Introduction
New Waste Local Plan
Nottinghamshire County Council and Nottingham City Council are working together to prepare a new Waste Local Plan which will replace the previous Waste Local Plan (2002) and the Waste Core Strategy (2013).
The new Waste Local Plan will provide the future planning strategy for waste management in Nottinghamshire and Nottingham until 2038 and will aim to provide sufficient capacity to meet future needs. It will also provide key policies against which future waste development will be assessed.
To help shape the plan, we will be seeking the views of local people, businesses and organisations on the key issues that the plan will need to focus on. The first stage of the review will be a consultation on an Issues and Options document which will run from 27 February until 7 May 2020.
Proposed responses.
Q1: 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?
We consider this is too short a timeframe when the Government’s NetZero legislation is taken into consideration. Whilst the “core” plan can cover the period up to 2038, there needs to be real long-term vision incorporated into this plan. It is likely the “waste” landscape will change dramatically over this period as our economy strives to become more sustainable and pressure on the worlds resources increases. Thus any plan and strategy needs to be able to adapt and be a living document in order to best serve residents, businesses and public authorities.

Q2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
The predicted impacts of climate change on the Plan area should also be included, flooding has been mentioned, but there may be other impacts. Also development plans such as the aligned core strategy for Nottingham will provide an indication of growth which also needs to be included.
Q3: Do you agree with the current waste estimate? Do you have any other information which may lead to a different waste estimate?
The waste estimate seems to be very much along the lines of business as usual (BAU). Evolution of packaging, pressure to reduce plastic, changes to local business types, output and evolution of a low carbon economy, we consider will change the volumes and nature of waste produced. These must be considered, the plan has to have forward vision, and also a degree of ambition to lead growth by anticipating and providing the types of facility and capacity to deal with this. There may also be opportunities to be capitalised upon.
Q4: Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
The information about waste types and recycling rates provided is limited and highlights a lack of knowledge, measurement and recording. Good data is the first step at assessing future needs. Quoting national estimates such as for commercial waste (C & D) is imprecise. Trend analysis and future projections, which also take into account projected changes in waste types, quantities is required if the plan is to be sound.
Q5: 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 would like to think scenario A, declining growth is the most likely as governments 25 Year Environment plan and other policy measures to move towards Net Zero take effect, people become more aware and products, services etc evolve. You consultation talks about overall quantities, not types and composition of this volume. This information is required if the correct suite of options for optimising the use this waste is put to.
Q6: 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 do not have any evidence to determine which scenario on which to base the plan. This needs to be linked to growth strategies for the Commercial and Industrial sectors.
Q7: 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 do not have the information with which to make comment.
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 agree it is correct to assume recycling rates and the use of manufacturer take back schemes will increase. What your consultation is not considering is any change to the makeup of waste such as through the introduction of new or emerging products such as increased use of plant based products for manufacture and packaging, changes in consumer buying patterns and product mix as part of a natural evolution. An example is the growth in personal IT and communications equipment in recent years and how this is making older infrastructure such as fixed telecommunications equipment redundant or needing to be repurposed. Will changes to the way people live, work and socialise also result in change. A forward thinking plan needs to consider such factors.
Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery is valuable part of the mix, but as a last resort option, not an easy option. Resource efficiency has to be the first priority with recycling and recovery. Where energy recovery is adopted, then it must be as part of an integrated scheme where all the generated energy can be recovered and used to offset in the first instance energy produced from fossil fuels. Where feasible mineral and other resources contained within the ash need to be mined and recovered, with the final residue becoming a product, not a waste. Such infrastructure requires large amounts of capital and technology along with the expertise to develop and manage it. Thus there is a need for a longer term vision than 2038, and a linkage to other strategies such as those for developing technologies, innovation and skills.
Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
There should be some additional disposal capacity within the Plan Area, not only to reduce transport as highlighted, but also to provide resilience and reassurance for those investing within the Plan Area that there needs can be met at an affordable cost in the future.

Vision
Our vision is for the Plan area to be sustainable in waste management, by encouraging businesses and communities to see the value of waste as a resource and take responsibility for their own waste by managing waste locally wherever possible.
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.
To protect the quality of life of those living, visiting and working in the area and to avoid any risks to human health. Stress the importance of the waste hierarchy and the circular economy to prevent and re-use waste as a resource wherever possible and meet, and preferably exceed recycling rates for Nottinghamshire and Nottingham.
Q12: Do you agree with the draft vision? Are there other things we should include?
We do agree with this vision, but feel it could go further. It should do more than “promote and modern and effective waste management industry”, it has to stimulate a sustainable waste management industry, encourage innovation and solutions which could also be beneficial to the economy and society as a whole.
Further the Plan needs to be integrated into other plans, objectives and strategies, not seen as a standalone item.
Q13: Are the above objectives appropriate? Are there others we should consider?
These objectives are appropriate; they should be at the start of the Plan, not near the end so it is clear from the start what is trying to be achieved.
Skills are omitted, not only for those working and delivering waste management, recycling and recovery, but for those who generate waste so they have a greater understanding of the impacts of their actions and start to embed a culture of thinking about the consequences of actions and how reuse, recycle and recover can be applied.
Q14: 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?
The proposed broad locations are logical. Whilst transport is an issue, note should be taken of facilities and plans in neighbouring areas seeking opportunities and efficiencies, perhaps sharing or partnership arrangements so that better investment decisions can be made to enable a better outcome.

Q15: 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?
A general criteria approach will provide flexibility to better serve the objective which is important in an evolving area such as waste management. This will also allow the best sites for facilities to be brought forward, and unsuitable one dismissed. The plan needs to show leadership where the preferred localities are and the types of facility required to best serve needs together with projections of change overtime as we move to a more circular economy, implement the 25 Year environment plan and its successor, and strive for NetZero by 2050.
Q16: 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 list is comprehensive. We consider that it should also include the support of commercial, academic and social activity as part of the local economy in order for the Plan to be wholly appropriate and provide opportunities and solutions.
Flooding and water resources are mentioned, water and soil quality are omissions and should be included.
Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
We consider that we have included comments within our responses. The Plan contains no reference to contingencies; the current Covid-19 pandemic shows how easy it is for disruption to occur in a very short time-frame. The Plan should be aligned with any current or future contingency planning or strategy for the area and country as a whole.
We thank you for the opportunity to comment.