Table 7 Recycling Scenarios

Consideration must be given as to how to make it easier to recycle more.

The assumption that recycling rates will improve is possibly optimistic.

Comments on behalf of Nottingham Friends of the Earth

1) The Waste Needs Assessment is not legally compliant or sound. In particular it fails to comply with the targets set out in the Environmental Targets (Residual Waste) (England) Regulations 2023, the Waste (Circular Economy) (Amendment) Regulations 2020 and the Environmental Improvement Plan (EIP) (2023). These aim to halve residual waste per person by 2042 (and reduce residual municipal waste per person by 29% by 2027), and to increase the recycling target from 50% to 65% by 2035. The Assessment should be revised to comply with up-to-date regulations.

This particularly relates to:

s2.3 Supporting Documents – Waste Needs Assessment

s5.23 Updated scenarios for Local Authoirty Collected Waste
s5.25 Table 1 Summary of forecasted LACW arisings
s5.29 Table 2 Summary of forecasted C&I arisings

2) Now that a 65% re-use and recycling target for municipal waste has been adopted for 2035 (Waste (Circular Economy) (Amendment) Regulations 2020 s11(a)(ii)):

s3.16 (EU Circular Economy Action Plan) is not legally compliant or sound in failing to note that the circular economy measures, including a target of 65%, were adopted in UK legislation in 2020.

s5.41 (Table 7. Recycling scenarios for LACW) is not sound in failing to require facilities to support the 65% target. 65% recycling should be considered as the 'low' recycling scenario, not the 'high' scenario, with perhaps 70% and 75% considered as higher options (which should be achievable).

3) References to the Circular Economy should more clearly support the targets in the government's Resources and Waste Strategy 2018, particularly to minimise residual waste. More emphasis should be given to facilities for re-use as well as separate collection of materials which can be recycled, and monitoring composition of waste to inform progressive reduction of residual waste.

s2.1 (Scope) is not sound in failing to include facilities for re-use as well as “recycling and waste”.

Appendix 1 (Monitoring and Implementation) SP2 – Future Waste Management Provision) should be more proactive in requiring waste compositions to be monitored.

4) References to "energy from waste" should recognise government policy that incineration should not displace facilities higher up the waste hierarchy. (See Defra statement, 11 July 2022: “The Government’s view is that Energy from Waste (EfW) should not compete with greater waste prevention, re-use, or recycling. Proposed new plants must not result in an over-capacity of EfW waste treatment provision at a local or national level.”) Also see the recent report by UK Without Incineration Network: (https://ukwin.org.uk/overcapacity/) which demonstrates that there is already a problem of overcapacity in the UK, including in the East Midlands.

s5.47 & s5.48 (Table 11: Capacity Gap Analysis) are not sound in failing to allow for targeted reductions in residual waste and the need to avoid overcapacity of energy from waste (incineration).

s7.13 (Policy SP2 – Future Waste Management Provision) is not sound in failing to ensure that “energy recovery facilities” will not prejudice achievement of residual waste reduction targets (which could be added to 1.b)i) and will not result in an over-capacity of EfW waste treatment provision at a local or regional level (which could be added as a new clause).

s7.49 (Policy SP6 – Sustainable movement of waste) is not sound in relation to importing waste from outside Nottinghamshire in not requiring all conditions to be met. The word “or” at the end of clauses 2a) and 2b) should be replaced by “and”.

5) The Plan should more clearly recognise that Anaerobic Digestion should not be considered (as "energy from waste") on the same level as incineration. (Unlike combustion, AD allows recycling of organic materials - liquid and solid - as well as generating energy, and Defra guidance on the waste hierarchy recognises this, at least for food waste.)

s7.15 – footnote 5 (Justification for Policy SP2 – Future Waste Management Provision) should note that Defra Guidance on applying the Waste Hierarchy (June 2011) indicates that Anaerobic Digestion should be considered on the same level as Recycling for some materials, particularly food waste.

6) References to energy recovery as "low carbon" should be deleted, or at least amended to make clear that burning plastic does not produce low carbon energy:

s7.6 (Introduction to Strategic Policies) is not sound in failing to include reference to the risk to climate change associated with burning plastics.

s7.47 (Justification for Policy SP5 – Climate Change) is not sound in failing to acknowledge that burning plastic is not low carbon.

Dear Sirs,

I submit my comments on the local plan which I feel lacks ambition and does not go far enough to meet the present legislation and targets.

1) The Waste Needs Assessment is not legally compliant or sound. In particular it fails to comply with the targets set out in the Environmental Targets (Residual Waste) (England) Regulations 2023, the Waste (Circular Economy) (Amendment) Regulations 2020 and the Environmental Improvement Plan (EIP) (2023). These aim to halve residual waste per person by 2042 (and reduce residual municipal waste per person by 29% by 2027), and to increase the recycling target from 50% to 65% by 2035. The Assessment should be revised to comply with up-to-date regulations.

This particularly relates to:
s2.3 Supporting Documents – Waste Needs Assessment
s5.23 Updated scenarios for Local Authoirty Collected Waste

s5.25 Table 1 Summary of forecasted LACW arisings

s5.29 Table 2 Summary of forecasted C&I arisings

2) Now that a 65% re-use and recycling target for municipal waste has been adopted for 2035 (Waste (Circular Economy) (Amendment) Regulations 2020 s11(a)(ii)):
s3.16 (EU Circular Economy Action Plan) is not legally compliant or sound in failing to note that the circular economy measures, including a target of 65%, were adopted in UK legislation in 2020.
s5.41 (Table 7. Recycling scenarios for LACW) is not sound in failing to require facilities to support the 65% target. 65% recycling should be considered as the 'low' recycling scenario, not the 'high' scenario, with perhaps 70% and 75% considered as higher options (which should be achievable).

3) References to the Circular Economy should more clearly support the targets in the government's Resources and Waste Strategy 2018, particularly to minimise residual
waste. More emphasis should be given to facilities for re-use as well as separate collection of materials which can be recycled, and monitoring composition of waste to inform progressive reduction of residual waste.
s2.1 (Scope) is not sound in failing to include facilities for re-use as well as “recycling and waste”.
Appendix 1 (Monitoring and Implementation) SP2 – Future Waste Management Provision) should be more proactive in requiring waste compositions to be monitored.

4) References to "energy from waste" should recognise government policy that incineration should not displace facilities higher up the waste hierarchy. (See Defra statement, 11 July 2022: “The Government’s view is that Energy from Waste (EfW) should not compete with greater waste prevention, re-use, or recycling. Proposed new plants must not result in an over-capacity of EfW waste treatment provision at a local or national level.”) Also see the recent report by UK Without Incineration Network:
(https://ukwin.org.uk/overcapacity/) which demonstrates that there is already a problem of overcapacity in the UK, including in the East Midlands.
s5.47 & s5.48 (Table 11: Capacity Gap Analysis) are not sound in failing to allow for targeted reductions in residual waste and the need to avoid overcapacity of energy from
waste (incineration).
s7.13 (Policy SP2 – Future Waste Management Provision) is not sound in failing to ensure that “energy recovery facilities” will not prejudice achievement of residual waste reduction targets (which could be added to 1.b)i) and will not result in an over-capacity of EfW waste treatment provision at a local or regional level (which could be added as a new clause).
s7.49 (Policy SP6 – Sustainable movement of waste) is not sound in relation to importing waste from outside Nottinghamshire in not requiring all conditions to be met. The word “or” at the end of clauses 2a) and 2b) should be replaced by “and”.

5) The Plan should more clearly recognise that Anaerobic Digestion should not be considered (as "energy from waste") on the same level as incineration. (Unlike combustion, AD allows recycling of organic materials - liquid and solid - as well as generating energy, and Defra guidance on the waste hierarchy recognises this, at least for food waste.)
s7.15 – footnote 5 (Justification for Policy SP2 – Future Waste Management Provision) should note that Defra Guidance on applying the Waste Hierarchy (June 2011) indicates that Anaerobic Digestion should be considered on the same level as Recycling for some materials, particularly food waste.

6) References to energy recovery as "low carbon" should be deleted, or at least amended to make clear that burning plastic does not produce low carbon energy:
s7.6 (Introduction to Strategic Policies) is not sound in failing to include reference to the risk to climate change associated with burning plastics.
s7.47 (Justification for Policy SP5 – Climate Change) is not sound in failing to acknowledge that burning plastic is not low carbon

I am a member of Lowdham Parish Council. Our clerk forwarded the plan to our members.

You are asking us to say if the plan is legally compliant and if it is "sound". I don't have the expertise to answer the question on legality.

Under "sound" you use the expression "sustainable development". I find that expression ambiguous. (If you launch a business producing tobacco and it flourishes, then that enterprise is sustained. So is that sustainable development? However, that isn't what we are looking for. We want an outcome that benefits, or at least doesn't harm, people, future populations or the biosphere.)

I prefer the words "sustainable" or "sustainability" which are defined as meeting the needs of the present without compromising the ability of future generations to meet their own needs.

Nowhere in the Waste Local Plan could I find discussion of the waste that gets recycled or the waste that doesn't get recycled. And I think that these materials should be considered.

For example:

Paper and cardboard
The recycling of these materials is going fine, as far as I can tell.

Steel cans
Likewise.

Plastic
This recycling isn't going well, either in Nottinghamshire or across the country or across the world. The City and County Council, the district councils and other local authorities and, indeed citizens, should be pressuring national government to take action and to get together with other governments to regulate, internationally, the production, reuse and recycling of all plastic products.
A great deal of plastic waste ends up in rivers, seas and oceans. It is swallowed by sea animals, fish and sea birds- and they die. It breaks up into microplastics too small to be seen, which have been found in human blood and mothers' milk. This is a problem that ranks with the climate and biosphere emergencies and it needs to be dealt with.
Single use pieces of plastics (some of which I enclose*) are used by the food industry, but also by other industries. A huge percentage ends up in the environment and they should be banned as soon as possible. They are a large part of the problem. Plastic drink bottles are a menace because many of them are not recycled.
(The women pictured on the front of your report, emptying six or more plastic milk bottles into a skip at a recycling centre is a paragon of recycling. But will her bottles be landfilled or incinerated or actually recycled?)

Aluminium
This is another problem material. Newark and Sherwood District Council would have us deposit foil (aluminium) food trays in their green coloured waste bins, presumably for landfill or incineration. (I don't know what happens with other district councils.) This is wrong. Clean aluminium is eminently recyclable.

Single use vapes
In the last two years single use vapes have become a problem so far as recycling is concerned. Vape batteries contain lithium, aluminium, steel, copper and plastics which can all be recycled. The casing is made of either of glass or solid plastic. The lithium is needed for electric car batteries.
Single use vapes are marketed as disposable so at least a million a week are being binned and sent to landfill or incineration. The lithium batteries can do and do catch fire if they are crushed. I believe the producers, importers and retailers should collect used vapes and arrange for them to be recycled. I enclose the "Guardian" report on single-use vapes (please see attachment).

Tetrapaks
This is an example of a wealthy company benefiting at the expense of the environment. Tetrapaks are ideal containers for liquid foods; not better than glass containers, but lighter. They are cardboard, plastic and aluminium welded together- impossible to separate at home for recycling. Many are thrown away; a small proportion can be left by consumers at dedicated collection points which are too far away for many communities; which are then transported to Halifax to be recycled. This scheme is paid for by the company.
This isn't good enough. All tetrapaks should be collected kerbside and recycled at the company's expense. But it is for the government to make this happen.

Overall, I believe that our recycling service is not nearly as good as it should be. We should be aiming to reuse or recycle 100% of waste. Materials that can't be reused or recycled should not be produced. This is a government responsibility, but we all have to pressurise the government. Single use plastics should be banned. The plastics situation should be brought under control, locally, nationally and internationally. Similarly, we should get a grip on single use vapes.

Please note that landfill emits methane, a greenhouse gas. If it's collected, presumably it will be burned, resulting in carbon dioxide, another greenhouse gas. Incinerators emit carbon dioxide. Both methods of disposal should be avoided.

This response is my own, However, it may or may not be endorsed by Lowdham Parish Council.

NB I also enclose advice for Lowdham on how to recycle. (Please see attachment).
* How are these different kinds of waste recycled?