that there is an urgent
need to replace the Langar facility which was closed several years ago and has left the east of Rushcliffe with no convenient household waste facility

Q.15. Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Paragraph 4 within the National Planning Policy for Waste (NPPW) states that waste planning authorities should identify, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations. Consequently, if an additional landfill capacity is required, these and larger waste recovery and recycling facilities should be identified within the plan. Their location should not be determined by criteria based policies alone.

Broader locations for smaller sites that serve local communities, could be identified according to the type of facility, for example industrial estates identified as B2 or B8 employment sites could accommodate waste collection, recovery or recycling facilities provided policy safeguards are in place to protect neighbouring businesses from access disruption, noise, dust or odours.

Q.16. What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
RBC does not propose any additional waste planning issues which require development management policies.

Q.17. Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
RBC has no other comments to make at this time and this concludes our representation on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options.

We look forward to reviewing the draft Waste Local Plan when it is published.

Yours sincerely

Dear Sir/Madam

Re: Nottinghamshire and Nottingham Waste Local Plan

Thank you for consulting Rushcliffe Borough Council (RBC) on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options and for extending the deadline for comments during this difficult period.

Please consider the following responses to those questions asked.

Q.1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
RBC supports the proposed plan period, this corresponds with the proposed plan period for the emerging Greater Nottingham Strategic Plan (GNSP). There would be clear benefits coordinating the planning of new development and planning the recovery, recycling and disposal of the waste it would generate.

Q.2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
The overview should refer to the proposed High Speed Two railway station at Toton within Broxtowe, this has the potential to bring significant economic benefits to Nottinghamshire, especially in and around Nottingham (including Rushcliffe).

The plan should also cross refer to the Minerals Local Plan and the issues which it is addresses, notably the extraction of sand and gravel within the Trent and Idle Valleys. A reduction in demand from the construction industry for minerals, in accordance with the Waste Hierarchy, and increased recycling of minerals waste (as set in paragraph 204 of the NPPF) may have implications when planning to meet future needs.

Q.3: Do you agree with the current waste estimate? Do you have any other
information which may lead to a different waste estimate?
Table 5 Page 12 of the Preliminary Waste Needs Assessment identifies the household
projections for the Nottinghamshire authorities. Rather than identifying projections, any increase in waste from domestic properties should be based on the final local housing need figure (using the Government’s Standard Method). This applies a ratio of affordability to the household projection and consequently reflects the number of homes that are needed and that will be planned for. For example Rushcliffe has an annual
household projection of 451 (rather than 600) (based on the most recent 2014 figures) and once the 2019 affordability ratio is applied a final housing need figure of 604 homes per annum. This figure is currently being used to inform the Borough’s five year land
supply.

Q.4. Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
No comment.

Q.5. Do you agree with the scenarios set out for Local Authority Collected Waste(LACW)? Which scenario do you consider to be the most suitable on which to
base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. Given the overriding national objective of reducing the generation of waste, in accordance with the waste hierarchy, the plan should not accept and plan for a high growth in waste generation per household. RBC consider a decline in waste generation per household as the most suitable scenario. This continues the overall decline and accords with the Government’s 25 Year Environment Plan and
Waste and Resources Strategy.

Q.6. Do you agree with the scenarios set out for commercial and Industrial (C & I).
Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out for commercial and industrial waste. RBC consider no change as the most suitable scenario, this reflects the Government’s position that there will be some growth, however this growth will be off-set by increases in the production of waste and its recycling.

Q.7. Do you agree with the scenarios set out for Construction, Demolition and Excavation Waste (CDE)? Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. As set out in answer to Q.3 the Government’s Standard Method for calculating housing need indicates Rushcliffe should provide a minimum 604 homes per annum, this equates to 12,080 during the plan period (2018 to 2038). The forthcoming Growth Options consultation will put forward different options which provide some flexibility and future drafts will distribute housing across the Greater Nottingham area. This distribution should inform the Waste Local Plan.

Q.8. Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
No comment

Q.9. Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan? Do you have any evidence to
suggest that different assumptions should be made?
Rushcliffe would agree that recycling rates are likely to increase further with the introduction of separate food waste collections as outlined in the Environment Bill 2020.

Likewise the impact of any future deposit return schemes could have an effect on the kerbside collection schemes for some dry recyclables. To further increase recycling rates across Nottinghamshire further action should be given to expanding the current input specification which places restrictions on what can be delivered and recycled at the current MRF.

Q.10. What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
No comment

Q.11. Do you agree with the need to provide additional disposal capacity within the Plan Area?
Given that the one suitable landfill site is due to close within a year, RBC agree that the County should retain capacity for landfill disposal and that additional disposal capacity is likely to be required (even after reductions, recovery and recycling). The county’s waste should be disposed of as close to where it is generated as possible.

Q.12. Do you agree with the draft vision? Are there other things we should include?
RBC agree with the draft vision.

Q.13. Are the above objectives appropriate? Are there others we should consider?
RBC consider the objectives appropriate.

Q.14. What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
RBC agree with the broad locations proposed for future waste management facilities (locating new facilities close to the main urban areas where most people live with larger facilities within the Nottingham/Mansfield/Ashfield area and smaller/medium sized facilities around Worksop, Retford, and Network). A focus on urban centres can in certain cases leave gaps in provision, however. RBC is of the view that there is an urgent
need to replace the Langar facility which was closed several years ago and has left the east of Rushcliffe with no convenient household waste facility

Q.15. Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Paragraph 4 within the National Planning Policy for Waste (NPPW) states that waste planning authorities should identify, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations. Consequently, if an additional landfill capacity is required, these and larger waste recovery and recycling facilities should be identified within the plan. Their location should not be determined by criteria based policies alone.

Broader locations for smaller sites that serve local communities, could be identified according to the type of facility, for example industrial estates identified as B2 or B8 employment sites could accommodate waste collection, recovery or recycling facilities provided policy safeguards are in place to protect neighbouring businesses from access disruption, noise, dust or odours.

Q.16. What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
RBC does not propose any additional waste planning issues which require development management policies.

Q.17. Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
RBC has no other comments to make at this time and this concludes our representation on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options.

We look forward to reviewing the draft Waste Local Plan when it is published.

Yours sincerely

Dear Sir/Madam

Re: Nottinghamshire and Nottingham Waste Local Plan

Thank you for consulting Rushcliffe Borough Council (RBC) on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options and for extending the deadline for comments during this difficult period.

Please consider the following responses to those questions asked.

Q.1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
RBC supports the proposed plan period, this corresponds with the proposed plan period for the emerging Greater Nottingham Strategic Plan (GNSP). There would be clear benefits coordinating the planning of new development and planning the recovery, recycling and disposal of the waste it would generate.

Q.2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
The overview should refer to the proposed High Speed Two railway station at Toton within Broxtowe, this has the potential to bring significant economic benefits to Nottinghamshire, especially in and around Nottingham (including Rushcliffe).

The plan should also cross refer to the Minerals Local Plan and the issues which it is addresses, notably the extraction of sand and gravel within the Trent and Idle Valleys. A reduction in demand from the construction industry for minerals, in accordance with the Waste Hierarchy, and increased recycling of minerals waste (as set in paragraph 204 of the NPPF) may have implications when planning to meet future needs.

Q.3: Do you agree with the current waste estimate? Do you have any other
information which may lead to a different waste estimate?
Table 5 Page 12 of the Preliminary Waste Needs Assessment identifies the household
projections for the Nottinghamshire authorities. Rather than identifying projections, any increase in waste from domestic properties should be based on the final local housing need figure (using the Government’s Standard Method). This applies a ratio of affordability to the household projection and consequently reflects the number of homes that are needed and that will be planned for. For example Rushcliffe has an annual
household projection of 451 (rather than 600) (based on the most recent 2014 figures) and once the 2019 affordability ratio is applied a final housing need figure of 604 homes per annum. This figure is currently being used to inform the Borough’s five year land
supply.

Q.4. Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
No comment.

Q.5. Do you agree with the scenarios set out for Local Authority Collected Waste(LACW)? Which scenario do you consider to be the most suitable on which to
base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. Given the overriding national objective of reducing the generation of waste, in accordance with the waste hierarchy, the plan should not accept and plan for a high growth in waste generation per household. RBC consider a decline in waste generation per household as the most suitable scenario. This continues the overall decline and accords with the Government’s 25 Year Environment Plan and
Waste and Resources Strategy.

Q.6. Do you agree with the scenarios set out for commercial and Industrial (C & I).
Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out for commercial and industrial waste. RBC consider no change as the most suitable scenario, this reflects the Government’s position that there will be some growth, however this growth will be off-set by increases in the production of waste and its recycling.

Q.7. Do you agree with the scenarios set out for Construction, Demolition and Excavation Waste (CDE)? Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. As set out in answer to Q.3 the Government’s Standard Method for calculating housing need indicates Rushcliffe should provide a minimum 604 homes per annum, this equates to 12,080 during the plan period (2018 to 2038). The forthcoming Growth Options consultation will put forward different options which provide some flexibility and future drafts will distribute housing across the Greater Nottingham area. This distribution should inform the Waste Local Plan.

Q.8. Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
No comment

Q.9. Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan? Do you have any evidence to
suggest that different assumptions should be made?
Rushcliffe would agree that recycling rates are likely to increase further with the introduction of separate food waste collections as outlined in the Environment Bill 2020.

Likewise the impact of any future deposit return schemes could have an effect on the kerbside collection schemes for some dry recyclables. To further increase recycling rates across Nottinghamshire further action should be given to expanding the current input specification which places restrictions on what can be delivered and recycled at the current MRF.

Q.10. What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
No comment

Q.11. Do you agree with the need to provide additional disposal capacity within the Plan Area?
Given that the one suitable landfill site is due to close within a year, RBC agree that the County should retain capacity for landfill disposal and that additional disposal capacity is likely to be required (even after reductions, recovery and recycling). The county’s waste should be disposed of as close to where it is generated as possible.

Q.12. Do you agree with the draft vision? Are there other things we should include?
RBC agree with the draft vision.

Q.13. Are the above objectives appropriate? Are there others we should consider?
RBC consider the objectives appropriate.

Q.14. What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
RBC agree with the broad locations proposed for future waste management facilities (locating new facilities close to the main urban areas where most people live with larger facilities within the Nottingham/Mansfield/Ashfield area and smaller/medium sized facilities around Worksop, Retford, and Network). A focus on urban centres can in certain cases leave gaps in provision, however. RBC is of the view that there is an urgent
need to replace the Langar facility which was closed several years ago and has left the east of Rushcliffe with no convenient household waste facility

Q.15. Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Paragraph 4 within the National Planning Policy for Waste (NPPW) states that waste planning authorities should identify, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations. Consequently, if an additional landfill capacity is required, these and larger waste recovery and recycling facilities should be identified within the plan. Their location should not be determined by criteria based policies alone.

Broader locations for smaller sites that serve local communities, could be identified according to the type of facility, for example industrial estates identified as B2 or B8 employment sites could accommodate waste collection, recovery or recycling facilities provided policy safeguards are in place to protect neighbouring businesses from access disruption, noise, dust or odours.

Q.16. What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
RBC does not propose any additional waste planning issues which require development management policies.

Q.17. Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
RBC has no other comments to make at this time and this concludes our representation on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options.

We look forward to reviewing the draft Waste Local Plan when it is published.

Yours sincerely

Dear Sir/Madam

Re: Nottinghamshire and Nottingham Waste Local Plan

Thank you for consulting Rushcliffe Borough Council (RBC) on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options and for extending the deadline for comments during this difficult period.

Please consider the following responses to those questions asked.

Q.1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
RBC supports the proposed plan period, this corresponds with the proposed plan period for the emerging Greater Nottingham Strategic Plan (GNSP). There would be clear benefits coordinating the planning of new development and planning the recovery, recycling and disposal of the waste it would generate.

Q.2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
The overview should refer to the proposed High Speed Two railway station at Toton within Broxtowe, this has the potential to bring significant economic benefits to Nottinghamshire, especially in and around Nottingham (including Rushcliffe).

The plan should also cross refer to the Minerals Local Plan and the issues which it is addresses, notably the extraction of sand and gravel within the Trent and Idle Valleys. A reduction in demand from the construction industry for minerals, in accordance with the Waste Hierarchy, and increased recycling of minerals waste (as set in paragraph 204 of the NPPF) may have implications when planning to meet future needs.

Q.3: Do you agree with the current waste estimate? Do you have any other
information which may lead to a different waste estimate?
Table 5 Page 12 of the Preliminary Waste Needs Assessment identifies the household
projections for the Nottinghamshire authorities. Rather than identifying projections, any increase in waste from domestic properties should be based on the final local housing need figure (using the Government’s Standard Method). This applies a ratio of affordability to the household projection and consequently reflects the number of homes that are needed and that will be planned for. For example Rushcliffe has an annual
household projection of 451 (rather than 600) (based on the most recent 2014 figures) and once the 2019 affordability ratio is applied a final housing need figure of 604 homes per annum. This figure is currently being used to inform the Borough’s five year land
supply.

Q.4. Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
No comment.

Q.5. Do you agree with the scenarios set out for Local Authority Collected Waste(LACW)? Which scenario do you consider to be the most suitable on which to
base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. Given the overriding national objective of reducing the generation of waste, in accordance with the waste hierarchy, the plan should not accept and plan for a high growth in waste generation per household. RBC consider a decline in waste generation per household as the most suitable scenario. This continues the overall decline and accords with the Government’s 25 Year Environment Plan and
Waste and Resources Strategy.

Q.6. Do you agree with the scenarios set out for commercial and Industrial (C & I).
Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out for commercial and industrial waste. RBC consider no change as the most suitable scenario, this reflects the Government’s position that there will be some growth, however this growth will be off-set by increases in the production of waste and its recycling.

Q.7. Do you agree with the scenarios set out for Construction, Demolition and Excavation Waste (CDE)? Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. As set out in answer to Q.3 the Government’s Standard Method for calculating housing need indicates Rushcliffe should provide a minimum 604 homes per annum, this equates to 12,080 during the plan period (2018 to 2038). The forthcoming Growth Options consultation will put forward different options which provide some flexibility and future drafts will distribute housing across the Greater Nottingham area. This distribution should inform the Waste Local Plan.

Q.8. Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
No comment

Q.9. Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan? Do you have any evidence to
suggest that different assumptions should be made?
Rushcliffe would agree that recycling rates are likely to increase further with the introduction of separate food waste collections as outlined in the Environment Bill 2020.

Likewise the impact of any future deposit return schemes could have an effect on the kerbside collection schemes for some dry recyclables. To further increase recycling rates across Nottinghamshire further action should be given to expanding the current input specification which places restrictions on what can be delivered and recycled at the current MRF.

Q.10. What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
No comment

Q.11. Do you agree with the need to provide additional disposal capacity within the Plan Area?
Given that the one suitable landfill site is due to close within a year, RBC agree that the County should retain capacity for landfill disposal and that additional disposal capacity is likely to be required (even after reductions, recovery and recycling). The county’s waste should be disposed of as close to where it is generated as possible.

Q.12. Do you agree with the draft vision? Are there other things we should include?
RBC agree with the draft vision.

Q.13. Are the above objectives appropriate? Are there others we should consider?
RBC consider the objectives appropriate.

Q.14. What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
RBC agree with the broad locations proposed for future waste management facilities (locating new facilities close to the main urban areas where most people live with larger facilities within the Nottingham/Mansfield/Ashfield area and smaller/medium sized facilities around Worksop, Retford, and Network). A focus on urban centres can in certain cases leave gaps in provision, however. RBC is of the view that there is an urgent
need to replace the Langar facility which was closed several years ago and has left the east of Rushcliffe with no convenient household waste facility

Q.15. Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Paragraph 4 within the National Planning Policy for Waste (NPPW) states that waste planning authorities should identify, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations. Consequently, if an additional landfill capacity is required, these and larger waste recovery and recycling facilities should be identified within the plan. Their location should not be determined by criteria based policies alone.

Broader locations for smaller sites that serve local communities, could be identified according to the type of facility, for example industrial estates identified as B2 or B8 employment sites could accommodate waste collection, recovery or recycling facilities provided policy safeguards are in place to protect neighbouring businesses from access disruption, noise, dust or odours.

Q.16. What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
RBC does not propose any additional waste planning issues which require development management policies.

Q.17. Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
RBC has no other comments to make at this time and this concludes our representation on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options.

We look forward to reviewing the draft Waste Local Plan when it is published.

Yours sincerely

Dear Sir/Madam

Re: Nottinghamshire and Nottingham Waste Local Plan

Thank you for consulting Rushcliffe Borough Council (RBC) on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options and for extending the deadline for comments during this difficult period.

Please consider the following responses to those questions asked.

Q.1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
RBC supports the proposed plan period, this corresponds with the proposed plan period for the emerging Greater Nottingham Strategic Plan (GNSP). There would be clear benefits coordinating the planning of new development and planning the recovery, recycling and disposal of the waste it would generate.

Q.2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
The overview should refer to the proposed High Speed Two railway station at Toton within Broxtowe, this has the potential to bring significant economic benefits to Nottinghamshire, especially in and around Nottingham (including Rushcliffe).

The plan should also cross refer to the Minerals Local Plan and the issues which it is addresses, notably the extraction of sand and gravel within the Trent and Idle Valleys. A reduction in demand from the construction industry for minerals, in accordance with the Waste Hierarchy, and increased recycling of minerals waste (as set in paragraph 204 of the NPPF) may have implications when planning to meet future needs.

Q.3: Do you agree with the current waste estimate? Do you have any other
information which may lead to a different waste estimate?
Table 5 Page 12 of the Preliminary Waste Needs Assessment identifies the household
projections for the Nottinghamshire authorities. Rather than identifying projections, any increase in waste from domestic properties should be based on the final local housing need figure (using the Government’s Standard Method). This applies a ratio of affordability to the household projection and consequently reflects the number of homes that are needed and that will be planned for. For example Rushcliffe has an annual
household projection of 451 (rather than 600) (based on the most recent 2014 figures) and once the 2019 affordability ratio is applied a final housing need figure of 604 homes per annum. This figure is currently being used to inform the Borough’s five year land
supply.

Q.4. Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
No comment.

Q.5. Do you agree with the scenarios set out for Local Authority Collected Waste(LACW)? Which scenario do you consider to be the most suitable on which to
base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. Given the overriding national objective of reducing the generation of waste, in accordance with the waste hierarchy, the plan should not accept and plan for a high growth in waste generation per household. RBC consider a decline in waste generation per household as the most suitable scenario. This continues the overall decline and accords with the Government’s 25 Year Environment Plan and
Waste and Resources Strategy.

Q.6. Do you agree with the scenarios set out for commercial and Industrial (C & I).
Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out for commercial and industrial waste. RBC consider no change as the most suitable scenario, this reflects the Government’s position that there will be some growth, however this growth will be off-set by increases in the production of waste and its recycling.

Q.7. Do you agree with the scenarios set out for Construction, Demolition and Excavation Waste (CDE)? Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. As set out in answer to Q.3 the Government’s Standard Method for calculating housing need indicates Rushcliffe should provide a minimum 604 homes per annum, this equates to 12,080 during the plan period (2018 to 2038). The forthcoming Growth Options consultation will put forward different options which provide some flexibility and future drafts will distribute housing across the Greater Nottingham area. This distribution should inform the Waste Local Plan.

Q.8. Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
No comment

Q.9. Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan? Do you have any evidence to
suggest that different assumptions should be made?
Rushcliffe would agree that recycling rates are likely to increase further with the introduction of separate food waste collections as outlined in the Environment Bill 2020.

Likewise the impact of any future deposit return schemes could have an effect on the kerbside collection schemes for some dry recyclables. To further increase recycling rates across Nottinghamshire further action should be given to expanding the current input specification which places restrictions on what can be delivered and recycled at the current MRF.

Q.10. What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
No comment

Q.11. Do you agree with the need to provide additional disposal capacity within the Plan Area?
Given that the one suitable landfill site is due to close within a year, RBC agree that the County should retain capacity for landfill disposal and that additional disposal capacity is likely to be required (even after reductions, recovery and recycling). The county’s waste should be disposed of as close to where it is generated as possible.

Q.12. Do you agree with the draft vision? Are there other things we should include?
RBC agree with the draft vision.

Q.13. Are the above objectives appropriate? Are there others we should consider?
RBC consider the objectives appropriate.

Q.14. What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
RBC agree with the broad locations proposed for future waste management facilities (locating new facilities close to the main urban areas where most people live with larger facilities within the Nottingham/Mansfield/Ashfield area and smaller/medium sized facilities around Worksop, Retford, and Network). A focus on urban centres can in certain cases leave gaps in provision, however. RBC is of the view that there is an urgent
need to replace the Langar facility which was closed several years ago and has left the east of Rushcliffe with no convenient household waste facility

Q.15. Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Paragraph 4 within the National Planning Policy for Waste (NPPW) states that waste planning authorities should identify, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations. Consequently, if an additional landfill capacity is required, these and larger waste recovery and recycling facilities should be identified within the plan. Their location should not be determined by criteria based policies alone.

Broader locations for smaller sites that serve local communities, could be identified according to the type of facility, for example industrial estates identified as B2 or B8 employment sites could accommodate waste collection, recovery or recycling facilities provided policy safeguards are in place to protect neighbouring businesses from access disruption, noise, dust or odours.

Q.16. What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
RBC does not propose any additional waste planning issues which require development management policies.

Q.17. Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
RBC has no other comments to make at this time and this concludes our representation on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options.

We look forward to reviewing the draft Waste Local Plan when it is published.

Yours sincerely

Dear Sir/Madam

Re: Nottinghamshire and Nottingham Waste Local Plan

Thank you for consulting Rushcliffe Borough Council (RBC) on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options and for extending the deadline for comments during this difficult period.

Please consider the following responses to those questions asked.

Q.1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
RBC supports the proposed plan period, this corresponds with the proposed plan period for the emerging Greater Nottingham Strategic Plan (GNSP). There would be clear benefits coordinating the planning of new development and planning the recovery, recycling and disposal of the waste it would generate.

Q.2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
The overview should refer to the proposed High Speed Two railway station at Toton within Broxtowe, this has the potential to bring significant economic benefits to Nottinghamshire, especially in and around Nottingham (including Rushcliffe).

The plan should also cross refer to the Minerals Local Plan and the issues which it is addresses, notably the extraction of sand and gravel within the Trent and Idle Valleys. A reduction in demand from the construction industry for minerals, in accordance with the Waste Hierarchy, and increased recycling of minerals waste (as set in paragraph 204 of the NPPF) may have implications when planning to meet future needs.

Q.3: Do you agree with the current waste estimate? Do you have any other
information which may lead to a different waste estimate?
Table 5 Page 12 of the Preliminary Waste Needs Assessment identifies the household
projections for the Nottinghamshire authorities. Rather than identifying projections, any increase in waste from domestic properties should be based on the final local housing need figure (using the Government’s Standard Method). This applies a ratio of affordability to the household projection and consequently reflects the number of homes that are needed and that will be planned for. For example Rushcliffe has an annual
household projection of 451 (rather than 600) (based on the most recent 2014 figures) and once the 2019 affordability ratio is applied a final housing need figure of 604 homes per annum. This figure is currently being used to inform the Borough’s five year land
supply.

Q.4. Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
No comment.

Q.5. Do you agree with the scenarios set out for Local Authority Collected Waste(LACW)? Which scenario do you consider to be the most suitable on which to
base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. Given the overriding national objective of reducing the generation of waste, in accordance with the waste hierarchy, the plan should not accept and plan for a high growth in waste generation per household. RBC consider a decline in waste generation per household as the most suitable scenario. This continues the overall decline and accords with the Government’s 25 Year Environment Plan and
Waste and Resources Strategy.

Q.6. Do you agree with the scenarios set out for commercial and Industrial (C & I).
Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out for commercial and industrial waste. RBC consider no change as the most suitable scenario, this reflects the Government’s position that there will be some growth, however this growth will be off-set by increases in the production of waste and its recycling.

Q.7. Do you agree with the scenarios set out for Construction, Demolition and Excavation Waste (CDE)? Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. As set out in answer to Q.3 the Government’s Standard Method for calculating housing need indicates Rushcliffe should provide a minimum 604 homes per annum, this equates to 12,080 during the plan period (2018 to 2038). The forthcoming Growth Options consultation will put forward different options which provide some flexibility and future drafts will distribute housing across the Greater Nottingham area. This distribution should inform the Waste Local Plan.

Q.8. Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
No comment

Q.9. Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan? Do you have any evidence to
suggest that different assumptions should be made?
Rushcliffe would agree that recycling rates are likely to increase further with the introduction of separate food waste collections as outlined in the Environment Bill 2020.

Likewise the impact of any future deposit return schemes could have an effect on the kerbside collection schemes for some dry recyclables. To further increase recycling rates across Nottinghamshire further action should be given to expanding the current input specification which places restrictions on what can be delivered and recycled at the current MRF.

Q.10. What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
No comment

Q.11. Do you agree with the need to provide additional disposal capacity within the Plan Area?
Given that the one suitable landfill site is due to close within a year, RBC agree that the County should retain capacity for landfill disposal and that additional disposal capacity is likely to be required (even after reductions, recovery and recycling). The county’s waste should be disposed of as close to where it is generated as possible.

Q.12. Do you agree with the draft vision? Are there other things we should include?
RBC agree with the draft vision.

Q.13. Are the above objectives appropriate? Are there others we should consider?
RBC consider the objectives appropriate.

Q.14. What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
RBC agree with the broad locations proposed for future waste management facilities (locating new facilities close to the main urban areas where most people live with larger facilities within the Nottingham/Mansfield/Ashfield area and smaller/medium sized facilities around Worksop, Retford, and Network). A focus on urban centres can in certain cases leave gaps in provision, however. RBC is of the view that there is an urgent
need to replace the Langar facility which was closed several years ago and has left the east of Rushcliffe with no convenient household waste facility

Q.15. Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Paragraph 4 within the National Planning Policy for Waste (NPPW) states that waste planning authorities should identify, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations. Consequently, if an additional landfill capacity is required, these and larger waste recovery and recycling facilities should be identified within the plan. Their location should not be determined by criteria based policies alone.

Broader locations for smaller sites that serve local communities, could be identified according to the type of facility, for example industrial estates identified as B2 or B8 employment sites could accommodate waste collection, recovery or recycling facilities provided policy safeguards are in place to protect neighbouring businesses from access disruption, noise, dust or odours.

Q.16. What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
RBC does not propose any additional waste planning issues which require development management policies.

Q.17. Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
RBC has no other comments to make at this time and this concludes our representation on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options.

We look forward to reviewing the draft Waste Local Plan when it is published.

Yours sincerely

Dear Sir/Madam

Re: Nottinghamshire and Nottingham Waste Local Plan

Thank you for consulting Rushcliffe Borough Council (RBC) on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options and for extending the deadline for comments during this difficult period.

Please consider the following responses to those questions asked.

Q.1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
RBC supports the proposed plan period, this corresponds with the proposed plan period for the emerging Greater Nottingham Strategic Plan (GNSP). There would be clear benefits coordinating the planning of new development and planning the recovery, recycling and disposal of the waste it would generate.

Q.2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
The overview should refer to the proposed High Speed Two railway station at Toton within Broxtowe, this has the potential to bring significant economic benefits to Nottinghamshire, especially in and around Nottingham (including Rushcliffe).

The plan should also cross refer to the Minerals Local Plan and the issues which it is addresses, notably the extraction of sand and gravel within the Trent and Idle Valleys. A reduction in demand from the construction industry for minerals, in accordance with the Waste Hierarchy, and increased recycling of minerals waste (as set in paragraph 204 of the NPPF) may have implications when planning to meet future needs.

Q.3: Do you agree with the current waste estimate? Do you have any other
information which may lead to a different waste estimate?
Table 5 Page 12 of the Preliminary Waste Needs Assessment identifies the household
projections for the Nottinghamshire authorities. Rather than identifying projections, any increase in waste from domestic properties should be based on the final local housing need figure (using the Government’s Standard Method). This applies a ratio of affordability to the household projection and consequently reflects the number of homes that are needed and that will be planned for. For example Rushcliffe has an annual
household projection of 451 (rather than 600) (based on the most recent 2014 figures) and once the 2019 affordability ratio is applied a final housing need figure of 604 homes per annum. This figure is currently being used to inform the Borough’s five year land
supply.

Q.4. Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
No comment.

Q.5. Do you agree with the scenarios set out for Local Authority Collected Waste(LACW)? Which scenario do you consider to be the most suitable on which to
base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. Given the overriding national objective of reducing the generation of waste, in accordance with the waste hierarchy, the plan should not accept and plan for a high growth in waste generation per household. RBC consider a decline in waste generation per household as the most suitable scenario. This continues the overall decline and accords with the Government’s 25 Year Environment Plan and
Waste and Resources Strategy.

Q.6. Do you agree with the scenarios set out for commercial and Industrial (C & I).
Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out for commercial and industrial waste. RBC consider no change as the most suitable scenario, this reflects the Government’s position that there will be some growth, however this growth will be off-set by increases in the production of waste and its recycling.

Q.7. Do you agree with the scenarios set out for Construction, Demolition and Excavation Waste (CDE)? Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. As set out in answer to Q.3 the Government’s Standard Method for calculating housing need indicates Rushcliffe should provide a minimum 604 homes per annum, this equates to 12,080 during the plan period (2018 to 2038). The forthcoming Growth Options consultation will put forward different options which provide some flexibility and future drafts will distribute housing across the Greater Nottingham area. This distribution should inform the Waste Local Plan.

Q.8. Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
No comment

Q.9. Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan? Do you have any evidence to
suggest that different assumptions should be made?
Rushcliffe would agree that recycling rates are likely to increase further with the introduction of separate food waste collections as outlined in the Environment Bill 2020.

Likewise the impact of any future deposit return schemes could have an effect on the kerbside collection schemes for some dry recyclables. To further increase recycling rates across Nottinghamshire further action should be given to expanding the current input specification which places restrictions on what can be delivered and recycled at the current MRF.

Q.10. What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
No comment

Q.11. Do you agree with the need to provide additional disposal capacity within the Plan Area?
Given that the one suitable landfill site is due to close within a year, RBC agree that the County should retain capacity for landfill disposal and that additional disposal capacity is likely to be required (even after reductions, recovery and recycling). The county’s waste should be disposed of as close to where it is generated as possible.

Q.12. Do you agree with the draft vision? Are there other things we should include?
RBC agree with the draft vision.

Q.13. Are the above objectives appropriate? Are there others we should consider?
RBC consider the objectives appropriate.

Q.14. What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
RBC agree with the broad locations proposed for future waste management facilities (locating new facilities close to the main urban areas where most people live with larger facilities within the Nottingham/Mansfield/Ashfield area and smaller/medium sized facilities around Worksop, Retford, and Network). A focus on urban centres can in certain cases leave gaps in provision, however. RBC is of the view that there is an urgent
need to replace the Langar facility which was closed several years ago and has left the east of Rushcliffe with no convenient household waste facility

Q.15. Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Paragraph 4 within the National Planning Policy for Waste (NPPW) states that waste planning authorities should identify, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations. Consequently, if an additional landfill capacity is required, these and larger waste recovery and recycling facilities should be identified within the plan. Their location should not be determined by criteria based policies alone.

Broader locations for smaller sites that serve local communities, could be identified according to the type of facility, for example industrial estates identified as B2 or B8 employment sites could accommodate waste collection, recovery or recycling facilities provided policy safeguards are in place to protect neighbouring businesses from access disruption, noise, dust or odours.

Q.16. What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
RBC does not propose any additional waste planning issues which require development management policies.

Q.17. Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
RBC has no other comments to make at this time and this concludes our representation on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options.

We look forward to reviewing the draft Waste Local Plan when it is published.

Yours sincerely

Dear Sir/Madam

Re: Nottinghamshire and Nottingham Waste Local Plan

Thank you for consulting Rushcliffe Borough Council (RBC) on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options and for extending the deadline for comments during this difficult period.

Please consider the following responses to those questions asked.

Q.1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
RBC supports the proposed plan period, this corresponds with the proposed plan period for the emerging Greater Nottingham Strategic Plan (GNSP). There would be clear benefits coordinating the planning of new development and planning the recovery, recycling and disposal of the waste it would generate.

Q.2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
The overview should refer to the proposed High Speed Two railway station at Toton within Broxtowe, this has the potential to bring significant economic benefits to Nottinghamshire, especially in and around Nottingham (including Rushcliffe).

The plan should also cross refer to the Minerals Local Plan and the issues which it is addresses, notably the extraction of sand and gravel within the Trent and Idle Valleys. A reduction in demand from the construction industry for minerals, in accordance with the Waste Hierarchy, and increased recycling of minerals waste (as set in paragraph 204 of the NPPF) may have implications when planning to meet future needs.

Q.3: Do you agree with the current waste estimate? Do you have any other
information which may lead to a different waste estimate?
Table 5 Page 12 of the Preliminary Waste Needs Assessment identifies the household
projections for the Nottinghamshire authorities. Rather than identifying projections, any increase in waste from domestic properties should be based on the final local housing need figure (using the Government’s Standard Method). This applies a ratio of affordability to the household projection and consequently reflects the number of homes that are needed and that will be planned for. For example Rushcliffe has an annual
household projection of 451 (rather than 600) (based on the most recent 2014 figures) and once the 2019 affordability ratio is applied a final housing need figure of 604 homes per annum. This figure is currently being used to inform the Borough’s five year land
supply.

Q.4. Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
No comment.

Q.5. Do you agree with the scenarios set out for Local Authority Collected Waste(LACW)? Which scenario do you consider to be the most suitable on which to
base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. Given the overriding national objective of reducing the generation of waste, in accordance with the waste hierarchy, the plan should not accept and plan for a high growth in waste generation per household. RBC consider a decline in waste generation per household as the most suitable scenario. This continues the overall decline and accords with the Government’s 25 Year Environment Plan and
Waste and Resources Strategy.

Q.6. Do you agree with the scenarios set out for commercial and Industrial (C & I).
Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out for commercial and industrial waste. RBC consider no change as the most suitable scenario, this reflects the Government’s position that there will be some growth, however this growth will be off-set by increases in the production of waste and its recycling.

Q.7. Do you agree with the scenarios set out for Construction, Demolition and Excavation Waste (CDE)? Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. As set out in answer to Q.3 the Government’s Standard Method for calculating housing need indicates Rushcliffe should provide a minimum 604 homes per annum, this equates to 12,080 during the plan period (2018 to 2038). The forthcoming Growth Options consultation will put forward different options which provide some flexibility and future drafts will distribute housing across the Greater Nottingham area. This distribution should inform the Waste Local Plan.

Q.8. Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
No comment

Q.9. Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan? Do you have any evidence to
suggest that different assumptions should be made?
Rushcliffe would agree that recycling rates are likely to increase further with the introduction of separate food waste collections as outlined in the Environment Bill 2020.

Likewise the impact of any future deposit return schemes could have an effect on the kerbside collection schemes for some dry recyclables. To further increase recycling rates across Nottinghamshire further action should be given to expanding the current input specification which places restrictions on what can be delivered and recycled at the current MRF.

Q.10. What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
No comment

Q.11. Do you agree with the need to provide additional disposal capacity within the Plan Area?
Given that the one suitable landfill site is due to close within a year, RBC agree that the County should retain capacity for landfill disposal and that additional disposal capacity is likely to be required (even after reductions, recovery and recycling). The county’s waste should be disposed of as close to where it is generated as possible.

Q.12. Do you agree with the draft vision? Are there other things we should include?
RBC agree with the draft vision.

Q.13. Are the above objectives appropriate? Are there others we should consider?
RBC consider the objectives appropriate.

Q.14. What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
RBC agree with the broad locations proposed for future waste management facilities (locating new facilities close to the main urban areas where most people live with larger facilities within the Nottingham/Mansfield/Ashfield area and smaller/medium sized facilities around Worksop, Retford, and Network). A focus on urban centres can in certain cases leave gaps in provision, however. RBC is of the view that there is an urgent
need to replace the Langar facility which was closed several years ago and has left the east of Rushcliffe with no convenient household waste facility

Q.15. Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Paragraph 4 within the National Planning Policy for Waste (NPPW) states that waste planning authorities should identify, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations. Consequently, if an additional landfill capacity is required, these and larger waste recovery and recycling facilities should be identified within the plan. Their location should not be determined by criteria based policies alone.

Broader locations for smaller sites that serve local communities, could be identified according to the type of facility, for example industrial estates identified as B2 or B8 employment sites could accommodate waste collection, recovery or recycling facilities provided policy safeguards are in place to protect neighbouring businesses from access disruption, noise, dust or odours.

Q.16. What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
RBC does not propose any additional waste planning issues which require development management policies.

Q.17. Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
RBC has no other comments to make at this time and this concludes our representation on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options.

We look forward to reviewing the draft Waste Local Plan when it is published.

Yours sincerely

Dear Sir/Madam

Re: Nottinghamshire and Nottingham Waste Local Plan

Thank you for consulting Rushcliffe Borough Council (RBC) on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options and for extending the deadline for comments during this difficult period.

Please consider the following responses to those questions asked.

Q.1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
RBC supports the proposed plan period, this corresponds with the proposed plan period for the emerging Greater Nottingham Strategic Plan (GNSP). There would be clear benefits coordinating the planning of new development and planning the recovery, recycling and disposal of the waste it would generate.

Q.2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
The overview should refer to the proposed High Speed Two railway station at Toton within Broxtowe, this has the potential to bring significant economic benefits to Nottinghamshire, especially in and around Nottingham (including Rushcliffe).

The plan should also cross refer to the Minerals Local Plan and the issues which it is addresses, notably the extraction of sand and gravel within the Trent and Idle Valleys. A reduction in demand from the construction industry for minerals, in accordance with the Waste Hierarchy, and increased recycling of minerals waste (as set in paragraph 204 of the NPPF) may have implications when planning to meet future needs.

Q.3: Do you agree with the current waste estimate? Do you have any other
information which may lead to a different waste estimate?
Table 5 Page 12 of the Preliminary Waste Needs Assessment identifies the household
projections for the Nottinghamshire authorities. Rather than identifying projections, any increase in waste from domestic properties should be based on the final local housing need figure (using the Government’s Standard Method). This applies a ratio of affordability to the household projection and consequently reflects the number of homes that are needed and that will be planned for. For example Rushcliffe has an annual
household projection of 451 (rather than 600) (based on the most recent 2014 figures) and once the 2019 affordability ratio is applied a final housing need figure of 604 homes per annum. This figure is currently being used to inform the Borough’s five year land
supply.

Q.4. Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
No comment.

Q.5. Do you agree with the scenarios set out for Local Authority Collected Waste(LACW)? Which scenario do you consider to be the most suitable on which to
base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. Given the overriding national objective of reducing the generation of waste, in accordance with the waste hierarchy, the plan should not accept and plan for a high growth in waste generation per household. RBC consider a decline in waste generation per household as the most suitable scenario. This continues the overall decline and accords with the Government’s 25 Year Environment Plan and
Waste and Resources Strategy.

Q.6. Do you agree with the scenarios set out for commercial and Industrial (C & I).
Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out for commercial and industrial waste. RBC consider no change as the most suitable scenario, this reflects the Government’s position that there will be some growth, however this growth will be off-set by increases in the production of waste and its recycling.

Q.7. Do you agree with the scenarios set out for Construction, Demolition and Excavation Waste (CDE)? Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. As set out in answer to Q.3 the Government’s Standard Method for calculating housing need indicates Rushcliffe should provide a minimum 604 homes per annum, this equates to 12,080 during the plan period (2018 to 2038). The forthcoming Growth Options consultation will put forward different options which provide some flexibility and future drafts will distribute housing across the Greater Nottingham area. This distribution should inform the Waste Local Plan.

Q.8. Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
No comment

Q.9. Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan? Do you have any evidence to
suggest that different assumptions should be made?
Rushcliffe would agree that recycling rates are likely to increase further with the introduction of separate food waste collections as outlined in the Environment Bill 2020.

Likewise the impact of any future deposit return schemes could have an effect on the kerbside collection schemes for some dry recyclables. To further increase recycling rates across Nottinghamshire further action should be given to expanding the current input specification which places restrictions on what can be delivered and recycled at the current MRF.

Q.10. What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
No comment

Q.11. Do you agree with the need to provide additional disposal capacity within the Plan Area?
Given that the one suitable landfill site is due to close within a year, RBC agree that the County should retain capacity for landfill disposal and that additional disposal capacity is likely to be required (even after reductions, recovery and recycling). The county’s waste should be disposed of as close to where it is generated as possible.

Q.12. Do you agree with the draft vision? Are there other things we should include?
RBC agree with the draft vision.

Q.13. Are the above objectives appropriate? Are there others we should consider?
RBC consider the objectives appropriate.

Q.14. What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
RBC agree with the broad locations proposed for future waste management facilities (locating new facilities close to the main urban areas where most people live with larger facilities within the Nottingham/Mansfield/Ashfield area and smaller/medium sized facilities around Worksop, Retford, and Network). A focus on urban centres can in certain cases leave gaps in provision, however. RBC is of the view that there is an urgent
need to replace the Langar facility which was closed several years ago and has left the east of Rushcliffe with no convenient household waste facility

Q.15. Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Paragraph 4 within the National Planning Policy for Waste (NPPW) states that waste planning authorities should identify, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations. Consequently, if an additional landfill capacity is required, these and larger waste recovery and recycling facilities should be identified within the plan. Their location should not be determined by criteria based policies alone.

Broader locations for smaller sites that serve local communities, could be identified according to the type of facility, for example industrial estates identified as B2 or B8 employment sites could accommodate waste collection, recovery or recycling facilities provided policy safeguards are in place to protect neighbouring businesses from access disruption, noise, dust or odours.

Q.16. What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
RBC does not propose any additional waste planning issues which require development management policies.

Q.17. Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
RBC has no other comments to make at this time and this concludes our representation on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options.

We look forward to reviewing the draft Waste Local Plan when it is published.

Yours sincerely

Dear Sir/Madam

Re: Nottinghamshire and Nottingham Waste Local Plan

Thank you for consulting Rushcliffe Borough Council (RBC) on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options and for extending the deadline for comments during this difficult period.

Please consider the following responses to those questions asked.

Q.1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
RBC supports the proposed plan period, this corresponds with the proposed plan period for the emerging Greater Nottingham Strategic Plan (GNSP). There would be clear benefits coordinating the planning of new development and planning the recovery, recycling and disposal of the waste it would generate.

Q.2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
The overview should refer to the proposed High Speed Two railway station at Toton within Broxtowe, this has the potential to bring significant economic benefits to Nottinghamshire, especially in and around Nottingham (including Rushcliffe).

The plan should also cross refer to the Minerals Local Plan and the issues which it is addresses, notably the extraction of sand and gravel within the Trent and Idle Valleys. A reduction in demand from the construction industry for minerals, in accordance with the Waste Hierarchy, and increased recycling of minerals waste (as set in paragraph 204 of the NPPF) may have implications when planning to meet future needs.

Q.3: Do you agree with the current waste estimate? Do you have any other
information which may lead to a different waste estimate?
Table 5 Page 12 of the Preliminary Waste Needs Assessment identifies the household
projections for the Nottinghamshire authorities. Rather than identifying projections, any increase in waste from domestic properties should be based on the final local housing need figure (using the Government’s Standard Method). This applies a ratio of affordability to the household projection and consequently reflects the number of homes that are needed and that will be planned for. For example Rushcliffe has an annual
household projection of 451 (rather than 600) (based on the most recent 2014 figures) and once the 2019 affordability ratio is applied a final housing need figure of 604 homes per annum. This figure is currently being used to inform the Borough’s five year land
supply.

Q.4. Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
No comment.

Q.5. Do you agree with the scenarios set out for Local Authority Collected Waste(LACW)? Which scenario do you consider to be the most suitable on which to
base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. Given the overriding national objective of reducing the generation of waste, in accordance with the waste hierarchy, the plan should not accept and plan for a high growth in waste generation per household. RBC consider a decline in waste generation per household as the most suitable scenario. This continues the overall decline and accords with the Government’s 25 Year Environment Plan and
Waste and Resources Strategy.

Q.6. Do you agree with the scenarios set out for commercial and Industrial (C & I).
Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out for commercial and industrial waste. RBC consider no change as the most suitable scenario, this reflects the Government’s position that there will be some growth, however this growth will be off-set by increases in the production of waste and its recycling.

Q.7. Do you agree with the scenarios set out for Construction, Demolition and Excavation Waste (CDE)? Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
RBC agree with the scenarios set out. As set out in answer to Q.3 the Government’s Standard Method for calculating housing need indicates Rushcliffe should provide a minimum 604 homes per annum, this equates to 12,080 during the plan period (2018 to 2038). The forthcoming Growth Options consultation will put forward different options which provide some flexibility and future drafts will distribute housing across the Greater Nottingham area. This distribution should inform the Waste Local Plan.

Q.8. Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
No comment

Q.9. Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan? Do you have any evidence to
suggest that different assumptions should be made?
Rushcliffe would agree that recycling rates are likely to increase further with the introduction of separate food waste collections as outlined in the Environment Bill 2020.

Likewise the impact of any future deposit return schemes could have an effect on the kerbside collection schemes for some dry recyclables. To further increase recycling rates across Nottinghamshire further action should be given to expanding the current input specification which places restrictions on what can be delivered and recycled at the current MRF.

Q.10. What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
No comment

Q.11. Do you agree with the need to provide additional disposal capacity within the Plan Area?
Given that the one suitable landfill site is due to close within a year, RBC agree that the County should retain capacity for landfill disposal and that additional disposal capacity is likely to be required (even after reductions, recovery and recycling). The county’s waste should be disposed of as close to where it is generated as possible.

Q.12. Do you agree with the draft vision? Are there other things we should include?
RBC agree with the draft vision.

Q.13. Are the above objectives appropriate? Are there others we should consider?
RBC consider the objectives appropriate.

Q.14. What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
RBC agree with the broad locations proposed for future waste management facilities (locating new facilities close to the main urban areas where most people live with larger facilities within the Nottingham/Mansfield/Ashfield area and smaller/medium sized facilities around Worksop, Retford, and Network). A focus on urban centres can in certain cases leave gaps in provision, however. RBC is of the view that there is an urgent
need to replace the Langar facility which was closed several years ago and has left the east of Rushcliffe with no convenient household waste facility

Q.15. Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Paragraph 4 within the National Planning Policy for Waste (NPPW) states that waste planning authorities should identify, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations. Consequently, if an additional landfill capacity is required, these and larger waste recovery and recycling facilities should be identified within the plan. Their location should not be determined by criteria based policies alone.

Broader locations for smaller sites that serve local communities, could be identified according to the type of facility, for example industrial estates identified as B2 or B8 employment sites could accommodate waste collection, recovery or recycling facilities provided policy safeguards are in place to protect neighbouring businesses from access disruption, noise, dust or odours.

Q.16. What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
RBC does not propose any additional waste planning issues which require development management policies.

Q.17. Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
RBC has no other comments to make at this time and this concludes our representation on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options.

We look forward to reviewing the draft Waste Local Plan when it is published.

Yours sincerely