Comment

Representation ID: 786

Received: 04/04/2022

Respondent: Mick George Ltd

Scenarios – CD&E Waste
7. Defra’s UK Statistics on Waste 2021 shows that in 2018 the recovery rate for non‐hazardous CD
waste in England was a remarkable 93.8% (Table 5 Recovery rate from non‐hazardous construction
and demolition waste, UK and England, 2010‐18). This confirms that CD waste recycling/recovery is
already at the maximum which was reiterated by the Minerals Products Association’s February Press
Release on the subject of Recycled aggregates in the UK market, (which was shared by all the AWP
secretaries). The Defra report also says that “The largest waste material categories generated in the
UK in 2018 were ‘Mineral Wastes’ (80.4 million tonnes), and ‘Soils’ (58.5 million tonnes). Together,
these make up almost two thirds (63%) of total UK waste.” (page 13) In addition, Table 9 shows that
55% of recycled or recovered materials comprise mineral wastes whilst 90% of backfilled materials
are soils, and 58% of all landfill are soils.
8. The draft plan notes that recycling and recovery rates for CD&E waste are already at high levels
(paragraph 5.43). We have examined the recycling/recovery scenarios for CD&E waste presented in
Table 9 and find them confusing. The table asserts that in the ‘business as usual’ scenario there is no
change to current recycling/recovery rates of 82.6%. This may be true of CD wastes which nationally
have reached saturation levels, but it is certainly not true of E waste. If an 82.6% recycling/recovery
rate is applied to the county arisings in Table 3 then the landfill element of arisings would be
206,000 tonnes. The high recycling scenario posits a 95% recycling/recovery rate by 2038 leaving a
residue of 59,000 tonnes to landfill each year (Table 10).
9. We find this very unrealistic. This would require the recovery of not only all of the hard CD wastes,
but almost all of the soft E wastes as well, which in turn would depend on a steady supply of
licensed land recovery operations. Experience shows that these are either short lived, or are
constrained by operational considerations. For example, the Harworth Tip recovery project on the
Doncaster border is too far away from the centre of the county where the bulk of inert wastes are
generated, and the reliance on this site for recovery of the majority of Nottinghamshire’s inert
waste arisings is not practicable. Similarly, for the recovery rates to be reliably complied with new
projects will have to come forward as older sites are completed, such as Bentinck Tip, Styrrup
Quarry and Coneygre Farm.