The Waste Needs Assessment (WNA) indicates that 1,186,000 tonnes of Construction, Demolition and Excavation (CD&E) waste arose in 2018 and assumes that the same amount will arise every year during the Plan Period (2019-2038). It further estimates a residual amount (after re-use or recycling) of 20% or 237,000 tonnes, which will need to go to landfill. Furthermore, the WNA projects that landfill capacity will run out well before the end of the Plan Period (early 2030s).

We note that only one landfill facility (Vale Road Quarry) exists in the Plan Area to take this residual CD&E waste and that this is relatively remote from the main area of greatest demand, being the conurbation around Nottingham. We consider that a site for the disposal of CD&E waste nearer Nottingham should be allocated to meet otherwise unmet need before the end of the Plan Period and to increase compliance with the proximity principle (and draft Policies SP4 and SP5).

To this end, we object to the omission of land adjacent to Shenton Lodge, Derby Road, Kirkby-in-Ashfield, Nottingham as an allocation for sustainable CD&E waste landfill. The site has previously been the subject of planning application reference F/3080 for this use and assessments of topography, ground conditions, flood risk, transport, dust, landscape and ecological impacts have been undertaken and restoration plans prepared. We provide these reports by separate email.

We consider that the lack of available alternatives outside of green belt to meet the identified need would constitute the exceptional circumstances necessary for removal from green belt in accordance with NPPF paragraphs 140 and 141.