Part One: Spatial Strategy and Policies (Regulation 19)

17.1. This section sets out the needs for waste infrastructure to support growth in the borough, in accordance with National Planning Policy for Waste (NPPW). The key driver is to minimise the amount of waste generated across all sectors and increase the re-use, recycling, and recovery rates of waste material (seeking to achieve net self-sufficiency). The Council will work collaboratively with other Waste Planning Authorities to address the identified waste infrastructure needs.

17.2. This policy sets out the overall strategy and principles for waste management and the types of waste development that will support this. It also identifies how much new waste management capacity is likely to be needed to support planned levels of growth over the plan period.

17.3. The Local Plan policies are focused on the borough's waste requirements and infrastructure, however given the nature of waste management (where waste arising in one area is often managed in another, and facilities will have catchment areas that extend beyond their boundaries) the wider context of the Black Country area (and beyond) is recognised.

Figure 17.1 Spatial Strategy Plan: Waste

17.4. In line with national waste planning guidance, the Plan aims to make provision for the suitable management of waste. Housing and employment land are projected to increase in the borough as the regeneration of the urban area progresses, to help meet strategic housing and employment targets. The needs of new waste infrastructure will need to be balanced with those of housing and employment for suitable development sites.

17.5. In seeking to identify development sites for waste infrastructure, priority shall be given to the safeguarding of existing sites for their continued use and the retention of the local employment areas in which they occur (see Policy DLP76 and Policy DLP20). As waste facilities are an essential part of the infrastructure of an area, it is not only important that they are appropriately located, but also that policy protection is applied to areas suitable for waste uses, to help achieve the objectives of moving waste up the hierarchy.              

17.6. Waste reduction and resource efficiency improvements will have a significant influence on future waste growth. 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.              

17.7. Transitioning towards the circular economy will involve a significant reduction in the amount of waste produced by households and businesses, because avoidable waste will be 'designed out' of products at the manufacturing stage. It will also mean a significant shift away from methods of managing unavoidable waste at the bottom of the 'waste hierarchy' (waste disposal and energy recovery) and towards those at the top of the hierarchy which can 'close the loop' (re-use and recycling). A circular economy and the effective management of waste also has a role to play in helping to address climate change, e.g., the re-use of resources helps reduce the demand for new materials and the emissions associated with producing the latter.

17.8. The Dudley Borough Waste Study (2023) provides an updated baseline on waste arisings, imports and exports. In 2021 Dudley was estimated to generate approximately 470,000 tonnes of waste. Excluding exempt sites, the largest waste stream was estimated to be construction, demolition and excavation (CD&E) waste at over 254,000 tonnes. Just under 127,000 tonnes were collected by the Council from household sources. Commercial and industrial (C&I) waste arisings (including LACW non-household sources) were estimated to be just under 70,000 tonnes and hazardous waste arisings to be over 19,000 tonnes. Other waste stream arisings were just over 400 tonnes, composed primarily of agricultural waste.

17.9. With the exception of exempt sites, over 114,000 tonnes (23.5%) were re-used, recycled or composted, over 182,000 tonnes (37.6%) were subject to recovery or treatment, over 149,000 tonnes (37.6%) (mainly construction and demolition waste) was disposed to landfill, and just over 40,000 tonnes (8.3%) were transferred for management elsewhere.

17.10. Dudley is an importer of waste with facilities within its boundaries (including permitted sites and incinerators) managing 662,000 tonnes in 2021. Of this total the biggest percentage (by tonnage) (24%) was received at Treatment sites, followed by Landfill sites (24%), Metal Recycling Sites (23%), Incinerators (15%) with the remainder managed through Transfer sites (14%).

17.11. Overall, Dudley was estimated to import circa 1,500 tonnes more waste than it exported in 2021, with the vast majority of these imports (85%) arising from within the West Midlands Region. Dudley was a net importer of hazardous waste by approximately 2,000 tonnes and a net exporter of non-hazardous waste by a mere 360 tonnes.

17.12. Despite being a net importer, exports from Dudley amounted to nearly 450,000 tonnes in 2021. Of the 450,000 tonnes of waste received at permitted sites in England and Wales and incinerators in England, outside of Dudley, the biggest percentage (by tonnage) (29%) was received at Landfill sites, followed by Treatment sites (22.5%), Metal Recycling Sites (18.5%), Incinerators (16%), Transfer (10%) and On/In Land sites (4%).             

17.13. The updated waste capacity requirements are based upon the housing and employment growth figures for the borough as set out in the DLP. Under the projections, the quantity of waste Dudley is projected to manage (included imported waste) increases from 1.2 million tonnes (mt) in 2021 to 1.5 mt in 2040/41 equating to an increase of 32% or 1.4% per annum. An ongoing emphasis on waste reduction has seen a 14% reduction in waste per household since 2006/07 and this trend could have a significant influence on future waste growth. However, there are emerging changes in the need for different types of waste management capacity. Exports already reflect a shortage of landfill space; household waste material processing plants and composting facilities and the way waste will be manged in the future is expected to change significantly with transition towards a Circular Economy. In particular, the quantities of waste reused, recycled and composted are expected to increase substantially.

17.14. Three waste management scenarios are presented according to the extent to which the Circular Economy targets for re-use and recycling of C&I and municipal waste over the plan period 2021/22 to 2040/41 are met. Based on the assumption that the 'Circular Economy' recycling targets will either be met (WMS2) or partially met (WMS3), the Dudley Borough Waste Study, 2023 (at Table 3.9) predicts that the following additional waste management capacity will need to be delivered up to 2041 to maintain the Borough's net self-sufficiency:

17.15. This takes account of known future developments or closures of waste management facilities. Total waste management capacity is projected to decrease from 758,000 tonnes in 2021 to 718,000 tonnes in 2041 which is driven by decreasing landfill space with recycling, recovery and transfer capacity not anticipated to change significantly.

17.16. Most of the new capacity requirements identified are expected to be delivered by the waste industry rather than by the Council as the Waste Planning Authority. Delivery will therefore depend on whether new projects are financially viable and attractive to investors. This will in turn depend on demand from waste producers, the effectiveness of government initiatives to incentivise re-use and recycling of waste in preference to energy recovery and disposal to landfill, and the availability of suitable sites within the borough where the new facilities can be built. The Council is looking to provide an additional Household Waste Recycling Centre (HWRC) to the north or centre of the borough to complement its existing Stourbridge HWRC, and a search for a suitable site remains ongoing.

17.17. The Dudley Borough Waste Study identifies that more than 80% of waste imported and exported from Dudley stays within the West Midlands region. Waste flows within the West Midlands emphasises the interdependence that exists between the authorities within this region. It is recognised that ongoing collaboration with relevant local authorities under the Duty to Cooperate will be required to ensure waste capacity requirements that cannot be delivered within the borough are available in other areas, where there are existing import/export relationships established and ongoing (e.g., disposal at landfills).