05 Appendix 3 WDF Table 3 – agree with representation
Policy/section / Comment / Organisation / Date Received / HCC Response /
General / Consistent reference required to figures in E of E plan for clarity.
References to Integrated Regional Strategy containing the Regional Waste Management Strategy which is incorrect. / EERA
Deborah Sacks / 14-12-2009
Email / Check document to ensure consistent referencing of all documentation – particularly those used in the evidence base.
General / Forecasting of waste figures should be for whole plan period therefore to 2026 including predicted growth rate in tables 3 and 4.
Document lacks clarity of existing waste management capacity in the county and level of capacity the sites will provide in plan period, when required and strategy to ensure this is met. / Lafarge Aggregates
Heaton Planning Consultants / 18-12-2009
Emailed letter / Agree –
All tables and figures to be re-drawn to clarify the position of waste capacity for all types of waste. Also consider splitting policy 2 into separate waste policies for different waste types.
General / Documents should cover waste water/sewage sludge to accommodate population growth – biological treatment, thermal treatment and chemical treatment.
Concern regarding lack of sewage treatment works in documents. / Thames Water
Carmelle Bell / 18-12-2009
Emailed rep form / Consider re-wording safeguarding policy and identifying strategic STWs on the key diagram.
General / Consistency and clarify required for terms: strategic sites, preferred site allocations, proposed preferred waste areas and areas of search. / Veolia Environmental services Ltd
Nick Hollands / 17-12-2009
Emailed rep form / Ensure consistency in the use of such terms.
General / Link with MSW Spatial Strategy not clear – need to explain use in site selection for composting and MSW treatment and transfer.
Little information on numbers and type of facilities required. / Welwyn Hatfield Borough Council
Sue Tiley / 18-12-2009
Emailed rep form / Make more explicit the link with the JMWMS.
Expand the supporting text to further explain the number and type of facilities required – this may be overcome if policy 2 is separated out and the waste capacity requirements are set out in a table as per a number of other reps.
Deliverability / No timescale for delivery and unclear delivery mechanisms. / North Herts District Council
David Hill / 18-12-2009
Letter / Flexibility built in to plan in terms of number and size of sites. To be clarified.
Replacing saved policies / Regulatory requirement to identify which extant saved local plan policies will be replaced/superseded – perhaps include as appendix. / Go East
Paul Fellows / 22-12-2009
Letter / Agree - add as appendix
Have your say / Need to promote waste minimisation further – no chapters dealing with minimisation and re-use.
Reactionary policy – seeks only to deal with waste without attempting to manage it.
Need to address all waste streams.
Lack of good data on what waste is produced and where. Small changes can result in large improvements.
Data collection should continue to monitor the effectiveness of the changes. / Mrs Tabitha Evans / 16-12-2009
Via Limehouse
Wsa37 / Consider adding more into the text regarding waste minimisation and where the responsibilities lie for ensuring waste minimisation. Additional information to be included re data and targets
Para 1.19 / Questions whether proposed site locations are practical. / Roger Tester / 9-12-09
Limehouse
Wsa13 / Make the reasons for employment land suitability more explicit in the supporting text. PPS10 and case law on change of use within B2.
Chapter 2 / Greater clarity of objectives – but reference needed to waste hierarchy.
Suggested rewording of objective 1: ‘To promote the provision of well designed and efficient facilities, that drive waste up the waste hierarchy and require less waste to be disposed in landfill, avoiding harm to the environment and human health.’ / Welwyn Hatfield Borough Council
Sue Tiley / 18-12-2009
Emailed rep form / Agree – consider rewording of objective.
Para 2.2 / Add ‘wherever practical’ after ‘sustainable transport links’. / Veolia Environmental services Ltd
Nick Hollands / 17-12-2009
Emailed rep form / Agreed
Para 2.3 / For consistency should be referred to as ‘strategic objectives’. / Vail Williams LLP (on behalf of Waterhall) / 21-12-2009
Emailed rep form / Agree – change to ‘strategic objectives’
Objective 1 / Recommend rewording objective 1: ‘To promote the provision of well designed and efficient facilities, that are located to ensure no harm to the environment and human health, which reduce waste volumes to be disposed in landfill.’ / Environment Agency
Kai Mitchell / 21-12-2009
Letter / Agree
Objective 5 / Disagree with objective 5 – should read: ‘To minimise waste, but, where waste cannot be avoided, to seek to meet the twin objectives of maximising the recovery value from waste while minimising the costs of disposal.’ / Giles Woodruff / 18-12-2009
Email / Agree in part – include ref to waste minimisation – costs of disposal are not spatial
Objective 5 / Disagree with objective 5 – suggest rewording: ‘To minimise waste, but, where waste cannot be avoided, to seek to meet the twin objectives of maximising the recovery value from waste while minimising the costs of disposal.’ / Rob Millist / 18-12-2009
Email / See above
Para 2.5 / Clarification required that constraints are environmental and from national policies and not Environment Agency constraints. / Environment Agency
Kai Mitchell / 21-12-2009
Letter / Agree to amend table 1 & para 3.11.
Link to policies / Increase recycling to reduce residual waste / David Ashton
Herts WithOutWaste / 15-12-2009
Via Limehouse
Wsa27 / Targets to be reviewed. RSS is proposing 65%
Chapter 3 / Good data on waste generated is required to base decisions on, identifying the particular location/process which produces a lot of a particular waste type. / Mrs Tabitha Evans / 24-11-09 via Limehouse
Wsa5 / Additional work being carried to reinforce spatial strategy
Chapter 3 spatial strategy / Employment growth figures in 3.3 are not from the adopted RSS 2008 but REiP Panel's report of 2007. / Stevenage Borough Council
Richard Javes / 17-12-2009
Via Limehouse
Wsa10 / Amend growth section to reflect most recent figures and make the information easier to understand.
Para 3.4 / Additional research on transport infrastructure required. / Cemex
Kirsten Hannaford-Hill / 21-12-2009
Emailed letter / Check the link with the Herts Investment and Infrastructure Study and SoS’s Priority Areas for Further Study.
Para 3.6 / Update paragraph 3.6 with the results from the Rye Meads water cycle study. / Stevenage Borough Council
Richard Javes / 17-12-2009
Via Limehouse
Wsa10 / Update the Core Strategy to reflect the most recent documents.
Paras 3.4-3.6 / Only reference to sewage and waste water is Rye Meads – RSS policy WAT2 states coordinated approach to plan making required.
Policy needed to support upgrades to existing STW and provision of new sites and comply with PPS12.
Wiltshire and Surrey quoted as having good policies for waste water treatment. / Thames Water
Carmelle Bell / 18-12-2009
Emailed rep form / Agree – add additional wording and policy re waste water infrastructure
Para 3.9 / Confirmation of Westmill is only non-hazardous site and contracts for export of municipal waste out of county required. / Environment Agency
Kai Mitchell / 21-12-2009
Letter / Contracts detailed elsewhere in plan including interim ones at para 3.33, compost ones at 3.57 and Edmonton at 3.18 & 4.27. Could further clarify the situation at 4.33, 3.9 & 3.70.
Para 3.9 / No clear strategy to provide for additional landfill capacity for non-hazardous waste.
Not clear in appendix D the level of capacity that adjoining authorities have for landfill and if including provision of Herts waste in their CS. / Lafarge Aggregates
Heaton Planning Consultants / 18-12-2009
Emailed letter / Contact adjoining authorities to ascertain capacity of landfill and existing contractual arrangements.
Address in text.
Para 3.10 / Should reword to:
‘Existing waste management facilities in Hertfordshire have insufficient capacity to recover the predicted volumes of waste.’ / Environment Agency
Kai Mitchell / 21-12-2009
Letter / Proposed wording is specific to future waste arisings which should be clarified.
Para 3.11 / Further information required re: capacity to treat and dispose of other waste streams. / Environment Agency
Kai Mitchell / 21-12-2009
Letter / To be included.
Para 3.13 / Questions relocation of HWRCs in light of lack of HWRC in Hitchin. / North Herts District Council
David Hill / 18-12-2009
Letter / Re-word to make clear that the need for relocation of some HWRC’s is not simply due to the lack of one in Hitchin.
Para 3.14 / ‘Recovery’ blurs distinction between two levels of waste hierarchy. / David Ashton
Herts WithOutWaste / 15-12-2009
Via Limehouse
Wsa32 / Ensure distinction is made between recovery of recyclate and energy from waste treatment.
Para 3.19 & chapter 2 / Energy policy should also be referred to as a material planning consideration.
Reference made to: SoS decision for Ince Marshes EfW, Cheshire & Energy White Paper & NPS for Energy (EN-1).
Agree with need to be flexible and technology neutral. / Biffa / 8-12-09
Emailed rep form / Check PPS22 Renewable Energy. Add reference to para 3.19
Spatial approach / Reminder - evidence on capacity gap and limited landfill will need to be presented.
Not clear where waste to be exported and quantities – whether current arrangements will continue or be amended.
No arrangements to adequately dispose of hazardous waste streams. / Go East
Paul Fellows / 22-12-2009
Letter / Capacity gap technical background work will form part of the evidence base and be within the library.
Clarify arrangements for hazardous waste state if no facilities within County.
State if contract arrangements are known/will be planned for predicted waste to be exported out of the county.
Page 11 / Not all STWs listed in preferred waste site list. / Thames Water
Carmelle Bell / 18-12-2009
Emailed rep form / Include strategic sites. Note re safeguarded sites.
Wording of HPO 023
Pg11 / Uniformity required between the documents regarding ‘Tyttenhanger Quarry’ and ‘Tyttenhanger Quarry Complex including Courser’s Road’. / Hertsmere Borough Council (Ms Maria Demetri) / 10-12-09
Emailed rep form / Change name of site to ensure consistency.
Table p11 List of preferred waste areas / Table on page 11 – 'Gunnelswood Road Employment Area' should be referred to as 'Gunnels Wood'. / Stevenage Borough Council
Richard Javes / 17-12-2009
Via Limehouse
Wsa10 / Comment noted – amend.
Para 3.13 / Fig should reflect 65-70% recycling rate which should be achievable by 2015 and 80-85% by 2031/2. / David Ashton
Herts WithOutWaste / 15-12-2009
Via Limehouse
Wsa32 / Targets to be reviewed – although targets suggested are generally considered unachievable. RSS is proposing 65% by 2031
Para 3.19 / Para 3.19 – should include 'the avoidance of conflict with the LDFs of district councils'. / Stevenage Borough Council
Richard Javes / 17-12-2009
Via Limehouse
Wsa10 / Comment noted – incorporate reference to WDFs in text.
3.23 / Not a good example of re-use on waste hierarchy: materials recycling facility is in fact ‘recycling'. Freegle (formerly freecycle) suggested as more suitable example. / Mrs Tabitha Evans / 24-11-09 via Limehouse
Wsa5 / Agreed
3.26 / Contract arrangements – not clear how long these can be relied on. / Lafarge Aggregates
Heaton Planning Consultants / 18-12-2009
Emailed letter / To be clarified
Policy 1 / Information in complex format and clearer quantities of waste to be managed required – preferable in one table.
Pleased with use of recent evidence of local arisings – will not cause harm to implementation of RSS. / EERA
Deborah Sacks / 14-12-2009
Email / Agree – the figures for capacity requirements will be shown in a table and consider policy 2 being separated into different waste types.
Policy 2 / Title of policy is misleading – focuses on MSW – should also refer to landfill provision as in para 4.33. / Biffa / 8-12-09
Emailed rep form / Consider separating the policy into
· MSW
· C&I
· C&D
And capacity requirements for each
Policy 2 / Question target for in vessel composting of food when AD is also suitable technology for this waste stream with addition of renewable energy in line with policy 7. / Biffa / 8-12-09
Emailed rep form / Agree – composting could be through either In- vessel or AD. Amend policy to reflect this.
Policy 2 / Monitoring for Policies 1 and 2 – need to clarify if "designated sites" refers to historic environment designations. / English Heritage
Tom Gilbert-Wooldridge / 18-12-2009
Via Limehouse
Wsa50 / Agree – clarify wording.
Policy 2 / Clarify whether "sites" means buildings and areas too - perhaps "features" would be a better generic term. / English Heritage
Tom Gilbert-Wooldridge / 18-12-2009
Via Limehouse
Wsa50 / Agree – clarify wording.
Policy 2 / Amend to reflect the fact that there are a number of mineral operations with potential for inert infill and aggregate facilities not located in employment land areas. / Lafarge Aggregates
Heaton Planning Consultants / 18-12-2009
Emailed letter / Agree.
Policy 2 / Should refer to all waste streams – add a sentence or delete word ‘municipal’. / Vail Williams LLP (on behalf of Waterhall) / 21-12-2009
Emailed rep form / Agree – policy should refer to all waste streams