Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
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Nottinghamshire and Nottingham Draft Waste Local Plan January 2022
5. Waste Management in the Plan Area
Representation ID: 756
Received: 04/04/2022
Respondent: Uniper UK Limited
Uniper has reviewed the draft Nottinghamshire and Nottingham Waste Local Plan (January 2022) and would like to make this representation regarding the information presented in Section 5 Waste Management in the Plan Area.
We have noted that many of the assumptions used to determine future waste tonnages are based on national target recycling rates (e.g. 65% for municipal solid waste (MSW) by 2035 in England). While the aspiration of these targets is admirable, we believe that they do not represent a likely scenario that takes into account the practical challenges, both techno-economic and behavioural, to increase the levels of recycling. Even countries (e.g. Germany and Wales) with more than 10 years of implementation of ambitious recycling policies, the recycling rates achieved are around 60%. As stated in the draft Waste Local Plan, the plan area’s recycling rate was 39% in 2019, well below the existing target and very far from the 65% target 2038; the required increase will be a significant challenge even with the benefit/addition of separate food waste collection being implemented.
While Section 5 of the Waste Local Plan has clearly selected high recycling scenarios, it is our belief that more moderate recycling rates would better represent realistic outcomes. This is not to say that recycling should not be supported and encouraged. However, if ambitious recycling targets are used to estimate future waste tonnages, and these recycling targets are not achieved, then the need for future waste treatment facilities will be underestimated in the Waste Local Plan. This will have the effect of discouraging the further development of alternative waste treatment facilities, with the consequence of having to export waste out of the plan area, or increase use of landfill, to deal with the shortfall.
We have already observed this problem with the Nottinghamshire and Nottingham Waste Needs Assessment by AECOM, which was used to inform the drafting of Section 5 of the Waste Local Plan. Up to 2038 the preferred scenario in the AECOM report is premised on projecting forward assumptions that no new waste management facilities will be built, local authority waste will reduce per household along a ‘medium trajectory’ and commercial and industrial waste will increase along a medium trajectory throughout the assessment period. Based on this preferred scenario of high recycling rates, it is projected that there would be an oversupply of recovery capacity of 35,378 tonnes per annum (tpa) in 2038. However, the AECOM report also identifies that if recycling was not to increase to a high level as projected, there would be a shortfall of recovery capacity in the area of 212,140 tpa.
We appreciate that the draft Waste Local Plan does acknowledge that estimates of future waste tonnages will be reviewed as part of preparing the next stage of the Plan. We strongly recommend that a more in-depth analysis of future (and, importantly, achievable) recycling levels should be incorporated into the Plan in the next iteration.
Uniper has reviewed the draft Nottinghamshire and Nottingham Waste Local Plan (January 2022) and would like to make this representation regarding the information presented in Section 5 Waste Management in the Plan Area.
We have noted that many of the assumptions used to determine future waste tonnages are based on national target recycling rates (e.g. 65% for municipal solid waste (MSW) by 2035 in England). While the aspiration of these targets is admirable, we believe that they do not represent a likely scenario that takes into account the practical challenges, both techno-economic and behavioural, to increase the levels of recycling. Even countries (e.g. Germany and Wales) with more than 10 years of implementation of ambitious recycling policies, the recycling rates achieved are around 60%. As stated in the draft Waste Local Plan, the plan area’s recycling rate was 39% in 2019, well below the existing target and very far from the 65% target 2038; the required increase will be a significant challenge even with the benefit/addition of separate food waste collection being implemented.
While Section 5 of the Waste Local Plan has clearly selected high recycling scenarios, it is our belief that more moderate recycling rates would better represent realistic outcomes. This is not to say that recycling should not be supported and encouraged. However, if ambitious recycling targets are used to estimate future waste tonnages, and these recycling targets are not achieved, then the need for future waste treatment facilities will be underestimated in the Waste Local Plan. This will have the effect of discouraging the further development of alternative waste treatment facilities, with the consequence of having to export waste out of the plan area, or increase use of landfill, to deal with the shortfall.
We have already observed this problem with the Nottinghamshire and Nottingham Waste Needs Assessment by AECOM, which was used to inform the drafting of Section 5 of the Waste Local Plan. Up to 2038 the preferred scenario in the AECOM report is premised on projecting forward assumptions that no new waste management facilities will be built, local authority waste will reduce per household along a ‘medium trajectory’ and commercial and industrial waste will increase along a medium trajectory throughout the assessment period. Based on this preferred scenario of high recycling rates, it is projected that there would be an oversupply of recovery capacity of 35,378 tonnes per annum (tpa) in 2038. However, the AECOM report also identifies that if recycling was not to increase to a high level as projected, there would be a shortfall of recovery capacity in the area of 212,140 tpa.
We appreciate that the draft Waste Local Plan does acknowledge that estimates of future waste tonnages will be reviewed as part of preparing the next stage of the Plan. We strongly recommend that a more in-depth analysis of future (and, importantly, achievable) recycling levels should be incorporated into the Plan in the next iteration.
