Comment

Representation ID: 22504

Received: 11/10/2021

Respondent: Environment Agency

Chapter 2 : The Black Country 2039: Spatial Vision, Strategic Objectives and
Strategic Priorities

The Vision of ‘Creating a prosperous, stronger and sustainable Black Country’ implies an area that is environmentally and economically resilient, not only adapted to Climate Change impacts, but that is robust to other events such as the Coronavirus Pandemic. A Circular Economy, that minimises residual waste, and maximises the economic potential of waste, should result in reduced carbon impacts and increased economic gains, by retaining resources where they can be recovered and put back into positive use, such as in manufacturing or organics in farming. A Circular Economy can support all the 8 Objectives, where waste becomes less of a ‘problem’ and more of a positive
opportunity. This point is perhaps not made as clearly as it could be in Strategic Priority
13. Additionally avoiding sending waste to landfill should not imply the alternative of burning it, as this causes carbon emissions.

Strategic Priority 2 also refers to maximising the use of low carbon energy solutions.
We need to identify ‘low carbon’ options for managing waste, including replacements for traditional Waste to Energy facilities, or possibly their modification to capture and utilise carbon.
The Duty to Cooperate also applies to Waste Management Planning, not just Housing and Employment. As in our letter of 8 September, 2017, we need to ensure that there is no conflict between adjacent developments, specifically residential areas and industrial/waste activities. Strategy 6 says: ‘To provide a built and natural environment that protects health and wellbeing through minimising pollution (air, noise and other forms), providing healthy homes…’ Therefore we need sufficient safeguarding for existing and new waste activities, with application of the NPPF ‘Agents of Change’ provision in the Plan, and with recognition that excessive housing encroachment near waste and other activities can impact negatively on resident’s amenities and wellbeing, including deprived and disadvantaged areas. Additionally, expansion in housing also means an increase in waste volumes produced, with consequent demand for more waste handling capacity, and waste transport can also contribute to both poor air quality in communities and wider carbon emissions, so we need to reduce ‘waste miles’, which requires more and/or larger local facilities for waste.

In short, waste can play a big role in delivering multiple solutions, -if we change how it is both viewed and treated. This probably requires a more integrated approach to infrastructure than has previously been considered, with waste often being dealt with as a largely separate planning issue.

Figure 2, (the Key Spatial Diagram), does not specifically show any existing or planned strategic waste capacity in the context of other proposed infrastructure and this should be rectified.