Comment

Representation ID: 22510

Received: 11/10/2021

Respondent: Environment Agency

Chapter 11: Waste

Paragraph 11.3 b): To reflect current thinking we recommend this is reworded to say

‘The expansion of producer responsibility obligations and introduction of deposit return schemes for packaging wastes….’
Paragraph 11.3 d) refers to ‘waste disposal crime’. Waste crime covers a wide range of activities, including failure of waste producers to comply with the Duty of Care regime, tax and compliance evasion, and ‘sham recovery’ activities, as well as flytipping, illegal dumping and warehousing. Please consider not restricting the problem to just ‘Waste Disposal’.

Figure 13: Waste Key Diagram

i) With regards to Safeguarding and ‘Agents of Change’ It is difficult to compare the
‘Areas of Search’ with the proposed housing and growth points identified in the other maps to assess where there may be any risk of incompatible adjacent developments. We would expect to see suitable safeguarded buffer zones or other interventions to avoid amenity complaints.
ii) It is not clear what the date of this drawing is, waste facilities do undergo
constant turnover for various reasons, including the ongoing impacts of
Coronavirus on people, businesses and the economy.
iii) It would also be useful to classify existing waste capacity according to its’ relative
Waste Hierarchy Status, rather than simply the general type of facility. As with the identified Metal Recycling sites, a future Circular Economy transition is likely to require more stream specific processing and recovery facilities, such as for various plastics, glass, cardboard and paper, construction materials, organics, automotive and electrical wastes, possibly items such as furniture, carpets and mattresses, and more specialist waste streams, including clinical wastes and batteries. Processing capacity for residual materials from waste to energy plant, specifically bottom ash and emissions abatement wastes also needs to be provided. Some, but not all of these wastes are listed in Paragraph 11.5. It would be useful for the economy to identify what wastes could contribute most economic value and employment opportunities as well as provide
local resources. Conversion of waste to make fuels and energy that will still result in carbon emissions should be avoided unless there is a really compelling argument.
iv) Assessing the relative age of each waste facility can also be helpful in identifying facilities that may be reaching the end of their lifespan and need replacing, or outdated, high-carbon technologies that are unsustainable for a low-carbon economy. Existing waste facilities, especially on brownfield sites, can also be targeted for other more valuable infrastructure development. Identifying which facilities are providing ‘significant useful and sustainable waste capacity’, compared to operations that may be inappropriately located, only handle
trivial waste amounts or are persistently problematic, such as subject to
community opposition can all be useful in understanding the infrastructure picture, to that more of the ‘right’ waste infrastructure comes forward when needed.

Paragraph 11.10 rightly states that: ‘The transition towards a circular economy, the approach to economic development designed to benefit businesses, society and the environment, is expected to significantly change the way waste will be managed in future. In particular, the quantities of waste reused, recycled, and composted are expected to increase substantially’. However we will also need to significantly minimise and avoid waste and especially non-recyclable waste streams as mentioned in Paragraph 1.11. The more ‘circular’ an economy becomes, the more that recovery and remanufacturing will displace traditional production based on ‘new’ raw materials. A consequence of this is that there will be a need for additional waste recovery facilities in addition to those required for planned ‘growth’. So how fast and ‘substantial’ this
increase will be depends on how quickly both a Circular and Decarbonised Economy can be delivered. Whilst progress has been made, it appears that it has not been at sufficient pace to reduce projected global temperature rise and related environmental impacts, including ‘More extreme weather extremes’, -that will then require further and possibly expensive adaptation measures, such as bigger flood defences.

Regarding Table 8, we observe that achieving 50% recycling rates probably represents the ‘Easy wins’ and that attaining higher rates probably requires other interventions and more effort. Whilst it is not normally considered in spatial Planning, a residents
‘environmental education pack’ could be useful in setting out what is and is not possible in a multilingual format, and could cover multiple socially responsible topics such as
litter and dog mess, burning waste, bulky waste collections, assisted collections, HWRC availability, hazardous, clinical and business waste, prevention of flytipping and reputable skip hire/waste removal services, etc .as well as what can and cannot be recycled. Asking residents not to pay cash, or use social media adverts or cold callers offering ‘cheap’ waste removal would all be useful.

Paragraph 11.21 refers to estimates of Business Waste arisings. You may be able to model sources of Business and Commercial Waste production via reference to the Non- Domestic Rates datasets, -held by Councils, which list all commercial premises, even where these are unoccupied. Given the type of business (e.g. retail, office, engineering, manufacturing, healthcare, entertainment, etc.) and size of premises, a model could be constructed of likely waste arisings for the most common premises, and you will also have some intelligence from Council trade waste services. Tracking new and closing businesses could help to refine this model and show trends such as the impact of the Pandemic on non-domestic waste production.

In Table 9, the row entitled ‘Recovery’ largely implies energy recovery, typically with the continued release of carbon to the atmosphere, albeit with some recovery of materials such as metals and bottom ash. New Waste to Energy facilities usually involve a ‘Lock in’ to ongoing carbon emissions for the life of the Plan and beyond, which will require offsetting or other significant cuts to emissions elsewhere. A ‘front end’ sorting facility should also be considered to ensure that only truly ‘residual’ waste is being burnt. Not sure how far we can challenge here? ??–Please refer to relevant Climate Emergency plans and any other National commitments including the potential for Incineration taxes and if there are any realistic alternatives. Recovery of combustible waste streams such as plastics, wood, paper/card, and food wastes may reduce the calorific value of refuse and make it harder to extract energy from?

Additionally you will appreciate that ‘Waste Transfer’ and HWRC facilities can usefully contribute to the pre-sorting of waste and landfill diversion, but do not offer any ‘end disposal’ capacity themselves, they are more a midpoint in the waste logistics chain.

Clearly the regulatory mechanisms for waste, incentives and taxes may also evolve over time, including measures to deliver a ‘Green Recovery’.