5.48

Change “If implemented, this non-operational capacity, could help to reduce future landfill disposal requirements.” to read “If implemented, this non-operational capacity could result in incineration overcapacity”.

Unsound. It is stated that: ”If implemented, this non-operational [energy recovery] capacity, could help to reduce future landfill disposal requirements” but this is unproven because it is unclear how much of the waste that would go to landfill would be combustible, or if the waste that would be treated if combustible would be landfilled in any case given the high level of incineration capacity in neighbouring authorities. It is also possible that an increase in energy recovery capacity could increase demand on landfill due to the increased production of by-products such as incinerator bottom ash which is sometimes landfilled.

The plan should suggest halting plans to increase EfW incineration capacity within Nottinghamshire as building this extra capacity will be against National guidance that overcapacity of incineration facilities should be avoided both locally and nationally. The fact that an extra 892,100tpa EfW incineration capacity is planned for, shows an astonishing lack of forward planning when NCC's own waste local plan document predicts only 180,494tpa deficit in 2038 with 160,284tpa surplus available capacity for recycling available in 2038. If recycling rates increase slightly then no extra capacity will be needed. If AD capacity increases in line with separate food waste collection then no extra capacity will be needed. It's imperative that this extra incineration capacity is not built as it will contravene National policy.

I disagree that the capacity requirements for HIC waste stream disposal and Energy recovery in 2038 will be as high as calculated yet, even with these calculations, there is a deficit of only 180,494tpa (126,825 + 53,669) in 2038. Yet NCC has already passed plans to build another 892,100tpa EfW incineration capacity. The throwaway comment about 892,100tpa incineration "could help to reduce future landfill disposal requirements" belies the fact that building these incinerators will be contrary to national guidance/legislation to avoid overcapacity of incineration both nationally and locally.