Nottinghamshire and Nottingham Draft Waste Local Plan January 2022

Comment

Representation ID: 735

Received: 01/04/2022

Respondent: Derbyshire County Council

Paragraph 3.37
Regarding the operational capacity, taken as maximum operational throughput from the last 5 years (2015 - 2019), it is acknowledged that the high C&I figure in 2019 might be anomalous (paragraph. 3.37), and that the CD&E figure for 2019 is also at the upper end of the range (paragraph. 3.65). Only using a single year's throughput, particularly as it is acknowledged that at least one figure could be anomalous, may give rise to an inaccurate level of realistically available capacity.
There is a reference in paragraph 4.6 to facilities being still active where they have received waste 'over the 2019 period'. Should 2015 - 2019 be the period for maximum operational throughput? If it is only 2019 there is evidence in the WDI that some facilities don't receive waste, or there are no records, in some years but do so in later years. If it is only for 2019, if the site then receives waste in 2020 it would be missed out of the calculations. With regards to data analysis and the use of the Environment Agency's Waste Data Interrogator, there are now several resources available regarding established best practice which may be useful to refer to. These are set out by the National Waste Technical Advisory Body and are accessible in the East Midlands via the EMRTAB group.
In relation to LACW and C&I, it is forecasted that up to 3.5Mt may need to be landfilled by the end of the Plan period. The draft sets out that landfill in the plan area is effectively exhausted. As this has been established the plan needs to indicate how landfill capacity is therefore to be provided.
If the intention is to use existing landfill capacity outside the plan area to satisfy the need that you identify, in Derbyshire and Derby for example then we would wish for this to be made clear through the Duty to Cooperate. Given the important strategic issues that exist between our adjoining authority areas we would also advise that you go further and come forward with a new Statement of Common Ground to clearly establish and agree such cross-border matters. Given the situation with the availability of landfill provision specifically, this would seem of particular importance.

Comment

Representation ID: 736

Received: 01/04/2022

Respondent: Derbyshire County Council

Paragraph 3.65
Regarding the operational capacity, taken as maximum operational throughput from the last 5 years (2015 - 2019), it is acknowledged that the high C&I figure in 2019 might be anomalous (paragraph. 3.37), and that the CD&E figure for 2019 is also at the upper end of the range (paragraph. 3.65). Only using a single year's throughput, particularly as it is acknowledged that at least one figure could be anomalous, may give rise to an inaccurate level of realistically available capacity.
There is a reference in paragraph 4.6 to facilities being still active where they have received waste 'over the 2019 period'. Should 2015 - 2019 be the period for maximum operational throughput? If it is only 2019 there is evidence in the WDI that some facilities don't receive waste, or there are no records, in some years but do so in later years. If it is only for 2019, if the site then receives waste in 2020 it would be missed out of the calculations. With regards to data analysis and the use of the Environment Agency's Waste Data Interrogator, there are now several resources available regarding established best practice which may be useful to refer to. These are set out by the National Waste Technical Advisory Body and are accessible in the East Midlands via the EMRTAB group.
In relation to LACW and C&I, it is forecasted that up to 3.5Mt may need to be landfilled by the end of the Plan period. The draft sets out that landfill in the plan area is effectively exhausted. As this has been established the plan needs to indicate how landfill capacity is therefore to be provided.
If the intention is to use existing landfill capacity outside the plan area to satisfy the need that you identify, in Derbyshire and Derby for example then we would wish for this to be made clear through the Duty to Cooperate. Given the important strategic issues that exist between our adjoining authority areas we would also advise that you go further and come forward with a new Statement of Common Ground to clearly establish and agree such cross-border matters. Given the situation with the availability of landfill provision specifically, this would seem of particular importance.