Waste Issues and Options

Dear Sir/Madam
RE: NOTTINGHAMSHIRE COUNTY COUNCIL – NEW WASTE LOCAL PLAN REVIEW 2020.
This letter represents the view of Biffa Waste Service Ltd (‘Biffa’) to the above consultation.
On reviewing the document ‘Waste Local Plan – issues and options’ we understand that the consultation is still at an early stage and further information would be required to assess as to where Biffa as a business could assist with the councils wastes needs, however we wish to show interest at this time with potential opportunity in the future.
Biffa
Biffa is the UK’s leading sustainable waste management business. We have over 8,000 employees working across more than 200 sites to change the way people think about waste. The Group operates across the waste management value chain, including the collection, treatment, processing and disposal of waste, as well as the production and sale of recovered commodities such as energy, paper, glass, metals and plastic.
We are first choice for customers, with our national customer base including local authorities, large corporates and SMEs, and purchasers of end-product commodities and energy. We are structured into two divisions: Collections and Resources & Energy. In FY19, the Group's total revenue was £1,091.2m and its Underlying EBITDA was £150.7m. Biffa has been listed on the London Stock Exchange since October 2016 and in March 2020 Biffa entered the FTSE-250
Biffa’s customer base for these services includes local authorities (which includes the collection of waste from households), large corporates and SMEs, and purchasers of end product commodities and energy. The Group’s services are organised across two operating divisions: Collection and Resource and Energy.
Biffa provides a wide range of services to corporate, industrial, and commercial and public sector customers, including waste collection, sorting services for the recovery of recyclable material and transfer of residual waste. The scope of the Group’s national coverage is an important part of its offering to its customers. The Industrial and Commercial Collection arm of Biffa operates a collection network of more than 1,100 front-line collection vehicles, which operate from 67 depots and 28 transfer stations, with over 75,000 customers.




Need for Landfill.
Section 4.24 of the Nottinghamshire WLP consultation document states “there is now only one suitable landfill site within the plan area which is due to close within a year. After this, waste for disposal will have to be sent to sites outside of the plan area unless a new local site can be found”
Over recent years landfill has been reducing in size as more waste is recycled or used as fuel in Energy from Waste facilities. This pattern can be seen across the UK as part of the general drive to divert more recyclable and combustible waste from landfill. The UK has a substantial shortfall of recycling and energy from waste infrastructure, meaning landfill disposal still plays an important waste management role to help the economy function and underpins the waste hierarchy albeit as a last resort.
There are also substantial volumes of residual waste from the economy which are not recyclable or suitable for fuel use and which will always have to be safely disposed of by landfill, along with residues from waste treatment and recycling facilities themselves.
Biffa is one of the main operators of landfill services in the UK. In the last year we handled around 3 million tonnes of waste through our 9 remaining operational landfill sites. Biffa also continue to manage 62 closed landfill sites in the UK.
We would therefore encourage the Council to consider a flexible approach in setting restoration aims for new or existing mineral extraction sites that would seek to consider the landfill of non-inert waste as part of those approved development schemes, and to consider those aims at this early stage whilst considering all of the necessary environmental and amenity obligations.
A ‘Circular Economy’
Whilst the need for Landfill has been identified within the plan area, Biffa support the principles of the Waste Hierarchy, which in addition to the EU Circular Economy Package still recognises the necessary supporting role of landfill as stated above, but not as a first resort for general waste.
As stated in our Reality Gap 2017 publication, all levels of the waste hierarchy serve a vital role and the measure of success is that a particular waste stream is managed in its most appropriate place in that hierarchy depending on its properties and value.
Achieving the overall aim of ‘moving waste up the Waste Hierarchy’ relies on moving away from the traditional linear economy and developing a circular economy. In a circular economy maximum resource efficiency is achieved by keeping products, components and materials at their highest value at all times, using products for as long as possible before recycling into new products to reduce the need to use new natural resources. Only when no further benefit can be recovered from a resource should it be disposed of.
The plan should address waste prevention and re-use, and should consider the key targets set out in the ‘Resource and Waste Strategy for England’ document which highlights a significant increase in recycling targets and a further reduction in Landfill.
• 50% recycling household waste by 2020
• 65% recycling municipal waste by 2035 (in line with EU CE package)
• 10% (or less) municipal waste to landfill by 2035 (in line with EU CE package)
• Eliminate all food waste to landfill by 2030
• All plastic packaging to be recyclable ,reusable or compostable by 2025
• 75% recycling of packaging by 2030
With this in mind, we encourage the council to be flexible in their planning permissions when determining the development of new waste facilities.

New locations – ‘Call For Sites’
Whilst no specific locations have yet been decided within the plan area, it is common for councils to propose areas of existing industrial or employment land in line with Section 4 of the ‘National Planning Policy For Waste’ that states “give priority to the re-use of previously-developed land, sites identified for employment uses, and redundant agricultural and forestry buildings and their curtilages”.

In identifying such land, we urge the Council to take a robust approach to site selection and undertake a full assessment of the options that are presented that also considers the commercial viability of particular sites and consider the following:

• Cost of land remediation;
• Insufficient size (economies of scale);
• Proximity to receptors, particularly in employment areas;
• High cost of purchase/competition
Once more accurate waste tonnages within the plan area have been established, the type of facility will also need to be decided based on the shortfalls identified within the ‘Waste Needs Assessment’.
Safeguarding
New and existing facilities should be safeguarded in line with the NPPF (Para. 182) and objective 5 of the Nottinghamshire – ‘Issues and Options’ document.
Facilities should be safeguarded from encroachment by other development, most particularly, housing. Waste sites are strategic assets and should be protected and offered sufficient flexibility in their operation such that they can continue to provide a vital service.
Aside from the existing safeguarded sites, the plan should rely on criteria based approach so that applicants can be sure that any site they are promoting meets the requirements of the plan.

I trust that our comments are helpful and will be taken into account in moving to the next stage of plan preparation. Should you have any queries then please do not hesitate to contact me.


Yours faithfully

Dear Sir/Madam
RE: NOTTINGHAMSHIRE COUNTY COUNCIL – NEW WASTE LOCAL PLAN REVIEW 2020.
This letter represents the view of Biffa Waste Service Ltd (‘Biffa’) to the above consultation.
On reviewing the document ‘Waste Local Plan – issues and options’ we understand that the consultation is still at an early stage and further information would be required to assess as to where Biffa as a business could assist with the councils wastes needs, however we wish to show interest at this time with potential opportunity in the future.
Biffa
Biffa is the UK’s leading sustainable waste management business. We have over 8,000 employees working across more than 200 sites to change the way people think about waste. The Group operates across the waste management value chain, including the collection, treatment, processing and disposal of waste, as well as the production and sale of recovered commodities such as energy, paper, glass, metals and plastic.
We are first choice for customers, with our national customer base including local authorities, large corporates and SMEs, and purchasers of end-product commodities and energy. We are structured into two divisions: Collections and Resources & Energy. In FY19, the Group's total revenue was £1,091.2m and its Underlying EBITDA was £150.7m. Biffa has been listed on the London Stock Exchange since October 2016 and in March 2020 Biffa entered the FTSE-250
Biffa’s customer base for these services includes local authorities (which includes the collection of waste from households), large corporates and SMEs, and purchasers of end product commodities and energy. The Group’s services are organised across two operating divisions: Collection and Resource and Energy.
Biffa provides a wide range of services to corporate, industrial, and commercial and public sector customers, including waste collection, sorting services for the recovery of recyclable material and transfer of residual waste. The scope of the Group’s national coverage is an important part of its offering to its customers. The Industrial and Commercial Collection arm of Biffa operates a collection network of more than 1,100 front-line collection vehicles, which operate from 67 depots and 28 transfer stations, with over 75,000 customers.




Need for Landfill.
Section 4.24 of the Nottinghamshire WLP consultation document states “there is now only one suitable landfill site within the plan area which is due to close within a year. After this, waste for disposal will have to be sent to sites outside of the plan area unless a new local site can be found”
Over recent years landfill has been reducing in size as more waste is recycled or used as fuel in Energy from Waste facilities. This pattern can be seen across the UK as part of the general drive to divert more recyclable and combustible waste from landfill. The UK has a substantial shortfall of recycling and energy from waste infrastructure, meaning landfill disposal still plays an important waste management role to help the economy function and underpins the waste hierarchy albeit as a last resort.
There are also substantial volumes of residual waste from the economy which are not recyclable or suitable for fuel use and which will always have to be safely disposed of by landfill, along with residues from waste treatment and recycling facilities themselves.
Biffa is one of the main operators of landfill services in the UK. In the last year we handled around 3 million tonnes of waste through our 9 remaining operational landfill sites. Biffa also continue to manage 62 closed landfill sites in the UK.
We would therefore encourage the Council to consider a flexible approach in setting restoration aims for new or existing mineral extraction sites that would seek to consider the landfill of non-inert waste as part of those approved development schemes, and to consider those aims at this early stage whilst considering all of the necessary environmental and amenity obligations.
A ‘Circular Economy’
Whilst the need for Landfill has been identified within the plan area, Biffa support the principles of the Waste Hierarchy, which in addition to the EU Circular Economy Package still recognises the necessary supporting role of landfill as stated above, but not as a first resort for general waste.
As stated in our Reality Gap 2017 publication, all levels of the waste hierarchy serve a vital role and the measure of success is that a particular waste stream is managed in its most appropriate place in that hierarchy depending on its properties and value.
Achieving the overall aim of ‘moving waste up the Waste Hierarchy’ relies on moving away from the traditional linear economy and developing a circular economy. In a circular economy maximum resource efficiency is achieved by keeping products, components and materials at their highest value at all times, using products for as long as possible before recycling into new products to reduce the need to use new natural resources. Only when no further benefit can be recovered from a resource should it be disposed of.
The plan should address waste prevention and re-use, and should consider the key targets set out in the ‘Resource and Waste Strategy for England’ document which highlights a significant increase in recycling targets and a further reduction in Landfill.
• 50% recycling household waste by 2020
• 65% recycling municipal waste by 2035 (in line with EU CE package)
• 10% (or less) municipal waste to landfill by 2035 (in line with EU CE package)
• Eliminate all food waste to landfill by 2030
• All plastic packaging to be recyclable ,reusable or compostable by 2025
• 75% recycling of packaging by 2030
With this in mind, we encourage the council to be flexible in their planning permissions when determining the development of new waste facilities.

New locations – ‘Call For Sites’
Whilst no specific locations have yet been decided within the plan area, it is common for councils to propose areas of existing industrial or employment land in line with Section 4 of the ‘National Planning Policy For Waste’ that states “give priority to the re-use of previously-developed land, sites identified for employment uses, and redundant agricultural and forestry buildings and their curtilages”.

In identifying such land, we urge the Council to take a robust approach to site selection and undertake a full assessment of the options that are presented that also considers the commercial viability of particular sites and consider the following:

• Cost of land remediation;
• Insufficient size (economies of scale);
• Proximity to receptors, particularly in employment areas;
• High cost of purchase/competition
Once more accurate waste tonnages within the plan area have been established, the type of facility will also need to be decided based on the shortfalls identified within the ‘Waste Needs Assessment’.
Safeguarding
New and existing facilities should be safeguarded in line with the NPPF (Para. 182) and objective 5 of the Nottinghamshire – ‘Issues and Options’ document.
Facilities should be safeguarded from encroachment by other development, most particularly, housing. Waste sites are strategic assets and should be protected and offered sufficient flexibility in their operation such that they can continue to provide a vital service.
Aside from the existing safeguarded sites, the plan should rely on criteria based approach so that applicants can be sure that any site they are promoting meets the requirements of the plan.

I trust that our comments are helpful and will be taken into account in moving to the next stage of plan preparation. Should you have any queries then please do not hesitate to contact me.


Yours faithfully

Dear Sir/Madam
RE: NOTTINGHAMSHIRE COUNTY COUNCIL – NEW WASTE LOCAL PLAN REVIEW 2020.
This letter represents the view of Biffa Waste Service Ltd (‘Biffa’) to the above consultation.
On reviewing the document ‘Waste Local Plan – issues and options’ we understand that the consultation is still at an early stage and further information would be required to assess as to where Biffa as a business could assist with the councils wastes needs, however we wish to show interest at this time with potential opportunity in the future.
Biffa
Biffa is the UK’s leading sustainable waste management business. We have over 8,000 employees working across more than 200 sites to change the way people think about waste. The Group operates across the waste management value chain, including the collection, treatment, processing and disposal of waste, as well as the production and sale of recovered commodities such as energy, paper, glass, metals and plastic.
We are first choice for customers, with our national customer base including local authorities, large corporates and SMEs, and purchasers of end-product commodities and energy. We are structured into two divisions: Collections and Resources & Energy. In FY19, the Group's total revenue was £1,091.2m and its Underlying EBITDA was £150.7m. Biffa has been listed on the London Stock Exchange since October 2016 and in March 2020 Biffa entered the FTSE-250
Biffa’s customer base for these services includes local authorities (which includes the collection of waste from households), large corporates and SMEs, and purchasers of end product commodities and energy. The Group’s services are organised across two operating divisions: Collection and Resource and Energy.
Biffa provides a wide range of services to corporate, industrial, and commercial and public sector customers, including waste collection, sorting services for the recovery of recyclable material and transfer of residual waste. The scope of the Group’s national coverage is an important part of its offering to its customers. The Industrial and Commercial Collection arm of Biffa operates a collection network of more than 1,100 front-line collection vehicles, which operate from 67 depots and 28 transfer stations, with over 75,000 customers.




Need for Landfill.
Section 4.24 of the Nottinghamshire WLP consultation document states “there is now only one suitable landfill site within the plan area which is due to close within a year. After this, waste for disposal will have to be sent to sites outside of the plan area unless a new local site can be found”
Over recent years landfill has been reducing in size as more waste is recycled or used as fuel in Energy from Waste facilities. This pattern can be seen across the UK as part of the general drive to divert more recyclable and combustible waste from landfill. The UK has a substantial shortfall of recycling and energy from waste infrastructure, meaning landfill disposal still plays an important waste management role to help the economy function and underpins the waste hierarchy albeit as a last resort.
There are also substantial volumes of residual waste from the economy which are not recyclable or suitable for fuel use and which will always have to be safely disposed of by landfill, along with residues from waste treatment and recycling facilities themselves.
Biffa is one of the main operators of landfill services in the UK. In the last year we handled around 3 million tonnes of waste through our 9 remaining operational landfill sites. Biffa also continue to manage 62 closed landfill sites in the UK.
We would therefore encourage the Council to consider a flexible approach in setting restoration aims for new or existing mineral extraction sites that would seek to consider the landfill of non-inert waste as part of those approved development schemes, and to consider those aims at this early stage whilst considering all of the necessary environmental and amenity obligations.
A ‘Circular Economy’
Whilst the need for Landfill has been identified within the plan area, Biffa support the principles of the Waste Hierarchy, which in addition to the EU Circular Economy Package still recognises the necessary supporting role of landfill as stated above, but not as a first resort for general waste.
As stated in our Reality Gap 2017 publication, all levels of the waste hierarchy serve a vital role and the measure of success is that a particular waste stream is managed in its most appropriate place in that hierarchy depending on its properties and value.
Achieving the overall aim of ‘moving waste up the Waste Hierarchy’ relies on moving away from the traditional linear economy and developing a circular economy. In a circular economy maximum resource efficiency is achieved by keeping products, components and materials at their highest value at all times, using products for as long as possible before recycling into new products to reduce the need to use new natural resources. Only when no further benefit can be recovered from a resource should it be disposed of.
The plan should address waste prevention and re-use, and should consider the key targets set out in the ‘Resource and Waste Strategy for England’ document which highlights a significant increase in recycling targets and a further reduction in Landfill.
• 50% recycling household waste by 2020
• 65% recycling municipal waste by 2035 (in line with EU CE package)
• 10% (or less) municipal waste to landfill by 2035 (in line with EU CE package)
• Eliminate all food waste to landfill by 2030
• All plastic packaging to be recyclable ,reusable or compostable by 2025
• 75% recycling of packaging by 2030
With this in mind, we encourage the council to be flexible in their planning permissions when determining the development of new waste facilities.

New locations – ‘Call For Sites’
Whilst no specific locations have yet been decided within the plan area, it is common for councils to propose areas of existing industrial or employment land in line with Section 4 of the ‘National Planning Policy For Waste’ that states “give priority to the re-use of previously-developed land, sites identified for employment uses, and redundant agricultural and forestry buildings and their curtilages”.

In identifying such land, we urge the Council to take a robust approach to site selection and undertake a full assessment of the options that are presented that also considers the commercial viability of particular sites and consider the following:

• Cost of land remediation;
• Insufficient size (economies of scale);
• Proximity to receptors, particularly in employment areas;
• High cost of purchase/competition
Once more accurate waste tonnages within the plan area have been established, the type of facility will also need to be decided based on the shortfalls identified within the ‘Waste Needs Assessment’.
Safeguarding
New and existing facilities should be safeguarded in line with the NPPF (Para. 182) and objective 5 of the Nottinghamshire – ‘Issues and Options’ document.
Facilities should be safeguarded from encroachment by other development, most particularly, housing. Waste sites are strategic assets and should be protected and offered sufficient flexibility in their operation such that they can continue to provide a vital service.
Aside from the existing safeguarded sites, the plan should rely on criteria based approach so that applicants can be sure that any site they are promoting meets the requirements of the plan.

I trust that our comments are helpful and will be taken into account in moving to the next stage of plan preparation. Should you have any queries then please do not hesitate to contact me.


Yours faithfully

Dear Sir/Madam
RE: NOTTINGHAMSHIRE COUNTY COUNCIL – NEW WASTE LOCAL PLAN REVIEW 2020.
This letter represents the view of Biffa Waste Service Ltd (‘Biffa’) to the above consultation.
On reviewing the document ‘Waste Local Plan – issues and options’ we understand that the consultation is still at an early stage and further information would be required to assess as to where Biffa as a business could assist with the councils wastes needs, however we wish to show interest at this time with potential opportunity in the future.
Biffa
Biffa is the UK’s leading sustainable waste management business. We have over 8,000 employees working across more than 200 sites to change the way people think about waste. The Group operates across the waste management value chain, including the collection, treatment, processing and disposal of waste, as well as the production and sale of recovered commodities such as energy, paper, glass, metals and plastic.
We are first choice for customers, with our national customer base including local authorities, large corporates and SMEs, and purchasers of end-product commodities and energy. We are structured into two divisions: Collections and Resources & Energy. In FY19, the Group's total revenue was £1,091.2m and its Underlying EBITDA was £150.7m. Biffa has been listed on the London Stock Exchange since October 2016 and in March 2020 Biffa entered the FTSE-250
Biffa’s customer base for these services includes local authorities (which includes the collection of waste from households), large corporates and SMEs, and purchasers of end product commodities and energy. The Group’s services are organised across two operating divisions: Collection and Resource and Energy.
Biffa provides a wide range of services to corporate, industrial, and commercial and public sector customers, including waste collection, sorting services for the recovery of recyclable material and transfer of residual waste. The scope of the Group’s national coverage is an important part of its offering to its customers. The Industrial and Commercial Collection arm of Biffa operates a collection network of more than 1,100 front-line collection vehicles, which operate from 67 depots and 28 transfer stations, with over 75,000 customers.




Need for Landfill.
Section 4.24 of the Nottinghamshire WLP consultation document states “there is now only one suitable landfill site within the plan area which is due to close within a year. After this, waste for disposal will have to be sent to sites outside of the plan area unless a new local site can be found”
Over recent years landfill has been reducing in size as more waste is recycled or used as fuel in Energy from Waste facilities. This pattern can be seen across the UK as part of the general drive to divert more recyclable and combustible waste from landfill. The UK has a substantial shortfall of recycling and energy from waste infrastructure, meaning landfill disposal still plays an important waste management role to help the economy function and underpins the waste hierarchy albeit as a last resort.
There are also substantial volumes of residual waste from the economy which are not recyclable or suitable for fuel use and which will always have to be safely disposed of by landfill, along with residues from waste treatment and recycling facilities themselves.
Biffa is one of the main operators of landfill services in the UK. In the last year we handled around 3 million tonnes of waste through our 9 remaining operational landfill sites. Biffa also continue to manage 62 closed landfill sites in the UK.
We would therefore encourage the Council to consider a flexible approach in setting restoration aims for new or existing mineral extraction sites that would seek to consider the landfill of non-inert waste as part of those approved development schemes, and to consider those aims at this early stage whilst considering all of the necessary environmental and amenity obligations.
A ‘Circular Economy’
Whilst the need for Landfill has been identified within the plan area, Biffa support the principles of the Waste Hierarchy, which in addition to the EU Circular Economy Package still recognises the necessary supporting role of landfill as stated above, but not as a first resort for general waste.
As stated in our Reality Gap 2017 publication, all levels of the waste hierarchy serve a vital role and the measure of success is that a particular waste stream is managed in its most appropriate place in that hierarchy depending on its properties and value.
Achieving the overall aim of ‘moving waste up the Waste Hierarchy’ relies on moving away from the traditional linear economy and developing a circular economy. In a circular economy maximum resource efficiency is achieved by keeping products, components and materials at their highest value at all times, using products for as long as possible before recycling into new products to reduce the need to use new natural resources. Only when no further benefit can be recovered from a resource should it be disposed of.
The plan should address waste prevention and re-use, and should consider the key targets set out in the ‘Resource and Waste Strategy for England’ document which highlights a significant increase in recycling targets and a further reduction in Landfill.
• 50% recycling household waste by 2020
• 65% recycling municipal waste by 2035 (in line with EU CE package)
• 10% (or less) municipal waste to landfill by 2035 (in line with EU CE package)
• Eliminate all food waste to landfill by 2030
• All plastic packaging to be recyclable ,reusable or compostable by 2025
• 75% recycling of packaging by 2030
With this in mind, we encourage the council to be flexible in their planning permissions when determining the development of new waste facilities.

New locations – ‘Call For Sites’
Whilst no specific locations have yet been decided within the plan area, it is common for councils to propose areas of existing industrial or employment land in line with Section 4 of the ‘National Planning Policy For Waste’ that states “give priority to the re-use of previously-developed land, sites identified for employment uses, and redundant agricultural and forestry buildings and their curtilages”.

In identifying such land, we urge the Council to take a robust approach to site selection and undertake a full assessment of the options that are presented that also considers the commercial viability of particular sites and consider the following:

• Cost of land remediation;
• Insufficient size (economies of scale);
• Proximity to receptors, particularly in employment areas;
• High cost of purchase/competition
Once more accurate waste tonnages within the plan area have been established, the type of facility will also need to be decided based on the shortfalls identified within the ‘Waste Needs Assessment’.
Safeguarding
New and existing facilities should be safeguarded in line with the NPPF (Para. 182) and objective 5 of the Nottinghamshire – ‘Issues and Options’ document.
Facilities should be safeguarded from encroachment by other development, most particularly, housing. Waste sites are strategic assets and should be protected and offered sufficient flexibility in their operation such that they can continue to provide a vital service.
Aside from the existing safeguarded sites, the plan should rely on criteria based approach so that applicants can be sure that any site they are promoting meets the requirements of the plan.

I trust that our comments are helpful and will be taken into account in moving to the next stage of plan preparation. Should you have any queries then please do not hesitate to contact me.


Yours faithfully