Policy W2 – Waste Sites

Support

Representation ID: 18425

Received: 11/10/2021

Respondent: FCC Environment Ltd

Agent: DBA Estates

2. Policy W2; Table 25 - Sandwell Strategic Waste Sites

FCC Environment notes and supports the designation of the ERQ site as a Strategic Waste Site. The continued importation and placing of soils is key to creating development platforms and allowing the site to contribute to meeting housing needs. It is anticipated that approximately 600,000 tonnes of soils will be accepted in 2021.

Support

Representation ID: 21228

Received: 11/10/2021

Respondent: The West Midlands Resource Technical Advisory Body

Waste management development considerations
WMRTAB supports the development considerations set out in Policies W2, W3 & W4 in relation to employment areas, minimising harm to human health and the environment, and other impacts of waste management proposals such as on surrounding buildings, resources and constraints on development. WMRTAB suggest additional clarity could be provided regarding the acceptability of proposals in terms of their impact on road networks.

In particular, WMRTAB supports the approach set out in Policy W2 of protecting existing waste facilities from other development which may impact on their operation. This is an important consideration, especially in an area where there is a need to find suitable land to alleviate other development pressures.

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.

Comment

Representation ID: 22511

Received: 11/10/2021

Respondent: Environment Agency

Policy W2 – Waste Sites

Paragraph 3 is welcomed, although it would be useful to indicate what the word ‘near’ means, -preferably setting a safety margin on top of a minimum buffer zone where required, and requiring appropriate measures under ‘Agents of Change’, including the ongoing maintenance of any requirements. Amenity impacts from waste facilities, including noise, odours and dust can travel some distance in adverse conditions, and climate change should also be anticipated.

Paragraph 11.33 refers to a list of sites in ‘Chapter 13’, there appears to be no Chapter
13 in the contents, is this an error?
Paragraph 11.38 The Environment Agency also works to tackle illegal sites and organised waste crime, and will work with Councils and other partners to disrupt such activities.

Paragraph 11.39 also refers to ‘within a short distance’, and as with the term ‘near’ it is not really clear what this means. Some guidance on these qualifiers would be helpful, and again an additional safety margin, so that developments are not built immediately up to the ‘nuisance boundary’, and allowing potential space for screening to be added, would be useful. These issues do appear to be explored in Paragraph 11.40.

Paragraph 11.53 says that ‘Many waste operations are similar to industrial processes’.
Whilst this can be valid, we have seen a shift over generations away from traditional
‘heavy’ industrial processes (e.g. Mineral extraction and processing, Coal combustion, coke, steel and other smelting and plating, chemicals production, ceramics, wood treatment, textiles, munitions production, animal product processing, other manufacturing, etc.) and more modern regulatory regimes have successfully reduced the impacts of those that remain. However certain waste processes (Landfill, anaerobic digestion, etc.) can still create significant amenity impacts that can be challenging to control, despite best efforts. Public acceptance of what is acceptable has probably also evolved over time, with broad expectation of a ‘right to amenity’ the enjoyment of clean air, open space and access to recreation and wellbeing opportunities. This is important in attracting a skilled workforce into the area to boost the economy.

Comment

Representation ID: 23531

Received: 11/10/2021

Respondent: Historic England

We are unclear at this time whether new waste sites are being proposed within the plan. If so, where are they located and what are the implications for the historic environment and what assessment has been undertaken to assess the harm? We remain concerned about the level of growth in the wider region and how the historic environment will be affected. We are keen to understand what Waste Site Impact Assessments will cover and how they relate to the need for appropriate assessment for the historic environment, where necessary. We request the inclusion of a clause relevant for the historic environment within paragraph 11.40.