Staffordshire and Stoke-on-Trent Joint Waste Core Strategy 2010 - 2026
Consultation Statement September 2011
Planning Committee Site Visit Protocol
www.staffordshire.gov.uk Contents
1 Introduction 1 The Regulations 1 Stages of plan preparation 1 Background to joint working 1
2 Who was invited to make representations 4 Consultation in accordance with Statement of Community Involvement 4
3 How representations were invited 6 How individuals were invited to be involved in the plan preparation 6 a) Issues and Options, March 2007 7 Consultation Statement (Regulation 30 document) b) Issues and Options Part 2, September 2008 7 c) Emerging Joint Waste Core Strategy, August 2010 9 d) Revised Draft Policies, April 2011 14
4 How representations have been taken into account 21 A summary of the main issues raised and how they informed the next stage 21 a) Issues and Options, March 2007 21 b) Issues and Options Part 2, September 2008 22 c) Emerging Joint Waste Core Strategy, August 2010 32 d) Revised Draft Policies, April 2011 37
5 Next Steps 40 Timetable for preparation of Joint Waste Core Strategy 40
6 Appendices 41 Appendix 1: Poster, Issues and Options March 2007 consultation 41 Contents
Appendix 2: Flyer, Issues and Options Part 2 September 2008 consultation 42 Appendix 3: Consultees List, Emerging Joint Waste Core Consultation Statement (Regulation 30 document) Strategy August 2010 consultation 43 Appendix 4: Media Campaigns 69 Support our Standards, 2010 69 Beyond the Bin, 2009 71 Appendix 5: Representations, Emerging Joint Waste Core Strategy August 2010 consultation 74 Appendix 6: Representations, Revised Draft Policies April 2011 consultation 178 Appendix 7: Press Releases 214 Issues and Options, March 2007 214 Issues and Options Part 2, September 2008 217 Appendix 8: Consultation Letters 219 Issues and Options, March 2007 219 Issues and Options Part 2, September 2008 220 Emerging Joint Waste Core Strategy, August 2010 221 Revised Draft Policies, April 2011 223 Introduction 1
1 Introduction
The Regulations 1
1.1 This document comprises the ‘Consultation Statement’ for the Joint Waste Core Strategy for Staffordshire and Stoke-on-Trent. It has been prepared by Staffordshire County Council and Stoke-on-Trent City Council in accordance with Regulation 30 of the Town and Country Planning (Local Development) (England) Regulations 2004, as amended in 2008 and 2009, ‘the Regulations’. It sets out how the Councils complied with Regulation 25 of the Regulations on public participation in production of the Joint Waste Core Strategy Development Plan Document.
1.2 Regulation 25 prescribe the need for early involvement of certain bodies as well as the local community and businesses in the preparation of Development Plan Documents (DPDs). Regulation 30 (1) (d) requires a statement setting out:
Who was invited to be involved in the plan preparation;
How they were invited to be involved in the plan preparation; and, Consultation Statement (Regulation 30 document) A summary of the main issues raised as a result of the consultation and how those main issues were taken into account.
Stages of plan preparation
1.3 There have been four stages of the preparation of the Joint Waste Core Strategy leading up to the submission draft of the Joint Waste Core Strategy (Regulation 27 Publication Document):
Issues and Options, March 2007; Issues and Options Part 2, September 2008; Emerging Joint Waste Core Strategy, August 2010; and, Revised Draft Policies for Joint Waste Core Strategy, April 2011.
1.4 This Consultation Statement details who was invited to be involved in each stage of the plan preparation and how their consultation responses were taken into account at the next stage.
Background to joint working
1.5 Staffordshire County Council had originally proposed to produce a Staffordshire Waste Core Strategy Development Plan Document (DPD) and a joint Staffordshire and Stoke-on-Trent Waste Site Allocation Development Plan Document. Following on from Issues and Options in March 2007 for the Staffordshire Waste Core Strategy the next stage was originally intended to be to develop Preferred Options. It was also the intention for Staffordshire County Council and Stoke-on-Trent City Council to commence work on a Joint Waste Site Allocations Document that same year and produce an issues and 2 Introduction
options consultation document. Following advice from Government Office for the West Midlands (GOWM) and the Planning Inspectorate (PINS), and given 1 the risk in proceeding to the next stages in the absence of greater clarity and certainty about the process and the prospect of this leading to a ‘sound’ DPD, Consultation Statement (Regulation 30 document) particularly for the Core Strategy, it was proposed to delay commencement of work on both the Preferred Options for the Waste Core Strategy and the Waste Site Allocations Document whilst further work was undertaken to develop options for the Waste Core Strategy that were locally distinctive, focused on place and linked to wider planning strategies. The further work proposed was to gather evidence and engage on spatial options.
1.6 In November 2007, a resolution was sought from and approved by Members of the County and City Councils to enter into a joint working arrangement on the Waste Core Strategy Development Plan Document in accordance with Part 2 “Local Development”, Section 28 “Joint local development documents” of the “Planning and Compulsory Purchase Act 2004”.
1.7 For a number of planning and financial reasons described below it made sense for Staffordshire County Council and Stoke-on-Trent City Council to work together on preparing a Joint Waste Core Strategy:
Advice from GOWM and the publication of “Lessons Learnt” by the Planning Inspectorate suggested that the Waste Core Strategy should identify “broad locations” and/or “strategic sites” for future waste development. Staffordshire County Council Planning Committee in July 2007 received a report (Agenda item 8) which included a section entitled “re-think in response to latest advice” which explained that: “Core strategies are where tough decisions need to be made: strategic decisions cannot be left to subsequent DPDs” (Development Plan Documents)”). The Planning White Paper (2007) suggested that Site Allocations DPD’s may not be needed; Stoke-on-Trent City Council and Newcastle under Lyme Borough Council were already working jointly on a Core Spatial Strategy for their combined authorities. They had been advised by the Government Office for the West Midlands to strengthen the waste policy content of their core strategy, or to consider joint working with Staffordshire County Council as a more pragmatic solution which would avoid undue delays to the preparation of their core spatial strategy. The adopted Regional Spatial Strategy and the emerging Regional Spatial Strategy draft waste policies identified the tonnages of waste requiring management to the sub-region of Staffordshire and Stoke-on-Trent; A draft Municipal Waste Management Strategy has been produced jointly for Staffordshire and Stoke-on-Trent; The waste to energy plant at Hanford, Stoke-on-Trent is a shared, strategic facility; Prior to the new plan-making regime introduced by the Planning and Compulsory Purchase Act 2004, the County and City Council’s have Introduction 3
previously worked together to prepare the Structure Plan, Minerals Local Plan and of particular relevance, the Waste Local Plan; The cost of preparing the Waste Core Strategy would be shared. 1
1.8 To view the report to Staffordshire County Council Planning Committee on 8 November 2007 in relation to the resolution sought for joint working please use the following link: http://www.staffordshire.gov.uk/Resources/Documents/123/6WasteCoreStrategyDPD81107.Doc Consultation Statement (Regulation 30 document) 4 Who was invited to make representations
2 Who was invited to make representations
2 Consultation in accordance with Statement of Community Involvement
Consultation Statement (Regulation 30 document) 2.1 The Regulations require local authorities to consult widely when preparing development plan documents. In addition to ‘specific’ bodies who must be consulted, ‘general’ and other bodies relevant to the purpose of the document should be consulted.
2.2 Consultation on the various preparatory stages of the Joint Waste Core Strategy has been undertaken in accordance with both Councils Statements of Community involvement (SCI). The Staffordshire County Council SCI was adopted in June 2006. The Stoke-on-Trent City Council SCI was adopted in 2007.
2.3 Table 1 of the Staffordshire County Council SCI is replicated below and lists the specific and general types of consultation bodies/groups that we have consulted and involved in the preparation of the Joint Waste Core Strategy.
Specific consultation bodies
Government Office for the West Midlands (abolished 31 Mar 2011) Local District and Borough Councils Parish / Town Councils Adjoining Local and Parish Councils The Environment Agency The Coal Authority English Heritage Natural England The Highways Authority The Secretary of State for Transport Primary Care Trust Statutory Undertakers Regional Development Agency Who was invited to make representations 5
General consultation bodies 2 Mineral and Waste site operators Planning consultants and agents Voluntary groups including: Environmental Heritage Social and health Sports Residents’ associations and other local community groups Religious and equal access groups Business associations ‘Hard to Reach’ groups
2.4 Individuals and organisations who responded to the Joint Waste Core Strategy consultation exercises at the various preparatory stages have been added to
the consultation list as the process developed. Everybody who was consulted Consultation Statement (Regulation 30 document) and/or responded to earlier stages were therefore also consulted at the next stage. Amendments were made to the consultation database between stages to provide updated contact information about consultees, if that information was made available to us. New consultees were also added as requested to the consultation list. By way of an example, Appendix 3 provides a list of the bodies and individuals invited to make representations in connection with the Emerging Joint Waste Core Strategy, August 2010. Those individuals on that list who had registered an email address were also invited to make representation in connection with the targeted consultation on Revised Draft Policies for the Joint Waste Core Strategy, April 2011. 6 How representations were invited
3 How representations were invited
3 How individuals were invited to be involved in the plan preparation
Consultation Statement (Regulation 30 document) 3.1 An intrinsic part of formulating the Joint Waste Core Strategy has been public consultation. All representations received have been carefully considered and amendments made where appropriate in order to arrive at the submission draft of the Joint Waste Core Strategy (Regulation 27 Publication Document).
3.2 The consultation stages so far have included:
Issues and Options: consultation took place between 30th March 2007 and 11th May 2007; Issues and Options Part 2: consultation took place between 3 October 2008 and 24 November 2008; Emerging Joint Waste Core Strategy: consultation took place between 9 August 2010 and 1 October 2010; and Revised Draft Policies for Joint Waste Core Strategy: consultation took place 12 April 2011 and 26 April 2011.
3.3 The process has been repeated for the different preparatory stages of the Joint Waste Core Strategy. To complement traditional consultation methods, in addition to providing the consultation document in paper format and in a version available for downloading from our dedicated website www.staffordshire.gov.uk, a version using e-consultation software http://consult.staffordshire.gov.uk/portal/ was made available to enable stakeholders to submit their comments directly via a website. Press releases were also issued at each stage of the process to inform the general public.
3.4 All consultees and in particular the Local District, Borough and Parish Councils were offered the opportunity to invite officers to attend meetings to discuss and explain the Joint Waste Core Strategy.
3.5 Various informal meetings and discussions took place with stakeholders, particularly with Local Authorities within and adjoining the plan area; the Environment Agency, and the waste industry. Small exhibitions were also held throughout the County at District Council offices.
3.6 The commentary below outlines the methods that were used to gather representations at each consultation stage, and details how many bodies and people responded to each consultation. Section 4of this document also provides a summary of the main issues raised by those representations, and how they were addressed at each stage of Core Strategy preparation. How representations were invited 7
a) Issues and Options, March 2007
3.7 Staffordshire County Council undertook formal consultation (in accordance 3 with Regulation 25) on the Staffordshire Waste Core Strategy for a period of six weeks between 30th March 2007 and 11th May 2007. The consultation document related to the County only and its intention was to generate feedback from the public on issues and options relevant to the review of planning policies for future waste development within the County currently set out in the Staffordshire and Stoke-on-Trent Waste Local Plan 1998-2011 (WLP).
Consultation methods
3.8 In accordance with the Councils Statements of Community Involvement the following consultation methods were undertaken:
107 copies of the consultation document were sent out to general and specific consultees including District Councils, mineral and waste operators and consultants, environment/amenity/local groups and interested individuals. Appendix 8 provides an example of a letter.
294 notification letters were sent out, of which 186 were to Parish Councils Consultation Statement (Regulation 30 document) within Staffordshire and 5 were to adjoining Parish Council Associations. Posters were sent to 132 display locations including District and County Council receptions, libraries, post offices, and supermarkets. Appendix 1 provides a copy of the poster. Email alerts were sent to 173 individuals. Media releases were also undertaken for newspapers covering the county in addition to local radio. Refer to Appendix 7.
Responses received
3.9 39 respondents returned 29 completed questionnaires which accompanied the issues and options document (response form ‘WSC1’). In addition 5 respondents made general comments. To view the feedback report on the Issues and Options consultation to 12 July 2007 Planning Committee please use the following link: http://www.staffordshire.gov.uk/Resources/Documents/123/8FeedbackWasteCoreStrategy12707.pdf
3.10 Refer also to section 4a) for a summary of the main issues raised as a result of the consultation and how those main issues have been addressed. b) Issues and Options Part 2, September 2008
3.11 Staffordshire County Council and Stoke-on-Trent City Council undertook formal consultation (in accordance with Regulation 25) on the Joint Waste Core Strategy for a period of six weeks between 3rd October 2008 and 24th November 2008. In consideration of the issues and options for the Joint Waste Core Strategy, comments were invited in relation to twelve issues and fifteen questions. 8 How representations were invited
3.12 In December 2007 consultants had been appointed to prepare an evidence based technical report on the current picture of waste and waste management 3 in Staffordshire and Stoke-on-Trent; the forecasted treatment need; the future waste management capacity gap; and the future infrastructure and landfill Consultation Statement (Regulation 30 document) need. By using this information consultants prepared a second stage Issues and Options consultation document to generate feedback from the public on issues and options relevant to the review of planning policies for future waste development in Staffordshire and Stoke-on-Trent. In July 2008 Members of the City Council and County Council approved these documents to be used to consult with stakeholders. Please note that the first stage Issues and Options consultation that took place in March 2007 related to Staffordshire only. The principle of a Joint Waste Core Strategy with Stoke-on-Trent City Council was agreed in November 2007.
3.13 A second stage Issues and Options consultation was deemed necessary in preparation of a Joint Waste Core Strategy that is more "place focused". In response to the requirement that the Core Strategy needs to identify "broad locations" or "strategic sites" for future waste management facilities that will make a major contribution to waste management capacity, it was also considered necessary to gather evidence on alternative options for future sites. Throughout October and November 2008, landowners and operators from the waste industry were invited to put forward any proposals for sites for future waste management facilities that they would like to be considered as part of the preparation of the Joint Waste Core Strategy.
Consultation methods
3.14 In accordance with the Councils Statements of Community Involvement the following consultation methods were undertaken to facilitate the consultation.
664 notification letters were sent out to general and specific consultees including mineral and waste operators and consultants, environment/amenity/local groups and interested individuals. Refer to Appendix 8. Hard copies of the consultation document including the Evidence Base Report were sent out to the 8 District Councils and to 46 libraries within Staffordshire as well as providing copies for the travelling libraries. Stoke-on-Trent City Council was also provided with 50 hard copies of each of the documents. Email alerts were sent to 598 individuals and organisations. Members of the public who had previously registered their interest in the preparation of the Waste Core Strategy were notified of the consultation either by email or via the post. 188 Parish Councils were notified either by email or letter of the consultation and were also sent an additional letter to notify on visits by officers to the eight District areas. In addition, copies of flyers relating to the consultation were also sent. How representations were invited 9
Flyers relating to the consultation were also sent to District and County Councils to be made available in their reception areas as well as to the libraries. Appendix 2 provides a copy of the flyer. 3 Visits to the eight Districts involving a small exhibition were held during the consultation period. Most of the exhibitions were held in the receptions of District Council offices, at Staffordshire County Councils St. Chads reception and at Newcastle Library. The purpose of the exhibition was to provide an opportunity for members of the public to discuss issues relating to the consultation with planning officers and to receive a demonstration on how to use the new e-consultation software. It also enabled planning officers to engage with local Members and Districts. To complement traditional consultation methods, in addition to providing the consultation document in paper format and in a version available for downloading from our dedicated website www.staffordshire.gov.uk , a version using e-consultation software was made available to enable stakeholders to submit their comments directly via a website http://consult.staffordshire.gov.uk/portal/. In relation to submission of site proposals, 795 invitation letters were sent out to potential developers including mineral and waste operators, and Consultation Statement (Regulation 30 document) consultants. Media releases were also undertaken for newspapers covering the county in addition to local radio. Refer to Appendix 7.
Responses received
3.15 40 respondents completed the 15 questions which accompanied the Issues and Options 2 consultation document. 13 respondents used the on-line e-consultation method. Also in response to the call for sites invitation, 28 site proposals were received.The feedback report to Staffordshire County Council Planning Committee (5 March 2009) contains a summary of the responses to the Issues and Options Part 2 consultation (Appendix A), a list of respondents (Appendix B), a list of site submissions (Appendix C), and a plan of site submissions (Appendix D). Please use the following link: http://moderngov.staffordshire.gov.uk/mgConvert2PDF.aspx?ID=3260
3.16 Refer also to Section 4b) for a summary of the main issues raised as a result of the consultation and how those main issues have been addressed. c) Emerging Joint Waste Core Strategy, August 2010
3.17 Staffordshire County Council and Stoke-on-Trent City Council undertook formal consultation (in accordance with Regulation 25) on the Emerging Joint Waste Core Strategy for a period of eight weeks between 9 August 2010 and 1 October 2010. Comments were invited in relation to the nine policies and subsequent nine questions. 10 How representations were invited
Consultation methods
3 3.18 In accordance with the Councils Statements of Community Involvement the following methods were undertaken to facilitate the consultation: Consultation Statement (Regulation 30 document) 801 emails were issued to people and organisations registered on the Staffordshire consultation database to advise them of the consultation being undertaken and how they could get involved. 645 letters were issued to people who had registered on the consultation database but had indicated they would prefer to be contacted by post. Appendix 3 provides a list of consultees invited to make representations in connection with the consultation. Appendix 8 provides a copy of the letter. 188 Parish Councils were notified either by email or letter prior to the start of the consultation to raise awareness of the Joint Waste Core Strategy. They were then notified again at the start of the consultation period. In addition to the more formal methods of consultation, a media campaign was launched to ‘Support our Standards’ for the future of waste management. A dedicated webpage was launched and leaflets were distributed to community leaders that aimed to raise awareness and get people interested in the future of waste management in Staffordshire. Appendix 4 provides a copy of the campaign leaflet and website.
3.19 Hard copies of the document were sent out to the District Councils and to all 51 libraries, including mobile libraries, within Staffordshire. Stoke–on-Trent City Council were also provided with 15 hard copies of the document. Hard copies were also placed at inspection points across the Plan area to view during normal office hours during the consultation period, namely:
Staffordshire County Council’s offices at Riverway and St Chad’s Place. Stoke-on-Trent City Council’s office at the Civic Centre, Glebe Street. All main libraries including mobile libraries.
3.20 The document, and all other Evidence Base Reports that accompanied the Joint Waste Core Strategy, were available to view and download from our dedicated website www.staffordshire.gov.uk and also at our consultation portal http://consult.staffordshire.gov.uk/portal/
3.21 Presentations were given to the Staffordshire Joint Waste Management Board (July 2010) and also to the Staffordshire Waste Officers Group (June 2010) to inform them of progress on the strategy.
3.22 231 Key stakeholders were invited to attend stakeholder meetings to discuss our draft policies and for the opportunity to raise any issues regarding policies. From this a programme of 25 stakeholder meetings was organised including meetings with: How representations were invited 11
Table 1 Stakeholder Meetings in connection with the Emerging Joint Waste Core Strategy 3 Stakeholders
LOCAL AUTHORITIES
1 Stafford Borough Council
2 Lichfield District Council
3 Staffordshire Moorlands District Council
4 South Staffordshire Council
5 Tamworth Borough Council
6 Cannock Chase Council
7 East Staffordshire Borough Council
8 Newcastle-under-Lyme Borough Council Consultation Statement (Regulation 30 document)
9 Black Country Authorities (on behalf of Walsall, Wolverhampton, Sandwell and Dudley)
10 Warwickshire, Worcestershire and GOWM
11 Derbyshire
12 Cheshire (Cheshire East, Cheshire West & Chester)
PARISH COUNCILS
13 Hilderstone Parish Council
14 Burntwood Parish Council
15 Hixon Parish Council
INTERNAL STAFFORDSHIRE COUNTY COUNCIL DEPARTMENTS
16 Highways
17 Regulation
18 Development Control
OTHER STATUTORY BODIES
19 Environment Agency 12 How representations were invited
Stakeholders
3 20 Staffordshire Wildlife Trust
Consultation Statement (Regulation 30 document) 21 Highways Agency
WASTE INDUSTRY
22 Jack Moody Ltd
23 Biffa Waste Services Ltd
24 H Brown & Son Recycling Ltd
25 Veolia Environmental Services Ltd
3.23 It should also be noted that a media campaign 'Beyond the Bin' was launched the previous year to raise awareness of waste planning. A website was launched which gave a general overview of waste planning, provided a link to the Waste Core Strategy dedicated webpage, and allowed visitors the ability to sign up to play a game which involved making decisions on where to locate new waste facilities. This website site was promoted on posters, leaflets, the Staffordshire County Council homepage, twitter, and You Tube site. It was also promoted in local newspapers and on bus backs during September and October 2009. Appendix 4 provides a copy of the campaign leaflet and busback.
Responses received
3.24 38 bodies/individuals responded to the Emerging Waste Core Strategy consultation document. 10 of which used the on-line e-consultation method. The other 26 responded by email or letter.1446 letters and emails were sent out. The response rate was only 2.7%
3.25 The total number of responses in relation to the nine policies and subsequent questions posed by the Emerging Waste Core Strategy consultation document amounted to 175 individual comments received from the 38 bodies/individuals.
Table 2 Respondents to Emerging Joint Waste Core Strategy, August 2010 consultation
No. Respondent Our Ref
1 Friends of the Earth Mr Keith Kondakor KK
2 Inland Waterways Association Mr Philip Sharpe IWA (Lichfield Branch)
3 Centro (Regeneration & Planning Mr Adam Harrison C Team) How representations were invited 13
No. Respondent Our Ref 3 4 The Coal Authority Miss Rachael Bust CA
5 Sport England (West Midlands Mrs Maggie Taylor SE Region)
6 Biffa Waste Services Ltd Mr Jeff Rhodes BWS
7 British Waterways Board Ms. C. Hemming BWB
8 Cannock Chase Council Mr John Morgan (2 responses - CCC amended response also received)
9 English Heritage (West Midlands Ms Amanda Smith EH Region)
10 Environment Agency (West Mr Jim Kitchen EA Midlands Region, Upper Trent
Area) Consultation Statement (Regulation 30 document)
11 Lichfield District Council Ms Elizabeth Boden LDC
12 Peel Environmental Ltd Ms Rachael Thorne PE
13 Staffordshire Moorlands District Mr David Davies SMDC Council
14 Cannock Chase AONB Mrs Ruth Hytch AONB Partnership
15 Cemex UK Operations Ltd Mr Shaun Denny CMX
16 Tamworth Borough Council Mr Matthew Bowyers TBC
17 South Staffordshire Council (2 Mrs Kelly Harris (20-10-10) SSC responses) Mr Andy Johnson (28-1-11)
18 H Brown & Son Recycling Ltd Mr Ian Hancock HBR
19 Crestwood Environmental Ltd Ms Navinder Bains CE
20 Dudley Metropolitan Borough Mr David Piper DMB Council
21 Willard Willard Ltd Mr Gez Willard GW
22 National Farmers Union Miss Sarah Faulkner NFU 14 How representations were invited
No. Respondent Our Ref 3 23 Natural England Ms Hazel McDowall NE Consultation Statement (Regulation 30 document) 24 Staffordshire Organics Ltd Mr Andrew Pym SO
25 Telford & Wrekin Council Mr David Coxhill TW
26 University of Keele Mr Andrew Parry UK
27 Kinver Parish Council Mrs J Spaull KPC
28 Warwickshire County Council Mrs Eva Neale WCC
29 Highways Agency Mr David McCann HA
30 PeakDistrictNational Park Mr David Bent PDNP Authority
31 Whitmore Parish Council Mr Haysom WPC
32 Heaton Planning Limited Mr Spencer Warren HP
33 East Staffordshire Borough Mr Glenn Jones ESBC Council
34 Stafford Borough Council Mr Mark Street SBC
35 Quarries Fighting Fund Cllr D Tyler QFF
36 Lower Reule Bioenergy Limited Ms Helen Franklin LRB
37 Newcastle-under-Lyme Borough Laura Brownsword NBC Council
38 Veolia Environmental Services Ltd Mr Alistair Pettigrew VES
3.26 Refer also to section 4c) for a summary of the main issues raised as a result of the consultation and how those main issues have been addressed.
3.27 In relation to the ‘Support our Standards’ media campaign (refer to Appendix 4) we received 219 responses of which 92.3% strongly agreed or agreed with the five standards. Only 6% disagreed with the standards.
d) Revised Draft Policies, April 2011
3.28 Staffordshire County Council and Stoke-on-Trent City Council undertook a targeted consultation over a two week period between12 April 2011 and 26 April 2011 to receive feedback from stakeholders on the four draft policies that would form the draft submission Joint Waste Core Strategy (Regulation 27 How representations were invited 15
Publication Document). All those consultees who had commented previously on the Strategy and all those registered on our consultation database with an email address were notified of the consultation by email. The purpose of the 3 consultation was to ascertain if the main concerns and comments raised by consultees in connection with the Emerging Joint Waste Core Strategy consultation in August 2010 had been addressed. If there were still major issues that needed to be addressed the Councils hoped to resolve these prior to publication and outside of the examination process.
3.29 This April 2011 consultation was not a statutory Regulation 25 public participation consultation. The consultation was used as an opportunity to explain the differences between the Emerging Joint Waste Core Strategy and the Strategy that the Councils proposed to publish in September 2011 (the draft submission Regulation 27 ‘Publication Document’).Stakeholders were made aware at that time that they would have the opportunity to submit formal representations when we published the Strategy.
Differences between the Revised draft policies for the Joint Waste Core Strategy and the Emerging Joint Waste Core Strategy. Consultation Statement (Regulation 30 document) 3.30 The number of policies has been reduced from the original 9 to 4 to create an easier to use and read document. It is important to note that this has been done by removing repetition and overlap, not by removing content.The issues, visions and strategic objectives have also been edited and simplified. The changes are shown below.
3.31 The April 2011 Revised draft policies for the Joint Waste Core Strategy consultation document consists of 4 draft policies which replace the 9 policies from the "Emerging Joint Waste Core Strategy" document (Emerging JWCS), which were consulted on in August 2010. 16 How representations were invited
Draft Policy 1 = Waste as a resource. This replaces Emerging JWCS Policy 3 4 (Maximising Waste Re-use, Recycling & Recovery of Resources) & parts of Policy 5 (Management of CD&E waste) & parts of Policy 6 ( Waste Minimisation Consultation Statement (Regulation 30 document) and Major Development Proposals)
Draft Policy 2 = Targets and broad locations for waste management facilities. This replaces Emerging JWCS Policy 1 (Targets and broad locations) & Policy 7 (Safeguarding Strategic Waste Facilities and the Location of Development in the Vicinity of Waste Management Facilities) and parts of Policy 5 (Management of CD&E waste) and parts of Policy 2 (Criteria for the Location of New Enclosed Waste Management Facilities).
Draft Policy 3 = Criteria for the location of new and enhanced waste management facilities. This replaces Emerging JWCS Policy 2 (Criteria for the Location of New Enclosed Waste Management Facilities), & Policy 3 (Criteria for the Location of Open Air Waste Management Facilities) & Policy 8 (Enhancement of Existing Waste Management Facilities) and parts of Policy 5 (Management of CD&E waste)
Draft Policy 4 = Protection and improvement of environmental quality. This replaces Emerging JWCS Policy 9 (High Quality Design) with general protection phrase from each of the original 9 policies.
3.32 The April 2011 consultation document consists of 5 key issues which replace the 10 issues in the Emerging JWCS. How representations were invited 17
Issue 1 = Climate Change. This replaces Emerging JWCS Issue 1 (Climate Change). 3
Issue 2 = Waste as a resource / Waste Hierarchy / resource efficiency construction and use of buildings. This replaces Emerging JWCS Issue 2 (Waste as a resource/Waste Hierarchy), Issue 6 (Restrict new landfill proposals), and Issue 10 (increase waste awareness and minimise waste production and encourage communities to accept responsibility for their own waste).
Issue 3 = Net self sufficiency / protection of capacity and additional capacity. This replaces Emerging JWCS Issue 3 (targets for MSW, C&I), Issue 4 (targets for CD&E), and Issue 7 (Protect existing waste management facilities and capacity from non waste related developments).
Issue 4 = Quality of waste management facilities / high quality design. This replaces Emerging JWCS Issue 5 (Improve environmental standards).This also replaces Emerging JWCS SO4 (Enhance existing waste management facilities), and SO5 (High quality design). Consultation Statement (Regulation 30 document) Issue 5 = Sustainable waste management in the right place – protection and improvement of environmental quality. This replaces Emerging JWCS Issue 8 (achieve sustainable waste management without adversely affecting people, local communities, the environment or transport systems), and Issue 9 (Protect the Area of Outstanding Natural Beauty (AONB), Green Belt, countryside and designated sites).
3.33 The April 2011 consultation document consists of 5 Strategic Objectives which replace the 10 Strategic Objectives from the Emerging JWCS. 18 How representations were invited
SO1 = Climate Change. This replaces Emerging JWCS SO1 (Climate Change) 3 SO2 = Waste as a resource / Waste Hierarchy / resource efficiency
Consultation Statement (Regulation 30 document) construction and use of buildings. This replaces Emerging JWCS SO2 (New and enhanced waste management facilities further up the Waste Hierarchy), SO6 (Take responsibility for the waste we produce), and SO10 (Increase waste awareness and minimise waste production).
SO3 = Net self sufficiency / protection of capacity and additional capacity. This replaces Emerging JWCS SO2 (New and enhanced waste management facilities further up the Waste Hierarchy), SO3 (Recycling of CD&E wastes), SO4 (Enhance existing waste management facilities and safeguard strategic waste facilities), and SO7 (Minimise the impact of transporting waste).
SO4 = Quality of waste management facilities / high quality design. This replaces Emerging JWCS SO4 (Enhance existing waste management facilities), and SO5 (High quality design).
SO5 = Sustainable waste management in the right place – protection and improvement of environmental quality. This replaces Emerging JWCS S08 (Protect people and local communities), and SO9 (Protect the environment).
Consultation methods
3.34 826 emails were sent out to consultees registered on our consultation database. The document, was available to view and download from our dedicated website www.staffordshire.gov.ukand also at our consultation portal http://consult.staffordshire.gov.uk/portal/. Appendix 8 provides a copy of the email.
Responses received
3.35 26 bodies / individuals responded to the informal consultation, 8 of which used the on-line e-consultation method. The other 18 responded by email or letter. The total number of responses in relation to the revised draft policies amounted to 50 responses. 32 responses related to the four draft policies; 10 responses related to the strategic objectives and spatial vision; 6 were general comments about the strategy and 2 comments were made in relation to the appendices and glossary.
Table 3 Respondents to Revised draft policies, April 2011 consultation
No. Respondent
1 Friends of the Earth Mr Keith Kondakor
2 British Pipelines Agency Mr Philip Hirst How representations were invited 19
No. Respondent
3 SCC Internal Consultee (Development Mr Mike Grundy 3 Control)
4 Inland Waterways Association (Lichfield Mr Philip Sharpe Branch)
5 Centro (Regeneration & Planning Team) Mr Adam Harrison
6 The Coal Authority Miss Rachael Bust
7 Sport England (West Midlands Region) Mrs Maggie Taylor
8 Blore Heath and Folly Wood Action Group Mr Frederick Fisher
9 Tidysite (Agent: McDyre & Co) Mr Ben McDyre
10 Biffa Waste Services Ltd Mr Jeff Rhodes
11 Brereton & Ravenhill Parish Council Mr P.G. Davies Consultation Statement (Regulation 30 document) 12 British Waterways Board Ms. C. Hemming
13 Cannock Chase Council Mr John Morgan
14 Campaign to Protect Rural England (CPRE) Mr Phil Goode (Staffordshire Branch)
15 English Heritage (West Midlands Region) Ms Amanda Smith
16 Environment Agency (West Midlands Mr Jim Kitchen Region, Upper Trent Area)
17 Lichfield District Council Ms Elizabeth Boden
18 Peel Environmental Ltd Ms Rachael Thorne
19 Staffordshire Moorlands District Council Mr David Davies
20 Cannock Chase AONB Partnership Mrs Ruth Hytch
21 SCC Internal Consultee (Waste Mr Mark Parkinson Management)
22 Cemex UK Operations Ltd Mr Shaun Denny
23 SCC Internal Consultee (Environment Mr Andy Goode Countryside Unit)
24 Tamworth Borough Council Mr Matthew Bowyers 20 How representations were invited
No. Respondent
3 25 West Midlands Metropolitan Authorities’ Mr Andy Donnelly Chief Engineers & Planning Officers Group Consultation Statement (Regulation 30 document) 26 Digbits Mr Marcus Clay How representations have been taken into 21 account
4 How representations have been taken into account
A summary of the main issues raised and how they informed the next stage 4
4.1 The commentary below provides a summary of the main issues raised by consultees, and how representations were addressed at each stage of the Joint Waste Core Strategy preparation.
4.2 The most significant rounds of consultation have been the Emerging Joint Waste Core Strategy consultation in August 2010 which proposed 9 draft policies and the Revised draft policies for the Joint Waste Core Strategy consultation in April 2011 which redrafted the policies into 4. Responses received in April 2011 in connection with the 4 draft policies has helped to shape the production of the draft submission Joint Waste Core Strategy (Regulation 27 Publication Document). a) Issues and Options, March 2007
4.3 39 respondents returned 29 completed questionnaires which accompanied
the Issues and Options document (response form ‘WSC1’) in 2007. In addition Consultation Statement (Regulation 30 document) 5 respondents made general comments, 3 respondents had no comments to make at this stage and 2 responses were received from the Regional Assembly and Government Office for the West Midlands (GOWM) assessing regional conformity and comments structured around the relevant soundness tests respectively.
Summary of comments received
4.4 The Staffordshire County Council Planning Committee report (12 July 2007) contains a summary of responses (Appendix A), please use the following link: http://www.staffordshire.gov.uk/Resources/Documents/123/8FeedbackWasteCoreStrategy12707.pdf
4.5 A more detailed schedule of the responses is also available using the following link (note 101 pages): http://www.staffordshire.gov.uk/Resources/Documents/i/Issues1to10SummaryofComments.pdf
How main issues were taken into account
4.6 The issues raised at this Issues and Options stage and at the second stage Issues and Options consultation were taken on board when drafting the Emerging Joint Waste Core Strategy. Refer to section b below. How representations have been taken into 22 account
b) Issues and Options Part 2, September 2008
4 4.7 40 respondents completed the 15 questions which accompanied the Issues and Options Part 2 consultation document in 2008. 13 respondents used the
Consultation Statement (Regulation 30 document) on-line e-consultation method. To view the feedback report on the Issues and Options Part 2 consultation to Staffordshire County Council Planning Committee (5 March 2009) please use the following link:
http://moderngov.staffordshire.gov.uk/mgConvert2PDF.aspx?ID=3260
4.8 A more detailed schedule of the responses is also available using the following link (note 32 pages):
http://www.staffordshire.gov.uk/Resources/Documents/s/st/StaffordshireandStokeonTrentWasteCoreStrategyComme.pdf
Summary of comments received
4.9 The following observations can be made from the consultation responses:
Several comments related to the need for sites to manage construction, demolition and excavation waste and therefore disagreed with the conclusions of the evidence base report which stated that no further land use provision is required for the future management of this waste stream. Given the rural nature of Staffordshire whilst not disputing the findings of the evidence base report in respect of agriculture not posing a significant pressure on future capacity need, the National Farmers Union provides anecdotal evidence of waste management issues for the farming community. Comments were also made with regard to the organic waste facilities and that there is a shortage of those that can take food waste. Comments have been made that waste is a resource and the Strategy should link to energy policy and carbon management - ‘energy hierarchy’ is now as relevant as a ‘waste hierarchy’.
Call for Sites - Summary of additional evidence received
4.10 Throughout October and November 2008, landowners and operators from the waste industry were invited to put forward any proposals for sites for future waste management facilities that they would like to be considered as part of the preparation of the Joint Waste Core Strategy. In response to that invitation, 28 Site proposals were received.
4.11 The proposals provide options for 13 enclosed facilities, 3 enclosed thermal treatment facilities, and 21 open-air facilities on the 28 Sites. 16 of the sites propose to handle commercial & industrial and municipal waste, 6 of which propose to handle only organic fractions of the waste (food and/or green waste) by anaerobic digestion, in-vessel composting and open windrow composting facilities. 18 of the sites propose to manage construction, demolition and excavation waste. How representations have been taken into 23 account
4.12 In terms of distribution throughout Staffordshire and Stoke-on-Trent, 1 site has been submitted for Stoke-on-Trent, 8 sites are proposed in Newcastle Borough, 3 sites are proposed in Stafford Borough, 2 sites are proposed in Cannock 4 Chase District, 7 sites are proposed in South Staffordshire District, 6 sites are proposed in Lichfield District, and 1 site has been submitted for the Borough of East Staffordshire.
4.13 Appendix C of the report to Staffordshire County Council Planning Committee (5 March 2009) provides details of the site submissions: http://moderngov.staffordshire.gov.uk/mgConvert2PDF.aspx?ID=3260 . A site assessment report was produced in March 2010 to record the assessment of suitable sites for waste management facilities, including those sites submitted in 2008 by landowners and the industry.
How main issues from Issues and Options (Part 1 and 2) were taken into account by the Emerging Joint Waste Core Strategy, August 2010
4.14 The following section summarises how the main issues and comments raised by consultees in response to the 2007 Issues and Options consultation and
the 2008 Issues and Options Stage 2 consultation have informed the process Consultation Statement (Regulation 30 document) on which the Emerging Joint Waste Core Strategy and draft policies were developed and which were consulted on in August 2010.
Strategic Objectives.
4.15 In particular as a result of the 2008 consultation exercise and responses received, the original strategic objectives were amended and the alternatives introduced and reflected in the policy options. The following table 4 shows what key common elements of the Sustainable Community Strategies are linked to the original objectives in the Issues and Options Stage 2 document and the new Strategic Objectives developed through the Emerging Joint Waste Core Strategy.
4.16 The Sustainable Community Strategies produced by each of the local authorities within Staffordshire and Stoke-on-Trent are a key influence in developing the vision and objectives as they have been the subject of wide consultation and reflect the priorities of the different communities across the area. The Joint Waste Core Strategy is a delivery mechanism for meeting some of these needs, although each objective must be achievable, for example, planning has little influence over waste reduction, which is better dealt with through other mechanisms such as international and national policy and market/economic influence. The following themes of the Sustainable Community Strategies have been taken into consideration:
The need to develop places where people want to live, work, visit and invest; Attracting sustainable, quality, public and private investment that supports our towns and villages; How representations have been taken into 24 account
Managing waste in ways which reduce environmental impact, support the economy, local communities and producing less waste, ensuring waste 4 is being re-used, recycled, composted and used to produce energy; and, Managing waste in ways which reduce environmental impact, support the Consultation Statement (Regulation 30 document) economy, local communities and producing less.
Table 4 Relationship between Sustainability Community Strategies, Objectives to Issues and Options and Emerging Strategy
Sustainable Objectives from Objectives from Community Strategies Issues and Options Emerging Strategy September 2008 July 2010
The need to develop To ensure that existing and SO2 To ensure that existing places where people new communities are well and new communities are want to live, work served by waste well served by a waste visit and invest management management infrastructure To safeguard and expand which supports efficient existing waste management waste collection and, where facilities provided that they meet some or all of the necessary, is backed by the strategic objectives development of additional and expansion of
appropriate existing waste management facilities to re-use, recycle, compost or
reprocess waste, or to generate low-carbon energy, thereby minimising residue
sent to landfill.
To ensure that the general SO8 To ensure that the amenity and health and general amenity and health safety of communities are & safety of people and taken into account when considering waste communities are taken into management facilities account when considering and monitoring waste
management facilities. How representations have been taken into 25 account
To ensure that the waste SO6 To ensure that implications of development development proposals fully proposals are taken into consider the implications of 4 account and be accountable for the waste they will produce.
The need to develop places SO5 To support high-quality where people want to live, design and innovation in work, visit and invest. To waste management facilities, support high-quality design ensuring that waste is and innovations in waste treated within enclosed management facilities facilities, and on general industrial and previously developed land wherever practicable and environmentally acceptable.
To protect and enhance SO9 To preserve the quality Staffordshire and and character of Stoke-on-Trent’s natural and Staffordshire and Consultation Statement (Regulation 30 document) historic environment Stoke-on-Trent by
protecting and enhancing the built and natural environment, including the historic environment, biodiversity and geodiversity, and preventing inappropriate forms of waste development in the Cannock Chase Area of Outstanding Natural Beauty, Green Belt, designated sites, or countryside.
Attracting To protect and enhance SO10 To encourage sustainable, quality Staffordshire and residents, businesses and public and private Stoke-on-Trent’s natural and developers to understand investment that historic environment and take responsibility for supports our towns the waste they produce by and villages way of waste minimisation, and by
working with local authorities to influence the way future sites for waste are planned, shifting the attitude away How representations have been taken into 26 account
from "waste" to valuing it as a resource which can benefit 4 the local economy. Consultation Statement (Regulation 30 document) Managing waste in To reduce the need to SO7 To reduce the need to ways which reduce transport waste especially by transport waste long environmental road and support the use of distances for treatment, impact, support the more sustainable modes of especially economy, local transportation communities and by road, by dealing with producing less waste as close as possible to where it arises; and to waste, ensuring support the use of more waste is being sustainable transportation re-used, recycled, options where practicable composted and used and environmentally to produce energy. acceptable.
SO4 To encourage and facilitate improvement of environmental quality of existing waste management facilities through expansion and redevelopment where appropriate, including the avoidance of adverse cumulative effects and the use of advanced technology, and through prevention of other developments within the vicinity which would restrict or constrain the future development of the facility. Also to safeguard sufficient landfill capacity and also the Energy from Waste facilities used for the recovery of municipal waste in order to meet the requirements of the Municipal Waste Management Strategy.
The need to protect To reduce the overall SO1 To reduce the overall and enhance the contribution of waste contribution of waste environment, making management to climate management to climate How representations have been taken into 27 account
it cleaner and change and ensure that change and ensure that greener. Using facilities are located and facilities are: designed and natural resources in designed to mitigate the located to be resilient to the 4 a sustainable way causes of climate change inevitable changes in and encouraging and adapt to its effects weather such as avoiding more sustainable being located in areas liable construction, to flooding; and, designed, securing high levels constructed and operated in of resource and such a way that they energy efficiency and minimise their impact on a reduction in carbon climate change through emissions, reduced greenhouse gas contributing to emissions. sustainable transport, enhancing SO3 To promote facilities for biodiversity and producing high quality helping to tackle recycled aggregates from climate change construction, demolition and excavation waste, and encourage resource efficient Consultation Statement (Regulation 30 document) construction techniques in order to conserve mineral resources and reduce the reliance on primary aggregates.
Draft Policies.
4.17 In addition to 10 Strategic Objectives, the Emerging Waste Core Strategy contains 9 draft policies which were influenced by the responses received in relation to the two previous Issues and Options consultations. Consultation responses which have helped to shape policies are shown below against each individual draft Policy.
Emerging Waste Core Strategy Draft Policy 1: Targets and Broad Locations for Waste Management Facilities.
4.18 The March 2007 Issues and Options consultation raised a question of the degree of guidance on scale and centralisation of facilities that the Waste Strategy should provide. Responses considered that locations for waste management facilities ought to be provided where need is proven and whilst account should be taken of growth areas, best use should be made of existing facilities in addition to the need for local facilities to serve dispersed areas of population. The key issue raised however was transportation miles and the availability of waste facilities in relation to the source of waste, balanced against cumulative impact of increased number of facilities. The policy attempts to How representations have been taken into 28 account
manage the waste close to where it arises thus reducing transportation and in order to mitigate and minimise effects additional locational criteria is provided 4 by policies 2, 3 and 8. The following has also been noted:
Consultation Statement (Regulation 30 document) Allowance should be made for cross boundary movement of waste across administrative boundaries as the proximity principle would still be applicable; If the waste capacity has been met during the plan period, then if a proposal came forward that it was unreasonable to reject on all other grounds then, it should be allowed to be developed; Waste management facilities should be located close to warehouses/distribution centres but waste facilities should not be placed on strategically important sites that could attract major employers; The strategy should not be over prescriptive and therefore reduce the opportunities to deliver the necessary infrastructure; The Strategy should acknowledge relationship with adjoining authorities, e.g. Warwickshire.
4.19 The September 2008 consultation on Issues and Options Stage 2 raised the question of whether new waste management facilities should be located within or close to the main urban areas and settlements defined in the draft Regional Spatial Strategy (West Midlands Regional Spatial Strategy Phase 2 Revision) and whether facilities should be directly accessible to/from the primary road network and have potential to use sustainable modes of transport i.e. Rail and canals. Consultation responses supported a wider coverage of settlements, including those in Staffordshire Moorlands and also Burntwood (note that Burntwood had a population of 28,000 as at the 2001 census and thus has a larger population than Rugeley but is excluded from the ‘large settlement’ category whereas Rugeley is included. Responses received from Lichfield District Council requested the inclusion of Burntwood as a large settlement) and this has led to the draft regional policy list of urban areas being supplemented in the Emerging Strategy draft Policy 1 by the other significant settlements category. Concern was however raised by consultees that the settlement hierarchy for locating waste sites and therefore further guidance has been provided in this policy of which urban areas are suitable for new waste management facilities to serve local communities or which are suitable for facilities of a strategic/ regional scale. Overall the consultation responses supported industrial locations but requested a flexible approach with an emphasis also on the use of brownfield land. Consideration for co-location of mechanical and biological processes and also thermal treatment facilities at mineral and landfill sites was requested and it was also stated that certain types of facilities needed to be located outside of urban areas for example in some cases organic treatment. With regard to transportation, whilst it was commented that rail would extend the waste catchment area for facilities and road vehicles were the most efficient and economic means of collecting and transporting waste, it was considered that long term options should not be How representations have been taken into 29 account
ruled out. Emerging Waste Core Strategy Draft Policy 1 therefore attempts to be flexible in terms of site location; however additional locational criteria will be necessary to support broad areas. 4
Emerging Waste Core Strategy Draft Policy 2: Criteria for the Location of New Enclosed Waste Management Facilities
4.20 The September 2008 consultation on Issues and Options Stage 2 reached general agreement that industrial locations are the most compatible with waste management uses. Additionally a more flexible approach has been requested with an emphasis on the use of previously developed land. It has been pointed out that certain types of facilities could be co-located including mechanical and thermal processes. With regard to transportation, whilst it was commented that rail would extend the waste catchment area for facilities and road vehicles were the most efficient and economic means of collecting and transporting waste, it was considered that long term options for rail should not be ruled out. This policy therefore supports opportunities for waste management facilities on general industrial and previously developed land within broad areas identified in Draft Policy 1 and provides additional locational criteria for
enclosed waste management facilities. The following responses have also Consultation Statement (Regulation 30 document) been noted:
Flexibility of location required to cope with technology changes; Policy should not be too prescriptive over locations – proximity and transport may be as important; Waste management facilities should be recognised as being part of the solution and not the problem – proactive approach; Smaller waste management facilities should be located close to the sources of origin such as the listed settlements where environmentally acceptable. Larger facilities should be located as close to source as possible but must be next to a good road infrastructure to allow for relatively easy transport for waste imported from outside the sub-region. On-farm facilities in more rural areas should not be excluded particularly for treating organic/food waste – rural renaissance/farm diversification.
Emerging Waste Core Strategy Draft Policy 3: Criteria for the Location of Open Air Facilities
4.21 With regard to open air processes such as composting, landfill and aggregate recycling and reprocessing, a general consensus resulted from the 2008 consultation on Issues and Options Stage 2 that the most appropriate locations for these uses are on agricultural land subject to meeting the requirements in relation to amenity, contamination and environment. A concern was raised in relation to offices and storage of recyclables included in open air operations. This might result in a negative impact on the rural landscape. The policy therefore should provide an opportunity for open air facilities on a temporary basis where there are doubts remaining about impact on the amenities. Further comments have also been received: How representations have been taken into 30 account
Agricultural land provides the most appropriate location for open air processes such as composting, landfill and aggregate recycling and 4 reprocessing. However, these sites will need to be carefully selected taking all relevant factors into account with regard to amenity, Consultation Statement (Regulation 30 document) contamination and protection of environmental and historic quality; Only open and poor quality agricultural land that has little or few planning constraints is likely to be required for open air processing of organic waste. Inert waste may be used in core levelling works if overlain with organic materials and serve to bring poor quality land back into beneficial use; Composting can have a rural location (with appropriate concern for travel distances) but should be screened by landscape features or existing farm buildings. Aggregate recycling is a non-rural use and more appropriate for the urban locations close to sources of supply. On the other hand they should be sited within working quarries and current landfill sites; Composting can be best carried out on previously developed land which has access to farm land for spreading the compost; Open air operations may include storage of recyclables before distribution elsewhere, which would all have a negative impact on the rural landscape. Previously developed sites close to existing transport networks would therefore be more appropriate; Suitable brownfield sites, mineral and landfill sites should also be included within the list of appropriate areas for open air facilities.
Emerging Waste Core Strategy Draft Policy 4: Maximising Waste Re-use, Recycling & Recovery of Resources
4.22 The earlier Issues and Options consultations reached general agreement on the need for a ‘Waste Hierarchy’ policy. Responses included:
More facilities to be delivered through the Waste Core Strategy to deal with commercial food waste; Need to make reference to the need for organic facilities to take commercial food waste. Clarification needed between the numbers of existing garden/green organic facilities and food/complex organic facilities; Further alignment needed with carbon management and energy policy – waste as a fuel resource not a recycling resource; The number of landfill sites for inert waste typically arising from the construction industry is in short supply to the extent that HGVs are travelling long distances and therefore having a knock on effect for pollution and greenhouse gases.
Emerging Waste Core Strategy Draft Policy 5: Management of Construction, Demolition and Excavation Waste How representations have been taken into 31 account
4.23 The earlier Issues and Options consultations reached general agreement on the need for more non-landfill waste management facilities and it is considered that more construction and demolition waste facilities should be planned for. 4 The following has been noted:
There is a need for treatment/recycling infrastructure for construction and demolition waste, which should include contaminated wood, plastics, glass, plaster board, etc. To include a policy within the core strategy that acknowledges that despite national guidelines seeking to limit the amount of waste being disposed at landfill, there will continue to be a requirement of a certain amount of waste to enhance the restoration of mineral workings within the county.
Emerging Waste Core Strategy Draft Policy 6: Waste Minimisation and Major Development Proposals
4.24 Earlier Issues and Options consultation responses supported the need for a waste minimisation and major development proposals policy. Responses included: Consultation Statement (Regulation 30 document) It must be made clear within the strategy that all streams of waste are properly planned for (including Commercial and Industrial as well as Municipal) and all new developments should consider how waste will be managed before collection and that waste management facilities must be located within sensible travelling distances; Local Development Documents should include a policy about all new development making appropriate provision for the storage of segregated waste in a visually acceptable manner. A link to Sustainable Building Standards for the West Midlands was suggested.
Emerging Waste Core Strategy Draft Policy 7: Safeguarding Strategic Waste Facilities and the Location of Development in the Vicinity of Waste Management Facilities
4.25 Responses received in connection with the earlier Issues and Options consultations supported a policy which protected our waste infrastructure. Comments included:
Only those sites should be safeguarded if they are consistent with the Waste Core Strategy and would ensure that, what may be a non-conforming use, will not be continued should the site become vacant and a more suitable alternative sites will need to be found; It is important that any waste management sites that have been granted planning permission are adequately protected from encroachment by incompatible uses. Public amenity should be protected from the impacts that may arise from waste management, in particular landfill operations. It is equally important that existing waste management facilities should How representations have been taken into 32 account
be afforded protection from locating sensitive development in close proximity; 4 Replacing existing sites can be very hard and Local Planning Authorities should only contemplate NOT safeguarding them if they are willing to use Consultation Statement (Regulation 30 document) Compulsory Purchase Order powers to secure alternative and better sites. If existing sites are operating and in accordance with their planning and environmental permits they should be operating acceptably anyway. In fact, by NOT safeguarding existing sites, this will simply encourage encroachment by more sensitive development around the site, making matters worse.
Emerging Waste Core Strategy Draft Policy 8: Enhancement of Existing Waste Management Facilities
4.26 Previous consultations have shown support for a policy that allows for enhancement and expansion of existing waste facilities especially where it is possible for sites able to manage several types of waste on one site and also where small and medium sized enterprises (SMEs) in the locality can use recycled products. Refer to responses to question 6 of March 2007 consultation and question 6 of September 2008 consultation.
Emerging Waste Core Strategy Draft Policy 9: High Quality Design
4.27 High Quality Design has not been discussed in great detail in our previous consultation documents. However, the idea of incorporating high quality design in waste management proposals has derived from the comments provided by the local councillors, general public and District planning officers. One particular comment was received as a result of the 2008 consultation listing the following requirement that all proposals related to waste management facilities should include high quality design – materials, appearance, boundary treatment (fencing and landscaping) and off-site landscaping.
c) Emerging Joint Waste Core Strategy, August 2010
4.28 The total number of responses in relation to the nine policies and subsequent questions posed by the Emerging Joint Waste Core Strategy consultation document in August 2010 amounted to 175 individual comments received from the 38 bodies/individuals.
4.29 It should be noted that the consultation ended on the 1 October 2010 and whilst a holding response had been submitted by the key stakeholder South Staffordshire District Council, the final response was received by letter on 28 January 2011. As the final response was received almost four months after the consultation deadline, only the holding response was considered in the analysis shown in the table below and the analysis in Appendix 5. The final response made comments and raised issues specifically in relation to Policies 1, 2, 4, 5, 6, and 9, and these comments were considered separately. How representations have been taken into 33 account
Table 5 Respondents to individual questions - Emerging Joint Waste Core Strategy August 2010. 4 Policy 1 24 out of the 38 / 63% (note 2 responses from Kinver Parish)
Policy 2 18 out of the 38 / 47%
Policy 3 13 out of the 38 / 34%
Policy 4 15 out of the 38/ 39%
Policy 5 15 out of the 38 / 39%
Policy 6 12 out of the 38 / 32%
Policy 7 13 out of the 38 / 34%
Policy 8 13 out of the 38/ 34% (note 2 responses from Crestwood Environmental Ltd)
Policy 9 16 out of the 38 / 42% Consultation Statement (Regulation 30 document)
Characteristics of Waste 4 out of the 38 / 11% Management in Staffordshire and Stoke-on-Trent
Vision statement 4 out of 38 / 11%
Strategic Objectives 4 out of 38 / 11%
General comments on Strategy 23 out of 38 / 61% (note 3 responses received from English Heritage, 2 from Cannock Chase Council and 2 from Biffa)
Summary of comments received
4.30 The 175 individual comments received in relation to the Emerging Joint Waste Core Strategy consultation in August 2010 were carefully considered in the production of the April 2011 consultation on the Draft revised policies. Appendix 5 provides a summary of the reduced and combined comments and main issues raised. To view the full version of the comment received by a specific stakeholder, please refer to the document 'Part 3 JWCS Consultation Summary' in the Joint Waste Core Strategy virtual library. The main points raised were:
The locational approach was queried, in particular the list of general industrial land suitable for waste management facilities, and the inclusion of certain urban areas as broad locations. A definition of 'close to urban areas' was requested. A definition of 'enclosed waste management facilities' was requested. How representations have been taken into 34 account
Up-to-date data, landfill diversion targets and capacity/facility targets were questioned. 4 Water environment and Historic environment should be referenced. Guidance needed on how to make best use of Site Waste Management Consultation Statement (Regulation 30 document) Plans. Some of the policy monitoring targets were considered inappropriate. Minor amendments to wording of policies. Opposition was raised to the proposal to develop an Energy Recovery Facility at Kingswood Lakeside Cannock. The decision relating to the Energy Recovery Facility permitted at Four Ashes was also questioned.
4.31 In addition to the analysis provided in Appendix 5, outlined below are the comments and issues raised in the final response received from South Staffordshire Council by letter on 28 January 2011. Comments and issues were raised in connection with Policies 1, 2, 4, 5, 6 and 9. The main points were:
1. The Council comments that many of their Main Service villages do not have a supply of previously developed land or general industrial land or existing waste management facilities, therefore Draft Policy 1 is not sufficiently flexible to achieve the objectives of the strategy. Definition is required of 'within or close' to the urban area and what waste management facilities would be appropriate. 2. Concern is raised over the enclosure of waste management facilities and the Council considers greater flexibility is needed. A caveat is requested to state 'proposals for new enclosed facilities will be supported where practical and where technology supports'. 3. Concern raised that there is very little reference in many of the policies to delivering facilities 'where there is a proven need' for them.The Council supports the principle of 'equivalent self-sufficiency, however requests that applicants are required to demonstrate that there is a proven need of the new facility, i.e. a demonstrable waste treatment gap, including how imported waste will be taken into consideration. 4. In order to risk prejudicing movement up the Waste Hierarchy, the capacity provided through the provision of Energy Recovery Facilities should be limited. Support however is given to Draft Policy 9 which promotes high quality design policy but the creation of renewable energy as well as its use should be promoted. 5. Account should be taken of cumulative impact of previous waste disposal facilities on the well-being of the local community. With regard to incineration and the provision of Energy Recovery Facilities, the Council should have regard to the consequential requirement to find suitable sites for the processing of Bottom Ash. 6. The Council suggests that the locational criteria set out in PPS10 Annex E are used when considering the issues and impacts that a proposed waste management facility will generate. How representations have been taken into 35 account
7. Proposals for waste management in the Green Belt should demonstrate that they are consistent with national and local policy. 8. The Council supports the ethos of Draft Policies 4, 5 and 6. Reference 4 should be made to Local Authority Core Strategies and importance of continued close working.
How main issues were taken into account by the Revised draft policies for Joint Waste Core Strategy April 2011 consultation
4.32 Appendix 5 provides a summary of the representations received in connection with the Emerging Joint Waste Core Strategy and our response detailing how these representations were taken into account when drafting the revised draft policies April 2011 consultation document. For example:
The April 2011 consultation document amended and reduced the 9 policies down to 4 revised policies. Whilst Revised Policy 2 provides the broad locations for waste management facilities as the main urban areas in the county, close to where waste arises, Policy 3 provides general criteria for new and enhanced waste facilities.The indicative list of general industrial
land suitable for a waste management use is no longer included in the Consultation Statement (Regulation 30 document) Strategy, instead Policy 2 relates to broad locations which list the main towns in the plan area. The criteria provided by Policy 3 then directs development to certain locations (preference is for industrial land and previously developed land where available and expansion of suitable existing waste management facilities within or close to the main urban areas in the county). The Waste Core Strategy is not based on site allocations, however it is considered the Strategy is flexible as the Site Assessment Report demonstrates the extent of employment land and previously developed land within the county which would be able to accommodate the future demand for waste management sites. This approach replicates criteria in PPS10 and the RSS Phase 2 Review. A distance for what is meant by 'close to' the urban area has not been defined, as the Strategy allows for development on suitable rural industrial land and previously developed land. Organic waste management facilities are also recognised as suitable in farm locations close to the main urban areas and it is recognised that there are a number of existing organic waste management facilities close to the urban areas which may want to expand in the future. A specified distance may limit the flexibility of the Strategy and the development of suitable rural industrial and farm sites. Policy 3 also lists general requirements for facilities to be fully contained within buildings or contained structures appropriate to the technology or process. Exceptions criteria however is included for open air operations. The evidence base has been revisited and the landfill diversion targets and capacity/facility targets have been adjusted. Waste forecasts and targets are based on the most up-to-date data: the Joint Municipal Waste Management Strategy 2007; regional policy (West Midlands Regional Spatial Strategy Phase 2 Review); and existing waste management capacity updated with planning permissions up to 1 April 2011. Whilst it How representations have been taken into 36 account
is acknowledged that the provisions of the Localism Bill, which is now before Parliament, will revoke regional spatial strategies, the technical 4 evidence that informed the West Midlands Regional Spatial Strategy Phase 2 Review has not been overtaken by more up to date information. Consultation Statement (Regulation 30 document) As the Joint Municipal Waste Management Strategy is due a refresh in 2012, clarification has also been sought from the Joint Waste Management Board about any specific needs of the Waste Disposal and Collection Authorities that should be included. Landfill diversion targets in Revised Policy 2 are now more ambitious than those stated in regional policy and monitoring performance indicators for policies have been revised. Many of the suggested amendments to policy wording have been incorporated. For example Revised Policy 4 relates to sustainable design and protection.This incorporates considerations of Green Belt, Site Waste Management Plans, historic environment and water environment. The Strategy is informed by the Joint Municipal Waste Management Strategy (MWMS). The MWMS approved in 2007 sets out waste management methods for managing municipal waste. The Four Ashes Energy Recovery Facility has a planning permission and is under construction. The proposed Energy Recovery Facility at Cannock is a current planning application, outside of the Joint Waste Core Strategy process.
4.33 As the South Staffordshire Council comments of 28 January 2011 was received after the analysis provided by Appendix 5 had been undertaken, the comments (summarised in para 4.40 above) were dealt with separately and have been taken into account in the following ways:
1. South Staffordshire Council has confirmed() that the main service villages are their main urban areas and therefore have all been included in Revised Policy 2 which provides the broad locations for new and enhanced waste management facilities. In respect of location distance from main urban area, there are a number of existing organic waste management facilities in South Staffordshire close to the Main Service Villages which may want to expand in the future. Policy 2 does not specify a distance as this may limit the flexibility of the Strategy and the development of suitable rural industrial and farm sites. 2. Revised Policy 3 includes general requirements and exceptions criteria for new and enhanced waste management facilities. General requirements are for facilities to be fully contained within buildings or contained structures appropriate to the technology or process. Exceptions criteria relates to open air operations. 3. Revised Policy 2 outlines targets for landfill diversion and net self sufficiency however these targets are not to be regarded as a cap, and proposals which deliver economic growth and manage waste higher up
Stakeholder meeting held with Mr Andy Johnson of South Staffordshire Council on 30 March 2011 How representations have been taken into 37 account
the waste hierarchy and reduce the amount of waste being landfilled will be given favourable consideration.The approach is consistent with PPS10 which states that waste planning authorities should not require applicants 4 to demonstrate a quantitative market need for their proposal. (PPS10 para 22. Also para 7.27 of the Companion Guide). 4. Revised Policy 1 relates to 'Waste as A Resource' and proposals for energy recovery (Policy 1.5) should demonstrate that the waste is residual waste, which cannot practically be reused, recycled or processed to recover materials. Revised Policy 4 contains criteria that proposals should make a positive contribution where appropriate to renewable energy supply (Policy 4.1). The Strategy does not set targets for additional energy recovery capacity. 5. Revised Policy 4 contains criteria for protection of environmental quality (Policy 4.2) and cumulative impact is a consideration within the People and Local Communities section. 6. The revised policies take on board the requirements of PPS10 and in particular the locational criteria set out in paragraph 20 and the factors set out in Annex E. The locational criteria set out in the RSS Phase 2 Review (Policy W5) has also been incorporated. Consultation Statement (Regulation 30 document) 7. Revised policy 4 incorporates Green Belt as a consideration and proposals must be in accordance with national and local policy. 8. Revised policies 1 and 4 require proposals to take account of local policy incorporated in Local Development Frameworks. d) Revised Draft Policies, April 2011
Summary of comments received
4.34 26 bodies / individuals responded to the informal consultation on the 'Revised Draft Policies' in April 2011. The total number of responses in relation to the revised draft policies amounted to 50 responses. Appendix 3 provides a summary of the comments received. For example the following observations can be made from the consultation responses:
Evidence base and data was queried. In particular the recycling rate for municipal waste was questioned. Also the amount of landfill allowance was queried and encouragement of landfill diversion of commercial and industrial waste as well as municipal waste was raised as an issue.Targets for recycling of construction, demolition and excavation waste and the monitoring of this waste stream was also queried.
Opposition to incineration was raised and reference was made to the Four Ashes Energy Recovery Facility and the Energy Recovery Facility proposal at Kingswood Lakeside, Cannock.
The listed sites to be safeguarded was queried. How representations have been taken into 38 account
Policies to give consideration to mineral sterilisation, land instability and AONB Management Plan was requested. 4 The Climate Change issue was queried. Consultation Statement (Regulation 30 document) Amendments were suggested in relation to the wording of the issues, strategic objectives and policies.
How main issues have been taken into consideration for Joint Waste Core Strategy Publication document
4.35 Appendix 6 summarises how the main issues and comments raised by consultees in response to the April 2011 consultation on the 'Revised Draft Policies' have been taken into consideration and how these have informed the process on which the Joint Waste Core Strategy Publication document and four policies were developed. Appendix 6 justifies the approach being taken by the Councils, and outlines where suggestions have been incorporated into policy, or outlines why the consultees suggestion is not relevant. In particular:
The evidence base has been reviewed again. In respect of the amount of landfill allowance specified, the reasoned justification for Policy 2 clarifies that landfill diversion targets are minimum, however whilst landfill is a 'last resort', it must be recognised that some waste streams cannot be economically or beneficially re-used, recycled or recovered for energy. Staffordshire also has a number of operational landfill sites and there is also potential additional capacity available at planning obligated sites, i.e. mineral sites with planning permission to be restored by landfilling. Landfill sites in Staffordshire will therefore continue to play a role, at least in the short term, in managing waste from Staffordshire and Stoke-on-Trent and from adjoining authorities. In respect of recycling rates for municipal waste, the Joint Waste Core Strategy is informed by the Joint Municipal Waste Management Strategy 2007. Finally, in respect of construction, demolition and excavation waste, the targets for new recycling capacity are minimum targets and monitoring performance indicators have been revised. Policy 1 relates to waste as a resource and policy 1.5 relates to energy recovery.The reasoned justification for the policy makes reference to the evidence base which indicates there is no anticipated shortage of residual treatment capacity for the plan period. However where proposals are put forward, the applicant should demonstrate that the development would not undermine more sustainable methods of waste management, such as re-use, recycling and composting. In respect to the two Energy Recovery Facilities at Four Ashes and Cannock, the Four Ashes facility is currently under construction and planning permission was granted at July 2011 Planning Committee for the Kingswood Lakeside Cannock facility. How representations have been taken into 39 account
The sites listed for safeguarding are those which are required to deliver the requirements of the Joint Municipal Waste Management Strategy. In addition the hazardous landfill is included for safeguarding. Despite 4 representations received, the list has not been amended for the Publication document to include additional sites further up the waste hierarchy, as it is considered that all waste management facilities will be afforded a form of protection by Policy 2.5. Amendments were made to Policy 4 in the Publication document and reference to the AONB Management Plan, mineral sterilisation and land instability have been incorporated into the reasoned justification for the policy. Amendments were made to the issues, strategic objectives, and policies in the Publication document. In particular the Revised draft Policies April 2011 consultation document comprised of five issues. Comments made in relation to the Climate Change issues have been taken on board and the issues have been revised and the Publication document now comprises of four issues, four strategic objectives and four policies. Many of the amendments and policy wording suggested by stakeholders have also been incorporated into the Publication document. Consultation Statement (Regulation 30 document) 40 Next Steps
5 Next Steps
5 Timetable for preparation of Joint Waste Core Strategy
Consultation Statement (Regulation 30 document) 5.1 The submission draft of the Joint Waste Core Strategy ('Publication Document') has been prepared by Staffordshire County Council and Stoke-on-Trent City Council and will be subject to representations on the ‘soundness’ of the Core Strategy for a period of six weeks beginning in September 2011. This will satisfy Regulation 27 of the Town and Country Planning (Local Development) (England) Regulations 2004, as amended in 2008 and 2009.
5.2 The Councils will then consider the responses and produce a Statement of Representations, in accordance with Regulation 30 (1) (e), summarising the main issues raised in those representations. The comments received will be reported to meetings of our Full Councils in December 2011 and any necessary minor changes will be made to the ‘Publication Document’ before submitting it to the Secretary of State in January 2012 for independent examination. The Secretary of State will then appoint an Inspector, who will hold an 'Examination' into the 'soundness' of the plan. It is anticipated that the Joint Waste Core Strategy will be adopted in Autumn 2012. Appendices 41
6 Appendices
Appendix 1: Poster, Issues and Options March 2007 consultation 6 Consultation Statement (Regulation 30 document) 42 Appendices
Appendix 2: Flyer, Issues and Options Part 2 September 2008 consultation
6 Consultation Statement (Regulation 30 document) Appendices 43
Appendix 3: Consultees List, Emerging Joint Waste Core Strategy August 2010 consultation 6 Table 6
Waste Recycling Group - Mr P.Taylor Denstone Post Office North Western Division
Hanson Aggregates Ltd Mrs Hudson Department for Constitutional Affairs (through GOWM)
Ideal Standard [ Formally Mr V.Whitby-Smith Department for Culture Armitage Ware] Media & Sport
Arthur Wright & Son Mr K.Stubbington Department for Education and Skills (through GOWM)
Auto Line Motor Salvage Cllr. Graham Sedgley Department for Environment, Food & Rural Consultation Statement (Regulation 30 document) Affairs (DEFRA) (through GOWM)
Baggeridge Brick plc Mrs K.Gibson Department for Environment, Food and Rural Affairs (DEFRA)
Barnacle and Son Mrs H.Grossman Department for Work and Pensions
Biddulph Sand Ltd. Mrs D.Knapper Department of Culture Media and Sport
Lafarge Cement UK Severn Trent Water Ltd Derbyshire Dales District Council
Tardis Environmental uk Forestry Commission Dickinson Dees Limited
Brassington & Co. Mrs Brian Downings Waste Recovery
British Gypsum Limited Mr Brian Dr Wright
Proactive Waste Solutions M.G. Christie Dr. Harvey Ltd
West Midlands Regional Mr. Hirst Draycott Post Office Assembly (WMRA) 44 Appendices
Coltman Precast Concrete Mrs. Colbeck Draycott-in-the-Clay Parish Ltd. Council 6 DME Tyres Ltd. Mr Colbeck Draycott-in-the-Clay Parish Consultation Statement (Regulation 30 document) Council
Aggregate Industries UK Ltd Mr Condliffe Drayton Bassett Parish Council
International Power, Rugeley Mr. Davies Dudley Metropolitan Power Ltd Borough Council
Cllr. N. Massey Mr Deakes Dunstall Parish Council
G. Wylie & Son Ltd. Mr CJ.Dimberline Duraline Hotelware Company / Dudson Duraline
G.T. & C. Talbot (Mr. G.T. Mrs R.Dodd E. A. Heath (R & W) Ltd. Talbot)
H. E. Humphries Ltd. Mr Donaldson E.A. Barnes & Sons Ltd. (Bloomfield Recycling)
WBB Minerals Mrs Donaldson Eagle Motors
Ibstock Brick Ltd Mr G. Donaldson East Mercia Chamber of Commerce
Jack Moody Ltd. Mr. I.Duckworth East Staffordshire Primary Care Trust
Waterford Wedgwood UK Mr J.Dunne Eccleshall Library plc
Lafarge Aggregates Ltd. Mr T English Eccleshall Parish Council
LWD Waste Services Mrs English Eccleshall Post Office
Cannock Chase AONB Mr J.Francis Ed. Weetman (Haulage & Partnership Storage) Ltd.
Moorland Green Waste Mrs S.Francis Edmund Nuttall Ltd. Recycling
Sustainability West Midlands Mrs Gibson Ellenhall Parish Meeting
Mr.R. Powell Mr. Sharrock English Partnerships Appendices 45
GW Minerals Environmental Staffordshire Stone Environment Agency - Consultancy (UK) Limited Midlands Region, Upper Severn Area 6
Dr. J. Hegarty Madeley Conservation Environment Agency - Group North West Region
OSS Group Ltd The Coal Authority Envirotech
Home Office H & H Bowe Ltd Ernies Skip Hire
Parkhill Estates Ltd. Mrs R.Davis Essington Quarry Liaison Group
G P Planning Ltd Fisher German LLP ESTROBEST
Radleigh Homes Mr D.Milburn Eternit Clay Tiles Ltd.
Cllr. P. Silk D.P.D.S Consulting Eternit Clay Tiles Ltd. Group Consultation Statement (Regulation 30 document) J Christopher Ashton Cemex UK Operations Eurocare Environmental Limited Services Ltd.
UK Coal Plc. Mr L.Bates European Metal Recycling Ltd.
Cemex FTMINS Evans Management Ltd.
Salop Sand and Gravel Mr D.Milburn F S P Concrete Products Supply Co. Ltd.
Severn Trent Water Ltd. Dr A.Morley-Davis F. McGuiness & Sons Ltd.
Severn Trent Water Ltd. Mr N.Taylor F.Watson & Sons
National Grid Transco Mr A.Perkins F.G. Davis & Son Ltd.
H. Brown & Son Recycling Mr P.Taylor Fallows Landfill Ltd
Government Office for the Mr J.Mcaneny Fawfieldhead Parish West Midlands (GOWM) Council
A. Redman & Son Mrs A.Smith Fazeley Town Council
Tarmac Ltd. Mr R.Thornton Featherstone Parish Council
Tarmac Ltd. Mr Johnson FFC Landscape Architects 46 Appendices
Tarmac Ltd. Mr N.Hooper Fight Landfill Action Group (FLAGS) 6 Walsall Concrete Mrs A.Davied Forest of Mercia Consultation Statement (Regulation 30 document) W. M. Briers & Son Mrs. Higginson Freethcartwright LLP (Tamworth) Ltd.
Tourism West Midlands and Tarmac Ltd Friends of the Earth - North Advantage West Midlands Staffordshire
Aggregate Industries UK Ltd Mr.B.McNulty Fusion Online Ltd
Fisher German Chartered Mr.R.Catmur Future Waste & Surveyors Reclamation
Newcastle under Lyme Staffordshire Moorlands G.D. Golding Waste Borough Council District Council Transfer Station
United Utilities Wienerberger Limited G.H. Astbury Dross Processors
Cemex Wienerberger Limited Geoff Bowker Ltd
Enviros Veolia Environmental Glascote Library Services Birmingham Ltd
Barton Willmore Mr.G.Hopkin Glenside (Recycling) Ltd.
Carter Jonas LLP Mr.Pickstock Glenside (Recycling) Ltd.
Crestwood Environmental Ms.Cottom Grange Aggregates
D. K. Symes Associates. Stone and Eccleshall Great Bridgeford Post Gazette Office
DPDS Consulting Group Cannock Chase District Great Haywood Post Office Council
Entec Mr.Boston Great Wyrley Library
Geoplan Ltd. A.N.Robinson GreenCore Recycling
GRM Development Ms.L.Glendining Greenpark Energy Ltd Solutions Limited
Staffordshire Moorlands Mr Deakin Grindon Parish Council District Council Appendices 47
Kent Jones & Done Foston and Scropton GVA Grimley Parish Council 6 Halletec Associates Ltd. Mr.B.Keates H & R Johnson Tiles Ltd.
Gareth Holland, FRICS, Friends of Fisherwick H. J. Banks & Co. Ltd. FAAV Woods, Lakes & Wildife
Peter Diffey & Associates Mr A. Harp H. J. Banks & Co. Ltd.
Rushton Hickman Mr. Davis H. Nickolls & Son Ltd Partnership
Derbyshire Association of Mrs T.Dimberline H. Skips Local Councils (DALC)
The Mineral Planning Group S Moore Hamptons (J.M. & N.W. Hampton)
Framptons Alliance Planning Hamstall Ridware Parish
Council Consultation Statement (Regulation 30 document)
P.P.S. Midlands (Phillips Wardell Armstrong LLP Hanford Waste Services Planning Services Ltd) Ltd.
Maer and Aston Parish Mrs.Brangwin Hargreaves Industrial Council Services Ltd
Marchington Parish Council Smith Gore Harold Ratcliffe & Son
Mavesyn and Hill Ridware GVA Grimley Harrishead Post Office Parish Council
Mayfield Parish Council Mr N.Gibson Hartley's Commercials
Milwich with Fradswell Mr P.Bennett Hatherton Parish Council Parish Council
Newborough Parish Council Mr C.Hamer Heath Hayes Library
Norton Canes Parish Mr Nicholls Heathylee Parish Council Council
Oakamoor Parish Council Mr J.Clarke Heaton Parish Council
Onecote Parish Council Creswell Parish Council Hednesford Library
Outwoods Parish Council United Utilities Henry Butcher Smith Vincent 48 Appendices
Pattingham and Patshull Government Office for Hepworth Building Parish Council the West Midlands Products Ltd. 6 Penkridge Parish Council Mrs J.Heath Hepworth Building Consultation Statement (Regulation 30 document) Products Ltd.
Perton Parish Council Mr A.Johnson High Offley Parish Council
Ranton Parish Council Mrs S.Lewis Highways Agency
Rocester Parish Council Mrs M.Avis Highways Agency
Rolleston-on-Dove Parish Coventry City Council Hilderstone Parish Council Council
Rugeley Town Council Mrs J. Steer Himley Parish Council
The Georgian Group Mr M.Dodson Holford Contracts (Staffs) Ltd
The National Forest Greenpark Energy Ltd Hollinsclough Parish Company Council
The Society for the BAV Crushers Limited Hollybank Trading LLP Protection of Ancient Buildings
The Stafford Historical and Mrs S.Bascombe Holmcroft Library Civic Society
The Victorian Society Mr I.Bascombe Horton Parish Council
Freight Transport Mrs R.Fenton Hulme Upright Manning Association
Inland Waterways Mr N.Aldridge Hyde Lea Parish Council Association (Lichfield Branch)
Auto-Cycle Union Ltd Miss F.Armitage Ibstock Building Products Ltd
Staffordshire Moorlands Mr C.Griffiths Ilam Parish Council Primary Care Trust
Network Rail Mr. Hall Ipstones Parish Council
Road Haulage Association Mr Harris Ipstones Sub-Post Office Ltd Appendices 49
Severn Navigation Mrs Harrison Isaac Shaw Ltd. Restoration Trust 6 Sustrans Miss Holland J & S Metals
Cory Environmental Mr A.Holland J L Goodfellow (Central) Ltd.
Salop Sand and Gravel Ltd Mr Housley J. & K. Supplies c/o Alliance Planning. (Moddeshall Cricket Club)
British Ceramic Mr Hudson J. Hossack & Associates Confederation (BCC) Ltd
Tamworth Borough Council Mr J.Meadows J. Oldham & Co. (Stonemasons) Ltd.
Mr. G. Hughes Mr Meakin J. Taberner Plant Hire Ltd.
Confederation of UK Coal Mrs Meakin J. Watson & Sons Consultation Statement (Regulation 30 document) Producers (COALPRO)
Scott Wilson Mr Middleton J.G.P. Rubbish Removals
Hughes Concrete Ltd Mrs Mobley J.N.S. Metals
Association for Organics Mr Mobley Jeffrey Armstrong Recycling
The Chartered Institute of Mrs Murdoch Johnson Aggregates Waste Management (CIWM) Limited
Country Land and Business Mrs Parks Joseph Kimberley & Sons Association Ltd.
National Farmers Union Mrs Parr Josiah Wedgwood & Sons (NFU) Ltd.
Business Link (Staffordshire) Mrs L Podmore Jumbo Skips Ltd Ltd.
InStaffs (UK) Ltd Mr Perry K.J. Baines Commercial
Royal Worcester & Spode, Mr Pritchar Keele Parish Council
Kerrygold Co. Ltd. Mrs Robson Keith Roberts Projects Ltd
Fuchs Lubricants (UK) Plc Mr Redmond Kent Jones & Done (Century Oils Ltd) 50 Appendices
Reuse Collections Ltd t/a Mr J.Baddeley Kidsgrove Library Berryman 6 Michelin Tyres Mrs. Breeze Kidsgrove Post Office Consultation Statement (Regulation 30 document) Sport Across Staffordshire Mr Robinson Kidsgrove Town Council
Stafford Borough Council Mr Rowley Kier Mining
East Staffordshire Borough Mrs Shackman King Street Breakers Council
Lichfield District Council Mrs L Smith Kings Bromley Parish Council
Brizlincote Parish Council Mrs P. Smith Kingsley Holt Post Office
Aucott Holdings Ltd. Hilderstone Parish Kingsley Parish Council Council,
Alrewas & Fradley with Mrs Turner Kingstone Parish Council Streethay Parish Council
Alstonefield Parish Council Mr Twigge Kingswinford Waste Services Ltd.
Alton Parish Council Mr Tyler Knight and Sons
Anslow Parish Council Mr Tyler Knutton Quarry Liaison Group
Armitage with Handsacre Mrs Tyler Knypersley Post Office Parish Council
Audley Parish Council Mr J Went Kwik Save Stores
Barlaston Parish Council Mrs Wheatley Kwik Save Stores
Barton-under-Needwood Mrs.Whiston Kwik Save Stores Parish Council
Berkswich Parish Council Mr Wilson Kwik Save Stores
Biddulph Town Council Mrs Wilson L.T.R. Recovery Services
Blore with Swinscoe Parish Mrs H Wood Lafarge Aggregates Ltd. Meeting
Branston Parish Council Mrs Wright Lafarge Aggregates Ltd. Appendices 51
Brewood and Coven Parish Mr Tomlinson Lafarge Cement UK Council 6 Bridgtown Parish Council Mrs P.Shotton Landor Society of Rugeley
Brocton Parish Council Mrs J.Roberts Lawton's Breakers
Brown Edge Parish Council Mr R.Cunningham Leekfrith Parish Council
Burntwood Town Council Mr K.Deakes Leese Bros. (Eccleshall) Ltd.
Butterton Parish Council Leith Planning Leigh Parish Council
Stone Rural Parish Council Dr S.Smith Lichfield City Council
Chapel and Hill Chorlton Mr A.Waterhouse Lichfield City Council Parish Council
Cheadle Town Council Mr J.Evans Lichfield Civic Society
Cheslyn Hay Parish Council Mrs W.Godfrey Lichfield Rail Promotion Consultation Statement (Regulation 30 document) Group
Clifton Campville with Mr A.Simons Linkwaste (UK) Ltd. Thorpe Constantine Parish Council
Colwich Parish Council Havey Little Haywood Post Office
Creswell Parish Council Probyn Longdon Parish Council
Croxden Parish Council Miss A.Vaughan Longnor Parish Council
Curborough/Elmhurst/Farewell Mr Bottomer Longnor Post Office and Chorley Parish Council
Denstone Parish Council Ms J.Pearson LW Skip Hire (Mr. L. Wallace)
Dilhorne Parish Council Mr N.Hadley M & I Parts
Draycott-in-the-Moors Parish Mr R.Willis Madeley Conservation Council Group
Dunston with Coppenhall mr M.Barker Mainline Pipelines Ltd. Parish Council c/o Fisher Germans Chartered Surveyors
Simpro Ltd. Mr Griffin Mainly Ford 52 Appendices
Edingale Parish Council Mr M.Grundy Malcolm Harrison Ltd
6 Elford Parish Council Mr R.Lane Mark Smith Transport
Consultation Statement (Regulation 30 document) Ellastone Parish Council Mr N.Gibson Marks & Spencer PLC
Endon with Stanley Parish Cllr. R.Lees Marston Metals Council
Enville Parish Council JPE Holdings Ltd Marston Parish Meeting
Essington Parish Council Mr S.Ross Martell, Hudson & Knight
Farley Parish Council Mr J.Elsby Martin Dale
Forsbrook Parish Council Alrewas Conservation Mavesyn and Hill Ridware Group Parish Council
Forton Parish Council Mr M.Pointon Meir Mini Skips
Fulford Parish Council Mr A.Sanders Merseyside Passenger Transport Authority
Gnosall Parish Council Mr M.Fellows Mid Staffordshire Health Authority
Great Wyrley Parish Council, Mrs D.Whittaker Middleton Hall Quarry Liaison Group
Hammerwich Parish Council Shah Mineral Surveying Services
Hanbury Parish Council British Waterways Miss Hargreaves
Harlaston Parish Council National Trust Monier Ltd
Haughton Parish Council Ms L.Wheatley Moores (Stoke-on-Trent) Ltd.
Heath Hayes & Wimblebury Ramblers Association Moorlands Hospital Parish Council Staffordshire Area & Heart of England Way Association
Hilton Parish Council Mr M.Rogers Mormet (Alloys) Ltd.
Hints and Canwell Parish Mrs J.Rogers Morrisons Supermakets Council
Hoar Cross Parish Council Steelite International Morrisons Supermarkets plc Appendices 53
Hopton and Coton Parish Cllr. J.Russell Morwaste Council 6 Huntington Parish Council Mr FC. Hirst Mr & Mrs Heggarty
Ingestre with Tixall Parish Mr M.Hardenberg Mr Dodd Council
Kings Bromley Parish Mr.CJ Hicken Mr Hughes Council
Kinver Parish Council Dr I.Pearson MP Mr Kenny
Lapley, Stretton and Mrs P.Sloan Mr Lythgoe Wheaton Aston Parish Council
Leek Town Council Mr F.Wright Mr Mason
Loggerheads Parish Council Loggerheads Parish Mr Oxby
Council Consultation Statement (Regulation 30 document)
Longsdon Parish Council Mr G.Hughes Mr P Till
Lower Penn Parish Council Mr M.Priddy Mr P. Breedon
Madeley Parish Council Mr D.Bray Mr Plant
Sandon and Burston Parish Ms J.Pearson Mr Podmore Council
Sheen Parish Council Mr M.Street Mr Street
Shenstone Parish Council Mr M.Tucker Mr Stringer
Standon Parish Council Mr Hall Mr Wood
Stanton Parish Council STAFFORD BC Mr. & Mrs Munday (Hinksford Lane)
Stowe by Chartley Parish Mrs J.Jones Mr. B George Council
Tatenhill Parish Council Mr P.MacMaster Mr. B. Evans
Wall Parish Council Mr Drury Mr. Blakemore (Anglesey Sandpit)
Waterhouses Parish Council Mr K.Tatton Mr. D.J. Milburn
Weeford Parish Council Mr JG.Bayles Mr. Delany 54 Appendices
Weston with Gayton Parish Mrs T.bayles Mr. Devon Council 6 Wetton Parish Council Mr M.Weetman Mr. G. A. Hanson Consultation Statement (Regulation 30 document) Whittington and Fisherwick Mr A.Houldcroft Mr. Hallam Parish Council
Mr M.Greatorex Mr Mr. Hallam M.Elphinstone-Walker
Stoke-on-Trent City Council Mr Stuart Mr. Hewitt
Wardell Armstrong Mr.P.Manfredi Mr. K.P. Parnell
Derbyshire County Council Mr J.Dale Mr. Moss
South Derbyshire District Mrs V.Battison Mr. P. Bowman Council
North West Leicestershire Mr J.Roycroft Mr. P. Gallimore, Building District Council and Civil Engineering Consultant
Warwickshire County Mr B.Braithwaite Mr. R. Boden (Hardwick Council Quarry)
North Warwickshire Borough Mrs S. Mahoney Mr. Woolliscroft Council
Sandwell Metropolitan Mr R.Oldfield Mr.M.Steer Borough Council
Solihull Metropolitan Mr L.Marsh Mrs C Smith Borough Council
Wyre Forest District Council Mr S.Tulitt Mrs C Wood
North Shropshire District Mrs M.Cottom Mrs Dodd Council
Macclesfield Borough Mr J. Maiden Mrs Goodwin Council
Advantage West Midlands Mr T.Roome Mrs Hudson
British Waterways Board Mr C.Owens Mrs J. Holland
British Waterways - Wales Mr B.Harrison Mrs Mason & Border Counties Appendices 55
English Partnerships Mr B.Simmons Mrs Plant
Environment Agency - Mr P.Ratheram Mrs Podmore 6 Midlands Region, Upper Trent Area
Cllr. P.G. Hall Mr A.Butwell Mrs Pointon
Robert Coates Mr A.Davies Mrs Street
Forestry Commission - West Mrs J.Berry Mrs Whymark Midlands Conservancy
West Midlands Health Mr S.Anderson Mrs Wright Protection Agency
British Pipeline Agency Ltd. Staffordshire Badger Mrs. Harvey Conservation Group
West Midlands Public Health Mrs B.Dodd Mrs. K. Fletcher
Observatory Consultation Statement (Regulation 30 document)
The Potteries Museum & Art Mr.J.Crittenden Mrs. Kent Gallery
North Staffordshire Mr.DG.Whalley Mrs. Moore Bridleways Association
Ramblers' Association Mr G.Heys Mrs. Sylvia Fawdon
Friends of the Earth - Cllr. P.Elkin Ms. Birch Stafford
Staffordshire Wildlife Trust Ms J.Kilty N & H Transport Ltd.
The Lichfield and Hatherton Mrs V.Allan National Association of Canals Restoration Trust Licensed Opencast Coal Operators c/o H. J. Banks Co. Ltd.
English, Welsh and Scottish Mrs NJ.Litchfield National Farmers Union Railways (EWS) (NFU)
Roger Bullivant Ltd Mr S.Cox National Power plc
Birmingham City Council Mr AJ.Litchfield National Power plc
Coventry City Council Newshaw Walk RA Natural England
Sandwell Metropolitan 4NW New Haden Metals Ltd. / Borough Council Cheadle Skip Hire 56 Appendices
Staffordshire Parish United Utilities Group Newcastle Access Councils' Association Plc 6 Staffordshire Environmental Warwickshire County Newcastle Library Consultation Statement (Regulation 30 document) Fund Ltd. Council
Ballast Phoenix Ltd. Mr C.Shaw Newcastle under Lyme Borough Council
Ballast Phoenix Ltd. Mr P.Housiaux NGR Land Developments Ltd.
Shropshire County Council South Staffordshire NHS Executive - West Water Plc Midlands
Shropshire County Council RPS Planning & Norbury Parish Council Development
Jonathan Lloyd Commercial Advantage West North & South Stoke Salvage Midlands Primary Care Trust
Telford & Wrekin Council Lichfield District Council North Staffordshire Combined Healthcare NHS Trust
Sport England - West The RSPB North Staffordshire Group Midlands Region of Geologists Association (NSGGA)
Cronimet (Great Britain) Ltd Wardell Armstrong LLP North Staffordshire Group of Geologists Association (NSGGA)
South Staffordshire Council South Staffordshire North Staffordshire Health Council Authority
Campaign to Protect Rural Brereton and Ravenhill North Staffordshire Health England (CPRE) - Parish Council Authority Staffordshire Branch
Cannock Chase Council East Staffordshire North Staffordshire Borough Council Hospital Trust
Newcastle under Lyme British Aggregates North West Leicestershire Borough Council Association District Council
Peak District National Park Marley Eternit Ltd Norton Canes Library Authority Appendices 57
NHS North Staffordshire Advantage West NTL (formerly Midlands Newcastle-under-Lyme 6 Primary Care Trust)
Hulme Landfill Management Stafford Borough Octagon (CBM) Ltd. Council
Stoke-on-Trent City Council Mr D.Hodges Office of Government Commerce
Severnside Recycling Ltd. Quarry Products Okeover Parish Council Association
Moores Metals (Fenton) Ltd. Quarries Campaign Optima Infrastructure Team Management
A. Dunford & Son Ms N.Balmer Orton Meadowlands Investments Ltd
Worcestershire County Mr P.Gilbert Owen Brothers Ltd. Consultation Statement (Regulation 30 document) Association of Local Councils (WALC)
South Staffordshire Primary Mr P.Corfield P & P Gallimore Care Trust
Loggerheads Library Mr D.Kemp P. Bartram Grab Loaders Ltd
Barton Library Anglesey Parish Pankhurst's Council
Burton Library Lafarge Aggregates Parkhill Estates Ltd. Ltd.
Kinver Library Tala PR Peak & Northern Footpaths Society
Leek Library Mr A.Hollyer Peak District National Park Authority
Lichfield Library Mrs D.Holihead Penkridge Library
Silverdale Library D. Morgan Plc Pensioners Association
Tamworth Library Mr R.Henderson Perton Library
Uttoxeter Library The Potters Clay & Pioneer Aggregates (UK) Coal Co Ltd Ltd. 58 Appendices
Wombourne Library Mrs J.Coyle Pipeline Management Ltd.
6 Sustainable Staffordshire Prof C.Barton Pipeline Management Ltd. Forum Consultation Statement (Regulation 30 document) Brock PLC Bailey Portmeirion Potteries (Holdings ) PLC
Dudson Armorlite Ltd Mrs L.Brangwin Post Office
PA Vincent Severn Trent Water Potteries Demolition Co. Ltd.
Viridis Mrs P.Watts Potteries Waste Ltd.
Walsall Metropolitan Aggregate Industries Potters Cross Post Office Borough Council UK Ltd
Cllr. G.D. Sedgley Newcastle-under-Lyme Potters Cross Post Office Borough Council
H. J. Banks & Co. Ltd. Mr D.Bromley PowerGen plc
Lichfield District Council Dr T.Hewitt Precast Concrete Agency
National Memorial Cllr.I.Parry Premier Health NHS Trust Arboretum
Tarmac Ltd. Mr M.Evans Quality of Life Group
CWI Trustees Mr B.Wheeler Quarnford Parish Council
Hixon Parish Council Mr M.Venables Quarry Products Association (QPA)
Arup Mrs E.Picken R.A. Simpson & Son
East Staffordshire Borough Mr C.Butt R.P. Minesearch Ltd. Council
Newcastle under Lyme Moorland and City Rainbow Waste Borough Council Railways Ltd Management Co. Ltd
The Planning Inspectorate Mr K Ramblers' Association
Commission for Architecture Mr A.Pym Ramshorn Parish Council and Built Environment (CABE)
Cheshire County Council Fisher German RCTB Consultants Appendices 59
Padgett Lavender Mr G.Willard Redland Roofing Systems Associates Ltd. 6 Silica and Moulding Sands Mr G.Wilalrd Richard Raper Ltd Association (SAMSA)
A.L.P. Ambrose Mr I.Boxall Rising Brook Libary
Aquaforce Special Waste Carter Jonas Rookery Post Office Limited
MJ Pope - Consultant Mr C.Comberbach Roy Blase & Sons
Biffa Waste Services Ltd FTMINS Royal Doulton PLC
Land Improvement / RPS Rugeley Library Landmatch Ltd.
Oaktree Environmental RPS Rural Youth Forum - North East Staffordshire Consultation Statement (Regulation 30 document) JDM Accord Ltd Brereton & Ravenhill Rushton Parish Council PC
The On-Farm Composting W2R team RWEM Power Network Staffordshire County Council
Hinson Parry & Company Mr C.Richards Rykneld Metals Ltd
Hednesford Town Council Willardwillard Ltd Safeway Stores
Silverdale Parish Council Savills Safeway Stores
Lafarge Aggregates Ltd. H&H Bowe Ltd Safeway Stores
Datum Design Mr A.Thornton Sainsburys Plc
Fisher German Chartered Tweedale Limited Sainsburys Plc Surveyors
Natural England Fisher German Sainsburys Plc
Mineral Industry Research Mr G.Holland Sainsburys Plc Organisation (MIRO)
The Institute of Quarrying Addleshaw Goddard Sainsburys Plc LLP
Royal Institute of Chartered Tweedale Ltd Salt and Enson Parish Surveyors (RICS) Council 60 Appendices
Enviroarm Limited The Mineral Planning Saredon Parish Council Group 6 Cemex 1st Choice Mini Skips Sarp UK Ltd Consultation Statement (Regulation 30 document) Tarmac Ltd. A C Salvage Saunders Brothers
Lord Staffords Estates A.G. Hackney & Co. Scally's Car Breakers
Mouchel (Land Aspects) A.S. Whittaker Scott Wilson
Duchy of Lancaster A.T. Finney & Sons Ltd. Seighford Parish Council
Midland Building Design Ltd A1 Express Skips Seisdon Post Office
Optima Infrastructure A1 Mini Skips Ltd Senior Citizens County Management Association
Waste Recycling Group plc Abbots Bromley Parish Severn Trent Water Ltd. Council
Aggregate Industries UK Ltd ABC Skips Severn Trent Water Ltd.
Biddulph Sand Ltd. Able Mini Skips / Able Severn Trent Water Ltd. Skip Hire
Silk Rowson Plant Acorus Consulting Shareshill Parish Council
British Gypsum Limited Acton Shell UK Ltd. Trussell/Bednall/Teddesley Parish Council
Fisher German Chartered Adbaston Parish Shenstone Library Surveyors Council
Silverdale Park Limited Advantage West Shireoak Quarry Liaison Midlands Group
East Staffordshire Borough Advantage West Shires Bathrooms Council Midlands
Lafarge Cement UK Age Concern - South Shobnall Parish Council Staffordshire
St. Modwen Properties PLC Aggregate Industries Shropshire and UK Ltd Staffordshire Strategic Health Authority
Horninglow and Eton Parish Aggregate Industries Shropshire Association of Council UK Ltd Local Councils (SALC) Appendices 61
Winshill Parish Council AGWR Ltd Shropshire Union Canal Society 6 Lafarge Cement UK Allens Spares & Sims McIntrye Metals Ltd. Salvage
ResourceUK Alliance Environmental Sir Robert Peel Hospital Planning Ltd
Freethcartwright LLP Allwaste Services SLR Consulting Ltd
Quarry Products Association Alrewas & Fradley with Smith Brothers Farms Ltd (QPA) Streethay Parish Council
RICS West Midlands Alrewas Post Office Smurfit Recycling
Silica and Moulding Sands Andy's Skip Hire Somerfield Stores Ltd Association (SAMSA)
Staffordshire RIGS Group Anslow & Son Somerfield Stores Ltd Consultation Statement (Regulation 30 document)
Southern Staffordshire Anslow Street Post South East Staffordshire Chamber of Commerce Office Health Authority
Mr P.Atkins Anson Skip Hire of South Herts Waste Rugeley Management Ltd.
Star Planning and Apple Motors Ltd South Staffordshire Water Development PLC
Monitoring & Control Ariort Ltd South Staffordshire Water Services Limited PLC
Roger Crane Ltd. Armitage with South Staffs District Youth Handsacre Parish Committee (SSDYC) Council
The Inglewood Investment Arthur Wright & Son South Stoke Primary Care Co Ltd Trust
Smiths Gore Asda Store Ltd South Stoke Primary Care Trust
Government Office for the Asda Stores Ltd South Western West Midlands (GOWM) Staffordshire Primary Care Trust
Highways Agency Asda Stores Ltd St. Modwen
Wardell Armstrong LLP Asda Stores Ltd Stafford Library 62 Appendices
The Green Arc Partnership AT Skip Hire Stafford Mini Skips
6 Resource Development Ltd Audley Library Staffordshire Blind
Consultation Statement (Regulation 30 document) Cleansing Services Group Aynsley China Ltd. Staffordshire County Ltd. Council
Environmental Services Bagnall Parish Council Staffordshire County Association (ESA) Council - Planning Committee
British Aggregates Bardon Concrete Ltd Staffordshire Enterprise Association (BAA) Chamber of Commerce
Cannock Chase Council Barton Post Office Staffordshire Moorlands District Council
Community Strategy Task bartonwillmore.co.uk Staffordshire Moorlands Group District Council
East Staffordshire Borough Baswich Library Staffordshire RIGS Group Council
North Staffordshire Chamber Baum's Skip Hire Staffs Concrete of Commerce and Industry
The Coal Authority Beech Action Group Stapenhill Parish Council
South Staffordshire Council Belford Bros. Steelite International PLC
Stafford Borough Council Betley, Balterley and Stoke-on-Trent and Wrinehill Parish Council Staffordshire Strategic Partnership (SSSP)
Staffordshire Moorlands Biddulph Library Stone Library District Council
Tamworth Borough Council Biddulph Moor Post Stone Town Council Office
Dickinson Dees Biddulph Post Office Stone Town Council
The British Wind Energy Biddulph Sand Ltd. Stonnal Post Office Association (BWEA)
Marley Building Materials Ltd Bilbrook Parish Council Stretton Parish Council
Defence Estates Birmingham City Stubbers Green Ash Co. Council Ltd. Appendices 63
English Heritage - West Blithfield Parish Council Swindon Parish Council Midlands Region 6 Stafford Railway Station Blymhill & Swinfen/Packington Parish Weston-under-Lizard Council Parish Council
Queens Hospital Blythe Bridge Library Swynnerton Parish Council
Tamworth Citizens Advice Blythe Gate Farm Swynnerton Post Office Bureau
Newcastle & Kidsgrove Bobbington Parish T. Bishop & Son Citizens Advice Bureau Council (Transport) Ltd.
Hixon Post Office and Stores Bobbington Parish Talke Library Council
Doxey Parish Council Bobbington Post Office Talke Pits Sub-Post Office
Friends of Hopwas Woods Bolton Emery Tamworth Railway Station Consultation Statement (Regulation 30 document) Partnership
Egniol Ltd Boundary Breakers Tamworth Waste Disposal Ltd/Kangaroo Skips
Smith Stuart Reynolds Bradley Parish Council Tarmac Recycling Ltd (SSR)
Blore Heath and Folly Wood Bradnop and Cawdrey Tarmac Recycling Ltd. Action Group Parish Council
Planning, Wayleave & Land Brereton & Ravenhill Tarr Waste Management Consultant Parish Council Ltd
Cllr. D. Tyler Brewood Library Tattons Salvage Car Repairs
McDyre & Co. Brian Robinson Tesco Stores Ltd Associates Ltd. - Consulting Engineers
Harris Lamb Bridgnorth District Tesco Stores Ltd Council
WBB Minerals Bridgtown Parish Tesco Stores Ltd Council
Cllr. A. Wilkins Brindley Heath Parish Tesco Stores Ltd Council 64 Appendices
Mobile Libraries British Gas Properties Tesco Stores Ltd
6 Cllr. M. Winnington British Geological The Civic Trust Survey (BGS) Consultation Statement (Regulation 30 document) Wardell Armstrong British Steel The Coal Authority - Mining Corporation Reports Office
Heaton Planning Limited British Telecom The Crown Estate
Ideal Standard [ Formally Broadmoorside Quarry The Ford and Vauxhall Armitage Ware] Centre
Cllr. Day Brock PLC The Ford Centre
Cllr. M. Lawrence Brock PLC The Garden History Society
Hanson Building Products Bromsgrove District The Rev. St. Kemm Ltd Council (Church Commissioners)
Department for Transport Brown Lees Post Office Think Green Skip Hire (c/o GOWM)
Youth Action Kouncil (YAK) Browns Mechanical Thorp Pre-cast Ltd & UK Youth Parliament Services Ltd.
Newcastle Young Peoples Buckingham Group Tidysite Skip Services Ltd. Association (NYPA) Contracting Ltd
Youth of Moorlands Action Building Design Group Tim Bates Plant Hire Ltd. Council (YOMAC)
Stafford and Stone District Burgess & Leigh ltd. Tittesworth Parish Council Youth Forum (SSDYF)
Burton Youth Forum (BY4U) Burntwood Library Trans Rail Freight Ltd.
South Staffs District Youth Burntwood, Lichfield Transco Committee (SSDYC) and Tamworth Primary Care Trust
Chase District Youth Forum Burntwood, Lichfield Transport 2000, (VOICE) and Tamworth Primary Staffordshire Care Trust
Lichfield District Youth Burton Hospitals NHS Trent Valley Tyres Ltd. Forum (Focused) Trust
Tamworth District Youth Burton Parish Council Trysull and Seisdon Parish Forum (TDYF) Council Appendices 65
Staffordshire Council of Burton Railway Station Tutbury Parish Council Voluntary Youth Services 6 Stoke-on-Trent and Burton Railway Station UK RIGS Staffordshire Strategic Partnership (SSSP)
Croxden Quarry Liaison Burton Skip Hire (Mr. Urban Mines Ltd. Group D.M. Sheratt)
Age Concern South Busy Bee Skip Hire Uttoxeter (Rural) Parish Staffordshire Council
Disability Partnership Panel C.A. Durber Uttoxeter Skip Hire
North Staffordshire Health C.E. & J.M. Dale Uttoxeter Town Council and Safety Group
Freehay Quarry Liaison Campaign for Real Ale Virgin Trains Group (CAMRA) Consultation Statement (Regulation 30 document) Leicestershire County Cannock and District Wade Ceramics Ltd. Council Access Group
Dudley Metropolitan Cannock Auto Salvage Wain Bros Ltd Borough Council Ltd
NHS North Staffordshire Cannock Chase Walton Post Office Hospital
Whiston Action Group Cannock Chase Wardell Armstrong Primary Care Trust
Matthews & Son Cannock Chase Warslow and Elkstones Primary Care Trust Parish Council
Royal Society for the Cannock Library Warwickshire County Protection of Birds (RSPB) Council
Outwoods Environmental Cannock Tipping Ltd. Waste Away UK Ltd Consultants
Urban Vision North Cannock Wood Parish Waste Information Centre Staffordshire Council
Moneystone Quarry Liaison Castle Oils Ltd. / Castle Waste Recycling Group - Group Waste Services North Western Division
Newbold & Uttoxeter Quarry Cavendish Trustees Werrington Library Liaison Groups 66 Appendices
Dr. D. Eardley Caverswall Parish Werrington Parish Council Council 6 White Young Green Caverswall Parish West Midland Bird Club Consultation Statement (Regulation 30 document) Planning Council
Augean Landfill Cawarden Brick & Tile Westdoor Ltd. Company Ltd.
Marches Wood Energy Cemex Weston Post Office Network Ltd Midlands Wood Fuel Ltd
Baker Barnett Ltdfage Cemex Wetley Rocks Post Office
Nexen Exploration UK Ltd Cemex Whitgreave Parish Council
St. Modwen Cemex Whittington Post Office
Mr Paul Bellamy Central Networks Wienerberger Ltd
Mr Howard Price Central Networks Wigginton and Hopwas Parish Council
DIGBITS Limited CENTRO Wilnecote Library
Mr. C Pointon Cheadle. Councils Wilshee's Skip Hire Ltd. Connect
Willardwillard Ltd Checkley Parish Wilshee's Skip Hire Ltd. Council
Cannock Chase Council Cheddleton Parish Wolverhampton City Council Council
Ms. S. Stringer Cheddleton Post Office Wolverhampton Health Authority
RPS Planning Cherry Hill Skip Hire / Wombourne Parish Rossisle Development Council Co. Ltd.
Mrs. Doreen Cheshire Association of Wooliscroft Trustees Local Councils (CALC)
Tarmac Ltd Cheslyn Hay Library Wootton Parish Council
Mr J.Russell Church Eaton Parish Wootton Parish Council Council Appendices 67
Staffordshire Rural Hub Citizens Advice Bureau Worcestershire County Council 6 Cllr. Jessel Citizens Advice Bureau WS Atkins - Midlands
Lichfield District Council Citizens Advice Bureau WS Atkins Transportation Engineering
Cllr. Becket Citizens Advice Bureau Wychnor Parish Meeting
Cllr. White City Skips Wychnor Parish Meeting
Cllr. Williams Civil Aviation Authority Wyre Forest District Council
Stafford Borough Council Clayton Library Yew Tree Coal Co., Old Landywood Lane
Cllr. Highfield Cleanaway Yoxall Parish Council
Staffordshire Moorlands Cleanaway Mrs Consultation Statement (Regulation 30 document) District Council A-M.Thorley-Walchester
Cllr. Gibson Cleansing Services Mr J.Walchester Group Ltd.
Stoke-on-Trent City Council Clearaway Skip Hire Mr J.Holdcroft
Tamworth Borough Council Cllr D. Davies Mrs Fleming
Mrs. Metcalf Cllr. B. Sinnott Mr Ward
Wienerberger Ltd Cllr. Cooke Mrs Devon
White Young Green Cllr. Gibson Mrs Amison Planning
Marshalls Natural Stone Coalfield Communities Mrs A.Emerton Campaign
National Industrial Symbiosis Codsall Library Mrs V.Galletley Programme
Whitmore Parish Council Codsall Parish Council Mrs V.Roycroft
OnTrent c/o Staffordshire Colton Parish Council Mr Oakes Wildlife Trust
Highways Agency Community Council of Mrs Oakes Staffordshire 68 Appendices
Knig Sturge Confederation of British Mr Price Industry 6 Mr. E. Sharkey Consall Parish Council Mrs Price Consultation Statement (Regulation 30 document) Lynn & Stonnall Construction Material Mr K.Sims Conservation & Historical Recycling Ltd. (CMR Society Ltd.)
Lichfield Eco-Folk Group Cory Environmental Mrs A.Alcock (Central) Ltd
Mr. A. Williams (Byrkley Cotton Parish Council Mr C.Hirst Books Ltd)
Close Asset Finance Ltd Council for British Mr M.Amos Archaeology
Mr.Loadwick Countryside Agency - Mrs K.Amos West Midlands
Mr.Licorish Coventry City Council Mrs Beckett
Mrs Robinson Creda Ltd. Mr Beckett
Mr S.Jones Crewe and Nantwich Mr S.Beck Borough Council
Mr J.Edwards Cross Country Trains Mrs Ball Ltd.
Mrs N.Litchfield Culture West Midlands Mr Ball
Mr A. Allen Cumberstone S Timms Properties Ltd c/o Katie Parnell Ltd
Mr C.Cottam D M Skip Hire E Timms
Mr C.Tidman D.P. Skip Hire Mrs R.Foster
Mr R.Tidman D.W. Anslow & Son Mrs P.Haslimann
Mr D.Colclough Daniel Platt Ltd. Sharpland
Cllr.Lynn Boleyn David Walker Mr T.Georgeson Chartered Surveyors
Mr R.Vanes Dawkes and Co. Blore Farm Appendices 69
Appendix 4: Media Campaigns
Support our Standards, 2010 6 Webpage (August 2010) Consultation Statement (Regulation 30 document) 70 Appendices
6 Consultation Statement (Regulation 30 document) Appendices 71
Beyond the Bin, 2009
'Beyond the Bin' A5 leaflet 6 Consultation Statement (Regulation 30 document) 72 Appendices
6 Consultation Statement (Regulation 30 document) Appendices 73
Photograph of bus back advertising 'Beyond the Bin' media campaign 6 Consultation Statement (Regulation 30 document)
74 Consultation Statement (Regulation 30 document) 30 (Regulation Statement Consultation 6 Appendices Appendix 5: Representations, Emerging Joint Waste Core Strategy August 2010 consultation
6.1 The tables below provide a summary of comments received in response to the Emerging Joint Waste Core Strategy consultation held in August 2010.The tables also detail our response of how these comments have been taken into account when drafting the revised draft policies for the April 2011 consultation. As the comments received have been reduced and combined to provide a summary of the issues, in order to view the full version of the comment received by a specific stakeholder, please refer to the document 'Part 3 JWCS Consultation Summary' in the Joint Waste Core Strategy virtual library.
Representations received in connection with Emerging Joint Waste Core Strategy August 2010 consultation.
Emerging Joint Waste Core Strategy, Chapter 1: Executive Summary Consultation Our Response Reference Reduced and combined comments
Policies should safeguard sufficient landfill for all waste streams, not just MSW. EA61 Agreed. Despite the wording, we consider that they do. No action necessary. The April 2011 consultation document has revised the policies, and whilst the aim is to restrict landfill, Policy 2.5 attempts to protect existing waste management facilities (including landfill) from non waste related development. Only the Emerging Joint Waste Core Strategy, Chapter 1: Executive Summary Consultation Our Response Reference Reduced and combined comments
hazardous landfill site is safeguarded by Policy 2.4.
Scope of the JWCS is limiting SBC 19 The scope is laid down in legislation and is not for us to change. The Strategy also addresses all waste streams and all types of waste management operations. This is not considered to be limiting. No action necessary
Emerging Joint Waste Core Strategy, Chapter 2: Introduction Consultation Our Response
Reference Appendices Reduced and combined comments
Strategy promotes a misleadingly small requirement for new waste facilities BWS 1 The calculations were revisited in preparation BWS 2 for the April 2011 Draft Revised Policies BWS 3 consultation document. 75
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We believe that current figures are an accurate representation, based on regional policies and studies (RSS Phase 2 Revision). Targets are minimum landfill diversion targets.
Emerging Joint Waste Core Strategy, Chapter 3: Characteristics of Waste Consultation Our Response Management in Staffordshire and Stoke-on-Trent Reference
Reduced and combined comments
Waste data underpinning the Core Strategy is old and inaccurate. KK 1, KK 2, The data was revisited. We believe that current KK 3, KK 4, figures are as accurate a representation as can KK 6, KK 7, realistically be achieved. Targets are based on KK 9, KK 8 Joint Municipal Waste Management Strategy 2007 and RSS Phase 2 Revision. Emerging Joint Waste Core Strategy, Chapter 3: Characteristics of Waste Consultation Our Response Management in Staffordshire and Stoke-on-Trent Reference
Reduced and combined comments
The landfill tax on inert matter is still only £2.50/tonne KK 5 True, but no action necessary
Para 3.5 should note that waste sites should not be located in Groundwater Source EA36 Noted, this was kept in Protection Zone 1 or Flood Zone 3b, and any waste developments in Flood Zones 2 or mind when finalising 3a are subject to Sequential and Exception Tests. EA37 policies. The April 2011 consultation document amended the policies. Draft Policy 4 requires consideration to be given to the effect of proposals on water resources.
Support the principle of facilitating improvements in design through new applications on EA38 Noted. No action existing sites necessary
Planning applications on existing sites give opportunities for retrofit of sustainable EA39 Noted. This was kept Appendices drainage systems as well as operational processes improvements. in mind when finalising policies. The April 2011 consultation document amended the policies. Draft Policy 4 requires proposals to provide sustainable drainage systems. 77
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Reduced and combined comments
Need to monitor capacity carefully to ensure enough capacity higher up hierarchy EA40 Noted. This was kept in mind when finalising policies. The April 2011 consultation document amended the policies. Monitoring of capacity in relation to the waste hierarchy is a performance indicator for Policy 1.
Opportunities to transform waste back into a resource should be encouraged EA41 Noted. This was kept in mind when finalising policies The April 2011 consultation document amended the policies. Policy 1 relates to waste as a resource.
SUDS can also help to mitigate the impacts of Climate Change. EA42 Noted. This was kept in mind when finalising EA43 policies. The April 2011 consultation document amended the policies. Emerging Joint Waste Core Strategy, Chapter 3: Characteristics of Waste Consultation Our Response Management in Staffordshire and Stoke-on-Trent Reference
Reduced and combined comments
Draft Policy 4 requires proposals to provide sustainable drainage systems.
Water environment should be referenced in Point 8 EA44 Noted. This was kept in mind when finalising the Strategy. The April 2011 consultation document amended the issues, strategic objectives, vision and policies. Reference to the water environment has been made throughout. Appendices Point 10 (waste awareness and minimisation) should have higher priority. SBC 20 Noted. This was kept in mind when finalising policies. The April 2011 consultation document amended the policies. Draft Policy 1 relates to 79
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Reduced and combined comments
waste as a resource and lists waste minimisation as a general principle.
The need for waste awareness and minimisation must apply to all sectors, not just SBC 21 Agreed. This was kept municipal waste. in mind when finalising policies. The April 2011 consultation document amended the policies. Draft Policy 1 relates to waste as a resource and lists waste minimisation as a general principle.
Need to change description of inland waterways. IWA1 Agreed. General characteristics section of IWA2 final Strategy will incorporate proposed text.
Table 4 shows maximum landfill tonnages remaining almost constant over plan period, WPC2 Comment noted. No when a reduction was expected. action necessary. This table replicates regional policy (RSS Phase 2 review) which sets out Emerging Joint Waste Core Strategy, Chapter 3: Characteristics of Waste Consultation Our Response Management in Staffordshire and Stoke-on-Trent Reference
Reduced and combined comments
minimum landfill diversion tonnages and maximum landfill tonnages over the plan period. The April 2011 consultation document amended the policies. Draft Policy 2 relates to landfill diversion targets and higher targets than regional policy are proposed.
Believe table 4 to be incorrect as it does not address Zero Waste to Landfill BWS 4 Comment noted. No action necessary. This table replicates regional policy (RSS Phase 2 Appendices review) which sets out minimum landfill diversion tonnages and maximum landfill tonnages over the plan period. The April 2011 consultation document 81
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Reduced and combined comments
amended the policies. Draft Policy 2 relates to landfill diversion targets and higher targets than regional policy are proposed.
Need to distinguish waste treatment capacity for different waste streams as there is still BWS 5 Comment noted. No a shortfall for C&I waste. action necessary. Regional policy (RSS Phase 2 review) sets out minimum landfill diversion tonnages and maximum landfill tonnages over the plan period. The April 2011 consultation document amended the policies. Draft Policy 2 relates to minimum landfill diversion targets and higher targets than regional policy are proposed. Additional Emerging Joint Waste Core Strategy, Chapter 3: Characteristics of Waste Consultation Our Response Management in Staffordshire and Stoke-on-Trent Reference
Reduced and combined comments
capacity is required for C&I and MSW recycling only in order to meet the minimum landfill diversion targets.
Proximity principle should be an incentive to ensure sufficient waste treatment facilities BWS 8 Comment noted. are available locally, rather than a constraint to resist development because of lack of However, any capacity local need. gap calculations in the Core Strategy are clearly stated to be minimum gaps. No additional action necessary
Concerned about whether existing drivers provide sufficient incentive for local authorities LRB 4 Noted. Whilst it must to roll out food waste collections. attempt to encourage
more waste to be treated Appendices higher up the waste hierarchy, it is not the role of the Waste Core Strategy to provide incentives for specific waste streams. No action necessary. 83
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Reduced and combined comments
Success of organic treatment facilities, in particular AD, will depend on economies of LRB 5 Noted. This could scale and the roll out of food waste collection systems possibly be a role for LRB 6 the Municipal Waste Strategy, but not the Waste Core Strategy which is being considered here. No action necessary
Emerging Joint Waste Core Strategy, Chapter 4: Spatial Vision Consultation Our Response Reference Reduced and combined comments
Largely support the vision HP1, PE 1 No action necessary
Need clarification on what constitutes inappropriate forms of development HP2, HP4 Noted. This was kept in mind when finalising policies. The April 2011 consultation document amended the policies. Draft Policy 4 and Draft Policy 3 set out locational criteria and Emerging Joint Waste Core Strategy, Chapter 4: Spatial Vision Consultation Our Response Reference Reduced and combined comments
general protection criteria. Decisions will always also need to reflect specific local circumstances.
Support the objectives, especially Objective 9, but concerned that it is consistently carried EH 5, EH 6 Noted. This was kept in through mind when finalising policies. The April 2011 consultation document amended and simplified the number of issues, strategic objectives and policies. The linkages between all three are clear to follow.
Text should include a reference to ‘other environmental enhancements’ as well as green EH 4 Noted, we will ensure Appendices infrastructure initiatives that an appropriate reference is included in the reasoned justification to policy 4.
Need a Strategic Objective that specifically relates to wider business activities. SO10, SBC 22 Comment noted. The is not explicit enough. April 2011 consultation document however 85
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amended and simplified the number of issues, strategic objectives and policies.
‘Cultural environment’ should be changed to ‘historic environment’ to accord with PPS5, EH 2, EH 3 Noted. The April 2011 and there should be a positive commitment to seeking to avoid impacts on non-designated consultation document assets and securing appropriate mitigation where this is not possible amended all references.
Vision should specify ‘employment’ land as opposed to ‘general industrial’ land as PE 5, PE 6 Noted. PPS10 para 20 preferred location for new waste developments. however refers to industrial sites and waste facilities are considered compatible with B2/B8 general industrial uses. Employment land would include B1 uses. We recognise that some would be anxious that waste developments might reduce the attractiveness of premium B1 employment sites. Emerging Joint Waste Core Strategy, Chapter 4: Spatial Vision Consultation Our Response Reference Reduced and combined comments
Strategic Objective 9, should refer specifically to protecting the setting of the PDNP1 Noted, we will ensure PeakDistrictNational Park (wording proposed) that an appropriate reference is included The April 2011 consultation document amended the policies and strategic objectives. Draft Policy 4 incorporates protection of the setting of the PDNP.
Rail freight and other sustainable transport options should be considered for waste C3, C4, PE We have already facilities to minimise impacts. Vision should refer to this 10 attempted to reflect this ideal, but recognise that it would be hard to achieve for all waste facilities. No action Appendices necessary
Good site design should extend to good management of surface and foul water drainage. EA30, EA31, We will ensure that this (details provided for Policy 8) EA32, EA33, is properly reflected in EA34, EA35, the Waste Core Strategy. EA33, EA34, The April 2011 EA35 consultation document 87
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amended the policies and strategic objectives. Draft Policy 4 relates to protection and improvement of environmental quality.
Welcome inclusion of design and layout guidance in vision, but it needs to be more EA45, EA46, Noted, will incorporate strongly worded and reflect needs of water environment (wording suggested) EA47, EA48, proposed wording or EA49 equivalent
Vision includes self-sufficiency. Significant quantities of waste generated in Staffordshire VES 3 This is already taken into are sorted and recycled at sites outside the county, while facilities within the county account. No further process similar quantities of waste arising beyond its borders. action necessary
Proximity Principle was developed for waste going to disposal, but it is less clearly BWS 7 Noted. No action applicable once waste is treated as a resource. necessary
Residual waste sent to landfill should be minimised, with emphasis on recovery and PE 2, PE 3, Diversion of waste from energy generation. EfW facilities will be important for delivery of waste plan PE 9 landfill is fundamental to the strategy. No action necessary
EfW facilities can benefit employment sites and attract other investors by providing PE 7, PE 8 Noted. No action secure supply of sustainable energy. necessary Emerging Joint Waste Core Strategy, General Comments Consultation Our Response Reference Reduced and combined comments
General support NE6, NE7, No action necessary NE8, NE9, WCC1, WPC1
In the absence of the RSS, all Planning Authorities should include a commitment towards EA59 Noted, will attempt to meeting River Basin Management Plan targets within their strategic plans. accommodate
Proposed changes to wording describing availability of land for waste sites near ESBC 16 Noted. The April 2011 Burton-upon-Trent (preferred wording provided) consultation document has revised the policies. The broad location policy (Policy 2) does not provide an indicative list now of suitable general industrial land. The supporting background
document for ‘Broad Appendices Locations’ does however include this list and this has been amended accordingly.
Concerns that inert waste deposited at Enville Road Quarry does not originate in QFF1 The origin of waste is not Staffordshire and does not count towards treatment capacity an issue in relation to targets. It has always 89
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been recognised that waste will be imported and exported for treatment. To do our fair share, we aim to treat a quantity of waste equivalent to that arising in the county, but not necessarily the exact waste. No action necessary
Targets for diversion from landfill must be seen as minimum targets VES 1 Targets are minimum. We will ensure that this is clear from the text. . The April 2011 consultation document amended the policies. Draft Policy 2 relates to landfill diversion targets and clearly states that targets are the minimum. Emerging Joint Waste Core Strategy, General Comments Consultation Our Response Reference Reduced and combined comments
Council remains opposed to the proposals to develop an Incinerator at Kingswood CCC2 This is not a matter for Lakeside, Cannock the Core Strategy. No action necessary
Object to the inclusion of Enville Road Quarry in the Joint Waste Core Strategy QFF2 The site in question is a permitted minerals site in progressive restoration. We will ensure that conditions are properly enforced, but it is not for the Waste Core Strategy to address its existence now or in the future. No action necessary.
Support the long range targets which are needed due to the immaturity of collection LRB 6 Noted, though the key systems. targets for municipal food
waste collection are Appendices defined in the Municipal Waste Strategy and are not the subject of the Waste Core Strategy. No action necessary 91
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The capital costs associated with enclosed organic treatment facilities are not small, and LRB 8 Capital costs for new collectively they can provide significant capacity waste facilities are always a significant issue, especially with newer technologies higher up the waste hierarchy, but no specific action necessary
A range of alternative facilities can encourage competitiveness, but providing too many LRB 9 Noted. Capacity gaps can impact on their commercial viability identify minimum additional facilities required, but it would be difficult for the Core Strategy to restrict development for the commercial benefit of existing operators. No action necessary
Core Strategy should allow flexibility for additional recovery capacity subject to VES 2 Noted. This, broadly, is compatibility with DC policies the aim of the Waste Core Strategy. No Emerging Joint Waste Core Strategy, General Comments Consultation Our Response Reference Reduced and combined comments
specific action necessary.
Emerging Joint Waste Core Strategy, Supporting documents - General Comments Consultation Our Response Reduced and combined comments Reference
Evidence Base
Plans within evidence base illustrate waste arisings from the PDNP4, Noted. The Strategy StaffordshirePeakDistrictNational Park; but document does not state that it seeks to PDNP5, addresses all waste address these arisings. PDNP are not proposing any specific waste facility provision arising within beyond communities meeting local needs (Supported by the evidence base and East PDNP6 Staffordshire and Midlands Regional Plan which suggested waste arisings should be treated in surrounding Stoke-on-Trent and urban areas). Has this has been taken into account in the evidence base? targets are minimum targets for new capacity. Cross border movement of waste is also Appendices addressed. The April 2011 consultation document amended the policies. Draft Policy 4 relates to protection, and the reasoned justification acknowledges that the Peak District National 93
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Evidence Base
Park is a separate Waste Planning Authority responsible for determining applications within its area and has an adopted Local Development Framework .In order to protect against impacts of waste development outside the Park itself, the Strategy states that there will be a presumption against waste development that might impact on the setting of the Peak District National Park. The National Park Authority will be consulted on any proposal which may have such an effect.
Table on Page 12 needs to be adjusted to more accurately reflect landfill availability: BWS 9, Comments are noted. BWS 10, Emerging Joint Waste Core Strategy, Supporting documents - General Comments Consultation Our Response Reduced and combined comments Reference
Evidence Base
Poplars landfill is likely to be operational beyond 2023 as consent is defined by BWS 11, volume rather than time period. BWS 12 Meece is also likely to be operational beyond 2015 Saredon is unlikely to be available as a landfill site for anything other than “naturally excavated materials”
SACs and HRA
Need to make specific reference to Cannock Chase SAC and the Cannock Extension CCC22 Noted. Such reference Canal SAC is made within the HRA
Two potential sites (NLUD354 and NLUD 355) lie close to the PeakPark and their PDNP2, Noted. This has been development could affect its setting. Any assessment must have regard to this. PDNP3 considered in the site assessment process. The process is only intended to give an initial indication of the
sustainability impacts Appendices that might arise should a waste development take place on one of the sites. Any planning application would give due weight to impact on the setting of the 95
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Evidence Base
National Park. The April 2011 consultation document amended the policies. Draft Policy 4 relates to protection, and the setting of the PeakDistrictNational Park.
Any proposals to intensify landfill use of land south of Dosthill would affect traffic on A51 WCC2 Noted. and Rush Lane
Districts may now be revising future employment land allocations, but if they wish to ESBC 13, Noted. The number of radically alter their total employment land requirements they will have to provide fresh, ESBC 14, sites that might be robust evidence. When the allocations were made, they did not allow for waste ESBC 15 required to meet the management uses. Districts may need to increase employment allocations to objectives of the Joint accommodate waste uses and specify types of usage that may be acceptable. Waste Core Strategy and shortfall in waste management capacity for the plan area are very small and unlikely to have a significant impact. Compatibility with neighbouring uses would always be a Emerging Joint Waste Core Strategy, Supporting documents - General Comments Consultation Our Response Reduced and combined comments Reference
Evidence Base
consideration when determining a planning application.
SFRA and water related issues
SFRA needs to adopt a precautionary approach to reflect potential impacts of climate EA50 Approach is being change. Further discussions could be undertaken where potential development areas adopted in SFRA. Any are located within the flood plain EA51 potential development areas in the flood plain were eliminated from consideration at an early stage.
The SFRA should detail appropriate development easements alongside all watercourses, EA52 Noted. The April 2011 linking in with an allowance for green infrastructure and complying with the various green consultation document infrastructure schemes amended the policies.
Draft Policy 4 relates to Appendices sustainable design and protection and improvement of environmental quality. The water environment is a consideration. 97
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Evidence Base
Deculverting should be promoted, with a full assessment of the benefits that may be EA53 Noted. The April 2011 achieved through this work, and its practicality. Any new culverting of open watercourses consultation document should be strongly discouraged EA54 amended the policies. Draft Policy 4 relates to sustainable design and protection and improvement of environmental quality. The water environment is a consideration.
The relevant Catchment Flood Management Plan should be directly reflected within the EA55 Noted. The April 2011 policies of this document consultation document amended the policies. Draft Policy 4 relates to sustainable design and protection and improvement of environmental quality. The water environment is a consideration.
Landraising within the floodplain should be actively discouraged EA56 Noted. The April 2011 consultation document amended the policies. Emerging Joint Waste Core Strategy, Supporting documents - General Comments Consultation Our Response Reduced and combined comments Reference
Evidence Base
Draft Policy 4 relates to sustainable design and protection and improvement of environmental quality. The water environment is a consideration. Draft Policy 1 relates to waste as a resource and landfill and landraising and flood risk.
Above points should all be incorporated into the policies wherever possible EA57 Noted. See responses above.
Policies and strategies should actively support aspirations and targets of The Water EA58 Noted. Framework Directive. Appendices Need to take a tough stance on the control of water pollution, ensuring betterment from EA60 Noted. The April 2011 the existing situation is achieved wherever possible, and the risk of contamination of consultation document Controlled Waters is minimised. amended the policies. Draft Policy 4 relates to sustainable design and protection and improvement of environmental quality. 99
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Reliance on targets is risky as they are not well scrutinised and quickly out of date. GW 2 Targets and data will be monitored on an annual basis through the Annual Monitoring Report. No data will ever be perfect, but we strive to get the best picture we can, and to develop policies and targets with flexibility to cope in case the data is not completely accurate.
Suggest splitting targets and broad locations, possibly with targets in a separate document BWS 18 Targets are intended to for ease of updating reflect minimum GW 3 requirements and policies try to offer flexibility. We will consider the best ways to keep targets up to date. The Annual Monitoring Report will be an option. Emerging Joint Waste Core Strategy, Policy 1: Broad Locations Consultation Our Response Reference Reduced and combined comments
Concerned that data and targets do not reflect current situation, so inappropriate BWS 15 Noted. Whilst no assumptions are being made. evidence base will ever BWS 16 be perfect, targets our based on the Joint TBC 1 Municipal Waste Management Strategy (2007) and regional policy (RSS Phase 2 Review). We will continue to strive to use the best evidence available and to plan for sufficient flexibility to accommodate any future trend in waste management
While the background information suggests there is no need for additional residual MSW PE 12 The needs identified in Appendices and C&I waste treatment, the policy should allow facilities to come forward if need is the Policy reflect the demonstrated minimum required to meet the equivalent of the County’s waste disposal needs. The policy also allows for additional waste 101
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treatment capacity to be permitted where a need can be demonstrated and appropriate criteria met. The reasoned justification for the policies will be reviewed to ensure that this is clear.
Policy does not adequately address the likely need for new or replacement facilities to LDC 1 The Joint Waste Core cope with increased recycling rates at HWRCs or efficient transport to new residual Strategy looks to the treatment facilities LDC 3 Joint Municipal Waste Strategy (2007) for guidance on the facilities needed to manage this waste stream. The MWMS makes no mention of any such requirements for new or replacement HWRCs or transfer stations. The MWMS is subject to a refresh in 2012 and clarification has been Emerging Joint Waste Core Strategy, Policy 1: Broad Locations Consultation Our Response Reference Reduced and combined comments
sought from the Joint Waste Management Board about any specific needs that should be included. We however note that proposals for HWRCs or transfer stations do not require strategic site allocations and could be adequately considered under the proposed policies for enclosed or open-air waste management facilities.
Current plans for facilities at Baddesley Ensor and Burntwood would reduce need for TBC 3 Noted. We will review Appendices more our estimates of need as new facilities are permitted. The Annual Monitoring Report will monitor policies and targets. 103
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While certain wastes may not be produced in sufficient quantities to justify new facilities, EA1 We will review the data there is still a need to plan for their management. May require a co-operative approach and consider whether with neighbouring authorities to ensure that capacity needs are met. EA2 this approach is required
Problems with list of general industrial land suitable for waste management facilities PE 14 Noted. Clearly it will be almost impossible to SMDC 3 produce an up to date list of all industrial land SMDC 4 suitable for the development of waste SMDC 5 facilities, and any such NBC 2 list would add little to the Core Strategy as it would soon be out of date. We will no longer include such a list in the Core Strategy, but will rely on criteria to define land likely to be considered suitable.
Many of the “Main Service Villages” in South Staffordshire are in Green Belt and lack SSC 2 We will re-examine the previously developed of industrial land locational strategy to ensure that it is robust in Emerging Joint Waste Core Strategy, Policy 1: Broad Locations Consultation Our Response Reference Reduced and combined comments
the absence of the RSS. A stakeholder meeting was however held with SSDC officers on 30 March 2011 and it was established that the main service villages were the main urban areas in the District and opposition was not raised to them all being included in the policy.
Object to new waste development in Green Belt, particularly if other sites can be found SSC 3 Noted. National on previously developed or industrial land. guidance makes it clear that very special circumstances are needed to justify waste Appendices development in the Green Belt. We do, however, acknowledge that the spatial requirements for certain types of waste facility (notably those 105
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producing bioaerosols) may sometimes make well chosen Green Belt locations justifiable
Under no circumstances should waste facilities be located within the functional floodplain EA8 Noted. This or Source Protection Zone (SPZ) 1, and should preferably not be elsewhere within the requirement will be floodplain or within the other buffers of a groundwater abstraction point’s zone of influence, incorporated into SPZ2 or SPZ3 policies where appropriate. Refer to revised Policy 4.
Suggested rewording text of second bullet point of 1.2 C to: ‘..including biodiversity, EH 7 Noted. We will amend geodiversity and the historic environment’ accordingly. . The April 2011 consultation document amended the policies. Policy 4 refers to historic environment.
Include the words ‘to an appropriate level’ to third bullet of 1.2 part C EA6 Noted. We will amend accordingly. The April 2011 consultation document amended the policies. Emerging Joint Waste Core Strategy, Policy 1: Broad Locations Consultation Our Response Reference Reduced and combined comments
Locating waste facilities within or close to urban areas may impact on residential amenity SSC 5 Residential amenity will always be a major consideration in determining waste applications. With good design, impacts can be minimised. The April 2011 consultation document amended the policies. Policy 4 refers to protection and environmental quality.
Need definition of “Urban” and close to urban areas” as well as guidance on what facilities SBC 23 We will re-examine the may be appropriate. locational strategy to SSC 6 ensure that it is clear and robust in the absence of the RSS. The April 2011 Appendices consultation document amended the policies. The reasoned justification for Policy 2 will include a definition of what is meant by close to urban areas. Policy 3 107
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provides locational criteria for new and enhanced facilities.
Draft policy 1 needs to be more flexible in line with Government guidelines SSC 1 We believe that Policy 1 already allows sufficient flexibility within broad locations. We will re-examine the locational strategy to ensure that it is robust in the absence of the RS. This issue will be considered. The April 2011 consultation document amended the policies. Policy 2 now provides the broad location criteria.
Not always possible to locate organic treatment facilities on urban industrial sites even LRB 1 Noted. We will clarify if they are enclosed. Particular issue with AD where use/disposal of digestate is a major policies to take consideration for location, and impacts on viability LRB 2 account of this. The April 2011 consultation LRB 3 document amended the Emerging Joint Waste Core Strategy, Policy 1: Broad Locations Consultation Our Response Reference Reduced and combined comments
policies. Policy 3 provides locational criteria for organic treatment and acknowledges that facilities may be locate in rural locations close to where the product (the digestate produced from the AD process) will be used.
Should offer more flexibility by encouraging upgrading existing open air waste CE3 Noted. We will clarify management facilities policies to take account of this. This policy was primarily intended to address broad locations. The Appendices April 2011 consultation document amended the policies. Policy 3 now has merged parts of draft Policy 1 and 8, and provides the general 109
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requirements for new and enhanced waste management facilities.
Inert landfill can play an important role in restoration, and this should be reflected in the CMX3 Noted, we will adjust explanation and policy. the text to clarify the important role of inert landfill in restoration but we would not welcome schemes designed specifically to provide a disposal route for such material. The April 2011 consultation document amended the policies. The new Policy 1 relates to waste as a resource and policy 1.3 favours recycling of C, D&E waste and the diversion of inert waste to quarries requiring backfill for restoration purposes. Emerging Joint Waste Core Strategy, Policy 1: Broad Locations Consultation Our Response Reference Reduced and combined comments
Cross border movement of C&D and inert waste appears not to have been properly CMX4 Noted, we will adjust considered so demand may be underestimated. the text to clarify this CMX5 and would welcome any supporting data that can be provided. The April 2011 consultation document amended the policies. The reasoned justification for the policies will acknowledge cross border waste movements and management.
Smaller settlements such as Hixon may be able to offer sustainable locations for waste SO6 This is in line with what treatment due to effective transport links including public transport for workers. we are trying to achieve in Policy 1. We will Appendices consider this issue as we re-examine the locational strategy to ensure that it is robust in the absence of the RS. The April 2011 consultation document 111
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amended the policies. Policy 2 now relates to broad locations. The reasoned justification will clarify suitability of urban and rural industrial land and previously developed land.
Further work may be needed to justify the need for new facilities to be enclosed. UK6 We will undertake Environmental impacts from construction can be minimised through upgrading existing further discussions and new open air. with consultees about the appropriateness of requiring enclosure but remain convinced that, with appropriate exemptions, the principle is still sound. It is helpful to note that Environment Agency licenses increasingly require waste to be processed and/or stored within a building. The April 2011 consultation document Emerging Joint Waste Core Strategy, Policy 1: Broad Locations Consultation Our Response Reference Reduced and combined comments
amended the policies. Whilst Policy 2 relates to broad locations, Policy 3 provides general criteria for new and enhanced waste facilities. Exceptions criteria are included for open air facilities.
Policy should recognise importance of accessibility to reduce total trip distances TBC 6 Noted. An objective of the Strategy is to locate facilities close to where the waste arises. This and accessibility are recognised in the Site Appraisal and Development Control Appendices process. We will ensure that it is adequately reflected in relevant location criteria. The April 2011 consultation document amended the policies. Policy 4 relates 113
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to sustainable design and includes the wording ‘all proposals... should ….provide safe and convenient access to all potential users…..’.
Support the principle of enclosed facilities but recognise impact on cost and viability TBC 4 Noted. The April 2011 consultation document amended the policies. Whilst Policy 2 relates to broad locations, Policy 3 provides general criteria for new and enhanced waste facilities. Exceptions criteria are included for open air facilities.
Reference to enclosed facilities would better be left to the policy on design TBC 5 Noted. The April 2011 consultation document amended the policies. Whilst Policy 2 relates to broad locations, Policy 3 provides general Emerging Joint Waste Core Strategy, Policy 1: Broad Locations Consultation Our Response Reference Reduced and combined comments
requirements for new and enhanced waste facilities and exceptions criteria is also provided. Given this is a spatial strategy, locational criteria needs to specify what type of facilities (enclosed and open air) would be suitable in certain locations, and it is not considered appropriate to leave this as a design issue.
Emerging Joint Waste Core Strategy, Policy 2 Enclosed Facilities Consultation Our Response
Reference Appendices Reduced and combined comments
Concerns raised about the implications of enclosing new waste management facilities. SSC 7, S08, Noted. Further The policy is too restrictive – limitations imposed by precision of this policy; this will limit GW5, S09, justification required in the opportunity for sites SSC 7 the reasoning behind the policy defining ‘enclosure’ and what 115
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Members and Officer want to achieve by this Policy. The Strategy is meant to be flexible allowing for waste facilities on a range of sites hence criteria for open air and enclosed operations. The April 2011 consultation document amended the policies. Whilst Policy 2 relates to broad locations, Policy 3 provides general requirements for new and enhanced waste facilities and whilst enclosure is the main objective, exceptions criteria for open air facilities are also provided. Emerging Joint Waste Core Strategy, Policy 2 Enclosed Facilities Consultation Our Response Reference Reduced and combined comments
The policy may be better understood if a definition of ‘enclosed’ in the context of the LDC 4 Noted. The April 2011 draft policy is included within the glossary. consultation document SBC 24 amended the policies. Policy 3 provides general requirements for new and enhanced waste facilities and exceptions criteria are also provided. The reasoned justification for the policy will define enclosure.
Caveat be added to this policy to state “proposals for new enclosed facilities will be SSC 12 Noted. The April 2011 supported where practical and where technology supports…” consultation document amended the policies. Policy 3 provides general requirements for new and enhanced waste Appendices facilities and exceptions criteria are also provided. Suggested caveat has been added to this policy to state “proposals for new enclosed facilities will 117
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be supported “where technically, environmentally and economically practicable”.
Each proposal needs to be assessed on its own merits. CCC5 Noted. No action required.
Definition / description of the term organic treatment required. NFU4 Check definition in Glossary of organic treatment. Perhaps highlight in policy reference to Evidence Report 1 technology descriptions and definition in glossary. Glossary includes definition of organic treatment. Evidence Base report 1 also describes the different technologies. Emerging Joint Waste Core Strategy, Policy 2 Enclosed Facilities Consultation Our Response Reference Reduced and combined comments
Separate policies for the different components of policy 2. BWS 21 No action required. Policy 2 - 2.1 relates to general requirements for enclosed facilities, 2.2 & 2.3 relate to enclosed organic treatment facility locations and 2.4 relates to reuse of farm and forestry buildings. The common theme is ‘enclosed’ operations. In order to keep the strategy simple with fewer policies it was considered that applications could be determined in terms of Appendices different types of technology/facility - either enclosed or open-air. Separating the different components of policy 2 could potentially complicate the Strategy by leading to a 119
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prescriptive list of locations for technologies which would easily become out-of-date. Note that the April 2011 consultation document amended the policies. Policy 3 now provides general requirements for new and enhanced waste facilities and exceptions criteria
There will be a need for sites set apart from settlements to provide for schemes which SO10 We will review the are substantially but not wholly enclosed policy to place emphasis on sites set apart from settlements to provide for schemes/ operations which are substantially but not wholly enclosed. I think this comment applies to organic treatment. Policy 2 allows for organic treatment on farm Emerging Joint Waste Core Strategy, Policy 2 Enclosed Facilities Consultation Our Response Reference Reduced and combined comments
locations. This could be fully enclosed i.e. AD or substantially enclosed i.e. IVC with secondary maturation in open-windrows. The April 2011 consultation document amended the policies. Policy 3 provides general requirements for new and enhanced waste facilities and exceptions criteria
Need to place more emphasis on location of facilities being driven by the location of UK9 We will review the resource users. policy to place emphasis on both Appendices location of facilities being driven from where the waste arises and also by the location of the resource user (this is particularly important 121
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with rural locations of on-farm composting facilities where the use of compost on agricultural land is in place of fertiliser). The April 2011 consultation document amended the policies. Policy 3 provides general requirements for new and enhanced waste facilities and exceptions criteria. Policy 3.2 refers to location of organic treatment proposal in farm locations due to more than half of material produced being used on the farm land or surrounding farms.
SBC 7 A prescriptive list of waste technologies would be impractical – Emerging Joint Waste Core Strategy, Policy 2 Enclosed Facilities Consultation Our Response Reference Reduced and combined comments
the list would be out-of-date as soon as it was written.Waste technology progresses at a fast rate etc. Distance from sensitive receptors can be applied to any urban or rural location. The April 2011 consultation document amended the policies. Policy 3 provides general requirements for new and enhanced waste facilities and exceptions criteria. Appendices The desirability of more recent rural buildings (rather than using traditional) being re-used SMDC 11 We will review the for waste management purposes would need to be carefully considered by the policy and consider determining authority, and it is suggested the choice of building would need to be well including reference to justified. re-use of traditional rural buildings and re-use of modern rural buildings. In the case of 123
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organic treatment (IVC and AD) it is however considered that purpose built facilities would be used rather than re-use of rural buildings whether they be traditional or modern rural buildings. The April 2011 consultation document amended the policies. Policy 3. 2 c relates to the re-use of redundant farm or forestry buildings providing that the external character and appearance of the building is either substantially unchanged or improved.
The policy (2.3) needs to be clearer to state that where Green Belt policy exists in SSC 14 In 2.1. ‘General Staffordshire, proposals for waste management must demonstrate that they are consistent Requirements for with national and local policy. Enclosed Facilities’, it already states that Emerging Joint Waste Core Strategy, Policy 2 Enclosed Facilities Consultation Our Response Reference Reduced and combined comments
proposals must address relevant national policy (refer to Appendix 4). We will review the policy 2.3 and either change this to relate to organic treatment facilities in farm locations (rather than rural locations) or clarify that waste operations in the Green Belt must demonstrate very special circumstances. The April 2011 consultation document amended the Appendices policies. Policy 3 provides general requirements for new and enhanced waste facilities and exceptions criteria. Reference is made to farm locations. Policy 4 relates to 125
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protection and Green Belt is a consideration and reference is made to PPG2.
There is very little reference in many of the policies to delivering facilities “where there SSC 13 Noted. The April 2011 is a proven need” for them. consultation document amended the policies. Policy 2 relates to landfill diversion targets and new capacity requirements to ensure sufficient opportunities for waste management. These targets are however minimum and not intended as a rigid cap on the development of waste management capacity (as stated by PPS10 Companion Guide – para 7.27). Emerging Joint Waste Core Strategy, Policy 2 Enclosed Facilities Consultation Our Response Reference Reduced and combined comments
Amend text in 2.1, 2.2, 2.3 and 2.4 so that all references to facilities are prefaced by TBC 7 Noted. The April 2011 'enclosed' for the avoidance of doubt. consultation document however amended the policies. Policy 3 provides general requirements for new and enhanced waste facilities and exceptions criteria.
Objection.The requirements for fully enclosed organic treatment facilities in urban areas SBC 5 Noted. However it is are neither reasonable nor practicable. considered that if the standoff distance from sensitive receptors could be achieved, then AD (or IVC) facilities would be able to be accommodated in Appendices urban areas.
It would be better to say that organic treatment facilities will not be located in urban SBC 6 The strategy needs to areas. be flexible with enabling policies rather than restrictive policies. If an AD 127
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facility could be located on industrial/ previously developed land in an urban location and have a sufficient stand off from sensitive receptors then Policy 2 should not restrict this.
The monitoring target of 90% of new facilities to be enclosed would restrict competition, SBC 8 We will review the lead to higher gate fees and unfairly limit large scale organic waste treatment in rural monitoring target. The areas. A more appropriate target could be 80% April 2011 consultation document amended the policies and targets.
Amendment to the second criterion under 2.1 [i.e.‘…..including biodiversity, geodiversity EH 8 We will review the and the historic environment’]. policy. The April 2011 consultation document amended the policies. The Strategy makes reference to the historic environment. Emerging Joint Waste Core Strategy, Policy 2 Enclosed Facilities Consultation Our Response Reference Reduced and combined comments
To ensure policies are deliverable, greater flexibility is needed, with planning applications VES 4 We will review the judged on specific circumstances and appropriately worded DC policies. policy to ensure that it SSC 8 reflects local circumstances and allows appropriate flexibility, but we believe that the principle of promoting enclosed sites is sound and in step with waste management licensing requirements. The April 2011 consultation document amended the policies. Policy 3 provides general requirements for new Appendices and enhanced waste facilities and exceptions criteria. This enables greater flexibility.
Technology for managing waste may change over the plan period; however it is SSC 9 Further work needs to unnecessary to disadvantage existing open facilities which are operating efficiently, or be done to define build new facilities if there is no proven need ‘enclosure’ and clarify 129
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what is meant by the vision for the Strategy in terms of enclosing new facilities and enhanced facilities where practicable (technically, environmentally and economically practicable). Existing facilities with a permanent planning permission will remain unaffected, unless they make an application to expand or change the nature of their operations/ technology etc at the site. The Strategy cannot and will not affect existing waste management facilities if they have a permanent planning permission for that land use. For Emerging Joint Waste Core Strategy, Policy 2 Enclosed Facilities Consultation Our Response Reference Reduced and combined comments
example existing open windrow composting facilities with a permanent planning permission will still offer the opportunity for green waste contracts etc..The April 2011 consultation document amended the policies. Policy 3 provides general requirements for new and enhanced waste facilities and exceptions criteria. The reasoned justification for this policy explains what the Appendices Strategy is trying to achieve.
Closing existing open air facilities in favour of fewer new and expensive enclosed facilities SSC 10 See comment above (ref could potentially increase traffic movement of waste and have an adverse impact on SSC 9). The strategy sustainability and overall costs will not and cannot close existing waste management facilities 131
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with a permanent planning permission for that land use. The Strategy can only influence decisions on applications for new and enhanced waste management facilities in line with the vision and strategic objectives for the Strategy.
Whilst the technology does not exist to eradicate all odours, enclosing waste management SSC 11 Noted. facilities “within or close” will not reduce the impact on local amenity
There will be a need for sites set apart from settlements for where energy crops are SO11 Noted. The April 2011 grown on farmland to be mixed with waste to achieve consistent (24/7) output; such consultation document schemes optimise the available capacity of the generating equipment. amended the policies. Whilst Policy 2 sets broad locations, Policy 3 provides general requirements for new and enhanced waste facilities and exceptions Emerging Joint Waste Core Strategy, Policy 2 Enclosed Facilities Consultation Our Response Reference Reduced and combined comments
criteria. It is considered that the Strategy is flexible and able to determine planning applications for all types of waste management facility.
The policy should provide for the appropriate siting of facilities with emphasis on protecting SO12 Noted. The April 2011 residential amenity and the employees in other commercial premises at all times. consultation document amended the policies. Policy 4 relates to protection.
The policy should provide for the use of appropriate green field sites (farm land). SO13 The Strategy’s main objective is to manage waste close where to it
arises, preferably on Appendices urban industrial land or previously developed land. Given the extent of rural industrial land, it is only considered that farm locations are suitable for organic 133
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waste treatment. Green field sites therefore would be suitable locations for open-windrow composting only and not other types of waste facilities. The April 2011 consultation document amended the policies. Policy 3 provides general requirements for new and enhanced waste facilities and exceptions criteria.
On-farm organic schemes cannot be limited to the re-use of existing farm buildings SO14 Noted.AD or IVC would require purpose built facilities and unlikely to be able to re-use existing farm buildings. Existing buildings may only be suitable for storage. The April 2011 Emerging Joint Waste Core Strategy, Policy 2 Enclosed Facilities Consultation Our Response Reference Reduced and combined comments
consultation document amended the policies. The reasoned justification for Policy 3 which provides general requirements for new and enhanced waste facilities and exceptions criteria acknowledges that if purpose built facilities are required for .organic waste treatment proposals, then consideration needs to be given to Green Belt, countryside and landscape as listed in Appendices Policy 4 which relates to Sustainable Design and Protection.
The policy should provide for specifically designed anaerobic digestion facilities to ensure SO15 Noted. See comment proper treatment and management above. 135
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The policy should set out criteria for the assessment of rural facilities, on farms and with SO16 The April 2011 the necessary facilities consultation document amended the policies. Policy 3 provides general requirements for new and enhanced waste facilities and exceptions criteria which relate to proposals in farm locations.
The policy should include assessments of the effect on landscape and ecology SO17 No action required.The Policy requires proposals to demonstrate that it will not give rise to any unacceptable adverse impact on the environment – this includes landscape and ecology. The April 2011 consultation document has however amended the policies. Policy 4 now relates to protection, Emerging Joint Waste Core Strategy, Policy 2 Enclosed Facilities Consultation Our Response Reference Reduced and combined comments
which includes landscape and ecology amongst other considerations.
Policy should make clear that it is desirable to site such schemes close to existing SO18 Review Policy to clarify buildings to avoid the creation of new groups of buildings in isolated locations in the that it is desirable to countryside. site enclosed waste facilities in rural settings close to existing buildings to avoid the creation of new groups of buildings in isolated locations in the countryside. The April 2011 consultation document amended the Appendices policies. Policy 4 now relates to sustainable design and protection, which includes taking into account local policies for building design, landscape 137
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character etc and compatibility with adjoining land uses.
Emerging Joint Waste Core Strategy, Policy 3: Open Air Facilities Consultation Our Response Reference Reduced and combined comments
Broadly support the policy CCC6, CMX6, No action necessary
GW 7, UK10,
TWC3, KPC 4,
HP7, HP8
UK11, ESBC 4,
SMDC 12
Is the restriction of open windrow composting in rural areas justified in terms of GW 8, GW 9, Noted. The April 2011 business opportunities, costs, competition, or visual impacts? consultation document KK15, ESBC 6, amended the policies. Policy 3 provides general ESBC 7, SBC 11 Emerging Joint Waste Core Strategy, Policy 3: Open Air Facilities Consultation Our Response Reference Reduced and combined comments
requirements for new and enhanced waste facilities and exceptions criteria which relate to proposals in farm locations. As the evidence base supporting the strategy shows that there is a significant numbers of facilities with open-windrow composting capacity, and that there is only a shortfall in organic treatment capacity for co-collected green and Appendices food waste, and given that the Strategy aspires to enclose waste management facilities, it is considered appropriate for applicants to demonstrate need arising 139
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from a shortage of local capacity for open windrow composting.
Target of <10% of new facilities being open air lacks evidence SBC 10 Targets will be reviewed to assess their Target of <20% would be better SBC 12 level, their justification, and whether they are required at all. The April 2011 consultation document amended the policies and targets. These targets have been removed.
Should refer to Environment Agency as regulators TBC 8 No action necessary. The April 2011 consultation document amended the policies. The reasoned justification to policies and also the section of implementation and Emerging Joint Waste Core Strategy, Policy 3: Open Air Facilities Consultation Our Response Reference Reduced and combined comments
monitoring acknowledges the role of the Environment Agency.
Composting sites within 250m of a workplace or dwellings that treat more than 500 EA11 Noted. The April 2011 tonnes of waste at any one time and involve open turned windrows are unlikely to consultation document be able to produce a sufficiently robust risk assessment. amended the policies. Policy 3 makes reference to EA permitting requirements in relation to bio-aerosols.
Restrictions on location of sensitive receptors would help UK12 Noted. We have attempted to achieve this already through this policy and Policy 7 on Safeguarding waste
sites. No further action Appendices necessary
Suggest consistent wording on protection of natural and historic environment [i.e. EH 9 Accepted, wording will be ‘…..including biodiversity, geodiversity and the historic environment’]. adjusted.
Concerned that temporary planning permission may weaken grounds for future SMDC 13 Noted. Temporary opposition. planning permissions are typically used where a 141
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development appears acceptable but lacks the track record, e.g. from similar plants, to demonstrate that adverse impacts will not arise. It needs to be granted with clear conditions that must be met to allow permanent permission to be considered. In such situations, we believe that the problems can be avoided and the approach can be helpful. No further action necessary
Policy 3 appears to contradict Policy 2 ESBC 3 Policy 2 is intended to address the majority of new developments which should be enclosed facilities. Policy 3 is intended to set out where Emerging Joint Waste Core Strategy, Policy 3: Open Air Facilities Consultation Our Response Reference Reduced and combined comments
open air facilities may be considered. The two policies are intended to run in parallel. We will revise presentation of all policies to clarify the way in which they should be applied. The April 2011 consultation document amended the policies. Policy 3 sets the general requirements (enclosure) however includes exceptions criteria (for open air facilities). Appendices 143
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Reduced and combined comments
Generally support TWC4, GW No action required 10, IK13, PE 17, SSC 15, SMDC 14, NBC 6
Support encouragement of recycling and re-use CCC8, No action required
BWS 23, UK14, SSC 15, SBC 9, PE 18, SSC 16
Support restriction on new landfill or land raising CCC12 No action required
No comment NE1 No action required
Support 4.2 ‘Waste Incineration’ BWS 25 No action required
We consider that opportunities should be sought for maximum energy recovery from PE 19 No action required waste incineration and that opportunities should be sought for potential heat off take and meeting combined heat and power needs Emerging Joint Waste Core Strategy, Policy 4: Maximising Waste Re-use , Consultation Our Response Recycling & Recovery of Resources Reference
Reduced and combined comments
Object to presumption of support for waste incineration CCC9 No action required .As stated in 4.1 proposals for new facilities should demonstrate that the most sustainable option has been sought at the top of the waste hierarchy.
Enclosed and Open air facilities should be covered by Policies 2 & 3 respectively rather BWS 24, No action required. The than singling out treatment types. BWS 22, April 2011 consultation BWS 27 document amended the policies. Policy 1 relates to waste as a resource and the waste hierarchy, Specific mention is made of energy recovery and Appendices landfill and the requirement not to undermine the viability/provision of waste management facilities operating further up the waste hierarchy. 145
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Reduced and combined comments
Landfill proposals should be supported with robust evidence of need but not restricted HP11, HP13, No action required. to a shortage of void capacity.The words ‘..arising from a shortage of void capacity that CMX8, Staffordshire and exists during the plan period.’ should be deleted. CMX7 Stoke-on-Trent currently have 21 permitted landfill sites, 10 of which are operational. These provide sufficient landfill void capacity for the time period of the Strategy. It will be however be necessary to maintain existing void for the disposal of residual waste as a last resort. The April 2011 consultation document amended the policies. Policy 1 relates to waste as a resource and Policy 1.6 relates to landfill and new proposals will only be considered where they are supported by robust evidence that Emerging Joint Waste Core Strategy, Policy 4: Maximising Waste Re-use , Consultation Our Response Recycling & Recovery of Resources Reference
Reduced and combined comments
there is an overriding need for the landfill capacity.
4.1 should read ‘…..including biodiversity, geodiversity and the historic environment’ EH 10 Noted. The April 2011 consultation document has however amended the policies. Policy 4 incorporates this wording.
More breadth and practical appreciation is required here. GW 11 Link to comment GW12 below.
Each proposal needs to be considered on its own merits CCC10, No action required KK25,
GW12, Appendices GW13, CMX9, CMX10 147
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Reduced and combined comments
Important that clear timescales are set for existing landfill operations. CCC13,CCC14 No action required. The waste core strategy does not have the opportunity to review existing permissions
Ensure close links with District Councils and make reference to Local Authority Core SSC 17, Noted. The April 2011 Strategies consultation document SSC 18 amended the policies. Reference is made to LA Core Strategies (see policy 4).
May raise potential conflicts in relation to landscape and visual impact at sites converting NE2 Noted. The April 2011 from existing windrow composting to anaerobic digestion / biomass or in vessel consultation document composting. amended the policies. Policy 4 relates to protection and includes landscape and visual impact considerations.
4.2 should read “market or potential markets” BWS 26 Noted. Amendments made in April 2011 consultation document. Emerging Joint Waste Core Strategy, Policy 4: Maximising Waste Re-use , Consultation Our Response Recycling & Recovery of Resources Reference
Reduced and combined comments
Waste incineration should not be a preferred option for any waste. KK 16 No action required. As stated in 4.1, proposals for new facilities should demonstrate that the most sustainable option has been sought at the top of the waste hierarchy.
Waste incineration facilities should not prevent waste moving up the waste hierarchy. KK 17 No action required. As stated in 4.1 proposals for new facilities should demonstrate that the most sustainable option has been sought at the top of the waste hierarchy. Appendices
Contracts to Waste Incineration facilities should be for no more than 10 years. KK18 No action required. Not an issue for JWCS
Waste Incineration should only use residual waste. KK 19, PE No action required. 4.2 20 states that proposals for waste incineration should use waste that cannot 149
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Reduced and combined comments
practicably and reasonably be re-used, recycled or processed to recover materials.
Waste incineration facilities should be flexible and able to operate with only 40,000 tpa; KK 20, No action required. should have a thermal efficiency over 40% and have continuous dioxin and PM2.5 KK21, KK22 Each proposal will be monitoring considered on its own merits.
Easily biodegradable waste should not be landfilled without pre-treatment KK 23 No action required. Landfill will be considered as the last resort.
Landfilling should be permitted when it is designed to sequester non-biodegradable KK 24 No action required. carbon and for mono-fills for later extraction. Landfill will be considered as the last resort
Funding for the creation of new de-centralised energy centres should be investigated UK15 No action required. Outside the remit of the JWCS. Emerging Joint Waste Core Strategy, Policy 4: Maximising Waste Re-use , Consultation Our Response Recycling & Recovery of Resources Reference
Reduced and combined comments
Adequate waste management provisions further up the hierarchy will be all the more EA 9 Noted. important as a result of this policy
Restrictions on landfill capacity should not result in more waste being landfilled outside EA10 No action required. the County Staffordshire and Stoke-on-Trent currently have 21 permitted landfill sites of which 10 are operational. These provide sufficient landfill void capacity for the time period of this Strategy.
Concerned about the policies approach to landfill HP9 No action required. Staffordshire and Stoke-on-Trent currently
have 21 permitted landfill Appendices sites of which 10 are operational. These provide sufficient landfill void capacity for the time period of this Strategy. Policy 5 states that mineral sites requiring 151
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Reduced and combined comments
backfill for restoration purposes will be favoured over new landfill purposes.
Mineral sites may benefit from the disposal of wastes; either inert or non inert. HP10 No action required. Policy 5 states that mineral sites requiring backfill for restoration purposes will be favoured over new landfill purposes.
Policy 4 does not entirely conform to Policy 5 HP12 No action required. Relates to HP11 comment.The April 2011 consultation document amended the policies.
Waste Incineration facilities need to be located near to source of waste or sustainable PE 21 No action required. 4.2 transport opportunities. states that proposals for waste incineration should be in close proximity to the sources of waste. Emerging Joint Waste Core Strategy, Policy 5: Waste Hierarchy Consultation Our Response Reference Reduced and combined comments
Support TWC5, No action required GW 14, CMX11, UK16, SSC 19,
CMX12
UK17
UK18
ESBC8
SBC 13
SSC 20
SSC 21 Appendices
SMDC 15
SMDC 16
NBC 7
NBC 8 153
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Re-consider broad location approach for recycling facilities. CCC15 Need to highlight the relationship of the policy GW 15 to the criteria to be applied for enclosed sites GW 16 under policy 2 and for open air facilities under GW 17 policy 3. UK19 Refer to “access” criteria SMDC 16 to be applied to broad locations – may need SMDC 17 some amendment.
SMDC 18 Consider the need for a strategy for CDEW SMDC 19 separate to policy 1
SMDC 20 Address concern in terms of justifying hierarchy of settlements under policy 1
See above – need flexibility but to define how site will best serve broad location. Emerging Joint Waste Core Strategy, Policy 5: Waste Hierarchy Consultation Our Response Reference Reduced and combined comments
No quarries are specifically identified for new recycling operations. Are we sufficiently clear that waste operations in quarries should be clearly related to permit activities?
The April 2011 consultation document amended the policies.
Acknowledge opportunity for recycling on construction/demolition sites. EA12 Noted. The April 2011 consultation document amended the policies.
Policy 1 refers to CDEW Appendices (policy 1.3) and Policy 3 refers to exceptions locational criteria for proposals at landfill or mineral sites. Reference is also made to permitted development rights and 155
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that there may be scope for permitting temporary recycling operations where large scale construction is involved.
Consider opportunities to reduce waste arising. EA13 Noted. Policy 6 however encourages waste minimisation. The April 2011 consultation document amended the policies and waste minimisation is a general principle in Policy 1. .
Note specification for recovered waste. EA14, Noted. Will try to EA15 incorporate this in the reasoned justification for the policy by providing a link to Aggregate quality Protocols (refer to WRAP website).
Consider use of waste for landscaping and engineering projects. EA16 No action required. Refer to criteria under section 5.6. The April Emerging Joint Waste Core Strategy, Policy 5: Waste Hierarchy Consultation Our Response Reference Reduced and combined comments
2011 consultation document amended the policies and this is incorporated into Policy 1.
Proposed change to criterion to define “environment” [i.e. ‘…..including biodiversity, EH 11 Noted The April 2011 geodiversity and the historic environment’]. consultation document amended the policies and this has been incorporated.
**Need to consider provision for managing incinerator bottom ash Noted. This industrial waste can be managed so that it can be reused as a substitute aggregate material similar to
CDEW. On the basis that Appendices policy 5 provides for sites to recycle CDEW, it should be noted that industrial wastes such as ash, glass, slag, railway ballast, ceramic waste and tyres could be 157
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similarly treated. The April 2011 consultation document amended the policies and Policy 2 refers to broad locations for recycling of CDEW and comparable industrial wastes.
Emerging Joint Waste Core Strategy, Policy 6: Waste Minimisation and Major Developments OurConsultation Response Reference Reduced and combined comments
Would prefer Option 3– which is the same as the preferred option but with the added reinforcement of Noted.NE3 No action checklists and design requirements for new waste management facilities. necessary. . The April 2011 consultation document amended the policies. Policy 4 relates to sustainable design and protection. Emerging Joint Waste Core Strategy, Policy 6: Waste Minimisation and Major Developments OurConsultation Response Reference Reduced and combined comments
Broadly support Noted.TWC6, No action necessary GW 18,
SSC 22,
CCC16,
SBC 14,
SSC 22
ESBC8
SSC Appendices 23
SMDC 22
SMDC 21 159
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Site Waste Management Plans - Local Authorities should establish who will carry visits sites and enforce Noted.EA19 Will promote regulations guidance as appropriate
Reference to West Midlands Checklist would add local element Noted,TBC11 will give serious consideration to the checklist.
Risks additional burden of bureaucracy and does not add a local aspect to national policy PolicyGW was not intended19 to introduce new burdens, simply toTBC ensure that maximum9 benefit was derived from the informationGW that developers20 are already required to TBC10 provide. Will review revised policy to ensure that it does not create additional burdens without justification. Emerging Joint Waste Core Strategy, Policy 6: Waste Minimisation and Major Developments OurConsultation Response Reference Reduced and combined comments
Local authority may lack skills and resources to make this policy work properly NotedTBC12 . Policy is not intended to add burdens for local authorities either, simply to ensure that the information they are required to collect is put to practical use
Practicalities of implementing this policy may inhibit use of quality materials and design Noted.TBC13
Need guidance on how to make best use of SWMPs Noted.NBC We will endeavour10 to make guidance available, though it may not be appropriate to include
this in the Waste Core Appendices Strategy
May lead to a reduction in fly tipping of C&D waste, which would be a good indicator WillEA20 consider this indicator. The April 2011EA21 consultation document amended the policies. This indicator has been 161
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included for monitoring policy 1 – waste as a resource.
County Council’s continued input into emerging South Staffordshire Core Strategy is requested, to promote Noted,SSC will continue recycling including C, D&E waste collaboration24
Emerging Joint Waste Core Strategy, Policy 7: Safeguarding Consultation Our Response Reference Reduced and combined comments
Do not support an approach that implies indefinite continuation of landfill operations CCC17 No action required. Policy would not have impact of extending permitted lifetime of existing landfill sites; neither could a WCS policy provide an opportunity to review existing permissions. Note however that the April 2011 consultation document amended the policies; only the Emerging Joint Waste Core Strategy, Policy 7: Safeguarding Consultation Our Response Reference Reduced and combined comments
hazardous landfill at Meece is now to be safeguarded. All waste management facilities will be afforded some protection in respect of Policy 2.5 The location of development in the vicinity of waste management facilities.
Generally support TWC7, No action required
SMDC 24,
SBC 16, SMDC 23 Appendices
Do we need to safeguard any additional facilities? EA25 No action required. The April 2011 consultation BWS 31 document amended the policies, Policy 2, in LRB 7 accordance with PPS10, provides protection for all waste sites. 163
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Need to ensure that this policy would not encourage treatment down the hierarchy EA22, We will review potential impacts, but PPS 10 EA23, already provides scope to safeguard all waste EA24 sites. This policy simply highlights those sites considered most important particularly for implementing the Joint Municipal Waste Management Strategy.
Potential may impact on broad locations for housing allocations SMDC 25 No action required. This should not be an issue if housing allocations have been prepared with PPS 10 in mind. This policy does not take safeguarding beyond level already provided
Technical query over whether Wilnecote landfill is in Staffordshire TBC14 It is in Staffordshire
No action required Emerging Joint Waste Core Strategy, Policy 8: Enhancement of Existing Facilities Consultation Our Response Reference Reduced and combined comments
Broad approach of Policy is supported. CCC18, No action required CE5, CE6, CE7, CE8, UK21, SBC 17, TWC8, BWS 32, GW 18, UK20, HA2, SMDC 26, EA27
Landfill restoration end dates are required. CCC17 No action required. WCS Policy would not provide an opportunity to review existing permissions. Appendices
Any proposal would need to be treated on its own merits. CCC19 Noted. No action required. 165
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Consolidation of existing consents (para. 8.3) unlikely to be appropriate or feasible in most BWS 33, We will review the cases and unlikely to achieve any positive benefit, just a very long multi-sectional BWS 34 policy. Reducing the permission. Consents for different waste operations on the same site are often for different cumulative effect of processes requiring different planning conditions/controls and covered by different EA multiple waste Environmental permits. activities is the issue to tackle. The April 2011 consultation document amended the policies, consolidation of existing consents has not been taken forward. Cumulative effect is however a consideration of Policy 4 which relates to protection.
The final bullet point of 8.1 (material planning benefits should outweigh the material planning GW 23 We will review the policy objections) could be misinterpreted. and
clarify the interpretation of material planning benefits should outweigh the material planning objection. The Emerging Joint Waste Core Strategy, Policy 8: Enhancement of Existing Facilities Consultation Our Response Reference Reduced and combined comments
April 2011 consultation document amended the policies. The general principles in Policy 1.1 require that the overall (economic, social and environmental) benefits outweigh any material planning objections.
Flexibility should be allowed on the types of technology employed at existing sites (8.1). UK22 No action required. The Strategy is flexible and non specific on technology. The policy allows for new proposals to complement existing
activities. Appendices
Strict operating parameters which are in line with those of new build facilities should be Uk23 Noted. There is potential enforced on an incremental basis to ensure continuity of service without increasing costs to bring the operating (to the producer) outside of the national average. standards of the facility up in phases whilst the facility is operational, rather than expect the applicant to undertake all 167
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the improvements before the facility is made operational. If this cannot be done through planning conditions it could be done by legal agreement. It would also be possible to link this policy to any BREEAM standards if incorporated into design policy 9. In the past we have discussed design standards for refurbishments and design standards for new build. Note however that the same conditions on a planning permission would apply to new build or enhanced waste facilities depending on the proposed operation/technology etc. EA environmental permits will also apply Emerging Joint Waste Core Strategy, Policy 8: Enhancement of Existing Facilities Consultation Our Response Reference Reduced and combined comments
same controls. The April 2011 consultation document amended the policies. Policy 3 relates to criteria for the location of new and enhanced waste management facilities. This includes that proposals should include a programme of phased improvements to bring the whole site up to modern standards.
Assessment of traffic data does not anticipate any problems HA1 Noted. No action required.
Amend 8.1 bullet point 5 to read ‘without significant impacts’. TBC15 We will review the Appendices policy. The April 2011 consultation document amended the policies. Policy 3 relates to criteria for the location of new and enhanced waste management facilities. 169
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This includes general requirements for enclosure, and exceptions criteria.
The general requirements of Policy 8 should reflect the comments made by the EA relating EA28 We will review the to Strategic Objectives 1 Climate Change and 4 Enhancement of existing facilities. policy. The April 2011 consultation document amended the policies. Policy 4 relates to sustainable design and protection and incorporates considerations of the water environment and climate change.
Consideration must be given to Policies in PPS4 such as EC6 and EC12 which seek to SMDC 27 No action required. The balance rural economic growth with countryside protection strategy supports waste facilities as acceptable in the countryside and Green Belt and therefore rural economic growth is not stifled. The countryside is however Emerging Joint Waste Core Strategy, Policy 8: Enhancement of Existing Facilities Consultation Our Response Reference Reduced and combined comments
also being protected by limiting what operations can take place on farm locations and rural industrial land. The April 2011 consultation document amended the policies. . Policy 3 relates to criteria for the location of new and enhanced waste management facilities.
Green Belt. The “inappropriate” nature that proposed new-build waste management SMDC 28 Noted. The April 2011 development in the greenbelt would represent (therefore requiring “very special consultation document circumstances”) should be referenced in the Policy, although, the re-use of existing buildings amended the policies. may not be contrary to Greenbelt policies. Policy 4 relates to protection and Green Belt Appendices is a consideration. Policy 3 relates to criteria for the location of new and enhanced waste management facilities and the reasoned justification makes it clear 171
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that any proposal needs to take into account the considerations listed in Policy 4.
Emerging Joint Waste Core Strategy, Policy 9: High Quality Design Consultation Our Response Reference Reduced and combined comments
Generally support CCC18, NE5, SBC No action required 18, SE1, TWC9, NE4, BWS 35,
BWS 36,
ESBC 10,
SSC 25, SMDC 29,
SMDC 30,
SMDC 31,
SMDC 32, SE2 Emerging Joint Waste Core Strategy, Policy 9: High Quality Design Consultation Our Response Reference Reduced and combined comments
It is not just the overall shape, scale or massing of a large building that determines ESBC 12 No action required whether or not a building makes a positive or negative impact on its surroundings, but also other considerations such as where on the site certain activities take place, the positioning of different buildings or elements of the scheme, the landscaping
Criteria should read “…where appropriate” to prevent policy becoming too PE 23, PE 24, PE Review whether policy restrictive. 25, BWS 37 is too restrictive. The April 2011 consultation document amended the policies. Policy 4 relates to sustainable design and protection and improvement of environmental quality.
Refer to Local Authority Open Space, Playing Pitch and Sports Strategies SE3 Noted. The April 2011
consultation document Appendices SE4 amended the policies. Policy 4 relates to sustainable design and protection and improvement of environmental quality and includes public open 173
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space (including recreational and sporting facilities) as a consideration.
Refer to maximising opportunities through site restoration SE5 Noted. The April 2011 consultation document amended the policies. Policy 4 relates to sustainable design and protection and improvement of environmental quality and includes restoration and recreational and sporting facilities as a consideration.
EfW facilities should be recognised as contributing positively to climate change BWS 38 Noted. The April 2011 through non fossil fuel energy generation consultation document amended the policies. Policy 4 relates to sustainable design and protection and improvement of Emerging Joint Waste Core Strategy, Policy 9: High Quality Design Consultation Our Response Reference Reduced and combined comments
environmental quality. Proposals should make a positive contribution where appropriate, towards decentralised and renewable or low carbon energy supply.
High design standards should not justify new waste facilities in an inappropriate CCC19 No action required All area proposals will be judged on a case by case basis against the requirements listed by all the policies proposed.
Support provision for protection for the AONB and that proposals for waste CCC20, AONB1, Noted. No action management facilities should contribute to the Forest of Mercia and Cannock CCC22 required.
Chase AONB Management Plan. Appendices
Define “appropriate” EA29 No action required. Strategy should be flexible enough to allow case officers to use their judgement. 175
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First criteria should include specific reference to ‘the historic environment and EH 12 Noted. The April 2011 heritage assets’. Final criteria should be broadened to allow contributions to the consultation document historic environment. amended the policies. Policy 4 relates to sustainable design and protection and improvement of environmental quality. The reasoned justification for the policy will make specific reference to historic environment and heritage assets and allow contributions towards these.
This policy would be better incorporated in an SPD on waste. LDC 5 No action required. As part of the vision and a strategic objective it is appropriate to have a design policy.
Promote creation of renewable energy as well as its use. SSC 26 Noted. The April 2011 consultation document amended the policies. Emerging Joint Waste Core Strategy, Policy 9: High Quality Design Consultation Our Response Reference Reduced and combined comments
Policy 4 relates to sustainable design and protection and improvement of environmental quality. Proposals should make a positive contribution where appropriate, towards decentralised and renewable or low carbon energy supply.
In practice design is not given as high a priority as it should be in waste ESBC 11 Noted. No action management. There is often little or no attempt to mitigate their impact on their required. This is a surroundings. statement by the consultee, rather than constructive policy comment. Appendices 177
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178 Consultation Statement (Regulation 30 document) 30 (Regulation Statement Consultation 6 Appendices Appendix 6: Representations, Revised Draft Policies April 2011 consultation
Representations received in connection with Revised Draft Policies for Joint Waste Core Strategy April 2011 consultation.
Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
Friends of The Strategy has failed to take account of the massive gap between The Strategy is informed by the Joint the Earth projected waste arisings and real waste data over the last few years. For Municipal Waste Management Strategy -Mr Keith waste incineration the area will become a significant net importer of MSW (MWMS). The MWMS approved in 2007 Kondakor from other areas. The combined 210,000tpa existing and 300,000 tpa sets out landfill diversion targets for incinerator under construction greatly exceed current and future levels municipal waste and waste management of residual MSW. methods for managing municipal waste.
The recycling target for 50% of MSW but 55% of household waste would The Strategy is also informed by the RSS equate to zero recycling of the non-household MSW.This is unreasonably Phase 2 Review with regard to waste low. All MSW should have a 70% target. projections. This has been through the Burning over half a million tonnes of waste each year is not compatible examination process. with a proper zero waste policy. There needs to be a clear statement that no new energy recovery capacity should be permitted with the exception of small scale anaerobic digestion below 60ktpa. Policy 1.6 - landfill gas is only for non-inert landfills. Policy 2.1 need 70% recycling targets for 2015/6 onwards - not just recovery targets.Your policy promotes burning ahead of recycling and fails to push the waste hierarchy. Policy 2.2 needs targets reduced to take account of real levels of waste generation. Contaminated Soils should be treated on site whenever possible. Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
Policy 2.4 Strategic waste facilities to be safeguarded. The Hanford Policy 1 is designed to increase the use of incinerator performs poorly and should be replaced with a more flexible, waste as a resource by determining safer non-incinerator based facility that would allow for greater recycling proposals in accordance with the waste in Stoke and North Staffordshire. hierarchy. Energy recovery will only be On page 63 information on LATS is dishonest.The LATS system is going supported if it does not prejudice the use to be scrapped as councils have greatly overachieved on landfill diversion of waste further up the hierarchy. of BWM. Councils in stoke and Staffordshire would never have been fined £150/tonne. Comment regarding policy 1.6 has been noted and policy amended to state where relevant to capture landfill gas.
Policy 2 has been revised in the Publication Document with more challenging targets for landfill diversion than those targets specified in Regional policy. Targets are set for additional recycling capacity. On-site management of waste is promoted however a key issue is to reduce quarrying Appendices and the promoting of increased recycling of construction, demolition and excavation waste.
Facilities required to deliver the Municipal Waste Management Strategy are to be safeguarded. Replacement of renewal of 179
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180 Consultation Statement (Regulation 30 document) 30 (Regulation Statement Consultation 6 Appendices Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
the existing Energy Recovery Facility at Hanford is a strategic priority for the Waste Disposal and Waste Collection Authorities.
The LATS comment is noted and the glossary has been revised in the Publication Document.
British BPA request that the rights of statutory consultation on all planning Comment has been noted. BPA are a Pipelines matters are maintained within our pipeline Area of Interest or easement.” statutory consultee in the Development Agency - Control process. Mr Philip Hirst Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
Centro – Centro considers that all plans within the wider West Midlands area Comments have been noted. Mr Adam should demonstrate that full consideration has been given to sustainable Harrison transport opportunities available and be in conformity with regional and national guidance. Centro welcomes in principle that the Core Strategy aims to “minimise the impacts of transporting waste, to encourage the development of a network of waste management facilities which are located close to the main urban areas wherever possible, so they are closest to where most of the waste is produced”. Moreover, Centro supports Strategic Objective 3:To achieve and maintain net self sufficiency in waste treatment by protecting the existing network of waste management facilities and Strategic Objective 5: to utilise the capacity of existing and potential transport infrastructure to support the sustainable movement of waste, seeking when practicable, environmentally acceptable and beneficial to use modes other than road transport.
Inland The Inland Waterways Association remains opposed to the Energy from The Four Ashes facility has a planning Appendices Waterways Waste plant at Four Ashes due to its adverse visual impact on the permission and is under construction. Association Staffordshire & Worcestershire Canal Conservation Area and its Green (Lichfield Belt and countryside setting. Branch) – Mr Philip Sharpe 181
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182 Consultation Statement (Regulation 30 document) 30 (Regulation Statement Consultation 6 Appendices Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
Inland Draft Policy 2. 2.3 Broad Locations:The Four Ashes site fails the transport The Strategy is informed by the Joint Waterways criteria because it is not best located within the waste source area to Municipal Waste Management Strategy Association minimise transport impacts, and the site selection process has not (MWMS). The MWMS approved in 2007 (Lichfield adequately considered the viable alternative of the i54 site. sets out waste management methods for Branch) – 2.4 Strategic Site Safeguarding: The Four Ashes site should not be managing municipal waste. The Four Mr Philip safeguarded as it is not the most appropriate site for such a facility. Ashes Energy Recovery Facility has a Sharpe The Strategy is also seriously deficient in entirely ignoring the current planning permission and is under proposal for a similar facility at the Poplars site at Cannock.There should construction. Facilities required to deliver be a fundamental review of the public and private incinerator plans within the Municipal Waste Management Strategy the Waste Strategy to allow for a more appropriately located privately are to be safeguarded. financed facility instead of the over-sized, badly located, and inappropriately financed Four Ashes project. The Energy Recovery Facility application at Cannock has been determined (July 2011 Planning Committee).
Digbits – Recycling of Construction, Demolition and Excavation (CD&E) waste - Comments are noted. Policy 1 (1.2) Mr Marcus there needs to be consideration for the detail. promotes maximising on-site management Clay Firstly, the 200,000 t p.a. quoted is a relatively small quantity, especially of C,D&E waste and site waste when split over multiple sites - the draft says potentially 2 to 4 - and policy management plans. Targets for additional will need to consider the viability of the approach. C,D&E recycling capacity are minimum local targets and a key issue is to reduce With the recent advent of Defra's Site Waste Managment Plans (SWMPs), quarrying and the promotion of increased the planning process has (theoretically) far greater control over on-site recycling of construction, demolition and recycling, but this needs to be backed up by clear local policy direction excavation waste. and enforcement. Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
Brereton & The Parish Council has nothing further to add to our previous comments Comment is noted. Ravenhill on waste policy but they remain very concerned about enforcement. Parish Council - Mr. P.G. Davies
Sport Sport England's only comment is to support Draft Policy 4 which seeks Comment is noted. England to protect sports facilities from relevant waste development. (West Midlands Region) - Mrs. Maggie Taylor
Biffa Section 2.1, Issue 1 and also Strategic Objective 1 should be expanded Comments are noted and amendments
Waste to refer to climate change in general, not just arising from waste have been made to the issues and Appendices Services management. This is because some waste management technologies objectives in the Publication version of the Ltd - Mr. contribute positively in terms of climate change, by reducing reliance on Strategy. The Publication document has Jeff fossil fuels, as acknowledged by Strategic Objective 2. revised the original five issues and five Rhodes Section 2.1, Issue 3 should also recognise the need for new facilities objectives and now contains four issues which recover value from waste, not just recycling facilities. This would and four strategic objectives and four then be consistent with the objective in Issue 2 to reduce reliance on policies. 183
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landfill, also consistent with the stated Vision in this section. The second two bullet points only refer to municipal waste and should therefore be expanded to include reference to similar commercial and industrial waste. Strategic Objective 3 should also include support for additional facilities to recover value and/or energy from waste in preference to landfill, in line with Issue 2. As written, this Objective appears to endorse a continuation of an unnecessary large proportion of residual waste to landfill.
We support Strategic Objectives 2, 4 and 5.
Biffa We agree with all except Draft Policy 2, section 2.2, Table 2. As with our Policy 2 has been revised in the Publication Waste comments on Strategic Objective 3, this appears to endorse a Document with more challenging targets Services continuation of current levels of landfill, rather than providing for landfill diversion than those targets Ltd - Mr. encouragement for additional facilities to recover value from residual specified in Regional policy. Jeff waste in preference to landfill. This encouragement also needs to relate Rhodes to commercial and industrial waste as well as municipal waste.
The Coal Previous comments do not appear to have been taken into account within Policy 4 has been revised in the Publication Authority - the current revised policies. The Coal Authority would like to see mineral Document and the wording suggested by Miss. safeguarding and mining legacy issues taken into account within Draft the Coal Authority has been incorporated. Rachael Policy 4 – Sustainable Design. The following wording is suggested: Bust Consider any impact upon mineral resources through potential sterilisation and address any land instability issues and/or contamination arising from former land uses Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
Reason – In order to ensure that the Joint Waste Core Strategy conforms with national planning policy on unstable land in PPG14 and that it also conforms with national policy on mineral safeguarding in MPS1.
Blore The Draft Policies correctly place emphasis on monitoring waste The Publication document contains a Heath and management. Implementation of the Strategy can only be achieved if section on Implementation and Monitoring Folly there is accurate monitoring. Our particular concern is the recycling of and targets and survey methods are Wood C, D & E waste with a view to "reducing the demand for extraction of proposed for monitoring what is happening Action new aggregate materials". with C,D&E waste. Group - During the last Minerals Local Plan a National guideline target of 27% Mr. (to 30%) of Alternative Material was discussed. Much of this Material Policy 1 and Policy 4 promote waste Frederick was supposed to be derived from re-cycled aggregates, arising chiefly minimisation and sustainable design and Fisher from demolition of buildings. However, in the Regional Options Paper construction techniques. (which also called for better data collection), the County Council admitted that it did not have an adequate means of collecting this data and instead proposed to delegate this responsibility to "District Councils". This was both unrealistic and risky. District councils are not accustomed nor are they resourced to collect this data. A better way needs to be found for Appendices the County Council to collect the data itself, say, by requiring demolition companies (operating under permit) to keep and submit records of their recycling activities. Also, there is need to assure demand for re-cycled aggregate. One way to achieve this would be to place a sufficiently high tax on land-won aggregate to encourage the substitution of Alternative Material, including recycled aggregate. Another possible approach would be to mandate 185
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the use of recycled aggregate by directing this in planning permissions for new homes and buildings. The quarrying industry wishes to have a plan for "sustainable" concrete and cement. Specifying the percentage use of recycled material in new construction would be an important step in the right direction.
Tidysite We support the approach, particularly the expectation that waste The Publication document has revised treatment facilities within buildings should be located on general industrial policy 3 and clarifies that where it is not or previously developed land. This would be in the interests of practicable or environmentally acceptable sustainability, minimising vehicle journeys and protecting undeveloped to enclose waste operations, the applicant land where necessary. However we consider that some open uses such must clearly demonstrate that any as scrap yards could where appropriate in environmental terms be also environmental impacts can be effectively located on general industrial and previously developed land. mitigated by alternative means.
Tidysite We support the general approach of the Revised Policies particularly The Strategy is not technology or site criteria guiding waste development to general industrial and previously specific and being criteria based allows for developed land close to where the waste arises and within or close to any type of waste management proposal the urban areas, particularly in Newcastle under Lyme and the North to be developed, including scrap yards. Staffordshire conurbation generally. However this should extend also to Whilst the general requirements for new scrap yards where environmentally acceptable as they are an important and enhanced facilities are for proposals component of the waste treatment regime.This whole approach is in the to be fully contained, the Strategy accepts interests of sustainability, minimising vehicle journeys and protecting the that some operations have to take place in unnecessary release of undeveloped land. the open-air. The Publication document has revised policy 3 and clarifies that where it is not practicable or environmentally Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
acceptable to enclose waste operations, the applicant must clearly demonstrate that any environmental impacts can be effectively mitigated by alternative means.
Cannock The Strategy should acknowledge the duty of authorities in primary Policy 4 of the Publication document has Chase legislation (s85 Countryside and Rights of Way Act 2000) to have regard been amended to safeguard the AONB AONB to the AONB which is locally expressed in the AONB Management Plan resource and states that there is a Partnership (current version 2009-14). It should also separate out the responsibilities presumption against waste development - Mrs. to conserve and enhance the AONB from those related to the Green Belt within the AONB or development that might Ruth Hytch and general countryside. Acknowledging the potential to mitigate impacts impact on its setting. Links are also from waste locations on the AONB and designations within it would help included to the AONB Management Plan support the integrity of the area. An ideal position might be to explicitly 2009 -14 and proposals should take into express a presumption against activity within the AONB. A summary list account the objectives and purposes listed. of AONB/waste management issues is: Protection of the landscape character, including views into and out of the AONB (i.e. consideration in some cases should include areas outside the AONB boundaries) Appendices Visual impact of activity within the AONB landscapes Protection of the biodiversity and other designated areas within boundaries Retention of the rural and open wilderness “feel” within the area Protection of the peace and tranquillity, including reduction of motorised traffic and use of AONB roads to access facilities outside its boundaries and operation of facilities. 187
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British British Waterways Board comment that a key characteristic of the Policy 4 of the Publication document Waterways environment in Staffordshire is the presence of the inland waterways. includes reference to using modes other Board - Staffordshire contains a number of canals, feeders and reservoirs, some than road transport and the section Ms. of which are located near to waste sites within the county, however they ‘Protection of Air, Soil and Water and Christine are mostly Canal Conservation Areas and located within the Green Belt. reduction of flood risk’ gives consideration Hemming In respect of Draft Policies 1 - 3, the presence of the waterways provides to the protection of the waterway opportunities and benefits for the waste industry. For example, the environment and its wider landscape waterways can provide a freight route for the transit/movement of character. Section 4 of the document, ‘The materials and waste by water can reduce vehicle movements by road, Spatial Portrait’, also includes reference to improving air quality etc. The waterways also produce waste materials, inland waterways being a key characteristic from the dredging of canals, which if treated, to prevent land of the area. contamination, and reprocessed, could be sold on as aggregates. BW supports the location of waste receiving and processing materials adjacent to the waterways, where appropriately assessed to protect the environment and the tourism potential of the waterways. BW also welcomes the reference to canal wharves as a facility/infrastructure for sustainable transport. In respect of Draft Policy 4 the waterway environment and its wider landscape character should be protected, to safeguard biodiversity of the waterway environment, control pollution, enhance and create habitats, and ensure any new development seeks to protect and enhance the landscape quality and biodiversity of waterway corridors. Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
Environment Draft Policy 1. It is suggested 1.1 (General Principles) is reworded to Policy 1 of the Publication document has Agency make it more robust: ‘Planning permission for the development of new been amended and the suggested wording (West waste management facilities will only be granted where the proposed for general principles has been Midlands development demonstrates that it accords with the principles listed below’. incorporated. Region, Could 1.2 (Make Better Use of Waste…) be elaborated upon? It is Upper assumed this policy refers to inert landfill, but the wording just says The reasoned justification fully explains Trent ‘landfill’ - this could be taken to include any landfill, and it is unclear what is meant by ‘make better use of waste Area) - whether this is what was intended. associated with non-waste related Mr. Jim The Environment Agency have read Section 1.4 (B) as relating to development’, and in respect of section 1.4 Kitchen ‘muckspreading’ which we did not believe was subject to planning (B) clarifies that planning permission will permission, but is controlled via out Environmental Permitting be required for the import of organic waste (exemptions) process. The wording of this may require refining to make for the purposes of land treatment resulting this clearer if this is not the case. in agricultural improvement. We also recommend that you consider including an additional bulletpoint along the lines of bullet 2 in Policy 1.5, to strengthen this policy. Policy 2 of the Publication document has Draft Policy 2. Table 2 in Section 2.2, sets a target of only 252,000 tpa been amended. Higher landfill diversion between 2020 and 2026 whereas it is noted that the original policy set targets have been set and given analysis Appendices a target for recycling/recovery capacity of 243,000 tpa by 2020/21 and of waste capacity at 1 April 2011, the 252,000 by tpa 2025/26 - why is this? Will any additional capacity be capacity and targets for new facilities have provided between now and 2020 and how will your Authorities ensure been amended. The reasoned justification this will be delivered if no target has been set? clearly explains that targets are not a cap. 2.4 shows a reduced list of safeguarded sites with only EfW facilities and In respect of policy 2.4, facilities required Haz Landfill site included. No safeguarded sites higher up the waste to deliver the Municipal Waste hierarchy have been identified. It is important that capacity further up the Management Strategy are to be 189
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hierarchy is maintained, and the decision not to safeguard any sites safeguarded. Policy 2.5 sets guidelines for further up the waste hierarchy must not be detrimental to maintaining local planning authorities to take into recycling / material recovery capacity. consideration when determining proposals 2.5 seeks to protect permitted / allocated waste facilities, but it does not for non-waste related development in the completely prevent the development of non-waste related uses that will vicinity of existing waste management prejudice waste management capacity. Are there any opportunities to facilities. The main objective of this policy seek mitigation from developers where the granting of planning is to protect existing waste management permission would result in a significant loss in capacity, could this be capacity/capabilities, rather than included within this policy? necessarily protecting waste management Draft Policy 3. We do not consider that point 2 of Policy 3.2(B) relating facilities on their existing sites. to bio-aerosol risk assessments is appropriate within planning policy as it is something which is controlled via our Environmental Permits, and Policy 3 has been amended in the as such should not be duplicated within the planning system. We Publication document. In respect of understand that this may have been added as a result of ambiguous exceptions criteria for open air windrow wording in our previous letter (reference to ‘applications’ in this case composting, proposals are required to meaning permitting applications rather than planning applications). satisfy that the location is capable of Permitting requirements relating to this are currently being reviewed by meeting EA permitting requirements in DEFRA and as such is subject to change prior to this plan being adopted. relation to bio-aerosols. The reasoned We will keep you informed of any changes. justification provides a link to the EA Draft Policy 4. We welcome the support for Sustainable Drainage website and the current EA position on Systems (SuDS) and the potential for water recycling in 4.1 (Sustainable regulating composting facilities. Design), however recommend that in order to ensure that both water resources and water quality are addressed this point should be subdivided Policy 4 has been amended in the into two bullet points, one effectively for clean rainwater and the other Publication document and the suggestions for contaminated run-off: made by the EA have been incorporated Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
• Provide a sustainable drainage system to manage clean uncontaminated in respect of water resources, and water roof and surface run-off, with a focus on infiltration techniques to improve quality. Reference is made also to local the quality of the water environment. policy in relation to green infrastructure. • Consideration should be given towards rainwater harvesting from The reasoned justification explains fully the impermeable surfaces and encouragement of layouts which considerations to be given to each of the accommodate wastewater recycling. factors listed in Policy 4.2. The last bullet point says: ‘Where appropriate contribute to green infrastructure initiatives’ but does not specify in what circumstances a The Publication document contains a contribution to green infrastructure initiatives would be considered section on Implementation and Monitoring. appropriate. This is welcomed, however further clarification should be The suggested C,D&E monitoring provided in order to define where and what would be appropriate.You performance indicator has been may wish to refer to green infrastructure strategies that Staffordshire incorporated. LPAs may have already undertaken, or compile your own strategy based on these principles. The Publication document has amended The Environment Agency questions the value added by section 4.2 which Policy 1.1 General Principles, and now despite its title, appears to only provide a get-out clause for overriding makes reference to waste is used as a considerations, and summarises national policy. On a smaller note, we resource, including the formation of waste Appendices recommend that Point 9 is reworded to reflect ‘Protection of air, soil and synergies, through the creation of resource water, and reduction of flood risk’ as PPS25 is not about managing water recovery parks. resources. Monitoring. Change in the number of flytipping incidents involving construction and demolition waste could be monitored to establish whether policies relating to construction and demolition waste are effective in reducing the amount of construction waste being disposed of illegally. 191
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We question whether NI E7 will continue to be used to monitor the effect Site waste management plans are a on flood risk management and water quality. requirement of all major development Other Issues. One aspect of waste planning that is perhaps not proposals (Policy 1.2), however it has also adequately catered for through the core policies is opportunities to provide been included as a sustainable design for / encourage the formation of waste synergies, for example through factor and incorporated into Policy 4.1. the creation of resource recovery parks. It is questioned whether the policies as they stand will ensure Site Waste Management Plans to be carried out, as per the original Policy 6. It appears that this is only mentioned on page 18 in support of Draft Policy 1. We draw your attention towards previous comments made in relation to SWMP compliance on page 8 of our previous letter of 01 October 2010.
Campaign Comment 1. In issue 1 we strongly suggest that climate change is only Only issues that the Waste Planning to Protect one of the major global issues affecting spatial strategies and underlying Authority can attempt to address by setting Rural both the importance of the subject of a waste strategy and its effective strategic objectives, policy and determining England - implementation. Of perhaps over-riding importance is the depletion of of planning applications are included. Mr. Phil Water/Food/Energy/Basic Materials and Resources linked to global Goode population rises and linked migration and employment issues.These are The Publication document after the all factors impinging on the subject of the Strategy and should receive introduction includes a section on Context mention if only to set the specific subject in its proper context and within and Conformity and European Directives the time frame chosen for the Strategy. and the Waste Hierarchy is explained here, in addition to Policy 1 and Appendix 4. Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
Comment 2. The leading importance of the “Waste Hierarchy” cannot The Vision is set out in section 5 of the be over-stated; it underlines the whole raison d’être of the Strategy, but Publication document and para 5.1 is not explained except as an Appendix. We suggest, if only to make the explains that it is a vision for managing our Strategy’s reasoning clear to any lay reader, that this Appendix should waste and the development of our waste be relocated as the foreword page. infrastructure for the period to 2026. Comment 3. In the preface “Vision” – the impression is given that waste networks and facilities are fully provided already! It is assumed that the The issues and strategic objectives have text refers to the anticipated outcome of the Strategy, and therefore the been slightly amended in the Publication future tense should be used for clarification. Document and no longer state the exact Comment 4. Strategic Objective 3 leaps into targets for waste volumes targets for waste management capacity. without supporting tables or graphs justifying the target figures, the These are set out in Policy 2 and Appendix trajectory from which they are derived, the assumptions for the growth 6 consists of waste data tables which or the effect the Strategy’s measures will have or the growth curve. We explain the targets. suggest that this is a fundamental omission which should appear in the Strategy document – with explanations – rather than in any supplementary The main challenges for the Strategy are reports. to increase waste management capacity Comment 5. CPRE understands the imperatives that have driven the so that we are no longer reliant on landfill. Appendices Strategy’s underlying opposition to landfill (not least because they have Minimum landfill diversion rates are set out been driven by proponents from European countries with different which are more challenging than those set priorities to the UK). We consequently support the policy in reason, not out in Regional Policy (RSS Phase 2 least because we support strongly the Waste Hierarchy. We take leave Revision). Policy 1 (1.6) sets out criteria to question however whether land-raising for justifiable purposes, and should landfill/landraise proposals be with the safeguards suggested, should not be considered in a more submitted. The policy clearly sets out however that landfill or landraise will not 193
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measured, design-led way. We question also whether there is a place be permitted and waste disposal should be in the Strategy for “mining” of earlier less-enlightened tip sites for recovery considered as the last resort. The of minerals and potentially now valuable elements? comments regarding landfill mining are Comment 6.The deficiencies of the term “sustainability” are demonstrated noted, however this has not formed a key in 2.2 of the Introduction. Waste treatment implies a continuing process consideration for the Strategy and has not into the indefinite future, a process which can only be meaningfully included. The Strategy is subject however addressed by the Waste Hierarchy process and its most rigorous to monitoring and review and landfill mining application. It appears however that Commercial and Industrial Waste, for recyclable material may be an issue for Fig. 2.1, has little prospects for reduction in volume, with 25% still future Strategies. incapable of diversion from landfill targets by 2026. It seems that in these circumstances this waste at least is unsustainable with continuing The reasoned justification for Policy 2.1 demands into the future for tipping land. Landfill diversion targets explains that with It is not clear from Fig. 2.2 and the text what tonnage of waste still remains a plan based on 2026, there is potential to to be tipped. Does the 252,000 tonnes pa capacity go to tip, or is it subject tackle the remaining 10% if MSW and 25% to recycling and material recovery; and if the latter, what is the “net” or of C&I ‘allowed to be landfilled’ at later “residual” amount to tip? stages of the plan when the full extents are Comment 7. CPRE has expressed grave reservations over the proposed known of our policies, changes in the waste Four Ashes facility regarding sustainable transport of feed stock and management industry and the effects of availability for re-use of the final waste ash, as well as CO² discharges financial, policy and legislative drivers and environmental issues. It seems that these issues are less likely to nationally and in Europe. be overlooked in any future EfM project, but the CO² discharge issue should be highlighted in Policy 1.5, Energy Recovery as a direct contradiction of global warming policies. Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
Conclusions. CPRE considers that waste treatment policies and progress Whilst landfill is a ‘last resort’, it however have been remarkably successful over a short time. It is apparent from must be recognised that some waste the Strategy however that there remains a very wide gap before the streams cannot be economically or Waste Hierarchy is developed to its full potential. It is a little surprising beneficially re-used, recycled or recovered that no mention appears to have been made of recent advances in for energy. Staffordshire also has a number technology and inventiveness in expanding recovery and reclamation of operational landfill sites and there is also and the part that waste authorities might play in encouraging and potential additional capacity available at facilitating this vital contribution. planning obligated sites, i.e. mineral sites with planning permission to restore by landfilling. Landfill sites in Staffordshire will therefore continue to play a role, at least in the short term, in managing waste from the plan area and from adjoining authorities.
Comments are noted regarding Four Ashes facility and Energy Recovery. Appendices The introduction of the Publication document acknowledges that the Strategy is flexible to accommodate the changes in the waste that is produced and the ways in which that waste can be managed. A key issue for the Strategy is to raise the standard of our waste infrastructure. 195
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Cannock General - The Joint Waste Core Strategy, August 2010, consultation The introduction to the Publication Chase contained the important statement in 2.8, “Given the modest capacity document explains that the Strategy is Council - gap (in terms of having sufficient waste management facilities and based on broad locations and does not Mr. John capacity by 2025/26 to manage an equivalent tonnage of waste to that identify specific sites. Morgan produced within Staffordshire and Stoke-on-Trent and given evidence that concludes there is no requirement to identify sites for major strategic waste facilities, it is proposed not to identify specific sites but rather to base the Strategy on the identification of broad locations.” . The draft Publication Plan does not contain this important statement and it is considered that this statement should be reinstated.
Cannock Issue 3 contains the comment that Staffordshire “must be net Comments are noted, however the Chase self-sufficient in waste management, treating an amount equivalent to Kingswood EfW application is outside the Council - that generated within our areas”. The Council supports this statement Core Strategy process. Mr. John on the basis as it is not considered there is a need for a sub-regional Morgan facility to deal with waste from the conurbation and therefore no The Publication document has amended justification for the Kingswood EfW incinerator proposal. issues, strategic objectives, vision and Issue 5/Strategic Objective 5 states there is a need to provide “sufficient policies. The criteria provided by Policies opportunities to develop new waste management infrastructure of the 1 – 4 clearly set out the locations suitable right type, in the right place and at the right time.” It is considered that for different types of waste management this statement is too open ended statement not capable of meaningful facility. interpretation. Vision - contains the objective “To minimize the impacts of transporting Targets for new waste management waste, we have encouraged the development of a network of waste capacity are however minimum targets and management facilities which are located close to the main urban areas should not be regarded as a cap. Due to Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
wherever possible, so they are closest to where most of the waste is the vacuum left by the absence of regional produced.” This comment is supported on the basis that the Council and national policy and criteria for large does not consider there is any justification for the Kingswood Lakeside scale facilities that serve waste arising from EfW proposal which would operate as a sub-regional facility. However, more than one Waste Planning Authority, there is a need for a policy which says that provision of waste criteria is included in Policy 2.3 c, in how management facilities designed to serve a wider need outside to assess proposals for facilities of a Staffordshire will not be supported regional and national scale. In section 4 of the Strategy, a section is included on cross border movement of waste which recognises that Staffordshire and Stoke-on-Trent receives large imports of waste from neighbouring authorities for management, and will continue to do so as limiting imports is unenforceable. Appendices 197
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Cannock Draft Policy 1 contains an assumption in favour of new waste The comments are noted however the Chase management facilities where these meet the four principles of waste Kingswood EfW application is outside the Council - minimisation, waste as a resource, the waste hierarchy and protection Core Strategy process. Mr. John of human health and environment. Morgan The Council considers that this Policy is too open-ended and not capable The Strategy is considered flexible able to of meaningful interpretation, particularly if it was used to justify new address proposals for all different types of facilities such as the Kingswood Lakeside EfW proposal. waste management facility, including Policy 2.3 contains the statement:- “In order to minimise the impact of Energy Recovery. Both national and new and enhanced waste management facilities, preference will be given regional policy (RSS Phase 2 review) to general industrial land (including urban and rural general industrial support industrial land as suitable locations (B2 & B8) estates), previously developed land and existing waste for waste management facilities and as set management sites within or close to the hierarchy of urban areas defined out in the Context and Conformity section below..” The Council would reiterate its agreed position that it has of the Publication document, account has expressed its strong opposition to a proposal by Biffa to locate an EfW been taken on the Planning for Growth Incinerator together with the complementary Material Recovery facility Ministerial Statement (April 2011). within the KingswoodLakesideEmploymentPark.The location of this type of facility in a prestigious, high-tec, employment park the success of which will be of vital importance to the future economy of the District, is not considered appropriate. The Council therefore objects to this Policy as currently worded as it is capable of being interpreted in such a way to justify the Kingswood Lakeside EfW proposal by giving preference to general industrial land (including urban and rural general industrial (B2& B8) estates) in order to minimize the impact of new and enhanced waste management facilities. Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
Draft Policy 3.1 – The criteria for new or expanded waste management facilities should “ be compatible with nearby uses, and appropriate in scale and character to their surroundings..” The Council support this wording. It is considered that the proposed Kigswood Lakeside EfW would not satisfy these criteria particularly in an existing high quality employment park
English Key Issues. The simplified set of key issues retain a good emphasis on Comments have been noted. Heritage securing high quality design (issue 4) and protecting and enhancing the (West environment (issue 5), including the historic environment. Midlands Vision. We welcome the specific reference to the historic environment Region) included in the vision statement. -Ms. Strategic Objectives. Objectives four and five flow from the identified key Amanda issues, and with regard to the latter we welcome the clear references to Smith the historic environment in support of the wider objective of protecting and enhancing the environment. As per the emerging framework, our
principal concern is how this is taken forward through the policy Appendices framework and the clarity and consistency of referencing to the historic environment and heritage assets in accordance with PPS5 Planning for the Historic Environment.
English The draft policies have been reduced considerably from the emerging Policy 4 of the Publication document has Heritage policy framework.Whilst we acknowledge the emphasis on not repeating been amended and in particular the (West national guidance, we continue to recommend appropriate policy reasoned justification for consideration of references to the historic environment and heritage assets in line with proposals on the historic environment has 199
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Midlands current guidance set out in PPS5. In the consideration of 'designated incorporated the suggestions from English Region) sites' care should be taken that the reasoned justification and indeed Heritage. In respect of monitoring, the -Ms. policy, interprets this appropriately to take account of all designated sites performance indicator for Policy 4 has been Amanda - this including the historic environment and heritage assets. amended to state designated sites Smith including heritage assets. Draft Policy 4: For improved clarity and consistency we recommend that the first point under Policy 4.1 includes an explicit reference to the historic environment, so '... for building design, landscape, ecology and the historic environment'. The last point in this policy section could also usefully be expanded to refer to include other environmental enhancement initiatives in order to cover circumstances which may not be fully covered by green infrastructure. For Policy 4.2 we strongly recommend that the second point is amended as follows in order to more fully reflect PPS5 - 'Natural and historic environment, including heritage assets and their settings. The reference to PPS5 Planning for the Historic Environment should also be corrected. Under the proposals for monitoring, the identified indicators predominantly rely on the national set of indicators for which there is no indicator for the historic environment. Can a locally specific indicator for potential impacts on heritage assets be developed? We suggest that it would be appropriate for the reasoned justification to explain that the policy provisions (4.1 and 4.2) cover both designated and non designated environmental assets - both important in the context of the character and quality of the local natural, built and historic Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
environment.The broad definition of the historic environment and heritage assets as set out in PPS5 reinforces the importance of considering both designated and non designated assets.
Cemex UK CEMEX is broadly supportive of the approach being taken, particularly The Publication document Policy 3.3 Operations draft policy 1.3, however the following observations are made: outlines the exceptions criteria for recycling Ltd - Mr. • Although draft policy 1.3 recognises that quarries are an appropriate of C,D&E waste on existing landfill or Shaun location for recycling of C & D waste and landfilling to effect restoration, mineral sites. The reasoned justification Denny this isn't referred to by draft policy 2.3. I suggest that draft policy 2.3c) under Policy 2.3 in relation to broad be revised to acknowledge the statement made by draft policy 1.3, and; locations also makes reference to Policy • on balance it is felt that draft policy 3.1 may be setting the bar too high 3.3.The reasoned justification under policy in terms of requirements for C & D recycling facilities. It is acknowledged 3.3. also incorporates clarification that open that a fully enclosed operation can mitigate environmental impacts that air proposals will be given favourable can stem from such operations, but the costs of providing such a structure consideration and the applicants argument could render financially marginal proposed unviable. Fully enclosed regarding full enclosure and health and operations also generate health and safety concerns for operators and safety concerns has been incorporated.
employees in terms of noise, vehicle manoeuvring and dust. It is Appendices suggested that in the case of C & D recycling, where odour is not an issue, if an operator can demonstrate that relevant environmental concerns can be satisfactorily addressed by means other than full enclosure, then planning permission should not be withheld for this reason alone. 201
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Peel Peel Environmental Ltd welcomes the more streamlined approach to the Comments have been noted. Environmental Core Strategy and the refined vision which is more succinct and provides Ltd - Ms a clearer outlook for the areas waste management infrastructure. Rachael Peel Environmental Ltd welcomes the recognition within the Core Strategy Thorne of Energy Recovery. This is specifically mentioned in the Vision which seeks to reduce reliance on landfill by various means include recovery of energy from residual waste. Peel Environmental Ltd also welcomes reference to energy recovery in Strategic Objective 2, which aims to make more use of waste as a resource.This includes recognising the potential of waste to deliver local sustainable energy as a contribution to low carbon and sustainable energy policy objectives where recycling is not viable.
Peel Draft Policy 1: Waste as a resource. Although the plan does not provide The Publication document has been Environmental targets for additional energy from waste facilities, it is important that this amended and the reasoned justification for Ltd - Ms form of waste management is recognised and provided for within the the targets (Policy 2.2) explains that targets Rachael plan. This will ensure that the core strategy is sufficiently flexible to deal should not be regarded as a cap. Policy Thorne with energy from waste facilities for residual waste should the need for 1.5 provides the criteria that ERF proposals such facilities be demonstrated. As such Peel Environmental Ltd should address and Policy 2.3 c set out the welcomes section 1.5 Energy Recovery of Draft Policy 1. This sets out siting /locational criteria for proposals of a the requirements for energy recovery proposals should they come regional and national scale. Policy 4.1 forward. Peel Environmental Ltd considers that the requirements of the requires proposals to seek where policy for energy recovery proposals are largely appropriate. However, practicable and beneficial to use modes it is important that point 3 which requires facilities to be in close proximity other than road transport. to the source of waste is not in conflict with point 5 which requires the Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
proposal to meet the locational approach of the strategy, especially with regard to facilities of a regional and national scale. It may also be appropriate to suggest that proposals for energy recovery should either be in close proximity to the source of waste or utilise sustainable transport options to minimise transport emissions. Draft Policy 2: Targets and broad locations for waste management facilities Peel Environmental Ltd continues to support the locational strategy set out within the Core Strategy which requires new and enhanced waste management facilities to be conveniently located so as to minimise transport impacts. This includes locating local or sub-regional facilities in or close to the North Staffordshire Conurbation, and the Large Settlements and regional or national facilities to be located so as to minimise transport impacts and demonstrate a sequential approach. Peel Environmental Ltd considers that the availability and utilisation of sustainable transport opportunities can minimise transport impacts and should be considered favourable where appropriate. Appendices Lichfield Lichfield District Council (LDC) agrees that the simplification of the draft Comments have been noted. District policies has reduced overlap and provides greater clarity overall. Council - LDC continues to support the underlying principles of the strategy and Elizabeth the outcomes sought by the vision. LDC considers that the revised vision Boden is more focussed with regard to treating waste as a resource. The vision 203
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is also more strategic and now non site-specific; these site specific issues being more appropriately encompassed within policies revised Draft Policy 2: Targets and Locations for Waste Management Facilities.
Lichfield Revised Draft Policy 1. LDC welcomes this as the first policy within the Comments made in relation to Policies 1,3 District Joint Waste Core Strategy, as treating waste as a resource and reducing and 4 are noted. In answer to the comment Council - the overall contribution from waste management to climate change has regarding Policy 2, targets for additional Elizabeth to be the fundamental aim of any Waste Core Strategy. municipal capacity are based on the Boden Revised Draft Policy 2. As raised in LDC’s previous comments it is noted approved Joint Municipal Waste that no requirement has been identified for new or replacement Household Management Strategy MWMS (2007).The Waste Recycling Centres (HWRCs). LDC reiterates the comment that MWMS has informed the Joint Waste Core the vision seeks increased waste re-use and recycling and thus has Strategy and is to be reviewed in 2012. concerns that this will generate a need for further HWRCs during the Table 28 in Appendix 6: Waste Data plan period. Tables, of the Publication document set LDC would also like to reiterate that the Government’s Review of Waste out the current (2011) strategic priorities Policies Consultation indicates a move towards more localised facilities. reflected in recent action plans supporting It therefore may be that more HWRCs are needed close to local the MWMS on which the Waste Disposal communities. Further evidence to justify the zero requirement for HWRCs Authority and Waste Collection Authorities is therefore still regarded as necessary. are now focused. This highlights that With regard to the broad locations identified in the policy the Council is municipal waste infrastructure needs to be satisfied with the approach of dealing with waste close to where it arises. improved and that the waste management As before however, the Council is concerned that there has not been needs of small businessed are not being adequate consideration of changes that may be needed to the pattern fully catered for. The reasoned justification of bulking facilities for waste transportation across the District and the for Policy 2 makes reference to these County. Whilst there are many commercial bulking sites there are priorities. It is however considered that Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
currently no domestic sites and only one is in the planning stages for this these priorities represent non-strategic district for operation in 2012/13. Currently there are no arrangements in facilities that could be accommodated place for domestic waste to be bulked on commercial sites.This situation through the normal planning application is against a background where all of the domestic waste and recycling process and do not require a specific (in excess of 40,000 tonnes) collected travels out of the district. These strategic site allocation in the Strategy. journeys could be significantly reduced if waste were to be bulked up Proposals can be considered against the closer to the point of collection. The benefits to the environment in terms criteria set out in Policies 1 – 4. The of reduced traffic movements, reduced carbon and emissions and cash Strategy is subject to five yearly reviews efficiency savings have not been assessed and needs to be addressed and consideration will be given to through the Waste Core Strategy. synchronising the refresh of the Joint Revised Draft Policy 3.LDC welcomes the changes to this draft policy, MWMS in tandem with the Joint Waste considering that the revised draft policy is less restrictive than previously Core Strategy in order to bring forward worded and would now encompass unenclosed HWRCs. development. Revised Draft Policy 4.Although LDC still considers that design guidance and advice on waste management technologies may be better incorporated within an SPD on waste, which would give greater flexibility in accommodating any changes that may arise within the plan period, Appendices this revised policy encompasses a wider range of factors than the previous draft policy JWCS policy 9 (not just design) in seeking to achieve better environmental quality from waste management facilities.
Staffordshire Issue 2 (p7) . Does this need to reference also the demolition of buildings, Issues, strategic objectives and vision have Moorlands for material recycling? Issue 3 (p7). It is presumed that reference to been amended in the Publication District requirements in the bullet points means requirements additional to document. Note that five issues and five existing? The last sentence “We must also give favourable consideration strategic objectives have been revised and 205
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Council – to meet future provision for local economic growth” is a little confusing merged into four issues and four strategic Mr David – does this mean the array of facilities in future must meet future objectives. A lot of the comments and Davies demographics, or does it imply that future growth relies on new facilities? suggested wording have been taken on Issue 4 (p8). Does “modern standards” also include legislation? If so board and incorporated where appropriate. should it be amended to “..keep pace with the requirements of recent The reasoned justification for the four legislation/modern standards..”? Issue 5 (p8) Would suggest slight policies also clearly explains that: high re-wording in places (refer to response in Objective consultation portal). quality design relates to all proposals, for new facilities and proposals at existing Vision. Para 2.2 (p9).Please re-word “our planning should contribute” to facilities; and additional capacity is required something like “There is a legal requirement for Development Plan between now and 2026 in addition to Documents of the Waste Planning Authority to contribute to…”The Vision existing capacity i.e. existing facilities, (p10) should be written in future tense. Suggested wording is provided needs to be protected. Policy 2 sets out (refer to Objective consultation portal). the targets for new facilities and capacity i.e. additional recycling capacity of 115,000 Strategic Objectives (p11+). Suggested wording is provided (Refer to tonnes per annum is required by 2026.This Objective consultation portal). In relation to SO3 (p12) The bullet points could equate just to one facility with a should be clear about whether these requirements are additional, ie are capacity of 115,000 tonnes being built in new recycling facilities equating to 252,000 tpa required alone, or is there for example year 2015, which would existing provision which already eats into this? Also the first bullet is address the capacity gap for the plan worded to suggest these requirements only kick in in 2020, is this correct, period as once operational, that facility or is there a gradual increase in requirement every year? SO4 (p13) would be able to manage 115,000 tonnes Does reference to high quality design just mean in relation to existing per annum. To clarify, the new waste waste management facilities? Or does it also cover extensions/new capacity requirements specified by Policy facilities? SO5 (p14) should there be reference to “social cohesion” in 2 do not require a facility to be built each part (b)? year. Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
Staffordshire Draft Policy 1.2 (p22) Third bullet “ie resource-efficiency in terms of Policies have been amended in the Moorlands sourcing of materials, construction methods, and demolition ie over the Publication document The majority of the District whole “life” of the development”” suggestions have been incorporated, and Council – Draft Policy 1.4 (p24) Part (A) third bullet is unclear – does “undermine further clarification has been added to the Mr David the provision” mean it would endanger the viability of recycling facilities reasoned justifications for the policies. In Davies further up the hierarchy, or does it just mean, the proposal would result particular ‘undermining the provision’ does in less material being recycled, therefore contrary to waste hierarchy? mean that only waste that cannot Part (B) – further to my earlier comments, should the last bullet refer to practically be reused, recycled or mitigation, not just avoidance? Are there exceptional circumstances processed to recover materials can be where amenity harm to residents can be allowed, with mitigation? accepted by the facility proposed so as not Draft Policy1.5 (p25) Third bullet refers to “close proximity”, but this is a to endanger the viability of recycling subjective term – should it state, “in the opinion of the Authority is located facilities and the use of the waste material in close enough proximity in order to obtain…emissions”?. Fourth bullet as a resource further up the waste “includes maximum energy recovery, either by employing combined heat hierarchy. and power (CHP) processes, or through electricity generation; and the CHP is ready..” [I would also question whether this policy should also With regard to Policy 2.4, the text ‘and refer to “combined cycle” electricity generation processes?] proposed’ related to the Four Ashes ERF. Appendices Draft Policy 2.2 table 2(p36). Reference to “0/9 hectares” instead of “0.9 As this is now under construction, this hectares” under waste transfer bulking. Under recycling/material recovery wording has been deleted. there is reference to “large areas of development” – should this say “large built up areas”? Last para states that new waste management facilities In respect of the comments made in that secure economic growth will be given favourable consideration. But relation to constraints i.e. green belt, presumably this subject to caveats in the other policies? This should be countryside, amenity etc, Policy 4 is the referenced, ie “..will usually be given favourable consideration, where it is consistent with other Policies in this JWCS”. 207
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Draft Policy 2.3 (p38). Reference to “local and sub-regional scale” on the general protection policy and to avoid one hand, and “to meet local needs only” need to be clearly defined in duplication, the other three policies cross the text of the JWCS if it hasn’t already. Part(c) again refers to “areas of reference to the design and environmental large development” – should it use the term ”urban areas”? considerations within Policy 4. Draft Policy 2.4(p39). The text refers to “and proposed” facilities. Does this Policy cover only existing facilities? In respect of the comment in relation to Policy 4 and the suggested low Draft Policy 2.5 (p40) Use of “we” should instead say “the Authority” Part carbon/renewable energy target, it is not (b) since the WPA are mostly not the determining authority, shouldn’t the fact that most waste management Policy be phrased eg “..this Authority will not support proposals for non facilities will be large in scale. It was not waste development..which unduly restrict..etc” . Part (c) since the WPA considered appropriate to set a target. are not the determining authority for non-waste developments on waste allocations, they do not have authority to require the supporting information in the policy. Draft Policy 3.1(p 48) The 2nd bullet should reference the fact that sites for new buildings may lie in open countryside/greenbelt, or may lie within other constraints eg conservation areas Draft Policy P3.2 (p49) Could part (c) also refer to potential benefits to visual appearance of existing buildings, as a result of re-use (see PPS4), ie “the external character and appearance of the building is either unchanged, or improved” Draft Policy 3.3 (p50) Does this policy need to reference sustainability, ie a landfill site may be too remote in transport terms even if it meets the other criteria? Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
Draft Policy 4.1 (P56) Agree broadly with the carbon saving criteria in this policy eg BREEAM standards and contribution to renewable energy etc. However, given that most waste management facilities will be large in scale, and because the then emerging-RSS (2007) issues certain requirements under Pol SR3 etc for carbon saving etc for major developments, shouldn’t there be a target for new facilities contributing to low carbon/renewable energy? This could always be caveated by saying that “this target is mandatory unless it can be demonstrated that applying this target would make the construction of the facility unviable”. Draft Policy 4.2 (p57) Perhaps this could also reference PPS4.
Tamworth I can confirm we have no further comments to add to our response on The comments in the response of 27th Borough the 27th September 2010 (attached). I would request that you give September 2010 in relation to the Emerging Council – consideration to the monitoring and implementation of policy 1.2 in light Joint Waste Core Strategy are noted. Mr of our previous comments and the role that the County Council will play PPS10 para 34 however clearly Matthew in doing so. encourages that proposed new
Bowers development should be supported by site Appendices waste management plans to identify the volume and type of material to be demolished and/or excavated, opportunities for the reuse and recovery of materials and to demonstrate how off-site disposal of waste will be minimised and managed. It 209
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is clear that the WPA will need to work closely with LPAs and establish how SWMPs are monitored.
West Draft Policy 1.2 Requirement for SWMPs . Unfortunately, LPAs cannot The reasoned justification for Policy 1.2 in Midlands insist on this level of detail for outline applications so it is advisable to the Publication document has been Metropolitan be less prescriptive. We suggest the policy requires a general waste amended to require a waste management Authorities’ management statement or waste audit, explaining how waste arising statement or waste audit for outline Chief from the development will be managed. This could include information planning applications submitted to LPA’s. Engineers about how waste will be managed within the development once it is in & Planning use, which the SWMP will not tell you about. The RJ could provide The reasoned justification for Policy 1.6 Officers examples of supporting information to include (e.g. an interim SWMP explains that Staffordshire has been Group - Mr might be part of this, information can also be provided on the application providing landfill capacity to neighbouring Andy form, on the plans or in the design and access statement), and can authorities, and this is likely to continue in Donnelly recommend what templates or guidance applicants could use. the future due to the number of mineral 1.6 Restrictions on landfill. The draft policy is consistent with national extraction sites where there is an obligation policy guidance and WFD. However, the RJ could usefully explain that, to restore by landfilling. whilst landfill is a “last resort,” some waste streams cannot be economically or beneficially re-used, recycled or recovered for energy (e.g. asbestos, bulky wastes). It is also not clear whether cross-boundary requirements/ movements of residual waste will be taken into account in considering the “need” for new capacity, or just the needs of Staffordshire and Stoke-on-Trent. Some WPAs in the West Midlands Metropolitan area (e.g. Birmingham, Wolverhampton) do not have “open gate” landfill sites or any potential to provide such sites. Their need for Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
residual waste disposal capacity will have to be met from neighbouring areas which do have such facilities, including Staffordshire.The RJ should therefore also explain that sub-regional needs will be taken into account in assessing proposals for landfill.
West Draft Policy 2.1 Landfill diversion targets. The targets are ambitious but The Publication document has a section Midlands consistent with RSS Phase 2 Revision and with current national waste on cross border movement of waste within Metropolitan strategy landfill diversion targets, which are based on those set by the the Spatial Portrait. Whilst the Strategy is Authorities’ Landfill Directive. based on achieving net self sufficiency, Chief The WFD also includes recycling targets for municipal and C&D waste evidence demonstrates that the plan area Engineers – has excess organic capacity, and residual & Planning should these be referred to in the policy (as WPAs are probably going treatment capacity and landfill capacity Officers to be which will allow for cross border waste Group - Mr made responsible for meeting these as well)? management, however recycling capacity Andy is required. Donnelly 2.2 Waste management targets. The principle of “net self-sufficiency” is supported, though municipal waste management arrangements can be The revised Waste Framework Directive
more complicated than that (and are often subject to change as short-term requires Member States to recycle 50% of Appendices contracts are re-negotiated). We assume that cross-boundary waste from households by 2020 and to arrangements for managing municipal waste have been factored into recover 70% of construction and demolition the targets. (Refer to response in Objective consultation portal for list of waste by 2020. The Joint Municipal Waste Staffordshire facilities used by WM metropolitan authorities). Management Strategy targets are to recycle 50% of MSW.The monitoring target 211
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for Policy 1 has been amended to include the WFD targets for construction and demolition waste.
West Draft Policy 3.3 Exceptions for CD&E waste facilities. We welcome this The reasoned justification for Policy 4 of Midlands policy which is aimed at preventing recycling operations at mineral the Publication document sets out Metropolitan working sites from becoming a permanent fixture. This is supported, as considerations to be made against each of Authorities’ it will ensure that former mineral working sites are restored in a timely the headings listed in Policy 4.2. Links are Chief manner, and that the effects of related treatment operations on the also included to the maps on designated Engineers highway network and neighbouring communities are minimised. sites found in the accompanying Habitats & Planning Draft Policy 4. We have no objections to this policy in principle, although Regulations Assessment report. Officers we note that it doesn’t seem to be as well developed as the others. Part Group - Mr 4.2 is largely a list of national policy guidance, which is likely to be The comments regarding the CLG Andy replaced by the proposed National Planning Policy Framework. To consultation are noted, and acknowledged Donnelly prevent the Core Strategy from being overtaken by events, it would be in the Context and Conformity section of advisable to identify the environmental and amenity issues of particular the Publication document. importance to Staffordshire and Stoke-on-Trent, such as particularly sensitive areas and areas where supporting information will be required to demonstrate that impacts are acceptable/ can be successfully mitigated. A constraint map could also be included, showing the main constraints/ areas to be avoided. Implications of Current CLG Consultation – Relaxation of Planning Rules for Change of Use from Commercial to Residential. If this proposal is implemented, it could undermine employment land allocations and Consultee Summarised Comment (refer to Objective consultation portal for full version of comment) Our Response
safeguarding policies in LDFs, and could impact on the effectiveness of Draft Policy 2. There will be nothing to stop existing employment land and employment land allocations from being developed with housing, and existing waste management facilities could also be affected by housing encroachment. Appendices 213
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Appendix 7: Press Releases
6 Issues and Options, March 2007
Consultation Statement (Regulation 30 document) Media Release 29 March 2007
Press Article
6.2 Life Magazine, Issue 20 April/May 2007 and Staffordshire Newsletter, April 5, Appendices 215
2007
6 Consultation Statement (Regulation 30 document) 216 Appendices
6 Consultation Statement (Regulation 30 document) Appendices 217
Issues and Options Part 2, September 2008
Media Releases 6 Consultation Statement (Regulation 30 document) 218 Appendices
6 Consultation Statement (Regulation 30 document) Appendices 219
Appendix 8: Consultation Letters
Issues and Options, March 2007 6 Consultation Statement (Regulation 30 document) 220 Appendices
Issues and Options Part 2, September 2008
6 Consultation Statement (Regulation 30 document) Appendices 221
Emerging Joint Waste Core Strategy, August 2010
6 Consultation Statement (Regulation 30 document) 222 Appendices
6 Consultation Statement (Regulation 30 document) Appendices 223
Revised Draft Policies, April 2011
6 Consultation Statement (Regulation 30 document)