Comment

Representation ID: 22507

Received: 11/10/2021

Respondent: Environment Agency

Policy CSP4 - Achieving well-designed places

Paragraph 2 starts with the qualifier ‘Where Possible..’, which immediately leaves scope for any proposals to claim the requirements are ‘Not possible here’. We recommend that this is deleted or a more challenging approach is included in Paragraph 2, such as through some defined criteria for ‘Not Possible’, such as emergency works, or evidence required to demonstrate when not viable. By comparison, the wording in Paragraph 3 is more absolute. This Paragraph also overlooks the economic opportunity from maximising the use of recovered and recycled materials in construction, especially where locally-sourced, as a Circular Economy needs a ‘pull’ for resources to stimulate the recovery of waste. Sustainable modern technologies should seek to minimise the demand for ‘new’ raw materials as far as possible. In particular would be approaches to increase the recovery and recycling of plasterboard from the ‘skip waste’ stream, as this material can be problematic when landfilled, and plaster is heavily used in construction. Conversion of commercial properties into homes, or the formation of Houses of Multiple Occupation or student accommodation mean that the ‘refurbishment waste stream’ can be a significant factor, as rental properties tend to require more frequent maintenance than owner-occupied premises.

Paragraph 5 refers to encouraging civil and responsible behaviours, this can include reducing practices such as littering, flytipping, open burning of waste, and illegal dumping, processing or ‘warehousing’ of large volumes of waste. It would be very welcome to discuss interventions in this area, including how to tackle locations that seem derelict or ‘uncared for,’ and can attract a range of anti-social activities and crime. A plan to manage and if possible eliminate these locations could be considered, especially to avoid simply ‘moving the problem around’.