Comment

Representation ID: 22511

Received: 11/10/2021

Respondent: Environment Agency

Policy W2 – Waste Sites

Paragraph 3 is welcomed, although it would be useful to indicate what the word ‘near’ means, -preferably setting a safety margin on top of a minimum buffer zone where required, and requiring appropriate measures under ‘Agents of Change’, including the ongoing maintenance of any requirements. Amenity impacts from waste facilities, including noise, odours and dust can travel some distance in adverse conditions, and climate change should also be anticipated.

Paragraph 11.33 refers to a list of sites in ‘Chapter 13’, there appears to be no Chapter
13 in the contents, is this an error?
Paragraph 11.38 The Environment Agency also works to tackle illegal sites and organised waste crime, and will work with Councils and other partners to disrupt such activities.

Paragraph 11.39 also refers to ‘within a short distance’, and as with the term ‘near’ it is not really clear what this means. Some guidance on these qualifiers would be helpful, and again an additional safety margin, so that developments are not built immediately up to the ‘nuisance boundary’, and allowing potential space for screening to be added, would be useful. These issues do appear to be explored in Paragraph 11.40.

Paragraph 11.53 says that ‘Many waste operations are similar to industrial processes’.
Whilst this can be valid, we have seen a shift over generations away from traditional
‘heavy’ industrial processes (e.g. Mineral extraction and processing, Coal combustion, coke, steel and other smelting and plating, chemicals production, ceramics, wood treatment, textiles, munitions production, animal product processing, other manufacturing, etc.) and more modern regulatory regimes have successfully reduced the impacts of those that remain. However certain waste processes (Landfill, anaerobic digestion, etc.) can still create significant amenity impacts that can be challenging to control, despite best efforts. Public acceptance of what is acceptable has probably also evolved over time, with broad expectation of a ‘right to amenity’ the enjoyment of clean air, open space and access to recreation and wellbeing opportunities. This is important in attracting a skilled workforce into the area to boost the economy.