Object

Representation ID: 13691

Received: 12/12/2020

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Safeguarding -
Recommend that the general issue of safeguarding regulated activity (such as AD plants, landfill, composting and other waste processing facilities) from proposed new sensitive receptors is considered within this policy as it is becoming an increasing concern. This is partly touched on in sections 8(x) 8(xiv) and 9.
Issues can include housing development close to waste operating facility.
‘Safeguarding’ can also refer specifically to providing for appropriate future expansion of existing infrastructure, by preventing conflicting developments. We are seeing increasing pressure on waste facilities especially in urban areas, largely due to housing developments which result in an increase in complaints to ourselves as the regulator of those facilities. Changes to planning system now allow commercial properties to be converted to residential use, such as offices on industrial estates.
It should be made clear that the Environmental Permitting Regulations do not demand ‘zero impact’, so conflict situations become inevitable.
Para. 182 of NPPF now makes reference to placing obligations onto the “Agent of Change” (i.e. the developers/applicants,) requiring them to ensure appropriate mitigations are put in place to protect neighbouring users from impacts.