Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 11116

Received: 28/08/2025

Respondent: Tata Chemicals Europe Limited

I&O_11614
The Waste Needs Assessment (2023) identifies that there is sufficient waste management capacity in existing sites and sites with planning permission to meet the projected management requirements up to 2045 (apart from landfill). However, we are not proposing to limit waste management development or prevent future developments due to a lack of ‘need’, as there will be waste flows between authority areas. Any new proposals for waste developments would be assessed on their own merits and against the criteria identified above. Do you agree with this approach? Please provide reasons for your answer. TCEL agree with this approach. Historically overprovision within local plan could result in increased waste management towards the bottom of the hierarchy (landfill) and demotivation towards driving waste up the hierarchy. With the advent of fiscal constraint (principally the landfill tax escalator) market forces have driven the delivery of waste management solutions up the hierarchy. Under provision risks not having the facilities we require to meet the need within the authority area, and adjoining areas (further up the hierarchy). Over provision of recycling and recovery facilities doesn’t happen because investors/developers simply will not build facilities where there is a shortage of waste to serve them. Consequently, it is much better from a plan perspective to over provide than under provide.