Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
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Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
3. Context for Waste Planning
Representation ID: 634
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Section 3 Context
This requires updating with the relevant details of the Environment Act 2021, as this includes
important elements that relate directly to this Plan, particularly the mandate for Biodiversity Net
Gain (BNG), and the requirement to create Nature Recovery Networks (NRN).
It is also essential that the national obligation to meet 30% of land for nature by 2030
(30x30) is recognised in this text, as that is a commitment made by this Government PM commits
to protect 30% of UK land in boost for biodiversity - GOV.UK (www.gov.uk), reflecting international
biodiversity obligations UK secures historic G7 commitments to tackle climate change and halt
biodiversity loss by 2030 - GOV.UK (www.gov.uk).
The Core diagram should show the ppSPA boundary, not just the SAC boundary, this would
ensure consistency with the subsequent references in later sections.
Thank you for consulting the Nottinghamshire Wildlife Trust (NWT) on the above. I apologise
for using this format of response, but the OPUS format is not straightforward to use for
responses to multiple sections and the insertion or highlighting of text. I have used bold italics
to suggest insertions of text and italics for your original text.
Overall NWT supports the principles of the Plan and we welcome the clear reiteration of the
need to move waste management urgently up the waste hierarchy. We would hope, however,
to see a stronger aim for further waste reduction and the obligation for each Local
Authority to secure ambitious waste reductions across all their work and areas of
influence.
Detailed comments in representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
5. Waste Management in the Plan Area
Representation ID: 635
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Section 5 Waste Management in the Plan Area
NWT is not in a position to question any of the figures, that is not within our remit. There does
appear, however, to be no mention of the use of agricultural crops for AD plants, despite this
occurring at an increasing scale in the County. Excessive growth of inappropriate crops, with
insufficient land capacity to safely spread digestate is a serious problem in the County. Whilst
some of these process are outside the remit of the WPA, the issue should be recognised, as it
is relevant to DM policies for development of AD plants on farms.
Thank you for consulting the Nottinghamshire Wildlife Trust (NWT) on the above. I apologise
for using this format of response, but the OPUS format is not straightforward to use for
responses to multiple sections and the insertion or highlighting of text. I have used bold italics
to suggest insertions of text and italics for your original text.
Overall NWT supports the principles of the Plan and we welcome the clear reiteration of the
need to move waste management urgently up the waste hierarchy. We would hope, however,
to see a stronger aim for further waste reduction and the obligation for each Local
Authority to secure ambitious waste reductions across all their work and areas of
influence.
Detailed comments in representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Vision
Representation ID: 636
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Vision
Then vision should start by referencing less use of materials, rather than starting at “re-use”.
It is fundamental that we secure a step change in reducing consumption, if ambitious targets to
reduce waste are to be met. If we are to address the climate emergency, as agreed by all the
Notts LAs, then we should be consuming and transporting less, the Vision does not
currently reflect this.
Thank you for consulting the Nottinghamshire Wildlife Trust (NWT) on the above. I apologise
for using this format of response, but the OPUS format is not straightforward to use for
responses to multiple sections and the insertion or highlighting of text. I have used bold italics
to suggest insertions of text and italics for your original text.
Overall NWT supports the principles of the Plan and we welcome the clear reiteration of the
need to move waste management urgently up the waste hierarchy. We would hope, however,
to see a stronger aim for further waste reduction and the obligation for each Local
Authority to secure ambitious waste reductions across all their work and areas of
influence.
Detailed comments in representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Strategic Objective 1: Acting on climate change
Representation ID: 637
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
SO1
First reduce what is used at all, encourage less consumerism, before thinking about how to
solve the problem of waste.
Acting on climate change - encourage the efficient use of natural resources by promoting waste
as a resource, limit further impacts by avoiding damage to air quality, water, biodiversity or
soil, reduce the need to transport waste and accept that some change is inevitable and manage
this by making sure that all new waste facilities are designed and located to withstand the likely
impacts of flooding, higher temperatures and more frequent storms.
Thank you for consulting the Nottinghamshire Wildlife Trust (NWT) on the above. I apologise
for using this format of response, but the OPUS format is not straightforward to use for
responses to multiple sections and the insertion or highlighting of text. I have used bold italics
to suggest insertions of text and italics for your original text.
Overall NWT supports the principles of the Plan and we welcome the clear reiteration of the
need to move waste management urgently up the waste hierarchy. We would hope, however,
to see a stronger aim for further waste reduction and the obligation for each Local
Authority to secure ambitious waste reductions across all their work and areas of
influence.
Detailed comments in representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Strategic Objective 3: Protecting our environment
Representation ID: 638
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
SO3
Protecting our environment – to ensure any new waste facilities protect the countryside, wildlife
and valuable habitats, and maximise the delivery of BNG over and above the
Nottinghamshire minimum target of 20%*. We will also protect and improve water, soil and
air quality across the plan area and to care for the built, historic and natural environment of the
area.
*The Draft BNG Framework for the County, recognises that for built development the minimum
target set for BNG in the Environment Act 2021 of 10% should be met, but that in
Nottinghamshire we have a shared aim to meet 20% where viable. For minerals and waste
planning, much higher levels of new habitats and BNG have always been possible, and have
been achieved, and thus the aim should remain to maximise BNG,
Thank you for consulting the Nottinghamshire Wildlife Trust (NWT) on the above. I apologise
for using this format of response, but the OPUS format is not straightforward to use for
responses to multiple sections and the insertion or highlighting of text. I have used bold italics
to suggest insertions of text and italics for your original text.
Overall NWT supports the principles of the Plan and we welcome the clear reiteration of the
need to move waste management urgently up the waste hierarchy. We would hope, however,
to see a stronger aim for further waste reduction and the obligation for each Local
Authority to secure ambitious waste reductions across all their work and areas of
influence.
Detailed comments in representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Strategic Objective 5: Meeting our future needs
Representation ID: 639
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
SO5:
Reducing our future needs – 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
reducing and recycling our waste. Safeguarding existing and/or potential future sites where
appropriate. Locate new waste facilities to support new residential, commercial and industrial
development across the plan area.
NWT consider that there is insufficient emphasis on the need to reduce waste production and
thus reduce the need for future facilities in this SO.
Thank you for consulting the Nottinghamshire Wildlife Trust (NWT) on the above. I apologise
for using this format of response, but the OPUS format is not straightforward to use for
responses to multiple sections and the insertion or highlighting of text. I have used bold italics
to suggest insertions of text and italics for your original text.
Overall NWT supports the principles of the Plan and we welcome the clear reiteration of the
need to move waste management urgently up the waste hierarchy. We would hope, however,
to see a stronger aim for further waste reduction and the obligation for each Local
Authority to secure ambitious waste reductions across all their work and areas of
influence.
Detailed comments in representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
SP2 - Future Waste Management Provision
Representation ID: 640
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
SP2 - Future Waste Management Provision
The Waste Local Plan aims to provide sufficient waste management capacity to meet identified
needs and will support proposals for waste management facilities which help to move waste
management up the waste hierarchy. In order to ensure that future waste needs are
minimised, the Councils will strive to reduce waste production through all areas of their
work and influence.
NWT questions whether this is ambitious enough without a specific reference again to reduction.
Past experience has shown that only reduced waste management capacity will actually
drive innovation in reduction and re-use.
Thank you for consulting the Nottinghamshire Wildlife Trust (NWT) on the above. I apologise
for using this format of response, but the OPUS format is not straightforward to use for
responses to multiple sections and the insertion or highlighting of text. I have used bold italics
to suggest insertions of text and italics for your original text.
Overall NWT supports the principles of the Plan and we welcome the clear reiteration of the
need to move waste management urgently up the waste hierarchy. We would hope, however,
to see a stronger aim for further waste reduction and the obligation for each Local
Authority to secure ambitious waste reductions across all their work and areas of
influence.
Detailed comments in representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
SP4 Residual Waste Management
Representation ID: 641
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
SP4 - Residual Waste Management
a) Proposals for the recovery of inert waste to land will be permitted where it can be
demonstrated that: i) It will not cause damage to environmental assets, including
biodiversity, heritage, air, soils, water, or a quiet environment. i. This will provide a
significant benefit or improvement which cannot practicably or reasonably be met in any other
way. ii. The waste cannot practicably and reasonably be re-used, recycled or processed in any
other way iii. The use of inert waste material replaces the need for non-waste materials iv. The development involves the minimum quantity of waste necessary to achieve the desired benefit
or improvement v. This will not prejudice the restoration of permitted mineral workings and
landfill sites.
Thank you for consulting the Nottinghamshire Wildlife Trust (NWT) on the above. I apologise
for using this format of response, but the OPUS format is not straightforward to use for
responses to multiple sections and the insertion or highlighting of text. I have used bold italics
to suggest insertions of text and italics for your original text.
Overall NWT supports the principles of the Plan and we welcome the clear reiteration of the
need to move waste management urgently up the waste hierarchy. We would hope, however,
to see a stronger aim for further waste reduction and the obligation for each Local
Authority to secure ambitious waste reductions across all their work and areas of
influence.
Detailed comments in representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
DM1 – General Site Criteria
Representation ID: 642
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
DM1
Previously developed land/derelict land – land that is no longer needed or has been abandoned.
This includes land which has previously been used for some form of permanent, built,
development that is no longer used but could also include former mineral workings or unrestored/
poorly restored colliery land where there are no formal restoration
requirements.
NWT have significant concerns about the inclusion of the reference to former mineral workings
or unrestored /poorly restored colliery land highlighted in bold above. To our knowledge there are no remaining mineral sites in Notts with no formal restoration requirements. Therefore,
under planning legislation they are restored/have an obligation to be restored and should be
considered as greenfield sites, not PDL. This assumption is crucial to the decisions that then
follow about appropriate locations for development. NWT therefore fundamentally object to the
Table in DM1.
Thank you for consulting the Nottinghamshire Wildlife Trust (NWT) on the above. I apologise
for using this format of response, but the OPUS format is not straightforward to use for
responses to multiple sections and the insertion or highlighting of text. I have used bold italics
to suggest insertions of text and italics for your original text.
Overall NWT supports the principles of the Plan and we welcome the clear reiteration of the
need to move waste management urgently up the waste hierarchy. We would hope, however,
to see a stronger aim for further waste reduction and the obligation for each Local
Authority to secure ambitious waste reductions across all their work and areas of
influence.
Detailed comments in representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
DM3 – Design of New and Extended Waste Management Facilities
Representation ID: 643
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
DM3 – Design of New and Extended Waste Management Facilities
Planning permission for new waste facilities or the extension of existing facilities will be granted
where it can be demonstrated that the development follows relevant best practice. All proposals
for new or extended waste facilities should demonstrate that the development is of a scale, form
and character appropriate to its location. Future waste management facilities should be
designed to include features, which, in both the construction and operation phases:
Avoid impacts and rigorously avoid and mitigate impacts on biodiversity first before
exploring the potential for BNG….
•.. Maximise landscape enhancements and biodiversity net gain, and other measures to
contribute to green infrastructure enhancement • Maximise efficient use of water and use
sustainable surface water drainage techniques • Minimise greenhouse gas emissions, including through
energy efficiency and green building construction techniques • Ensure resilience and enable
adaptation to climate change
Thank you for consulting the Nottinghamshire Wildlife Trust (NWT) on the above. I apologise
for using this format of response, but the OPUS format is not straightforward to use for
responses to multiple sections and the insertion or highlighting of text. I have used bold italics
to suggest insertions of text and italics for your original text.
Overall NWT supports the principles of the Plan and we welcome the clear reiteration of the
need to move waste management urgently up the waste hierarchy. We would hope, however,
to see a stronger aim for further waste reduction and the obligation for each Local
Authority to secure ambitious waste reductions across all their work and areas of
influence.
Detailed comments in representations
