3. Context for Waste Planning
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 597
Received: 28/03/2022
Respondent: Susan Edwards
Concern for the environment. Worry about building more energy from waste incinerators when current legislation will lead to less residual waste and therefore an overcapacity of incineration facilities. There should be a moratorium on new incinerators until future incineration capacity is fully examined. Food waste will soon be collected seperately and should mainly be anaerobically digested to provide biogas and compost, thereby greatly reducing residual waste destined for incineration or landfill. EfW incineration should be a worst option as it is high carbon and causes air pollution. We should be looking to reducing incineration not expanding.
Concern for the environment. Worry about building more energy from waste incinerators when current legislation will lead to less residual waste and therefore an overcapacity of incineration facilities. There should be a moratorium on new incinerators until future incineration capacity is fully examined. Food waste will soon be collected seperately and should mainly be anaerobically digested to provide biogas and compost, thereby greatly reducing residual waste destined for incineration or landfill. EfW incineration should be a worst option as it is high carbon and causes air pollution. We should be looking to reducing incineration not expanding.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 625
Received: 01/04/2022
Respondent: Mr Zbigniew Luczynski
This context section needs to include other policies including updated legislation contained in the Climate Change Act 2008(2050 target Amendment) Order 2019; the Net Zero Strategy 2021; the Carbon budget Order 2021 ;the Environment Act 2021; to ensure these laws are acknowledged in the Plan and are prioritised in weighing planning balance decisions by Planning Committees.
This context section needs to include other policies including updated legislation contained in the Climate Change Act 2008(2050 target Amendment) Order 2019; the Net Zero Strategy 2021; the Carbon budget Order 2021 ;the Environment Act 2021; to ensure these laws are acknowledged in the Plan and are prioritised in weighing planning balance decisions by Planning Committees.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 626
Received: 01/04/2022
Respondent: Mr Zbigniew Luczynski
3.6 Waste hierarchy must be used to prioritise Council investment. Anaerobic Digestion (AD) recognised as a form of recycling. Energy from Waste Incineration facilities are not on a par as energy recovery processes.
Evidence in
1, Statutory guidance Food and Drink waste hierarchy(April; 2021) where Anaerobic Digestion is number 4 after prevention, redistribution and animal feed. Incineration to generate energy is 7
2. Waste management Plan for England 2021 Diagram page17.
3. Net Zero Strategy p180
4. Resources and Waste Strategy 2018 p71
5.Waste Needs Assessment table 27 AD is a form of recycling
3.6 Waste hierarchy must be used to prioritise Council investment. Anaerobic Digestion (AD) recognised as a form of recycling. Energy from Waste Incineration facilities are not on a par as energy recovery processes.
Evidence in
1, Statutory guidance Food and Drink waste hierarchy(April; 2021) where Anaerobic Digestion is number 4 after prevention, redistribution and animal feed. Incineration to generate energy is 7
2. Waste management Plan for England 2021 Diagram page17.
3. Net Zero Strategy p180
4. Resources and Waste Strategy 2018 p71
5.Waste Needs Assessment table 27 AD is a form of recycling
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 627
Received: 04/04/2022
Respondent: Nottingham Friends of the Earth
AD is preferred to incineration in government guidance on waste hierarchy.
Circular economy, para 3.3:
We strongly support the principle of using waste as a resource. The Plan should ensure that all relevant facilities are provided for, including repair, re-use and re-processing.
Waste hierarchy, para 3.6:
We support the principle of the waste hierarchy. But the text in para 3.6 fails to state that government policy requires anaerobic digestion of food waste to be considered higher in the hierarchy than incineration. For example, Defra's guidance on "Food and drink waste hierarchy" (April 2021) describes anaerobic digestion of food waste as recycling, with a higher priority than composting, and places incineration below landspreading. Government support for AD is also made clear in the Resources & Waste Strategy (2018), Waste Management Plan for England (2021), Net Zero Strategy (2021) and consultation on Environment Act targets (2022). Current government policy should be properly taken into account in the Plan.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 634
Received: 04/04/2022
Respondent: Nottinghamshire Wildlife Trust
Section 3 Context
This requires updating with the relevant details of the Environment Act 2021, as this includes
important elements that relate directly to this Plan, particularly the mandate for Biodiversity Net
Gain (BNG), and the requirement to create Nature Recovery Networks (NRN).
It is also essential that the national obligation to meet 30% of land for nature by 2030
(30x30) is recognised in this text, as that is a commitment made by this Government PM commits
to protect 30% of UK land in boost for biodiversity - GOV.UK (www.gov.uk), reflecting international
biodiversity obligations UK secures historic G7 commitments to tackle climate change and halt
biodiversity loss by 2030 - GOV.UK (www.gov.uk).
The Core diagram should show the ppSPA boundary, not just the SAC boundary, this would
ensure consistency with the subsequent references in later sections.
Thank you for consulting the Nottinghamshire Wildlife Trust (NWT) on the above. I apologise
for using this format of response, but the OPUS format is not straightforward to use for
responses to multiple sections and the insertion or highlighting of text. I have used bold italics
to suggest insertions of text and italics for your original text.
Overall NWT supports the principles of the Plan and we welcome the clear reiteration of the
need to move waste management urgently up the waste hierarchy. We would hope, however,
to see a stronger aim for further waste reduction and the obligation for each Local
Authority to secure ambitious waste reductions across all their work and areas of
influence.
Detailed comments in representations
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 744
Received: 05/04/2022
Respondent: Kristian Ravnkilde
Circular economy, para 3.3: I support the principle of using waste as a resource, as above.
I welcome the opportunity to comment on the draft plan. I am doing so in the form of an email because I find the online process cumbersome and hard to use – even though I as a rule prefer the online approach.
In general, I find the document short sighted and lacking in ambition, as well as hard to read and extract the key points from. It seems to be written and laid out specifically to discourage engagement and comments. However, I have some specific points to make:
1) I am particularly interested in anaerobic digestion of food waste in combination with sewage sludge and other suitable waste materials. The current gas price crisis highlights the opportunity to solve at least two problems at the same time, and makes it a good investment for the Pension Fund in place of fossil fuel companies. I am strongly against incineration in general, and for food waste in particular.
2) Reduction of greenhouse gases should be a key policy
3) Recycling rates should be more ambitious and specific measures should be put in place to promote waste reduction
On some of the individual parts of the document:
Circular economy, para 3.3: I support the principle of using waste as a resource, as above.
Waste hierarchy, para 3.6: Government policy requires anaerobic digestion of food waste to be considered higher in the hierarchy than incineration (and AD should be included under “recycling” not “other recovery”)
Recycling scenarios for local authority collected waste, para 5.40, Table 7: The Waste Framework Directive target of 65% by 2030 should be the minimum and the plan should aim to provide recycling facilities to at least achieve this.
Strategic Objective 1 – Acting on climate Change: (This refers to “avoiding damage to air quality, water or soil” but makes no makes no reference to limiting greenhouse gas emissions.) Representations on the previous round of consultation “suggested greenhouse gas emissions should be explicitly referenced and this objective should be connected with delivering more innovative waste solutions to meet climate change commitments”. This Strategic Objective should aim to minimise greenhouse gas emissions.
Policy SP2 – Future Waste Management Provision: Support “Priority will be given to the development of new or extended recycling, composting and anaerobic digestion facilities”. Priority should also be given to re-use and repair facilities.
Policy SP5 – Climate Change: (As with Strategic Objective 1 the policy makes no reference to greenhouse gas emissions.) Para 7.47 does say this could include “Minimise greenhouse gas emissions . . .” but this should also be included in Policy SP5. Any reference to supporting “low carbon energy” should note that incineration of waste typically emits around a tonne of CO2 for every tonne of waste and cannot be considered to be “low carbon”.
Appendix 1 – Monitoring and Implementation Framework, SP2: Monitoring for Future Waste Management Provision should include monitoring waste composition because this will be important for planning the balance of waste management facilities.
Appendix 1 – Monitoring and Implementation Framework, SP5: Monitoring for the Climate Change policy should include monitoring greenhouse gas emissions, including from landfill and incinerators.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 745
Received: 05/04/2022
Respondent: Kristian Ravnkilde
Waste hierarchy, para 3.6: Government policy requires anaerobic digestion of food waste to be considered higher in the hierarchy than incineration (and AD should be included under “recycling” not “other recovery”)
I welcome the opportunity to comment on the draft plan. I am doing so in the form of an email because I find the online process cumbersome and hard to use – even though I as a rule prefer the online approach.
In general, I find the document short sighted and lacking in ambition, as well as hard to read and extract the key points from. It seems to be written and laid out specifically to discourage engagement and comments. However, I have some specific points to make:
1) I am particularly interested in anaerobic digestion of food waste in combination with sewage sludge and other suitable waste materials. The current gas price crisis highlights the opportunity to solve at least two problems at the same time, and makes it a good investment for the Pension Fund in place of fossil fuel companies. I am strongly against incineration in general, and for food waste in particular.
2) Reduction of greenhouse gases should be a key policy
3) Recycling rates should be more ambitious and specific measures should be put in place to promote waste reduction
On some of the individual parts of the document:
Circular economy, para 3.3: I support the principle of using waste as a resource, as above.
Waste hierarchy, para 3.6: Government policy requires anaerobic digestion of food waste to be considered higher in the hierarchy than incineration (and AD should be included under “recycling” not “other recovery”)
Recycling scenarios for local authority collected waste, para 5.40, Table 7: The Waste Framework Directive target of 65% by 2030 should be the minimum and the plan should aim to provide recycling facilities to at least achieve this.
Strategic Objective 1 – Acting on climate Change: (This refers to “avoiding damage to air quality, water or soil” but makes no makes no reference to limiting greenhouse gas emissions.) Representations on the previous round of consultation “suggested greenhouse gas emissions should be explicitly referenced and this objective should be connected with delivering more innovative waste solutions to meet climate change commitments”. This Strategic Objective should aim to minimise greenhouse gas emissions.
Policy SP2 – Future Waste Management Provision: Support “Priority will be given to the development of new or extended recycling, composting and anaerobic digestion facilities”. Priority should also be given to re-use and repair facilities.
Policy SP5 – Climate Change: (As with Strategic Objective 1 the policy makes no reference to greenhouse gas emissions.) Para 7.47 does say this could include “Minimise greenhouse gas emissions . . .” but this should also be included in Policy SP5. Any reference to supporting “low carbon energy” should note that incineration of waste typically emits around a tonne of CO2 for every tonne of waste and cannot be considered to be “low carbon”.
Appendix 1 – Monitoring and Implementation Framework, SP2: Monitoring for Future Waste Management Provision should include monitoring waste composition because this will be important for planning the balance of waste management facilities.
Appendix 1 – Monitoring and Implementation Framework, SP5: Monitoring for the Climate Change policy should include monitoring greenhouse gas emissions, including from landfill and incinerators.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 845
Received: 12/04/2022
Respondent: Shlomo Dowen
Energy from waste is not ‘sustainable’
73.Only Solutions LLP takes issue with the characterisation of heat and energy
supplied through the Eastcroft incinerator as ‘sustainable’ (e.g. at dWLP
Paragraph 3.6), not least because the feedstock used to generate heat and power contains plastic, and burning fossil-based plastic is not considered sustainable.
The dWLP should not contain statements that could be considered ‘greenwash’ and should therefore describe the Eastcroft incinerator in more neutral terms.
Only Solutions LLP’s Submission to
the Nottinghamshire and Nottingham
Waste Local Plan Consultation.
See accompanying Representations for details.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 846
Received: 12/04/2022
Respondent: Shlomo Dowen
Update WID, WMPE and Environment Bill/Act references
74.Reference is made on page 15 of the dWLP to the Waste Incineration Directive (2000/76/EC) within the context of existing policies. Only Solutions notes that the
Waste Incineration Directive (WID) was replaced by the Industrial Emissions Directive (2010/75/EU) in 2010.
References to the WID should be replaced by references to the Industrial Emissions Directive (IED) and to the EU (Withdrawal) Act 2018.
76. Similarly, references to the 2013 Waste Management Plan for England (e.g. in the heading on page 17 of the dWLP) should be corrected to reflect the adoption in
January 2021 of the 2021 Waste Management Plan for England (WMPE).
77. Finally, the reference in dWLP paragraphs 8.59 and 8.63 to the to “the draft Environmental Bill” need to be updated to reflect the fact that The Environment
Bill is now the Environment Act. The Environment Act 2021 contains provisions
for the protection and improvement of the environment, including introducing biodiversity net gain.
Only Solutions LLP’s Submission to
the Nottinghamshire and Nottingham
Waste Local Plan Consultation.
See accompanying Representations for details.
Comment
Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
Representation ID: 859
Received: 12/04/2022
Respondent: Shlomo Dowen
1. Paragraph 3.5 of the draft Waste Local Plan (dWLP) states that: “Although the UK
left the EU in January 2020, the Government has stated that there are unlikely to
be any immediate changes to UK waste policy and targets, however this will be
kept under review and this plan will be updated accordingly” citing a non-
Government website as the source.
2. In reality, Government has put forward a range of post-Brexit proposals to change
UK waste policy and targets, over and above the measure set out in the
Resources and Waste Strategy (e.g. consistency of collection requirements
including of food waste and dry recyclate, 65% recycling target, Extended
producer Responsibility (EPR) scheme, Deposit Return Scheme (DRS), etc.).
3. These additional post-Brexit proposals include:
• Changes to the National Policy Statement for renewable energy infrastructure
(EN-3) to strengthen protections against incineration overcapacity;
• New waste reduction targets which imply higher recycling ambitions; and
• Inclusion of incineration (EfW) in the Emissions Trading Scheme (ETS) which
could free up capacity at existing waste incinerators whilst making recycling
and waste minimisation more financially attractive.
Changes to EN-3 to strengthen protections against incineration overcapacity
4. Draft EN-3 (2021) are paragraphs 2.10.4 and 2.10.5 states that:
“2.10.4 As the primary function of EfW plants is to treat waste, applicants must
demonstrate that proposed EfW plants are in line with Defra’s policy position on
the role of energy from waste in treating municipal waste.
"2.10.5 The proposed plant must not result in over-capacity of EfW waste
treatment at a national or local level.”
5. One planning professional who is currently working for the incineration industry
commented on the significance of this national requirement, stating that "…this
wording would mean they [promoters of new EfW waste treatment schemes] will
need to be robust in making the case that there is demand for the project"
6. This indicates that the Government is acknowledging the need for the planning
system to ensure that controls are in place to prevent incineration overcapacity.
Such an interpretation is in line with other Government statements.
7. In the House of Commons John Grogan MP questioned the then Environment
Secretary Michael Gove, asking: "Most studies now indicate that we have an
excess of incineration capacity to deal with residual waste. Is there not a danger
that, if we build more incinerators, waste that would otherwise be recycled will
be diverted to those incinerators?" and the Environment Secretary acknowledged
this danger by responding: "That is a fair point".2
8. Rebecca Pow, speaking on behalf of the Government, told Parliament that: "...we
seek to minimise the amount of waste that goes to incineration or landfill…"3
9. The UK Government's then Resource Minister Thérèse Coffey gave oral evidence
to the Environmental Audit Committee that: "I think, actually, there is sufficient
capacity out there for incineration”.4
New waste reduction targets which imply higher recycling ambitions
10. The Government has announced proposals for an environmental target to halve
the waste that ends up at landfill or incineration by 2042.5
11. The Government explains that the target “would represent a municipal recycling
rate of around 70-75% by 2042”, and so this goes beyond the Resources and
Waste Strategy’s ambition to reach 65% recycling by 2035.
12. This indicates that we could have significant incineration overcapacity compared
future demand, highlighting the importance of ensuring that there are high
recycling and waste minimisation targets along with appropriate planning
controls to prevent incineration overcapacity.
Inclusion of incineration (EfW) in the Emissions Trading Scheme (ETS) which could
make recycling and waste minimisation more financially attractive.
13. The UK’s Emissions Trading Scheme (ETS) provides a mechanism to require those
who produce electricity to pay towards the carbon cost of their activity.
14. For years incinerator operators have been exempt from being part of this
scheme, but the Government is now proposing to close this loophole.
15. According to the consultation document: “Our starting proposition is that the UK
ETS should cover the incineration of fossil material by all waste incinerators. This
means the UK ETS obligation for robust monitoring, reporting and verification
(MRV) would be placed on all operators of waste incinerators. For EfW, this
would mean conventional incineration and ATT/ACT (pyrolysis/gasification) would
fall under the scope of the UK ETS and pay a carbon price according to their
greenhouse gas emissions”.6
16. Increasing the price of incineration could potentially push waste further up the
waste hierarchy, making higher recycling and waste minimisation objectives more
financially attractive.
17. Measures to reduce the quantity of plastic and other high-carbon materials going
to incineration, such as front-end sorting, would free up capacity at existing
incinerators. To the extent that removing plastic reduces the calorific value of the
feedstock, it can increase the total capacity of the incineration plants.
18. Incinerators that increased their permitted/consented capacity while maintaining
their thermal MW capacity to allow for greater operational hours and/or reduced
average CV include: Ardley7 (Oxfordshire), Avonmouth8 (Bristol), Beddington
Lane9 (South London), Cardiff10, Great Blakenham11 (Ipswich), K3 CHP12 in
Sittingbourne (Kent), Runcorn13 (Cheshire), Severnside Energy Recovery14 (South
Gloucestershire), and Slough Multifuel15 (Berkshire).
19. For example, the above sources show that in Cardiff it was reported that: “lower
average calorific value of waste is being generated – meaning more waste is
needed to maintain the energy output”, and in relation to Beddington Lane it was
stated that: “There is no change to the original design capacity of the incinerator
and this increase [in maximum authorized capacity] reflects the potential for the
burning of a higher tonnage of waste at a lower calorific value”.
Only Solutions LLP’s Submission to
the Nottinghamshire and Nottingham
Waste Local Plan Consultation.
See accompanying Representations for details.