Policy W4 – Locational Considerations for New Waste Facilities

Comment

Representation ID: 10593

Received: 19/08/2021

Respondent: Mr Ian Satterthwaite

Municipal waste incinerator combined heat and power plants would be a means of dealing with waste on a local level and providing power for battery powered waste collection vehicles, grid feed and heating for baths, other civic buildings and council housing

Support

Representation ID: 21230

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: 21369

Received: 11/10/2021

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

7. Policy W4 - Locational Considerations for New Waste
Facilities


7.1 Policy W4 sets out a number of locational considerations for all new waste management proposals and requirements for supporting information in relation to waste applications, including applications under Section 73 to vary conditions attached to an existing waste permission.

7.2 The policy seeks to focus new waste facilities in locations which contribute to Spatial Objective

13 and the objectives of Policy WI, including the contribution to be made to landfill diversion and the diversification of the range of facilities available.

7.3 The requirements set out under policy W4 are highly prescriptive and are overly onerous for applicants as set out below but where the conclusion is almost that waste facilities are almost anticipated to be in isolated locations.

7.4 Whilst the policy sets out numerous considerations in terms of the potential impacts of waste operations, no consideration is given to the locational requirements of new waste facilities in relation to the operators, customer base, locations where the source arises and in the case of our client, where the recycled products are then re-used and the wider sustainability impacts of this.

7.5 Our client's current operations at Bott Lane are located centrally to the majority of their customer base, with the benefit of minimising vehicle movements and journey times to access their facility.

7.6 If our client is required to seek alternative premises from those currently in operation at Bott Lane, the prescriptive nature of policy W4 in seeking to locate waste operations within existing local employment areas will severely restrict our client's ability to identify future premises within the Black Country area, with the search for alternative premises already being unsuccessful. This, combined with the already identified shortfall in employment land and a focus of housing provision on previously developed land and existing employment sites will further exasperate our client's ability to relocate within the Black Country area where they have developed a facility which significantly assists with meeting sustainability objectives ..

Comment

Representation ID: 22512

Received: 11/10/2021

Respondent: Environment Agency

Policy W4 - Locational Considerations for New Waste Facilities

Paragraphs 3 and 4 both include the words ‘Should include’ - why is this qualifier necessary, and in what circumstances would such information not be required? In particular the design, operational and Nominal throughput capacity of a waste facility
can be a cause of some discussion, regarding capacity planning, so this information can be valuable. In particular, waste facilities often show distinct seasonality, especially relating to the increase in construction waste production and use of HWRCs over the warmer months.

Paragraph 11.70 also introduces the qualifier of ‘where Feasible’. Inevitably there may be practical restrictions in some circumstances, however an effective (solid, passive,) enclosure significantly reduces amenity impacts at many waste facilities. Please review this and all similar qualifier terms that may occur in the Plan to ensure they are not excluded as being simply ‘too expensive,’ by applicants, or will only be retrofitted ‘if complaints are received’. A high ‘right first time’ standard of environmental protection should be designed in, and retrofitting can often be more expensive and problematic. The insertion of such qualifiers in not uncommon in Plans, may represent genuine efforts to produce a ‘reasonable’ worded plan, but can also undermine the overall robustness and ambition if not carefully used and kept to a minimum where they are only absolutely necessary. Otherwise Paragraphs 11.83 to 11.90 are welcome.

In Monitoring, rather than a simple tracking of changes in Waste Capacity, it would be positive to develop metrics that can reflect the more detailed movement of waste up the Waste Hierarchy, away from Landfill and Incineration and towards a Circular Economy.

Comment

Representation ID: 23094

Received: 11/10/2021

Respondent: Canal & River Trust

We note from policy W3 that Local Employment Areas are identified as the preferred locations for waste management facilities. Many of these Local Employment Areas are located along the canal network of the Black Country and, as such, the development of new facilities has the potential to have a significant impact on the local natural and built environments of the canals. Policy W4 2(d) lists a number of criteria that will be considered for new waste management proposals. However, this list does not fully do justice to the requirements of policies set out elsewhere in the plan. For the avoidance of doubt, policy W4 or the
supporting text should state that waste management proposals will also need to comply with the requirements of relevant policies in other chapters of the plan (including policy ENV7).

Comment

Representation ID: 23533

Received: 11/10/2021

Respondent: Historic England

There is currently no reference to the historic environment within this policy and we consider that it is necessary to include a relevant clause that seeks to protect the significance of heritage assets, including their setting.