Waste Issues and Options

Thank you for consulting NWT on the above, I welcome the emphasis on the circular waste economy and hope to see stronger targets for further waste reduction and re-use.

In this response, I have followed the normal convention of showing the existing text from the consultation document in italics and recommended changes in bold italics.

Q1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
NWT consider this is the longest period that could be appropriate, as it is essential that robust targets can be set within a reasonably predictable context. Beyond this period, external factors could change so dramatically that setting targets becomes impossible. Even within this timeframe there are likely to be substantive changes in some areas, particularly regarding packaging and re-use (which has changed considerably in the last decade), so either a review period will need to embedded in the Plan, to re-set targets, or the Plan period shortened.

Q2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
Para 3.6. does not fully encompass the breadth and value of the County’s biodiversity resource, so NWT would suggest the following additions:
“The County’s landscape is characterised by rich rolling farmlands to the south, with a central belt of mixed woodland and farmland, giving way to heathland in the north and open, flat agricultural landscapes dominated by the River Trent to the east. Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, to the north of Mansfield. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status. There is, however, a significant network of SSSIs and LWS across the County, representing the wide range of habitat types found on the diverse geology of the County and hosting diverse, and often scarce, species of flora and fauna. Some of these habitats have been created as a result of the restoration of former waste sites, and this Plan will ensure that the restoration of future waste sites contributes to this network of wildlife-rich habitats, as part of Nottinghamshire’s Nature Recovery Network”.

Plan 1 – The Plan Area does not adequately or accurately represent this biodiversity resource. The green shape that is categorized as “Sherwood Forest including Special Area of Conservation” neither shows the SAC accurately (nor the ppSPA), nor does it encompass the boundaries of “Sherwood Forest” that have been discussed and agreed by multiple parties over many years. NWT would suggest that the SAC is shown accurately as a polygon, the ppSPA is shown as a dotted line boundary, and that ,as a minimum, dots are used to show the SSSIs. We agree that at this scale, it would not be possible to show the LWS.

Q 3-8
I will not respond in detail to the questions about waste calculations and predictions, as this is not a field where NWT has technical expertise, but as a general principle, we would expect more ambitious targets for reduction and re-use for LACW, not least given the admittedly small, changes in the major supermarkets in the last year towards reduced plastic packaging etc., but which is an area that is changing rapidly. In NWT’s view, Option A is lacking in ambition and there should be a higher reduction target per household. Option D should not be countenanced at all. Similarly, rapidly advancing technologies in reuse of industrial and commercial waste as a valuable resource should also enable a higher target for the C&I sector.

Q9: Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan. Do you have any evidence to suggest that different assumptions should be made?
NWT suggest that these targets for recycling should be more ambitious, as this will drive innovation, and should be combined with drivers and incentives from the public sector to force change. The current situation under Covid 19 has shown how dramatically behaviour can be changed in a very short time (under awful circumstances that we hope will never be repeated) given sufficient government will. NWT would suggest that there is an opportunity for the WPAs to use lessons learned from the current crisis, about reductions in food waste, increased re-useable packaging (such as glass milk bottles) etc., to set considerably more ambitious targets, for the LACW stream in particular.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery is important for those last elements of the waste stream that cannot be reused or recycled, but should be considered as a last resort when absolutely all other options have been tried (as represented in the Waste Hierarchy). This needs to be more strongly stated in the Plan than in the current wording. There should be a target to reduce the production of RDF and other waste disposal by incineration. Nottingham and Nottinghamshire, in line with the former’s ambitious Carbon neutrality target and given the innovation and science sectors in the City and County, should be well placed to lead in this area of avoiding the production of materials that have to be converted to RDF.

NWT share the stated concern in the text that large, long term facilities, can have the unfortunate consequence of driving the need for waste to service them. It is also important to recognize, however, that even smaller facilities can cause this effect, as has been clearly seen by the series of unfortunate outcomes of the promotion and subsidy for anaerobic digestion on farms. In Nottinghamshire, this has directly resulted in unsustainable maize production solely for the purposes of feedstock for digesters, which has damaged soils and habitats, and added to pollution of the aquifers, results in substantial increases in NOx, NH4 and CO2 outputs from its production, and has reduced land availability for human food crops and biodiversity.

Therefore, driving the need for reduction in energy use should be the overriding policy, not supporting energy recovery. This should apply across all sectors, particularly municipal and industrial, and notably with regard to housing. So, in summary, NWT do not consider that there should be a plan for higher levels of energy recovery, as this will drive the production of more waste to supply it, rather than finding other ways of reducing that waste stream entirely.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
Availability of disposal sites can prevent or reduce innovation in finding other solutions, although there may be a need for disposal for the small fraction that cannot be used or recycled in any other way. There should be a presumption against developing large new disposal capacity in the context of strong drivers and incentives to find other solutions, so NWT would suggest that any additional capacity should be targeted to be deliberately small, to drive more material into the reduce-reuse-recycle circle.

Q12: Do you agree with the draft vision? Are there other things we should include?
NWT support the vision in general. Our only suggestion is that “ minimise the effects of climate change” is insufficiently specific, as it could refer to climate impact mitigation rather than greenhouse gas production. We suggest that “minimise greenhouse gas emissions that result from waste management in the County” is more accurate as a description of what appears to be intended.
Also the role of the restoration of waste sites to priority habitats should be highlighted by adding the following to the second paragraph:
“All waste sites will contribute towards a greener Nottinghamshire and Nottingham by ensuring that they contribute to biodiversity delivery of priority habitats and the re-
connection of ecological networks, and so ensuring that they also contribute to improving long term access for local people to high quality wildlife-rich greenspaces.”

Q13: Are the above objectives appropriate? Are there others we should consider?
Objective 1 Climate change. NWT consider that this needs to refer specifically to habitats , as there is always habitat damage as a result of new waste development, “ Encourage the efficient use of natural resources by promoting waste as a resource, limit further impacts by avoiding damage to air quality, water, habitats or soil, reduce the need to transport waste and accept that some change is inevitable and manage this by making sure that all new waste facilities are designed and located to withstand the likely impacts of flooding, higher temperatures and more frequent storms and that restoration of waste sites prioritises habitat creation, as that will also help in sequestering Carbon. “
Objective 3. The environment, This needs clarification about what is being protected, and also explicit reference to the need for waste sites to play their part in delivering biodiversity targets. Therefore, NWT suggest the following wording ; “to ensure any new waste facilities protect or enhance the countryside, wildlife and valuable habitats, protect water, soil and air quality across the plan area and thus ensure conservation of the built and natural heritage of the area. After their operational use ceases, all waste sites will be restored to beneficial nature conservation afteruse which optimises their contribution to meeting the County’s biodiversity targets and to delivering Nature Recovery Networks”
Objective 4. Community, Health and Wellbeing. The availability of wildlife-rich greenspace on people’s doorsteps is a significant factor in good physical and mental health and wellbeing , so NWT would suggest the following addition: – “to ensure any new waste facilities do not adversely impact on local amenities and quality of life from impacts such as dust, traffic, noise, odour and visual impact, and any loss of local greenspace upon which people rely for their good health and wellbeing and address local health concerns.”
Objective 5. Meet our future needs. It is essential to emphasise that any sites should be allocated on the basis of both robust SA and EIA, so that proper comparative assessments are made at the plan-making stage. Hence NWT would suggest the following addition to the wording: “Ensuring that there is a mix of site types, sizes and locations to help us manage waste sustainably wherever possible. Meet current and future targets for recycling our waste. Safeguarding existing and/or potential future sites where appropriate and where robust SA and EIA have been undertaken to allocate those sites. Locate new waste facilities to support new residential, commercial and industrial development across the plan area.”

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
NWT broadly agree with these locational priorities, but all decisions on location should always be subject to robust science based decision-making, tested through SA and EIA, so that the full range of impacts, including long distance ones such as NOx, can be properly assessed.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
In NWT’s view, using a criteria-based approach would be insufficiently robust. It is essential that a proper comparative SA of possible sites is undertaken at the same time and in a consistent manner, to ensure that the level of assessment is equal. Otherwise there is a risk of judging sites against variable criteria and contexts in the future. It is also essential to screen out unsustainable sites at an early stage, to prevent uncertainty, local concerns and potentially poor decision-making later.

Q16: What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
Of the scope listed, NWT would highlight the need for the follow changes and additions:
“Highways and transport • Air quality (for both human health and impacts on habitats and species) • Green Belt • Landscape protection • Habitat and species protection and conservation. Archaeology. Greenhouse Gas impacts • Heritage • Pollution • Noise • Flooding and water resources • Health and wellbeing • Public rights of Way. Visual impact. Restoration and aftercare to maximise the contribution to UK and County biodiversity targets.”
It is important to be aware of the issue of NOx and NH3 emissions from certain types of waste facilities potentially impacting habitats. Nitrogen deposition on habitats has been identified as the most serious pollutant of habitats across the UK and Europe and these emissions can be particularly problematic for the heathlands and calcareous grasslands found in Nottinghamshire.
Nottinghamshire has Biodiversity Opportunity Maps, (which will inform the development of a NRN map for the County over the next 12 months), they are held by the County Council through the Biodiversity Action Group, and is it is essential that these documents are taken into account in the development of the Waste Local Plan, both to protect key areas of the network and to ensure that the location of waste sites may also contribute the Network in the long term when they are decommissioned and restored.

NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape-scale conservation in Nottinghamshire, in line with the Lawton Review and the 25 Year Environment Plan, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
It is essential that up to date biodiversity information at the necessary level of detail is used to help the preparation of the Plan, both with regard to data from the NGBRC and the Biodiversity Opportunity Maps.

NWT would expect the WPAs to embed the restoration and re-creation of biodiversity into the WLP, in accordance with the requirements of the 25 Year Environment Plan and the NPPF. It is particularly important, therefore, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a waste scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Nottinghamshire in the past. So these requirements should be secured through robust planning obligations and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

For potential larger footprint waste sites NWT would expect the use of site restoration briefs at an allocation stage, as has been undertaken for the MLP. This is an exemplary and constructive approach and should be replicated in this Waste Local Plan, with the creation of priority biodiversity habitats as the primary restoration aim for all allocations and extensions.

The restoration of waste sites can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable waste sites where the substrate is acidic, and has low nutrient status. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector waste industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.
The site allocation restoration briefs should list the target priority habitats using the existing NE Natural Character Area (NCA) approach and the Biodiversity Opportunity Map, the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which may be achieved through waste site restoration, as described above:
Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows
Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches
Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.

Trent Valley and Rises:rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.
Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.
Please do not hesitate to contact me if you have any queries about the above or if I can provide more information. I look forward to working with the WPA in the development of this important Plan.

Yours sincerely,

Thank you for consulting NWT on the above, I welcome the emphasis on the circular waste economy and hope to see stronger targets for further waste reduction and re-use.

In this response, I have followed the normal convention of showing the existing text from the consultation document in italics and recommended changes in bold italics.

Q1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
NWT consider this is the longest period that could be appropriate, as it is essential that robust targets can be set within a reasonably predictable context. Beyond this period, external factors could change so dramatically that setting targets becomes impossible. Even within this timeframe there are likely to be substantive changes in some areas, particularly regarding packaging and re-use (which has changed considerably in the last decade), so either a review period will need to embedded in the Plan, to re-set targets, or the Plan period shortened.

Q2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
Para 3.6. does not fully encompass the breadth and value of the County’s biodiversity resource, so NWT would suggest the following additions:
“The County’s landscape is characterised by rich rolling farmlands to the south, with a central belt of mixed woodland and farmland, giving way to heathland in the north and open, flat agricultural landscapes dominated by the River Trent to the east. Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, to the north of Mansfield. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status. There is, however, a significant network of SSSIs and LWS across the County, representing the wide range of habitat types found on the diverse geology of the County and hosting diverse, and often scarce, species of flora and fauna. Some of these habitats have been created as a result of the restoration of former waste sites, and this Plan will ensure that the restoration of future waste sites contributes to this network of wildlife-rich habitats, as part of Nottinghamshire’s Nature Recovery Network”.

Plan 1 – The Plan Area does not adequately or accurately represent this biodiversity resource. The green shape that is categorized as “Sherwood Forest including Special Area of Conservation” neither shows the SAC accurately (nor the ppSPA), nor does it encompass the boundaries of “Sherwood Forest” that have been discussed and agreed by multiple parties over many years. NWT would suggest that the SAC is shown accurately as a polygon, the ppSPA is shown as a dotted line boundary, and that ,as a minimum, dots are used to show the SSSIs. We agree that at this scale, it would not be possible to show the LWS.

Q 3-8
I will not respond in detail to the questions about waste calculations and predictions, as this is not a field where NWT has technical expertise, but as a general principle, we would expect more ambitious targets for reduction and re-use for LACW, not least given the admittedly small, changes in the major supermarkets in the last year towards reduced plastic packaging etc., but which is an area that is changing rapidly. In NWT’s view, Option A is lacking in ambition and there should be a higher reduction target per household. Option D should not be countenanced at all. Similarly, rapidly advancing technologies in reuse of industrial and commercial waste as a valuable resource should also enable a higher target for the C&I sector.

Q9: Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan. Do you have any evidence to suggest that different assumptions should be made?
NWT suggest that these targets for recycling should be more ambitious, as this will drive innovation, and should be combined with drivers and incentives from the public sector to force change. The current situation under Covid 19 has shown how dramatically behaviour can be changed in a very short time (under awful circumstances that we hope will never be repeated) given sufficient government will. NWT would suggest that there is an opportunity for the WPAs to use lessons learned from the current crisis, about reductions in food waste, increased re-useable packaging (such as glass milk bottles) etc., to set considerably more ambitious targets, for the LACW stream in particular.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery is important for those last elements of the waste stream that cannot be reused or recycled, but should be considered as a last resort when absolutely all other options have been tried (as represented in the Waste Hierarchy). This needs to be more strongly stated in the Plan than in the current wording. There should be a target to reduce the production of RDF and other waste disposal by incineration. Nottingham and Nottinghamshire, in line with the former’s ambitious Carbon neutrality target and given the innovation and science sectors in the City and County, should be well placed to lead in this area of avoiding the production of materials that have to be converted to RDF.

NWT share the stated concern in the text that large, long term facilities, can have the unfortunate consequence of driving the need for waste to service them. It is also important to recognize, however, that even smaller facilities can cause this effect, as has been clearly seen by the series of unfortunate outcomes of the promotion and subsidy for anaerobic digestion on farms. In Nottinghamshire, this has directly resulted in unsustainable maize production solely for the purposes of feedstock for digesters, which has damaged soils and habitats, and added to pollution of the aquifers, results in substantial increases in NOx, NH4 and CO2 outputs from its production, and has reduced land availability for human food crops and biodiversity.

Therefore, driving the need for reduction in energy use should be the overriding policy, not supporting energy recovery. This should apply across all sectors, particularly municipal and industrial, and notably with regard to housing. So, in summary, NWT do not consider that there should be a plan for higher levels of energy recovery, as this will drive the production of more waste to supply it, rather than finding other ways of reducing that waste stream entirely.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
Availability of disposal sites can prevent or reduce innovation in finding other solutions, although there may be a need for disposal for the small fraction that cannot be used or recycled in any other way. There should be a presumption against developing large new disposal capacity in the context of strong drivers and incentives to find other solutions, so NWT would suggest that any additional capacity should be targeted to be deliberately small, to drive more material into the reduce-reuse-recycle circle.

Q12: Do you agree with the draft vision? Are there other things we should include?
NWT support the vision in general. Our only suggestion is that “ minimise the effects of climate change” is insufficiently specific, as it could refer to climate impact mitigation rather than greenhouse gas production. We suggest that “minimise greenhouse gas emissions that result from waste management in the County” is more accurate as a description of what appears to be intended.
Also the role of the restoration of waste sites to priority habitats should be highlighted by adding the following to the second paragraph:
“All waste sites will contribute towards a greener Nottinghamshire and Nottingham by ensuring that they contribute to biodiversity delivery of priority habitats and the re-
connection of ecological networks, and so ensuring that they also contribute to improving long term access for local people to high quality wildlife-rich greenspaces.”

Q13: Are the above objectives appropriate? Are there others we should consider?
Objective 1 Climate change. NWT consider that this needs to refer specifically to habitats , as there is always habitat damage as a result of new waste development, “ Encourage the efficient use of natural resources by promoting waste as a resource, limit further impacts by avoiding damage to air quality, water, habitats or soil, reduce the need to transport waste and accept that some change is inevitable and manage this by making sure that all new waste facilities are designed and located to withstand the likely impacts of flooding, higher temperatures and more frequent storms and that restoration of waste sites prioritises habitat creation, as that will also help in sequestering Carbon. “
Objective 3. The environment, This needs clarification about what is being protected, and also explicit reference to the need for waste sites to play their part in delivering biodiversity targets. Therefore, NWT suggest the following wording ; “to ensure any new waste facilities protect or enhance the countryside, wildlife and valuable habitats, protect water, soil and air quality across the plan area and thus ensure conservation of the built and natural heritage of the area. After their operational use ceases, all waste sites will be restored to beneficial nature conservation afteruse which optimises their contribution to meeting the County’s biodiversity targets and to delivering Nature Recovery Networks”
Objective 4. Community, Health and Wellbeing. The availability of wildlife-rich greenspace on people’s doorsteps is a significant factor in good physical and mental health and wellbeing , so NWT would suggest the following addition: – “to ensure any new waste facilities do not adversely impact on local amenities and quality of life from impacts such as dust, traffic, noise, odour and visual impact, and any loss of local greenspace upon which people rely for their good health and wellbeing and address local health concerns.”
Objective 5. Meet our future needs. It is essential to emphasise that any sites should be allocated on the basis of both robust SA and EIA, so that proper comparative assessments are made at the plan-making stage. Hence NWT would suggest the following addition to the wording: “Ensuring that there is a mix of site types, sizes and locations to help us manage waste sustainably wherever possible. Meet current and future targets for recycling our waste. Safeguarding existing and/or potential future sites where appropriate and where robust SA and EIA have been undertaken to allocate those sites. Locate new waste facilities to support new residential, commercial and industrial development across the plan area.”

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
NWT broadly agree with these locational priorities, but all decisions on location should always be subject to robust science based decision-making, tested through SA and EIA, so that the full range of impacts, including long distance ones such as NOx, can be properly assessed.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
In NWT’s view, using a criteria-based approach would be insufficiently robust. It is essential that a proper comparative SA of possible sites is undertaken at the same time and in a consistent manner, to ensure that the level of assessment is equal. Otherwise there is a risk of judging sites against variable criteria and contexts in the future. It is also essential to screen out unsustainable sites at an early stage, to prevent uncertainty, local concerns and potentially poor decision-making later.

Q16: What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
Of the scope listed, NWT would highlight the need for the follow changes and additions:
“Highways and transport • Air quality (for both human health and impacts on habitats and species) • Green Belt • Landscape protection • Habitat and species protection and conservation. Archaeology. Greenhouse Gas impacts • Heritage • Pollution • Noise • Flooding and water resources • Health and wellbeing • Public rights of Way. Visual impact. Restoration and aftercare to maximise the contribution to UK and County biodiversity targets.”
It is important to be aware of the issue of NOx and NH3 emissions from certain types of waste facilities potentially impacting habitats. Nitrogen deposition on habitats has been identified as the most serious pollutant of habitats across the UK and Europe and these emissions can be particularly problematic for the heathlands and calcareous grasslands found in Nottinghamshire.
Nottinghamshire has Biodiversity Opportunity Maps, (which will inform the development of a NRN map for the County over the next 12 months), they are held by the County Council through the Biodiversity Action Group, and is it is essential that these documents are taken into account in the development of the Waste Local Plan, both to protect key areas of the network and to ensure that the location of waste sites may also contribute the Network in the long term when they are decommissioned and restored.

NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape-scale conservation in Nottinghamshire, in line with the Lawton Review and the 25 Year Environment Plan, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
It is essential that up to date biodiversity information at the necessary level of detail is used to help the preparation of the Plan, both with regard to data from the NGBRC and the Biodiversity Opportunity Maps.

NWT would expect the WPAs to embed the restoration and re-creation of biodiversity into the WLP, in accordance with the requirements of the 25 Year Environment Plan and the NPPF. It is particularly important, therefore, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a waste scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Nottinghamshire in the past. So these requirements should be secured through robust planning obligations and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

For potential larger footprint waste sites NWT would expect the use of site restoration briefs at an allocation stage, as has been undertaken for the MLP. This is an exemplary and constructive approach and should be replicated in this Waste Local Plan, with the creation of priority biodiversity habitats as the primary restoration aim for all allocations and extensions.

The restoration of waste sites can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable waste sites where the substrate is acidic, and has low nutrient status. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector waste industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.
The site allocation restoration briefs should list the target priority habitats using the existing NE Natural Character Area (NCA) approach and the Biodiversity Opportunity Map, the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which may be achieved through waste site restoration, as described above:
Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows
Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches
Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.

Trent Valley and Rises:rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.
Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.
Please do not hesitate to contact me if you have any queries about the above or if I can provide more information. I look forward to working with the WPA in the development of this important Plan.

Yours sincerely,

Thank you for consulting NWT on the above, I welcome the emphasis on the circular waste economy and hope to see stronger targets for further waste reduction and re-use.

In this response, I have followed the normal convention of showing the existing text from the consultation document in italics and recommended changes in bold italics.

Q1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
NWT consider this is the longest period that could be appropriate, as it is essential that robust targets can be set within a reasonably predictable context. Beyond this period, external factors could change so dramatically that setting targets becomes impossible. Even within this timeframe there are likely to be substantive changes in some areas, particularly regarding packaging and re-use (which has changed considerably in the last decade), so either a review period will need to embedded in the Plan, to re-set targets, or the Plan period shortened.

Q2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
Para 3.6. does not fully encompass the breadth and value of the County’s biodiversity resource, so NWT would suggest the following additions:
“The County’s landscape is characterised by rich rolling farmlands to the south, with a central belt of mixed woodland and farmland, giving way to heathland in the north and open, flat agricultural landscapes dominated by the River Trent to the east. Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, to the north of Mansfield. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status. There is, however, a significant network of SSSIs and LWS across the County, representing the wide range of habitat types found on the diverse geology of the County and hosting diverse, and often scarce, species of flora and fauna. Some of these habitats have been created as a result of the restoration of former waste sites, and this Plan will ensure that the restoration of future waste sites contributes to this network of wildlife-rich habitats, as part of Nottinghamshire’s Nature Recovery Network”.

Plan 1 – The Plan Area does not adequately or accurately represent this biodiversity resource. The green shape that is categorized as “Sherwood Forest including Special Area of Conservation” neither shows the SAC accurately (nor the ppSPA), nor does it encompass the boundaries of “Sherwood Forest” that have been discussed and agreed by multiple parties over many years. NWT would suggest that the SAC is shown accurately as a polygon, the ppSPA is shown as a dotted line boundary, and that ,as a minimum, dots are used to show the SSSIs. We agree that at this scale, it would not be possible to show the LWS.

Q 3-8
I will not respond in detail to the questions about waste calculations and predictions, as this is not a field where NWT has technical expertise, but as a general principle, we would expect more ambitious targets for reduction and re-use for LACW, not least given the admittedly small, changes in the major supermarkets in the last year towards reduced plastic packaging etc., but which is an area that is changing rapidly. In NWT’s view, Option A is lacking in ambition and there should be a higher reduction target per household. Option D should not be countenanced at all. Similarly, rapidly advancing technologies in reuse of industrial and commercial waste as a valuable resource should also enable a higher target for the C&I sector.

Q9: Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan. Do you have any evidence to suggest that different assumptions should be made?
NWT suggest that these targets for recycling should be more ambitious, as this will drive innovation, and should be combined with drivers and incentives from the public sector to force change. The current situation under Covid 19 has shown how dramatically behaviour can be changed in a very short time (under awful circumstances that we hope will never be repeated) given sufficient government will. NWT would suggest that there is an opportunity for the WPAs to use lessons learned from the current crisis, about reductions in food waste, increased re-useable packaging (such as glass milk bottles) etc., to set considerably more ambitious targets, for the LACW stream in particular.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery is important for those last elements of the waste stream that cannot be reused or recycled, but should be considered as a last resort when absolutely all other options have been tried (as represented in the Waste Hierarchy). This needs to be more strongly stated in the Plan than in the current wording. There should be a target to reduce the production of RDF and other waste disposal by incineration. Nottingham and Nottinghamshire, in line with the former’s ambitious Carbon neutrality target and given the innovation and science sectors in the City and County, should be well placed to lead in this area of avoiding the production of materials that have to be converted to RDF.

NWT share the stated concern in the text that large, long term facilities, can have the unfortunate consequence of driving the need for waste to service them. It is also important to recognize, however, that even smaller facilities can cause this effect, as has been clearly seen by the series of unfortunate outcomes of the promotion and subsidy for anaerobic digestion on farms. In Nottinghamshire, this has directly resulted in unsustainable maize production solely for the purposes of feedstock for digesters, which has damaged soils and habitats, and added to pollution of the aquifers, results in substantial increases in NOx, NH4 and CO2 outputs from its production, and has reduced land availability for human food crops and biodiversity.

Therefore, driving the need for reduction in energy use should be the overriding policy, not supporting energy recovery. This should apply across all sectors, particularly municipal and industrial, and notably with regard to housing. So, in summary, NWT do not consider that there should be a plan for higher levels of energy recovery, as this will drive the production of more waste to supply it, rather than finding other ways of reducing that waste stream entirely.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
Availability of disposal sites can prevent or reduce innovation in finding other solutions, although there may be a need for disposal for the small fraction that cannot be used or recycled in any other way. There should be a presumption against developing large new disposal capacity in the context of strong drivers and incentives to find other solutions, so NWT would suggest that any additional capacity should be targeted to be deliberately small, to drive more material into the reduce-reuse-recycle circle.

Q12: Do you agree with the draft vision? Are there other things we should include?
NWT support the vision in general. Our only suggestion is that “ minimise the effects of climate change” is insufficiently specific, as it could refer to climate impact mitigation rather than greenhouse gas production. We suggest that “minimise greenhouse gas emissions that result from waste management in the County” is more accurate as a description of what appears to be intended.
Also the role of the restoration of waste sites to priority habitats should be highlighted by adding the following to the second paragraph:
“All waste sites will contribute towards a greener Nottinghamshire and Nottingham by ensuring that they contribute to biodiversity delivery of priority habitats and the re-
connection of ecological networks, and so ensuring that they also contribute to improving long term access for local people to high quality wildlife-rich greenspaces.”

Q13: Are the above objectives appropriate? Are there others we should consider?
Objective 1 Climate change. NWT consider that this needs to refer specifically to habitats , as there is always habitat damage as a result of new waste development, “ Encourage the efficient use of natural resources by promoting waste as a resource, limit further impacts by avoiding damage to air quality, water, habitats or soil, reduce the need to transport waste and accept that some change is inevitable and manage this by making sure that all new waste facilities are designed and located to withstand the likely impacts of flooding, higher temperatures and more frequent storms and that restoration of waste sites prioritises habitat creation, as that will also help in sequestering Carbon. “
Objective 3. The environment, This needs clarification about what is being protected, and also explicit reference to the need for waste sites to play their part in delivering biodiversity targets. Therefore, NWT suggest the following wording ; “to ensure any new waste facilities protect or enhance the countryside, wildlife and valuable habitats, protect water, soil and air quality across the plan area and thus ensure conservation of the built and natural heritage of the area. After their operational use ceases, all waste sites will be restored to beneficial nature conservation afteruse which optimises their contribution to meeting the County’s biodiversity targets and to delivering Nature Recovery Networks”
Objective 4. Community, Health and Wellbeing. The availability of wildlife-rich greenspace on people’s doorsteps is a significant factor in good physical and mental health and wellbeing , so NWT would suggest the following addition: – “to ensure any new waste facilities do not adversely impact on local amenities and quality of life from impacts such as dust, traffic, noise, odour and visual impact, and any loss of local greenspace upon which people rely for their good health and wellbeing and address local health concerns.”
Objective 5. Meet our future needs. It is essential to emphasise that any sites should be allocated on the basis of both robust SA and EIA, so that proper comparative assessments are made at the plan-making stage. Hence NWT would suggest the following addition to the wording: “Ensuring that there is a mix of site types, sizes and locations to help us manage waste sustainably wherever possible. Meet current and future targets for recycling our waste. Safeguarding existing and/or potential future sites where appropriate and where robust SA and EIA have been undertaken to allocate those sites. Locate new waste facilities to support new residential, commercial and industrial development across the plan area.”

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
NWT broadly agree with these locational priorities, but all decisions on location should always be subject to robust science based decision-making, tested through SA and EIA, so that the full range of impacts, including long distance ones such as NOx, can be properly assessed.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
In NWT’s view, using a criteria-based approach would be insufficiently robust. It is essential that a proper comparative SA of possible sites is undertaken at the same time and in a consistent manner, to ensure that the level of assessment is equal. Otherwise there is a risk of judging sites against variable criteria and contexts in the future. It is also essential to screen out unsustainable sites at an early stage, to prevent uncertainty, local concerns and potentially poor decision-making later.

Q16: What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
Of the scope listed, NWT would highlight the need for the follow changes and additions:
“Highways and transport • Air quality (for both human health and impacts on habitats and species) • Green Belt • Landscape protection • Habitat and species protection and conservation. Archaeology. Greenhouse Gas impacts • Heritage • Pollution • Noise • Flooding and water resources • Health and wellbeing • Public rights of Way. Visual impact. Restoration and aftercare to maximise the contribution to UK and County biodiversity targets.”
It is important to be aware of the issue of NOx and NH3 emissions from certain types of waste facilities potentially impacting habitats. Nitrogen deposition on habitats has been identified as the most serious pollutant of habitats across the UK and Europe and these emissions can be particularly problematic for the heathlands and calcareous grasslands found in Nottinghamshire.
Nottinghamshire has Biodiversity Opportunity Maps, (which will inform the development of a NRN map for the County over the next 12 months), they are held by the County Council through the Biodiversity Action Group, and is it is essential that these documents are taken into account in the development of the Waste Local Plan, both to protect key areas of the network and to ensure that the location of waste sites may also contribute the Network in the long term when they are decommissioned and restored.

NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape-scale conservation in Nottinghamshire, in line with the Lawton Review and the 25 Year Environment Plan, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
It is essential that up to date biodiversity information at the necessary level of detail is used to help the preparation of the Plan, both with regard to data from the NGBRC and the Biodiversity Opportunity Maps.

NWT would expect the WPAs to embed the restoration and re-creation of biodiversity into the WLP, in accordance with the requirements of the 25 Year Environment Plan and the NPPF. It is particularly important, therefore, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a waste scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Nottinghamshire in the past. So these requirements should be secured through robust planning obligations and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

For potential larger footprint waste sites NWT would expect the use of site restoration briefs at an allocation stage, as has been undertaken for the MLP. This is an exemplary and constructive approach and should be replicated in this Waste Local Plan, with the creation of priority biodiversity habitats as the primary restoration aim for all allocations and extensions.

The restoration of waste sites can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable waste sites where the substrate is acidic, and has low nutrient status. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector waste industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.
The site allocation restoration briefs should list the target priority habitats using the existing NE Natural Character Area (NCA) approach and the Biodiversity Opportunity Map, the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which may be achieved through waste site restoration, as described above:
Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows
Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches
Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.

Trent Valley and Rises:rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.
Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.
Please do not hesitate to contact me if you have any queries about the above or if I can provide more information. I look forward to working with the WPA in the development of this important Plan.

Yours sincerely,

Thank you for consulting NWT on the above, I welcome the emphasis on the circular waste economy and hope to see stronger targets for further waste reduction and re-use.

In this response, I have followed the normal convention of showing the existing text from the consultation document in italics and recommended changes in bold italics.

Q1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
NWT consider this is the longest period that could be appropriate, as it is essential that robust targets can be set within a reasonably predictable context. Beyond this period, external factors could change so dramatically that setting targets becomes impossible. Even within this timeframe there are likely to be substantive changes in some areas, particularly regarding packaging and re-use (which has changed considerably in the last decade), so either a review period will need to embedded in the Plan, to re-set targets, or the Plan period shortened.

Q2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
Para 3.6. does not fully encompass the breadth and value of the County’s biodiversity resource, so NWT would suggest the following additions:
“The County’s landscape is characterised by rich rolling farmlands to the south, with a central belt of mixed woodland and farmland, giving way to heathland in the north and open, flat agricultural landscapes dominated by the River Trent to the east. Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, to the north of Mansfield. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status. There is, however, a significant network of SSSIs and LWS across the County, representing the wide range of habitat types found on the diverse geology of the County and hosting diverse, and often scarce, species of flora and fauna. Some of these habitats have been created as a result of the restoration of former waste sites, and this Plan will ensure that the restoration of future waste sites contributes to this network of wildlife-rich habitats, as part of Nottinghamshire’s Nature Recovery Network”.

Plan 1 – The Plan Area does not adequately or accurately represent this biodiversity resource. The green shape that is categorized as “Sherwood Forest including Special Area of Conservation” neither shows the SAC accurately (nor the ppSPA), nor does it encompass the boundaries of “Sherwood Forest” that have been discussed and agreed by multiple parties over many years. NWT would suggest that the SAC is shown accurately as a polygon, the ppSPA is shown as a dotted line boundary, and that ,as a minimum, dots are used to show the SSSIs. We agree that at this scale, it would not be possible to show the LWS.

Q 3-8
I will not respond in detail to the questions about waste calculations and predictions, as this is not a field where NWT has technical expertise, but as a general principle, we would expect more ambitious targets for reduction and re-use for LACW, not least given the admittedly small, changes in the major supermarkets in the last year towards reduced plastic packaging etc., but which is an area that is changing rapidly. In NWT’s view, Option A is lacking in ambition and there should be a higher reduction target per household. Option D should not be countenanced at all. Similarly, rapidly advancing technologies in reuse of industrial and commercial waste as a valuable resource should also enable a higher target for the C&I sector.

Q9: Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan. Do you have any evidence to suggest that different assumptions should be made?
NWT suggest that these targets for recycling should be more ambitious, as this will drive innovation, and should be combined with drivers and incentives from the public sector to force change. The current situation under Covid 19 has shown how dramatically behaviour can be changed in a very short time (under awful circumstances that we hope will never be repeated) given sufficient government will. NWT would suggest that there is an opportunity for the WPAs to use lessons learned from the current crisis, about reductions in food waste, increased re-useable packaging (such as glass milk bottles) etc., to set considerably more ambitious targets, for the LACW stream in particular.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery is important for those last elements of the waste stream that cannot be reused or recycled, but should be considered as a last resort when absolutely all other options have been tried (as represented in the Waste Hierarchy). This needs to be more strongly stated in the Plan than in the current wording. There should be a target to reduce the production of RDF and other waste disposal by incineration. Nottingham and Nottinghamshire, in line with the former’s ambitious Carbon neutrality target and given the innovation and science sectors in the City and County, should be well placed to lead in this area of avoiding the production of materials that have to be converted to RDF.

NWT share the stated concern in the text that large, long term facilities, can have the unfortunate consequence of driving the need for waste to service them. It is also important to recognize, however, that even smaller facilities can cause this effect, as has been clearly seen by the series of unfortunate outcomes of the promotion and subsidy for anaerobic digestion on farms. In Nottinghamshire, this has directly resulted in unsustainable maize production solely for the purposes of feedstock for digesters, which has damaged soils and habitats, and added to pollution of the aquifers, results in substantial increases in NOx, NH4 and CO2 outputs from its production, and has reduced land availability for human food crops and biodiversity.

Therefore, driving the need for reduction in energy use should be the overriding policy, not supporting energy recovery. This should apply across all sectors, particularly municipal and industrial, and notably with regard to housing. So, in summary, NWT do not consider that there should be a plan for higher levels of energy recovery, as this will drive the production of more waste to supply it, rather than finding other ways of reducing that waste stream entirely.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
Availability of disposal sites can prevent or reduce innovation in finding other solutions, although there may be a need for disposal for the small fraction that cannot be used or recycled in any other way. There should be a presumption against developing large new disposal capacity in the context of strong drivers and incentives to find other solutions, so NWT would suggest that any additional capacity should be targeted to be deliberately small, to drive more material into the reduce-reuse-recycle circle.

Q12: Do you agree with the draft vision? Are there other things we should include?
NWT support the vision in general. Our only suggestion is that “ minimise the effects of climate change” is insufficiently specific, as it could refer to climate impact mitigation rather than greenhouse gas production. We suggest that “minimise greenhouse gas emissions that result from waste management in the County” is more accurate as a description of what appears to be intended.
Also the role of the restoration of waste sites to priority habitats should be highlighted by adding the following to the second paragraph:
“All waste sites will contribute towards a greener Nottinghamshire and Nottingham by ensuring that they contribute to biodiversity delivery of priority habitats and the re-
connection of ecological networks, and so ensuring that they also contribute to improving long term access for local people to high quality wildlife-rich greenspaces.”

Q13: Are the above objectives appropriate? Are there others we should consider?
Objective 1 Climate change. NWT consider that this needs to refer specifically to habitats , as there is always habitat damage as a result of new waste development, “ Encourage the efficient use of natural resources by promoting waste as a resource, limit further impacts by avoiding damage to air quality, water, habitats or soil, reduce the need to transport waste and accept that some change is inevitable and manage this by making sure that all new waste facilities are designed and located to withstand the likely impacts of flooding, higher temperatures and more frequent storms and that restoration of waste sites prioritises habitat creation, as that will also help in sequestering Carbon. “
Objective 3. The environment, This needs clarification about what is being protected, and also explicit reference to the need for waste sites to play their part in delivering biodiversity targets. Therefore, NWT suggest the following wording ; “to ensure any new waste facilities protect or enhance the countryside, wildlife and valuable habitats, protect water, soil and air quality across the plan area and thus ensure conservation of the built and natural heritage of the area. After their operational use ceases, all waste sites will be restored to beneficial nature conservation afteruse which optimises their contribution to meeting the County’s biodiversity targets and to delivering Nature Recovery Networks”
Objective 4. Community, Health and Wellbeing. The availability of wildlife-rich greenspace on people’s doorsteps is a significant factor in good physical and mental health and wellbeing , so NWT would suggest the following addition: – “to ensure any new waste facilities do not adversely impact on local amenities and quality of life from impacts such as dust, traffic, noise, odour and visual impact, and any loss of local greenspace upon which people rely for their good health and wellbeing and address local health concerns.”
Objective 5. Meet our future needs. It is essential to emphasise that any sites should be allocated on the basis of both robust SA and EIA, so that proper comparative assessments are made at the plan-making stage. Hence NWT would suggest the following addition to the wording: “Ensuring that there is a mix of site types, sizes and locations to help us manage waste sustainably wherever possible. Meet current and future targets for recycling our waste. Safeguarding existing and/or potential future sites where appropriate and where robust SA and EIA have been undertaken to allocate those sites. Locate new waste facilities to support new residential, commercial and industrial development across the plan area.”

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
NWT broadly agree with these locational priorities, but all decisions on location should always be subject to robust science based decision-making, tested through SA and EIA, so that the full range of impacts, including long distance ones such as NOx, can be properly assessed.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
In NWT’s view, using a criteria-based approach would be insufficiently robust. It is essential that a proper comparative SA of possible sites is undertaken at the same time and in a consistent manner, to ensure that the level of assessment is equal. Otherwise there is a risk of judging sites against variable criteria and contexts in the future. It is also essential to screen out unsustainable sites at an early stage, to prevent uncertainty, local concerns and potentially poor decision-making later.

Q16: What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
Of the scope listed, NWT would highlight the need for the follow changes and additions:
“Highways and transport • Air quality (for both human health and impacts on habitats and species) • Green Belt • Landscape protection • Habitat and species protection and conservation. Archaeology. Greenhouse Gas impacts • Heritage • Pollution • Noise • Flooding and water resources • Health and wellbeing • Public rights of Way. Visual impact. Restoration and aftercare to maximise the contribution to UK and County biodiversity targets.”
It is important to be aware of the issue of NOx and NH3 emissions from certain types of waste facilities potentially impacting habitats. Nitrogen deposition on habitats has been identified as the most serious pollutant of habitats across the UK and Europe and these emissions can be particularly problematic for the heathlands and calcareous grasslands found in Nottinghamshire.
Nottinghamshire has Biodiversity Opportunity Maps, (which will inform the development of a NRN map for the County over the next 12 months), they are held by the County Council through the Biodiversity Action Group, and is it is essential that these documents are taken into account in the development of the Waste Local Plan, both to protect key areas of the network and to ensure that the location of waste sites may also contribute the Network in the long term when they are decommissioned and restored.

NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape-scale conservation in Nottinghamshire, in line with the Lawton Review and the 25 Year Environment Plan, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
It is essential that up to date biodiversity information at the necessary level of detail is used to help the preparation of the Plan, both with regard to data from the NGBRC and the Biodiversity Opportunity Maps.

NWT would expect the WPAs to embed the restoration and re-creation of biodiversity into the WLP, in accordance with the requirements of the 25 Year Environment Plan and the NPPF. It is particularly important, therefore, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a waste scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Nottinghamshire in the past. So these requirements should be secured through robust planning obligations and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

For potential larger footprint waste sites NWT would expect the use of site restoration briefs at an allocation stage, as has been undertaken for the MLP. This is an exemplary and constructive approach and should be replicated in this Waste Local Plan, with the creation of priority biodiversity habitats as the primary restoration aim for all allocations and extensions.

The restoration of waste sites can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable waste sites where the substrate is acidic, and has low nutrient status. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector waste industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.
The site allocation restoration briefs should list the target priority habitats using the existing NE Natural Character Area (NCA) approach and the Biodiversity Opportunity Map, the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which may be achieved through waste site restoration, as described above:
Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows
Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches
Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.

Trent Valley and Rises:rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.
Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.
Please do not hesitate to contact me if you have any queries about the above or if I can provide more information. I look forward to working with the WPA in the development of this important Plan.

Yours sincerely,

Thank you for consulting NWT on the above, I welcome the emphasis on the circular waste economy and hope to see stronger targets for further waste reduction and re-use.

In this response, I have followed the normal convention of showing the existing text from the consultation document in italics and recommended changes in bold italics.

Q1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
NWT consider this is the longest period that could be appropriate, as it is essential that robust targets can be set within a reasonably predictable context. Beyond this period, external factors could change so dramatically that setting targets becomes impossible. Even within this timeframe there are likely to be substantive changes in some areas, particularly regarding packaging and re-use (which has changed considerably in the last decade), so either a review period will need to embedded in the Plan, to re-set targets, or the Plan period shortened.

Q2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
Para 3.6. does not fully encompass the breadth and value of the County’s biodiversity resource, so NWT would suggest the following additions:
“The County’s landscape is characterised by rich rolling farmlands to the south, with a central belt of mixed woodland and farmland, giving way to heathland in the north and open, flat agricultural landscapes dominated by the River Trent to the east. Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, to the north of Mansfield. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status. There is, however, a significant network of SSSIs and LWS across the County, representing the wide range of habitat types found on the diverse geology of the County and hosting diverse, and often scarce, species of flora and fauna. Some of these habitats have been created as a result of the restoration of former waste sites, and this Plan will ensure that the restoration of future waste sites contributes to this network of wildlife-rich habitats, as part of Nottinghamshire’s Nature Recovery Network”.

Plan 1 – The Plan Area does not adequately or accurately represent this biodiversity resource. The green shape that is categorized as “Sherwood Forest including Special Area of Conservation” neither shows the SAC accurately (nor the ppSPA), nor does it encompass the boundaries of “Sherwood Forest” that have been discussed and agreed by multiple parties over many years. NWT would suggest that the SAC is shown accurately as a polygon, the ppSPA is shown as a dotted line boundary, and that ,as a minimum, dots are used to show the SSSIs. We agree that at this scale, it would not be possible to show the LWS.

Q 3-8
I will not respond in detail to the questions about waste calculations and predictions, as this is not a field where NWT has technical expertise, but as a general principle, we would expect more ambitious targets for reduction and re-use for LACW, not least given the admittedly small, changes in the major supermarkets in the last year towards reduced plastic packaging etc., but which is an area that is changing rapidly. In NWT’s view, Option A is lacking in ambition and there should be a higher reduction target per household. Option D should not be countenanced at all. Similarly, rapidly advancing technologies in reuse of industrial and commercial waste as a valuable resource should also enable a higher target for the C&I sector.

Q9: Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan. Do you have any evidence to suggest that different assumptions should be made?
NWT suggest that these targets for recycling should be more ambitious, as this will drive innovation, and should be combined with drivers and incentives from the public sector to force change. The current situation under Covid 19 has shown how dramatically behaviour can be changed in a very short time (under awful circumstances that we hope will never be repeated) given sufficient government will. NWT would suggest that there is an opportunity for the WPAs to use lessons learned from the current crisis, about reductions in food waste, increased re-useable packaging (such as glass milk bottles) etc., to set considerably more ambitious targets, for the LACW stream in particular.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery is important for those last elements of the waste stream that cannot be reused or recycled, but should be considered as a last resort when absolutely all other options have been tried (as represented in the Waste Hierarchy). This needs to be more strongly stated in the Plan than in the current wording. There should be a target to reduce the production of RDF and other waste disposal by incineration. Nottingham and Nottinghamshire, in line with the former’s ambitious Carbon neutrality target and given the innovation and science sectors in the City and County, should be well placed to lead in this area of avoiding the production of materials that have to be converted to RDF.

NWT share the stated concern in the text that large, long term facilities, can have the unfortunate consequence of driving the need for waste to service them. It is also important to recognize, however, that even smaller facilities can cause this effect, as has been clearly seen by the series of unfortunate outcomes of the promotion and subsidy for anaerobic digestion on farms. In Nottinghamshire, this has directly resulted in unsustainable maize production solely for the purposes of feedstock for digesters, which has damaged soils and habitats, and added to pollution of the aquifers, results in substantial increases in NOx, NH4 and CO2 outputs from its production, and has reduced land availability for human food crops and biodiversity.

Therefore, driving the need for reduction in energy use should be the overriding policy, not supporting energy recovery. This should apply across all sectors, particularly municipal and industrial, and notably with regard to housing. So, in summary, NWT do not consider that there should be a plan for higher levels of energy recovery, as this will drive the production of more waste to supply it, rather than finding other ways of reducing that waste stream entirely.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
Availability of disposal sites can prevent or reduce innovation in finding other solutions, although there may be a need for disposal for the small fraction that cannot be used or recycled in any other way. There should be a presumption against developing large new disposal capacity in the context of strong drivers and incentives to find other solutions, so NWT would suggest that any additional capacity should be targeted to be deliberately small, to drive more material into the reduce-reuse-recycle circle.

Q12: Do you agree with the draft vision? Are there other things we should include?
NWT support the vision in general. Our only suggestion is that “ minimise the effects of climate change” is insufficiently specific, as it could refer to climate impact mitigation rather than greenhouse gas production. We suggest that “minimise greenhouse gas emissions that result from waste management in the County” is more accurate as a description of what appears to be intended.
Also the role of the restoration of waste sites to priority habitats should be highlighted by adding the following to the second paragraph:
“All waste sites will contribute towards a greener Nottinghamshire and Nottingham by ensuring that they contribute to biodiversity delivery of priority habitats and the re-
connection of ecological networks, and so ensuring that they also contribute to improving long term access for local people to high quality wildlife-rich greenspaces.”

Q13: Are the above objectives appropriate? Are there others we should consider?
Objective 1 Climate change. NWT consider that this needs to refer specifically to habitats , as there is always habitat damage as a result of new waste development, “ Encourage the efficient use of natural resources by promoting waste as a resource, limit further impacts by avoiding damage to air quality, water, habitats or soil, reduce the need to transport waste and accept that some change is inevitable and manage this by making sure that all new waste facilities are designed and located to withstand the likely impacts of flooding, higher temperatures and more frequent storms and that restoration of waste sites prioritises habitat creation, as that will also help in sequestering Carbon. “
Objective 3. The environment, This needs clarification about what is being protected, and also explicit reference to the need for waste sites to play their part in delivering biodiversity targets. Therefore, NWT suggest the following wording ; “to ensure any new waste facilities protect or enhance the countryside, wildlife and valuable habitats, protect water, soil and air quality across the plan area and thus ensure conservation of the built and natural heritage of the area. After their operational use ceases, all waste sites will be restored to beneficial nature conservation afteruse which optimises their contribution to meeting the County’s biodiversity targets and to delivering Nature Recovery Networks”
Objective 4. Community, Health and Wellbeing. The availability of wildlife-rich greenspace on people’s doorsteps is a significant factor in good physical and mental health and wellbeing , so NWT would suggest the following addition: – “to ensure any new waste facilities do not adversely impact on local amenities and quality of life from impacts such as dust, traffic, noise, odour and visual impact, and any loss of local greenspace upon which people rely for their good health and wellbeing and address local health concerns.”
Objective 5. Meet our future needs. It is essential to emphasise that any sites should be allocated on the basis of both robust SA and EIA, so that proper comparative assessments are made at the plan-making stage. Hence NWT would suggest the following addition to the wording: “Ensuring that there is a mix of site types, sizes and locations to help us manage waste sustainably wherever possible. Meet current and future targets for recycling our waste. Safeguarding existing and/or potential future sites where appropriate and where robust SA and EIA have been undertaken to allocate those sites. Locate new waste facilities to support new residential, commercial and industrial development across the plan area.”

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
NWT broadly agree with these locational priorities, but all decisions on location should always be subject to robust science based decision-making, tested through SA and EIA, so that the full range of impacts, including long distance ones such as NOx, can be properly assessed.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
In NWT’s view, using a criteria-based approach would be insufficiently robust. It is essential that a proper comparative SA of possible sites is undertaken at the same time and in a consistent manner, to ensure that the level of assessment is equal. Otherwise there is a risk of judging sites against variable criteria and contexts in the future. It is also essential to screen out unsustainable sites at an early stage, to prevent uncertainty, local concerns and potentially poor decision-making later.

Q16: What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
Of the scope listed, NWT would highlight the need for the follow changes and additions:
“Highways and transport • Air quality (for both human health and impacts on habitats and species) • Green Belt • Landscape protection • Habitat and species protection and conservation. Archaeology. Greenhouse Gas impacts • Heritage • Pollution • Noise • Flooding and water resources • Health and wellbeing • Public rights of Way. Visual impact. Restoration and aftercare to maximise the contribution to UK and County biodiversity targets.”
It is important to be aware of the issue of NOx and NH3 emissions from certain types of waste facilities potentially impacting habitats. Nitrogen deposition on habitats has been identified as the most serious pollutant of habitats across the UK and Europe and these emissions can be particularly problematic for the heathlands and calcareous grasslands found in Nottinghamshire.
Nottinghamshire has Biodiversity Opportunity Maps, (which will inform the development of a NRN map for the County over the next 12 months), they are held by the County Council through the Biodiversity Action Group, and is it is essential that these documents are taken into account in the development of the Waste Local Plan, both to protect key areas of the network and to ensure that the location of waste sites may also contribute the Network in the long term when they are decommissioned and restored.

NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape-scale conservation in Nottinghamshire, in line with the Lawton Review and the 25 Year Environment Plan, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
It is essential that up to date biodiversity information at the necessary level of detail is used to help the preparation of the Plan, both with regard to data from the NGBRC and the Biodiversity Opportunity Maps.

NWT would expect the WPAs to embed the restoration and re-creation of biodiversity into the WLP, in accordance with the requirements of the 25 Year Environment Plan and the NPPF. It is particularly important, therefore, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a waste scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Nottinghamshire in the past. So these requirements should be secured through robust planning obligations and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

For potential larger footprint waste sites NWT would expect the use of site restoration briefs at an allocation stage, as has been undertaken for the MLP. This is an exemplary and constructive approach and should be replicated in this Waste Local Plan, with the creation of priority biodiversity habitats as the primary restoration aim for all allocations and extensions.

The restoration of waste sites can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable waste sites where the substrate is acidic, and has low nutrient status. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector waste industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.
The site allocation restoration briefs should list the target priority habitats using the existing NE Natural Character Area (NCA) approach and the Biodiversity Opportunity Map, the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which may be achieved through waste site restoration, as described above:
Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows
Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches
Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.

Trent Valley and Rises:rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.
Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.
Please do not hesitate to contact me if you have any queries about the above or if I can provide more information. I look forward to working with the WPA in the development of this important Plan.

Yours sincerely,

Thank you for consulting NWT on the above, I welcome the emphasis on the circular waste economy and hope to see stronger targets for further waste reduction and re-use.

In this response, I have followed the normal convention of showing the existing text from the consultation document in italics and recommended changes in bold italics.

Q1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
NWT consider this is the longest period that could be appropriate, as it is essential that robust targets can be set within a reasonably predictable context. Beyond this period, external factors could change so dramatically that setting targets becomes impossible. Even within this timeframe there are likely to be substantive changes in some areas, particularly regarding packaging and re-use (which has changed considerably in the last decade), so either a review period will need to embedded in the Plan, to re-set targets, or the Plan period shortened.

Q2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
Para 3.6. does not fully encompass the breadth and value of the County’s biodiversity resource, so NWT would suggest the following additions:
“The County’s landscape is characterised by rich rolling farmlands to the south, with a central belt of mixed woodland and farmland, giving way to heathland in the north and open, flat agricultural landscapes dominated by the River Trent to the east. Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, to the north of Mansfield. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status. There is, however, a significant network of SSSIs and LWS across the County, representing the wide range of habitat types found on the diverse geology of the County and hosting diverse, and often scarce, species of flora and fauna. Some of these habitats have been created as a result of the restoration of former waste sites, and this Plan will ensure that the restoration of future waste sites contributes to this network of wildlife-rich habitats, as part of Nottinghamshire’s Nature Recovery Network”.

Plan 1 – The Plan Area does not adequately or accurately represent this biodiversity resource. The green shape that is categorized as “Sherwood Forest including Special Area of Conservation” neither shows the SAC accurately (nor the ppSPA), nor does it encompass the boundaries of “Sherwood Forest” that have been discussed and agreed by multiple parties over many years. NWT would suggest that the SAC is shown accurately as a polygon, the ppSPA is shown as a dotted line boundary, and that ,as a minimum, dots are used to show the SSSIs. We agree that at this scale, it would not be possible to show the LWS.

Q 3-8
I will not respond in detail to the questions about waste calculations and predictions, as this is not a field where NWT has technical expertise, but as a general principle, we would expect more ambitious targets for reduction and re-use for LACW, not least given the admittedly small, changes in the major supermarkets in the last year towards reduced plastic packaging etc., but which is an area that is changing rapidly. In NWT’s view, Option A is lacking in ambition and there should be a higher reduction target per household. Option D should not be countenanced at all. Similarly, rapidly advancing technologies in reuse of industrial and commercial waste as a valuable resource should also enable a higher target for the C&I sector.

Q9: Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan. Do you have any evidence to suggest that different assumptions should be made?
NWT suggest that these targets for recycling should be more ambitious, as this will drive innovation, and should be combined with drivers and incentives from the public sector to force change. The current situation under Covid 19 has shown how dramatically behaviour can be changed in a very short time (under awful circumstances that we hope will never be repeated) given sufficient government will. NWT would suggest that there is an opportunity for the WPAs to use lessons learned from the current crisis, about reductions in food waste, increased re-useable packaging (such as glass milk bottles) etc., to set considerably more ambitious targets, for the LACW stream in particular.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery is important for those last elements of the waste stream that cannot be reused or recycled, but should be considered as a last resort when absolutely all other options have been tried (as represented in the Waste Hierarchy). This needs to be more strongly stated in the Plan than in the current wording. There should be a target to reduce the production of RDF and other waste disposal by incineration. Nottingham and Nottinghamshire, in line with the former’s ambitious Carbon neutrality target and given the innovation and science sectors in the City and County, should be well placed to lead in this area of avoiding the production of materials that have to be converted to RDF.

NWT share the stated concern in the text that large, long term facilities, can have the unfortunate consequence of driving the need for waste to service them. It is also important to recognize, however, that even smaller facilities can cause this effect, as has been clearly seen by the series of unfortunate outcomes of the promotion and subsidy for anaerobic digestion on farms. In Nottinghamshire, this has directly resulted in unsustainable maize production solely for the purposes of feedstock for digesters, which has damaged soils and habitats, and added to pollution of the aquifers, results in substantial increases in NOx, NH4 and CO2 outputs from its production, and has reduced land availability for human food crops and biodiversity.

Therefore, driving the need for reduction in energy use should be the overriding policy, not supporting energy recovery. This should apply across all sectors, particularly municipal and industrial, and notably with regard to housing. So, in summary, NWT do not consider that there should be a plan for higher levels of energy recovery, as this will drive the production of more waste to supply it, rather than finding other ways of reducing that waste stream entirely.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
Availability of disposal sites can prevent or reduce innovation in finding other solutions, although there may be a need for disposal for the small fraction that cannot be used or recycled in any other way. There should be a presumption against developing large new disposal capacity in the context of strong drivers and incentives to find other solutions, so NWT would suggest that any additional capacity should be targeted to be deliberately small, to drive more material into the reduce-reuse-recycle circle.

Q12: Do you agree with the draft vision? Are there other things we should include?
NWT support the vision in general. Our only suggestion is that “ minimise the effects of climate change” is insufficiently specific, as it could refer to climate impact mitigation rather than greenhouse gas production. We suggest that “minimise greenhouse gas emissions that result from waste management in the County” is more accurate as a description of what appears to be intended.
Also the role of the restoration of waste sites to priority habitats should be highlighted by adding the following to the second paragraph:
“All waste sites will contribute towards a greener Nottinghamshire and Nottingham by ensuring that they contribute to biodiversity delivery of priority habitats and the re-
connection of ecological networks, and so ensuring that they also contribute to improving long term access for local people to high quality wildlife-rich greenspaces.”

Q13: Are the above objectives appropriate? Are there others we should consider?
Objective 1 Climate change. NWT consider that this needs to refer specifically to habitats , as there is always habitat damage as a result of new waste development, “ Encourage the efficient use of natural resources by promoting waste as a resource, limit further impacts by avoiding damage to air quality, water, habitats or soil, reduce the need to transport waste and accept that some change is inevitable and manage this by making sure that all new waste facilities are designed and located to withstand the likely impacts of flooding, higher temperatures and more frequent storms and that restoration of waste sites prioritises habitat creation, as that will also help in sequestering Carbon. “
Objective 3. The environment, This needs clarification about what is being protected, and also explicit reference to the need for waste sites to play their part in delivering biodiversity targets. Therefore, NWT suggest the following wording ; “to ensure any new waste facilities protect or enhance the countryside, wildlife and valuable habitats, protect water, soil and air quality across the plan area and thus ensure conservation of the built and natural heritage of the area. After their operational use ceases, all waste sites will be restored to beneficial nature conservation afteruse which optimises their contribution to meeting the County’s biodiversity targets and to delivering Nature Recovery Networks”
Objective 4. Community, Health and Wellbeing. The availability of wildlife-rich greenspace on people’s doorsteps is a significant factor in good physical and mental health and wellbeing , so NWT would suggest the following addition: – “to ensure any new waste facilities do not adversely impact on local amenities and quality of life from impacts such as dust, traffic, noise, odour and visual impact, and any loss of local greenspace upon which people rely for their good health and wellbeing and address local health concerns.”
Objective 5. Meet our future needs. It is essential to emphasise that any sites should be allocated on the basis of both robust SA and EIA, so that proper comparative assessments are made at the plan-making stage. Hence NWT would suggest the following addition to the wording: “Ensuring that there is a mix of site types, sizes and locations to help us manage waste sustainably wherever possible. Meet current and future targets for recycling our waste. Safeguarding existing and/or potential future sites where appropriate and where robust SA and EIA have been undertaken to allocate those sites. Locate new waste facilities to support new residential, commercial and industrial development across the plan area.”

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
NWT broadly agree with these locational priorities, but all decisions on location should always be subject to robust science based decision-making, tested through SA and EIA, so that the full range of impacts, including long distance ones such as NOx, can be properly assessed.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
In NWT’s view, using a criteria-based approach would be insufficiently robust. It is essential that a proper comparative SA of possible sites is undertaken at the same time and in a consistent manner, to ensure that the level of assessment is equal. Otherwise there is a risk of judging sites against variable criteria and contexts in the future. It is also essential to screen out unsustainable sites at an early stage, to prevent uncertainty, local concerns and potentially poor decision-making later.

Q16: What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
Of the scope listed, NWT would highlight the need for the follow changes and additions:
“Highways and transport • Air quality (for both human health and impacts on habitats and species) • Green Belt • Landscape protection • Habitat and species protection and conservation. Archaeology. Greenhouse Gas impacts • Heritage • Pollution • Noise • Flooding and water resources • Health and wellbeing • Public rights of Way. Visual impact. Restoration and aftercare to maximise the contribution to UK and County biodiversity targets.”
It is important to be aware of the issue of NOx and NH3 emissions from certain types of waste facilities potentially impacting habitats. Nitrogen deposition on habitats has been identified as the most serious pollutant of habitats across the UK and Europe and these emissions can be particularly problematic for the heathlands and calcareous grasslands found in Nottinghamshire.
Nottinghamshire has Biodiversity Opportunity Maps, (which will inform the development of a NRN map for the County over the next 12 months), they are held by the County Council through the Biodiversity Action Group, and is it is essential that these documents are taken into account in the development of the Waste Local Plan, both to protect key areas of the network and to ensure that the location of waste sites may also contribute the Network in the long term when they are decommissioned and restored.

NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape-scale conservation in Nottinghamshire, in line with the Lawton Review and the 25 Year Environment Plan, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
It is essential that up to date biodiversity information at the necessary level of detail is used to help the preparation of the Plan, both with regard to data from the NGBRC and the Biodiversity Opportunity Maps.

NWT would expect the WPAs to embed the restoration and re-creation of biodiversity into the WLP, in accordance with the requirements of the 25 Year Environment Plan and the NPPF. It is particularly important, therefore, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a waste scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Nottinghamshire in the past. So these requirements should be secured through robust planning obligations and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

For potential larger footprint waste sites NWT would expect the use of site restoration briefs at an allocation stage, as has been undertaken for the MLP. This is an exemplary and constructive approach and should be replicated in this Waste Local Plan, with the creation of priority biodiversity habitats as the primary restoration aim for all allocations and extensions.

The restoration of waste sites can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable waste sites where the substrate is acidic, and has low nutrient status. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector waste industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.
The site allocation restoration briefs should list the target priority habitats using the existing NE Natural Character Area (NCA) approach and the Biodiversity Opportunity Map, the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which may be achieved through waste site restoration, as described above:
Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows
Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches
Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.

Trent Valley and Rises:rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.
Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.
Please do not hesitate to contact me if you have any queries about the above or if I can provide more information. I look forward to working with the WPA in the development of this important Plan.

Yours sincerely,

Thank you for consulting NWT on the above, I welcome the emphasis on the circular waste economy and hope to see stronger targets for further waste reduction and re-use.

In this response, I have followed the normal convention of showing the existing text from the consultation document in italics and recommended changes in bold italics.

Q1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
NWT consider this is the longest period that could be appropriate, as it is essential that robust targets can be set within a reasonably predictable context. Beyond this period, external factors could change so dramatically that setting targets becomes impossible. Even within this timeframe there are likely to be substantive changes in some areas, particularly regarding packaging and re-use (which has changed considerably in the last decade), so either a review period will need to embedded in the Plan, to re-set targets, or the Plan period shortened.

Q2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
Para 3.6. does not fully encompass the breadth and value of the County’s biodiversity resource, so NWT would suggest the following additions:
“The County’s landscape is characterised by rich rolling farmlands to the south, with a central belt of mixed woodland and farmland, giving way to heathland in the north and open, flat agricultural landscapes dominated by the River Trent to the east. Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, to the north of Mansfield. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status. There is, however, a significant network of SSSIs and LWS across the County, representing the wide range of habitat types found on the diverse geology of the County and hosting diverse, and often scarce, species of flora and fauna. Some of these habitats have been created as a result of the restoration of former waste sites, and this Plan will ensure that the restoration of future waste sites contributes to this network of wildlife-rich habitats, as part of Nottinghamshire’s Nature Recovery Network”.

Plan 1 – The Plan Area does not adequately or accurately represent this biodiversity resource. The green shape that is categorized as “Sherwood Forest including Special Area of Conservation” neither shows the SAC accurately (nor the ppSPA), nor does it encompass the boundaries of “Sherwood Forest” that have been discussed and agreed by multiple parties over many years. NWT would suggest that the SAC is shown accurately as a polygon, the ppSPA is shown as a dotted line boundary, and that ,as a minimum, dots are used to show the SSSIs. We agree that at this scale, it would not be possible to show the LWS.

Q 3-8
I will not respond in detail to the questions about waste calculations and predictions, as this is not a field where NWT has technical expertise, but as a general principle, we would expect more ambitious targets for reduction and re-use for LACW, not least given the admittedly small, changes in the major supermarkets in the last year towards reduced plastic packaging etc., but which is an area that is changing rapidly. In NWT’s view, Option A is lacking in ambition and there should be a higher reduction target per household. Option D should not be countenanced at all. Similarly, rapidly advancing technologies in reuse of industrial and commercial waste as a valuable resource should also enable a higher target for the C&I sector.

Q9: Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan. Do you have any evidence to suggest that different assumptions should be made?
NWT suggest that these targets for recycling should be more ambitious, as this will drive innovation, and should be combined with drivers and incentives from the public sector to force change. The current situation under Covid 19 has shown how dramatically behaviour can be changed in a very short time (under awful circumstances that we hope will never be repeated) given sufficient government will. NWT would suggest that there is an opportunity for the WPAs to use lessons learned from the current crisis, about reductions in food waste, increased re-useable packaging (such as glass milk bottles) etc., to set considerably more ambitious targets, for the LACW stream in particular.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery is important for those last elements of the waste stream that cannot be reused or recycled, but should be considered as a last resort when absolutely all other options have been tried (as represented in the Waste Hierarchy). This needs to be more strongly stated in the Plan than in the current wording. There should be a target to reduce the production of RDF and other waste disposal by incineration. Nottingham and Nottinghamshire, in line with the former’s ambitious Carbon neutrality target and given the innovation and science sectors in the City and County, should be well placed to lead in this area of avoiding the production of materials that have to be converted to RDF.

NWT share the stated concern in the text that large, long term facilities, can have the unfortunate consequence of driving the need for waste to service them. It is also important to recognize, however, that even smaller facilities can cause this effect, as has been clearly seen by the series of unfortunate outcomes of the promotion and subsidy for anaerobic digestion on farms. In Nottinghamshire, this has directly resulted in unsustainable maize production solely for the purposes of feedstock for digesters, which has damaged soils and habitats, and added to pollution of the aquifers, results in substantial increases in NOx, NH4 and CO2 outputs from its production, and has reduced land availability for human food crops and biodiversity.

Therefore, driving the need for reduction in energy use should be the overriding policy, not supporting energy recovery. This should apply across all sectors, particularly municipal and industrial, and notably with regard to housing. So, in summary, NWT do not consider that there should be a plan for higher levels of energy recovery, as this will drive the production of more waste to supply it, rather than finding other ways of reducing that waste stream entirely.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
Availability of disposal sites can prevent or reduce innovation in finding other solutions, although there may be a need for disposal for the small fraction that cannot be used or recycled in any other way. There should be a presumption against developing large new disposal capacity in the context of strong drivers and incentives to find other solutions, so NWT would suggest that any additional capacity should be targeted to be deliberately small, to drive more material into the reduce-reuse-recycle circle.

Q12: Do you agree with the draft vision? Are there other things we should include?
NWT support the vision in general. Our only suggestion is that “ minimise the effects of climate change” is insufficiently specific, as it could refer to climate impact mitigation rather than greenhouse gas production. We suggest that “minimise greenhouse gas emissions that result from waste management in the County” is more accurate as a description of what appears to be intended.
Also the role of the restoration of waste sites to priority habitats should be highlighted by adding the following to the second paragraph:
“All waste sites will contribute towards a greener Nottinghamshire and Nottingham by ensuring that they contribute to biodiversity delivery of priority habitats and the re-
connection of ecological networks, and so ensuring that they also contribute to improving long term access for local people to high quality wildlife-rich greenspaces.”

Q13: Are the above objectives appropriate? Are there others we should consider?
Objective 1 Climate change. NWT consider that this needs to refer specifically to habitats , as there is always habitat damage as a result of new waste development, “ Encourage the efficient use of natural resources by promoting waste as a resource, limit further impacts by avoiding damage to air quality, water, habitats or soil, reduce the need to transport waste and accept that some change is inevitable and manage this by making sure that all new waste facilities are designed and located to withstand the likely impacts of flooding, higher temperatures and more frequent storms and that restoration of waste sites prioritises habitat creation, as that will also help in sequestering Carbon. “
Objective 3. The environment, This needs clarification about what is being protected, and also explicit reference to the need for waste sites to play their part in delivering biodiversity targets. Therefore, NWT suggest the following wording ; “to ensure any new waste facilities protect or enhance the countryside, wildlife and valuable habitats, protect water, soil and air quality across the plan area and thus ensure conservation of the built and natural heritage of the area. After their operational use ceases, all waste sites will be restored to beneficial nature conservation afteruse which optimises their contribution to meeting the County’s biodiversity targets and to delivering Nature Recovery Networks”
Objective 4. Community, Health and Wellbeing. The availability of wildlife-rich greenspace on people’s doorsteps is a significant factor in good physical and mental health and wellbeing , so NWT would suggest the following addition: – “to ensure any new waste facilities do not adversely impact on local amenities and quality of life from impacts such as dust, traffic, noise, odour and visual impact, and any loss of local greenspace upon which people rely for their good health and wellbeing and address local health concerns.”
Objective 5. Meet our future needs. It is essential to emphasise that any sites should be allocated on the basis of both robust SA and EIA, so that proper comparative assessments are made at the plan-making stage. Hence NWT would suggest the following addition to the wording: “Ensuring that there is a mix of site types, sizes and locations to help us manage waste sustainably wherever possible. Meet current and future targets for recycling our waste. Safeguarding existing and/or potential future sites where appropriate and where robust SA and EIA have been undertaken to allocate those sites. Locate new waste facilities to support new residential, commercial and industrial development across the plan area.”

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
NWT broadly agree with these locational priorities, but all decisions on location should always be subject to robust science based decision-making, tested through SA and EIA, so that the full range of impacts, including long distance ones such as NOx, can be properly assessed.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
In NWT’s view, using a criteria-based approach would be insufficiently robust. It is essential that a proper comparative SA of possible sites is undertaken at the same time and in a consistent manner, to ensure that the level of assessment is equal. Otherwise there is a risk of judging sites against variable criteria and contexts in the future. It is also essential to screen out unsustainable sites at an early stage, to prevent uncertainty, local concerns and potentially poor decision-making later.

Q16: What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
Of the scope listed, NWT would highlight the need for the follow changes and additions:
“Highways and transport • Air quality (for both human health and impacts on habitats and species) • Green Belt • Landscape protection • Habitat and species protection and conservation. Archaeology. Greenhouse Gas impacts • Heritage • Pollution • Noise • Flooding and water resources • Health and wellbeing • Public rights of Way. Visual impact. Restoration and aftercare to maximise the contribution to UK and County biodiversity targets.”
It is important to be aware of the issue of NOx and NH3 emissions from certain types of waste facilities potentially impacting habitats. Nitrogen deposition on habitats has been identified as the most serious pollutant of habitats across the UK and Europe and these emissions can be particularly problematic for the heathlands and calcareous grasslands found in Nottinghamshire.
Nottinghamshire has Biodiversity Opportunity Maps, (which will inform the development of a NRN map for the County over the next 12 months), they are held by the County Council through the Biodiversity Action Group, and is it is essential that these documents are taken into account in the development of the Waste Local Plan, both to protect key areas of the network and to ensure that the location of waste sites may also contribute the Network in the long term when they are decommissioned and restored.

NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape-scale conservation in Nottinghamshire, in line with the Lawton Review and the 25 Year Environment Plan, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
It is essential that up to date biodiversity information at the necessary level of detail is used to help the preparation of the Plan, both with regard to data from the NGBRC and the Biodiversity Opportunity Maps.

NWT would expect the WPAs to embed the restoration and re-creation of biodiversity into the WLP, in accordance with the requirements of the 25 Year Environment Plan and the NPPF. It is particularly important, therefore, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a waste scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Nottinghamshire in the past. So these requirements should be secured through robust planning obligations and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

For potential larger footprint waste sites NWT would expect the use of site restoration briefs at an allocation stage, as has been undertaken for the MLP. This is an exemplary and constructive approach and should be replicated in this Waste Local Plan, with the creation of priority biodiversity habitats as the primary restoration aim for all allocations and extensions.

The restoration of waste sites can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable waste sites where the substrate is acidic, and has low nutrient status. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector waste industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.
The site allocation restoration briefs should list the target priority habitats using the existing NE Natural Character Area (NCA) approach and the Biodiversity Opportunity Map, the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which may be achieved through waste site restoration, as described above:
Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows
Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches
Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.

Trent Valley and Rises:rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.
Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.
Please do not hesitate to contact me if you have any queries about the above or if I can provide more information. I look forward to working with the WPA in the development of this important Plan.

Yours sincerely,

Thank you for consulting NWT on the above, I welcome the emphasis on the circular waste economy and hope to see stronger targets for further waste reduction and re-use.

In this response, I have followed the normal convention of showing the existing text from the consultation document in italics and recommended changes in bold italics.

Q1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
NWT consider this is the longest period that could be appropriate, as it is essential that robust targets can be set within a reasonably predictable context. Beyond this period, external factors could change so dramatically that setting targets becomes impossible. Even within this timeframe there are likely to be substantive changes in some areas, particularly regarding packaging and re-use (which has changed considerably in the last decade), so either a review period will need to embedded in the Plan, to re-set targets, or the Plan period shortened.

Q2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
Para 3.6. does not fully encompass the breadth and value of the County’s biodiversity resource, so NWT would suggest the following additions:
“The County’s landscape is characterised by rich rolling farmlands to the south, with a central belt of mixed woodland and farmland, giving way to heathland in the north and open, flat agricultural landscapes dominated by the River Trent to the east. Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, to the north of Mansfield. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status. There is, however, a significant network of SSSIs and LWS across the County, representing the wide range of habitat types found on the diverse geology of the County and hosting diverse, and often scarce, species of flora and fauna. Some of these habitats have been created as a result of the restoration of former waste sites, and this Plan will ensure that the restoration of future waste sites contributes to this network of wildlife-rich habitats, as part of Nottinghamshire’s Nature Recovery Network”.

Plan 1 – The Plan Area does not adequately or accurately represent this biodiversity resource. The green shape that is categorized as “Sherwood Forest including Special Area of Conservation” neither shows the SAC accurately (nor the ppSPA), nor does it encompass the boundaries of “Sherwood Forest” that have been discussed and agreed by multiple parties over many years. NWT would suggest that the SAC is shown accurately as a polygon, the ppSPA is shown as a dotted line boundary, and that ,as a minimum, dots are used to show the SSSIs. We agree that at this scale, it would not be possible to show the LWS.

Q 3-8
I will not respond in detail to the questions about waste calculations and predictions, as this is not a field where NWT has technical expertise, but as a general principle, we would expect more ambitious targets for reduction and re-use for LACW, not least given the admittedly small, changes in the major supermarkets in the last year towards reduced plastic packaging etc., but which is an area that is changing rapidly. In NWT’s view, Option A is lacking in ambition and there should be a higher reduction target per household. Option D should not be countenanced at all. Similarly, rapidly advancing technologies in reuse of industrial and commercial waste as a valuable resource should also enable a higher target for the C&I sector.

Q9: Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan. Do you have any evidence to suggest that different assumptions should be made?
NWT suggest that these targets for recycling should be more ambitious, as this will drive innovation, and should be combined with drivers and incentives from the public sector to force change. The current situation under Covid 19 has shown how dramatically behaviour can be changed in a very short time (under awful circumstances that we hope will never be repeated) given sufficient government will. NWT would suggest that there is an opportunity for the WPAs to use lessons learned from the current crisis, about reductions in food waste, increased re-useable packaging (such as glass milk bottles) etc., to set considerably more ambitious targets, for the LACW stream in particular.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery is important for those last elements of the waste stream that cannot be reused or recycled, but should be considered as a last resort when absolutely all other options have been tried (as represented in the Waste Hierarchy). This needs to be more strongly stated in the Plan than in the current wording. There should be a target to reduce the production of RDF and other waste disposal by incineration. Nottingham and Nottinghamshire, in line with the former’s ambitious Carbon neutrality target and given the innovation and science sectors in the City and County, should be well placed to lead in this area of avoiding the production of materials that have to be converted to RDF.

NWT share the stated concern in the text that large, long term facilities, can have the unfortunate consequence of driving the need for waste to service them. It is also important to recognize, however, that even smaller facilities can cause this effect, as has been clearly seen by the series of unfortunate outcomes of the promotion and subsidy for anaerobic digestion on farms. In Nottinghamshire, this has directly resulted in unsustainable maize production solely for the purposes of feedstock for digesters, which has damaged soils and habitats, and added to pollution of the aquifers, results in substantial increases in NOx, NH4 and CO2 outputs from its production, and has reduced land availability for human food crops and biodiversity.

Therefore, driving the need for reduction in energy use should be the overriding policy, not supporting energy recovery. This should apply across all sectors, particularly municipal and industrial, and notably with regard to housing. So, in summary, NWT do not consider that there should be a plan for higher levels of energy recovery, as this will drive the production of more waste to supply it, rather than finding other ways of reducing that waste stream entirely.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
Availability of disposal sites can prevent or reduce innovation in finding other solutions, although there may be a need for disposal for the small fraction that cannot be used or recycled in any other way. There should be a presumption against developing large new disposal capacity in the context of strong drivers and incentives to find other solutions, so NWT would suggest that any additional capacity should be targeted to be deliberately small, to drive more material into the reduce-reuse-recycle circle.

Q12: Do you agree with the draft vision? Are there other things we should include?
NWT support the vision in general. Our only suggestion is that “ minimise the effects of climate change” is insufficiently specific, as it could refer to climate impact mitigation rather than greenhouse gas production. We suggest that “minimise greenhouse gas emissions that result from waste management in the County” is more accurate as a description of what appears to be intended.
Also the role of the restoration of waste sites to priority habitats should be highlighted by adding the following to the second paragraph:
“All waste sites will contribute towards a greener Nottinghamshire and Nottingham by ensuring that they contribute to biodiversity delivery of priority habitats and the re-
connection of ecological networks, and so ensuring that they also contribute to improving long term access for local people to high quality wildlife-rich greenspaces.”

Q13: Are the above objectives appropriate? Are there others we should consider?
Objective 1 Climate change. NWT consider that this needs to refer specifically to habitats , as there is always habitat damage as a result of new waste development, “ Encourage the efficient use of natural resources by promoting waste as a resource, limit further impacts by avoiding damage to air quality, water, habitats or soil, reduce the need to transport waste and accept that some change is inevitable and manage this by making sure that all new waste facilities are designed and located to withstand the likely impacts of flooding, higher temperatures and more frequent storms and that restoration of waste sites prioritises habitat creation, as that will also help in sequestering Carbon. “
Objective 3. The environment, This needs clarification about what is being protected, and also explicit reference to the need for waste sites to play their part in delivering biodiversity targets. Therefore, NWT suggest the following wording ; “to ensure any new waste facilities protect or enhance the countryside, wildlife and valuable habitats, protect water, soil and air quality across the plan area and thus ensure conservation of the built and natural heritage of the area. After their operational use ceases, all waste sites will be restored to beneficial nature conservation afteruse which optimises their contribution to meeting the County’s biodiversity targets and to delivering Nature Recovery Networks”
Objective 4. Community, Health and Wellbeing. The availability of wildlife-rich greenspace on people’s doorsteps is a significant factor in good physical and mental health and wellbeing , so NWT would suggest the following addition: – “to ensure any new waste facilities do not adversely impact on local amenities and quality of life from impacts such as dust, traffic, noise, odour and visual impact, and any loss of local greenspace upon which people rely for their good health and wellbeing and address local health concerns.”
Objective 5. Meet our future needs. It is essential to emphasise that any sites should be allocated on the basis of both robust SA and EIA, so that proper comparative assessments are made at the plan-making stage. Hence NWT would suggest the following addition to the wording: “Ensuring that there is a mix of site types, sizes and locations to help us manage waste sustainably wherever possible. Meet current and future targets for recycling our waste. Safeguarding existing and/or potential future sites where appropriate and where robust SA and EIA have been undertaken to allocate those sites. Locate new waste facilities to support new residential, commercial and industrial development across the plan area.”

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
NWT broadly agree with these locational priorities, but all decisions on location should always be subject to robust science based decision-making, tested through SA and EIA, so that the full range of impacts, including long distance ones such as NOx, can be properly assessed.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
In NWT’s view, using a criteria-based approach would be insufficiently robust. It is essential that a proper comparative SA of possible sites is undertaken at the same time and in a consistent manner, to ensure that the level of assessment is equal. Otherwise there is a risk of judging sites against variable criteria and contexts in the future. It is also essential to screen out unsustainable sites at an early stage, to prevent uncertainty, local concerns and potentially poor decision-making later.

Q16: What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
Of the scope listed, NWT would highlight the need for the follow changes and additions:
“Highways and transport • Air quality (for both human health and impacts on habitats and species) • Green Belt • Landscape protection • Habitat and species protection and conservation. Archaeology. Greenhouse Gas impacts • Heritage • Pollution • Noise • Flooding and water resources • Health and wellbeing • Public rights of Way. Visual impact. Restoration and aftercare to maximise the contribution to UK and County biodiversity targets.”
It is important to be aware of the issue of NOx and NH3 emissions from certain types of waste facilities potentially impacting habitats. Nitrogen deposition on habitats has been identified as the most serious pollutant of habitats across the UK and Europe and these emissions can be particularly problematic for the heathlands and calcareous grasslands found in Nottinghamshire.
Nottinghamshire has Biodiversity Opportunity Maps, (which will inform the development of a NRN map for the County over the next 12 months), they are held by the County Council through the Biodiversity Action Group, and is it is essential that these documents are taken into account in the development of the Waste Local Plan, both to protect key areas of the network and to ensure that the location of waste sites may also contribute the Network in the long term when they are decommissioned and restored.

NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape-scale conservation in Nottinghamshire, in line with the Lawton Review and the 25 Year Environment Plan, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
It is essential that up to date biodiversity information at the necessary level of detail is used to help the preparation of the Plan, both with regard to data from the NGBRC and the Biodiversity Opportunity Maps.

NWT would expect the WPAs to embed the restoration and re-creation of biodiversity into the WLP, in accordance with the requirements of the 25 Year Environment Plan and the NPPF. It is particularly important, therefore, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a waste scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Nottinghamshire in the past. So these requirements should be secured through robust planning obligations and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

For potential larger footprint waste sites NWT would expect the use of site restoration briefs at an allocation stage, as has been undertaken for the MLP. This is an exemplary and constructive approach and should be replicated in this Waste Local Plan, with the creation of priority biodiversity habitats as the primary restoration aim for all allocations and extensions.

The restoration of waste sites can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable waste sites where the substrate is acidic, and has low nutrient status. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector waste industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.
The site allocation restoration briefs should list the target priority habitats using the existing NE Natural Character Area (NCA) approach and the Biodiversity Opportunity Map, the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which may be achieved through waste site restoration, as described above:
Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows
Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches
Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.

Trent Valley and Rises:rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.
Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.
Please do not hesitate to contact me if you have any queries about the above or if I can provide more information. I look forward to working with the WPA in the development of this important Plan.

Yours sincerely,

Thank you for consulting NWT on the above, I welcome the emphasis on the circular waste economy and hope to see stronger targets for further waste reduction and re-use.

In this response, I have followed the normal convention of showing the existing text from the consultation document in italics and recommended changes in bold italics.

Q1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
NWT consider this is the longest period that could be appropriate, as it is essential that robust targets can be set within a reasonably predictable context. Beyond this period, external factors could change so dramatically that setting targets becomes impossible. Even within this timeframe there are likely to be substantive changes in some areas, particularly regarding packaging and re-use (which has changed considerably in the last decade), so either a review period will need to embedded in the Plan, to re-set targets, or the Plan period shortened.

Q2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
Para 3.6. does not fully encompass the breadth and value of the County’s biodiversity resource, so NWT would suggest the following additions:
“The County’s landscape is characterised by rich rolling farmlands to the south, with a central belt of mixed woodland and farmland, giving way to heathland in the north and open, flat agricultural landscapes dominated by the River Trent to the east. Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, to the north of Mansfield. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status. There is, however, a significant network of SSSIs and LWS across the County, representing the wide range of habitat types found on the diverse geology of the County and hosting diverse, and often scarce, species of flora and fauna. Some of these habitats have been created as a result of the restoration of former waste sites, and this Plan will ensure that the restoration of future waste sites contributes to this network of wildlife-rich habitats, as part of Nottinghamshire’s Nature Recovery Network”.

Plan 1 – The Plan Area does not adequately or accurately represent this biodiversity resource. The green shape that is categorized as “Sherwood Forest including Special Area of Conservation” neither shows the SAC accurately (nor the ppSPA), nor does it encompass the boundaries of “Sherwood Forest” that have been discussed and agreed by multiple parties over many years. NWT would suggest that the SAC is shown accurately as a polygon, the ppSPA is shown as a dotted line boundary, and that ,as a minimum, dots are used to show the SSSIs. We agree that at this scale, it would not be possible to show the LWS.

Q 3-8
I will not respond in detail to the questions about waste calculations and predictions, as this is not a field where NWT has technical expertise, but as a general principle, we would expect more ambitious targets for reduction and re-use for LACW, not least given the admittedly small, changes in the major supermarkets in the last year towards reduced plastic packaging etc., but which is an area that is changing rapidly. In NWT’s view, Option A is lacking in ambition and there should be a higher reduction target per household. Option D should not be countenanced at all. Similarly, rapidly advancing technologies in reuse of industrial and commercial waste as a valuable resource should also enable a higher target for the C&I sector.

Q9: Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan. Do you have any evidence to suggest that different assumptions should be made?
NWT suggest that these targets for recycling should be more ambitious, as this will drive innovation, and should be combined with drivers and incentives from the public sector to force change. The current situation under Covid 19 has shown how dramatically behaviour can be changed in a very short time (under awful circumstances that we hope will never be repeated) given sufficient government will. NWT would suggest that there is an opportunity for the WPAs to use lessons learned from the current crisis, about reductions in food waste, increased re-useable packaging (such as glass milk bottles) etc., to set considerably more ambitious targets, for the LACW stream in particular.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery is important for those last elements of the waste stream that cannot be reused or recycled, but should be considered as a last resort when absolutely all other options have been tried (as represented in the Waste Hierarchy). This needs to be more strongly stated in the Plan than in the current wording. There should be a target to reduce the production of RDF and other waste disposal by incineration. Nottingham and Nottinghamshire, in line with the former’s ambitious Carbon neutrality target and given the innovation and science sectors in the City and County, should be well placed to lead in this area of avoiding the production of materials that have to be converted to RDF.

NWT share the stated concern in the text that large, long term facilities, can have the unfortunate consequence of driving the need for waste to service them. It is also important to recognize, however, that even smaller facilities can cause this effect, as has been clearly seen by the series of unfortunate outcomes of the promotion and subsidy for anaerobic digestion on farms. In Nottinghamshire, this has directly resulted in unsustainable maize production solely for the purposes of feedstock for digesters, which has damaged soils and habitats, and added to pollution of the aquifers, results in substantial increases in NOx, NH4 and CO2 outputs from its production, and has reduced land availability for human food crops and biodiversity.

Therefore, driving the need for reduction in energy use should be the overriding policy, not supporting energy recovery. This should apply across all sectors, particularly municipal and industrial, and notably with regard to housing. So, in summary, NWT do not consider that there should be a plan for higher levels of energy recovery, as this will drive the production of more waste to supply it, rather than finding other ways of reducing that waste stream entirely.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
Availability of disposal sites can prevent or reduce innovation in finding other solutions, although there may be a need for disposal for the small fraction that cannot be used or recycled in any other way. There should be a presumption against developing large new disposal capacity in the context of strong drivers and incentives to find other solutions, so NWT would suggest that any additional capacity should be targeted to be deliberately small, to drive more material into the reduce-reuse-recycle circle.

Q12: Do you agree with the draft vision? Are there other things we should include?
NWT support the vision in general. Our only suggestion is that “ minimise the effects of climate change” is insufficiently specific, as it could refer to climate impact mitigation rather than greenhouse gas production. We suggest that “minimise greenhouse gas emissions that result from waste management in the County” is more accurate as a description of what appears to be intended.
Also the role of the restoration of waste sites to priority habitats should be highlighted by adding the following to the second paragraph:
“All waste sites will contribute towards a greener Nottinghamshire and Nottingham by ensuring that they contribute to biodiversity delivery of priority habitats and the re-
connection of ecological networks, and so ensuring that they also contribute to improving long term access for local people to high quality wildlife-rich greenspaces.”

Q13: Are the above objectives appropriate? Are there others we should consider?
Objective 1 Climate change. NWT consider that this needs to refer specifically to habitats , as there is always habitat damage as a result of new waste development, “ Encourage the efficient use of natural resources by promoting waste as a resource, limit further impacts by avoiding damage to air quality, water, habitats or soil, reduce the need to transport waste and accept that some change is inevitable and manage this by making sure that all new waste facilities are designed and located to withstand the likely impacts of flooding, higher temperatures and more frequent storms and that restoration of waste sites prioritises habitat creation, as that will also help in sequestering Carbon. “
Objective 3. The environment, This needs clarification about what is being protected, and also explicit reference to the need for waste sites to play their part in delivering biodiversity targets. Therefore, NWT suggest the following wording ; “to ensure any new waste facilities protect or enhance the countryside, wildlife and valuable habitats, protect water, soil and air quality across the plan area and thus ensure conservation of the built and natural heritage of the area. After their operational use ceases, all waste sites will be restored to beneficial nature conservation afteruse which optimises their contribution to meeting the County’s biodiversity targets and to delivering Nature Recovery Networks”
Objective 4. Community, Health and Wellbeing. The availability of wildlife-rich greenspace on people’s doorsteps is a significant factor in good physical and mental health and wellbeing , so NWT would suggest the following addition: – “to ensure any new waste facilities do not adversely impact on local amenities and quality of life from impacts such as dust, traffic, noise, odour and visual impact, and any loss of local greenspace upon which people rely for their good health and wellbeing and address local health concerns.”
Objective 5. Meet our future needs. It is essential to emphasise that any sites should be allocated on the basis of both robust SA and EIA, so that proper comparative assessments are made at the plan-making stage. Hence NWT would suggest the following addition to the wording: “Ensuring that there is a mix of site types, sizes and locations to help us manage waste sustainably wherever possible. Meet current and future targets for recycling our waste. Safeguarding existing and/or potential future sites where appropriate and where robust SA and EIA have been undertaken to allocate those sites. Locate new waste facilities to support new residential, commercial and industrial development across the plan area.”

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
NWT broadly agree with these locational priorities, but all decisions on location should always be subject to robust science based decision-making, tested through SA and EIA, so that the full range of impacts, including long distance ones such as NOx, can be properly assessed.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
In NWT’s view, using a criteria-based approach would be insufficiently robust. It is essential that a proper comparative SA of possible sites is undertaken at the same time and in a consistent manner, to ensure that the level of assessment is equal. Otherwise there is a risk of judging sites against variable criteria and contexts in the future. It is also essential to screen out unsustainable sites at an early stage, to prevent uncertainty, local concerns and potentially poor decision-making later.

Q16: What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
Of the scope listed, NWT would highlight the need for the follow changes and additions:
“Highways and transport • Air quality (for both human health and impacts on habitats and species) • Green Belt • Landscape protection • Habitat and species protection and conservation. Archaeology. Greenhouse Gas impacts • Heritage • Pollution • Noise • Flooding and water resources • Health and wellbeing • Public rights of Way. Visual impact. Restoration and aftercare to maximise the contribution to UK and County biodiversity targets.”
It is important to be aware of the issue of NOx and NH3 emissions from certain types of waste facilities potentially impacting habitats. Nitrogen deposition on habitats has been identified as the most serious pollutant of habitats across the UK and Europe and these emissions can be particularly problematic for the heathlands and calcareous grasslands found in Nottinghamshire.
Nottinghamshire has Biodiversity Opportunity Maps, (which will inform the development of a NRN map for the County over the next 12 months), they are held by the County Council through the Biodiversity Action Group, and is it is essential that these documents are taken into account in the development of the Waste Local Plan, both to protect key areas of the network and to ensure that the location of waste sites may also contribute the Network in the long term when they are decommissioned and restored.

NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape-scale conservation in Nottinghamshire, in line with the Lawton Review and the 25 Year Environment Plan, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
It is essential that up to date biodiversity information at the necessary level of detail is used to help the preparation of the Plan, both with regard to data from the NGBRC and the Biodiversity Opportunity Maps.

NWT would expect the WPAs to embed the restoration and re-creation of biodiversity into the WLP, in accordance with the requirements of the 25 Year Environment Plan and the NPPF. It is particularly important, therefore, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a waste scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Nottinghamshire in the past. So these requirements should be secured through robust planning obligations and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

For potential larger footprint waste sites NWT would expect the use of site restoration briefs at an allocation stage, as has been undertaken for the MLP. This is an exemplary and constructive approach and should be replicated in this Waste Local Plan, with the creation of priority biodiversity habitats as the primary restoration aim for all allocations and extensions.

The restoration of waste sites can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable waste sites where the substrate is acidic, and has low nutrient status. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector waste industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.
The site allocation restoration briefs should list the target priority habitats using the existing NE Natural Character Area (NCA) approach and the Biodiversity Opportunity Map, the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which may be achieved through waste site restoration, as described above:
Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows
Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches
Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.

Trent Valley and Rises:rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.
Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.
Please do not hesitate to contact me if you have any queries about the above or if I can provide more information. I look forward to working with the WPA in the development of this important Plan.

Yours sincerely,

Thank you for consulting NWT on the above, I welcome the emphasis on the circular waste economy and hope to see stronger targets for further waste reduction and re-use.

In this response, I have followed the normal convention of showing the existing text from the consultation document in italics and recommended changes in bold italics.

Q1: We envisage the plan period covering up to 2038, do you think this is appropriate? If not, what other plan period should be used and why?
NWT consider this is the longest period that could be appropriate, as it is essential that robust targets can be set within a reasonably predictable context. Beyond this period, external factors could change so dramatically that setting targets becomes impossible. Even within this timeframe there are likely to be substantive changes in some areas, particularly regarding packaging and re-use (which has changed considerably in the last decade), so either a review period will need to embedded in the Plan, to re-set targets, or the Plan period shortened.

Q2: Do you think any further information should be included in the overview of the Plan area and the implications for the management of waste?
Para 3.6. does not fully encompass the breadth and value of the County’s biodiversity resource, so NWT would suggest the following additions:
“The County’s landscape is characterised by rich rolling farmlands to the south, with a central belt of mixed woodland and farmland, giving way to heathland in the north and open, flat agricultural landscapes dominated by the River Trent to the east. Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, to the north of Mansfield. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status. There is, however, a significant network of SSSIs and LWS across the County, representing the wide range of habitat types found on the diverse geology of the County and hosting diverse, and often scarce, species of flora and fauna. Some of these habitats have been created as a result of the restoration of former waste sites, and this Plan will ensure that the restoration of future waste sites contributes to this network of wildlife-rich habitats, as part of Nottinghamshire’s Nature Recovery Network”.

Plan 1 – The Plan Area does not adequately or accurately represent this biodiversity resource. The green shape that is categorized as “Sherwood Forest including Special Area of Conservation” neither shows the SAC accurately (nor the ppSPA), nor does it encompass the boundaries of “Sherwood Forest” that have been discussed and agreed by multiple parties over many years. NWT would suggest that the SAC is shown accurately as a polygon, the ppSPA is shown as a dotted line boundary, and that ,as a minimum, dots are used to show the SSSIs. We agree that at this scale, it would not be possible to show the LWS.

Q 3-8
I will not respond in detail to the questions about waste calculations and predictions, as this is not a field where NWT has technical expertise, but as a general principle, we would expect more ambitious targets for reduction and re-use for LACW, not least given the admittedly small, changes in the major supermarkets in the last year towards reduced plastic packaging etc., but which is an area that is changing rapidly. In NWT’s view, Option A is lacking in ambition and there should be a higher reduction target per household. Option D should not be countenanced at all. Similarly, rapidly advancing technologies in reuse of industrial and commercial waste as a valuable resource should also enable a higher target for the C&I sector.

Q9: Do you consider these assumptions about future recycling rates are an appropriate basis for the Waste Local Plan. Do you have any evidence to suggest that different assumptions should be made?
NWT suggest that these targets for recycling should be more ambitious, as this will drive innovation, and should be combined with drivers and incentives from the public sector to force change. The current situation under Covid 19 has shown how dramatically behaviour can be changed in a very short time (under awful circumstances that we hope will never be repeated) given sufficient government will. NWT would suggest that there is an opportunity for the WPAs to use lessons learned from the current crisis, about reductions in food waste, increased re-useable packaging (such as glass milk bottles) etc., to set considerably more ambitious targets, for the LACW stream in particular.

Q10: What role do you think recovery should play? Should the plan provide for higher levels of energy recovery in future?
Energy recovery is important for those last elements of the waste stream that cannot be reused or recycled, but should be considered as a last resort when absolutely all other options have been tried (as represented in the Waste Hierarchy). This needs to be more strongly stated in the Plan than in the current wording. There should be a target to reduce the production of RDF and other waste disposal by incineration. Nottingham and Nottinghamshire, in line with the former’s ambitious Carbon neutrality target and given the innovation and science sectors in the City and County, should be well placed to lead in this area of avoiding the production of materials that have to be converted to RDF.

NWT share the stated concern in the text that large, long term facilities, can have the unfortunate consequence of driving the need for waste to service them. It is also important to recognize, however, that even smaller facilities can cause this effect, as has been clearly seen by the series of unfortunate outcomes of the promotion and subsidy for anaerobic digestion on farms. In Nottinghamshire, this has directly resulted in unsustainable maize production solely for the purposes of feedstock for digesters, which has damaged soils and habitats, and added to pollution of the aquifers, results in substantial increases in NOx, NH4 and CO2 outputs from its production, and has reduced land availability for human food crops and biodiversity.

Therefore, driving the need for reduction in energy use should be the overriding policy, not supporting energy recovery. This should apply across all sectors, particularly municipal and industrial, and notably with regard to housing. So, in summary, NWT do not consider that there should be a plan for higher levels of energy recovery, as this will drive the production of more waste to supply it, rather than finding other ways of reducing that waste stream entirely.

Q11: Do you agree with the need to provide additional disposal capacity within the Plan Area?
Availability of disposal sites can prevent or reduce innovation in finding other solutions, although there may be a need for disposal for the small fraction that cannot be used or recycled in any other way. There should be a presumption against developing large new disposal capacity in the context of strong drivers and incentives to find other solutions, so NWT would suggest that any additional capacity should be targeted to be deliberately small, to drive more material into the reduce-reuse-recycle circle.

Q12: Do you agree with the draft vision? Are there other things we should include?
NWT support the vision in general. Our only suggestion is that “ minimise the effects of climate change” is insufficiently specific, as it could refer to climate impact mitigation rather than greenhouse gas production. We suggest that “minimise greenhouse gas emissions that result from waste management in the County” is more accurate as a description of what appears to be intended.
Also the role of the restoration of waste sites to priority habitats should be highlighted by adding the following to the second paragraph:
“All waste sites will contribute towards a greener Nottinghamshire and Nottingham by ensuring that they contribute to biodiversity delivery of priority habitats and the re-
connection of ecological networks, and so ensuring that they also contribute to improving long term access for local people to high quality wildlife-rich greenspaces.”

Q13: Are the above objectives appropriate? Are there others we should consider?
Objective 1 Climate change. NWT consider that this needs to refer specifically to habitats , as there is always habitat damage as a result of new waste development, “ Encourage the efficient use of natural resources by promoting waste as a resource, limit further impacts by avoiding damage to air quality, water, habitats or soil, reduce the need to transport waste and accept that some change is inevitable and manage this by making sure that all new waste facilities are designed and located to withstand the likely impacts of flooding, higher temperatures and more frequent storms and that restoration of waste sites prioritises habitat creation, as that will also help in sequestering Carbon. “
Objective 3. The environment, This needs clarification about what is being protected, and also explicit reference to the need for waste sites to play their part in delivering biodiversity targets. Therefore, NWT suggest the following wording ; “to ensure any new waste facilities protect or enhance the countryside, wildlife and valuable habitats, protect water, soil and air quality across the plan area and thus ensure conservation of the built and natural heritage of the area. After their operational use ceases, all waste sites will be restored to beneficial nature conservation afteruse which optimises their contribution to meeting the County’s biodiversity targets and to delivering Nature Recovery Networks”
Objective 4. Community, Health and Wellbeing. The availability of wildlife-rich greenspace on people’s doorsteps is a significant factor in good physical and mental health and wellbeing , so NWT would suggest the following addition: – “to ensure any new waste facilities do not adversely impact on local amenities and quality of life from impacts such as dust, traffic, noise, odour and visual impact, and any loss of local greenspace upon which people rely for their good health and wellbeing and address local health concerns.”
Objective 5. Meet our future needs. It is essential to emphasise that any sites should be allocated on the basis of both robust SA and EIA, so that proper comparative assessments are made at the plan-making stage. Hence NWT would suggest the following addition to the wording: “Ensuring that there is a mix of site types, sizes and locations to help us manage waste sustainably wherever possible. Meet current and future targets for recycling our waste. Safeguarding existing and/or potential future sites where appropriate and where robust SA and EIA have been undertaken to allocate those sites. Locate new waste facilities to support new residential, commercial and industrial development across the plan area.”

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
NWT broadly agree with these locational priorities, but all decisions on location should always be subject to robust science based decision-making, tested through SA and EIA, so that the full range of impacts, including long distance ones such as NOx, can be properly assessed.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
In NWT’s view, using a criteria-based approach would be insufficiently robust. It is essential that a proper comparative SA of possible sites is undertaken at the same time and in a consistent manner, to ensure that the level of assessment is equal. Otherwise there is a risk of judging sites against variable criteria and contexts in the future. It is also essential to screen out unsustainable sites at an early stage, to prevent uncertainty, local concerns and potentially poor decision-making later.

Q16: What do you think of our proposals for the scope of the development management policies? Are there any others that should be covered such as for specific types of waste management facility?
Of the scope listed, NWT would highlight the need for the follow changes and additions:
“Highways and transport • Air quality (for both human health and impacts on habitats and species) • Green Belt • Landscape protection • Habitat and species protection and conservation. Archaeology. Greenhouse Gas impacts • Heritage • Pollution • Noise • Flooding and water resources • Health and wellbeing • Public rights of Way. Visual impact. Restoration and aftercare to maximise the contribution to UK and County biodiversity targets.”
It is important to be aware of the issue of NOx and NH3 emissions from certain types of waste facilities potentially impacting habitats. Nitrogen deposition on habitats has been identified as the most serious pollutant of habitats across the UK and Europe and these emissions can be particularly problematic for the heathlands and calcareous grasslands found in Nottinghamshire.
Nottinghamshire has Biodiversity Opportunity Maps, (which will inform the development of a NRN map for the County over the next 12 months), they are held by the County Council through the Biodiversity Action Group, and is it is essential that these documents are taken into account in the development of the Waste Local Plan, both to protect key areas of the network and to ensure that the location of waste sites may also contribute the Network in the long term when they are decommissioned and restored.

NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape-scale conservation in Nottinghamshire, in line with the Lawton Review and the 25 Year Environment Plan, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.

Q17: Are there any other comments you would like to make to help inform the preparation of the Waste Local Plan?
It is essential that up to date biodiversity information at the necessary level of detail is used to help the preparation of the Plan, both with regard to data from the NGBRC and the Biodiversity Opportunity Maps.

NWT would expect the WPAs to embed the restoration and re-creation of biodiversity into the WLP, in accordance with the requirements of the 25 Year Environment Plan and the NPPF. It is particularly important, therefore, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a waste scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Nottinghamshire in the past. So these requirements should be secured through robust planning obligations and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

For potential larger footprint waste sites NWT would expect the use of site restoration briefs at an allocation stage, as has been undertaken for the MLP. This is an exemplary and constructive approach and should be replicated in this Waste Local Plan, with the creation of priority biodiversity habitats as the primary restoration aim for all allocations and extensions.

The restoration of waste sites can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable waste sites where the substrate is acidic, and has low nutrient status. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector waste industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.
The site allocation restoration briefs should list the target priority habitats using the existing NE Natural Character Area (NCA) approach and the Biodiversity Opportunity Map, the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which may be achieved through waste site restoration, as described above:
Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows
Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches
Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.

Trent Valley and Rises:rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.
Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.
Please do not hesitate to contact me if you have any queries about the above or if I can provide more information. I look forward to working with the WPA in the development of this important Plan.

Yours sincerely,