Comment

Representation ID: 22512

Received: 11/10/2021

Respondent: Environment Agency

Policy W4 - Locational Considerations for New Waste Facilities

Paragraphs 3 and 4 both include the words ‘Should include’ - why is this qualifier necessary, and in what circumstances would such information not be required? In particular the design, operational and Nominal throughput capacity of a waste facility
can be a cause of some discussion, regarding capacity planning, so this information can be valuable. In particular, waste facilities often show distinct seasonality, especially relating to the increase in construction waste production and use of HWRCs over the warmer months.

Paragraph 11.70 also introduces the qualifier of ‘where Feasible’. Inevitably there may be practical restrictions in some circumstances, however an effective (solid, passive,) enclosure significantly reduces amenity impacts at many waste facilities. Please review this and all similar qualifier terms that may occur in the Plan to ensure they are not excluded as being simply ‘too expensive,’ by applicants, or will only be retrofitted ‘if complaints are received’. A high ‘right first time’ standard of environmental protection should be designed in, and retrofitting can often be more expensive and problematic. The insertion of such qualifiers in not uncommon in Plans, may represent genuine efforts to produce a ‘reasonable’ worded plan, but can also undermine the overall robustness and ambition if not carefully used and kept to a minimum where they are only absolutely necessary. Otherwise Paragraphs 11.83 to 11.90 are welcome.

In Monitoring, rather than a simple tracking of changes in Waste Capacity, it would be positive to develop metrics that can reflect the more detailed movement of waste up the Waste Hierarchy, away from Landfill and Incineration and towards a Circular Economy.