Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
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Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
DM1 – General Site Criteria
Representation ID: 654
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Paragraph 8.19
Landfill within the Green Belt may be acceptable if very special circumstances can be
demonstrated. This could include the restoration of former mineral workings. Land-raise
schemes may be appropriate on derelict land where this would provide the best means of
reclamation and could be considered on Greenfield sites if there are no other options. However,
land-raise schemes are unlikely acceptable within the Green Belt because of the visual impact
on the otherwise open character of the landscape
The phrase highlighted in bold refers to the same incorrect assumptions as described above for
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
DM2 – Health, Wellbeing and Amenity
Representation ID: 655
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Paragraph 8.23
All waste related development should take account of its surroundings and be located,
designed, and operated to minimise any potentially harmful impacts, especially to air, water
and soil.
NWT disagrees with the listing of these 3 areas of natural capital, and the use of “especially”
which implies these are more important than other natural capital, such as biodiversity. It
paragraph should either have a longer and fully inclusive list of natural capital or not list any.
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
DM2 – Health, Wellbeing and Amenity
Representation ID: 656
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Paras 8.24 to 8.25
These paragraphs omit to mention BNG at all. It should be clear that BNG should be
maximised, and also that the biodiversity mitigation hierarchy should be rigorously
followed in all applications.
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
DM2 – Health, Wellbeing and Amenity
Representation ID: 657
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Paragraph 8.27
Ensuring a good standard of health, wellbeing and amenity for all existing and future occupants
of land and buildings is a core planning principle of the National Planning Policy Framework.
New and existing development should not contribute to, or be put at risk from, pollution or other
sources of nuisance or intrusion which could adversely affect health, wellbeing and local
amenity, particularly in relation to sensitive human or wildlife receptors.
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
SP5 – Climate Change
Representation ID: 658
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Paragraph 7.47.
This could include: • Enclosing waste facilities which would help to reduce noise, dust and
odour and would also act as a temperature control measure. • Minimise water consumption (e.g.
use of recycled water for waste management processes, harvesting of rainwater). • Designing
facilities to include measures to deliver landscape enhancement and biodiversity gain. Such
measures should contribute to the wider network of green infrastructure across the county (e.g.
green roofs) • Utilising associated lower-carbon energy generation such as heat recovery and
the recovery of energy from gas produced from the waste so activity is maximised. • Minimise
greenhouse gas emissions, including through energy efficiency, design and orientation of
buildings………….substantively reducing ALL waste management or processing that
results in the production of the most damaging GHG eg. CH4, and those which have other
serious detrimental effects on the environment, including adverse impacts on sensitive
and scarce habitats including NOx, NH4.
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
DM2 – Health, Wellbeing and Amenity
Representation ID: 659
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Paragraph 8.3.
It should be noted that whilst the impacts of waste development proposals on amenity and
the environment will be considered when determining applications, the Councils will have to
assume that control processes, particularly in relation to pollution, that are the function
of other regulatory bodies will be effective. For example, it is the role of the Environmental
Permit which is issued by the Environment Agency that ensures processes and standards are
in place to prevent air and water pollution, thus protecting human health and the environment
from any potential impacts from proposals. It is therefore also recommended that applicants
seek advice from relevant regulatory bodies early on within the application process so that any
impacts and concerns can be addressed through the appropriate regulatory regimes.
NWT have serious concerns about the phrase in bold and believe it should be challenged. Whilst
this is the correct position of the WPA, we know that this is not the reality of what happens on
the ground Environment Agency downgrading 93% of prosecutions for serious pollution |
Environment Agency | The Guardian. Therefore, NWT believe the WPA should now question
whether this approach is still valid and what other measures should be taken to address the
serious risk of lack of regulation and consequent pollution events.
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
7. Strategic Policies
Representation ID: 866
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
7.5. Where there are no relevant plan policies, or the policies which are most important for
determining the application are out of date at the time of making the decision, the Council will
grant planning permission unless: a) The application of policies in the NPPF that protect areas or assets of particular importance provides a clear reason for refusing the development
proposed or b) Any adverse impacts of doing so would significantly and demonstrably outweigh
the benefits, when assessed against policies in the NPPF taken as a whole.
NWT has a substantive concerns about 7.5b and how the assessment of “outweigh” would be
made. Also it would be possible to argue that many policies are inherently contradictory in any
plan, so this also invalidate this approach. This needs substantial further explanation of how
this clause would actually operate .
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
7. Strategic Policies
Representation ID: 867
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
7.6. The presumption in favour of sustainable development does not apply where proposals are
likely to have a significant effect on a habitats site (either alone or in combination with other
proposals), unless an appropriate assessment has concluded that the proposals will not
adversely affect the integrity of the habitats site.
Clear explanation is needed to the meaning of “habitats site”, I assume it refers to the SAC or
the ppSPA, but this needs clarification, for the avoidance of doubt or misinterpretation.
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
