Comment

Representation ID: 21365

Received: 11/10/2021

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

Protecting waste sites

6.3 There is a clear shortfall identified in the Waste Study 2020, which is expected to increase with the development of housing over the lifetime of the BCP. Policy W2, which is further discussed in Section 9, fails to protect existing sites which could further affect the shortfall of recycling sites. The Policy aims to safeguard all existing strategic and other waste management facilities, however the BCP contradicts this through allocating a sustainable recycling site for housing, despite the shortfall.

Waste sites

9 .20 Policy W2 of the plan relates to waste sites, the safeguarding and proposals for housing on such sites.

9.21 The Waste Study 2020 found that the Black Country is currently short of recycling sites. Housing and employment growth is predicated to increase over the plan period which will further increase the shortfall, therefore more recycling sites are required to address the need.

9 .22 The site has temporary permission for the current use; however, this permission has not expired and the site can continue to operate as existing until September 2026. This use is not expected to cease before the expiry of the permission and as previously mentioned, our client would seek to make this use of the site permanent as the efforts to date to find alternate premises within their geographical area of operation has come to naught and with little prospect of alternate suitable sites becoming available, especially given the allocation of employment sites for housing land.

9 .23 Although the site is allocated for housing within one of the Core Regeneration Areas, the economic benefits of the continued use of the site for recycling and assisting with meeting sustainability objectives is considered to be a significant consideration.

9.24 The BCP has also not identified any other potentially suitable sites for the business to relocate to.

Our client has also looked at potential relocation sites, however none are available.


9.25 Policy W2 states that proposals for housing will not be permitted unless certain criteria are met, which are addressed as follows:

• The site has temporary permission, however the site and infrastructure are considered to be suitable for the continued use as a recycling site.

• The likelihood of the site being delivered for housing is unlikely and the regeneration area proposals are not considered to be sound. The benefits of delivering housing on the site do not outweigh those provided if the site were to remain as a waste site.
• No suitable replacement site or infrastructure has been identified or permitted through the
BCP as discussed in Section 5.

9 .26 The existing recycling facilities located at Bott Lane are unique within the Black Country area, and are highly efficient enabling 100% diversion of inert waste from landfill and the recycling of materials to provide high quality aggregates. Our client's operations make a significant positive contribution in meeting targets for the recycling of materials and moving waste up the waste management hierarchy, but also significantly reducing the need for the quarrying of virgin materials.

9 .27 Overall, the proposed use for housing would lead to a loss of a recycling site which the BPC has an identified need for, therefore the allocation cannot be justified.

10.4 The permanent use of the site for recycling of aggregate material would address the growing need for such facilities and conform with Policy W2.