Object

Representation ID: 424

Received: 21/12/2023

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

DLP77 Preferred Areas for New Waste Facilities
3.17 Policy DLP77 identifies the preferred location for new waste management sites as being the Local Employment Area as shown on the proposals map and
Waste Key Diagram.

3.18 Paragraph 17.31 of the plan states:
It is not proposed to allocate specific sites for waste in the Plan because no new sites likely to be deliverable within the Plan period have been identified, apart from sites that already have planning permission. To have sufficient confidence to allocate a site, it would need to be actively promoted for waste management use by a waste planning authority, a landowner, or a commercial waste operator.

3.19 However, this overlooks our client’s site. Our client’s site has been actively promoted for waste
management through the 2020 Call for Sites consultation and in response to the now abandoned Black
Country Core Strategy and more recently through the design code and master planning process for Lye
Valley. Pegasus Grab Hire Ltd.’s representations are attached at appendix EP2. However, it is yet to be
allocated for waste use despite also operating as such since 2018, continuous engagement with Officers
where it has been made clear our client wishes to maintain a long term commitment to the site and
through our client’s investment and commitment to the continued improvement of the site and its
operation.

Comment

Representation ID: 606

Received: 18/01/2024

Respondent: Environment Agency

This appears to be a shared development site with Sandwell Council who have also identified adjoining land in their draft Local Plan. We recommend the Councils consider a formal framework agreement to agree who is responsible for responding to amenity complaints and other regulatory issues depending on the nature of the activities allowed on site. This would help facilitate collaborative working between the Council Departments.
We note the Bloomfield Road/Budden Road site is located close to residential development. The waste facilities will need to be suitably designed and operated to minimise impacts, with an appropriately sized buffer zone that includes an additional “safety margin” to separate the source from sensitive receptors.

Comment

Representation ID: 607

Received: 22/12/2023

Respondent: Worcestershire County Council

Policy DLP77 Preferred Areas for New Waste Facilities
Part 1 of policy DLP77 establishes a single “preferred location” for new waste management facilities. The actual effect of this is unclear. It appears that, although the area is preferred by DMBC, there is no specific policy tool that directs development to that location, rather than to any other suitable site. The relevant explanation is given in paragraph 17.36 of the Justification (which follows policy DLP78, not DLP77). Paragraph 17.36 appears to set criteria for when development that is not within the preferred area would be allowed. It states that this may be appropriate “should opportunities at the ‘Preferred Area’ not be available or suitable for individual proposals”. These tests are not explained further, and there is no requirement for applicants to provide any particular evidence, should they claim that one or both scenarios apply. More explanation may be useful here.
We would also welcome greater consistency in terminology, as the policy title and Justification refer to “Preferred Areas”, but policy point (1) refers to the “preferred location”.
Parts 2 and 3 of policy DLP77 require proposals to comply with other policies in the DLP (policies DLP75 and DLP78, respectively). Because the plan must be read as a whole, it is unclear why DLP77 needs to remind applicants to comply with any other policies. Parts 2 and 3 are therefore considered unnecessary.

Note there is a typo in paragraph 17.40, which refers to “open window composting”.

Comment

Representation ID: 824

Received: 30/01/2024

Respondent: Historic England

DLP77. We have not commented on the Area of Search at this time. How has the historic environment been assessed in terms of waste proposals?

Comment

Representation ID: 869

Received: 22/12/2023

Respondent: West Midlands Resource Technical Advisory Body (WMRTAB)

WMRTAB has the following observations on the approach in the Plan to identifying suitable land for waste management:
• WMRTAB acknowledges that the approach of not allocating specific sites reflects the local circumstances/nature of the Black Country whereby waste sites frequently feature within general employment areas across the urban area and these are located within large urban areas that are constrained in terms of opportunities for new developments overall. In light of the size of the identified waste management capacity gap and the fact that waste management can struggle to compete with higher value employment land uses, WMRTAB recommends that the approach, of not allocating specific sites and relying on general areas and areas of employment land, be robustly justified within the evidence base.
• To provide certainty that the land at Bloomfield Road/Budden Road, Coseley is available, WMRTAB suggest that this be safeguarded solely for waste management development.
• WMRTAB acknowledge that the choice of the ‘Preferred Areas’ identified in the BWCS ‘as being most suited to the development of new waste recovery, treatment, and transfer infrastructure’ was based on a series of locational considerations and constraints to identify the most appropriate likely future location for new waste facilities.
• WMRTAB understand Dudley has undertaken numerous Call for Sites exercises during the preparation of the current Local Plan and as part of its involvement in the former Black Country Plan.