Table 10. Predicted Waste Arisings by Forecast Waste Management Method in 2038 (tpa rounded to nearest 1,000 tonne)

Table 10 should be corrected to reflect the correct totals.

Confusion arises with respect to Table 10 as the right hand side totals do not match the numbers contained in the columns to the left of the total column, e.g. 193,000 + 103,000 = 296,000 and not 348,000 and 419,000 + 828,000 + 1,114,000 = 2,361,000 not 2,309,000.

The figures for Energy Recovery/Other disposal appear to be based on the assumption that all waste within the code 19 12 12 would be potentially suitable for energy recovery and that the 10% landfill target applies to all waste including C&I waste (as per Table 12 of the WNA).

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.

In fact, a large proportion of 19 12 12 currently sent to landfill is material that is inert and not combustible (or uneconomic to send for incineration as it could be landfilled at the lower rate) - see attached document. Such waste should be reallocated from ‘Recovery’ to ‘Disposal’.

Energy recovery by incineration (Energy from waste - EfW) should be a separate category from Other disposal as it should be classified as lower down the waste hierarchy. Anaerobic digestion should be classified as recycling especially when dealing with separately collected food waste. Without separate classification of anaerobic digestion there is no remit for increasing provision within this plan. Increased provision seems to be solely an increase in incineration facilities which is a backward step and means that waste will be treated lower down the waste hierarchy that necessary.

Firstly, there is an error in Table 10. The total for Energy recovery/Other disposal should be 296 not 348.
Energy recovery/ Other disposal should be defined more precisely. Incineration (energy from waste - EfW) should be a separate category and should not be considered equivalent to Other disposal such as anaerobic digestion. It should be classified as lower down the waste hierarchy and therefore be a separate category. I think waste arisings figures are higher than will be the case because there will be lower per household waste and higher recycling rates as I've explained previously.