Policy W1 – Waste Infrastructure – Future Requirements

Comment

Representation ID: 11493

Received: 04/10/2021

Respondent: Woodsetton Charitable Trust

The proposals are supported.However the recent withdrawl of access of Dudley residents to the Anchor Lane Waste disposal and recycling facility shows that physical provision alo ne will not deliver the plans aims and objectivesunless backed up by the necccessary access arrangements so as to minimise travel.The Anchor Lane facitlity was provided to provide access to all residents in North Dudley and Wolverhampton.

Comment

Representation ID: 16135

Received: 11/10/2021

Respondent: Susan Dowler

Having lived in the Dudley borough for over 60 years having already lost green belt and several hospitals I certainly don’t want to lose anymore.

During and after the pandemic there has been more and more fly tipping in the Dudley borough and surrounding councils which is disappointing.
My questions are
1. What is the cost of clearing all of this rubbish away especially hazardous waste 2. Why hasn’t the council re introduced a twice yearly collected of household rubbish 3. Why couldn’t there be a small charge for this service
4. The hours of the recycling centre have been reduced so this encourages fly tipping can’t they be open longer on an evening.
5. Why can’t we use the centre without an appointment.

Comment

Representation ID: 16557

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

Waste: (BC Plan pg. 296 – 331)
Producing and distributing things we buy consumes fossil fuels and contributes to
increased greenhouse gas emissions. What we discard generates more greenhouse
gas emissions by its being transported away and then processed for example by
incineration. It follows therefore that we must reduce our consumption to reduce
harmful emissions by re-using, repairing and repurposing what we already have.
Dudley reuses, recycles and composts only 38% of its household waste.
Some waste disposal is contracted out in the borough and some waste still
goes to landfill.
Our aim is for Dudley Borough to be a zero-waste area by 2030 where all
waste reused or recycled as part of a circular economy approach. The
official government target for Dudley is 68%. Friends of the Earth’s target
is 100%
The Council should Implement food waste recycling by 2023. This will be a national
requirement. Use food waste according to the food waste hierarchy of prevent,
reuse, recycle and ensure non-recyclable biodegradeable waste is used to make
biogas. A local composting scheme would also be effective and useful for green
management.
Our target for Dudley is to cease sending domestic and industrial waste to landfill
either in the UK or abroad by the Council and or it’s contractors by 2025.
We would like to see Dudley MBC promote reduction of waste at source by installing
water taps in public places to reduce single use plastics. The Council should increase
capacity to recycle a wider range of plastics and other materials. Work with
businesses and services to reduce waste at source and take greater responsibility for
recycling. Promote plastic free status for all community and town centres including
single use vending machines in council facilities such as leisure centres.
The Council needs to work more closely with the local community and conservation
groups to achieve ‘clear water’ by removing dumped waste and single use plastics
from watercourses in the borough.

Support

Representation ID: 17147

Received: 11/10/2021

Respondent: Worcestershire County Council

Waste
We welcome the inclusion of policies relating to ensuring sufficient waste management capacity, particularly policy W1, which includes in part (c) support for proposals where they ensure that “sufficient capacity is located within the Black Country to accommodate the waste capacity requirements during the plan period and reducing the reliance on other authority areas” (emphasis added).
Worcestershire County Council welcomes the recognition that 2% of waste imported into the Black Country is from Worcestershire and welcomes further Duty to Cooperate discussions related to cross-boundary movements of waste.

Comment

Representation ID: 21225

Received: 11/10/2021

Respondent: The West Midlands Resource Technical Advisory Body

Duty to Cooperate
Dudley, Sandwell, Walsall and the City of Wolverhampton comprise the four local authorities (Black Country Authorities (BCAs) that are jointly preparing the BCP and all four authorities of WMRTAB are members of WMRTAB. WMRTAB is pleased to note that these authorities are all active members of WMRTAB with an officer from each of the Councils regularly attending the group’s meeting and contributing to its work. WMRTAB has therefore facilitated discussion between the Black Country authorities and other neighbouring waste planning authorities to assist with meeting its Duty to Cooperate on matters pertaining to the planning for waste management within the Black Country area.

Page 306 of the Plan indicates that a document entitled ‘Black Country Plan - Duty to Co-operate: Waste and Minerals - Strategic Matters (2020)’ exists within the evidence base, however it has not been possible to find this document. Clearly such a document would be helpful in demonstrating how the Black Country authorities have met their Duty to Cooperate responsibilities associated with strategic waste planning. WMRTAB would be happy to consider this document and provide comments were it to be made available at a later date.

Comment

Representation ID: 21226

Received: 11/10/2021

Respondent: The West Midlands Resource Technical Advisory Body

Planning for sufficient waste management capacity
Para 11.18 of the BCP states that the Black Country is a net importer of waste, providing significant capacity for surrounding authorities of around four million tonnes
annually. As a result, as stated in para 11.22, the Black Country is currently achieving net self-sufficiency in its waste management overall. However, ‘capacity gaps’ are
identified over the plan period in relation to waste management capacity and the BCP Page 3 of 9 notes that the following additional capacity will need to be developed between 2018 to 2038 to maintain net self-sufficiency:
a) Re-use/Recycling (non-hazardous municipal waste) – 0.75 to 1.0 million
tonnes per annum (tpa)
b) Reuse/Recycling (inert construction demolition and excavation waste) – 0.75
to 1.0 million tpa
c) Energy Recovery (residual municipal waste) – 1.0 to 1.2 million tpa
Notwithstanding the fact that the maintenance of net self sufficiency does not appear to be an objective within the BCP, WMRTAB consider this to be a sound basis on which to plan for future capacity as this helps ensure that the Black Country is providing for the equivalent of its waste management requirements. Furthermore, for the avoidance of doubt, WMRTAB consider that such an objective should be clearly set out within the BCP.

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.

Comment

Representation ID: 21227

Received: 11/10/2021

Respondent: The West Midlands Resource Technical Advisory Body

It is noted that no land for new waste management facilities has been allocated that might provide certainty that the capacity gaps can be addressed. The BCP explains “To have sufficient confidence to allocate a site, it would need to be actively promoted for waste management use by one or more of the BCAs, other waste planning authorities, a landowner, or a commercial waste operator.” On this basis it is assumed that the BCAs have robust evidence to demonstrate that such bodies have been given adequate opportunity to promote a site and WMRTAB suggest that this should extend beyond passive consultation e.g. landowners specifically invited top promite sites for waste management development.

The requirement for additional waste management capacity is clearly quantified in Table 9 of the BCP and this includes an estimate of the land area required which is shown to be significant. WMRTAB are unclear whether this quantum of capacity will actually be achieved, especially in light of the fact that no land has been specifically allocated, and this suggests some assessment of how such land will become available is required. This assessment should consider whether changes to policy are required which might provide greater encouragement for the development of this
capacity.

Despite the diminishing amount of waste requiring non hazardous landfill, this is still a waste stream that needs to be planned for and WMRTAB notes that there is little consideration of this matter in the BCP. Indeed Table 9 ‘Black Country Waste Capacity Requirements 2018 – 2039’ makes no mention of this matter. A report prepared for WMRTAB on landfill in the West Midlands indicates the following for 2019:

There are five landfill sites for inert, non-hazardous & hazardous waste in the Black Country. At the end of 2019, active inert landfill capacity was estimated at 690,000 (m3), non-hazardous LF capacity estimated at 11,666,401 (m3) and non-hazardous LF capacity with SNRHW cell estimated at 418,953 (m3). Landfill sites have been Page 4 of 9 allocated in Walsall1 which allow a further increase inert landfill capacity of 3,000,000
(m3) in future.

Despite the apparent plentiful supply of non hazardous landfill capacity in the Black Country, WMRTAB consider that the BCP should clearly consider how requirements for non hazardous landfill will met, taking account of any unmet requirements in neighbouring areas. This should consider how imports to non hazardous landfill in the Black Country might increase as landfill capacity elsewhere becomes exhausted.

As a significant net importer of non-hazardous and hazardous waste, it is important that BCP is clear about how the BCAs plan to continue to meet the needs of other areas, in order that they can plan for their needs accordingly.

Comment

Representation ID: 21364

Received: 11/10/2021

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

Policy Wl - Waste Infrastructure - Future Requirements


6.1 Policy W 1 identifies a need for additional waste management capacity to be delivered in order to maintain net self-sufficiency. To achieve this, the capacity for re-use / recycling of non• hazardous municipal waste and inert C&DE waste must be increased.

6.2 The Waste Study 2020 highlights a need for an additional 1.5 mt of recycling capacity to maintain self-sufficiency. Table 9-Black Country Waste Capacity Requirements 2018- 2039 within the BCP states there is a requirement of up to 1 mt and mentions 7-20 facilities with a capacity between
50,000 and 150,000 tonnes per annum. This leaves a lot of uncertainty surrounding the delivery of additional waste capacity and is further undermined by the sites' unknown financial viability and

Comment

Representation ID: 22510

Received: 11/10/2021

Respondent: Environment Agency

Chapter 11: Waste

Paragraph 11.3 b): To reflect current thinking we recommend this is reworded to say

‘The expansion of producer responsibility obligations and introduction of deposit return schemes for packaging wastes….’
Paragraph 11.3 d) refers to ‘waste disposal crime’. Waste crime covers a wide range of activities, including failure of waste producers to comply with the Duty of Care regime, tax and compliance evasion, and ‘sham recovery’ activities, as well as flytipping, illegal dumping and warehousing. Please consider not restricting the problem to just ‘Waste Disposal’.

Figure 13: Waste Key Diagram

i) With regards to Safeguarding and ‘Agents of Change’ It is difficult to compare the
‘Areas of Search’ with the proposed housing and growth points identified in the other maps to assess where there may be any risk of incompatible adjacent developments. We would expect to see suitable safeguarded buffer zones or other interventions to avoid amenity complaints.
ii) It is not clear what the date of this drawing is, waste facilities do undergo
constant turnover for various reasons, including the ongoing impacts of
Coronavirus on people, businesses and the economy.
iii) It would also be useful to classify existing waste capacity according to its’ relative
Waste Hierarchy Status, rather than simply the general type of facility. As with the identified Metal Recycling sites, a future Circular Economy transition is likely to require more stream specific processing and recovery facilities, such as for various plastics, glass, cardboard and paper, construction materials, organics, automotive and electrical wastes, possibly items such as furniture, carpets and mattresses, and more specialist waste streams, including clinical wastes and batteries. Processing capacity for residual materials from waste to energy plant, specifically bottom ash and emissions abatement wastes also needs to be provided. Some, but not all of these wastes are listed in Paragraph 11.5. It would be useful for the economy to identify what wastes could contribute most economic value and employment opportunities as well as provide
local resources. Conversion of waste to make fuels and energy that will still result in carbon emissions should be avoided unless there is a really compelling argument.
iv) Assessing the relative age of each waste facility can also be helpful in identifying facilities that may be reaching the end of their lifespan and need replacing, or outdated, high-carbon technologies that are unsustainable for a low-carbon economy. Existing waste facilities, especially on brownfield sites, can also be targeted for other more valuable infrastructure development. Identifying which facilities are providing ‘significant useful and sustainable waste capacity’, compared to operations that may be inappropriately located, only handle
trivial waste amounts or are persistently problematic, such as subject to
community opposition can all be useful in understanding the infrastructure picture, to that more of the ‘right’ waste infrastructure comes forward when needed.

Paragraph 11.10 rightly states that: ‘The transition towards a circular economy, the approach to economic development designed to benefit businesses, society and the environment, is expected to significantly change the way waste will be managed in future. In particular, the quantities of waste reused, recycled, and composted are expected to increase substantially’. However we will also need to significantly minimise and avoid waste and especially non-recyclable waste streams as mentioned in Paragraph 1.11. The more ‘circular’ an economy becomes, the more that recovery and remanufacturing will displace traditional production based on ‘new’ raw materials. A consequence of this is that there will be a need for additional waste recovery facilities in addition to those required for planned ‘growth’. So how fast and ‘substantial’ this
increase will be depends on how quickly both a Circular and Decarbonised Economy can be delivered. Whilst progress has been made, it appears that it has not been at sufficient pace to reduce projected global temperature rise and related environmental impacts, including ‘More extreme weather extremes’, -that will then require further and possibly expensive adaptation measures, such as bigger flood defences.

Regarding Table 8, we observe that achieving 50% recycling rates probably represents the ‘Easy wins’ and that attaining higher rates probably requires other interventions and more effort. Whilst it is not normally considered in spatial Planning, a residents
‘environmental education pack’ could be useful in setting out what is and is not possible in a multilingual format, and could cover multiple socially responsible topics such as
litter and dog mess, burning waste, bulky waste collections, assisted collections, HWRC availability, hazardous, clinical and business waste, prevention of flytipping and reputable skip hire/waste removal services, etc .as well as what can and cannot be recycled. Asking residents not to pay cash, or use social media adverts or cold callers offering ‘cheap’ waste removal would all be useful.

Paragraph 11.21 refers to estimates of Business Waste arisings. You may be able to model sources of Business and Commercial Waste production via reference to the Non- Domestic Rates datasets, -held by Councils, which list all commercial premises, even where these are unoccupied. Given the type of business (e.g. retail, office, engineering, manufacturing, healthcare, entertainment, etc.) and size of premises, a model could be constructed of likely waste arisings for the most common premises, and you will also have some intelligence from Council trade waste services. Tracking new and closing businesses could help to refine this model and show trends such as the impact of the Pandemic on non-domestic waste production.

In Table 9, the row entitled ‘Recovery’ largely implies energy recovery, typically with the continued release of carbon to the atmosphere, albeit with some recovery of materials such as metals and bottom ash. New Waste to Energy facilities usually involve a ‘Lock in’ to ongoing carbon emissions for the life of the Plan and beyond, which will require offsetting or other significant cuts to emissions elsewhere. A ‘front end’ sorting facility should also be considered to ensure that only truly ‘residual’ waste is being burnt. Not sure how far we can challenge here? ??–Please refer to relevant Climate Emergency plans and any other National commitments including the potential for Incineration taxes and if there are any realistic alternatives. Recovery of combustible waste streams such as plastics, wood, paper/card, and food wastes may reduce the calorific value of refuse and make it harder to extract energy from?

Additionally you will appreciate that ‘Waste Transfer’ and HWRC facilities can usefully contribute to the pre-sorting of waste and landfill diversion, but do not offer any ‘end disposal’ capacity themselves, they are more a midpoint in the waste logistics chain.

Clearly the regulatory mechanisms for waste, incentives and taxes may also evolve over time, including measures to deliver a ‘Green Recovery’.

Comment

Representation ID: 23153

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

We are in general agreement with waste management policies in the plan and welcome point f) in policy W1 relating to the avoidance of adverse impacts on landscape and townscape, health, nature and heritage.

We support the recognition of stage 2 and 3 screening procedures that identify the importance of national and regional designated sites for natural and cultural heritage as important constraints (reference in table 10 site selection screening procedures)

Comment

Representation ID: 23530

Received: 11/10/2021

Respondent: Historic England

We require a separate clause for the protection of the historic environment and to ensure that any planning applications that come forward for waste proposals fully consider the impacts for the historic environment. A separate clause will allow specific wording to be including to protect the significance of heritage assets and assess issues that may affect their setting such as air quality, noise pollution, traffic trip generation etc. We recommend that you consider the advice within Good Practice Advice Note 3 which details the specific considerations for setting.