Draft Black Country Plan

Ended on the 11 October 2021
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(8) 11 Waste

Introduction

11.1 The BCA are the Waste Collection, Waste Disposal and Waste Planning Authorities for their respective administrative areas.

11.2 The key driver across the four authorities is to minimise the amount of waste generated across all sectors and increase the re-use, recycling, and recovery rates of waste material.

11.3 The following policy aims are likely to be important for the Black Country going forward:

a) the proposed introduction of a requirement to segregate certain municipal wastes for collection, which implies a need for a review and the revision of collection regimes for local authorities and businesses producing commercial waste;

b) continued focus on measures to encourage waste prevention including, in line with national policy, the introduction of produce responsibility obligations for packaging wastes and reduction of single use plastics; and

c) continued focus on the protection of the environment and human health and tackling waste disposal crime.

Figure 13 - Waste Key Diagram

Figure 13 - Waste Key Diagram

 

Waste Infrastructure – Future Requirements

11.4 This policy sets out the overall strategy and principles for waste management in the Black Country and the types of waste development that will support this. It also identifies how much new waste management capacity the Black Country is likely to need to support planned levels of housing and growth over the plan period, and to help deliver the Strategic Priority of meeting the Black Country's resource and infrastructure needs.
 

(11) Policy W1 – Waste Infrastructure – Future Requirements

  1. Proposals for relevant, major development shall evidence how its operation will minimise waste production, as well as facilitating the re-use and recovery of waste materials including, for example, through recycling, composting and energy from waste.
  2. Proposals for waste management facilities will be supported based upon the following principles;
    1. managing waste through the waste hierarchy in sequential order. Sites for the disposal of waste will only be permitted where it meets a need which cannot be met by treatment higher in the waste hierarchy;
    2. promoting the opportunities for on-site management of waste where it arises and encouraging the co-location of waste developments that can use each other’s waste materials;
    3. ensuring that sufficient capacity is located within the Black Country to accommodate the waste capacity requirements during the plan period and reducing the reliance on other authority areas;
    4. enabling the development of recycling facilities across the Black Country, including civic amenity sites, and ensuring that there is enough capacity and access for the deposit of municipal waste for re-reuse, recycling, and disposal;
    5. waste must be disposed of, or be recovered in, one of the nearest appropriate facilities, by means of the most appropriate methods and technologies, to ensure a high level of protection for the environment and public health;
    6. ensuring new waste management facilities are located and designed to avoid unacceptable adverse impacts on the townscape and landscape, human health and well-being, nature conservation and heritage assets and amenity;
    7. working collaboratively with neighbouring authorities with responsibilities for waste who import waste into, or export waste out of, the Black Country, to ensure a co-operative cross boundary approach to waste management is maintained.

 

Justification

11.5 In line with national waste planning guidance, the Plan will where necessary make provision for the suitable management of non-hazardous waste; Local Authority Collected Waste (LACW) and Commercial and Industrial Waste (C & I); construction, demolition and excavation waste (CD&E); hazardous waste such as asbestos or batteries, low-level radioactive waste, agricultural waste and waste water produced from water treatment.

11.6 Findings in the Black Country Waste Study (2020) show that the waste industry has grown quickly over the past twenty years and makes a significant contribution to the national economy. The past two decades has seen growth of around 55% in employment and incomes in the sector.

11.7 The waste sector is of particular importance to the Black Country, where it makes a far more significant contribution to the economy (0.88% of its jobs) when compared with a national figure of 0.55%. It is expected that this sector's contribution to the Black Country's GVA will grow by nearly 250% by 2030. To deliver these environmental and economic benefits, the Plan will have an important role in providing the land use policy in its support.

11.8 Housing and employment land are projected to increase in the Black Country as the regeneration of the urban area progresses, to help meet strategic housing and employment targets. The needs of new waste infrastructure will be required to be balanced with those of housing and employment for suitable development sites. In seeking to identify development sites for waste infrastructure, priority shall be given to the safeguarding of existing and allocated sites for their continued use and the retention of the local employment areas in which they occur.

11.9 Waste reduction and resource efficiency improvements will have a significant influence on future waste growth. Waste per household decrease from a peak of 1,244 kilograms per household per year (kg/hh/yr) in 2002/03 to 984 kg/hh/yr in 2017 - 18 (a reduction of over 20%). This has been driven by a range of factors, including household income, increased resource efficiency and changes in consumer behaviours. Similar factors are also thought to be driving reductions in C&I waste.

11.10 In addition, 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.

11.11 Transitioning towards the circular economy will involve a significant reduction in the amount of waste produced by households and businesses, because avoidable waste will be 'designed out' of products at the manufacturing stage. It will also mean a significant shift away from methods of managing unavoidable waste at the bottom of the 'waste hierarchy' (waste disposal and energy recovery) and towards those at the top of the hierarchy which can 'close the loop' (re-use and recycling).

11.12 As waste facilities are an essential part of the infrastructure of an area, it is not only important that they are appropriately located, but also that policy protection is applied to areas suitable for waste uses, to help achieve the objectives of moving waste up the hierarchy.

11.13 A different set of assumptions have been applied to the CD&E stream, based on the construction waste targets set under the Waste Framework Directive (2009/98/EC), the management of current CD&E arisings and the likely targets to be set in the future.

11.14 Total waste management capacity in the Black Country is driven by decreasing disposal capacity as existing landfill and other disposal sites run out of void space. The capacities include both internal and external capacity for recycling and transfer, based on exports of waste from the Black Country; the capacities of these site categories are not anticipated to increase or decrease significantly over the plan period.

11.15 To account for likely changes in operational capacity at the waste management sites, internal capacity is based on five-year average (mean) tonnages of 'waste received' at permitted sites and operational incinerators by site category, 2013-2017. Material legislative and collection approach changes have been minimal over this time period, so a five-year average is a more reliable figure than using the longer ten-year average. It should be noted that external capacity is based on 2017 input tonnages of 'waste received' at permitted sites and operational incinerators, by site category.
 

Expected Changes – Waste Management

11.16 The waste projections have also considered a range of waste management scenarios based on the recycling rates that may be achieved, and these are summarised in Table 8 below. The BCWS considers that Waste Management Scenario 2 (WMS2) is the most likely scenario for the Black Country.

11.17 WMS2 (Circular Economy) assumes that the targets for reuse and recycling of municipal waste will be achieved for household and C&I waste over the plan period (i.e. 65% of waste from these streams will be recycled by 2030). A different set of assumptions has been applied to the CD&E waste stream, based on existing CD&E waste management rates in the Black Country and potential future recycling targets suggested in the 'Circular Economy Package' proposals.

Table 8 - Black Country Waste Study – Waste Management Scenarios

Scenarios

Household Waste

C&I Waste

CD&E Waste

Waste Management Scenario (WMS1): no change in recycling performance

No change in household waste recycling

No change in C&I waste recycling

No change in CD&E waste recycling[92]

Waste Management Scenario (WMS2): meet indicative EU Circular Economy targets

65% household waste reuse, recycling and composting by 2030

65% C&I waste reuse recycling and composting by 2030

c.85% CD&E waste recycling or recovery by 2030

Waste Management Scenario 3 (WMS3): progress towards EU Circular Economy targets

55% household waste reuse, recycling and composting by 2030

55% C&I waste reuse, recycling and composting by 2030

c. 80% CD&E waste recycling or recovery by 2030

Source: BCWS, Table 4.7
 

Waste Imports and Exports

11.18 The BCWS waste projections also took into account net waste imports. Around 4.90 million tonnes of waste were received at permitted waste sites (including landfill sites) and operational incinerators in the Black Country in 2017 (BCWS Tables 3.11, 3.15). The total tonnage of waste received in 2017 was exceptionally high compared to previous years and compared to the tonnage received in 2018. Analysis of past trends shows it is more typical for around four million tonnes to be received at Black Country sites annually. If this is compared to the estimated 2.01 million tonnes of waste from the Black Country managed at permitted sites and operational incinerators in 2017, it is clear that the Black Country is a significant net importer of waste.

11.19 More than 80% of the waste received at permitted waste facilities in the Black Country (excluding incinerators) in 2017 by tonnage originated within the former West Midlands region (BCWS Appendix J, Table J4). However, the originating authority of more than half of this waste (56%) is not known. 25% of the waste is recorded as originating from within the Black Country, and 14% from adjacent authority areas (8% from Birmingham, 4% in Staffordshire and 2% from Worcestershire).

11.20 Similarly, more than 80% of the waste received at permitted sites in England which was recorded as having originated in the Black Country in 2017 (by tonnage) did not travel beyond the former West Midlands region, and most of the rest was received at sites in the East Midlands (6%) and South West (7%). Because the precise origin of so much of the waste arising in the West Midlands is not known, more waste is likely to have arisen in the Black Country than is actually recorded.

11.21 The waste figures arising above include an estimate of how much of the waste of unknown origin is likely to have arisen in the Black Country. As much of the waste is C&I waste, the 'apportionment' of this waste has been based on the percentage of business enterprises in the West Midlands that were in the Black Country in 2017 (NOMIS Labour Market Statistics, 'Business Counts').
 

'Capacity Gaps' and Need for New Waste Infrastructure 2018 – 2039

11.22 Based on the assumption that the 'Circular Economy' recycling targets identified in Table 7 above will either be met (WMS2) or partially met (WMS3), the BCWS (Table 4.9) predicts that the following additional waste management capacity will need to be delivered in the Black Country between 2018 and 2038 to maintain net self-sufficiency:

a) Re-use/ Recycling (non-hazardous municipal waste) – 0.75 to 1.0 million tpa
b) Re-use/ Recycling (inert C&DE waste) – 0.75 to 1.0 million tpa[93]
c) Energy Recovery (residual municipal waste) – 1.0 to 1.2 million tpa

(Source - BCWS, 4.5.1 – 4.5.29, Table 4.9)

11.23 Although the BCWS does not identify a need for additional waste transfer capacity, Dudley MBC is looking to provide an additional HWRC to the north or centre of the borough to complement its existing Stourbridge HWRC. Walsall Council is looking to replace its waste transfer station and one of its HWRCs (BCWS, Table 3.17), hence these requirements are identified in the policy. Up to 0.21 million tpa of additional energy recovery capacity would also be required if either of the energy from waste plants (EfWs) in Dudley and Wolverhampton should close.

11.24 The BCWS identifies that the Dunton Environmental soil treatment 'hub' at Horsley Fields in Wolverhampton has an operational capacity of around 40,000 tpa (BCWS, 4.4.11). However, this facility is operating under a temporary permission that ends in September 2020, so there is likely to be a need to replace the capacity lost once it closes, to support the remediation of brownfield sites (BCWS, 4.5.15). The BCWS also identifies that there are permitted/ former mineral working sites in Walsall that may come forward as inert only landfills during the plan period (BCWS, Table 3.13).

11.25 Table 9 below summarises the requirements identified in the policy and what this is likely to mean in terms of the number of new waste sites required, the potential annual throughput capacity per site, and the land take per site, based on examples of facilities of similar type from published sources. Annual monitoring of new waste developments coming forward, and losses in waste capacity, will provide an indicator of progress on meeting the indicative waste capacity targets in the policy.
 

Table 9 - Black Country Waste Capacity Requirements 2018 - 2039

Management Method

Types of Waste

Total Capacity Requirement (tpa)

Operational Throughput Capacity Per Site (tpa)

Number of Facilities / Location

Land Take Per Site

Re-Use and Recycling

Non-hazardous municipal waste

Up to 1,000,000

MRF - Between 100,000 and 250,000

4 - 10

(Black Country)

1.5 – 3.0 hectares

Re-Use and Recycling

Inert CD&E waste

Up to 1,000,000

Between 50,000 and 150,000

7 - 20

(Black Country)

1.0 – 1.5 hectares

Recovery

Residual municipal waste

Up to 1,200,000

EfW - Between 150,000 and 400,000

3 - 8

(Black Country)

2.0 – 3.0 hectares

EfW - Around 100,000

1 – 2

(Dudley and/ or Wolverhampton)[94]

Transfer

Municipal waste

Around 150,000

Around 150,000

1

(Walsall)

1.0 – 2.0 hectares

HWRC

Municipal waste

Around 65,000

Around 25,000

Around 40,000

1 (Dudley)

1 (Walsall)

0.5 - 1.0 hectare

Treatment

Contaminated soil

Around 40,000

Around 40,000

1

(Black Country)

Variable

Inert Landfill

Residual Inert CD&E waste

Not known

Depends on void space available

Subject to demand

(Walsall)

Variable

Source: BCWS Tables 3.17, 4.9 and 5.1, BCWPS 4.6 and Appendix F, Surrey Waste Local Plan - Types of Waste Management Facilities: An Explanation Note (January 2019 v2), Surrey County Council

11.26 Most of the new capacity requirements identified in the policy are expected to be delivered by the waste industry rather than by the BCAs. Delivery will therefore depend on whether new projects are financially viable and attractive to investors. This will in turn depend on demand from waste producers, the effectiveness of government initiatives to incentivise re-use and recycling of waste in preference to energy recovery and disposal to landfill, and the availability of suitable sites within the Black Country where the new facilities can be built (see Policy W3).
 

Evidence

  • Black Country Core Strategy Waste Planning Study (BCWPS) (2008), Atkins
  • Black Country Plan Waste Study (BCWS) (2020), Wood
  • Black Country Plan – Waste Technical Appendix (2020)
  • Black Country Plan - Duty to Co-operate: Waste and Minerals - Strategic Matters (2020)
  • Environment Agency Waste Data Interrogator (WDI) 2007 - 2018
  • Environment Agency Hazardous Waste Interrogator (HWI) 2007 – 2018
  • Defra Local Authority Collected Waste Statistics 2006/07 – 2018/19
  • National Planning Policy for Waste (NPPW) (2014), MHCLG
  • National Planning Practice Guidance (NPPG) – Waste (2015), MHCLG
  • Industrial Strategy: Building a Britain Fit for the Future November 2017), HM Government
  • A Green Future: Our 25 Year Plan to Improve the Environment (January 2018), HM Government
  • Our Waste, Our Resources: A Strategy for England (December 2018), HM Government
  • Environment Bill 2019 – 2021
  • Surrey Waste Local Plan – Types of Waste Management Facilities: An Explanation Note (January 2019 v2), Surrey County Council
     

Delivery

  • UK Government – introduce updated national planning policy and regulations for waste, continue with/ introduce new fiscal and other incentives to encourage more efficient use of waste and resources, e.g. Landfill Tax
  • Waste Industry – develop new waste management infrastructure in locations that are well placed to meet demand from waste producers
  • Investors – support delivery of new/ upgraded waste infrastructure
  • Waste Disposal Authorities – deliver new/ upgraded WTS/ HWRC/ MRF capacity needed to support separate collection of waste glass, metal, paper, card and food from households and increased recycling of these wastes
  • Manufacturers and Retailers - maximise use of re-used and recycled materials in production, reduce and where feasible eliminate difficult to recycle packaging waste
  • BCA Planning Services – determine planning applications for new waste infrastructure and upgrading or expansion of existing waste infrastructure within the prescribed/ agreed target dates
  • Planning Inspectorate (PINS) – determine applications for consent of NSIPs for waste (i.e. energy recovery facilities and hazardous waste treatment/ disposal facilities falling within the thresholds in S104 (3) of Planning Act 2008 (as amended)) where applicable.
     

Issues and Options consultation responses

11.27 Policy W1 will replace the existing BCCS Policy WM1. The Issues & Options Report (2017) recognised that the indicative waste capacity requirement figures in Policy WM1 would need updating but did not identify a need to change the policy approach (Table 1). The rewritten policy has had regard to the representations received and the recommendations of the BCWS.

11.28 There has been no change to the approach set out in existing policy WM1 except for the updating of waste capacity requirements to reflect planned housing and employment growth in the Black Country to 2039 and the associated projected future waste capacity requirements that flow from the planned levels of growth and development.

11.29 As well as updating waste capacity requirements to 2039, the policy approach and general principles have been revised to reflect current national policy and guidance on waste.

11.30 The BCAs agree with the comments received at the Issues and Options stage that the strategy for waste should reflect the significant changes to national policy on waste and in particular, the adoption of the 'Circular Economy' approach. The policy therefore assumes that the Black Country will move towards a more 'circular economy' and that there will be a significant demand for new recycling infrastructure over the plan period to support this.
 

Waste Sites

11.31 This policy seeks to safeguard and retain the capacity of existing waste facilities in order to maintain the existing waste management capacity and address the Strategic Priority of meeting the Black Country's resource and infrastructure needs.
 

(5) Policy W2 – Waste Sites

Protecting Waste Sites

  1. The BCA will safeguard all existing strategic and other waste management facilities from inappropriate development, in order to maintain existing levels of waste management capacity and meet Strategic Objective 13, unless it can be demonstrated that:
    1. there is no longer a need for the facility; and
    2. capacity can be met elsewhere; or
    3. appropriate compensatory provision is made in appropriate locations elsewhere in the Black Country; or
    4. the site is required to facilitate the strategic objectives of the Black Country.
  2. This policy will also apply to all new waste management sites that are implemented within the lifetime of the plan.

    New development near existing waste facilities

     
  3. Proposals for housing and other potentially sensitive uses will not be permitted near to or adjacent to an existing waste management site where there is potential for conflict between the uses,
    1. unless a temporary permission for a waste use has expired, or the waste management use has otherwise ceased, and the site or infrastructure is considered unsuitable for a subsequent waste use;
    2. or redevelopment of the waste site or loss of waste infrastructure would form part of a strategy or scheme that has wider environmental, social and / or economic benefits that outweigh the retention of the site or infrastructure for the waste use and alternative provision is made for the displaced waste use;
    3. or a suitable replacement site or infrastructure has otherwise been identified and permitted.
  4. Waste Site Impact Assessments will be expected to demonstrate that at least one of the above criteria applies. Applications should also identify any ‘legacy’ issues arising from existing or former waste uses, and how these will be addressed through the design of the development and the construction process.

 

Justification

Waste Sites

11.32 The existing pattern of waste management infrastructure is illustrated in the Black Country Waste Study, which shows the location of all known waste management facilities in the Black Country.

11.33 The existing strategic sites are identified on the Waste Diagram and listed in Chapter 13 are the significant waste management facilities operating in the Black Country. They have been identified through a detailed analysis of all known licenced and exempt facilities in each authority area and include waste treatment, waste transfer, waste to energy and landfill facilities.

11.34 The definition of a strategic waste management site is;

a) all facilities that form a vital part of the Black Country's municipal waste management infrastructure, e.g. energy from waste plants, waste transfer facilities and HWRCs, depots;
b) all commercial waste management facilities that fulfil more than one local role, e.g. they are part of a nationwide or regional operation linked to other facilities elsewhere and take in waste from all over the Black Country and / or beyond;
c) all commercial facilities specialising in a particular waste stream or waste management technology, of which there are no others, or very few other of the same type operating elsewhere in the Black Country;
d) all facilities likely to make a significant contribution towards existing waste management capacity;
e) a site with sufficient capacity to recover, treat or dispose of at least 20,000 tonnes of waste per annum;
f) a facility forming part of the UK's network of installations for waste disposal, such as landfill sites;
g) a hazardous waste recovery facility of sufficient size to qualify as a Nationally Significant Infrastructure Project (NSIP).

11.35 The Strategic Waste sites are listed in Chapter 13 of the BCP.
 

Safeguarding Existing and Planned Waste Sites

11.36 The Black Country is expected to see significant housing and employment land growth between now and 2039. However, the need for new housing and employment development has to be balanced against the need to retain the infrastructure needed to support local households, businesses, and the construction industry. This includes the infrastructure that manages the waste they generate. Waste Planning authorities must therefore ensure that the impact of non-waste development on existing and planned waste facilities is acceptable, and "does not prejudice the implementation of the waste hierarchy and/ or the efficient operation of such facilities" (NPPW, para. 8).

11.37 The BCWS therefore recommends a safeguarding policy for existing strategic and other waste sites and preferred industrial areas, identified for the development of new waste infrastructure (BCWS, 5.6.1 – 5.6.5 and 6.2.1). However, it also recognises that the redevelopment of existing or former waste management sites with new housing, employment or other land uses is sometimes justified and the policy reflects this. For example, redevelopment is likely to be acceptable where the waste facility has already closed, or the operator is proposing to close it or relocate the operations to another site.

11.38 Another important material consideration will be whether or not the waste operations are lawful, i.e. whether they have planning permission or a lawful development certificate. For example, if the waste operations are unauthorised and unsuitable for the location, the Council will normally consider taking enforcement action to stop them.
 

Potential Losses of Waste Management Capacity

11.39 When determining applications for non-waste development within a short distance or adjacent an existing waste management facility, regard will be had to any potential adverse impacts the proposed development might have on the future of the site as a location for the continuation of waste management activities. If a development is likely to have an unacceptable impact on the future of the site as a location for waste management, it will be refused.
 

Waste Site Impact Assessments

11.40 Taking on board the BCWS recommendations, the policy requires applications for non-waste development, which could be sensitive to the operation of a waste management site, on or near to an existing or planned waste site to include a Waste Site Impact Assessment. This should:

a) identify the waste site potentially affected;
b) explain the spatial relationship between the application site and the waste site;
c) provide a brief description of the waste site, which should include:

  1. its operational status and any proposed changes;
  2. the facility type;
  3. whether the site is a strategic waste site;
  4. the types of waste managed;
  5. the waste operations permitted on the site.

d) summarise the main effects of the waste operations
e) identify any effects that could be harmful to the health, wellbeing, and amenity of the occupiers of the new development;
f) consider how the occupiers of the new development could be affected;
g) consider how the waste site could be affected by the development;
h) demonstrate how the development complies with the policy and the measures proposed to ensure that the waste site and the proposed development can co-exist without compromising each other.
 

Evidence

  • Black Country Plan Waste Study (BCWS) (2020), Wood
  • Black Country Councils Water Cycle Study: Phase 1 (2020), JBA Associates
  • National Planning Policy for Waste (NPPW) (2014), MHCLG
  • National Planning Practice Guidance (NPPG) – Waste (2015) MHCLG
  • A Green Future: Our 25 Year Plan to Improve the Environment (January 2018), HM Government
  • Our Waste, Our Resources: A Strategy for England (December 2018), HM Government
  • Making Space for Waste: Designing Waste Management in New Developments (June 2010), Association of Directors of Environment, Planning and Transport (ADEPT)
  • The Town and Country Planning (Use Classes) Order 1987 (as amended)
  • Planning Act 2008 (as amended)
  • Environment Bill 2019 – 2021
     

Delivery

  • Local Planning Authority – planning applications
  • Waste Industry – engage positively with developers and the local planning authority on proposals to change the use of existing or planned waste sites and proposals for non-waste development near to existing or planned waste sites
  • Developers – ensure that new developments near to existing or planned waste sites have regard to the potential effects on both developments, ensure that proposals for non-waste development make efficient use of resources and are designed to include sufficient space for secure waste storage, management and collection to meet the needs of the occupiers.
     

Issues and Options consultation responses

11.41 Policy W2 has replaced the previous BCCS Policy WM2. The Issues and Options Report (2017) identified a need for a stronger approach towards safeguarding all waste sites in existing Policy WM2, to reflect concerns expressed by stakeholders about land use conflicts that may arise where non-waste development is proposed near to existing waste sites.

11.42 The BCAs are seeking to no longer promote the change of use of employment land to housing on the scale previously required under the provisions of the BCCS. This is because demand for employment land has been more buoyant than anticipated. The cost of remediation of some employment sites to a standard capable of supporting housing has also been a factor. The significant shortfall in readily available employment land compared to demand identified in the Employment Demand Needs Assessment (EDNA), as part of the BCP evidence base, points to a need to retain as much as possible of the Black Country's remaining employment land to support the local economy and enable local businesses to grow and invest.

11.43 Monitoring shows that no Strategic Waste Sites identified in the BCCS have been lost as a direct result of changes of use to housing. However, the BCWS identifies that housing has encroached into some established employment areas that include existing waste sites, and that there is a continuing need for waste sites to be safeguarded.

11.44 The BCAs therefore agree with the comments received at the Issues and Options stage that housing should not normally be developed near to existing or planned waste sites, to avoid land use conflicts that could be difficult to mitigate against once planning permission is granted. The policy also needs to set out how such conflicts should be managed if housing proposals do come forward near to waste sites.
 

Preferred Areas for New Waste Facilities

11.45 The identification and delivery of new waste management facilities will make a significant contribution towards meeting new capacity requirements set out in W1 and will meet the Strategic Priorities of the Plan.
 

(3) Policy W3 – Preferred Areas for New Waste Facilities

  1. The preferred locations for waste management facilities are the Local Employment Areas shown on the BCP map, Waste Key Diagram and Local Authority Plan Maps.
  2. All proposals for new waste management facilities should demonstrate how they will contribute to Spatial Objective 13 and the strategic objectives of Policy W1, such as the contribution they will make to landfill diversion, delivery of new waste management capacity and diversification of the range of facilities currently available.
  3. All applications for waste development will be expected to comply with the requirements in Policy W4.

 

Justification

11.46 The BCA consider that as the Black Country Plan is a strategic plan, it should continue to focus on safeguarding Strategic Waste Sites, which account for nearly 75% of the Black Country's estimated operational waste management capacity by tonnage, while also giving appropriate protection to other waste sites.

11.47 Waste facilities are an essential part of the infrastructure of an area; hence provision must be made in the BCP to deliver facilities and enable the objectives of moving waste up the hierarchy.

11.48 Certain forms of waste infrastructure are relatively specialised or of strategic scale or are in other ways particularly important in terms of the contribution they make to the overall network. However, and in combination, all facilities can contribute to delivering these objectives.

11.49 National Planning Policy for Waste (NPPW) requires the Waste Management Authorities to identify suitable sites and areas for waste management in Local Plan documents. A number of specific locations have been identified in the Black Country Waste Study 2020, where new waste management facilities could be located.

11.50 When deciding which areas should be allocated waste planning authorities should assess their suitability against a range of criteria;

a) the extent to which the site or area will support the other policies set out in the NPPW;
b) physical and environmental constraints on development, including existing and proposed neighbouring land uses;
c) the capacity of the existing and potential transport infrastructure to support the sustainable movement of waste and products arising from resource recovery, seeking when practicable and beneficial to use modes other than road transport, and;
d) the cumulative impact of existing and proposed waste disposal facilities on the well-being of local community, including any significant adverse impacts on environmental quality, social cohesion and inclusion or economic potential.

11.51 The NPPW advises that when identifying suitable sites and areas for waste, waste planning authorities should consider opportunities for on-site management of waste where it arises. This has been addressed in Policy W1 part 2b.

11.52 The NPPW also recommends looking at a broad range of locations for the development of new waste infrastructure, including industrial sites (particularly where there are opportunities to co-locate waste management facilities together). Priority should be given to the re-use of previously developed land, sites allocated for employment use and redundant agricultural buildings (NPPW, paragraph 4).

11.53 As the strategy towards sustainable waste management involves broadening the range of waste management facilities available in the Black Country it is necessary to identify a range of opportunities that can accommodate different types of operation and technology. Many waste operations are similar to industrial processes and can be accommodated in Local Employment Areas.
 

Identification of Preferred Sites

11.54 It is not proposed to allocate specific sites for waste in the BCP because no new sites likely to be deliverable within the plan period have been identified, apart from sites that already have planning permission (NPPF, 16, 35, Annex 2). To have sufficient confidence to allocate a site, it would need to be actively promoted for waste management use by one or more of the BCAs, other waste planning authorities, a landowner, or a commercial waste operator.
 

Identification of Preferred Areas

11.55 A number of employment areas have been identified in the BCWS as being most suited to the development of new waste recovery, treatment, and transfer infrastructure. These sites were identified through a three-stage screening process followed by an assessment of employment locations and selected sites promoted through the 'call for sites' which fell outside of the excluded areas (BCWS, Chapter 5). The methodology is summarised in Table 10 below.
 

Table 10 - Black Country Potential Areas for Waste – Screening Criteria

Stage

Objectives

Criteria

Stage 1

Identification and mapping of Positive Locational Objectives (preferred locations for waste uses)

Brownfield sites, existing industrial areas, co-location of existing waste facilities, existing infrastructure, within five minutes' drive of motorway junction at peak times, close to strategic highway network/ key route network, potential for rail link

Stage 2

Identification and mapping of Spatial Exclusionary Objectives (constraints that rule out waste development as a matter of policy)

Sites allocated for other uses in adopted plans, surface water bodies, Groundwater SPZ Inner Zone, undefended Flood Zone 3 / 3b, nationally and internationally important sites for nature conservation and cultural heritage

Stage 3

Identification and mapping of Spatial Discretionary Objectives (constraints that may rule out waste development as a matter of policy)

Green Belt, open space, Grade 1, 2, 3a agricultural land, Groundwater SPZ outer zone, undefended Flood Zone 2, locally/ regionally important sites for nature conservation and cultural heritage, areas of NO2 exceedance, Noise Action Plan 'Important Areas,' MSAs

Source: BCWS (2020), 5.2.3 – 5.2.15, Tables 5.1 – 5.4 and Figures 5.1 – 5.3

11.56 Waste site options within the resulting 'refined study area' were then identified in consultation with the BCA. These were then subjected to two further rounds of assessment:

a) Stage 4: Positive Local Factors - using criteria similar to Stage 1 to identify characteristics likely to be attractive to waste operators and to encourage delivery of new waste infrastructure; and
b) Stage 5: Detailed Non-Spatial Assessment – focusing on site constraints, potential land use conflicts and transport/ access constraints likely to be a potential barrier to delivery of new waste infrastructure.

11.57 The results of the assessments are presented in Appendix M of the BCWS and are summarised in Table 5.10 of the main report. The preferred areas identified in the policy are those recommended in the study and are listed in the individual local authority sections of Chapter 13 of the plan. These areas are considered least likely to give rise to land use conflicts, and in several cases, there is already co-location of existing waste facilities to which new sites would contribute.

11.58 While most types of waste facilities are likely to be acceptable in all Local Employment Areas, the list of facilities acceptable on Strategic Employment Areas is much shorter. They will normally be restricted to fully enclosed operations that fall within Use Classes B1 (c) or B2 and are already classified as employment uses, or sui generis operations that would be compatible with a Strategic Employment Area location and would not compromise existing or potential future employment uses falling within Use Classes E(g)(ii), E(g)(iii), B2 or B8 (Policies EMP2 and EMP3).

11.59 Certain waste operations may be acceptable on 'Other Employment' land not identified as strategic or local employment areas for long-term retention in employment land use. However, given the status of these sites and the potential that they will be developed for a non-employment use, the BCA are only likely to grant a temporary permission for waste development in these types of location.

11.60 The policy recognises that some types of waste operation involve the processing of waste in the open air and are therefore unlikely to be suitable on employment sites, for example, the disposal of inert waste onto or into land.
 

Evidence

  • Black Country Plan Waste Study (2020), Wood
  • Black Country Employment Area Review (BEAR) (2020), Black Country Local Authorities
  • National Planning Policy for Waste (NPPW) (2014), MHCLG
  • National Planning Practice Guidance (NPPG) – Waste (2015) MHCLG
  • Dudley Statement of Community Involvement (SCI) (February 2017), Dudley MBC
  • Sandwell Statement of Community Involvement (SCI) (July 2016), Sandwell MBC
  • Walsall Statement of Community Involvement (SCI) (November 2018), Walsall Council
  • Wolverhampton Statement of Community Involvement (SCI) (October 2018), City of Wolverhampton Council
  • Dudley, Sandwell, Walsall, Wolverhampton Authorities' Monitoring Reports
     

Delivery

  • DM, legal and funding mechanisms.
     

Issues and Options consultation responses

11.61 The Issues and Options Report (2017) identified that references to specific sites in Policy WM3 would need to be updated but proposed to maintain the existing policy approach.

11.62 The following Options for the updated policy were considered, having regard to the representations received and the findings of the BCWS:

  1. No change to approach in existing policy WM3.
  2. Identify preferred areas for enclosed waste facilities the Black Country as well as strategic waste infrastructure projects, preferably within employment area.
  3. Identify preferred areas for waste facilities that cannot be expected to locate in employment areas such as facilities requiring an open site.
  4. Move locational guidance for different types of waste facilities in existing policy WM4 into this policy and update it to reflect changes to employment land categories and the waste operations likely to be compatible with each land category.

11.63 Option One was considered a reasonable option because there is a need for more specific guidance for waste operators on the locations where new waste infrastructure is likely to be supported in principle.

11.64 Monitoring has identified several outstanding permissions for new waste infrastructure of a strategic scale, which could make a significant contribution towards the additional capacity requirements identified in Policy W1. It would therefore be appropriate for these existing 'commitments' to be identified in the plan.

11.65 Following a detailed analysis of opportunities and constraints across the Black Country, the BCWS has also identified the employment locations considered to be most suitable for waste development (excluding landfill). The BCAs consider the outcomes of the assessment are robust and that the preferred options for waste development should be identified in the plan.

11.66 This has been updated to reflect the employment land categories proposed in the Plan as a result of the survey work and assessment undertaken through the Black Country Employment Area Review (BEAR).
 

Locational Considerations for New Waste Facilities

11.67 Steering waste management facilities towards the most suitable locations where they are likely to generate maximum benefits in terms of co-location, provide supporting infrastructure for other uses and minimise potential harmful effects on the environment and local communities will support the Strategic Priorities of the Plan.
 

(6) Policy W4 – Locational Considerations for New Waste Facilities

Key Locational Considerations for All Waste Management Proposals

  1. Proposals should demonstrate how they will contribute to Spatial Objective 13 and the strategic objectives of Policy W1, such as the contribution they will make towards landfill diversion, delivery of new waste management capacity and diversification of the range of facilities currently available.
  2. Development for new build waste management facilities should be focused in local employment areas and will be required to meet the following criteria:
    1. evidence the need for the facility;
    2. all waste processes and operations must be contained, processed and managed within buildings unless there are acceptable operational reasons why these processes cannot be contained in buildings;
    3. proposals must accord with all other policies in relation to the protection of the environment and public amenity, or demonstrate that other material considerations outweigh any policy conflicts;
    4. consideration will be given to the potential impacts of waste management proposals on;
    1. minimising adverse visual impacts;
    2. potential detrimental effects on the environment and public health;
    3. generation of odours, litter, light, dust, and other infestation;
    4. noise, excessive traffic and vibration;
    5. risk of serious fires through combustion of accumulated wastes;
    6. harm to water quality and resources and flood risk management;
    7. land instability;
    8. land use conflict; proposals should demonstrate compatibility with the uses already present within / adjacent to the area;
    9. where necessary mitigation measures should be identified to reduce any adverse effects to an acceptable level.
    10. whether the proposal would provide opportunities for co-location of related uses and / or generate other benefits (for example; produce a range of waste types or streams, produce high quality aggregates or other useful raw materials, or supply heat and power or other forms of energy to adjacent uses).

Waste Applications – Supporting Information

  1. Planning applications for waste development (Note 1) should include a supporting statement that clearly describes the key characteristics of the development. It should also explain how the development aligns with Spatial Objective 13 and the General Principles and Preferred Methods of managing waste in Policy W1. In particular, the application should explain the contribution the development would make towards driving waste up the waste hierarchy, supporting the development of a more circular economy, meeting the Black Country’s additional waste capacity requirements, and broadening the range of waste facilities currently available in the plan area.
  1. The following information should also be included in the supporting statement and / or on the planning application form:
    1. the type of waste facility or facilities proposed;
    2. the waste streams and types of waste to be managed;
    3. the types of operation to be carried out on the site;
    4. whether waste would be sourced locally, regionally or nationally;
    5. the maximum operational throughput in tonnes per annum;
    6. for waste disposal, the total void space to be infilled in cubic metres;
    7. the outputs from the operations, including waste residues;
    8. the expected fate and destination of the outputs;
    9. the number of associated vehicular movements;
    10. the number of jobs created.
Notes:
(1)    This includes applications for new build waste developments, changes of use to waste developments, applications for new operational development and other material changes to existing waste sites, and ‘s73’ applications to vary a condition attached to an existing waste permission. For definitions of ‘waste development’ and ‘waste’ see the Policy Justification.

 

Justification

11.68 National policy guidance requires the BCA to identify suitable sites and areas for waste management in development plan documents. When deciding which sites should be allocated, their suitability should be assessed against a range of criteria, including physical and environmental constraints, cumulative impacts, and transport effects.

11.69 A number of specific sites and locations suitable for the development of new waste management facilities have been identified in Policy W3 and on the Local Plan Policies Map. The Black Country Waste Study has been undertaken to review the existing operating capacity of waste infrastructure across the Black Country and to assess future requirements over the Plan period.

11.70 There are a number of spatial issues common to all waste management proposals that should be addressed in all cases. The relationship of a proposal to the strategy for waste, as set out in Spatial Objective 13 and Policy W1, is of paramount importance and all proposals should demonstrate how they will contribute towards this. They should also address other locational issues such a proximity to the source of waste, relationships to adjoining / neighbouring uses, visual impacts and other potential effects on the surrounding area. Potentially harmful environmental / amenity impacts will be minimised where operations are contained within a building or enclosure, so facilities should always be enclosed where feasible.

11.71 As the strategy towards sustainable waste management involves broadening the range of waste management facilities available in the Black Country, it is necessary to identify a range of opportunities that can accommodate different types of operation and technology.

11.72 Many of the waste management facilities have operations that are similar to industrial processes and therefore may be located in retained employment areas. Operators seeking a location for new waste management facilities should be focusing their search on areas to be retained as employment land and should avoid those areas proposed to change to housing. The Waste Study identifies a number of areas across the Black Country that are considered suitable for locating new waste management facilities.

11.73 There are certain types of waste management facilities that require an open site and will therefore be difficult to accommodate within the urban areas of the Black Country due to the lack of suitable sites (e.g. open window composting facilities). These types of facility are subject to strict regulation by the Environment Agency and must be located at least 250m away from sensitive receptors.

11.74 The last part of the policy sets out the criteria against which new waste management proposals will be assessed.
 

Waste Applications – Supporting Information

11.75 All waste applications should be accompanied by a supporting statement which provides a general description of the development. There are a number of other issues common to all waste developments that should also be addressed in all cases. For example, the relationship of the proposal to the strategy for waste and resources as set out in Spatial Objective 13 and in the General Principles and Preferred Methods of managing waste in Policy W1 is of paramount importance, and all applications should explain how the proposed development is aligned with these principles.

11.76 Applicants will be required to provide a certain amount of information about their proposed development on the planning application form, including information about the waste streams to be managed and the maximum annual throughput in tonnes and/ or void space in cubic metres. However, as the space available on the form is limited, a more comprehensive description of the proposed waste operations should be provided in the main supporting statement.

11.77 To assist applicants, the policy sets out the key pieces of information they should provide to enable the Local Planning Authority to understand the types of operation proposed and the potential effects of the development on the environment and on the health, wellbeing and amenity of people living or working near the site. This information should be collated together into the summary included in the supporting statement.

11.78 The most appropriate place to set out, describe in detail and assess such a proposal against relevant planning policies is within a Planning Statement. In addition, if the development is 'EIA development' (meaning it requires an Environmental Impact Assessment), as Schedule 1 or 2 development, details should be included in an Environmental Statement (ES).
 

Evidence

  • Black Country Plan Waste Study (2020), Wood
  • Black Country Employment Area Review (BEAR) (2020), Black Country Local Authorities
  • National Planning Policy for Waste (NPPW) (2014), MHCLG
  • National Planning Practice Guidance (NPPG) – Waste (2015), MHCLG
  • Guidance on the Legal Definition of Waste and its Application (August 2012, Part 2 updated 2016), Defra
  • European Council Directive 2008/97/EC (Waste Framework Directive) (as amended)
  • The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (EIA Regulations), SI 2017 No. 571 (as amended)
  • Town and Country Planning (Development Management) (Procedure) Order 2015 (as amended) (DMPO), SI 2015 No. 595
  • Environmental Handbook for the Fire and Rescue Service (2015), Environment Agency and MHCLG
  • Reducing Fire Risk at Waste Sites (2017), Waste Industry Safety and Health (WISH) Forum
  • National Operational Guidance (NOG): Fires in Waste Sites (online guidance), UK Fire and Rescue Service
     

Delivery

  • Delivery of new facilities in accordance with the policy will primarily be through Site Allocations DPDs, Area Action Plans, other area regeneration frameworks and planning applications. Whereas municipal waste facilities will be driven by the needs of the WDAs, which may be identified through MWMs or other mechanisms. Commercial facilities will be borough forward as and when the market allows, in some cases through the Local Plan as site allocations and other through planning applications. Compliance with the locational criteria will be through an assessment of planning applications and pre-application discussions with waste operators.
  • Waste Operators – seek pre-application advice from WPA Development Management Team before submitting planning applications for new waste infrastructure projects, ensure that applications address policy requirements before they are submitted.
  • Environment Agency, Council Pollution Control and Public Health Teams – provide appropriate advice to waste operators and WPA Development Management Teams on the potential environmental and health effects of proposed waste developments at pre-application and application stage.
  • Local Planning Authorities – engage positively with waste operators when pre-application advice is sought, check that waste applications include all the information required in the policy as part of the validation process, request any missing information from applicants where necessary, assess compliance with policy when evaluating waste applications.
     

Issues and Options consultation responses

11.79 Policy W4 is intended to replace that part of the existing BCCS Policy WM4 dealing with the general requirements for new waste applications. The Issues and Options Report (2017) identified that the existing policy has been successful in raising the quality of new waste facilities and did not identify any need for change.

11.80 The following Options for the policy were considered, having regard to the representations received and the findings of the BCWS:

  1. No change to requirements in existing policy WM4.
  2. Move locational guidance for different types of waste facilities in existing policy WM4 into new Policy W4, and update remainder of policy to reflect current guidance on the potential environmental effects of waste development.

11.81 Option One was considered the best option because the locational guidance had been successful in the existing Core Strategy.
 

Resource Management and New Development

11.82 Managing material resources – including waste - in a responsible way is an important element of sustainable development and will support Spatial Objective 13 of the Plan.
 

(2) Policy W5 – Resource Management and New Development

Waste Management in new developments

  1. All new developments should;
    1. address waste as a resource;
    2. minimise waste as far as possible;
    3. design sites with resource and waste management in mind;
    4. manage unavoidable waste in a sustainable and responsible manner; and
    5. maximise use of materials with low environmental impacts.
  2. Where a proposal includes uses likely to generate significant amounts of waste, these should be managed either on-site or in as close a proximity as possible to the source of the waste.
  3. Resource and waste management requirements should be reflected in the design and layout of new development schemes. Wherever possible building, engineering and landscaping projects should use alternatives to primary aggregates, such as secondary and recycled materials, renewable and locally sourced products and materials with low environmental impacts. Consideration should also be given to how waste will be managed within the development once it is in use.
  4. Where redevelopment of existing buildings or structures and / or remediation of derelict land is proposed, construction, demolition and excavation wastes (CD&EW) should be managed on-site where feasible and as much material as possible should be recovered and re-used for engineering or building either on-site or elsewhere.

 

Justification

11.83 The management of material resources including 'waste' in a responsible way is an important element of sustainable development. This policy sets out general principles on waste management and resource efficiency to be addressed by new developments, including requirements to manage large amounts of waste on site or nearby, recycle and re-use products as far as possible.

11.84 The "waste hierarchy" ranks waste management options according to what is best for the environment.It gives top priority to preventing waste arising in the first place. When waste is created, it gives priority to preparing it for re-use, then recycling, then recovery, and last of all disposal (e.g. landfill).

11.85 Achieving zero waste growth and driving waste up the "waste hierarchy" are important objectives of national policy guidance and the strategy for waste management in the Black Country. Delivering on site-waste management of waste and making better use of waste generated through development are critical to the delivery of these objectives.

11.86 The scale of development across the Back Country presents a major opportunity to influence decisions over how resources are managed and to develop a more integrated and holistic approach towards this at a local level. This policy sets out the minimum requirements for planning applications for all developments to demonstrate how they have addressed waste and resource issues.

11.87 Residential developments should include adequate storage for recyclable and non-recyclable waste pending collection, including storage for recyclable wastes and access for waste collection vehicles. As the Black Country is not a single Waste Authority, applicants for housing development should therefore liaise with the relevant Waste Disposal Authority at the earliest opportunity to check requirements for the storage of recyclable and non-recyclable waste, and to understand requirements for waste collection vehicles.

11.88 The resources and waste management requirements of businesses will be an important consideration in development projects to improve employment areas, town, and district centres. Where feasible, regeneration schemes should include provision for on-site waste management.

11.89 Where organisations are generating significant amounts of a particular type of waste, which is not currently managed in the Black Country, consideration should be given towards waste being disposed of or being recovered at the nearest appropriate facility(s).

11.90 Opportunities for symbiosis – matching waste producers with organisations who might have a use for the waste produced - should be explored.
 

Evidence

  • Black Country Plan Waste Study (BCWS) (2020), Wood
  • Black Country Councils Water Cycle Study: Phase 1 (2020), JBA Associates
  • National Planning Policy for Waste (NPPW) (2014), MHCLG
  • National Planning Practice Guidance (NPPG) – Waste (2015) MHCLG
  • A Green Future: Our 25 Year Plan to Improve the Environment (January 2018), HM Government
  • Our Waste, Our Resources: A Strategy for England (December 2018), HM Government
  • Making Space for Waste: Designing Waste Management in New Developments (June 2010), Association of Directors of Environment, Planning and Transport (ADEPT)
  • The Town and Country Planning (Use Classes) Order 1987 (as amended)
  • Planning Act 2008 (as amended)
  • Environment Bill 2019 – 2021
  • Dudley MBC website – online planning application search
  • Dudley MBC website – Bins and Recycling (accessed April 2020)
  • Sandwell MBC website – online planning application search
  • Sandwell MBC website – Bins and Recycling (accessed April 2020)
  • Walsall Council website – online planning application search
  • Walsall Council website – Bins (accessed April 2020)
  • City of Wolverhampton Council website – online planning application search
  • City of Wolverhampton Council website – Waste and Recycling (accessed April 2020)
  • Environment Agency Public Register
     

Delivery

  • Waste Industry – engage positively with developers and the local planning authority on proposals to change the use of existing or planned waste sites and proposals for non-waste development near to existing or planned waste sites
  • Developers – ensure that new developments near to existing or planned waste sites have regard to the potential effects on both developments, ensure that proposals for non-waste development make efficient use of resources and are designed to include sufficient space for secure waste storage, management and collection to meet the needs of the occupiers
  • Waste Collection Authorities – provide advice to developers and the local planning authority on the waste bins and storage space required in residential developments
  • Local Planning Authorities – planning applications
  • Indicator and Target.
     

Issues and Options consultation responses

11.91 The existing policy WM5 is supported in its approach of aiming to reduce waste and deal with waste within the sub-region as close to where it arises as is practical.
 

Monitoring

Policy

Indicator

Target

W1

% of LACW recycled / recovered per annum

(DeFRA LACW Statistics)

50% of municipal waste to be recycled by 2020

55% of municipal waste to be recycled by 2025

60% of municipal waste to be recycled by 2030

65% of municipal waste to be recycled by 2035

New waste recycling, recovery and transfer capacity (tonnes per annum)

New landfill capacity (cubic metres / tonnes)

Waste capacity lost (tonnes per annum)

(BCA Annual Monitoring)

Waste received annually (tonnes) at permitted sites and operational incinerators by site category

(Environment Agency waste data - interrogator and operational incinerators data, which is published separately in an Excel workbook by the Environment Agency / DeFRA)

As specified in Policy W1 d) – l) and Table

W2

Number of planning applications for housing development near to a Strategic Waste Site / % of proposals compliant with policy

(BCA Annual Monitoring)

100% of housing developments near to a Strategic Waste Site to include effective measures to manage land use conflicts

Number of planning applications for new housing development per annum / % of proposals compliant with policy

(BCA Annual Monitoring)

100% of new housing developments to include sufficient household waste storage areas

W3

Implementation of permissions on preferred sites

100% of preferred sites delivered

Total number of planning applications for waste development approved, number of applications approved within the preferred areas or other retained employment areas

100% of planning permissions for waste development (excluding landfill sites) to be in preferred areas or other retained employment areas

Net change in waste capacity – significant losses in capacity / significant gains from development of new infrastructure

(BCA Annual Monitoring)

100% of indicative waste capacity requirements in Policy W1 delivered

W4

Total number of planning applications for waste development submitted, number of applications held in abeyance / invalid

(BCA Annual Monitoring)

100% of waste applications include information required by the policy

W5

Total number of planning applications

100% of waste applications include information required by the policy

 

 

[92] It is estimated that the recycling and recovery rate achieved for CD&E waste in the Black Country in 2017 was around 33% (see BCWS, Table 3.10). This suggests that the Black Country is currently not meeting the existing Waste Framework Directive (2009/98/EC) target to recycle or recover 70% of non-hazardous C&D waste by 2020. The likely reasons for this are identified above.

[93] As no breakdown is provided in the BCWS, the BCAs have assumed that around half of the total Re-use/ Recycling requirement of between 1.5 and 1.9 million tpa will be for non-hazardous household/ similar C&I waste (e.g. glass, metal cans, plastics, card and paper), and around half for inert C&DE waste. This is on the basis that nearly half of the existing Treatment - Recycling capacity at permitted sites in the Black Country is predominantly for recycling of inert C&DE waste (BCWS, Table 3.16, 4.5.8). It is not envisaged that any composting or anaerobic digestion (AD) facilities will be developed in the Black Country due to the difficulty of providing sufficient distance separation from 'sensitive receptors.'

[94] May be required to replace capacity lost if either or both of the EfWs is decommissioned once the existing waste contracts end.

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