MP1.19

Object

Representation ID: 99478

Received: 16/12/2022

Respondent: Dr L David Ormerod

Legally compliant? No

Sound? No

Duty to co-operate? No

Glass Recycling as a Silica Sand Substitute A

Glass recycling can potentially contribute to the shortfall of silica sand extraction though it is far from being straight-forward. However, Sibelco have a celebrated history in Belgium of developing a supply chain for the provision of suitable glass cullet. Sibelco UK have not encouraged such a development in the UK and it is not included by N.C.C. in the new Policy MPSS1. Glass recycling would indeed support the presumption of sustainable development. The main issue is to provide a clear glass cullet that is not contaminated. The NMWLP, 2022, and NMWLP Preferred Options, July 2019 do not consider this option.

The issue was discussed at length in a public consultation document ID no.94688, dated 26/10/2019 submitted by CATSS, Campaigners Against Two Silica Sand Sites. A recent British Geology Survey/DEFRA Mineral Planning Fact Sheet entitled, Silica Sand, dated January 2020 is also very relevant. These documents make a compelling case for Norfolk to do more to meet the potential market for recycling selected glass cullet suitable to supplement silica sand extraction.

In 2020, 38.5% of UK glass container manufacture comprised recycled glass. This reduced the demand for raw materials. Every ton of glass cullet saves 1.2 tons of extracted sand. Furthermore, as it takes less energy to melt; every ton of cullet in container glass manufacture saves 580kg of CO2, aiding global warming amelioration. Flat glass manufacture by the float glass process is highly sensitive to impurities and so demolition site glass and most curbside collected glass is particularly difficult to use. Flat glass cullet from downstream fabricator glass wastage in the automobile and double-glazing industries can however be readily substituted. Preparative technologies are continually improving the cullet that can be used.

In several places in the "consultation" record in the document, NMWLP Statement of Consultation, May 2022, the possibility of supplementing the Norfolk silica sand extraction with appropriate glass recycling is raised in order to conserve both resource and landscape. Variations on a standard response is generated, such as that on page 58: "Norfolk already has a well-developed and effective collection process for glass recycling at the kerbside, through Household Waste Recycling Centres, and bring banks. The glass collected through these methods in Norfolk is sent to existing glass recycling facilities located elsewhere in the UK. Silica sand is a necessary ingredient in the remelt feedstock for recycled glass. The NM&WLP contains criteria based policies which would be used to determine planning applications for waste management facilities including glass recycling and other inert waste recycling. The plan does not fail the Sustainability appraisal Report."

While these statements are reasonably correct, they hide the fact that the N.C.C. "well-developed and effective collection process for glass recycling" is very much unsuitable for the supplementation of silica sand extraction. Furthermore, Norfolk's performance in general glass recycling does not hold comparison with European performance, and so the deficits in performance are not being acknowledged. It is true that in some areas of Norfolk, 99% of glass is recycled for general glass reclamation, but the figures are patchy across the County. The total recycling of domestic waste glass was 44.21% in 2021/22, compared with 46.71% in 2016/17 so there appears to be no improving trend. The retention of business glass waste is probably better. These figures have not met the 2015 MRF target for the separate collection of glass. It has to be remembered that glass is essentially inert and that theoretically almost all glass can be recycled in a circular economy with optimal recycling, and the availability of materials recycling and reprocessing facilities.

In the EU, the average closed-loop glass recycling figure is 74%, with 61% in France and 77% in Germany. This includes 90% of bottles in the EU. There has been considerable investment in bottle bank systems, and in public education. Clearly there are substantial technicalities, but these comparative figures have some legitimate force. DEFRA has proposed that by 2030, 83% of glass should be recycled with an 82% remelt target. The biggest losses are occurring at the collection stage where the conventional curbside collections result in unacceptable contamination. Deposit-return schemes elsewhere in the western world have resulted in up to 98% recycling of beverage glass. Universally-available glass and bottle collection facilities are also fundamental. The scaling up of refillable glass packaging schemes too are being promoted.

Glass recycling for silica sand replacement has to be based upon the reclamation of clear glass with minimal contamination. However, a much higher-value glass cullet is required. Although not obligated by the NPPF, it makes eminent sense in a situation where the selection of potential silica sand extraction sites in Norfolk has become increasingly difficult to the extent of N.C.C. now proposing to abandon its main proposals under the NMWLP. 2022, to optimize its recovery of silica sand-worthy recycled glass. This seems to be just another denial of the facts.

Sibelco UK has recently acquired glass processing centres in Peterborough, Sheffield and Motherwell. The company seeks to increase the UK average glass recovery to the European average of 90%, and to improve glass collection away from contamination in domestic waste. Is not the prospect of optimising the substitute replacement of silica sand raw material with good quality colour-sorted cullet of correct composition and low levels of contamination for both glass container and flat glass manufacture an important strategic opportunity for Norfolk in collaboration with Sibelco UK?

Soundness: Not Effective, Not Positively Prepared, Not Consistent with National Policy