Object

Representation ID: 425

Received: 21/12/2023

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

DLP78 Locational Considerations for New Waste Facilities

3.20 The requirements set out under policy DLP78 are highly prescriptive and are overly onerous for applicants
as set out below but where the conclusion suggests that waste facilities are almost anticipated to be in
isolated locations.

3.21 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.

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

Comment

Representation ID: 615

Received: 18/01/2024

Respondent: Environment Agency

The policy needs strengthening. Under Section 3 ‘Waste applications – supporting information’ the word ‘should’ be used. See submission for suggested wording.

Are there circumstances where a supporting statement would not be expected? We recommend this is replaced with the word ‘must.’

In terms of monitoring, we recommend analysing waste arisings and capacity based on their respective position in the Waste Hierarchy would enable you to track the delivery of a circular economy and progress towards achieving the top levels of the Waste Hierarchy.

Comment

Representation ID: 825

Received: 30/01/2024

Respondent: Historic England

DLP78. We consider a clause could be included to safeguard the significance of heritage assets, including their setting.

Comment

Representation ID: 870

Received: 22/12/2023

Respondent: West Midlands Resource Technical Advisory Body (WMRTAB)

WMRTAB generally supports Policy DLP78 but has the following observations:
• Clause 1 appears to be concerned with general strategic matters rather than ‘locational considerations’ (and so perhaps should be incorporated within Policy DLP 75).
• Also regarding clause 1, WMRTAB notes that ‘landfill diversion’ is not the same as management of waste in accordance with the waste hierarchy and suggest that this clause be amended to ensure facilities are developed which will ensure waste is managed in accordance with the waste hierarchy.
• Clause 2b requires that ‘all waste processes and operations must be contained, processed and managed within buildings unless there are acceptable operational reasons why these processes cannot be contained in buildings’. However it is not clear what the term ‘acceptable operational reasons’ means in practice and so, to ensure the policy can be implemented as envisaged some explanation is needed.
• Clause 3 invokes ‘broadening the range of waste facilities currently available in the plan area’ as a reason to grant planning permission (amongst other things), whereas such a broadening may not necessarily be appropriate e.g. this may mean greater availability of facilities lower down the waste hierarchy.