Pre- Submission Draft Waste Local Plan

5. Waste Management in the Plan Area

(1) 5.1. In order to Plan effectively it is important to understand how much waste is produced, how this is currently managed, and what is likely to change in future. To help with this process the Councils appointed specialist consultants (AECOM) to prepare a detailed Waste Needs Assessment.

(1) 5.2. The Waste Needs Assessment (WNA, 2023) sets out information on current waste arisings and forecasts likely future growth for each of the main waste streams. The assessment then looks at existing waste management capacity within the Plan area and makes specific recommendations as to whether additional facilities are likely to be needed.

Waste produced within the Plan Area

5.3. The WNA has confirmed that on average approximately 3.4 million tonnes of waste is produced across the Plan area each year. This is from a variety of sources including Local Authority Collected Waste from households and schools; commercial and industrial waste from shops, offices, and factories; and construction, demolition, and excavation wastes such as rubble and soils. Other sources of waste include wastewater and sewage, agricultural waste, and mining wastes. In the past, large quantities of ash have also been produced from coal-fired power stations which are due to be phased out by 2025. Waste from any of these sources, which is especially harmful to human health or the environment, is classified separately as hazardous waste. The amount of each type of waste produced during 2021 (the latest year for which data is available) is shown in Figure 4.

Figure 4 – Waste produced in the Plan area 2021

Source: Nottinghamshire and Nottingham Waste Needs Assessment, AECOM, May 2023

5.4. As the Plan looks ahead to 2038 it is important to ensure it can meet long-term needs as well as adapt to short term changes. Regular monitoring will be carried out to assess how well the Plan is performing. The proposed monitoring and implementation framework for the Plan is set out in Chapter 9 of this document.

Local Authority Collected Waste (LACW)

5.5. Local Authority Collected Waste (LACW) is made up of household waste collected at the kerbside from individual households (or taken by householders to a local authority recycling centre/civic amenity site) and also any non-household waste that is collected by the local authority from local businesses (also known as trade waste).

5.6. The amount of LACW waste generated each year has remained relatively stable over the last ten years, ranging between around 540,000 and 593,000 tonnes per year. In 2021 just under 593,000 tonnes of LACW was produced within the Plan area.

5.7. Since the publication of the Waste Core Strategy recycling rates have slowed and, in some cases, fallen. In 2021, the average across the plan area for household waste recycling rate was at 38%, with 6.2% of household waste sent to landfill.

Commercial and industrial (C&I) waste

5.8. The amount of commercial and industrial (C&I) waste produced by shops, offices, factories, and other businesses has fluctuated considerably over the last ten years from a peak of almost 1.4 million tonnes in 2013 down to a low of just under 500,000 tonnes in 2016. Much of this change is thought to be due to economic circumstances and the decline in ash produced by coal-fired power stations.

5.9. In 2019, the amount of commercial and industrial waste recorded increased suddenly by 26% from the previous year to almost 950,000 tonnes. Arisings have continued to increase, reaching approximately 1.2 million tonnes in 2021, a high not seen since 2014. This large increase may be the result of major changes in waste markets over the last two to three years including the closure of certain export markets. It is possible that some of this increase is therefore material that was previously exported as Refuse Derived Fuel (RDF).

5.10. As local authorities do not control how or where C&I waste is managed, previous estimates of the recycling and recovery rate for this waste stream have been based on national surveys rather than local data. To try and overcome this problem, the WNA has looked at the recorded fate of all C&I waste known to have been produced in the Plan area in 2021 using the Environment Agency Waste Data Interrogator. This method may not capture all C&I waste but helps to provide a more up to date, local picture^[1].

5.11. The WNA analysis suggests that around 63% of C&I waste is now recycled or composted with 28% sent to landfill.

Construction, demolition and excavation (CD&E) waste

5.12. Construction, demolition, and excavation (CD&E) waste comes from construction activities such as house building, road building and other infrastructure schemes. This also includes the demolition of existing buildings, excavation, and earthmoving works. There is no requirement for businesses to report on CD&E waste and significant quantities of this waste are managed at the construction/demolition site rather than at a permitted waste management facility. Mobile plant is often used to crush, screen, and separate the waste either for re-sale or re-use on site. The WNA acknowledges that the Environment Agency Waste Data Interrogator provides limited information on the total amount of CD&E waste produced but this has been used to give the most accurate picture possible/to consider the amount of recorded waste requiring management each year.

5.13. CD&E waste arisings have increased overall since 2010, reaching a high of 1.5 million tonnes in 2014, but have since fluctuated between roughly 950,000 and 1.4 million tonnes per annum. Using the Environment Agency data for 2021, it is estimated that just over 83% of CD&E waste is recycled, particularly C&D waste such as aggregates due to their high value or recovered with less than 20% disposed of to landfill.

Hazardous waste

5.14. Hazardous waste contains substances which are harmful to human health or the environment and can include oils, chemicals, batteries, asbestos, and pesticides. Hazardous waste arisings within the plan area have shown some fluctuation over the past 10 years but overall have remained between approximately 34,000 and 52,000 tonnes per annum between 2010 and 2019. However, in 2020 and 2021 there was a large increase in arisings to approximately 75,000 tonnes. The data indicates this is due to a large transfer of waste between two waste management sites. These estimates are taken from the Environment Agency's separate Hazardous Waste Data Interrogator.

Agricultural Waste

5.15. Agricultural waste includes all waste generated from farming activities including natural waste such as slurry and manure as well as non-natural waste such as plastic rubber, metal, and oil. The total amount of agricultural waste produced in the plan area has increased since 2010, largely due to more waste being managed through anaerobic digestion facilities, and therefore recorded, rather than being spread to land. 2021 saw agricultural waste double compared to 2019 and 2020, increasing to just under 78,000 tonnes.

5.16. As only a small amount of agricultural waste is produced each year (less than 2.5% of the total waste generated in the plan area in 2021) it is not considered necessary to identify specific waste management capacity for this waste stream.

Mining Waste

5.17. Mining waste is produced during the extraction and processing of mineral resources and includes waste solids or slurries left over after the mineral has been removed, waste rock, and soil. In the past large tonnages of colliery spoil were produced from the area's many coal mines but there are no longer any active collieries within the Plan area. Since 2010, the production of mining waste within the Plan area has generally been less than 1,000 tonnes per year although the opening a new quarry in 2016 saw a peak of just over 12,400 tonnes.

5.18. As with agricultural waste, mineral working now produces very small quantities of waste each year, much of which can be used to help restore other mineral workings or landfill sites. It is not therefore seen as necessary to make separate provision for this waste stream.

Low-level radioactive waste

5.19. Radioactive waste will either contain radioactive material or will have been contaminated by radioactivity. In the UK, radioactive waste is categorised according to the type and amount of radioactivity it contains, and the amount of heat it can generate. All high-level radioactive waste, such as that from nuclear power stations, is dealt with at a national level and is treated or disposed of at specialist sites. Non-nuclear, low-level radioactive waste produced by hospitals, universities, and industry for example, can be managed at conventional facilities. The Waste Needs Assessment has confirmed that there are no major radioactive waste facilities in the Plan area and that only very small quantities of low-level radioactive waste are produced which do not require any specific provision within the Plan.

Wastewater

5.20. Wastewater is a combination of used water from domestic properties, industry, and agriculture as well as rainwater run-off from roads and other hard surfaced areas. Existing wastewater treatment facilities in the Plan area manage an average daily flow of more than 300 million litres of effluent. The Councils will work with the water utility companies to assess the need for additional wastewater treatment capacity within the Plan area.

Forecasting future waste arisings in the Plan area

5.21. The need for further waste management capacity will depend on factors such as the level of planned housing, commercial and industrial development within the plan area, whether any major infrastructure projects are likely to take place, and the impact of wider measures to reduce waste and re-use materials in line with the circular economy principle. The Waste Needs Assessment therefore considers a range of different growth scenarios for each of the main waste streams in line with national policy and guidance on forecasting future waste arisings. These scenarios have been updated from those considered at the previous Draft Plan consultation stage. The different options considered and the preferred scenario for each waste stream is summarised below. In each case except for C, D&E waste, 2021 has been used as the baseline for forecasting as this is the most recent year for which there is comparable data available for each of the main waste streams.

Local Authority Collected Waste

5.22. To forecast LACW arisings, the NPPG recommends establishing a growth profile that considers a range of possible outcomes based on household or population growth and waste arisings per household or per head. This should factor in a range of different scenarios to take account of both historic growth trends and progressively lowering growth rates due to waste minimisation initiatives.

(4) 5.23. The previous Issues and Options consultation considered a range of options including progressive growth in the amount of waste produced per household. The most recent Waste Needs Assessment has updated the previous LACW forecasting scenarios from the Issues and Options and Draft Plan stage to take account of more recent housing estimates and gives greater emphasis to future waste minimisation initiatives. The three updated scenarios are described below:

(2) 5.24. These updated scenarios now also take account of the proportion of non-household, or trade waste which is collected by local authorities. Non-household waste is difficult to forecast as it can be affected by a number of variables such as market trends, national policy, and the state of the economy. However, rates have remained relatively stable between 2007 and 2021 so it has been assumed that there will be no change in the most recent non-household LACW generation rate.

(2) 5.25. Table 1 below summarises the forecast arisings at key intervals during the plan period.

Table 1. Summary of Forecasted LACW Arisings (in five-year intervals) (000s tonnes), 2021 – 2038

(3) 5.26. Scenario A (high decline) takes account of future waste minimisation measures but includes the 2007-2008 period when, as a result of the recession, households and businesses produced significantly less waste. This single year drop skews the data and is not considered to be representative of future trends. Scenario B (low decline) takes account of expected future waste reduction measures but is not skewed by the effects of the 2007-2008 recession. Scenario C (no change) assumes waste arisings will remain static and takes no account of future waste reduction measures and is also therefore not considered to be realistic because it does not reflect national policy aims. Scenario B is therefore considered to be the most realistic and has been chosen as the preferred option upon which to base the Plan.

Commercial and industrial waste

5.27. To forecast commercial and industrial waste arisings, national policy guidance recommends that waste planning authorities should assume a certain level of growth in waste arisings unless there is clear evidence to indicate otherwise. the latest WNA looks at future economic output and predicts future waste generation rates per employee and the employee projections from the Nottingham Employment Land Needs Study^[2].

5.28. The three updated scenarios are:

(2) 5.29. Table 2 below summarises the forecast arisings at key intervals during the plan period.

Table 2. Summary of Forecasted C&I Arisings (in five-year intervals) (000s tonnes), 2021 – 2038

(1) 5.30. Compared to the previous forecasts, using the 2021 data results in a higher baseline from which to project future waste growth but is likely to be a more realistic starting point as this reflects the probable impacts of increasing restrictions on waste exports (see paragraph 5.9). Scenario A (no change) does not take account of predicted future economic growth or the likely impact of waste minimisation measures. This is not considered to be representative of long-term trends as it does not reflect national policy or local growth estimates. Scenario B (low growth) takes account of predicted growth in the local economy after 2024 and the likely impact of waste minimisation measures as described in Chapter 3. Scenario C (high growth) takes account of predicted economic growth but assumes there will be no reduction in the amount of waste produced per employee. This is not considered to be representative of long-term trends as it does not take account of waste minimisation measures. Scenario B is therefore considered to be the most realistic and has been chosen as the preferred option upon which to base the Plan.

Construction, Demolition and Excavation Waste

5.31. When forecasting future CD&E arisings, national policy guidance recommends that WPAs should assume a constant level of future arisings as there is a limited evidence base on which to base forward projections. Allowance should also be made for the fact that a sizeable proportion of construction and demolition waste arisings are managed or re-used on-site, or at exempt sites. Although the starting point is to assume that arising will remain constant over time, forecasts should also take account of any significant planned regeneration or major infrastructure projects over the timescale of the Plan.

(1) 5.32. The Waste Needs Assessment concludes that there is no evidence to suggest an increase in future CD&E arisings. The only major construction project considered potentially likely to have a significant impact on CD&E generations rates during the plan period is Phase 2b of high-speed railway HS2, with the eastern leg terminating just inside the boundary of Nottinghamshire. Therefore, the impacts on C&DE waste arisings are not considered to be significant. For this reason, only one forecasting scenario has been considered as follows:

5.33. Table 3 below summarises the forecast arisings at key intervals during the plan period.

Table 3. Summary of Forecasted CD&E Arisings (in five-year intervals) (000s tonnes), 2021 – 2038

5.34. In line with national guidance, and the lack of alternative evidence, this is considered to be an appropriate forecast upon which to base the Plan.

Hazardous waste

5.35. The NPPG recommends that forecasts of future hazardous waste arisings should be based on extrapolating historic time series data as information on hazardous waste is considered likely to be robust. The previous Issues and Options consultation considered a single scenario based on waste production over the last 10 years. The latest Waste Needs Assessment maintains this approach but has revised the underlying figures on the amount of waste produced over the last 10 years using data from the Environment Agency's Hazardous Waste Data Interrogator. A single forecasting scenario has therefore been considered as follows:

5.36. Table 4 below summarises the forecast arisings at key intervals during the plan period.

Table 4. Summary of Forecasted Hazardous Waste Arisings (in five-year intervals) (000s tonnes), 2021 – 2038

5.37. In line with guidance in the NPPG, this projection of hazardous waste arisings based on historic time series data is considered an appropriate forecast upon which to base the Plan.

Agricultural waste, mining waste, low-level radioactive waste, and wastewater

5.38. No specific guidance is provided on forecasting future waste arisings for other waste streams such as agricultural waste mining waste, low-level radioactive waste, and wastewater. In most cases these are produced in very small quantities and are capable of being managed at existing facilities. For this reason, it is not considered necessary to make any specific provision for these waste streams. The need for additional waste treatment capacity is usually determined by the regulated water utility companies on a case-by-case basis. Local planning authorities consult the water utility companies during local plan production and on major development proposals and both water supply and disposal requirements are considered as part of local infrastructure delivery plans. To date, no specific requirements have been identified but the Plan will continue to make policy provision for the extension or renewal of existing treatment facilities or the provision of new facilities if required.

Existing Capacity within Plan Area

5.39. In order to ensure sufficient provision to handle the waste arisings forecasted within the plan area, firstly the WNA assesses the amount of waste management capacity that is already available within the Plan area. This is again based on data from the Environment Agency's Waste Data Interrogator which shows the quantity and type of waste which has been received at each facility. In line with national guidance this takes account of those facilities which have planning permission and are operational. This is considered to be more reliable than including facilities which have planning permission but have either not been built or are no longer in use.

5.40. Tables 5 and 6 below provide a summary of existing capacity by type of facility and the waste streams they accept. Further details on the capacity of individual facilities can be found in Appendix F of the Waste Needs Assessment. Due to the way in which waste data is reported through the Waste Data Interrogator, it is not possible to separate the capacity of each facility between LACW and C&I waste streams. This is recorded as a single, category of household, industrial and commercial waste (HIC) for reporting purposes.

Table 5 Existing waste treatment capacity by type in December 2021 (tonnes per annum)

Table 6. Remaining Landfill Capacity by type in December 2021 (rounded to nearest 100 tonnes)

Future waste management methods

(1) 5.41. As well as establishing the level of existing capacity, we also need to consider how waste is likely to be managed in future i.e. the proportions of each waste stream that are likely to be recycled, recovered, or disposed of. This will help to identify the types of facilities needed and whether any new capacity will be required over the plan period. The Waste Needs Assessment sets out the recycling, recovery and disposal scenarios which have been considered for each waste stream. In each case these range from a continuation of current recycling rates, a moderate increase, and a more challenging stretch-target likely to require much wider changes from government, industry, and society as a whole.

(4) Table 7 Recycling Scenarios for LACW

(2) 5.42. The low scenario reflects a continuation of the current recycling rate for LACW and does not take account of additional recycling measures announced by Government such as the separate collection of food waste from all households. The medium scenario represents a considerable improvement on the current recycling rate but still falls short of the national waste strategy target. The high recycling scenario is preferred as this reflects the more ambitious national target and takes account of the future recycling measures which are due to be introduced.

Table 8 Recycling Scenarios for C&I Waste

(1) 5.43. The low scenario reflects a continuation of the current recycling rate for C&I waste and does not take account of proposed measures such as the wider use of Extended Producer Responsibility (customer take-back) schemes. The medium scenario assumes a small increase in the recycling rate over the Plan period. The high scenario is preferred as this reflects a more optimistic target by the end of the Plan period and takes more account of proposed recycling measures.

Table 9 Recycling/Recovery Scenarios for CD&E Waste

5.44. Recycling and recovery rates for CD&E waste are already at a high level. The low recycling scenario assumes a continuation of the current rate but does not take account of potential future improvements. The construction and demolition sector is identified as a priority area to tackle certain waste materials^[3]. The medium scenario assumes an increase in the recycling or recovery of CD&E waste. The high scenario represents a very high recycling and recovery rate for this waste stream and is seen as the most optimistic outcome as the basis for assessing future recycling needs and minimising landfill. This is comparable with selecting the high recycling scenario for LACW and reflects the increasing commercial market for recycled material in the construction sector.

(1) 5.45. The high recycling scenario has therefore been chosen as the preferred option for each of the waste streams. To show what this would mean for future waste management, Table 10 below sets out the tonnages of waste that would need to be recycled, recovered or disposed of each year by the end of the Plan period.

(2) Table 10. Predicted Waste Arisings by Forecast Waste Management Method in 2038 (tpa rounded to nearest 1,000 tonne)

Assessing the need for additional waste management capacity

5.46. By forecasting future waste arisings this enables us to calculate the overall requirement for future recycling, recovery, and disposal capacity. Having established the total requirement, a 'capacity gap analysis' can then be carried out to establish whether or not there is sufficient existing waste management capacity to meet expected future needs. The accompanying Waste Needs Assessment provides a more detailed explanation of this methodology and includes a comparison of the predicted capacity requirement using each of the recycling scenarios considered (high/medium/low).

(2) 5.47. Tables 11 and 12 below show the estimated recycling, recovery, and disposal capacity that would be required at key intervals during the Plan period based on achieving the high recycling scenario for each waste stream. Due to the way in which waste data is reported through the Waste Data Interrogator, it is not possible to separate the capacity of each facility between LACW and C&I waste streams. In practice many facilities which handle LACW waste are also able to take C&I waste and this is recorded as a single, combined, category of household, industrial and commercial waste (HIC) for reporting purposes. The capacity requirement is therefore shown in terms of the total HIC need.

(4) Table 11. Capacity Gap Analysis for HIC Waste Stream (tpa)

Table 12 Capacity Gap Analysis for CD&E Waste Streams (tpa)

(2) 5.48. Based on the preferred high recycling scenario for each waste stream, it can be seen that there is sufficient recycling/composting capacity to manage the Plan area's LACW, C&I and CD&E waste up to 2038. There is though insufficient energy recovery capacity to manage LACW and C&I waste during the first part of the Plan period although This decreases over the life of the plan if the higher recycling scenario is achieved. Planning permission has been granted for up to 892,100 tonnes per annum of further energy recovery capacity that has not yet come forward. If implemented, this non-operational capacity, could help to reduce future landfill disposal requirements.

5.49. Landfill capacity for LACW and C&I waste is effectively exhausted, and the Waste Needs Assessment estimates that up 2.5 million tonnes of waste could require landfilling over the plan period, depending on future recycling and recovery rates. Landfill capacity for CD&E waste is currently adequate but could run out close to the end of the Plan period. Opportunities for future non-hazardous landfill, to manage LACW and C&I waste, are limited within the Plan area due to the underlying geology and groundwater constraints. There may be opportunities for inert CD&Ewaste to be used as backfill to restore f future quarry sites over the life of the Plan. N.B. although the Waste Needs Assessment carried out by Aecom assumes a future landfill rate of 5% for LACW and 10% for C&I and C, D&E, this is a likely maximum to ensure sufficient provision, it does preclude waste being recovered or recycled. If waste was handled higher up the waste hierarchy this would mean there will be less requirement for landfill than envisaged in the WNA. This will be monitored in the Councils Annual Monitoring Reports.

5.50. The WNA does not identify a need for additional waste management capacity for hazardous waste. It is predicted that approximately 108,00 tonnes of hazardous waste will be generated within the plan area in 2038 with sufficient capacity to manage 180,000tonnes of hazardous waste per year. For other waste streams such as agricultural and mining waste, which are produced in relatively small quantities, the WNA concludes that these are capable of being manged within existing facilities and that no additional capacity would be needed to handle these wastes in future.

5.51. In addition to waste recycling, recovery and disposal facilities, waste transfer stations also play an important intermediary role in waste management. Their primary function is to sort and bulk up waste into more efficient loads before moving the waste on to a final destination (e.g. recycling, energy from waste or landfill). Waste transfer capacity is not therefore included in Tables 11 and 12 above to avoid double counting. The WNA concludes that there is currently sufficient transfer capacity to manage750,000 tonnes of HIC waste and 260,000 tonnes of CD&E waste per year. If it is assumed that the same proportion of waste will be managed by transfer stations in future, there will still be a surplus of waste transfer capacity for both HIC and CD&E waste by the end of the Plan.

(1) 5.52. On this basis the Plan needs to consider how to make appropriate provision for additional energy recovery and disposal capacity where required. The Councils carried out a 'call for sites' at the previous Issues and Options consultation stage but very few sites were put forward. This means that it is not possible to make an objective comparison of a range of possible sites. Given this lack of site-specific evidence, the Councils have drafted a criteria-based policy against which to judge future waste management proposals (Policy DM1). This policy is similar to that used in the previous Waste Core Strategy and sets out the types of location that are likely to be considered suitable for the different types of waste use.

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