Policy W3 – Preferred Areas for New Waste Facilities

Support

Representation ID: 21229

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.

Object

Representation ID: 21367

Received: 11/10/2021

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

Preferred Areas for New Waste Facilities

6.4 Policy W3 discusses the preferred areas for new waste sites. The preferred location for these is within Local Employment Areas identified by the BCP. Despite the shortfall, the BCP and Policy W3 fail to allocate specific waste sites. Paragraph 11.54 states:

"It is not proposed to allocate specific sites for waste in the BCP because no new sites likely to be deliverable within the plan period have been identified, apart from sites that already have planning permission (NPPF, 16, 35, Annex 2). 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."

6.5 Our client's site has been actively promoted for waste management through the 2020 Call for

Sites consultation, the Pegasus Grab Hire Ltd's representations are attached at appendix EP2 (see attachment appendix 2). However, it is yet to be allocated for waste use despite also operating as such. The site has instead been allocated for housing, which will further affect the shortfall of recycling facilities.

6.6 The policy fails to identify new sites despite the shortfall of recycling facilities identified through the Waste Study 2020. Furthermore, the policy finds Local Employment Land preferable for waste sites, but the BCP fails to allocate enough land for employment purposes, with a 210-hectare shortfall so cannot be expected to meet all needs from this finite supply. There is significant uncertainty surrounding the delivery of waste sites to meet the waste needs identified within the waste policies.

Comment

Representation ID: 23532

Received: 11/10/2021

Respondent: Historic England

Are there sites proposed for waste facilities or are there only local areas at this stage? What heritage impact assessment has been undertaken to date? It is difficult for Historic England to comment on broad areas and how these may be harmful to the historic environment or appropriate for development.