I welcome the opportunity to comment on the draft plan. I am doing so in the form of an email because I find the online process cumbersome and hard to use – even though I as a rule prefer the online approach.

In general, I find the document short sighted and lacking in ambition, as well as hard to read and extract the key points from. It seems to be written and laid out specifically to discourage engagement and comments. However, I have some specific points to make:

1) I am particularly interested in anaerobic digestion of food waste in combination with sewage sludge and other suitable waste materials. The current gas price crisis highlights the opportunity to solve at least two problems at the same time, and makes it a good investment for the Pension Fund in place of fossil fuel companies. I am strongly against incineration in general, and for food waste in particular.

2) Reduction of greenhouse gases should be a key policy

3) Recycling rates should be more ambitious and specific measures should be put in place to promote waste reduction

On some of the individual parts of the document:

Circular economy, para 3.3: I support the principle of using waste as a resource, as above.

Waste hierarchy, para 3.6: Government policy requires anaerobic digestion of food waste to be considered higher in the hierarchy than incineration (and AD should be included under “recycling” not “other recovery”)

Recycling scenarios for local authority collected waste, para 5.40, Table 7: The Waste Framework Directive target of 65% by 2030 should be the minimum and the plan should aim to provide recycling facilities to at least achieve this.

Strategic Objective 1 – Acting on climate Change: (This refers to “avoiding damage to air quality, water or soil” but makes no makes no reference to limiting greenhouse gas emissions.) Representations on the previous round of consultation “suggested greenhouse gas emissions should be explicitly referenced and this objective should be connected with delivering more innovative waste solutions to meet climate change commitments”. This Strategic Objective should aim to minimise greenhouse gas emissions.

Policy SP2 – Future Waste Management Provision: Support “Priority will be given to the development of new or extended recycling, composting and anaerobic digestion facilities”. Priority should also be given to re-use and repair facilities.

Policy SP5 – Climate Change: (As with Strategic Objective 1 the policy makes no reference to greenhouse gas emissions.) Para 7.47 does say this could include “Minimise greenhouse gas emissions . . .” but this should also be included in Policy SP5. Any reference to supporting “low carbon energy” should note that incineration of waste typically emits around a tonne of CO2 for every tonne of waste and cannot be considered to be “low carbon”.

Appendix 1 – Monitoring and Implementation Framework, SP2: Monitoring for Future Waste Management Provision should include monitoring waste composition because this will be important for planning the balance of waste management facilities.

Appendix 1 – Monitoring and Implementation Framework, SP5: Monitoring for the Climate Change policy should include monitoring greenhouse gas emissions, including from landfill and incinerators.