Comment

Representation ID: 22505

Received: 11/10/2021

Respondent: Environment Agency

Policy CSP1 - Development Strategy.

We recommend reference to both safeguarding key infrastructure and ‘Agents of Change’ here, potentially in point 1c). Policy CSP5 does reference Agents of Change regarding Cultural and Performance venues, however the NPPF wording is not restricted in what Agents of Change should apply to. We are aware of general concerns from the waste sector of residential developments being allowed adjacent to active waste facilities, against objections, with consequent blighted properties and complaints from residents. In some cases effective mitigation would be impractical and
prohibitively expensive and maintaining suitable undeveloped buffer zones is the only realistic solution.

It would also be positive and support decarbonisation to specify that developments are should be Zero waste/carbon and as low-energy as possible. Commitment to driving waste minimisation would also be helpful, for example ensuring that developments provide better provision for waste stream segregation and sorting at source, to allow for increased waste recycling and reuse.