Uniper

Uniper is a leading international energy company with around 11,500 employees and activities in more than 40 countries. With about 34 GW of installed generation capacity, Uniper is among the largest global power generators. Its main activities include power generation in Europe and Russia as well as global energy trading, including a diversified gas portfolio that makes Uniper one of Europe’s leading gas companies. The company is headquartered in Düsseldorf, being the third-largest listed German utility. Under its new strategy, Uniper aims to become climate neutral in its European power generation by 2035.

In the UK Uniper owns and operates a fleet of seven power stations, including Ratcliffe-on-Soar power station.
Our response to the individual consultation questions is provided below. Our views in summary are:
• The move towards a circular economy and the UK Government’s target to bring all greenhouse gas emissions to net zero by 2050 will present significant challenges and potential opportunities to the waste sector. In this context, long-term projections are very uncertain as policy develops and the waste industry adapts to these changes. The mandatory period of review (at least once in every 5 years) is critical and the review period may need to be shorter. This will ensure the Plan’s overall ambitions can be met while adapting to future changes.

About Ratcliffe
As set out in our Call for Sites submissions, Uniper is bringing forward plans for development of an energy recovery facility (ERF) at the Ratcliffe-on-Soar Power Station site—known as East Midlands Energy Re-Generation (EMERGE) Centre. The facility would generate energy from non-hazardous domestic and commercial waste left over from the recycling process. In addition, Uniper is currently evaluating a proprietary process which we are hoping will improve recycling rates from partially pre-separated waste streams by a further 10–15 %. This process could also be used for production of fuels and chemical feedstocks from waste. If this combination of technologies proves to be economically feasible, we plan to develop an additional project (or projects) at the power station site.

Uniper is proud of the contribution Ratcliffe-on-Soar makes to the East Midlands regional economy. To understand how the site can be part of sustainable growth in the region, Uniper has been working in collaboration with stakeholders, including the Midlands Engine, local councils, universities and Local Enterprise Partnerships.
Our vision is to move towards becoming a zero carbon technology and energy hub for the East Midlands, providing reliable and lower carbon heat and power for use by world-class businesses and institutions, who choose to locate to the site in the future.

The first step in delivering our vision will be the EMERGE Centre, for which we will shortly be applying for planning permission. Information on the EMERGE Centre is available at www.uniper.energy/emerge.

Although our response to the consultation is separate from the planning application for the EMERGE Centre, we thought it would be important to briefly describe our plans openly to avoid any perceived hidden conflict of interests.

Response to consultation questions
Question 1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
In line with paragraph 1.2 of the consultation, we agree that a period of at least 15 years does provide some certainty to the Councils and waste providers. There needs to be flexibility built into the plan to take into account the significant changes the waste sector and Councils will face over the next few years. Some of these changes include the following:
• The move towards a circular economy and the UK Government’s target to bring all greenhouse gas emissions to net zero by 2050 will present significant challenges and potential opportunities to the waste sector. This will most likely be exacerbated by external factors such as taxes for imported waste levied by countries that currently process waste produced in the UK. We expect that the waste industry will go through a period of significant transformation in the next 5 to 10 years, which is extremely difficult to predict;
• Increased reuse and recycling rates, separate collection of food waste, incremental use of renewable raw materials and a landfill ban will all have a significant effect on the amount and composition of waste. The stagnation of household waste recycling rates, failure to meet the 2020 recycling rate target, and the setting of even higher recycling rate aspirations in ‘Our Waste, Our Resources: A Strategy for England’ will require changes that could spur both technical and commercial innovation that would not be predicted by a long plan period; and
• These factors will have an impact at both local and national levels. At present, for example, the number of energy recovery facilities is concentrated in the north of England while the largest amount of waste is produced in the south. There is the emerging view in the industry that movement of waste from south to north will very probably develop and accelerate as a result of the changes described above.

Long-term projections are very uncertain as policy develops and the waste industry adapts to these changes. Accordingly, the mandatory period of review (at least once in every 5 years) is critical and the review period may be shorter. This will ensure the Plan’s overall ambitions can be met while catering for the changes that lie ahead for the waste sector.

Question 2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
No, the information is sufficient.

Question 3: Do you agree with the current waste estimate? Do you have any other information which may lead to a different waste estimate?
We agree with the current waste estimate and methodology used in the plan for local authority collected waste, as this can be estimated in line with projected house numbers across the plan area, and supported by the four scenarios proposed.

We agree with the proposed estimate range for Commercial and Industrial (C&I) waste production arisings across the plan area to increase from 2020 levels (606 kt) to between 740 ktpa and 1.2 Mtpa by 2038. We agree with the methodologies proposed of using local economic forecast reports (such as the awaited D2N2 report) to assist with the local plan forecasting. However, if the local economic forecasts are not available, then the approach proposed within the plan of using a scenario-based approach is a good rationale. We support the requirement for the ongoing evaluation of the estimated levels throughout the plan timeframe, with reviews in accordance with the NPPF requirement of at least once every 5 years. The reviews can identify any significant regeneration or major infrastructure projects which may occur within the plan area over the life of the plan.
The scope to monitor significant changes in C&I waste streams includes the assessment of any significant projects planned within neighbouring counties to allow for ‘overspill’ of waste into the plan area.

To further enhance the data collection process, the Councils should consider using data from third-party sources, e.g. Environment Agency’s Waste Data Interrogator and the statistics on waste published by the UK Government. While these may not provide an accurate forecast for the future, they can be used to refine the scenarios presented later in the consultation.

Question 4: Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
Other than via existing methods of disposal, the plan should consider the potential issue expected from changes in the likely increased utilisation/reuse opportunities of separated waste streams during the life of the plan. We anticipate certain waste streams, such as separated food wastes and non-recyclable plastics, will increasingly become utilised for alternative end use materials during the timeframe of the plan. A review of this potentially new disposal area should be undertaken at each of the 5 year review periods.

Question 5: Do you agree with the scenarios set out for Local Authority Collected Waste (LACW)? Which scenario do you consider to be the most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
We agree with the proposed scenario range provided within the plan, and feel Scenario A (0.5 % growth) is the most realistic estimate of the four scenarios proposed and, therefore, the most suitable scenario to base the local plan against.

The growth in housing as set out in the consultation will result in an increase in waste; each UK person currently produces just below 400 kg of waste per year. However, given the range of measures that are being introduced to tackle the rise in food waste and plastics especially, through taxation or initiatives such as the WRAP Courtauld Commitment (2025), which will be supported by households and businesses, the rise will not reach 1 %. Through the required 5 year review of the plan, the growth or otherwise in waste volumes can be reviewed periodically.

Question 6: Do you agree with the scenarios set out for Commercial and Industrial (C & I)? Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
We agree with the proposed scenario range provided within the plan, and feel Scenario B (2 % medium growth) is the most robust estimate of the three scenarios proposed and, therefore, the most suitable scenario to base the local plan against. The scenarios should be re-evaluated when the expected Local Economic Forecast report has been received by the regional LEP (D2N2).
We agree the plan area is likely to experience growth within the plan timeframe, with the development of new houses, business parks and HS2. The implementation of waste minimisation processes by manufacturers and retailers, and the increasing use of ‘take back’ schemes and repair services is all expected to balance out the extra production with better utilisation.

Question 7: Do you agree with the scenarios set out for Construction, Demolition and Excavation Waste (CDE)? Which scenario do you consider to be most suitable on which to base the Plan? Do you have any evidence to support any other scenarios?
We have no opinion on the expected volumes of CDE waste within the plan timeframe, but by utilising the various data sources available and the 5 year review period, any changes can be accounted for.

Question 8: Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
We have no opinion on the expected volumes of hazardous waste within the plan timeframe.

Question 9: Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan? Do you have any evidence to suggest that different assumptions should be made?
We consider the assumptions of increasing recycling levels across the plan area of 10 % above current 2020 levels by 2038 as a reasonable target.

With only 84 local authorities (2018/19 season) with recycling rates better than 50 % in the UK, recycling is obviously still struggling to gather any commercial momentum. With Nottinghamshire County Council at position166 and Nottingham City Council at position 325 out of 345 UK authorities in the national league table for recycling levels, promoting the improvement in recycling rates should be a key part of the plan, looking to attract companies that can help increase the recycling rates in this area.

Question 10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Paragraph 4.23 of the consultation document contains a series of statements we would like to comment on:
• “Where waste cannot be recycled, using it as a source of energy can provide benefits in terms of generating heat and power. This is more sustainable than simply disposing of the waste and can help to offset fossil fuel use. However, this can raise concerns over the appropriate size of facilities to ensure that they do not ‘compete’ with recycling facilities by locking waste in to long-term contracts.”

There are a number of studies that demonstrate ERFs do not ‘compete’ with recycling facilities and this is set out in a report issued by the Environmental Services Association. The energy recovery process has diverted non-recyclable waste from landfill rather than diverting recyclable waste from recycling. If this point is considered from a practical perspective, it is wholly unrealistic to think that households and businesses that are putting their recyclables in a source segregated recycling bin will decide to stop doing that and instead put their recyclables in the residual waste bin just because there is a new ERF facility somewhere.

As previously stated in our response to Question 2, although the UK has not yet reached ERF market saturation, there is an expectation that an increased number of ERFs could possibly operate as merchant facilities rather than be tied to long-term waste contracts.
• “Currently the UK exports large quantities of residual waste as Refuse Derived Fuel (RDF) to countries in mainland Europe where it is burned for energy. With the UK leaving the EU, the waste industry expects there to be more demand to process and manage this waste as a resource within the UK.”

We agree that current UK waste exports will diminish over time and that the waste industry will have to manage this waste as a resource within the UK. In this respect, we consider that ERFs will play a very important role to ensure that this non-reusable, non-recyclable waste is not sent to landfill.
• “Nottinghamshire and Nottingham currently has 750,000 tonnes of permitted annual energy recovery capacity but only 185,000 of this is operational.”
We strongly believe there is the need for additional energy recovery capacity within the Plan area and beyond in the wider region. (This is why we have decided to bring forward plans for development of the EMERGE Centre). For the Plan area, this capacity gap should be expressed as the minimum capacity required for Nottinghamshire to be net self-sufficient. It should be seen as the minimum that Nottinghamshire should plan for, not as a barrier or limit.

It is well known many permitted projects do not get developed for a range of commercial and technical reasons. Including permitted sites that are not yet in operation in the consideration of the capacity gap makes a false assumption about available capacity to fill the gap. Consideration of the capacity gap should exclude projects with planning permission but not operational, in accordance with National Planning Policy for Waste paragraph 3.

Question 11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
We agree with the requirement to provide some ongoing disposal capacity for certain waste types, which cannot be recovered or recycled, within the Plan area. If the expected CDE waste stream within the Plan area is expected to remain stable, or moderately increase, over the timeframe of the plan, then transporting large volumes of waste outside the area could potentially be subjected to future impacts from any transport limitations on movement of waste.

Future disposal of waste to landfill should first require an assessment of the waste to confirm that it cannot be utilised. Disposal is at the bottom of the waste hierarchy and should therefore be used only when there is no other available option. Economics should not be the main reason for the avoidance of landfill. Any waste which can be recycled, reused, repaired or sent for energy recovery, should be.

Furthermore, by promoting recycling within the local plan and promoting the most efficient use of materials over the lifecycle of the building as part of Nottingham County and City Councils role as planning authorities, it is possible to increase the rates of recycling of construction and demolition rates. The consequence of this will be a reduction in the volume of material that needs to be disposed of.

Question 12: Do you agree with the draft vision? Are there other things we should include?
In principle, we agree with the draft vision and would suggest the plan would be further enhanced if it includes a commitment to the wider UK Government target of net zero by 2050. For example, the statement could be written as:
To promote a modern and effective waste management industry, protect Nottinghamshire’s and Nottingham’s environment, wildlife and heritage and minimise the effects of climate change, thus contributing to the UK’s journey towards net zero by 2050.

Question 13: Are the above objectives appropriate? Are there others we should consider?
Yes, the objectives are appropriate.

Question 14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
We do not propose any other options. However, the Plan should recognise that the waste industry will face transformational changes with the development of a circular economy. It is important that proposals for broad locations of future waste management facilities do not inadvertently influence planning decisions on waste developments against the circular economy, as well as the UK Government’s 2050 net zero target.

Question 15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
In accordance with NPPW paragraph 4, the Plan should identify sites and/or areas for new or enhanced waste management facilities in appropriate locations. To do so it should allocate specific sites, particularly those deemed suitable from the Call for Sites process. Each allocation should (again NPPW paragraph 4) identify the broad type or types of waste management facility that would be appropriately located on the allocated site or in the allocated area, taking care not to be overly prescriptive so as to avoid stifling innovation. Allied with the allocations, there needs to be a criteria based policy to cover waste developments that might come forward on unallocated sites. The criteria in such a policy should mirror the criteria for choosing the allocations, such that there can be consistency in decision making and schemes that meet the criteria can be given equal weighting to those on allocated sites.

In making the allocations, particular regard needs to be given to NPPW paragraph 6 which deals with the Green Belt. In short, this is entirely permissive of allocating sites / land in the Green Belt where the development would be appropriate development in the Green Belt.

Question 16: What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
The proposals for the scope of the development management policies are satisfactory.

Question 17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
No further comments.