Nottinghamshire and Nottingham Draft Waste Local Plan January 2022

Comment

Representation ID: 714

Received: 04/04/2022

Respondent: Mick George Ltd

In paragraphs 5.11 & 5.12 the treatment of CD&E waste could be stronger. One of the crucial
differences that could have been further explained is the distinction between CD waste and its
current recycling/recovery target of 70% nationally, and E waste for which there are very few ways
to reuse and recycle/recover. Essentially, the levels of recycling for CD waste are exceptionally high
due to their value as mostly aggregates and reclaimed building materials. E waste is mostly soils. The
better quality soils are often reused as topsoil but demand is limited. For the most part, the subsoils
and mixed materials are only suitable for land reclamation or landfill cover/cell construction. In
terms of its environmental impact, there is little or no difference between landfilling E waste and
land recovery using E waste. Therefore, it is unjustifiable to treat inert landfill in the same way as
landfill for other types of waste. Inert landfill provides as much a benefit in the reclamation of land
as does a formal recovery operation. The only difference is in the classification of the activity for
licensing purposes.
The company has also found that in areas where insufficient inert landfill capacity is provided, there
is pressure for a number of recovery projects of dubious value. However, this has ameliorated in
more recent years by the EA bringing recovery operations into the licensing system.

Comment

Representation ID: 784

Received: 04/04/2022

Respondent: Mick George Ltd

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

Comment

Representation ID: 785

Received: 04/04/2022

Respondent: Mick George Ltd

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

Comment

Representation ID: 786

Received: 04/04/2022

Respondent: Mick George Ltd

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

Comment

Representation ID: 787

Received: 04/04/2022

Respondent: Mick George Ltd

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

Comment

Representation ID: 788

Received: 04/04/2022

Respondent: Mick George Ltd

SP1
We support Strategic Policy SP1: Waste Prevention and Re‐use. We generally support Strategic
Policy SP2 but as set out above, we do not consider that the assessment of disposal capacity for
inert wastes has been assessed realistically. Although we accept that consideration of further capacity rests on a need to demonstrate the extent to which residual waste that cannot be recycled or recovered (part c) we consider that careful attention should be paid to the limitations of inert waste recovery sites as set out above.

Comment

Representation ID: 789

Received: 04/04/2022

Respondent: Mick George Ltd

SP2
We support Strategic Policy SP1: Waste Prevention and Re‐use. We generally support Strategic Policy SP2 but as set out above, we do not consider that the assessment of disposal capacity for inert wastes has been assessed realistically. Although we accept that consideration of further capacity rests on a need to demonstrate the extent to which residual waste that cannot be recycled
or recovered (part c) we consider that careful attention should be paid to the limitations of inert waste recovery sites as set out above.

Comment

Representation ID: 790

Received: 04/04/2022

Respondent: Mick George Ltd

We also support Strategic Policy SP4 in relation to inert waste recovery sites. The constraints on the development of such sites, however, do not appear to reflect the confidence of earlier parts of the plan that recovery will be capable of dealing with the vast majority of waste soils. We are grateful for the acknowledgement in paragraph 7.27 of some priority for the restoration of suitable mineral sites by infilling with waste, even though as the text says, “the majority of former quarries and
colliery sites have now been restored”. We also support the text of paragraphs 7.29‐7.35 dealing with an explanation of the conditions under which inert waste recovery operation will be acceptable.

Comment

Representation ID: 791

Received: 04/04/2022

Respondent: Mick George Ltd

We support Strategic Policy SP5: Climate Change. We also support Strategic Policy SP6: Minimising
the Movement of Waste. We understand the requirements to limit the movement across administrative boundaries unnecessarily. We also support Strategic Policy SP7: Green Belt and Strategic Policy SP8: Safeguarding Waste Management Sites.

Comment

Representation ID: 792

Received: 04/04/2022

Respondent: Mick George Ltd

SP8
We support Strategic Policy SP5: Climate Change. We also support Strategic Policy SP6: Minimising
the Movement of Waste. We understand the requirements to limit the movement across
administrative boundaries unnecessarily. We also support Strategic Policy SP7: Green Belt and
Strategic Policy SP8: Safeguarding Waste Management Sites.