Comment

Draft Black Country Plan

Representation ID: 21231

Received: 11/10/2021

Respondent: The West Midlands Resource Technical Advisory Body

Representation Summary:

WMRTAB notes that that no explicit mention is made 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.