Pre- Submission Draft Waste Local Plan

Thank you for consulting Rushcliffe Borough Council (RBC) on the Pre-Submission Draft Waste Local Plan and supporting Sustainability Appraisal Pre-Submission Draft. Having read the documents, please accept the following responses.

Policy SP1 – Waste prevention and re-use

We acknowledge that you have reviewed our previous comments, which raised concerns regarding the supporting text of Policy SP1 which suggested that Policy SP1 of the Waste Local Plan should be applied to non-waste developments which we believe should, instead, be determined in accordance with the development plan for the local planning authority.

We note that you are progressing with the same approach. We therefore wish to reiterate our previous comments.
The supporting text of Policy SP1 makes clear that this policy will apply to proposals for non-waste development and should be considered by the local planning authority responsible for determining the application. Planning Practice Guidance on plan making states that specialist plans, such as waste plans, provide a framework for decisions involving these uses.1 It does not extend to non-waste proposals.

Whilst RBC does not object to the reduction of waste generation from non-waste developments, we question whether this development plan, which is intended to manage waste proposals, can be applied to non-waste developments that should, instead, be determined in accordance with the development plan for the local planning authority.

Policies within these district or borough local plans should address waste generation from non-waste developments – such as Policy 2 (Climate Change) within RBC’s Local Plan Part 1 which requires development to minimise waste.

Forecasting future waste arising in the Plan area
We reiterate our previous comments, which question the conclusions on pages 30-32 that household waste will decrease (Scenario B (Low rate of decline)) as any decline in household residual waste (which cannot be recycled) may be off-set by the rise in the number of residents working from home. RBC are not seeing a decrease (just a smaller drop now some are returning to a mix of both office and remote).

Sustainability Appraisal Pre-Submission Draft
Having read the SA pre-submission draft, RBC has no concerns regarding the methodology and the appraisal of the vision, strategic objectives, policies and its conclusions.

If you would like to discuss our comments on the emerging plan, please feel free to contact me.

Yours sincerely

Thank you for consulting Rushcliffe Borough Council (RBC) on the Pre-Submission Draft Waste Local Plan and supporting Sustainability Appraisal Pre-Submission Draft. Having read the documents, please accept the following responses.

Policy SP1 – Waste prevention and re-use

We acknowledge that you have reviewed our previous comments, which raised concerns regarding the supporting text of Policy SP1 which suggested that Policy SP1 of the Waste Local Plan should be applied to non-waste developments which we believe should, instead, be determined in accordance with the development plan for the local planning authority.

We note that you are progressing with the same approach. We therefore wish to reiterate our previous comments.
The supporting text of Policy SP1 makes clear that this policy will apply to proposals for non-waste development and should be considered by the local planning authority responsible for determining the application. Planning Practice Guidance on plan making states that specialist plans, such as waste plans, provide a framework for decisions involving these uses.1 It does not extend to non-waste proposals.

Whilst RBC does not object to the reduction of waste generation from non-waste developments, we question whether this development plan, which is intended to manage waste proposals, can be applied to non-waste developments that should, instead, be determined in accordance with the development plan for the local planning authority.

Policies within these district or borough local plans should address waste generation from non-waste developments – such as Policy 2 (Climate Change) within RBC’s Local Plan Part 1 which requires development to minimise waste.

Forecasting future waste arising in the Plan area
We reiterate our previous comments, which question the conclusions on pages 30-32 that household waste will decrease (Scenario B (Low rate of decline)) as any decline in household residual waste (which cannot be recycled) may be off-set by the rise in the number of residents working from home. RBC are not seeing a decrease (just a smaller drop now some are returning to a mix of both office and remote).

Sustainability Appraisal Pre-Submission Draft
Having read the SA pre-submission draft, RBC has no concerns regarding the methodology and the appraisal of the vision, strategic objectives, policies and its conclusions.

If you would like to discuss our comments on the emerging plan, please feel free to contact me.

Yours sincerely