Waste Core Strategy First Consultation 22nd July – 30th September 2011 Summary of Consultation Responses The Waste Core Strategy (WCS) First Consultation represented the first formal steps towards the preparation of North Yorkshire Waste Core Strategy. The consultation exercise ran from 22nd July 2011 until 30th September 2011, spanning 10 weeks. 1 In total 1323 representations were received from 203 interested parties in relation to the Waste Core Strategy First Consultation document. A brief summary of the main issues raised in the Waste Core Strategy First Consultation is provided below. The table below indicates to which areas of the document the representations relate. Question Respondents Question Box 1 – Stakeholder Involvement 186 Question Box 2 - Evidence Base 190 Question Box 3 - North Yorkshire Context 187 Question Box 4 - Policy Context 192 Question Box 5 - Waste Context 195 Question Box 6 - Spatial Vision 188 Question Box 7 – General / Additional 185 What were the main Issues raised in response? The tables below indicate the key Issues raised in the representations, in question order: Question Box 1 - Stakeholder Involvement “Do you agree that the overall approach to stakeholder involvement, set out in this section of the document, is appropriate?” Total Yes No Didn’t Say Did not answer the question 25 158 3 16 1 The consultation exercise took place in the run-up to the expected submission of an application for a major waste treatment facility (Allerton Waste Recovery Park) and the interest in this proposal appears to have been reflected in the responses received. As a result of this, an action group produced a standard response which accounted for the majority of responses to the consultation. Waste Core Strategy First Consultation – Summary of Responses 1 “If not, what other approach would you suggest?” Approach Total Don’t present the Allerton Waste Recovery Park (AWRP) Proposal as a fact and not ‘up for discussion’ 141 Evaluation of consultation responses should be made independently 122 Make clear that waste management includes treatment and transportation elements 118 The online questionnaire was difficult to use and the multiple choice questions were susceptible to wrong interpretation 116 Ensure a copy of the response can be retained by the respondent 102 The AWRP Proposal should be decided after the WCS is adopted 6 Place more effort in publicising the consultation 5 The consultation period should be longer and not over the holiday period 3 Stakeholders must have a genuine opportunity to shape policy 3 Encourage the involvement of everyone affected by waste issues by more targeted consultation 2 At evaluation stage all options for waste treatment and disposal should be up for consideration 2 Provide balanced information 2 Hold road shows or other such events during later stages of WCS production to involve more people 2 Focus publicising consultation around existing waste management sites 2 Hold one-to-one meetings and workshops with relevant stakeholders 2 Create an internet bulletin board/forum for the WCS 1 Waste Core Strategy First Consultation – Summary of Responses 2 Ensure that the views gathered through consultation contribute to formulating policy 1 Greater emphasis needs to be placed on detailed consultation with all residents and their representatives 1 Simplify the approach to stakeholder involvement 1 Stakeholders should be involved in the evaluation of the consultation responses 1 Any large waste proposal should be accompanied by a transport assessment and cumulative impact assessment 1 Work alongside Highways Agency to ensure policy developed gives consideration to sustainable accessibility and transport issues 1 Figure 2 could be improved by including reference to Habitat Regulations Assessment (HRA) and Sustainability Appraisal (SA) process 1 Continue to work with English Heritage as waste developments may impact on historic buildings and landscape 1 Continue to work with industry to build a complete and accurate evidence base, and reflects views and aspirations of stakeholders 1 Undertake pre-application community involvement for significant applications to ensure views of local community are taken into account 1 Four stages in the Development Plan Document (DPD) process is too many, could be reduced to 2 1 Ensure proper evidence base upon which to base consultations 1 Ensure WCS fully reflects identified current and future requirements for managing municipal waste 1 Carry out parish council presentations 1 Have an accessible LDF website which is regularly updated 1 More evidence needed on promoting recycling before considering an incinerator 1 Clarify the word stakeholder, and explain different types 1 Note: The vast majority of respondents mentioned more than one issue when responding to qualitative questions. As a result of this the total number of issues raised does not correspond to the total number of respondents to the question. Waste Core Strategy First Consultation – Summary of Responses 3 Question Box 2 - Evidence Base “Do you agree that the range of evidence for the preparation of the Waste Core Strategy is sufficient?” Total Yes No Didn’t Say Did not answer the question 15 165 10 12 “If not, what other evidence should the Council be seeking to obtain to help it in its work?” Comment/Theme Total Waste Projections 138 Evidence is too narrow 91 Lack of financial information 91 The attempt to underpin the AWRP Proposal is not justified by evidence 91 Waste management information from neighbouring Authorities 5 Growth areas and proposed development 3 Strategic transport assessment 3 Evaluation of single site versus multiple sites 3 Analysis of potential sites for waste treatment facilities 2 Survey of waste operators 2 Site selection criteria/call for sites 2 Assessment of carbon costs and climate impacts 2 Location of key habitats and populations of species in National and Local Biodiversity Action Plans Biodiversity opportunity and ecological network mapping (The Yorkshire and Humber Biodiversity Forum) 1 1 Yorkshire and Humber Climate Change Adaption Study 1 Future waste capacity 1 Courtland Commitment and Food Industry Sustainability Strategy 1 Revised Waste Framework Directive 1 District plans and Strategies 1 Waste Core Strategy First Consultation – Summary of Responses 4 A Zero Waste UK document 1 Waste management and employability 1 Information on designated sites for landscape value, biodiversity and geological conservation 1 Sustainable Development Commission reports on waste 1 Evidence about nature and state of Historic Assets in Plan area 1 Managing Landscape Change Study 1 Flood Water Management Act 2010 1 Evaluation of main methods of waste treatment 1 Environmental and health information 1 Information on the costs of alternative approaches to waste management 1 Location of areas of groundwater and aquifers 1 Emerging waste recovery and disposal technology 1 Question Box 3 - North Yorkshire Context “Do you agree with the summary provided in the text box in section 5?” Total Yes No Didn’t Say Did not answer the question 20 159 8 15 “If not, why?” Issue Total Geography of the county and poor east/west access lends itself to multiple sites e.g. Scarborough waste should not be transported across the county 142 The increasing cost of transporting waste by road 124 Ignores the proximity principle with regard to municipal waste 112 The strategy should consider sites which use more sustainable transport e.g. by rail/water 112 Lack of consideration of co-locating waste treatment facilities with new economic developments 109 Waste Core Strategy First Consultation – Summary of Responses 5 Consideration should be given to a joint plan to share facilities across boundaries 4 There should be an emphasis on more local sites at each of the major population areas in the county 3 There is poor access from the west, including the Yorkshire Dales National Park. This area could be better served by using waste facilities outside of the county The electricity generation industry in the Leeds region will need increasing volumes of waste in future years - an opportunity for local income 2 2 The scope for local multi-waste sites should be explored 2 Growth projections have not been considered 1 There is no direct correlation between economic activity and waste arisings 1 “What other important issues do you think there are?” Issue Total The plan area provides opportunities for sustainable waste management facilities to contribute to environmental objectives e.g. climate change, waste recovery and recycling 116 Mention other treatment options, such as the Power Stations in Selby and outside of the Plan area 114 Potential transport modes such as rail links 114 Needs to include a wider regional context 113 Make clear that ‘waste management’ includes treatment 113 Needs to discuss the electricity network and heat demand 112 The rural nature of the County provides opportunities for small scale community based waste management 6 Need to consider the distance to waste management sites across authority boundaries 4 Need to consider the size of the County in greater detail when considering the transportation of waste 4 Waste Core Strategy First Consultation – Summary of Responses 6 Transportation of waste in rural areas, and its impact, needs to be considered in greater detail 3 Transporting waste east/west along the A56 is not safe 2 More emphasis needed on the relevance of population to transport links 2 Waste management in the Plan area is inefficient 2 The plan ignores integrating with existing power generation stations 2 North Yorkshire should not have to provide for the larger urban areas 2 Consideration should be given to a joint plan to share facilities and coordinate across boundaries. 2 There should not be the need for the County to develop its own waste management capacity if facilities exist elsewhere in areas which can be accessed from North Yorkshire 2 The size of North Yorkshire suggests several sites would be better than a single site at AWRP Proposal Site 2 Source protection Zones and Principal Aquifers need to be considered in the environment section 1 The impact of the recession on the level of commercial/industrial activity and likely future capacity needs 1 Focus on re-use rather than on recycling 1 It should not be assumed that waste facilities should be located close to the main north/south corridors unless robust evidence is provided 1 Consider locating sites on previously developed land, and co-location of sites 1 The strategy should ensure that waste allows for sustainable use of the County’s soil resources 1 Waste treatment solutions should include landfilling of inert material for restoration of mineral sites in the county 1 Multiple sites are needed to reduce the need to transfer waste 1 Waste Core Strategy First Consultation – Summary of Responses 7 The spatial implications of a ‘zero waste economy’ 1 North Yorkshire is predominantly agricultural allowing a greater use of Anaerobic Digestion which would create local sites and employment 1 Opposition to incineration on numerous grounds including impact on the environment of the County 1 The location of the AWRP Proposal site is not well serviced from the motorway network 1 Centralisation of a waste facility in the County is not optimal due to geography of the area and cost 1 Smaller site operations would be amore amenable 1 The council seems fixed on one idea (AWRP Proposal) as there are alternatives that are being completely ignored. 1 Question Box 4 - Policy Context “Do you agree with the summary points provided in the text boxes in this section?” Total Yes No Didn’t Say Did not answer the question 15 147 13 10 Online Responses (See table below) 17 “If not, why?“ Issue Total Fails to report emerging policy e.g. focus on the 2008 EU Waste Directive rather than the impending new waste directive and others e.g. energy and climate 133 The increased need to recycle has not been explored to a degree that reflects the government’s strategy 91 Too much focus on energy-from-waste (by incineration) 5 The WCS should be decided before the York and North Yorkshire Municipal Waste Management Strategy (Y&NY MWMS) 4 Insufficient evidence to indicate recognition of the 2011 Government Review of Waste Policy 4 Waste Core Strategy First Consultation – Summary of Responses 8 The summary is at odds with the Council’s intention to build the AWRP Proposal 4 The document appears to be looking backwards rather than forwards 3 Too much emphasis on ‘moving up the waste hierarchy’ 2 This approach closes the door to new technologies for waste management 2 Targets for recycling and reuse are too low 2 The evidence is too narrow 2 It does not consider exporting waste to treatment plants in other areas 1 No reference to the government’s new policies on climate change and energy efficiency 1 Ignores the impact of incineration of waste upon climate change 1 More flexible solutions to waste management should be considered 1 The concept of a ‘Zero Waste Economy’ has not been covered 1 Objectives of the Y&NY MWMS, to maximise reuse, recycling and composting, will not be realised if AWRP Proposal proceeds 1 The document is underweighted on treatment and management of waste issues 1 It fails to note the international obligations the UK has in relation to climate change 1 Ensure consistency with the revised 2008 Waste Framework Directive 1 Waste Core Strategy First Consultation – Summary of Responses 9 “To what extent do you agree or disagree with the relevance of the summaries provided in the policy context section” (Online Response Question only) Strongly Agree Agree Neither Disagree Strongly Disagree Don’t Know European Policies and Strategies 1 4 6 1 4 1 National Planning Policy 2 4 6 4 1 Regional Policies 1 4 4 3 4 1 Local Policies 2 2 5 2 5 1 “What other key relevant policy context should the Council be taking into account in developing the Waste Core Strategy?” Additional Key Policy Total Adhere to the ‘Zero Waste Economy’ concept 119 The WCS should be decided before AWRP Proposal 119 Focus on moving the treatment of waste up the waste hierarchy 112 Develop a clear planning framework, utilising examples from other Local Authorities 7 Waste disposal options should be examined from a financial standpoint 3 Focus upon waste reduction 3 The emerging National Planning Policy Framework (2011) 3 Impending new EU Directives on energy efficiency and climate change 3 Maintain flexibility to ensure ability to utilise technology advancements 3 PPS10 – Planning for Sustainable Waste Management, and its Companion Guide Documents on waste management produced by ‘Greenpeace’ and ‘Friends of the Earth’ (e.g. Residual Waste Research Phase II) The strategy needs to include emerging waste policy in addition to existing policy Needs to be based on properly evaluated viable options, including AWRP Proposal 2 2 2 2 Need to increase opportunities for households to recycle 2 Government Review of Waste Policy in England (2011) 2 Need to take account of public and business concerns 2 Exporting waste to plants that are outside our region 2 Waste Core Strategy First Consultation – Summary of Responses 10 Take into account the emerging Localism Bill 1 Self contained localised sites determined by residents/voters 1 Increase recycling levels 1 OSPAR Convention for the Protection of the Marine Environment of the North East Atlantic 1 UN Stockholm Convention 1 Keep the treatment of Household and Industrial waste separate 1 Focus more effort in educating residents to recycle more 1 The Council need to be more outward looking 1 Encourage campaigns for increased recycling and waste minimisation in the commercial and industrial sector 1 Ensure infrastructure is in place to support the transport of waste 1 Biodiversity and Geological Conservation considerations through the Regional Biodiversity Strategy 1 Water Resources Management Plan (2009) produced by United Utilities 1 Harrogate District Core Strategy, particularly policy EQ1 1 Work with District/Borough Councils to produce a joint strategy 1 The Strategy needs to justify the need and proposed location of the AWRP Proposal site 1 Green Alliance – ‘A Zero Waste UK’ (2006) 1 Economic and Social Research Council – ‘Consumption: Reducing, Reusing and Recycling’ (2007) 1 The Waste (England and Wales) Regulations (2011) 1 Anaerobic Digestion Strategy and Action Plan (June 2011) 1 Energy White Paper ‘Meeting the Energy Challenge’ (May 2007) 1 Draft PPS: Planning for a Low Carbon Future in a Changing Climate (March 2010) DECC – Review of the generation of costs and deployment potential of renewable electricity technologies in UK Study Report (June 2011) 1 1 National Policy Statement for Energy Infrastructure (June 2011) 1 Y&NY Municipal Waste Management Strategy (June 2006) 1 The North Yorkshire Local Transport Plan 2011-2016 (LTP3) 1 Recent Parliamentary Advisory Committee discussions upon the high cost and low effectiveness of Private Finance Initiative 1 Waste Core Strategy First Consultation – Summary of Responses 11 Define methods by which a new public awareness of waste issues will be realised 1 Need a clear policy for alternative methods to manage waste 1 Need to place importance upon and protect countryside areas outside of Areas of Outstanding Natural Beauty (AONB) and Special Landscape Areas (SLA) Recognise and value permitted footpaths and open access paths in addition to Public Rights of Ways In terms of carbon emissions, properly managed landfill is a better solution than combustive processes The WCS should not avoid ruling out waste management technologies that do not accord with our aspirations 1 1 1 1 “What specific issues raised in section 6 (Policy Context) do you think are a priority in North Yorkshire?” Policy Context : Issue Restrict energy recovery to residual waste that cannot be reused or recycled Work with adjoining authorities to avoid risks of creating excess or inappropriate capacity Total 128 126 The WCS should inform and not be constrained by other policies 113 Increase re-use, composting and recycling 10 Ensure policies are not short term 10 Reduction and prevention of waste 7 Reduce the transportation of waste 7 Prioritise environmental and human health 5 Reduce climate change impacts 4 Diversion of waste from Landfill 4 Improve sustainable transport of waste 4 Co-ordination of waste policies with adjoining authorities and district/borough councils within North Yorkshire 4 Sustainable development/construction 3 Solutions need to be flexible 2 Proximity Principle, treat waste as close to its source as possible 2 Develop proposals which have the support of local communities 2 Negating impact upon local communities 2 Waste Core Strategy First Consultation – Summary of Responses 12 More information should be available to the public with regard to waste policy/applications The Council should view itself as the ‘provider of last resort’ with regard to waste management sites The priority of policy levels should be national, followed by regional and then European 2 1 1 Note advantages of co-locating opportunities for waste facilities 1 Focus on developing/emerging issues/policy 1 Ensure consistency with national strategy 1 The Council should not view waste management facilities as a mechanism for generating income from other Local Authorities 1 Meeting future demand whilst limiting environmental impacts 1 Mitigation of any shortfall in supply of water resources 1 Locate Energy-from-Waste facilities where the energy can be used effectively 1 Separate collection of food waste 1 Recognise the role of waste management as a driver for local economic growth 1 Managing Industrial waste 1 Implementation of the policy for joint municipal waste management set out in the Y&NY MWMS Greater emphasis needs to be placed upon the changing definition of municipal waste which now incorporates commercial wastes with similar properties to municipal waste Community and business education on the impacts of disposing of waste 1 1 1 Drive the management of waste up the ‘Waste Hierarchy’ 1 Anaerobic Digestion of biodegradable waste 1 Facilitate Commercial recycling schemes 1 AWRP Proposal should be allocated as a Strategic Waste Management Allocation within the WCS to accord with PPS12 Strategic Waste Management Facilities should be supported by an adequate on-site educational facility 1 1 Consideration of the current Regional Spatial Strategy 1 Provide a clear and systematic planning framework 1 Need to explain how AWRP Proposal links to the policy to maximise reuse, recycling and composting of household waste Utilisation of residues from Thermal Mechanical Biological Treatment as restoration of disused quarries Reflect the concerns and interests of communities Waste Core Strategy First Consultation – Summary of Responses 1 1 1 13 Waste management options, that assume arisings of waste will not be reduced by recycling initiatives, should not be considered 1 Place importance upon the collection of waste data 1 Question Box 5 - Waste Context “Which of the issues in the text box in this section do you think will be particularly important when planning for waste in the area?” Issue Total The WCS should be decided before the AWRP Proposal 146 An incinerator will discourage recycling 17 Progress of the AWRP Proposal 7 Waste transportation 5 Robust information on waste facilities in the Plan area and the amount of waste they produce Making provision for future waste arisings while managing impacts of these facilities Impact of development of waste facilities on environment and local communities need to be taken into account 3 3 3 Interaction with adjacent waste authorities 3 Proximity principle 3 Any long term strategy should be sufficiently flexible to adapt to change 3 Increasingly demanding targets for more sustainable waste management Take account of the issues which overlap with the Minerals Core Strategy Reduction in overall amount of waste produced A range of waste streams and waste management methods will need to be planned for Opportunity to deliver social, environmental and economic benefits through evolving waste management practices 2 2 2 1 1 East/west transport links restricted 1 Consider the carbon footprint of moving waste 1 The disposal of industrial waste and its impact upon the visual amenity and landscape 1 Reduce amount going to landfill 1 Reduce the amount of waste from power stations 1 Waste Core Strategy First Consultation – Summary of Responses 14 Increase re-use, and do not classify it with recycling 1 Put waste facilities in existing industrial locations to minimise impact 1 Recycling targets should be more ambitious 1 There is not one body responsible for managing the entire waste stream in the County, there would be benefits if there were. 1 Incineration should be one of the last options not the first 1 Waste should be recognised as a resource to fulfil the strategy of zero waste strategy 1 “Which of the following issues do you think will be particularly important when planning for waste in the Plan area?” (Online Response Question only) Very Important Important Neither A range of waste streams and waste management methods will need to be planned for 6 9 2 Increasingly demanding targets for more sustainable waste management will require the development of more waste management facilities and this will need to be appropriately managed 3 11 2 The interactions in waste arisings and management between the Plan area and adjacent waste planning authorities and regions will need to be considered 7 3 5 Robust information on the number of waste facilities in the Plan area and the amount of waste they process will be important for future planning, and industry assistance with this will be needed 8 7 1 A key challenge for the WCS will be making adequate provision for future waste arisings whilst managing the impacts of these facilities on the environment and local amenity 10 4 3 The progress of proposals for Allerton Waste Recovery Park will need to be factored in to development of the WCS as the project continues 2 4 2 Un important Waste Core Strategy First Consultation – Summary of Responses Very Unimportant Don’t Know 1 1 1 1 2 6 1 15 Development of waste facilities can have impacts on the environment and local communities and these need to be acknowledged and taken into account 13 4 The opportunity to deliver social and environmental, as well as economic benefits, through evolving waste management practices, which should be explored 5 9 2 It is important to take into account the issues which overlap with those that may be relevant to the Minerals Core Strategy 4 10 3 1 “What other important issues, not identified in this section do you think should be addressed in developing a waste planning strategy for the plan area?” Issue Total Acknowledge the impact waste facilities can have upon the environment and local communities 123 AWRP Proposal has failed to engage with the local community 112 Consider impact of post minerals extraction use, such as landfill, on underground water sources, such as aquifers 4 Link with the Minerals Core Strategy 4 The environmental impact of transporting waste must be considered 3 Look at alternatives to incineration of waste 2 Take into account likely changes in technology to treat waste 2 The WCS should be decided before AWRP Proposal 2 The pattern of waste development, few large sites versus many small ones Robust information on waste facilities and their capacities and capabilities 2 2 Make more use of rail as a mode of transport 2 Consider the proximity principle 2 Recognise that inappropriate technology choices can impact upon economic development and the health of local people 2 Increase the focus upon the need to recycle 1 Waste Core Strategy First Consultation – Summary of Responses 16 Attach greater weight to the waste hierarchy 1 Place greater emphasis upon waste minimisation 1 Take account of the changing nature of waste 1 Focus upon creating a zero waste economy 1 Ensure accountability of decision makers 1 Ask the public if they want an incinerator 1 The overall spatial approach to waste, an important point for sustainability appraisal 1 Transportation of waste will have a bearing on the strategy chosen 1 The use of waste as a resource 1 Take account of the effect of the new strategy on the local community and county as a whole Mitigation measures will need to be in place to offset any negative effects on the environment Construction and demolition waste needs to be better addressed in the WCS Encourage the reuse of existing buildings rather than demolishing them Encourage development of facilities for reuse of demolition waste, especially where material can be used to help repair historic buildings The carbon impact of waste will be used as a method of assessment more than tonnages in the future 1 1 1 1 1 1 Minerals sites able to host waste management facilities 1 No mention of waste water issues in main body of the document 1 Agricultural waste management has changed over recent years, and this needs to be taken into account Waste management can be carried out on agricultural land and should be seen as part of the local solution to waste management 1 1 Do not place any new facilities near to waste water infrastructure 1 Households should be encouraged to recycle more 1 Encourage manufacturers to reduce packaging 1 More emphasis on the role that landfill will play in the future 1 Consider the overlap issues with national policy/strategy for sustainable energy supply and climate change Consider interactions between facilities where waste is treated/sorted to provide recycling opportunities and facilities where recyclate material can be used as a resource Long term strategy should be flexible Waste Core Strategy First Consultation – Summary of Responses 1 1 1 17 There does not appear to be an alternative to the AWRP Proposal 1 Local sustainability 1 Develop a long term policy for reducing waste 1 Listen and consult with people in an open manner without prejudice 1 Need to include site selection criteria 1 Start to look at potential options 1 Concerned industry views will be prioritised over members of the public 1 Waste data should take account of the nature and types of waste being managed, identifying them and categorising them The loss of valuable agricultural land and adverse impact on landscape restoration as a result of the proposed diversion of waste from landfill Energy produced from waste should be put to a sustainable and environmentally friendly use 1 1 1 Question Box 6 - Spatial Vision “Do you agree that the points set out in the text box in section 8 could provide a suitable starting point for the development of a vision?” Total Yes No Didn’t Say Did not answer the question Online Responses (See table below) 15 147 9 14 17 “To what extent do you agree or disagree with how the following statements can provide a suitable starting point for development of the vision” (Online Response Question only) Strongly Agree Agree Neither Ensure that Waste management takes place as far up the waste hierarchy as practicable 8 4 3 Support a good fit between waste management facilities and sources of waste arisings, appropriate to there scale and nature of waste arisings being dealt with and consider the implications of transporting waste 8 6 1 1 3 5 6 1 Where practicable provide enough waste management Disagree Waste Core Strategy First Consultation – Summary of Responses Strongly Disagree Don’t Know 2 1 1 1 18 capacity to deal with its waste arisings throughout the plan period to 2030 Ensure that those elements of North Yorkshire’s environment, important for there own sake and to residents and visitors, are given appropriate protection 12 4 Ensure that the highest practicable standards of operation are applied and that the waste management industry are working effectively with local communities 9 4 1 2 2 “What other important objectives should waste planning in this area be seeking to achieve?“ Issue Comment Sufficient flexibility to accommodate changes in waste volumes, recycling and technology 141 Deliverance of ‘value for money’ of waste facilities 131 Support the local economy by maximising the use of locally owned and operated facilities 121 Focus on waste minimisation and recycling 2 Include mitigating the effects of climate change 2 Support the movement of waste up the waste hierarchy 2 Must be acceptable to stakeholders/members of the public 2 Include more ambitious targets 1 Adopt a non-incineration policy 1 Minimise carbon impact 1 Reduce visual intrusion from waste facilities 1 A vision which brings together all sectors of the community 1 Minimise environmental pollution 1 Require waste facilities to resubmit licences annually 1 Welcome use of waste hierarchy, proximity principle and self sufficiency where practicable to inform the vision 1 Welcome protection of the environment and communities 1 Waste Core Strategy First Consultation – Summary of Responses 19 Welcome achievement of highest standards of operation and partnership working with communities Will need to provide stronger support for maximising transportation of waste by sustainable means, ensuring new waste facilities can be supported by existing infrastructure Make reference to increasing opportunities for reducing greenhouse gas emissions, and adapting to a changing climate The WCS should protect the County’s most important landscapes WCS should seek to protect and enhance the County’s biodiversity and geodiversity Welcome commitment to ensure that elements which contribute to distinct character and quality of life of the communities of North Yorkshire are safeguarded The draft vision does not include a statement on sustainability, using waste as a resource Should reinforce the importance of pre-application community involvement regarding new waste developments 1 1 1 1 1 1 1 1 Vision too wordy 1 Need to include cross cutting issues 1 The word ‘practicable’ should be clarified 1 Ensure local sorting sites are set up for reclamation, repair and sale of recovered items from the waste stream, aim to benefit the local economy 1 The plan is expensive and inflexible 1 Ensure energy recovery from residual waste is restricted to waste which cannot be recycled Capitalise on synergies between different types of waste and waste management techniques 1 1 Consider using existing facilities 1 Consider the impact on the economy provided by tourism 1 Plan long term to 2030 1 The plan must ensure that it provides a sound basis for the objectives of the strategy 1 Include local sustainability 1 Ensure the plan can accommodate changes in recycling techniques, ratios and volumes 1 The vision fails to provide any aspiration in terms of reducing waste 1 Does not include anything about local labour input 1 Waste Core Strategy First Consultation – Summary of Responses 20 A revised vision suggested by one of the respondents: “By 2030 North Yorkshire’s communities and businesses will be managing their waste locally and in a sustainable manner. The County will have an ambitious and modern waste industry that manages waste as a resource to be re-used in line with the waste hierarchy, and which is part of wider economy that supports green energy and other sustainable technologies. We will be producing less waste, reusing more and striving to exceed national recycling targets as far as practically possible. Disposal via landfill will be the last resort once options to re-use, recycle or recover have been exhausted. The geographical spread of waste facilities will be designed to minimise transport, closely linked to the concentrations of population. Larger facilities will be located close to the main urban areas of York/Harrogate, Scarborough/Whitby, Skipton, Richmond/Northallerton, and Selby. Rural communities will be supported by smaller-scale schemes and, where appropriate, farm-based initiatives. All waste development schemes will respect and enhance those elements of the North Yorkshire environment, wildlife, landscape and heritage that are important for their own sake and to residents and visitors. They will successfully mitigate their possible impacts on climate change.” Question Box 7- General / Additional “Are there any additional matters or issues not covered in your responses to earlier questions that you think the Waste Core Strategy should address?” Comments The WCS should be decided before the AWRP Proposal The online questionnaire was difficult to use and the multiple choice questions were susceptible to misinterpretation Implementation of the Y&NY MWMS would pre-empt the outcomes of the WCS Total 140 122 4 The ‘fact sheet’ approach is helpful and accurate 3 Document too long and complicated 3 Greater explanation and debate of AWRP Proposal 3 Broadly support the proposals within the document 2 Energy recovery from waste treatment should be near to areas that can use it The WCS consultation process is meaningless because it includes the AWRP Proposal Government want to see increase in Anaerobic Digestion, so this should form a key part of the WCS Public not generally aware of this consultation so limited response will be received 2 2 2 2 Identify and stop rogue waste disposal/transfer activities 1 Ensure waste minimisation is a focus 1 Waste Core Strategy First Consultation – Summary of Responses 21 The AWRP Proposal should generate electricity 1 Integrated approach to SA is welcomed 1 Consider taking all waste management into public hands 1 Approach to green infrastructure is welcomed 1 Ensure SA links with WCS are not tenuous and objectives can easily be monitored 1 The strategy does not clearly identify specific sites at this stage 1 MoD should be consulted on any waste schemes within the airfield safeguarding consultation zones 1 Need a robust environmental evidence base 1 Plan making should be guided by the objectives of the WCS, SA and HRA Waste prevention and reduction, sustainable resource use, environmental protection and protection of health and amenity are well represented The Council should consider planning applications for Anaerobic Digestion facilities on farms to be non-waste applications Need to make sure that there is an adequate supply of feedstock for future facilities in the WCS Consideration must be given to the markets for compost and digestate outputs Should consider the agricultural landbank available for spreading increased volumes of waste-derived materials Waste developments should not be permitted until infrastructure capacity is available The Council should obtain local capacity information from water companies to identify areas where there is capacity for development The Council should consider the full carbon impact of future developments Take account of draft policy IN2 of Harrogate District Sites and Policies DPD and Leeds City Region Green Infrastructure Strategy Protect the landscape by requesting Landscape and Visual Impact Assessments (LVIA) where necessary Harrogate BC is seeking to designate a buffer zone around the World Heritage site Studley Royal Park 1 1 1 1 1 1 1 1 1 1 1 1 Avoid disposal methods which pollute the environment 1 Anticipate likely changes in legislation e.g. carbon taxes 1 The proximity principle should form a key part of the strategy 1 The WCS is not fully consistent with the Y&NY MWMS 1 The tests of soundness are not met 1 Support moving away from landfill to more recyclable waste 1 Waste Core Strategy First Consultation – Summary of Responses 22 There is no attempt to demonstrate how the strategic needs of the Council develop into a suite of spatial recommendations 1 There is a lack of ambition in the draft vision 1 Packaging and plastic bags minimisation should be included 1 Concern that due to high recycling rates being met there will not be enough waste to fuel the incinerator 1 More emphasis should be given to low level radioactive waste 1 Take account of potential mineral sterilisation and mining legacy when looking at site allocations or areas of search The Council should facilitate/promote recycling co-ops for Small and Medium Sized Enterprises to make it viable for waste collection companies to collect items from them Anaerobic Digestion is more acceptable for decomposable waste, with the methane and compost produced able to be utilised If all reusable materials have been removed from waste then calorific value so low will not burn, so landfill preferable to incineration Recycling is always preferable to incineration, only non-recyclable waste should be incinerated There should not be any waste disposal facilities in Leyburn or Wensleydale WCS should look at long term issues of local sustainability and reducing waste production by promoting behaviour changes 1 1 1 1 1 1 1 Support small scale sites suited to the geography of the County 1 There is a lack of facts in the document 1 A centralised modern plant makes sense to take advantage of economies of scale Incinerator may be a financial burden on the Council and need funds diverted from other services to support it 1 1 The WCS should not predetermine treatment methods to be used 1 Having one centralised facility goes against the proximity principle 1 WCS does not elaborate on the ‘social and economic objectives’ mentioned in the document A high volume of waste will be needed to fuel the incinerator so recycling rates will go down 1 1 Road transport network not suitable to support the AWRP Proposal 1 Consultation period too short 1 Some questions ambiguous 1 Should set targets for reducing carbon impact of waste, encouraging waste prevention and reuse, increase recycling, get the most out of residual waste 1 Questions online different to paper response form 1 Need a more flexible view in the future as waste management has changed 1 Waste Core Strategy First Consultation – Summary of Responses 23 WCS makes reference to relationship between minerals and waste, this is important in terms of transport 1 Research the viability of new rail links to new or existing waste facilities 1 Provide cost implications of using existing facilities compared to the provision of a single facility 1 Consider the implications of the loss of Best and Most Versatile Land 1 Consider the length of time taken to restore quarries if we divert waste away from landfill Provide data on utilising waste treatment plants in neighbouring authorities close to the boundary Waste Core Strategy First Consultation – Summary of Responses 1 1 24
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