Comment

Representation ID: 753

Received: 29/03/2022

Respondent: East Leake Parish Council

• In considering the relative merits of different methods of waste disposal, there should be recognition of the adverse impact of carbon dioxide emissions from incineration, and a strong commitment to carbon capture for this process.

Comment

Representation ID: 754

Received: 29/03/2022

Respondent: East Leake Parish Council

• It is disappointing that there is no commitment to increase the amount of food waste dealt with by anaerobic digestion rather than incineration or landfill. In order to do this separate collection is required, and its introduction should be a key objective for Nottingham and Nottinghamshire at the earliest opportunity.

Comment

Representation ID: 755

Received: 29/03/2022

Respondent: East Leake Parish Council

• Consideration should be given to creation of a “Resource Recovery Park”
including a “Household Waste Recycling Centre” at the Ratcliffe on Soar power station site, at the same location as the new incinerator, to minimise transport of waste and to increase opportunities for recovery, re-use and recycling using innovative technologies.

Comment

Representation ID: 756

Received: 04/04/2022

Respondent: Uniper UK Limited

Uniper has reviewed the draft Nottinghamshire and Nottingham Waste Local Plan (January 2022) and would like to make this representation regarding the information presented in Section 5 Waste Management in the Plan Area.

We have noted that many of the assumptions used to determine future waste tonnages are based on national target recycling rates (e.g. 65% for municipal solid waste (MSW) by 2035 in England). While the aspiration of these targets is admirable, we believe that they do not represent a likely scenario that takes into account the practical challenges, both techno-economic and behavioural, to increase the levels of recycling. Even countries (e.g. Germany and Wales) with more than 10 years of implementation of ambitious recycling policies, the recycling rates achieved are around 60%. As stated in the draft Waste Local Plan, the plan area’s recycling rate was 39% in 2019, well below the existing target and very far from the 65% target 2038; the required increase will be a significant challenge even with the benefit/addition of separate food waste collection being implemented.

While Section 5 of the Waste Local Plan has clearly selected high recycling scenarios, it is our belief that more moderate recycling rates would better represent realistic outcomes. This is not to say that recycling should not be supported and encouraged. However, if ambitious recycling targets are used to estimate future waste tonnages, and these recycling targets are not achieved, then the need for future waste treatment facilities will be underestimated in the Waste Local Plan. This will have the effect of discouraging the further development of alternative waste treatment facilities, with the consequence of having to export waste out of the plan area, or increase use of landfill, to deal with the shortfall.

We have already observed this problem with the Nottinghamshire and Nottingham Waste Needs Assessment by AECOM, which was used to inform the drafting of Section 5 of the Waste Local Plan. Up to 2038 the preferred scenario in the AECOM report is premised on projecting forward assumptions that no new waste management facilities will be built, local authority waste will reduce per household along a ‘medium trajectory’ and commercial and industrial waste will increase along a medium trajectory throughout the assessment period. Based on this preferred scenario of high recycling rates, it is projected that there would be an oversupply of recovery capacity of 35,378 tonnes per annum (tpa) in 2038. However, the AECOM report also identifies that if recycling was not to increase to a high level as projected, there would be a shortfall of recovery capacity in the area of 212,140 tpa.

We appreciate that the draft Waste Local Plan does acknowledge that estimates of future waste tonnages will be reviewed as part of preparing the next stage of the Plan. We strongly recommend that a more in-depth analysis of future (and, importantly, achievable) recycling levels should be incorporated into the Plan in the next iteration.

Comment

Representation ID: 768

Received: 30/03/2022

Respondent: Mansfield District Council

Waste Storage

• From an operational point of view, it is important that any developments have adequate storage provision and this is something that we have had issues with in the past. There needs to be enough storage space to enable residents to participate in all recycling services.

• If the waste hierarchy is to be considered when plans are being drawn up, there should be encouragement for communal properties to have an area to present / store bulky waste items (i.e. furniture) for collection by a charity or social enterprise.

• Whilst the details from the Environment Bill regarding waste management and the consistency of household recycling collections have yet to be confirmed, it is anticipated that there will be food waste collections for householders and businesses and this will inevitably require additional storage.


Waste Collection Points

• There seems to be a general move towards private drives and shared access on a lot of new residential developments which can cause issues on collection days as the resident does not want the 26 tonne vehicle driving on their private drive but they also do not want ‘X’ number of bins at a collection point at the entrance to the development.

Waste Collection Vehicles

• The switch to electric vehicles will only gather more pace over the next 16 years (including refuse vehicles) so it would be good to see some reference to charging facilities at waste facilities or some recognition that there will be a reduction in noise and an improvement in local air quality. The number one strategic objective is to act on climate change and as the way we transport and collect waste will change with electric vehicles becoming more common, there should be a steer towards developing this in any new infrastructure.

Comment

Representation ID: 769

Received: 08/04/2022

Respondent: Leicestershire County Council

Since the evidence base was prepared, we understand that a further EfW facility at Ratcliffe-on-Soar has been permitted. It would be useful to know capacity and throughput of this. This facility will likely have cross-boundary impacts and we are grateful for agreement that this will be looked at.
It is noted that the emerging Waste Local Plan and Waste Needs Assessment does not take into account undelivered capacity such as the recently permitted EfW at Ratcliffe-on-Soar. Its inclusion in the evidence base would be useful to ascertain impact upon waste flows.

Comment

Representation ID: 770

Received: 08/04/2022

Respondent: Leicestershire County Council

We also welcome the opportunity to comment on the landfill rates and capacity. Again, the commitment from Nottinghamshire to reflect with AECOM on the landfill component is supported. The absence of non-hazardous landfill capacity from 2024 onwards is an issue and would result in waste movements to other authority areas that have capacity. This may result in some waste having to travel greater distances than at present, which needs to be considered against the intention to minimise the impacts of transporting waste in Strategic Objective 7. In addition, it would also place pressure on other authority’s non-hazardous landfill capacity. These issues should be considered.

Comment

Representation ID: 772

Received: 08/04/2022

Respondent: Leicestershire County Council

With regard to Table 11, it would be useful for there to be clarification in relation to the -3,567,089 figure for remaining disposal capacity is per annum or cumulative over the life of the plan (noting that the table title include reference to tpa).

Comment

Representation ID: 774

Received: 31/03/2022

Respondent: Rushcliffe Borough Council

Forecasting future waste arising in the Plan area
RBC question the conclusions on page 31 and 32 that household waste will decrease (Scenario B (Low rate of decline)) as any decline in household residual waste (which cannot be recycled) may be off-set by the rise in the number of residents working from home. RBC are not seeing a decrease (just a smaller drop now some are returning to a mix of both office and remote).

Comment

Representation ID: 775

Received: 31/03/2022

Respondent: Severn Trent Water Ltd

Paragraph 5.19
Severn Trent would recommend that along with explaining what wastewater is there is an additional paragraph that highlights the benefits of separating surface water at source, and directing flows towards SuDS that outfall to the most sustainable drainage outfall in accordance with the drainage hierarchy or are harvested for re-use i.e. rain water used for flushing toilets etc.

Comment

Representation ID: 779

Received: 13/04/2022

Respondent: Sir or Madam

It is noted that the Plan is a strategic document and aims to provide the planning policy framework against which all proposals for new waste development will be assessed in Nottinghamshire and Nottingham and forms the land use planning strategy for waste development. As such the Plan’s relevance to HS2 is largely limited to the forecasted mass of Construction, Demolition and Excavation Waste (CD&E) in the Plan and whether this is reasonably accounts for HS2 (CD&E) wastes generated over the same time period.

Based on comparison of figures estimated in the Plan (section 5.32, Table 3) and those quoted in the Working Draft Environmental Statement (WDES) Volume 3 (which only provide figures for the whole HS2 East Leg), we are of the opinion that HS2’s CD&E waste contribution is minimal and the figures stated in the Plan’s forecast are reasonable. Therefore, from a HS2 perspective we would have no objection to the CD&E figures quoted in the Plan.

Finally, the authority should note the Government’s recently published Integrated Rail Plan (IRP) and what it means for the HS2 project in this location. The IRP itself can be found at: https://www.gov.uk/government/publications/integrated-rail-plan-for-the-north-and-the-midlands.

The IRP has also identified that further development work is required - for example, how best to get HS2 trains into Leeds. Depending on the outcome of this work, Government will consider updating safeguarding as required but at this time we do not expect any changes to safeguarding which will remain unless or until different plans are confirmed. As you are aware Safeguarding Directions are kept under review anyway and are updated periodically to reflect the latest route design. They can also be removed if necessary and safeguarding can apply route-wide or in specific locations.

Comment

Representation ID: 784

Received: 04/04/2022

Respondent: Mick George Ltd

CD& E Waste arisings
4. The national guidance for forecasting CD&E arisings is mentioned in paragraph 5.30. However, we
note that PGG says that Local Plans should identify need for new waste management facilities which
should include reference to waste arisings (PPG 28‐022), and imports and exports. Moreover, this
also includes forecasting amounts of waste to be managed at the end of the plan period (PPG 28‐
028), and that although local authorities should start from the basis of net arisings remaining
constant over time, they should also take into account annual returns from waste management
facilities (PGG28‐033) as well as major infrastructure projects and regeneration initiatives. The WDI
data shows, as the plan admits, deposits of inert waste between 670,000 tonnes and 530,000
tonnes in the last five years alone, most of which are local arisings. This does not suggest that the
levels of arisings will be constant. In fact, they vary radically due to a number of factors, most
commonly the levels of construction in the area, and the availability of voidspace. This variability in arisings and deposited waste is also occurring when CL:AIRE is available to developers to recategorise material as non‐waste and remediate material on‐site.

Comment

Representation ID: 785

Received: 04/04/2022

Respondent: Mick George Ltd

Treatment Capacity
6. We agree with the Plan’s approach to use EA data on remaining landfill capacity rather than data on
planning permissions to assess future availability. We note that Table 6 shows an inert landfill
capacity at the end of 2019 of 2.265 Mt. Within one year this had dropped to 1.96 Mt. There is some
future capacity permitted but not yet operational at Dorket Head (southern extension) some of which is to be brought forward to prevent the sterilisation of minerals closest to new‐build housing on the edge of Arnold. However, this does not take account of the significant quantities of CD&E waste diverted to land recovery, which will be dealt with below.

Comment

Representation ID: 786

Received: 04/04/2022

Respondent: Mick George Ltd

Scenarios – CD&E Waste
7. Defra’s UK Statistics on Waste 2021 shows that in 2018 the recovery rate for non‐hazardous CD
waste in England was a remarkable 93.8% (Table 5 Recovery rate from non‐hazardous construction
and demolition waste, UK and England, 2010‐18). This confirms that CD waste recycling/recovery is
already at the maximum which was reiterated by the Minerals Products Association’s February Press
Release on the subject of Recycled aggregates in the UK market, (which was shared by all the AWP
secretaries). The Defra report also says that “The largest waste material categories generated in the
UK in 2018 were ‘Mineral Wastes’ (80.4 million tonnes), and ‘Soils’ (58.5 million tonnes). Together,
these make up almost two thirds (63%) of total UK waste.” (page 13) In addition, Table 9 shows that
55% of recycled or recovered materials comprise mineral wastes whilst 90% of backfilled materials
are soils, and 58% of all landfill are soils.
8. The draft plan notes that recycling and recovery rates for CD&E waste are already at high levels
(paragraph 5.43). We have examined the recycling/recovery scenarios for CD&E waste presented in
Table 9 and find them confusing. The table asserts that in the ‘business as usual’ scenario there is no
change to current recycling/recovery rates of 82.6%. This may be true of CD wastes which nationally
have reached saturation levels, but it is certainly not true of E waste. If an 82.6% recycling/recovery
rate is applied to the county arisings in Table 3 then the landfill element of arisings would be
206,000 tonnes. The high recycling scenario posits a 95% recycling/recovery rate by 2038 leaving a
residue of 59,000 tonnes to landfill each year (Table 10).
9. We find this very unrealistic. This would require the recovery of not only all of the hard CD wastes,
but almost all of the soft E wastes as well, which in turn would depend on a steady supply of
licensed land recovery operations. Experience shows that these are either short lived, or are
constrained by operational considerations. For example, the Harworth Tip recovery project on the
Doncaster border is too far away from the centre of the county where the bulk of inert wastes are
generated, and the reliance on this site for recovery of the majority of Nottinghamshire’s inert
waste arisings is not practicable. Similarly, for the recovery rates to be reliably complied with new
projects will have to come forward as older sites are completed, such as Bentinck Tip, Styrrup
Quarry and Coneygre Farm.

Comment

Representation ID: 787

Received: 04/04/2022

Respondent: Mick George Ltd

MGL’s view is that the circumstances of a site (i.e. whether it is an acceptable planning solution)
should determine whether it should be filled with inert waste, whether it termed a recovery operation or a landfill. Indeed, it is not logical to declare an inert landfill as not a land recovery operation since the environmental impact of it is almost exactly the same as a recovery operation (or better because of improved investment in infrastructure) and the end result of it is largely the
same – land reclamation.
11. It is MGL’s view that to not plan for some specific inert landfill but to rely wholly on recovery projects is both unwise and risky, especially in view of the high levels of imports to recovery operations.
12. To illustrate this point, we present an analysis of the 2020 WDI data for Notts inert waste landfill and recovery below.
(See accompanying document)
13. This clearly shows that there is not a hair’s breadth between the two types of site in terms of the
proportion of input which is soils, which is exceptionally high. However, when it comes down to the
source of the waste, the inert landfills take in a much higher proportion of local waste than do the
recovery operations, even allowing for the unspecified nature of the source of inputs to Vale Rd
landfill. Even if half of the Vale Rd input came from outside the county, the combined effect would
still be much higher than the recovery operations. The reason why recovery operations commonly
draw material from further afield is that they often have much lower operating standards than
landfills and can compete with material more easily, and they are often governed by a strict
timetable to complete operations and thus prioritise input quantities over profitability. However,
this is not to deny that recovery operations supply a valuable service even if it is focused outside the
county.
14. The outcome of this argument is that we consider that the capacity gap analysis presented in Table
12 severely under‐estimates the need for inert waste disposal capacity. The arisings for CD&E waste are already in 2019 in reality much higher than the Plan’s 2019 figure of 207,700 tonnes. Taking
both types of site and allowing a 50% share of Vale Rd’s input from local sources, leads to a
combined arising and deposited figure of the order of 226, 800 tonnes. Unless recovery operations
of the required magnitude, frequency and location come forward, it is unlikely that this type of
waste management could deal with all arisings and imports, and that some capacity for inert landfill
will be needed for the foreseeable future, especially for the south west of the county where the bulk
of arisings occur.

Comment

Representation ID: 820

Received: 12/04/2022

Respondent: Shlomo Dowen

With respect to the Waste Needs Assessment (WNA), Only Solutions notes how the WNA is described as “an important part of the evidence base for the Waste Plan” (e.g. at dWLP paragraph 5.2).
A range of dWLP tables and policies are predicated on the WNA, including the
dWLP’s Table 11 Capacity gap analysis and associated supporting text. The WNA
is also relevant to dWLP policies such as Policy SP2.
We agree with the following WNA statement from paragraph 3.15 that: “Historic
trends indicate that waste per household is likely to continue to decline within
the plan area”.
Forecasts of future waste arisings and recycling rates
Even the WNA’s highest waste decline and recycling scenarios fail to keep pace with the trajectory implied by the Government’s proposal to halve residual waste per capita by 2042 (relative to a 2019 base year) which is associated with a municipal waste recycling rate of between 70% and 75%.
As such, with respect to WNA’s Table 3 LACW Scenarios for tonnes of waste per household (tph), while Scenario 1 (‘High decline’) should be seen as more realistic
than Scenarios 2 (‘Low decline’) and 3 (‘No change’), Only Solutions calls for the modelling of an even higher decline scenario for LACW that more closely aligns
with emerging Government targets and aspirations, reflecting current and emerging Government proposals to minimise waste arisings.
Such a ‘Higher decline’ Scenario should be used to the inform the Waste Local Plan, instead of WNA Scenario 2 (also referred to as ‘Scenario B’ in Table 1 of the
DWLP), including being used for WLP Tables 10 and 11.
Only Solutions further notes that the WNA justification for recommending Scenario 2 be used for the WLP not only fails to take appropriate account of emerging Government targets and aspirations but also fails to anticipate the
possibility of economic slow-downs and even downturns (recessions).
Whilst acknowledging the profound impact of a recession on waste arisings (e.g.
at WNA paragraph 3.21) the WNA fails to consider the impact of an economic
recession at any point between now and 2038.
In light of the rapidly rising inflationary pressures on households, the economic challenges associated with Brexit, Covid, climate change, and geopolitical
instability arising from the war in Ukraine, the prospect of slower UK economic growth and even recession appears to be increasingly realistic, whereas the prospect of two and a half decades of unimpeded grown seems unlikely.
Additionally, we can expect to see further decoupling of waste arisings and economic growth in Nottinghamshire, e.g. due to shifts away from the production of physical goods and towards the provision of digital services and businesses that trade in the knowledge economy. Such service provision is associated with significantly lower levels of waste arisings.
Changing patterns of behaviour and consumption will also impact on overall waste arisings, including the Covid-accelerated trend that favours increases in
home working which in turn greatly reduces the waste generated as part of employees’ travel to and from their workplace.
In relation to forecasting future Commercial and Industrial (C&I) waste arisings, both the WNA and the dWLP (e.g. Table 2 of the dWLP) underestimate the level of waste reduction that can be anticipated in light of the Government’s Environmental Target proposal to halve residual waste by 2024 (relative to a 2019 base year) and current and emerging Government proposals to minimise waste arisings and residual waste arising.
Only Solutions calls for the modelling of an even higher decline scenario for C&I waste that more closely aligns with emerging Government targets and aspirations.
Estimates of existing and anticipated waste treatment capacity.
There are two further considerations the need to be taken into account when considering the need for waste management facilities in Nottinghamshire and
Nottingham, namely the quantity of waste required to produce Refuse Derived Fuel (RDF) and the potential for Solid Recovered Fuel (SRF) to be used to power
cement kilns.
With respect to RDF, Only Solutions notes how – due to moisture loss / dewatering – the production of 1 tonne of RDF requires more than 1 tonne of ‘raw’ waste, meaning that the capacity of incinerators designed to process RDF
feedstock can be assumed to be higher than the headline RDF incineration capacity figure.
In relation to the potential for capacity EMERGE, it should be noted that this facility is expected to process refuse derived fuels (RDF). Because it takes more than one tonne of raw waste to produce a tonne of RDF, this means that the effective capacity (i.e. demand for feedstock) exceeds the headline capacity.
Tolvik has estimated moisture loss (reduction of mass) at MBT facilities in the UK to be on average around 20%, meaning incinerators in effect require around 1.25
times the quantity of source (‘raw’) waste19 relative to the headline incineration capacity (excluding material loss through recycling).20 Reported Mass Loss as % of input Tonnage for UK MBTs (Tolvik 2017)
If this is taken into account, the capacity of the incinerator should be increased by 1.25x. The multiplication factor is based on the formula 100 ÷ (100-N) where N is
the mass loss due to moisture loss. For example 100 ÷ (100-20) = 100 ÷ 80 = 1.25
It would be worth stating in the supporting text of the Waste Local Plan that the total feedstock demand needs to be taken into account which assessing the impact of proposed incinerators / EfW plants that are designed to treat RDF.
The multiplication factor is based on the formula 100 ÷ (100-N) where N is the mass loss due to moisture loss. For example 100 ÷ (100-20) = 100 ÷ 80 = 1.25
20 Briefing Report: Mechanical Biological Treatment – 15 Years of UK Experience. Tolvik, September 2017. Available from: https://www.tolvik.com/wp-content/uploads/2017/09/Tolvik-2017-Briefing-Report-Mechanical-Biological-Treatment.pdf
According to documentation provided to the Environment Agency by Uniper in their application for an nvironmental Permit for the EMERGE facility: “the installation will be capable of processing up to 585,000 tonnes per annum”. In the event that this capacity was met using RDF, this would equate to more than 731,000 tonnes of ‘raw’ waste per annum.
With respect to SRF, cement kilns, and co-incineration capacity, Only Solutions notes that residual waste is increasingly being converted into SRF for use as
feedstock to power cement kilns as an alternative to the conventional use of fossil fuels. Environmental consultancy Eunomia predicts 1.0m tonnes of UK
cement kiln feedstock from residual waste by 2030.22
Indeed, the online consultation event for the dWLP included a presentation on this topic. Yet, despite this, the WNA and associated dWLP policies fail to account
for the way that some of the residual waste arising in Nottinghamshire and Nottingham could be expected to be used for co-incineration purposes and would
therefore not be available for use as feedstock for conventional incinerators.
This means that the level of incineration overcapacity could be higher than is accounted for in either the WNA or the DWLP.

Comment

Representation ID: 848

Received: 12/04/2022

Respondent: Shlomo Dowen

dWLP Table 5 column totals are incorrect
81. There appears to be a number of errors contained within dWLP Table 5 (on page 36) when adding up the various columns to arrive at a total. For example:
• The value in the total column for ‘Recycling’ is inconsistent with the sum of the respective waste streams. When adding the respective capacities for HIC
and CD&E and Hazardous recycling the total should be 2,061,400 (and not 2,060,500 as portrayed); and
• The value in the total column for ‘Recycling total’ is inconsistent with the sum of the respective waste streams. When calculating the ‘Recycling Total’ the
sum should be 2,557,000 (and not 2,061,400 as portrayed).
Energy from incineration should not be described as ‘low carbon’
82. Only Solutions takes issue with the dWLP framing that, in relation to the views of Issues and Options consultees, “The majority of respondents supported the use of energy recovery where this would reduce the need for landfill and increase the supply of low carbon energy”.
83. Numerous studies have found that is not correct to suggest that the energy currently generated from waste incineration could reasonably be described as
‘low carbon energy’, including ‘Evaluation of the climate change impacts of waste incineration in the United Kingdom’24,‘The climate change impacts of burning
municipal waste in Scotland - Technical Report’25, ‘Greenhouse Gas and Air Quality Impacts of Incineration and Landfill’26, 'Dirty white elephants: Incinerators
were supposed to solve the UK’s waste crisis. Are they making it worse?'27 and the Climate Change Committee’s (CCC’s) Sixth Carbon Budget (see below).
84. The incineration of a tonne of waste typically results in the direct release of around 1 tonne of CO2. Around half of the CO2 in mixed waste is 'fossil CO2', and
this proportion can be significantly higher when food waste is separately collected.28
24 https://ukwin.org.uk/files/pdf/UKWIN-2018-Incineration-Climate-Change-Report.pdf
25 https://www.zerowastescotland.org.uk/content/climate-change-impact-burning-municipal-waste-scotland
26 https://www.clientearth.org/latest/documents/greenhouse-gas-and-air-quality-impacts-of-incineration-andlandfill/
27 https://www.source-material.org/blog/dirty-white-elephants
28 https://ukwin.org.uk/files/pdf/UKWIN-2018-Incineration-Climate-Change-Report.pdf
85. As set out in the table overleaf, the CCC noted that "In a Net Zero world EfW facilities are likely to be significantly higher carbon than other forms of energy
production" and the CCC categorises unabated waste incineration as a 'highcarbon' activity.
86. In May 2021 the UK Government stated: "Incineration of fossil derived waste is a contributor to greenhouse gas emissions. Total greenhouse gas emissions from waste incineration accounted for around 1.4% (6.47 million tonnes of carbon dioxide equivalent) of the UK’s [non-biogenic] greenhouse gas emissions in 2019.
Of this, about 6.19 million tonnes of [fossil] carbon dioxide equivalent was emitted from Energy from Waste plants. It is clear that we will need to reduce that impact. That is why the Government continues to take action, including through our Environment Bill measures, to reduce, re-use and recycle more of our waste and to move to a circular economy".29
87. Focussing on the fossil CO2e released per net unit of energy exported to the grid, the annual reported real world carbon intensity of the incinerators set out above
typically ranged from around 828 to 873 grams of fossil CO2e per kWh exported.
This is significantly higher than the carbon intensity of Combined Cycle Gas Turbines (CCGT) and the BEIS estimates for long-run and grid average fossil
carbon intensity. The total CO2 emissions released by these incineration plants is roughly double the fossil CO2 figure because of the release of biogenic CO2.
88. Even if one assumes the carbon intensity for incinerators is the same as that claimed by Cory Energy for their Riverside incinerator of 617 gCO2/kWh30, modern waste incinerators still have a significantly higher carbon intensity than the conventional use of fossil fuels (and far higher emissions than technologies like
solar and wind).
89. Tables overleaf are reproduced from the July 2021 ‘Good Practice Guidance for Assessing the GHG Impacts of Waste Incineration’.

Comment

Representation ID: 849

Received: 12/04/2022

Respondent: Shlomo Dowen

Much of the residual waste stream could be recycled
91. Page 37 of the dWLP uncritically repeats incineration industry propaganda with
respect to the demand of domestic energy recovery. The suggestion that there is
a “need for the need for more energy recovery capacity as RDF exports are
rapidly decreasing and the UK still landfills large quantities of waste which could
be subject to energy recovery” is misleading in several respects.
92. Firstly, RDF is not sent to landfill, so if RDF export is declining then this could be
attributed to an increase in domestic (UK) incineration capacity rather than to any
unevidenced practice of sending RDF to landfill.
93. Secondly, much of what is currently being sent to landfill or incineration could
and should instead be recycled, composted, or substituted. Thus, material being
sent to landfill should not be used as justification for increases in incineration
capacity, as there is very little by way of combustible material that could not be
separately collected for recycling or composting.
94. Defra's August 2020 'Resources and Waste Strategy Monitoring and Evaluation
Report' found that only 8% of England's residual waste from household sources
was "Difficult to Recycle or Substitute", concluding that the majority of the
residual waste was readily recyclable.
95. According to Defra's Report: "The large amount of avoidable residual waste and
avoidable residual plastic waste generated by household sources each year
suggests there remains substantial opportunity for increased recycling…The
message from this assessment is that a substantial quantity of material appears
to be going into the residual waste stream, where it could have at least been
recycled or dealt with higher up the waste hierarchy…Of total residual waste from
household sources in England in 2017, an estimated 53% could be categorised as
readily recyclable, 27% as potentially recyclable, 12% as potentially substitutable
and 8% as difficult to either recycle or substitute…Of approximately 13.1 million
tonnes of residual waste generated by household sources in England in 2017,
around 7 million tonnes could be categorised as readily recyclable, 3.5 million
tonnes as potentially recyclable, 1.6 million tonnes as potentially substitutable,
and 1.0 million tonnes as difficult to recycle or substitute".47
47 https://www.gov.uk/government/publications/resources-and-waste-strategy-for-england-monitoring-andevaluation
April 2022 Only Solutions submission to Notts Waste Local Plan Consultation Page 22
Charts from Defra's 2020 Resources and waste strategy monitoring report
showing how much residual waste is considered avoidable

Comment

Representation ID: 860

Received: 12/04/2022

Respondent: Shlomo Dowen

There appears to be a number of errors contained within dWLP Table 5 (on page
36) when adding up the various columns to arrive at a total. For example:
• The value in the total column for ‘Recycling’ is inconsistent with the sum of
the respective waste streams. When adding the respective capacities for HIC
and CD&E and Hazardous recycling the total should be 2,061,400 (and not
2,060,500 as portrayed); and
• The value in the total column for ‘Recycling total’ is inconsistent with the sum
of the respective waste streams. When calculating the ‘Recycling Total’ the
sum should be 2,557,000 (and not 2,061,400 as portrayed).