Comment

Representation ID: 21227

Received: 11/10/2021

Respondent: The West Midlands Resource Technical Advisory Body

It is noted that no land for new waste management facilities has been allocated that might provide certainty that the capacity gaps can be addressed. The BCP explains “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.” On this basis it is assumed that the BCAs have robust evidence to demonstrate that such bodies have been given adequate opportunity to promote a site and WMRTAB suggest that this should extend beyond passive consultation e.g. landowners specifically invited top promite sites for waste management development.

The requirement for additional waste management capacity is clearly quantified in Table 9 of the BCP and this includes an estimate of the land area required which is shown to be significant. WMRTAB are unclear whether this quantum of capacity will actually be achieved, especially in light of the fact that no land has been specifically allocated, and this suggests some assessment of how such land will become available is required. This assessment should consider whether changes to policy are required which might provide greater encouragement for the development of this
capacity.

Despite the diminishing amount of waste requiring non hazardous landfill, this is still a waste stream that needs to be planned for and WMRTAB notes that there is little consideration of this matter in the BCP. Indeed Table 9 ‘Black Country Waste Capacity Requirements 2018 – 2039’ makes no mention of this matter. A report prepared for WMRTAB on landfill in the West Midlands indicates the following for 2019:

There are five landfill sites for inert, non-hazardous & hazardous waste in the Black Country. At the end of 2019, active inert landfill capacity was estimated at 690,000 (m3), non-hazardous LF capacity estimated at 11,666,401 (m3) and non-hazardous LF capacity with SNRHW cell estimated at 418,953 (m3). Landfill sites have been Page 4 of 9 allocated in Walsall1 which allow a further increase inert landfill capacity of 3,000,000
(m3) in future.

Despite the apparent plentiful supply of non hazardous landfill capacity in the Black Country, WMRTAB consider that the BCP should clearly consider how requirements for non hazardous landfill will met, taking account of any unmet requirements in neighbouring areas. This should consider how imports to non hazardous landfill in the Black Country might increase as landfill capacity elsewhere becomes exhausted.

As a significant net importer of non-hazardous and hazardous waste, it is important that BCP is clear about how the BCAs plan to continue to meet the needs of other areas, in order that they can plan for their needs accordingly.