Question 12

This is a good vision but needs to be properly acted upon with a huge effort from everyone.

All a bit understated.

Need much more on waste reductio
& improved recycling driven by better integrated collection & disposal systems (universal across area), including compulsory food waste collections and better kerbside offereg glass at kerbside(unless deposit return will remove need) & much better HRC facilities. Many eg Retford are obsolete, especially when compared to Gainsborough in Lincolnshire (which is marginally closer, but not available).

Agree.

Yes agree with this wording.

We believe that the Vision should include a reference to Climate Change Action and how a waste disposal strategy can contribute.

Yes agreed.

Q1 – why not tie in with UK carbon budget cycle?

https://researchbriefings.files.parliament.uk/documents/CBP-7555/CBP-7555.pdf

Q12 – vision should be aligned with need to make deep and urgent cuts to our GHG emissions, so as to remain with our notional fair share of available carbon budget in order to constrain global temperature rise to less than1.5 degrees by 2100

It doesn’t say anything about repair? And could it say something about the more informal or community based waste reduction economy. I appreciate it is about planning – but does a circular economy need land-use planning to allow for facilities we have yet to envisage, or have thought about, but aren’t there yet? And that ideally need to be developed locally rather than off shoring both extraction, production and a lot of the distribution of goods and also the recycling, reprocessing, re-purposing, repairing, etc etc

Waste Local plan Consultation on issues and Options response from Stapleford Town Council

Below are Stapleford Town Councils responses to the questions in the consultation document.

Q12: Do you agree with the draft vision? Are there other things we should include?

Generally, the vision is too passive. The vocabulary used, such as encourage and promote, is too vague. Both the County Council and City council have the capacity to act as agents of change, initiate schemes for businesses, deliver a modern and effective waste management industry. The Annual Monitoring Report shows that no action was taken on policy WCS9 “New waste management technologies are developed to ensure increased efficiency and sustainability” highlighting a lack of ambition. Section 2.7 states “The new waste local plan deals with waste that has already been produced and there are many factors that influence waste production that are outside the remit of the waste local plan.” However, both Councils have a great deal of authority and can proactively influence waste and recycling rates for Nottinghamshire and Nottingham. We acknowledge that the consultation document is positive in its approach to waste management but feel its vision could go further beyond coping with the waste produced.

Q13: Are the above objectives appropriate? Are there others we should consider?

Objective 1 climate change: This objective does not explicitly mention Greenhouse gas emissions. An objective should be that specific waste types will be processed by the method with the lowest net Greenhouse gas emissions. The statement “avoiding damage to air quality, water or soil, reduce the need to transport waste” should be removed from this objective as these issues are mentioned in objectives 3 and 7.

Additionally, the statement “encourage the efficient use of natural resources by promoting waste as a resource,” should be a separate objective and include proactively working to reduce the net amount of waste produced.
Objective 6 High quality design and operation: It is noted in the Annual Monitoring Report that the facilities for energy recovery are only 25% operational. This objective should include maintaining efficiency of facilities so that they can operate at full capacity.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?

In response to the Sustainability Appraisal Scoping Report.

Table 1 key messages from documents review, page 19-20 climate change, does not consider the fugitive greenhouse gas emissions of the waste, only the emissions from the development and infrastructure used. As 2.10 states the goal is to become net zero for all greenhouse gas emissions by 2050. Nottingham City Council is also aiming to be the first carbon neutral city in the country by 2028, these emissions must be considered.

Table 2 Sustainability Issues page 42 states that “Methane from landfill is also a potent greenhouse gas along with potential emissions from incineration and other types of thermal treatment” the plan however makes no attempt to address this issue.

As such objective 7 of the SA proposed indicators (page 50) should include emissions from existing as well as new sites.

https://www.nottinghamshire.gov.uk/planning-and-environment/waste-development-plan/new-waste-local-plan

Since a main driver of the Waste Local Plan is to facilitate the movement of waste up the waste hierarchy consideration should be given to referencing the hierarchy earlier on in the Vision. We believe wording in the second paragraph could be amended to read: "minimise the effects of negative climate change".

Dear Sirs
RE: CONSULTATION ON THE ISSUES & OPTIONS VERSION OF THE COUNTY COUNCIL AND NOTTINGHAM CITY COUNCIL NEW JOINT WASTE LOCAL PLAN – RESPONSE BY PEEL L&P ENVIRONMENTAL LTD

We are pleased to provide our comments on the Issues and Options version of the new Joint Waste Local Plan (WLP) and set out below our responses on the questions contained therein. We have also responded on the call for sites and promoted land at Bilsthorpe Business Park, which is subject to an extant consent for an Energy from Waste (EfW) facility, and on which the Councils rely (as existing non-operating capacity) in Table 6 of the Preliminary Waste Needs Assessment.

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 believe the period to 2038 is appropriate and note, that in accordance with NPPF paragraph 33, the WLP needs to be reviewed at least every 5 years through this period.

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?
We have no comments.

Q3: Do you agree with the current waste estimate? Do you have any other information which may lead to a different waste estimate?

We are in general agreement with the waste quantities estimated on the assumption they are derived correctly from stated source and proper account has been given to imports / exports from the WLP area.

Q4: Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?

We note that 2018/19 household waste recycling data is now available and the more contemporary data should be used as the WLP moves forward. The LACW data for the City Council looks high bearing in mind in 2018/19 they only achieved 26.5% recycling for household waste. See: https://www.letsrecycle.com/councils/league-tables/2018-19-overall-performance/

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?

The scenarios offer a good range. Based on patterns over the past 10 years (household waste grew by only 2.2% 2010-2017)1 we consider scenario B is most realistic i.e. the quantity of waste produced per household will be broadly static, albeit with economic boom and recessionary peaks and troughs, but overall LACW will increase over time as there is growth in the number of households .

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?

The scenarios offer a good range. We consider something around scenarios A and B is most realistic. We note DEFRA estimated C&I growth for 2010-2016 was an average of 1.5% per annum.

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 have no comments.

Q8: Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?

We have no comments.

Q9: 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 that recycling rates are capable of increasing by circa 10% over the WLP period, but this requires quite significant intervention and implementing all of the measures in ‘Our Waste, Our Resources; A Strategy for England’ (DEFRA 2018). Achieving circa 50% household waste recycling and circa 65% C&I waste recycling by the end of the WLP period would be in line with Tolvik national modelling.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?

We suggest the WLP amends the terminology used. ‘Recovery’ includes recycling and we believe what is being referred to here is, for the purposes of the waste hierarchy, ‘other recovery’. However, we suggest the term ‘energy recovery’ is adopted as it is likely to be better understood.

The RDF export market has contracted more drastically than the WLP indicates. With measures such as the Dutch introduction of a €31-per-tonne tax on the import of waste into the country for incineration, in January 2020, it is forecast that RDF exports will radically decrease.
Further, the UK’s commitment for Net Zero by 2050 requires the elimination of ‘off-shoring’ waste.

Further, the UK is still landfilling large quantities of waste that could be subject to energy recovery.

Accordingly, there will be an increased role for energy recovery in the future.

Finally, we note that the extant Waste Core Strategy aims for Nottingham & Nottinghamshire to be ‘self-sufficient’, but there is less emphasis on this in the emerging WLP and Preliminary Waste Needs Assessment. In terms of energy recovery infrastructure, we make two points on this matter:
• We believe it is important that Nottinghamshire actually delivers more energy recovery infrastructure within the WLP area.
• As the UK moves towards delivering its final energy recovery capacity, which will occur in the WLP period, the WLP must be flexible and recognise that the latter EfW facilities will undoubtedly rely on wider catchment areas to ‘mop up’ the remaining residual waste. Thereafter there will probably be an element of geographic rebalancing as waste contracts expire and are replaced. Accordingly, the WLP must be permissive of the potential for residual waste to be exported into the Plan area, where such a movement supports the delivery of new energy recovery infrastructure that can also be used for the management of the City’s / County’s waste. Such an approach is entirely consistent with national Government strategy which specifically acknowledges that there is nothing in the legislation or the proximity principle that says accepting waste from another council, city, region or country is a bad thing and indeed in many cases it may be the best economic and environmental solution.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?

We have no comments.

Q12: Do you agree with the draft vision? Are there other things we should include?

We generally support the draft vision, but believe the reference to managing waste locally wherever possible, should relate to complete waste management not, for example, simply managing by bulking the waste and exporting it out of the County. The vision might want to be tweaked to reflect this objective.

Q13: Are the above objectives appropriate? Are there others we should consider?

We believe 6 of the 7 objectives are appropriate and 1 new objective should be provided:
• With: UK household waste recycling rates effectively flat for the past 7 years at 44-45%; the 2020 household waste recycling target being missed by a margin; the move to a circular economy; and Net Zero commitments; the waste sector needs to innovate like never before. Such innovation will be delivered during the WLP period particularly, for example, in the management of plastics and WEEE. Accordingly, the WLP needs an objective to embrace, support and deliver, innovative waste management solutions and infrastructure which will help achieve our sustainable waste management and climate change commitments.
• Objective 7: Sustainable Transport, effectively mirrors Waste Core Strategy Policy WCS11. This Policy (and the objective) fundamentally misunderstands the dispersed nature of waste generation and the movement of the vast majority of the UK’s waste. In short, we believe that Policy WCS11 has never delivered an operational waste management facility that uses rail or water with Nottingham / Nottinghamshire. The ability to utilise rail is dependent upon residual waste being loaded, or being able to be loaded, onto the railway in the first place. At the present time there is no merchant waste on the rail system looking for a home and there are very few rail connected transfer facilities that have capability to load residual waste. Those that exist are all tied up on specific, long term, PFI type local authority contracts. The same is true with water. Whilst objective 7 is less stringent than WCS Policy 11 in terms of non-road based transport, it also seeks to put waste facilities close to where waste arises. Clearly, this is only possible in the very broadest sense as waste generation is so widely distributed. Further, it then seeks to put waste facilities close to the end markets. Given that end markets frequently change and end markets may be no where near where the waste arises, we find the objective unhelpful. We suggest it is re-drafted or removed.

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?

We support the approach currently adopted in the Waste Core Strategy for broad locations. We suggest that if Waste Core Strategy Plan 4: Key Diagram is adopted, the County’s main roads are added with fairly broad lines. This will enable waste facilities serving more than one settlement, but located between then on or close to a main route, to be supported.

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?

National Planning Policy for Waste (NPPW) paragraph 4, requires the WLP to identify sites and / or areas for new or enhanced waste management facilities in appropriate locations. We believe the requirements of NPPW are best met through the allocation of specific sites, arising from the call for sites process. Each allocation should identify the broad type or types of waste management facility that would be appropriately located on the allocated site or in the allocated area, taking care not to be overly prescriptive so as to avoid stifling innovation.
We believe that there also needs to be a criteria based policy to cover waste developments that might come forward on unallocated sites. The criteria in such a policy should mirror the criteria for choosing the allocations, such that there can be consistency in decision making and schemes that meet the criteria can be given equal weighting to those on allocated sites.

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?

We have no specific comments on the proposed scope of development management policies, but note, as per our response to question 13, that the policies should not stifle innovation.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?

Our overarching comment, as per our response to question 13, is that the WLP needs to be sufficiently flexible to be able to support and deliver, innovative waste management solutions and infrastructure which will help achieve sustainable waste management and climate change commitments.

We trust the foregoing will be given due regard in the ongoing preparation of the new WLP.
Yours faithfully

NOTTINGHAMSHIRE AND NOTTINGHAM WASTE LOCAL PLAN - ISSUES AND OPTIONS DOCUMENT AND SUSTAINABILITY APPRAISAL (SA) SCOPING DOCUMENT

Thank you for the opportunity to engage with the above consultation. As the Government’s adviser on the historic environment Historic England is keen to ensure that the conservation and enhancement of the historic environment is fully taken into account at all stages and levels of the development plan document.

Please find below our comments on the Issues and Options document and the SA Scoping document.

Issues and Options Document

We have set out responses to questions which are relevant to our remit below.

Q2: Overview of Plan and implications for the management of waste

The historic environment is not mentioned in paragraphs 3.2 - 3.12 and it is recommended that it is represented as an issue within the Plan. Nottingham City and the District and Borough Councils in Nottinghamshire include a rich variety of heritage assets and any impact on these assets would need to be considered by the Plan as it progresses.

Q4: Managing waste streams; and,
Q7: CDE Scenarios

Historic England’s 2019 Heritage Counts report focuses on reuse and recycling buildings to reduce carbon and highlights alternative opportunities to demolition of existing fabric and new build which produces C, D and E waste. This information may be of use as evidence base information for the PPP section of the Sustainability Appraisal associated with the Plan in respect of the above questions. In addition the 2019 report includes reference to the work undertaken by Poyntons, commissioned by Nottingham City Council, in respect of new homes over commercial uses in existing built fabric. This may be of relevance to CDE waste scenarios and any economic outcomes from the current pandemic situation. Links to relevant web pages and information are as follows:

<https://historicengland.org.uk/whats-new/news/recycle-buildings-tackle-climate-change/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

Q10: Energy recovery options

It is recommended that any new sites identified for potential energy recovery facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q11: Additional disposal capacity

It is recommended that any new sites identified for potential additional disposal facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q12: Draft vision

The inclusion of heritage protection within the draft vision is welcomed.

Q13: Plan Objectives

Objective 3 relates to the environment and refers to built and natural heritage. It is recommended that this be revised to read ‘built, historic and natural environments’ or a similar alternative. At present, ‘built heritage’ refers only to buildings in respect of the historic environment and any buried archaeological remains would not be included in the Plan objectives contrary to the requirements of the NPPF.

Q14: Broad locations for future waste management facilities

It is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q15: Future provision - general criteria or specific site allocation

Whichever approach/approaches is/are used in the Plan for future provision, the Plan will need to demonstrate a positive approach to the historic environment and that its future provision requirements are achievable and deliverable in respect of the historic environment. As with previous question responses it is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q16: Scope of Development Management policies

The inclusion of a heritage policy in respect of decision making is welcomed.

Sustainability Appraisal Scoping Report

We have set out responses to questions which are relevant to our remit below.

Q1: SEA and SA requirement explanation

It is noted that para 1.3 refers to our natural, built and historic environment and the inclusion of both ‘built’ and ‘historic’ environments are welcomed.

Q2: Methodology

The proposed methodology is noted and we would welcome opportunity to engage with you further in due course, as the Plan and SA develop, in respect of any assessment criteria for the historic environment.

Q3: Appendix 1 relevant documents

In respect of the Historic (environment?) and cultural heritage section it is recommended that the following Historic England documents are referred to:

<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1/>

<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

<https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

It is noted that Historic Landscape Characterisation is referred to in the Landscape section and this is welcomed.

Q4: Key messages

In respect of the Historic (environment?) and cultural heritage section the key messages do not sit well with NPPF requirements in respect of the differentiation of substantial and less than substantial harm. If this is not reconciled in the SA it may have implications for the Plan in respect of soundness at a later stage. We would be happy to discuss this with you further in due course.

Q5: Implications for SA Framework

In respect of the Historic (environment?) and cultural heritage section the last part of the SA Framework implication does not sit well with NPPF para.199 which states that ‘the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted’. This could perhaps be addressed by amended wording in line with that contained in the key messages section Bullet Point 6 (BP6).

Q6: Baseline data

It is recommended that Grade II listed buildings are included in the baseline information in addition to non-designated heritage assets and setting including any locally listed assets. It is also noted that there is no reference made to Cresswell Crags which is on the tentative list for World Heritage Sites.

Q7: no response

Q8: Key characteristics

It is recommended that the Historic Environment and Cultural Heritage section refers more fully to its archaeological past and include reference to Cresswell Crags.

Q9: Sustainability issues; and,
Q10: Significance

The issues for the historic environment and cultural heritage are noted and the moderate/high significance to the Plan is accepted.

Q11: Plan influence on issue

The influence set out for the historic environment and cultural heritage is noted. It is recommended that ‘preservation’ be replaced with ‘conservation’ since all heritage assets are covered by the issue and would be in line with NPPF terminology.

Q12: SA Objective

The SA objective in respect of the historic environment and cultural heritage is welcomed in respect of the Waste Plan.

Q13: Decision making criteria and proposed indicators

In respect of the historic environment the decision making criteria are noted. It is recommended that an additional indicator relating to opportunities for enhancement and better revealing of assets is included and that non-designated assets are referred to in a separate indicator.

Q14: Other comments on Scoping Report

We are not convinced that the Internal compatibility of the SA objectives set out in Table 6 is an accurate reflection of the synergy the Historic Environment SA objective has with other SA objectives. At present it is indicated as linking with SA objectives 1, 5, 6 and 9 as well as itself (4). However, it is an iterative process and we look forward to working with you on the Plan and its SA as it progresses.

Should you have any queries please do not hesitate to contact me.


Yours sincerely,

We support the principles set out in the draft vision.

Uniper

Uniper is a leading international energy company with around 11,500 employees and activities in more than 40 countries. With about 34 GW of installed generation capacity, Uniper is among the largest global power generators. Its main activities include power generation in Europe and Russia as well as global energy trading, including a diversified gas portfolio that makes Uniper one of Europe’s leading gas companies. The company is headquartered in Düsseldorf, being the third-largest listed German utility. Under its new strategy, Uniper aims to become climate neutral in its European power generation by 2035.

In the UK Uniper owns and operates a fleet of seven power stations, including Ratcliffe-on-Soar power station.
Our response to the individual consultation questions is provided below. Our views in summary are:
• The move towards a circular economy and the UK Government’s target to bring all greenhouse gas emissions to net zero by 2050 will present significant challenges and potential opportunities to the waste sector. In this context, long-term projections are very uncertain as policy develops and the waste industry adapts to these changes. The mandatory period of review (at least once in every 5 years) is critical and the review period may need to be shorter. This will ensure the Plan’s overall ambitions can be met while adapting to future changes.

About Ratcliffe
As set out in our Call for Sites submissions, Uniper is bringing forward plans for development of an energy recovery facility (ERF) at the Ratcliffe-on-Soar Power Station site—known as East Midlands Energy Re-Generation (EMERGE) Centre. The facility would generate energy from non-hazardous domestic and commercial waste left over from the recycling process. In addition, Uniper is currently evaluating a proprietary process which we are hoping will improve recycling rates from partially pre-separated waste streams by a further 10–15 %. This process could also be used for production of fuels and chemical feedstocks from waste. If this combination of technologies proves to be economically feasible, we plan to develop an additional project (or projects) at the power station site.

Uniper is proud of the contribution Ratcliffe-on-Soar makes to the East Midlands regional economy. To understand how the site can be part of sustainable growth in the region, Uniper has been working in collaboration with stakeholders, including the Midlands Engine, local councils, universities and Local Enterprise Partnerships.
Our vision is to move towards becoming a zero carbon technology and energy hub for the East Midlands, providing reliable and lower carbon heat and power for use by world-class businesses and institutions, who choose to locate to the site in the future.

The first step in delivering our vision will be the EMERGE Centre, for which we will shortly be applying for planning permission. Information on the EMERGE Centre is available at www.uniper.energy/emerge.

Although our response to the consultation is separate from the planning application for the EMERGE Centre, we thought it would be important to briefly describe our plans openly to avoid any perceived hidden conflict of interests.

Response to consultation questions
Question 1: 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?
In line with paragraph 1.2 of the consultation, we agree that a period of at least 15 years does provide some certainty to the Councils and waste providers. There needs to be flexibility built into the plan to take into account the significant changes the waste sector and Councils will face over the next few years. Some of these changes include the following:
• The move towards a circular economy and the UK Government’s target to bring all greenhouse gas emissions to net zero by 2050 will present significant challenges and potential opportunities to the waste sector. This will most likely be exacerbated by external factors such as taxes for imported waste levied by countries that currently process waste produced in the UK. We expect that the waste industry will go through a period of significant transformation in the next 5 to 10 years, which is extremely difficult to predict;
• Increased reuse and recycling rates, separate collection of food waste, incremental use of renewable raw materials and a landfill ban will all have a significant effect on the amount and composition of waste. The stagnation of household waste recycling rates, failure to meet the 2020 recycling rate target, and the setting of even higher recycling rate aspirations in ‘Our Waste, Our Resources: A Strategy for England’ will require changes that could spur both technical and commercial innovation that would not be predicted by a long plan period; and
• These factors will have an impact at both local and national levels. At present, for example, the number of energy recovery facilities is concentrated in the north of England while the largest amount of waste is produced in the south. There is the emerging view in the industry that movement of waste from south to north will very probably develop and accelerate as a result of the changes described above.

Long-term projections are very uncertain as policy develops and the waste industry adapts to these changes. Accordingly, the mandatory period of review (at least once in every 5 years) is critical and the review period may be shorter. This will ensure the Plan’s overall ambitions can be met while catering for the changes that lie ahead for the waste sector.

Question 2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
No, the information is sufficient.

Question 3: Do you agree with the current waste estimate? Do you have any other information which may lead to a different waste estimate?
We agree with the current waste estimate and methodology used in the plan for local authority collected waste, as this can be estimated in line with projected house numbers across the plan area, and supported by the four scenarios proposed.

We agree with the proposed estimate range for Commercial and Industrial (C&I) waste production arisings across the plan area to increase from 2020 levels (606 kt) to between 740 ktpa and 1.2 Mtpa by 2038. We agree with the methodologies proposed of using local economic forecast reports (such as the awaited D2N2 report) to assist with the local plan forecasting. However, if the local economic forecasts are not available, then the approach proposed within the plan of using a scenario-based approach is a good rationale. We support the requirement for the ongoing evaluation of the estimated levels throughout the plan timeframe, with reviews in accordance with the NPPF requirement of at least once every 5 years. The reviews can identify any significant regeneration or major infrastructure projects which may occur within the plan area over the life of the plan.
The scope to monitor significant changes in C&I waste streams includes the assessment of any significant projects planned within neighbouring counties to allow for ‘overspill’ of waste into the plan area.

To further enhance the data collection process, the Councils should consider using data from third-party sources, e.g. Environment Agency’s Waste Data Interrogator and the statistics on waste published by the UK Government. While these may not provide an accurate forecast for the future, they can be used to refine the scenarios presented later in the consultation.

Question 4: Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
Other than via existing methods of disposal, the plan should consider the potential issue expected from changes in the likely increased utilisation/reuse opportunities of separated waste streams during the life of the plan. We anticipate certain waste streams, such as separated food wastes and non-recyclable plastics, will increasingly become utilised for alternative end use materials during the timeframe of the plan. A review of this potentially new disposal area should be undertaken at each of the 5 year review periods.

Question 5: 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 agree with the proposed scenario range provided within the plan, and feel Scenario A (0.5 % growth) is the most realistic estimate of the four scenarios proposed and, therefore, the most suitable scenario to base the local plan against.

The growth in housing as set out in the consultation will result in an increase in waste; each UK person currently produces just below 400 kg of waste per year. However, given the range of measures that are being introduced to tackle the rise in food waste and plastics especially, through taxation or initiatives such as the WRAP Courtauld Commitment (2025), which will be supported by households and businesses, the rise will not reach 1 %. Through the required 5 year review of the plan, the growth or otherwise in waste volumes can be reviewed periodically.

Question 6: 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 agree with the proposed scenario range provided within the plan, and feel Scenario B (2 % medium growth) is the most robust estimate of the three scenarios proposed and, therefore, the most suitable scenario to base the local plan against. The scenarios should be re-evaluated when the expected Local Economic Forecast report has been received by the regional LEP (D2N2).
We agree the plan area is likely to experience growth within the plan timeframe, with the development of new houses, business parks and HS2. The implementation of waste minimisation processes by manufacturers and retailers, and the increasing use of ‘take back’ schemes and repair services is all expected to balance out the extra production with better utilisation.

Question 7: 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 have no opinion on the expected volumes of CDE waste within the plan timeframe, but by utilising the various data sources available and the 5 year review period, any changes can be accounted for.

Question 8: Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
We have no opinion on the expected volumes of hazardous waste within the plan timeframe.

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 consider the assumptions of increasing recycling levels across the plan area of 10 % above current 2020 levels by 2038 as a reasonable target.

With only 84 local authorities (2018/19 season) with recycling rates better than 50 % in the UK, recycling is obviously still struggling to gather any commercial momentum. With Nottinghamshire County Council at position166 and Nottingham City Council at position 325 out of 345 UK authorities in the national league table for recycling levels, promoting the improvement in recycling rates should be a key part of the plan, looking to attract companies that can help increase the recycling rates in this area.

Question 10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Paragraph 4.23 of the consultation document contains a series of statements we would like to comment on:
• “Where waste cannot be recycled, using it as a source of energy can provide benefits in terms of generating heat and power. This is more sustainable than simply disposing of the waste and can help to offset fossil fuel use. However, this can raise concerns over the appropriate size of facilities to ensure that they do not ‘compete’ with recycling facilities by locking waste in to long-term contracts.”

There are a number of studies that demonstrate ERFs do not ‘compete’ with recycling facilities and this is set out in a report issued by the Environmental Services Association. The energy recovery process has diverted non-recyclable waste from landfill rather than diverting recyclable waste from recycling. If this point is considered from a practical perspective, it is wholly unrealistic to think that households and businesses that are putting their recyclables in a source segregated recycling bin will decide to stop doing that and instead put their recyclables in the residual waste bin just because there is a new ERF facility somewhere.

As previously stated in our response to Question 2, although the UK has not yet reached ERF market saturation, there is an expectation that an increased number of ERFs could possibly operate as merchant facilities rather than be tied to long-term waste contracts.
• “Currently the UK exports large quantities of residual waste as Refuse Derived Fuel (RDF) to countries in mainland Europe where it is burned for energy. With the UK leaving the EU, the waste industry expects there to be more demand to process and manage this waste as a resource within the UK.”

We agree that current UK waste exports will diminish over time and that the waste industry will have to manage this waste as a resource within the UK. In this respect, we consider that ERFs will play a very important role to ensure that this non-reusable, non-recyclable waste is not sent to landfill.
• “Nottinghamshire and Nottingham currently has 750,000 tonnes of permitted annual energy recovery capacity but only 185,000 of this is operational.”
We strongly believe there is the need for additional energy recovery capacity within the Plan area and beyond in the wider region. (This is why we have decided to bring forward plans for development of the EMERGE Centre). For the Plan area, this capacity gap should be expressed as the minimum capacity required for Nottinghamshire to be net self-sufficient. It should be seen as the minimum that Nottinghamshire should plan for, not as a barrier or limit.

It is well known many permitted projects do not get developed for a range of commercial and technical reasons. Including permitted sites that are not yet in operation in the consideration of the capacity gap makes a false assumption about available capacity to fill the gap. Consideration of the capacity gap should exclude projects with planning permission but not operational, in accordance with National Planning Policy for Waste paragraph 3.

Question 11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
We agree with the requirement to provide some ongoing disposal capacity for certain waste types, which cannot be recovered or recycled, within the Plan area. If the expected CDE waste stream within the Plan area is expected to remain stable, or moderately increase, over the timeframe of the plan, then transporting large volumes of waste outside the area could potentially be subjected to future impacts from any transport limitations on movement of waste.

Future disposal of waste to landfill should first require an assessment of the waste to confirm that it cannot be utilised. Disposal is at the bottom of the waste hierarchy and should therefore be used only when there is no other available option. Economics should not be the main reason for the avoidance of landfill. Any waste which can be recycled, reused, repaired or sent for energy recovery, should be.

Furthermore, by promoting recycling within the local plan and promoting the most efficient use of materials over the lifecycle of the building as part of Nottingham County and City Councils role as planning authorities, it is possible to increase the rates of recycling of construction and demolition rates. The consequence of this will be a reduction in the volume of material that needs to be disposed of.

Question 12: Do you agree with the draft vision? Are there other things we should include?
In principle, we agree with the draft vision and would suggest the plan would be further enhanced if it includes a commitment to the wider UK Government target of net zero by 2050. For example, the statement could be written as:
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, thus contributing to the UK’s journey towards net zero by 2050.

Question 13: Are the above objectives appropriate? Are there others we should consider?
Yes, the objectives are appropriate.

Question 14: 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?
We do not propose any other options. However, the Plan should recognise that the waste industry will face transformational changes with the development of a circular economy. It is important that proposals for broad locations of future waste management facilities do not inadvertently influence planning decisions on waste developments against the circular economy, as well as the UK Government’s 2050 net zero target.

Question 15: 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?
In accordance with NPPW paragraph 4, the Plan should identify sites and/or areas for new or enhanced waste management facilities in appropriate locations. To do so it should allocate specific sites, particularly those deemed suitable from the Call for Sites process. Each allocation should (again NPPW paragraph 4) identify the broad type or types of waste management facility that would be appropriately located on the allocated site or in the allocated area, taking care not to be overly prescriptive so as to avoid stifling innovation. Allied with the allocations, there needs to be a criteria based policy to cover waste developments that might come forward on unallocated sites. The criteria in such a policy should mirror the criteria for choosing the allocations, such that there can be consistency in decision making and schemes that meet the criteria can be given equal weighting to those on allocated sites.

In making the allocations, particular regard needs to be given to NPPW paragraph 6 which deals with the Green Belt. In short, this is entirely permissive of allocating sites / land in the Green Belt where the development would be appropriate development in the Green Belt.

Question 16: 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 proposals for the scope of the development management policies are satisfactory.

Question 17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
No further comments.

NEWARK & SHERWOOD DISTRICT COUNCIL RESPONSE TO THE WASTE LOCAL PLAN CONSULTATION

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?
The plan period seems reasonable particularly given the Government requirement to review plans every 5 years to ensure continuing relevance.

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?
It would be useful to highlight existing major waste infrastructure sites in order to provide the current locational context. It would also potentially be helpful to highlight the history of extractive industries in the Plan Area given the past relationship with landfill.

It would also be useful to highlight that between the main towns and ‘small villages’ a number relatively large towns and villages exist across the County. This is a particular issue when considering how to plan the provision of services (including waste) in rural areas.

The map does not appear to show the A46 Newark bypass.

Q3: Do you agree with the current waste estimate? Do you have any other information which may lead to a different waste estimate?
None at this time, the report appears to have captured all of the data we are aware of.

Q4: Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
None at this time, the report appears to have captured all of the data we are aware of.

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?
Current trends show that waste production levels have fallen and this is to some extent in line with the economic downturn and its social impacts. It remains to be seen if the push for more efficient resource use has had sufficient impact to maintain the low levels of growth we have seen since 2014. The continued growth of local authority kerbside garden waste collection may also result in additional demands as waste may be diverted from home composting and into the municipal stream.

On this basis we would advise that predictions of future demands are based on option C.

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?
As discussed in the response to question 5 current levels of growth are low but we would not necessarily expect them to stay this way. On this basis we would anticipate low growth initially (Option A) but feel this should be reviewed every 5 years to adjust the plan accordingly.

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 are not in a position to comment on this question.

Q8: Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
We are not in a position to comment on this question.

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 expect future recycling rates to be higher (60%+) but given the uncertainty around national policy and future economic growth we understand why the proposed plan is for a 10% increase.

Additional consideration should be given to the types of facilities that may be required to handle new and increased waste streams.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery through incineration can be unpopular and controversial, and the practice may receive less support in the future.

Rather than planning for increased usage/capacity for energy recovery from incineration, opportunities should be created for increased recycling and priority given to energy recovery from food and garden waste via in-vessel composting and anaerobic digestion facilities.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
We agree that some disposal capacity will still be required. This can be minimised through better recycling opportunities which should reduce the by-products of incineration such as incinerator bottom ash which would still require landfill for disposal.

Q12: Do you agree with the draft vision? Are there other things we should include?
We suggest amending the final paragraph to provide a specific overarching target:
To protect the quality of life of those living, visiting and working in the area and to avoid any risks to human health. Facilitate the application of the waste hierarchy and the circular economy to prevent and re-use waste as a resource wherever possible and to exceed a 60% recycling rate for all mixed municipal and industrial waste in Nottinghamshire and Nottingham by 2030.

Q13: Are the above objectives appropriate? Are there others we should consider?
We suggest that Objective 4 be revised to take account of the potential need for mitigation where avoidance is not possible:
Community, Health and Wellbeing – to ensure any adverse impacts from new waste facilities on local amenities and quality of life including dust, traffic, noise, odour and visual impact are appropriately mitigated and local health concerns are addressed.

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?
While it is superficially attractive to have a facility near Newark, this may not be the most sustainable approach, and it may prove to be unpopular with local residents. Even proposals on industrial sites can be controversial near residential areas.

A large number of vehicles used by tradespeople and small businesses making journeys to visit the waste management facility from around and outside the District could have a significant carbon footprint. If these vehicles could visit one of a network of smaller sites closer to them, there would be fewer emissions.

Major sites could be located on brownfield sites away from residences in areas with good transport links rather than around areas where a lot of waste is produced. Smaller Waste Transfer Stations could then be used to move the waste to larger facilities.

Existing employment sites with established or former industrial uses could be suitable locations for these smaller sites, in some instances meaning that waste would be brought from businesses on the same site. This could provide opportunities to reuse brownfield sites where the principal of industrial use is established.
This approach would support local businesses by providing a simple and convenient way to access recycling and recovery facilities which can handle a range of materials at one location. This would facilitate the easy management of waste within the waste hierarchy. Smaller, more energy efficient, vehicles can be used to travel short distances to transfer stations and overall vehicle miles would be reduced.

If one facility became unable to operate normally, material could be moved to an alternative location.

Where appropriate, opportunities should be sought to use railways and rivers to transport waste. This would reduce both traffic impacts and harmful emissions from motor vehicles.

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 criteria based approach could be appropriate if it takes account of the concerns raised above and facilitates the development of a network of waste management facilities. Impacts on the climate crisis should also be considered as part of this approach.

This could be combined with a call for sites for smaller Waste Transfer Stations where materials can be sorted and bulked up for transport elsewhere.

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?
We agree that all the topics suggested should be considered and we propose adding two: the climate crisis; and impacts on the waste hierarchy.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
We are keen to see issues relating to the climate crisis and the environment addressed within the plan.

Thank you for consulting NWT on the above, I welcome the emphasis on the circular waste economy and hope to see stronger targets for further waste reduction and re-use.

In this response, I have followed the normal convention of showing the existing text from the consultation document in italics and recommended changes in bold italics.

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?
NWT consider this is the longest period that could be appropriate, as it is essential that robust targets can be set within a reasonably predictable context. Beyond this period, external factors could change so dramatically that setting targets becomes impossible. Even within this timeframe there are likely to be substantive changes in some areas, particularly regarding packaging and re-use (which has changed considerably in the last decade), so either a review period will need to embedded in the Plan, to re-set targets, or the Plan period shortened.

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?
Para 3.6. does not fully encompass the breadth and value of the County’s biodiversity resource, so NWT would suggest the following additions:
“The County’s landscape is characterised by rich rolling farmlands to the south, with a central belt of mixed woodland and farmland, giving way to heathland in the north and open, flat agricultural landscapes dominated by the River Trent to the east. Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, to the north of Mansfield. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status. There is, however, a significant network of SSSIs and LWS across the County, representing the wide range of habitat types found on the diverse geology of the County and hosting diverse, and often scarce, species of flora and fauna. Some of these habitats have been created as a result of the restoration of former waste sites, and this Plan will ensure that the restoration of future waste sites contributes to this network of wildlife-rich habitats, as part of Nottinghamshire’s Nature Recovery Network”.

Plan 1 – The Plan Area does not adequately or accurately represent this biodiversity resource. The green shape that is categorized as “Sherwood Forest including Special Area of Conservation” neither shows the SAC accurately (nor the ppSPA), nor does it encompass the boundaries of “Sherwood Forest” that have been discussed and agreed by multiple parties over many years. NWT would suggest that the SAC is shown accurately as a polygon, the ppSPA is shown as a dotted line boundary, and that ,as a minimum, dots are used to show the SSSIs. We agree that at this scale, it would not be possible to show the LWS.

Q 3-8
I will not respond in detail to the questions about waste calculations and predictions, as this is not a field where NWT has technical expertise, but as a general principle, we would expect more ambitious targets for reduction and re-use for LACW, not least given the admittedly small, changes in the major supermarkets in the last year towards reduced plastic packaging etc., but which is an area that is changing rapidly. In NWT’s view, Option A is lacking in ambition and there should be a higher reduction target per household. Option D should not be countenanced at all. Similarly, rapidly advancing technologies in reuse of industrial and commercial waste as a valuable resource should also enable a higher target for the C&I sector.

Q9: 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?
NWT suggest that these targets for recycling should be more ambitious, as this will drive innovation, and should be combined with drivers and incentives from the public sector to force change. The current situation under Covid 19 has shown how dramatically behaviour can be changed in a very short time (under awful circumstances that we hope will never be repeated) given sufficient government will. NWT would suggest that there is an opportunity for the WPAs to use lessons learned from the current crisis, about reductions in food waste, increased re-useable packaging (such as glass milk bottles) etc., to set considerably more ambitious targets, for the LACW stream in particular.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery is important for those last elements of the waste stream that cannot be reused or recycled, but should be considered as a last resort when absolutely all other options have been tried (as represented in the Waste Hierarchy). This needs to be more strongly stated in the Plan than in the current wording. There should be a target to reduce the production of RDF and other waste disposal by incineration. Nottingham and Nottinghamshire, in line with the former’s ambitious Carbon neutrality target and given the innovation and science sectors in the City and County, should be well placed to lead in this area of avoiding the production of materials that have to be converted to RDF.

NWT share the stated concern in the text that large, long term facilities, can have the unfortunate consequence of driving the need for waste to service them. It is also important to recognize, however, that even smaller facilities can cause this effect, as has been clearly seen by the series of unfortunate outcomes of the promotion and subsidy for anaerobic digestion on farms. In Nottinghamshire, this has directly resulted in unsustainable maize production solely for the purposes of feedstock for digesters, which has damaged soils and habitats, and added to pollution of the aquifers, results in substantial increases in NOx, NH4 and CO2 outputs from its production, and has reduced land availability for human food crops and biodiversity.

Therefore, driving the need for reduction in energy use should be the overriding policy, not supporting energy recovery. This should apply across all sectors, particularly municipal and industrial, and notably with regard to housing. So, in summary, NWT do not consider that there should be a plan for higher levels of energy recovery, as this will drive the production of more waste to supply it, rather than finding other ways of reducing that waste stream entirely.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
Availability of disposal sites can prevent or reduce innovation in finding other solutions, although there may be a need for disposal for the small fraction that cannot be used or recycled in any other way. There should be a presumption against developing large new disposal capacity in the context of strong drivers and incentives to find other solutions, so NWT would suggest that any additional capacity should be targeted to be deliberately small, to drive more material into the reduce-reuse-recycle circle.

Q12: Do you agree with the draft vision? Are there other things we should include?
NWT support the vision in general. Our only suggestion is that “ minimise the effects of climate change” is insufficiently specific, as it could refer to climate impact mitigation rather than greenhouse gas production. We suggest that “minimise greenhouse gas emissions that result from waste management in the County” is more accurate as a description of what appears to be intended.
Also the role of the restoration of waste sites to priority habitats should be highlighted by adding the following to the second paragraph:
“All waste sites will contribute towards a greener Nottinghamshire and Nottingham by ensuring that they contribute to biodiversity delivery of priority habitats and the re-
connection of ecological networks, and so ensuring that they also contribute to improving long term access for local people to high quality wildlife-rich greenspaces.”

Q13: Are the above objectives appropriate? Are there others we should consider?
Objective 1 Climate change. NWT consider that this needs to refer specifically to habitats , as there is always habitat damage as a result of new waste development, “ Encourage the efficient use of natural resources by promoting waste as a resource, limit further impacts by avoiding damage to air quality, water, habitats or soil, reduce the need to transport waste and accept that some change is inevitable and manage this by making sure that all new waste facilities are designed and located to withstand the likely impacts of flooding, higher temperatures and more frequent storms and that restoration of waste sites prioritises habitat creation, as that will also help in sequestering Carbon. “
Objective 3. The environment, This needs clarification about what is being protected, and also explicit reference to the need for waste sites to play their part in delivering biodiversity targets. Therefore, NWT suggest the following wording ; “to ensure any new waste facilities protect or enhance the countryside, wildlife and valuable habitats, protect water, soil and air quality across the plan area and thus ensure conservation of the built and natural heritage of the area. After their operational use ceases, all waste sites will be restored to beneficial nature conservation afteruse which optimises their contribution to meeting the County’s biodiversity targets and to delivering Nature Recovery Networks”
Objective 4. Community, Health and Wellbeing. The availability of wildlife-rich greenspace on people’s doorsteps is a significant factor in good physical and mental health and wellbeing , so NWT would suggest the following addition: – “to ensure any new waste facilities do not adversely impact on local amenities and quality of life from impacts such as dust, traffic, noise, odour and visual impact, and any loss of local greenspace upon which people rely for their good health and wellbeing and address local health concerns.”
Objective 5. Meet our future needs. It is essential to emphasise that any sites should be allocated on the basis of both robust SA and EIA, so that proper comparative assessments are made at the plan-making stage. Hence NWT would suggest the following addition to the wording: “Ensuring that there is a mix of site types, sizes and locations to help us manage waste sustainably wherever possible. Meet current and future targets for recycling our waste. Safeguarding existing and/or potential future sites where appropriate and where robust SA and EIA have been undertaken to allocate those sites. Locate new waste facilities to support new residential, commercial and industrial development across the plan area.”

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?
NWT broadly agree with these locational priorities, but all decisions on location should always be subject to robust science based decision-making, tested through SA and EIA, so that the full range of impacts, including long distance ones such as NOx, can be properly assessed.

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?
In NWT’s view, using a criteria-based approach would be insufficiently robust. It is essential that a proper comparative SA of possible sites is undertaken at the same time and in a consistent manner, to ensure that the level of assessment is equal. Otherwise there is a risk of judging sites against variable criteria and contexts in the future. It is also essential to screen out unsustainable sites at an early stage, to prevent uncertainty, local concerns and potentially poor decision-making later.

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?
Of the scope listed, NWT would highlight the need for the follow changes and additions:
“Highways and transport • Air quality (for both human health and impacts on habitats and species) • Green Belt • Landscape protection • Habitat and species protection and conservation. Archaeology. Greenhouse Gas impacts • Heritage • Pollution • Noise • Flooding and water resources • Health and wellbeing • Public rights of Way. Visual impact. Restoration and aftercare to maximise the contribution to UK and County biodiversity targets.”
It is important to be aware of the issue of NOx and NH3 emissions from certain types of waste facilities potentially impacting habitats. Nitrogen deposition on habitats has been identified as the most serious pollutant of habitats across the UK and Europe and these emissions can be particularly problematic for the heathlands and calcareous grasslands found in Nottinghamshire.
Nottinghamshire has Biodiversity Opportunity Maps, (which will inform the development of a NRN map for the County over the next 12 months), they are held by the County Council through the Biodiversity Action Group, and is it is essential that these documents are taken into account in the development of the Waste Local Plan, both to protect key areas of the network and to ensure that the location of waste sites may also contribute the Network in the long term when they are decommissioned and restored.

NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape-scale conservation in Nottinghamshire, in line with the Lawton Review and the 25 Year Environment Plan, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
It is essential that up to date biodiversity information at the necessary level of detail is used to help the preparation of the Plan, both with regard to data from the NGBRC and the Biodiversity Opportunity Maps.

NWT would expect the WPAs to embed the restoration and re-creation of biodiversity into the WLP, in accordance with the requirements of the 25 Year Environment Plan and the NPPF. It is particularly important, therefore, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a waste scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Nottinghamshire in the past. So these requirements should be secured through robust planning obligations and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

For potential larger footprint waste sites NWT would expect the use of site restoration briefs at an allocation stage, as has been undertaken for the MLP. This is an exemplary and constructive approach and should be replicated in this Waste Local Plan, with the creation of priority biodiversity habitats as the primary restoration aim for all allocations and extensions.

The restoration of waste sites can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable waste sites where the substrate is acidic, and has low nutrient status. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector waste industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.
The site allocation restoration briefs should list the target priority habitats using the existing NE Natural Character Area (NCA) approach and the Biodiversity Opportunity Map, the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which may be achieved through waste site restoration, as described above:
Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows
Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches
Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.

Trent Valley and Rises:rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.
Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.
Please do not hesitate to contact me if you have any queries about the above or if I can provide more information. I look forward to working with the WPA in the development of this important Plan.

Yours sincerely,

[ • Green Belt • Landscape • - & including Light pollution - Pollution],
therefore • Countryside [&] • Sensitive design
- unclear in Objective 6 - might be added to 7.2 its (Q16) scope.

OBJECTIVES 3 and OBJECTIVES 4 (page 30), therefore within the plan area
its tiers of planning authority (LPA) councils, ought to each, already,
have robust planning policies in place: to protect against land and soils being
(unnecessarily) degraded, trashed, literary wasted; to protect against unchecked and/or wasteful demolition. These issues questioning because of it seems
flaws in the planning-system, that put - frankly not very clever - construction
& ‘development’, before (both heritage and)
the more natural environment.

[Instead of atonement concerning negative planning before] simplification
is observed in the councils’ - development-corporation skewed - overview,
to the (Q2) plan area.

Dear Sir/Madam

Re: Nottinghamshire and Nottingham Waste Local Plan

Thank you for consulting Rushcliffe Borough Council (RBC) on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options and for extending the deadline for comments during this difficult period.

Please consider the following responses to those questions asked.

Q.1: 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?
RBC supports the proposed plan period, this corresponds with the proposed plan period for the emerging Greater Nottingham Strategic Plan (GNSP). There would be clear benefits coordinating the planning of new development and planning the recovery, recycling and disposal of the waste it would generate.

Q.2: 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 overview should refer to the proposed High Speed Two railway station at Toton within Broxtowe, this has the potential to bring significant economic benefits to Nottinghamshire, especially in and around Nottingham (including Rushcliffe).

The plan should also cross refer to the Minerals Local Plan and the issues which it is addresses, notably the extraction of sand and gravel within the Trent and Idle Valleys. A reduction in demand from the construction industry for minerals, in accordance with the Waste Hierarchy, and increased recycling of minerals waste (as set in paragraph 204 of the NPPF) may have implications when planning to meet future needs.

Q.3: Do you agree with the current waste estimate? Do you have any other
information which may lead to a different waste estimate?
Table 5 Page 12 of the Preliminary Waste Needs Assessment identifies the household
projections for the Nottinghamshire authorities. Rather than identifying projections, any increase in waste from domestic properties should be based on the final local housing need figure (using the Government’s Standard Method). This applies a ratio of affordability to the household projection and consequently reflects the number of homes that are needed and that will be planned for. For example Rushcliffe has an annual
household projection of 451 (rather than 600) (based on the most recent 2014 figures) and once the 2019 affordability ratio is applied a final housing need figure of 604 homes per annum. This figure is currently being used to inform the Borough’s five year land
supply.

Q.4. Do you have any other information about how these waste streams are managed? Are there other issues the Plan should consider?
No comment.

Q.5. 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?
RBC agree with the scenarios set out. Given the overriding national objective of reducing the generation of waste, in accordance with the waste hierarchy, the plan should not accept and plan for a high growth in waste generation per household. RBC consider a decline in waste generation per household as the most suitable scenario. This continues the overall decline and accords with the Government’s 25 Year Environment Plan and
Waste and Resources Strategy.

Q.6. 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?
RBC agree with the scenarios set out for commercial and industrial waste. RBC consider no change as the most suitable scenario, this reflects the Government’s position that there will be some growth, however this growth will be off-set by increases in the production of waste and its recycling.

Q.7. 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?
RBC agree with the scenarios set out. As set out in answer to Q.3 the Government’s Standard Method for calculating housing need indicates Rushcliffe should provide a minimum 604 homes per annum, this equates to 12,080 during the plan period (2018 to 2038). The forthcoming Growth Options consultation will put forward different options which provide some flexibility and future drafts will distribute housing across the Greater Nottingham area. This distribution should inform the Waste Local Plan.

Q.8. Do you agree with the estimate set out for Hazardous Waste? Do you have any evidence to support any other scenarios?
No comment

Q.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?
Rushcliffe would agree that recycling rates are likely to increase further with the introduction of separate food waste collections as outlined in the Environment Bill 2020.

Likewise the impact of any future deposit return schemes could have an effect on the kerbside collection schemes for some dry recyclables. To further increase recycling rates across Nottinghamshire further action should be given to expanding the current input specification which places restrictions on what can be delivered and recycled at the current MRF.

Q.10. What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
No comment

Q.11. Do you agree with the need to provide additional disposal capacity within the Plan Area?
Given that the one suitable landfill site is due to close within a year, RBC agree that the County should retain capacity for landfill disposal and that additional disposal capacity is likely to be required (even after reductions, recovery and recycling). The county’s waste should be disposed of as close to where it is generated as possible.

Q.12. Do you agree with the draft vision? Are there other things we should include?
RBC agree with the draft vision.

Q.13. Are the above objectives appropriate? Are there others we should consider?
RBC consider the objectives appropriate.

Q.14. 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?
RBC agree with the broad locations proposed for future waste management facilities (locating new facilities close to the main urban areas where most people live with larger facilities within the Nottingham/Mansfield/Ashfield area and smaller/medium sized facilities around Worksop, Retford, and Network). A focus on urban centres can in certain cases leave gaps in provision, however. RBC is of the view that there is an urgent
need to replace the Langar facility which was closed several years ago and has left the east of Rushcliffe with no convenient household waste facility

Q.15. 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?
Paragraph 4 within the National Planning Policy for Waste (NPPW) states that waste planning authorities should identify, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations. Consequently, if an additional landfill capacity is required, these and larger waste recovery and recycling facilities should be identified within the plan. Their location should not be determined by criteria based policies alone.

Broader locations for smaller sites that serve local communities, could be identified according to the type of facility, for example industrial estates identified as B2 or B8 employment sites could accommodate waste collection, recovery or recycling facilities provided policy safeguards are in place to protect neighbouring businesses from access disruption, noise, dust or odours.

Q.16. 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?
RBC does not propose any additional waste planning issues which require development management policies.

Q.17. Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
RBC has no other comments to make at this time and this concludes our representation on the Nottinghamshire and Nottingham Waste Local Plan Issues and Options.

We look forward to reviewing the draft Waste Local Plan when it is published.

Yours sincerely

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.