Part One: Spatial Strategy and Policies (Regulation 18)

Support

Representation ID: 597

Received: 18/01/2024

Respondent: Environment Agency

We welcome the policy and its requirements for achieving Biodiversity Net Gain (BNG) as part of developments in Dudley. The Severn River Basin Management Plan is a key evidence base to identify ways in which water-related habitats and biodiversity can be created and enhanced for water bodies across the district.

The BNG guidance refers to RBMPs as an important source of information for achieving BNG for the water environment. Would welcome reference to this in the policy. We are likely to support the production of the Local Nature Recovery Strategy so that the priorities for nature recovery capture the water environment opportunities.

Support

Representation ID: 598

Received: 18/01/2024

Respondent: Environment Agency

We support the policies requirement for major development to contribute to the greening of Dudley by optimising the use of multi-functional green infrastructure for urban cooling and local flood risk management.

Support

Representation ID: 600

Received: 18/01/2024

Respondent: Environment Agency

We strongly support the policy, and particularly welcome the requirements from section 10 to 15 of the policy which cover watercourses and flood mitigation. Point 15 is positive where it requires developments to seek wider betterment, contribute to a reduction in overall flood risk and provide partnership funding toward wider community schemes. There are four flood risk management schemes affecting Dudley which would potentially benefit from partnership funding.
• Halesowen, River Stour, Property Level Protection Scheme
• Illey Brook Flood Alleviation Scheme, Halesowen
• Wordsley and Lye Stourbridge Property Level Protection Scheme
• Wordsley Brook Flood Alleviation Scheme Stourbridge

Comment

Representation ID: 601

Received: 18/01/2024

Respondent: Environment Agency

We support Policy DLP47 which requires the achievement of full credits for water efficiency. However, we recommend that for non-residential development over 1000sqm, BREEAM ‘excellent’ standards for water consumption should be met when water resources are under pressure. As of July 2021, Severn Trent and South Staffs are now classed as operating in areas of serious water stress. The policy requires this standard from 2029 but we think there is sufficient evidence and reason to aim for this standard now. This would also align more with the aims of paragraph 158.

Comment

Representation ID: 602

Received: 18/01/2024

Respondent: Environment Agency

We support the requirements in this policy, particularly, sections 2a b and c (restoration of riverbank habitat, of in-channel habitat including removal of culverts, improving the water quality of discharges, and retaining or creating at least 10 metres Green Infrastructure either side of the Stour and its tributaries).

We would like to see the ‘removal of weirs’ including within this policy as part of 2b. Weirs within rivers are often no longer needed and their removal would greatly improve ecological connectivity.

Comment

Representation ID: 604

Received: 18/01/2024

Respondent: Environment Agency

The Council should consider how the waste policies in the Local Plan support a circular economy. Part 2 (d) of the policy aims to ensure there is enough capacity and access for the municipal waste sites. We support this as a principle and add that a circular economy involves potentially expanding and rebranding Household Waste and Recycling Centres, into local Reuse, Recycling, Donation and Rental Centres.

Part 2 (d) could be strengthened by supporting the waste hierarchy here, by emphasising recovery and recycling ahead of disposal and then only ‘where necessary’ disposing of waste.

Paragraph 17.25 (f) and (g) outline that the Waste Site Impact Assessment should include consideration of how the occupiers of the new development could be affected, and how the waste site could be affected by the development. The action implied within (f) and (g) should be more robust, as should impacts on the occupiers of new development or waste site be identified, mitigation measures will need to be demonstrated.

See submission for suggested wording.

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: 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: 616

Received: 18/01/2024

Respondent: Environment Agency

Regarding Section 1 (c) of the policy, new developments should allow for additional waste storage and segregation at source, including in homes and commercial premises, for example for food wastes and batteries. Accessibility considerations around handling waste are also a factor. It’s important the space is designed so that the elderly, infirm or disabled residents can move bags or bins easily, especially when segregating waste. Building design can also help to minimise problems such as fly tipping in insecure communal areas. The term ‘significant’ in section 2 is ambiguous and it would help if this was quantified or defined.

We are advocating the adoption of “Whole Life” plans (or “Passports”), for all buildings to reduce energy, conserve water, and control carbon emissions and waste, not only during construction but during use, maintenance, refurbishment and enlargement, repurposing and at end-of-life.

Please also consider the case for a ‘derelict buildings strategy’, so that useful structures containing embedded carbon are not abandoned and left to decay until they need demolition but are retained in a positive use for as long as possible.