* Analysis of Comments on the Preferred Waste Strategy
**Copy of Factsheet 2 can be obtained on request from East Sussex County Council on 01273 481846 or wasteandmineralsdf@eastsussex.gov.uk
PAAL has responded to ESCC with an open letter detailing their concerns about the continued delay in this process. Copy letter as follows:
Ian Blake
Waste and Minerals Planning Policy Team
Transport & Environment
East Sussex County Council
County Hall
St Anne’s Crescent
Lewes
BN7 1UE
7th January 2011
Dear Sir,
East Sussex County Council Waste & Minerals Core Strategy
Following the publication of the Analysis of Comments on the Preferred Strategy and Factsheet 2, I am writing on behalf of P.A.A.L. to raise a number of points we have with the County Council’s approach and presentation of a number of key issues.
We welcome the new emphasis on alternative disposal methods and are encouraged that the County’s discussions with industry are proving constructive. As we and many others set out in their consultation responses, given the almost complete absence of suitable landfill sites, “every effort” must be made to increase the recovery and reuse to the highest possible levels. It is evident and regrettable that every effort had not been made during the preparation of the Preferred Strategy consultation.
Our principal point of concern is the continued delay to the process and the impact that this extended period of uncertainty has on local communities, particularly those directly affected by the landraise Opportunity Areas, so-called, and the landfill possibility at Ashdown Brickworks. Setting aside the obvious potential financial loss for an individual’s own property, which we accept is not a planning concern, there is real impact on local socio-economic issues (e.g. willingness of businesses and individuals to invest in affected areas) and, in some cases no doubt, a perceived impact on individuals’ health and well-being. These are matters of planning and, one might say, of political concern too.
The County Council’s sanguine approach to the extended timescale is unfortunate. It is appreciated that the Coalition Government is preparing a new national waste policy but in the meantime urges councils to continue to make their plans. The Chief Planner’s letter to local planning authorities, dated 6th July 2010, regarding the revocation of Regional Strategies, stresses that “Planning Authorities should continue to press ahead with their waste plans, and provide enough land for waste management facilities to support the sustainable management of waste (including the move away from disposal of waste by landfill).” It seems to us that in this sentence the Government’s whole position is summed up neatly. Unfortunately, it is in stark contrast with the County Council’s continuing delay and out of date Preferred Strategy; sitting back and waiting for the Government’s review isn’t acceptable.
To this end we wonder what is happening in respect of the promised detailed environmental and engineering design assessment of the Opportunity Areas and Ashdown Brickworks. We were told that this work would be likely to be commissioned from consultants and would commence during or at the end of the period for assessment of the consultation responses. We understand that no such work has been commissioned from consultants or instructed to in-house staff. This work is capable of being undertaken whilst waiting for the Government’s review and, crucially, its results could be capable of ruling out some or all of the Opportunity Areas, providing relief to those communities at least.
I would also add that we are disappointed with the summary of the responses on the Opportunity Areas. There was no express mention of the weighty criticism of the site selection process and no mention of the absence of landowner consultation. For the Newick/Piltdown there are several specific points which are of importance but have not been included; for example, no references to the remote location from the arisings and the inadequate capacity of the site once adequate buffers have been employed.
P.A.A.L. urges the County to press on urgently with its discussions with industry and to ensure that spatial provision is made in the plan for built disposal facilities. We look forward to being informally consulted, as promised in the Factsheet. It is vital that the County is ready to respond immediately to the Coalition’s strategy as soon as it is available.
Yours faithfully,
Bob White
Chairman P.A.A.L.