Nottinghamshire and Nottingham Draft Waste Local Plan January 2022

Circular economy, para 3.3:

We strongly support the principle of using waste as a resource. The Plan should ensure that all relevant facilities are provided for, including repair, re-use and re-processing.

Waste hierarchy, para 3.6:

We support the principle of the waste hierarchy. But the text in para 3.6 fails to state that government policy requires anaerobic digestion of food waste to be considered higher in the hierarchy than incineration. For example, Defra's guidance on "Food and drink waste hierarchy" (April 2021) describes anaerobic digestion of food waste as recycling, with a higher priority than composting, and places incineration below landspreading. Government support for AD is also made clear in the Resources & Waste Strategy (2018), Waste Management Plan for England (2021), Net Zero Strategy (2021) and consultation on Environment Act targets (2022). Current government policy should be properly taken into account in the Plan.

Recycling scenarios for local authority collected waste, para 5.40, Table 7:

The projected recycling rates for LACW are unacceptable. The Waste Framework Directive target of 65% by 2030 should be the minimum and the plan should aim to provide recycling facilities to at least achieve this, with a higher target at least 70%.

Strategic Objective 1 – Acting on climate Change: (This refers to “avoiding damage to air quality, water or soil” but makes no reference to limiting greenhouse gas emissions.)

Representations on the previous round of consultation “suggested greenhouse gas emissions should be explicitly referenced and this objective should be connected with delivering more innovative waste solutions to meet climate change commitments”. Strategic Objective 1 should explicitly aim to minimise greenhouse gas emissions. It is unacceptable for a Climate Change Objective to not mention greenhouse gases!

Policy SP5 – Climate Change: (As with Strategic Objective 1 the policy makes no reference to greenhouse gas emissions.)

Para 7.47 does say this could include “Minimise greenhouse gas emissions . . .” but this should also be included explicitly in Policy SP5. Any reference to supporting “low carbon energy” should note that incineration of waste typically emits around a tonne of CO2 for every tonne of waste and cannot be considered to be “low carbon”.

Monitoring and Implementation Framework, SP2: Monitoring for Future Waste Management Provision

Tonnage of waste arisings should include data required for monitoring waste composition because this will be important for planning the balance of waste management facilities.

Monitoring and Implementation Framework, SP5: Monitoring for the Climate Change policy

Monitoring should include greenhouse gas emissions, particularly from landfill and incinerators.

Monitoring and Implementation Framework, SP2: Monitoring for Future Waste Management Provision

Tonnage of waste arisings should include data required for monitoring waste composition because this will be important for planning the balance of waste management facilities.

Monitoring and Implementation Framework, SP5: Monitoring for the Climate Change policy

Monitoring should include greenhouse gas emissions, particularly from landfill and incinerators.