Dear Secretary of State Department/ Michael Gove
Re: Ratcliffe on Soar EfW incinerator – Planning application ES/4154 – Moratorium on incinerators urgently needed.
I am calling on you to action an urgent review on waste management to investigate projected significant over capacity of Energy from Waste (EfW) incineration in England in light of predicted reductions in residual waste expected due to new legislation and waste reduction targets going forward. There should be a moratorium on new incinerators until the review determines if any more incineration capacity will be needed locally or nationally.
Nottinghamshire County Council recently approved the planning application for the Energy from Waste (EfW) incinerator at Ratcliffe on Soar (RonS). It has been referred to you for further scrutiny as it has wider implications than being purely a local issue. Please consider a moratorium on new incinerators because there are far too many incinerators proposed to be built in England. There is a considerable body of evidence showing that, should we reach our recycling targets, there will be significant overcapacity of incineration facilities in England.
Evidence that a waste review is needed
There are constant updates on legislation and recommendations to combat climate change and waste is a prime consideration. In the latest “Consultation on Environmental Targets” published on March 18th 2022 the UK Government announced a target of “halving the waste that ends up at landfill or incineration by 2042”.
Current estimations for residual waste are around 30million tons per annum (mtpa) by 2035 if we continue with current rates (taken from the “Our Waste, Our Resources: A Strategy for England – Evidence Annex p77). Halve this and we will have 15mtpa – possibly slightly more by 2042 due to population growth? Current capacity for incineration including capacity from new incinerators currently under construction (including the one at Shepshed – just one junction down the M1 from Ratcliffe on Soar) is just under 19mtpa. Overcapacity of 4mtpa already, without the many more incinerators at similar stage in the planning process as the RonS incinerator.
We already have enough incinerators to cope with residual waste without building more incinerators so there should be an urgent review of capacity to ensure that lots of money is not wasted on building something that will discourage meeting waste reduction targets that are essential if we are serious about tackling climate change.
Energy from Waste incinerators are not low carbon – incineration of waste typically emits one ton of CO2 for every ton of waste and cannot be considered low carbon. They are also very inefficient energy producers – only around 20% for electricity production. From a carbon emission perspective EfW is possibly as bad as coal, much worse than gas and that is on top of the terrible air pollution problems associated with burning rubbish (asthma, leukaemia etc.).
We should be avoiding incinerating waste as much as possible by reduce, re-use, recycle and with food waste soon to be collected separately for anaerobic digestion (to produce biogas and compost etc.) we should easily achieve our recycling targets of 65% by 2030. Local predictions are that there will be overcapacity of incineration facilities if we reach 65% recycling by 2038 (see Local Waste Needs assessment Jan 2022 from Nottinghamshire County Council Waste Local plan p41). Both locally and nationally there are predictions of overcapacity of EfW incineration facilities.
Wales already has a moratorium on incinerators and has already reached 65% recycling.
To avoid significant overcapacity of incineration facilities in England we need an urgent review of predicted residual waste and the capacity required for incineration facilities going forward. This is essential to avoid both unnecessary expenditure on building incinerators which will no longer be needed and risk of potential legal costs/compensation claims from companies which have invested lots of money to build these facilities only to find they are not now required.
Please call in this planning application as it will contribute to incineration overcapacity if it goes ahead. Please also consider a general moratorium on incinerators until a comprehensive review of waste needs assessment nationally has determined the future capacity required for incineration in England.
Thank you for your attention
Dear Susan Edwards
Thank you for your email of 22 March about the above planning application and national waste management policy.
Nottinghamshire County Council referred the planning application to the Secretary of State under the Town and Country Planning (Consultation) (England) Direction 2009 on 9 March. The Secretary of State is very selective about calling in applications and in this case it was decided that he should not intervene. He was content that the application should be determined by the council. I have enclosed a copy of the decision letter sent to the council on 21 March for your information.
In respect of your comments about waste management policy, as the Department for Environment, Food and Rural Affairs are responsible for this, we will forward your email and ask them to respond to you direct.