SP2 - Future Waste Management Provision

The Waste Needs Assessment (WNA) indicates that 1,186,000 tonnes of Construction, Demolition and Excavation (CD&E) waste arose in 2018 and assumes that the same amount will arise every year during the Plan Period (2019-2038). It further estimates a residual amount (after re-use or recycling) of 20% or 237,000 tonnes, which will need to go to landfill. Furthermore, the WNA projects that landfill capacity will run out well before the end of the Plan Period (early 2030s).

We note that only one landfill facility (Vale Road Quarry) exists in the Plan Area to take this residual CD&E waste and that this is relatively remote from the main area of greatest demand, being the conurbation around Nottingham. We consider that a site for the disposal of CD&E waste nearer Nottingham should be allocated to meet otherwise unmet need before the end of the Plan Period and to increase compliance with the proximity principle (and draft Policies SP4 and SP5).

To this end, we object to the omission of land adjacent to Shenton Lodge, Derby Road, Kirkby-in-Ashfield, Nottingham as an allocation for sustainable CD&E waste landfill. The site has previously been the subject of planning application reference F/3080 for this use and assessments of topography, ground conditions, flood risk, transport, dust, landscape and ecological impacts have been undertaken and restoration plans prepared. We provide these reports by separate email.

We consider that the lack of available alternatives outside of green belt to meet the identified need would constitute the exceptional circumstances necessary for removal from green belt in accordance with NPPF paragraphs 140 and 141.

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

We will respond by email as the online portal does not have the functionality to incorporate tables etc. in the comment / representation boxes.

We will respond by email as the online portal does not have the functionality to incorporate tables etc. in the comment / representation boxes.

We will respond by email as the online portal does not have the functionality to incorporate tables etc. in the comment / representation boxes.

Please find attached Newark and Sherwood District Council’s consultation response to the Draft Waste Local Plan. Our response was
approved by the Council’s Economic Development Committee on the 23 March 2022.

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.

Representation on behalf of Mick George Ltd to the Nottingham and Nottinghamshire Draft Waste Local Plan.
See Representations.

These representations are submitted by Mick George Ltd (MGL), which is one of the largest waste
and aggregates companies in the East of England and in the East Midlands. This representation is
designed to support the promotion of Dorket Head as an inert landfill site and to make more general
comments about the strategy proposed to be adopted in the Waste Local Plan. The company has
been unable to participate in the local Plan process before now as it has only recently acquired the
rights to develop the site.

Only Solutions LLP’s Submission to
the Nottinghamshire and Nottingham
Waste Local Plan Consultation.
See accompanying Representations for details.