Comment

Representation ID: 787

Received: 04/04/2022

Respondent: Mick George Ltd

MGL’s view is that the circumstances of a site (i.e. whether it is an acceptable planning solution)
should determine whether it should be filled with inert waste, whether it termed a recovery operation or a landfill. Indeed, it is not logical to declare an inert landfill as not a land recovery operation since the environmental impact of it is almost exactly the same as a recovery operation (or better because of improved investment in infrastructure) and the end result of it is largely the
same – land reclamation.
11. It is MGL’s view that to not plan for some specific inert landfill but to rely wholly on recovery projects is both unwise and risky, especially in view of the high levels of imports to recovery operations.
12. To illustrate this point, we present an analysis of the 2020 WDI data for Notts inert waste landfill and recovery below.
(See accompanying document)
13. This clearly shows that there is not a hair’s breadth between the two types of site in terms of the
proportion of input which is soils, which is exceptionally high. However, when it comes down to the
source of the waste, the inert landfills take in a much higher proportion of local waste than do the
recovery operations, even allowing for the unspecified nature of the source of inputs to Vale Rd
landfill. Even if half of the Vale Rd input came from outside the county, the combined effect would
still be much higher than the recovery operations. The reason why recovery operations commonly
draw material from further afield is that they often have much lower operating standards than
landfills and can compete with material more easily, and they are often governed by a strict
timetable to complete operations and thus prioritise input quantities over profitability. However,
this is not to deny that recovery operations supply a valuable service even if it is focused outside the
county.
14. The outcome of this argument is that we consider that the capacity gap analysis presented in Table
12 severely under‐estimates the need for inert waste disposal capacity. The arisings for CD&E waste are already in 2019 in reality much higher than the Plan’s 2019 figure of 207,700 tonnes. Taking
both types of site and allowing a 50% share of Vale Rd’s input from local sources, leads to a
combined arising and deposited figure of the order of 226, 800 tonnes. Unless recovery operations
of the required magnitude, frequency and location come forward, it is unlikely that this type of
waste management could deal with all arisings and imports, and that some capacity for inert landfill
will be needed for the foreseeable future, especially for the south west of the county where the bulk
of arisings occur.