Object

Representation ID: 21369

Received: 11/10/2021

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

7. Policy W4 - Locational Considerations for New Waste
Facilities


7.1 Policy W4 sets out a number of locational considerations for all new waste management proposals and requirements for supporting information in relation to waste applications, including applications under Section 73 to vary conditions attached to an existing waste permission.

7.2 The policy seeks to focus new waste facilities in locations which contribute to Spatial Objective

13 and the objectives of Policy WI, including the contribution to be made to landfill diversion and the diversification of the range of facilities available.

7.3 The requirements set out under policy W4 are highly prescriptive and are overly onerous for applicants as set out below but where the conclusion is almost that waste facilities are almost anticipated to be in isolated locations.

7.4 Whilst the policy sets out numerous considerations in terms of the potential impacts of waste operations, no consideration is given to the locational requirements of new waste facilities in relation to the operators, customer base, locations where the source arises and in the case of our client, where the recycled products are then re-used and the wider sustainability impacts of this.

7.5 Our client's current operations at Bott Lane are located centrally to the majority of their customer base, with the benefit of minimising vehicle movements and journey times to access their facility.

7.6 If our client is required to seek alternative premises from those currently in operation at Bott Lane, the prescriptive nature of policy W4 in seeking to locate waste operations within existing local employment areas will severely restrict our client's ability to identify future premises within the Black Country area, with the search for alternative premises already being unsuccessful. This, combined with the already identified shortfall in employment land and a focus of housing provision on previously developed land and existing employment sites will further exasperate our client's ability to relocate within the Black Country area where they have developed a facility which significantly assists with meeting sustainability objectives ..