Comment

Draft Black Country Plan

Representation ID: 22506

Received: 11/10/2021

Respondent: Environment Agency

Representation Summary:

Policy CSP3 – Towns and Neighbourhood Areas and the green belt Neighbourhood
Growth

We suggest that the coordination of the phasing of Neighbourhood Growth Areas and other strategic developments, so that surplus bulk excavation spoil can be managed to offer ‘Mass-neutral’ construction of building platforms, and minimise the need for waste disposal. This would also help avoid stimulating illegal waste activity, especially where this can present a threat to the Green Belt or Amenity/Habitat areas. In the absence of a national Site Waste Management Plan regime, it would be positive to see a requirement for an equivalent system. The Environment Bill is also exploring how to reduce waste from the Construction sector.