5.2

The WNA should be updated to reflect the residual waste treatment capacity located within a 2-hour drive from the Plan area, reflecting in particular the 1.45 million tonnes of incineration capacity at Ferrybridge which currently accepts waste from Nottinghamshire and which is located about 1.5 hours from Nottingham. The Plan should be reoriented to avoid incineration overcapacity at local, regional, and national levels.

The draft Plan is unsound in that it is not justified and not effective. This is due to the failure to recognise the high levels of incineration capacity in neighbouring Authorities and the fact that this capacity could justify the Plan area having less incineration capacity than potential incinerator feedstock in order to avoid exacerbating regional overcapacity that could adversely impact on the waste hierarchy and that could result in waste being imported from long distances in contravention of the proximity principle.

For example, the draft Plan does not spell out how the current arrangements with Veolia mean that waste arising in Nottinghamshire is routinely sent for incineration in North Yorkshire. Indeed, the draft Plan fails to address the way that waste routinely travels 2 or more hours to reach its treatment destination, and the fact that there is significant incineration capacity (existing and in active development) within 2-hour isochrone of the Plan area. Explicit reference should be made to the 455,000 tonnes of capacity at the Newhurst Energy Recovery Facility (30 minutes from Nottingham), 169,000 tonnes of capacity at Drakelow Park Renewable Energy Centre (50 minutes from Nottingham), 130,000 tonnes at Baddesley Energy from Waste Facility (50 minutes from Nottingham), 210,000 tonnes at Stoke Energy from Waste Facility (1 hour from Nottingham), 340,000 tonnes at Staffordshire ERF (1.25 hours from Nottingham), 400,000 tonnes at Kelvin Energy ERF (1.25 hours from Nottingham), 118,000 tonnes at Wolverhampton Energy from Waste Plant (1.5 hours from Nottingham), 245,000 tonnes at Sheffield ERF (1 hour from Nottingham) and all other facilities within approximately 2 hours drive from the Plan area, not least the 1.45 million tonnes of incineration capacity at Ferrybridge which currently accepts waste from Nottinghamshire and which is located about 1.5 hours from Nottingham.

Also see comments on Paragraph 3.37 for Government statements regarding the need to avoid incineration overcapacity.

Note: Only Solutions LLP is challenging the soundness relating to this consultation point. We have no position on legal compliance or the duty to co-operate, but there is no option to indicate this in the interactive online consultation system.