Comment

Representation ID: 21226

Received: 11/10/2021

Respondent: The West Midlands Resource Technical Advisory Body

Planning for sufficient waste management capacity
Para 11.18 of the BCP states that the Black Country is a net importer of waste, providing significant capacity for surrounding authorities of around four million tonnes
annually. As a result, as stated in para 11.22, the Black Country is currently achieving net self-sufficiency in its waste management overall. However, ‘capacity gaps’ are
identified over the plan period in relation to waste management capacity and the BCP Page 3 of 9 notes that the following additional capacity will need to be developed between 2018 to 2038 to maintain net self-sufficiency:
a) Re-use/Recycling (non-hazardous municipal waste) – 0.75 to 1.0 million
tonnes per annum (tpa)
b) Reuse/Recycling (inert construction demolition and excavation waste) – 0.75
to 1.0 million tpa
c) Energy Recovery (residual municipal waste) – 1.0 to 1.2 million tpa
Notwithstanding the fact that the maintenance of net self sufficiency does not appear to be an objective within the BCP, WMRTAB consider this to be a sound basis on which to plan for future capacity as this helps ensure that the Black Country is providing for the equivalent of its waste management requirements. Furthermore, for the avoidance of doubt, WMRTAB consider that such an objective should be clearly set out within the BCP.

about how the management of waste can contribute to the mitigation of climate change and, in light of national policy (and plan making legislation), suggest that this is an area in need of attention. A review of the policies to ensure they are aligned with this agenda is recommended. Such a review might consider how energy from waste facilities could be required to ensure
that use of heat produced, as well as electricity, is maximised.

Policy CC5 on Flood Risk, identifies waste (and mineral) facilities as the only types of development where all such proposals would require a flood risk assessment and surface water drainage strategy. While proposals for certain types of waste facilities may need such assessment, WMRTAB suggest that the BCAs check whether this blanket approach is justified.