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8. Waste Management
This chapter covers future requirements for waste management infrastructure.
It is a key objective of existing local and national policy that the amount of
waste produced should be reduced, and that as much value as possible
should be recovered from unavoidable waste. Local plans are expected to play
a role in this, by making provision for the infrastructure required to make this
happen. We therefore need to identify locations in the borough where new
recycling and recovery facilities could be developed, and allocate sites where
such projects are expected to be delivered during the plan period. We also
need to safeguard “strategic” waste management sites, which provide most of
the borough’s existing waste management capacity, from other development
that could compromise their continued operation.
Jargon Buster
•
Inert waste – waste which does not undergo any significant physical,
biological or chemical changes likely to cause risks to health or to the
environment or affect water quality - the legal definition of “inert waste” is set
out in Article 2 of the Landfill Directive (1991/31/EC).
•
Non-hazardous waste – waste that is neither inert nor hazardous, which can
include pre-treated organic wastes and stabilised residues from waste
treatment.
•
Hazardous waste – waste whose properties are likely to cause risks to
health, the environment or water quality - Annex III of the Waste Framework
Directive
(2008/98/EC)
defines
the
properties
which
render
waste
“hazardous.” The Environment Agency has produced guidance on the types
of waste that are likely to be hazardous.
•
Landfill Diversion – ways of recovering value from waste instead of
disposing of it to landfill, using methods at the higher levels of the “waste
hierarchy” (re-use, recycling, recovery).
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Waste Hierarchy – a system for ranking methods of managing waste in order
of preference, with waste prevention at the top (the preferred option), and
waste disposal at the bottom (the least preferred option). The Waste
Hierarchy is explained in further detail in the box in Section 8.2 below.
•
Waste Projections – forecasts or predictions of the amounts of waste likely
to arise over a given period. The estimates are calculated by “projecting” from
an estimate of current arisings (the “baseline”), and by applying assumptions
about how waste is likely to grow or fall over time.
•
Waste Disposal – managing waste in ways that do not allow any value to be
recovered, such as landfilling or incineration without energy recovery – the
legal definition of “disposal operations” is set out in Annex I of the Waste
Framework Directive (2008/98/EC).
•
Waste Recovery – managing waste in ways that allow value to be recovered,
essentially the same as “Landfill Diversion” (see above) – the legal definition
of “recovery operations” is set out in Annex II of the Waste Framework
Directive (2008/98/EC).
8.1
Current Situation
Walsall has a significant network of waste management infrastructure. There are
more than seventy waste management sites in the borough, ranging in size from
very large facilities covering several hectares of land, to small transfer stations and
scrap yards covering less than half a hectare. There are also several outstanding
planning permissions for development of new facilities. The location of existing sites
and other sites with planning permission is shown on Map 8.1. A significant “cluster”
of facilities has developed around Bentley Mill Way in Darlaston (within the Darlaston
LDO area), and other “clusters” are beginning to develop in Aldridge and on a
smaller scale at Leamore in Bloxwich and at Ashmore Lake in Willenhall.
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Nearly all of Walsall’s waste management facilities are located in established
employment areas. These include treatment facilities in industrial buildings, which to
the casual observer do not look significantly different to adjacent employment uses.
Other facilities, such as transfer stations and scrap yards, are open yards with small
ancillary buildings, although even these are usually enclosed by perimeter fencing.
Walsall also has two operational landfill sites for the final disposal of residual waste,
at Branton Hill Quarry in Aldridge (which can only accept inert waste) and at
Highfields South Quarry in Shelfield (which can accept inert and non-hazardous
waste). These are former quarry sites, whose peripheral location is dictated by
where mineral resources worth exploiting are to be found.
Most of Walsall’s waste management infrastructure is commercially owned and
operated. Only three sites are operated by or on behalf of the Council – a transfer
station and household waste recycling centre (HWRC) at Fryers Road in Bloxwich,
another HWRC and a small depot at Merchants Way in Aldridge, and the Council’s
main Environmental Depot in Brownhills. The latter site includes the Council’s waste
management offices, and is the base for its fleet of waste collection and street
cleaning vehicles.
A high proportion of Walsall’s existing waste infrastructure is based around metal
recycling, vehicle dismantling, and the recycling, recovery and treatment of
hazardous wastes. We have limited capacity for managing other types of waste. For
example, Walsall has no facilities for composting or anaerobic digestion of organic
wastes, and no facilities for recovering energy from waste, other than the Vigo/
Utopia landfill gas plant. This means that some of the waste produced by
communities and businesses in Walsall – in particular, organic waste – has to be
transported elsewhere for management.
Monitoring shows that proposals for new waste management facilities or for
expansion of existing facilities are coming forward on a regular basis and that most
of the schemes that receive planning permission are implemented. However,
facilities also close from time-to-time, and recent gains in waste management
capacity have been offset by losses.
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8.2 Policy
National Policy Guidance
The current national policy objectives for waste and guidance on planning for waste
are contained in the following documents:
•
Planning Policy Statement 10: (2011) (PPS10), CLG;
•
Planning for Sustainable Waste Management: Companion Guide to PPS10
(2006), CLG; and
•
Guidance for Local Planning Authorities on Implementing the Planning
Requirements
of
the
EU
Waste
Framework
Directive
(2008/98/EC)
(December 2012) CLG.
PPS10 has not been replaced by the National Planning Policy Framework (NPPF).
Revised guidance on waste is expected to be included in the revised national waste
strategy, which is expected to be in place by the end of 2013. In the meantime,
waste planning authorities are expected to plan for future waste management
infrastructure requirements in accordance with the above guidance.
The Waste Framework Directive has been transposed into national legislation
through the Waste (England and Wales) Regulations 2011 (SI 2011 No. 988) (as
amended), which impose specific duties on planning authorities when planning for
future waste management requirements, hence CLG issued new guidance on
compliance with the Directive in December 2012.
National policy guidance advises that local plans should make provision for the
sustainable management of all types of waste arising in the area, including municipal
and household wastes, commercial and industrial wastes, construction and
demolition wastes, low level radioactive wastes, agricultural wastes, hazardous
wastes and waste water.
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The requirement to comply with the Waste Framework Directive means that when
preparing plans for waste, we have a duty to apply the following principles:
•
The “waste hierarchy” (see box below) – this means that wherever possible,
when considering the need for new waste infrastructure, we should choose
options that will drive waste up the hierarchy, although options that depart
from the hierarchy may be supported where there is evidence they will deliver
the “best overall environmental outcome;” and
•
The principles of “proximity” and “self-sufficiency” - this means that when
planning for waste disposal and municipal waste recovery1 infrastructure,
each area should take more responsibility for the waste it generates, although
the Directive recognises that it will not always be economic or feasible for
each area to have every type of facility.
Local plans are required to provide a “waste management plan” for the area, which
sets out the requirements for new infrastructure. This should include an analysis of
the capacity of existing waste disposal and recovery installations, new capacity likely
to be provided through schemes with outstanding planning permission, and the need
to replace facilities likely to close within the plan period.
When planning for waste we are also expected to consider the impact of non-waste
uses on existing waste management sites, and the need for waste management
infrastructure alongside other land use planning objectives, particularly for
employment land. Plans should also include locational criteria (which take into
account potential effects on health and the environment and other potential
constraints) which can be used to identify and evaluate sites for new waste disposal
and recovery installations not currently planned.
Planning is also expected to promote sustainable management of waste and
material resources in new developments, such as on-site management of site waste,
use of recycled building and engineering materials, and ensuring that there is
1
This means installations for the recovery of mixed municipal waste collected from households and/
or from other sources as part of the same collection regime.
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adequate provision for storage, collection and management of waste within the
development once it is built.
The Waste Hierarchy
Walsall Council has a legal duty to apply the Waste Hierarchy when planning for the borough’s
future waste management requirements. The diagram below illustrates how each method of
management fits into the hierarchy – further information can be found in PPS10, Annex C.
Guidance published by Defra in June 2011 and by CLG in December 2009 explains where
different types of waste management facilities sit within the Hierarchy. Defra has produced
separate guidance on applying the Hierarchy to hazardous waste treatment (November 2011)
(which can be a recycling, recovery or disposal operation depending on the fate of the outputs
following treatment), and Energy from Waste Technologies (February 2013).
BCCS Spatial Objective 9 and BCCS Policies WM1 – WM5 already apply the Waste Hierarchy,
by seeking to address waste as a resource, and by setting targets for the diversion of LACW and
C&I waste away from landfill. The targets require the Black Country Authorities to provide
infrastructure with sufficient capacity to re-use, recycle or recover 84% of the LACW and 75% of
the C&I waste expected to arise in the area by 2026 (see BCCS Appendix 6).
Indicators relating to the Waste Hierarchy have been included in the assessment framework for
waste proposals developed by the Black Country Authorities, which the Council will use when
evaluating the suitability of potential site allocations for waste management development in the
SAD and AAP (see BCCS Policy WM4 and BCCS Waste Background Paper 2, Appendix 6).
The Waste Hierarchy image above is reproduced from the Waste Planning Merseyside
website, with the kind permission of Merseyside Environmental Advisory Service.
The Waste Framework Directive also sets recycling targets for municipal waste
and construction, demolition and excavation waste (CD&EW) by 2020. The
“duty to co-operate” also applies to the management of waste, when planning for the
management of waste, particularly where significant quantities of waste arising in a
particular area are being managed elsewhere.
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Local Planning Policy
At a local level, the requirements of PPS10 and the Waste Framework Directive
have largely been addressed through the waste policies in the Black Country Core
Strategy (Spatial Objective 9 and Policies WM1 – WM5).
The BCCS provides a “waste management plan” for the Black Country. It
quantifies future waste management requirements for each authority and sets
targets for diversion of waste away from landfill (Policy WM1). These
requirements and targets take into account the need for the Black Country to
manage a wider range of wastes, to drive waste up the “waste hierarchy,” and
achieve net “self-sufficiency” in waste disposal and municipal waste recovery as far
as possible, as required by the Waste Framework Directive.
The future waste management requirements identified in the BCCS were worked out
hare based on the difference between the estimated capacity of the Black Country’s
existing waste management infrastructure and the tonnages of waste expected to
arise in the area by 2026 (Policy WM1). The plan also seeks to safeguard existing
waste disposal and recovery infrastructure from encroachment by other types of
development, in particular, “strategic sites” (Policy WM2).
In setting targets for the additional capacity that needs to be planned for by each
authority, the BCCS also takes account the capacity likely to be provided through
planned infrastructure projects, and the availability of employment land likely to be
suitable for the development of other infrastructure as yet unplanned (Policy WM3). It
identifies the types of location likely to be most suitable for the development
of different types of facility (including for waste disposal) and criteria for
assessing the suitability of new proposals (Policy WM4).
The BCCS also includes a policy to guide waste and resource management in new
non-waste developments, such as housing, industry and town centre uses (Policy
WM5). This includes guidance on the management of construction and demolition
waste, and the provision of space to store and manage waste within the new
development once it is in use.
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8.3 Key Issues
There are four main issues that the SAD needs to address for waste:
(a) Future Waste Management Requirements
We need to review the waste management requirements for Walsall and the
wider Black Country identified in the BCCS and BCCS technical evidence, in
the light of the targets and other requirements in the Waste Framework
Directive, and the aspirations of the emerging national waste strategy.
(b) Safeguarding Walsall’s Existing Waste Infrastructure
We need to safeguard the “Strategic Sites” identified in the BCCS, and
consider whether any other waste management sites in Walsall (such as new
sites recently developed) should be identified as “Strategic Sites” in the SAD;
(c) Delivery of New Waste Infrastructure
We need to allocate the waste infrastructure proposals identified in BCCS
Policy WM3 in the SAD, and consider whether the SAD should allocate any
other sites, for example, sites with outstanding planning permission, and other
projects planned by waste operators within the plan period;
(d) Suitable Waste Management Locations in Walsall
We need to identify the most suitable locations where proposals that could be
required in the future could be developed e.g. employment areas likely to be
particularly suitable for recycling and recovery infrastructure of different types.
Waste Questions – Key Issues:
W:Q1 Have we identified all of the key waste management issues for the
SAD? Please provide details of any other issues you have identified, and
explain why you think they should be addressed in the SAD.
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(a) Future Waste Management Requirements
As is noted above, local plans are expected to make provision for any new
infrastructure required to manage waste from all of the waste streams arising locally.
The box below summarises the main “waste streams” we are expected to plan for.
Waste Streams
Local plans are expected to plan for the sustainable management of waste from the following
sources or Waste Streams where they arise in the area:
Local Authority Collected Waste (LACW) – waste collected from households and small
businesses by Walsall Council, also includes waste collected from Council premises and
deposited at the two household waste recycling centres (HWRCs) in Walsall at Fryers Road in
Bloxwich and Merchants Way in Aldridge. In 2011/12, 91% of the LACW collected by Walsall
Council was household waste.
Municipal Waste – defined in Article 2 of the Landfill Directive as “waste from households, as
well as other waste which, because of its nature or composition is similar to household waste.”
Municipal waste therefore includes all LACW (see above), but also similar wastes – including
paper, metal, plastic and glass - generated by businesses, which form part of the C&I waste
stream (see below).
Commercial and Industrial Waste (C&IW) – waste generated by businesses and industry,
which can include a wide range of materials, including waste similar to that generated by
households. Only a very tiny fraction of C&I waste, mainly from small shopkeepers, market
traders and Council premises, is managed by Walsall Council as part of the LACW stream (see
above).
Construction, Demolition and Excavation Waste (CD&EW) – waste generated by the
development process, sometimes called “site waste.” Much of this waste is classified as “inert”
waste, for example, demolition rubble and soils, but it also includes fractions of other materials,
such as timber, metal, insulation materials, asbestos and “green” waste from site clearance. In
areas like Walsall where is a history of heavy industry, it can also include contaminated soils.
Hazardous Waste – see “Jargon Buster.” This is a sub-set of all other waste streams, each of
which generates a proportion of wastes that are classified as “hazardous.” For example, LACW
typically includes batteries and light bulbs, C&I waste includes a wide variety of hazardous
substances such as oils, solvents and chemicals, and CD&EW includes asbestos and
contaminated soils.
Other Waste Streams – national policy guidance expects local plans to make provision for the
management of the following waste streams where necessary:
•
•
•
Agricultural Waste;
Low-Level Radioactive Waste;
Waste Water.
The BCCS identifies gaps in the existing infrastructure for managing LACW, C&IW (including
“municipal” waste) and CD&EW. It does not identify any need for additional infrastructure for
treatment of hazardous waste (except for contaminated soils), agricultural waste, low-level
radioactive waste, or waste water. However, if a need is identified for such infrastructure in
Walsall, the SAD will be expected to make provision for it.
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The starting point for planning for future waste management requirements is to
consider how much waste arises now, and how the amount of waste produced is
likely to change over the plan period. We then have to look at the waste
management infrastructure we already have, to see whether there is sufficient
capacity to cope with current and future demand.
This involves estimating the annual throughput capacity of existing recovery and
treatment facilities – the tonnage of waste they can process per annum, or tonnes
per annum (TPA). For landfill sites, which provide most of the Black Country’s waste
disposal infrastructure, we also have to consider how much void space is available to
be filled (volume in cubic metres), how much waste is likely to be deposited per
annum, and how many years each site will take to fill.
Current and Projected Waste Arisings in Walsall
The BCCS has already estimated the quantities of waste that arose in Walsall in the
“baseline” year (2006/07), and predicts the tonnage of waste expected to arise
annually by the end of the plan period (2025/26), taking into account actors likely to
influence waste growth, such as new housing development and housing demolitions.
The figures are summarised in Table 8.1 below. Further information about waste
arisings can be found in a separate Waste Background Paper.
Table 8.1: Waste Arisings in Walsall – BCCS “Baseline” Estimate of Arisings in
2006/07 and Projected Arisings by 2025/26 by Waste Stream
Waste Stream
Baseline Arisings 2006/07
(tonnes per annum)
Projected Arisings 2025/26
(tonnes per annum)
LACW
145,000
166,000
C&IW
381,000
570,000
CD&EW
239,000
239,000
TOTAL ARISINGS
765,000
975,000
Hazardous
46,000
69,000
Source: Appendix E, Black Country Core Strategy Waste Planning Study (2009), Atkins Ltd for Black
Country Authorities.
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Existing Waste Capacity - Walsall’s Existing Waste Management Infrastructure
There are currently more than 70 waste management sites in Walsall. The location
of each site is shown on Map 8.1 and on the Ward Maps in the separate ward
schedule. When preparing the BCCS, the Black Country Authorities reviewed the
capacity provided by existing waste disposal, recovery and treatment facilities,
including the capacity of the most important sites in the borough (“Strategic Sites”).
LACW and C&I Waste Management Infrastructure
Table 8.2 below summarises and updates the BCCS information on LACW and C&I
waste management capacity in Walsall Borough.
Table 8.2: Estimated LACW and C&I Waste Management Capacity in Walsall @
31.03.12 – Update of BCCS “Baseline” Information
LACW Management Capacity
Estimated C&I Waste
(tonnes per annum)
Management Capacity
(tonnes per annum)
Existing
Capacity with
Existing
Capacity with
Capacity
Planning
Capacity
Planning
(31.03.12)
Permission @
(31.03.12)
Permission @
Facility Type
31.03.12
31.03.12
Recycling
0
0
400,800
275,000
Recovery
0
0
470,000
55,000
TOTAL DIVERSION
0
0
870,000
330,000
Treatment
0
0
108,000
0
120,000
0
125,000
0
Transfer
Source: Update of Tables 3.10 of BCCS Waste Planning Study (2009), Atkins and Table WA2f of
BCCS Waste Background Paper 2 (2010), Black Country Authorities,, using information in Tables 9 12 of Walsall AMR 2012, Waste Technical Appendix, applying facility types identified in Annex 1 of
CLG guidance on application of Waste Framework Directive (December 2012).
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Map 8.1: Waste Management Infrastructure in Walsall – Waste Management Sites Identified @ March 2013
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The Council is not planning to develop any new LACW management infrastructure in
Walsall with the possible exception of a third household waste recycling centre
(HWRC) in Darlaston or Willenhall. This is one of the proposed infrastructure
projects identified in BCCS Policy WM3. The Council currently carries out separate
collections of co-mingled recyclable waste (paper, card, plastics, cans and glass),
green garden waste and residual waste from households, and relies on short-term
contracts with commercial waste operators to manage this waste. This is expected to
continue for as far as can be seen ahead. A high proportion of Walsall’s LACW is
currently managed outside the borough, even though there are facilities in Walsall
that could – in theory - manage at least some of it.
Walsall’s C&I waste management infrastructure is dominated by metal recycling sites
(MRS), hazardous waste recycling and treatment facilities and specialist recycling
facilities. There is no infrastructure for managing organic wastes, or for recovering
energy from waste, apart from the Vigo/ Utopia Landfill Gas Plant, the only
renewable energy facility of any significance in the borough (see Chapter 11 Utilities
Infrastructure). The capacity for managing small items of waste electrical and
electronic equipment (WEEE) is also limited.
Many businesses in Walsall will already have arrangements in place for minimising
waste and managing unavoidable waste in the most efficient manner. Various
national and local organisations can provide help and advice to businesses on
minimising
waste,
recovering
value
from
waste,
and
sustainable
waste
management.2 Some local businesses have their own in-house waste management
facilities. Examples include Middleton in Bescot which has a paper recycling facility,
A. F. Blakemore in Willenhall which has a recycling facility to recover packaging
waste, Stairways in Bescot, which has a small-scale biomass plant to generate
energy from waste wood, and Intercoat Industrial Paints in Walsall which has a small
transfer facility for waste paints and varnishes.
2
For example: the Waste and Resources Action Programme (WRAP), the Prince’s Trust Mayday
Network (Business in the Community), Groundwork Black Country Business Environment Association
(BCBEA) and the Black Country Enterprise Partnership (LEP) “Find it in the Black Country” resource.
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Even so, there is evidence that the waste management needs of some local
businesses are not being met, particularly small and medium-sized enterprises
(SMEs). For example, 23% of Walsall businesses who participated in the Walsall
Business Survey in 2010 said that local waste management facilities were not
sufficient to meet their needs and 17% of those surveyed said that they required
support, particularly in the provision of paper recycling.3 There is unlikely to be
scope to meet the needs of SMEs through new LACW infrastructure within the plan
period, because as noted above, none is proposed except possibly a third HWRC.
CD&EW Management Infrastructure
The BCCS technical work identified around 0.8 million TPA of CD&EW recycling
capacity in the Black Country. There are currently four sites in Walsall with planning
permission or a lawful use for CD&EW recycling, one of which (Bace Groundworks)
is currently vacant. These have been identified as Strategic Sites and are shown on
Map 8.2 (WS1, WS2, WS17 and WS20). The newest facility, the Interserve
Recycling Centre, is an indoor recycling facility (MRF) which handles mostly
CD&EW, but also C&IW. Based on information provided with planning applications,
the combined annual throughput capacity of the three facilities currently operating is
estimated to be around 130,000 tonnes of CD&EW per annum.4 However, a
proportion of the CD&EW generated in Walsall is likely to be recycled on-site rather
than at fixed recycling sites like those identified.
There is some anecdotal evidence that CD&EW from Walsall is being managed at
facilities in neighbouring authority areas. For example, there are facilities at
Cranebrook Quarry and Shire Oak Quarry in Staffordshire, near to the borough
boundary, which are likely to be accepting waste from Walsall. This suggests that
there may be scope to manage more of the CD&EW arising in the borough locally by
increasing CD&EW recycling capacity. This would also help to meet local and
national requirements for construction aggregates (see Chapter 9: Minerals). On the
3
Walsall Sector Analysis Study: Walsall Business Survey Report (October 2010), Ekosgen for Walsall
Council, published on the Walsall Partnership website.
4
However, information published on the Interserve website suggests that the operational capacity of
the new recycling facility could be significantly higher than indicated in the planning application.
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other hand, competition from existing facilities may mean that establishing new ones
in Walsall is not economically viable (see Chapter 13: Delivery and Viability).
There are no facilities for treatment and remediation of contaminated soils anywhere
in Walsall or the rest of the Black Country. This is a potential issue given the ground
condition problems highlighted in Chapter 13: Delivery and Viability. However, the
BCCS was unable to quantify future requirements for this, as there are different
methods of treatment available, depending on the type of contaminants present. The
BCCS Waste Planning Study also concluded that the quantities of material requiring
treatment are likely to be too limited for a new facility to be viable.
Hazardous Waste Treatment Infrastructure
The BCCS identified a surplus of hazardous waste treatment capacity in the Black
Country and did not identify any need to develop new treatment infrastructure in the
area. The main hazardous waste treatment facilities in Walsall are the Empire
Treatment Works in Aldridge and the recently-developed Envirosol. Both of these
have been identified as Strategic Sites and are shown on Map 8.2 (WS6 and WS18).
Waste Disposal - Landfill Capacity
Although waste disposal is a “last resort,” there will always be residual waste that
cannot be managed in any other way. Local plans are expected to make provision
for landfill where suitable sites exist, such as voids left from quarrying. Clean soils
and other excavation wastes can also be beneficially used or disposed of onto land,
and may be an essential element in landscaping, engineering and land remediation
projects (see Chapters 9: Minerals and 13: Delivery and Viability).
The evidence in the BCCS on the need for future landfill capacity indicated that
provision could run out by the end of the plan period. However, as more waste is
likely to be diverted from landfill than anticipated in the BCCS, we think that the sites
likely to become available over the plan period in the Black Country will be sufficient
to meet the requirements of the area, as well as the needs of neighbouring
authorities with no scope to provide landfill capacity, such as Birmingham.
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Monitoring suggests that the Black Country currently has very little permitted inertonly landfill capacity remaining, although inert wastes can be deposited in nonhazardous sites. New capacity should become available within the plan period at
Aldridge Quarry once the operator is in a position to begin infilling. Subject to
approval of the current quarry extension scheme, further landfill cells are also likely
to come forward at Branton Hill Quarry in the future. There is also planning
permission to infill two former railway cuttings with inert materials, one in Walsall
(North Walsall Cutting) and the other in Wolverhampton.
There is still significant non-hazardous landfill capacity remaining at Highfields South
Quarry, and at Himley Quarry in Dudley. The current planning permission covering
the restoration of Highfields South Quarry requires landfilling to cease by the middle
of 2016, but it could take longer if the final levels have not been reached by then.
Potential new non-hazardous landfill sites have also been identified in the BCCS at
Oak Farm Clay Pit in Dudley (BCCS Proposal WP4) and Sandown Quarry in Walsall
(BCCS Proposals WP1 and WP6), which could help to replace existing sites once
they reach the end of their operational life. In the longer-term, Atlas Quarry could
also come forward but this will almost certainly not happen within the plan period.
Other Waste Infrastructure
The BCCS does not identify any specific requirements for infrastructure to manage
agricultural waste, low level radioactive waste or waste water.
Around a third of Walsall’s administrative area is Green Belt, and this includes farm
holdings and other establishments likely to be generating agricultural waste. The
Environment Agency’s Public Register indicates that some of these have registered
waste exemptions. Types of waste that fall into this category include animal manure
and slurry (if not used directly as a fertiliser), empty pesticide containers, old silage
wrap, out-of-date animal medicines and wormers, used tyres and surplus milk.
However, we currently have no evidence that there is a need or demand for facilities
to manage these types of waste in Walsall.
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The Government has produced guidance on the management of solid low-level
radioactive waste (LLW) from the non-nuclear industry.5 This includes LLW
produced by hospitals, health centres, dentists and vets who carry out X-rays and
other similar procedures. There are a number of sites in Walsall that are likely to be
producing these types of waste, such as the Manor Hospital. Some LLW has to be
disposed of to specialist landfill sites in other parts of the country. However, where
the quantities of waste are very small or the levels of radioactivity are very low
(VLLW), it can be disposed of more locally by incineration. There is currently no
evidence of a need or demand for any LLW disposal facilities in Walsall.
Walsall has three waste water treatment facilities at Goscote Sewage Treatment
Works, Walsall Wood (Green Lane) Sewage Treatment Works and Willenhall
Sewage Treatment Works. The need for waste water treatment infrastructure is
considered in Chapter 11: Utilities Infrastructure. Willenhall Sewage Treatment
Works has been put forward for development with other uses and is identified as a
“Choices Site” (References CH81 and CH92). Further details about the choices sites
can be found in Chapter 12: Sites, Choices and Constraints.
Achieving Self-Sufficiency
National policy guidance recognises that “self-sufficiency” does not necessarily mean
every waste planning authority area has to have the full range of facilities needed to
dispose of all the residual waste, or manage all the recyclable or recoverable
municipal waste, arising in the area. This is unlikely to be feasible where only small
amounts of waste are generated or where it is more cost-effective to provide a single
facility serving a wider area. However, the limited range of waste management
infrastructure available in the Black Country means that significant amounts of waste
we do produce, such as organic wastes and contaminated soils, cannot be managed
locally, and have to be exported elsewhere for management.
5
Strategy for the Management of Solid Low Level Radioactive Waste from the Non-Nuclear Industry
in the United Kingdom – Part 1: Anthropogenic Radionuclides (March 2012), DECC, DOENI, Scottish
Government and Welsh Assembly
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There is evidence – from the Environment Agency Waste Data Interrogator - that
wastes received at facilities in Walsall (including metals and hazardous wastes) are
being exported to other areas, even when in theory the infrastructure to manage
them exists locally. On the other hand, significant amounts of waste (particularly
metals and hazardous waste liquids) are being imported into recovery and treatment
facilities Walsall from other parts of the country. This suggests that either the
facilities in Walsall are specialised and cannot process all of the metallic and
hazardous wastes that arise locally, or that other factors such as cost, convenience,
and organisational practices are playing a role in how and where waste is managed.
Where there is evidence of significant movements of waste out of Walsall into other
areas for recycling, recovery, treatment or disposal, particularly, LACW and other
municipal wastes, the Council will need to liaise with the relevant waste planning
authorities, to establish whether these are likely to be able to continue for as far as
we can see ahead.
Delivery of the recycling and recovery infrastructure we lack depends on two things:
firstly, having sufficient “readily available” employment land or other suitable land, of
the right type and in the right place, for the type of facility (see Chapter 4: Land for
Industry), and secondly, identifying sufficient demand from waste producers, and
sufficient demand for the end-products from the recycling or recovery process, to
make it economically viable. Chapter 13: Delivery and Viability considers the issues
affecting viability of waste management schemes in more detail.
Future Waste Capacity Requirements - BCCS Landfill Diversion Targets
The BCCS analysis of waste management capacity took into account the capacity of
schemes in the pipeline and the potential for major facilities to be lost, where
employment land is proposed to be redeveloped with housing over the plan period.
The requirements for the Black Country as a whole set out in Policy WM1 of the
BCCS represent the new capacity that we need to provide in the Black Country to
meet the landfill diversion targets set, taking into account the capacity already in
place at existing facilities likely to remain in place for as far as we can see ahead.
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The BCCS indicates that Walsall and the other Black Country Authorities are already
“self-sufficient” in waste recovery infrastructure and that overall, there is no long-term
“capacity gap” for LACW and C&I waste diversion (see BCCS Appendix 6, Tables
WM1f and WM1g). It was estimated that existing facilities have sufficient waste
recycling, recovery and treatment capacity to meet the landfill diversion targets for
LACW and C&I waste in the BCCS.
While the BCCS technical work did not identify any quantitative gaps in provision, it
was recognised that the range of waste management infrastructure available in the
area is limited, and is dominated by metal recycling and hazardous waste treatment,
as is noted above. Hence, the BCCS Spatial Objective for waste seeks to broaden
the range of facilities available, and the requirements identified in Policy WM1 took
into account that a significant proportion of the Black Country’s infrastructure
consists of metal recycling and hazardous waste treatment facilities.
BCCS Policy WM3 identifies a number of projects in the pipeline – including three in
Walsall - which are expected to be delivered by 2026. The “residual” requirements
for individual authorities identified in BCCS Policy WM3 represent the remaining
capacity to be provided to meet the BCCS landfill diversion targets, assuming that
the specific projects will be delivered. The requirements have been “apportioned” to
each authority according to their likely ability to be able to accommodate new
infrastructure, which is based on each authority’s “share” of employment land.
The analysis of waste infrastructure carried out for the BCCS was also not carried
out strictly in accordance with the latest guidance on compliance with the Waste
Framework Directive issued by CLG in December 2012. The Council is therefore
proposing to review the BCCS technical evidence in the light of this guidance. This
will include a survey of known waste management sites in Walsall, to check which
ones are operating (lawfully or otherwise!) and where they fit within the Waste
Hierarchy. The sites we are proposing to include in this review are identified on Map
8.1, and are listed in Appendix 8a. In the meantime there is further information about
Walsall’s existing waste management infrastructure and capacity in a separate
Waste Background Paper.
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Another issue we need to think about is compliance with the recycling targets in the
Waste Framework Directive and any other targets that might be set in the revised
national waste strategy, which is expected to be published by the end of 2013, which
are different to the landfill targets set in the BCCS. The implications of these targets
for future waste management requirements in Walsall are explained below.
Achieving Self-Sufficiency
National policy guidance recognises that “self-sufficiency” does not necessarily mean
every waste planning authority area has to have the full range of facilities needed to
dispose of all the residual waste, or manage all the recyclable or recoverable
municipal waste, arising in the area. This is unlikely to be feasible where only small
amounts of waste are generated or where it is more cost-effective to provide a single
facility serving a wider area. However, the limited range of waste management
infrastructure available in the Black Country means that significant amounts of waste
we do produce, such as organic wastes and contaminated soils, cannot be managed
locally, and have to be exported elsewhere for management.
There is evidence – from the Environment Agency Waste Data Interrogator - that
wastes received at facilities in Walsall (including metals and hazardous wastes) are
being exported to other areas, even when in theory the infrastructure to manage
them exists locally. On the other hand, significant amounts of waste (particularly
metals and hazardous waste liquids) are being imported into recovery and treatment
facilities Walsall from other parts of the country. This suggests that either the
facilities in Walsall are specialised and cannot process all of the metallic and
hazardous wastes that arise locally, or that other factors such as cost, convenience,
and organisational practices are playing a role in how and where waste is managed.
Where there is evidence of significant movements of waste out of Walsall into other
areas for recycling, recovery, treatment or disposal (see Waste Background Paper),
particularly, LACW and other municipal wastes, the Council will need to liaise with
the relevant waste planning authorities, to establish whether these are likely to be
able to continue for as far as we can see ahead.
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Delivery of the recycling and recovery infrastructure we lack depends on two things:
firstly, having sufficient “readily available” employment land or other suitable land, of
the right type and in the right place, for the type of facility (see Chapter 4: Land for
Industry), and secondly, identifying sufficient demand from waste producers, and
sufficient demand for the end-products from the recycling or recovery process, to
make it economically viable. Chapter 13: Delivery and Viability considers the issues
affecting viability of waste management schemes in more detail.
Waste Management – Current Requirements and Targets
The BCCS sets targets for the diversion of LACW and C&I waste away from landfill,
which reflected the national policy targets in place at the time the plan was prepared.
By 2026, the Black Country as a whole is expected to have in place infrastructure
capable of diverting 84% of the LACW and 75% of the C&I waste arising in the area.
Different targets for LACW have been set for each authority – the target for Walsall is
75%, meaning that by 2026 Walsall Council is expected to have access to
infrastructure capable of diverting 75% of its LACW away from landfill.
Walsall is also expected to contribute towards national waste management targets.
The document “Government Waste Policy Review in England” published by Defra in
July 2011 signals an aspiration towards achieving a “zero waste economy” by 2020.
This essentially means driving waste up the Waste Hierarchy as far as possible, and
will be measured against the Landfill Directive targets for reduction of biodegradable
municipal waste sent to landfill in 2013 and 2020, and the Waste Framework
Directive targets for re-use and recycling of municipal waste and non-hazardous
construction and demolition waste (see paragraphs 32 – 33 and 46 – 48).
Table 8.3 below indicates what this means for Walsall over the rest of the plan
period, assuming that waste arisings by 2026 are as projected in the BCCS. It should
be noted that the Landfill Trading Allowance Scheme (LATS) is due to cease after
the 2012/13 target year, and that there will be no official “targets” set for reduction of
biodegradable LACW in 2019/20. The 2019/20 target for Walsall from the LATS
Public Register is reproduced in the table for completeness.
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Table 8.3: Towards a “Zero Waste Economy” in Walsall – Relevant Targets
Projected
Landfill Directive –
Waste Framework
BCCS – Targets for
Waste
LATS Target for
Directive Re-Use and
Diversion of Waste
Arisings
Reduction of
Recycling Targets
from Landfill – Re-Use,
2025/26
Biodegradable
(2019/20)
Recycling, Recovery
(tonnes)
Municipal Waste to
and Treatment
Landfill (2019/20)
(2025/26)
Waste
Reduction
Maximum
Recycling
Minimum
Diversion
Minimum
Stream
Rate (%)
Tonnes
Rate (%)
Tonnes
Rate (%)
Tonnes
144,500
35% of
26,202
50%
72,250
75%
108,375
285,750
1995
LACW
levels
C&IW
381,000
?
-
-
-
-
75%
35% of
-
50%
?
-
-
-
75%
179,250
-
-
1995
Municipal
levels
Non-Haz C&D
239,000
-
Source: Article 4 Landfill Directive (1999/31/EC), Waste Strategy for England 2007, Article 11 Waste
Framework Directive (2008/98/EC), Tables WM1d and WM1e, BCCS Appendix 6.
The evidence set out in Table 8.3 above suggests that although Walsall has no
capacity for recycling or recovery of LACW and is not likely to have any such
capacity by 2026, C&I waste recycling and recovery capacity (estimated to be
around 870,000 TPA @ 31.03.12) is already sufficient to manage all of the LACW
and C&IW predicted to arise in the borough by 2026 (around 726,000 TPA in total).
The evidence reviewed in the 2012 AMR also suggests that high levels of C&IW
diversion are already being achieved.
In Policy WM1 of the BCCS (Table 16), the Black Country Authorities have set
themselves a target to provide 0.303 million tonnes of additional LACW recycling,
composting and energy recovery capacity and 1 million tonnes of additional nonmetal recycling, non-hazardous C&I waste recycling, recovery and treatment
capacity by 2026. A need for CD&EW recycling and contaminated soil treatment
capacity is also identified, but it was not possible to quantify requirements.
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The targets in BCCS Table 16 are aimed at meeting qualitative rather than
quantitative needs, in support of BCCS Spatial Objective 9, which aims to drive
waste up the Waste Hierarchy and broaden the range of infrastructure available,
allowing more of the waste produced by Black Country communities and businesses
to be managed locally, and providing the opportunity to minimise the distance waste
has to travel. Policy WM3 of the BCCS identifies a number of planned infrastructure
projects expected to contribute towards these requirements (Table 17), and the
“residual requirements” that remain, once the capacity expected to be provided in the
identified projects has been discounted (Table 18). The residual requirements in
Table 18 have been apportioned to each authority as far as possible.
The Walsall AMR 2012 provides an update of the residual requirements for Walsall
and the Black Country as a whole, taking into account new capacity developed and
capacity lost since the “baseline” year (2008/09). The remaining requirements
identified at the end of March 2012 are summarised in Table 8.4 below. We have
identified three alternative “reasonable” options for how we address the
remaining Future Waste Management Requirements in the SAD – see Waste
Option 1 (1a – W1c) in the Options section below. However, the targets in the BCCS
and Waste Framework Directive must be met, so it would not be a “reasonable”
option not to make provision to meet them, where it is necessary (see Waste Option
1 (1d only) in Options section below and in Appendix 12b).
Further analysis will be required to establish how much of Walsall’s C&IW arisings
are likely to be “municipal waste,” how much of its existing recycling and recovery
capacity is recovering “municipal waste,” and whether existing and planned capacity
is likely to be sufficient to enable the Waste Framework Directive recycling target to
be met. The Council will also need to review Walsall’s existing CD&EW recycling
capacity to establish whether it will enable Walsall to meet the Waste Framework
Directive target for re-use and recycling of non-hazardous construction and
demolition waste. 6
6
The Directive sets targets for at least 50% of municipal waste (comprising paper, metal, plastic and
glass from households and other similar waste streams) to be prepared for re-use, recycling and other
material recovery by 2020, and for at least 70% of non-hazardous construction and demolition waste
to be prepared for re-use, recycling and other material recovery by 2020.
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Table 8.4: Updated Residual Waste Capacity Requirements for Walsall and the
Black Country 2012/13 – 2025/26
Updated BCCS
Authority
Updated BCCS
Updated BCCS
Residual
Residual
Residual
Updated BCCS
Requirement for
Requirement for
Requirement for
Residual
Commercial
LACW Diversion
C&IW Diversion
Requirement for
Waste Transfer
Capacity @
Capacity @
CD&EW Capacity
Capacity @
31.03.12 (TPA)
31.03.12 (TPA)
@ 31.03.12
31.03.12
Unable to quantify
need for CD&EW
Recycling - 27,300
Walsall
recycling. Potential
Requirement not
need for temporary
General Household,
Composting – 18,500
broken down by
"hub" sites for
Commercial &
Recovery – 20,900
facility type
contaminated soil
Industrial Transfer
Total - 66,700
Total - 149,200
treatment.
Total - 10,000
At least 1 additional
Recycling -124,000
Black Country
CD&EW recycling
Requirement not
Composting - 84,000
facility, plus
General Household,
broken down by
temporary "hub" sites
Commercial &
Recovery - 95,000
facility type
for contaminated soil
Industrial Transfer
Total - 303,000
Total – 513,200
treatment as required
Total - <70,000
Source: BCCS Tables 16 and 18, Tables 26 - 30, Walsall AMR 2012, Waste Technical Appendix.
Notes on Table W4:
1.
All figures are rounded to the nearest 1,000 TPA.
2.
The residual LACW requirements have been apportioned to Walsall in the same way as the C&IW and
Commercial Waste Transfer are apportioned in BCCS Table 18, in the following proportions: Dudley
24%, Sandwell 31%, Walsall 22% and Wolverhampton 23%.
3.
The apportionments are based on the amount of retained employment land each authority is likely to
have by 2026, as employment land is likely to provide most opportunities for this type of infrastructure.
4.
All of the LACW requirements in BCCS Table 16 remain to be met, as BCCS Proposal WP5 in Sandwell
will not provide any recycling, composting or recovery capacity as was envisaged when the BCCS was
prepared. The recovery capacity to be provided at Four Ashes in Staffordshire has not been discounted
as although it will be managing LACW from Sandwell and Walsall it is outside the Black Country.
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Waste Questions – Future Waste Management Requirements:
W:Q2 Do you agree that the SAD should set targets for landfill reduction
and recycling in Walsall, based on existing national and local targets such
as those in the Black Country Core Strategy?
Supplementary Question:
W:Q2A Do you agree that meeting the combined “residual” requirements for
LACW and C&IW identified in BCCS Policy WM3 would enable Walsall to meet
the Waste Framework Directive target to re-use or recycle 50% of municipal
waste by 2020? If not, what other targets would you suggest and why?
W:Q3 Do we need more waste management facilities in Walsall to meet the
targets mentioned in Question WQ2 or manage types of waste that are not
currently catered for in the borough? If so, what facilities do we need?
Supplementary Questions:
W:Q3A Is there a need for additional CD&EW recycling facilities in Walsall to
meet the Waste Framework Directive target to re-use or recycle 70% of nonhazardous construction and demolition waste by 2020? If so, how much
additional annual throughput capacity (tonnes per annum) do we need? Please
provide evidence in support of your comments.
W:Q4B Is there is a need for contaminated soil treatment facilities in Walsall? If
so, what type of facilities do you think we need, and what role (if any) should the
SAD play in delivering them? Please provide evidence in support of your
comments.
W:Q3C Do you agree that Walsall is likely to have enough waste disposal
capacity to meet the needs of the borough and the wider Black Country as well
as other neighbouring authorities unlikely to be able to provide facilities
themselves? If not, please explain why you think there is a deficiency.
W:Q3D Do we need new infrastructure in Walsall to manage any of the following
types of waste?
o Agricultural Waste; and/or
o Low Level Radioactive Waste; and/or
o Waste Water?
If so, please indicate which of these wastes need to be managed in Walsall, the
quantities of waste likely to require management, how the waste should be
managed, and how the need could be addressed in the SAD.
W:Q4 Other than landfill sites, does Walsall need to provide new facilities to
manage waste from areas outside the Black Country - and if so, why?
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Supplementary Question:
W:Q4 Do you think that Walsall is already contributing enough towards crossboundary requirements for waste management, given that we have a number of
specialist facilities for recycling batteries, fridges and tyres, metal recycling sites,
hazardous waste treatment facilities, and landfill sites, which are receiving
significant amounts of waste from other areas?
W:Q5 Do you have any comments on the information in the Waste
Background Paper about future waste management requirements and the
need for new waste management infrastructure in Walsall?
Supplementary Question:
W:Q5A Do you agree that in quantitative terms Walsall already has enough
waste management capacity to meet the combined landfill diversion targets for
LACW and C&IW in BCCS Policy WM1 and BCCS Appendix 6? If not, please
explain why you think there is a deficiency.
(b) Safeguarding Walsall’s Existing Waste Infrastructure
During the preparation of the BCCS it was recognised that some waste management
sites were at risk from proposals to change the use of employment land to housing,
and the capacity likely to be lost as a result of this was factored into the requirements
identified in the Core Strategy (see Issue (a) above).
BCCS Policy WM2 therefore seeks to safeguard existing waste infrastructure from
needless loss or encroachment from other land uses that may not be compatible and
could compromise their current operation or plans for future expansion. The policy
requires all proposed changes of land use affecting any waste site to have regard to
the impacts on waste management capacity. Development affecting one of the
Strategic Sites identified in the BCCS must provide supporting information justifying
any loss of waste management capacity that is likely to result. We have identified
two alternative options for how the SAD should Safeguard Walsall’s Existing
Waste Infrastructure – see Waste Option 2 (2a and W2b) in the Options section.
However, it would not be appropriate for the SAD to safeguard closed sites that are
not likely to be re-used, or operational sites that are likely to close. The Council will
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therefore liaise with the relevant waste operators and land owners to establish which
waste sites have closed and are not likely to be re-used for waste management, and
whether any of the sites still operating are likely to close in the foreseeable future.
Sixteen of Walsall’s waste management facilities are identified in the BCCS as
Strategic Sites These are very large facilities or facilities that specialise in managing
particular types of waste. There is a definition of a Strategic Site in BCCS Policy
WM2. A significant proportion of Walsall’s existing waste management capacity around 83% in 20117 - is based within the Strategic Sites (see section below). The
loss of one of these sites could have a major impact on the borough’s overall waste
management capacity. Most of them are in established employment areas, or in the
case of landfill sites, in the Green Belt.
To manage the potential impacts of risks from future land use change, particularly
where sites are in employment areas, changes affecting Strategic Sites are being
monitored. This means that if a Strategic Site closes or relocates, any loss in
capacity can be taken into account when planning for future waste management
requirements, or when determining applications for new waste management
developments. Since the BCCS was prepared, at least two of the sites in Walsall
have closed, but three new sites have been developed and another site has been
identified. The Strategic Sites identified in the BCCS and the proposed new ones are
shown on Map 8.2 and are listed in Table 8.5 below.
One of the sites – former Metal & Waste Recycling (Bull Lane) has been granted
planning permission for a change of use which has now been implemented. This site
has therefore been lost and it is not proposed to identify it as a Strategic Site in the
SAD. The Council will consider whether sites that have closed but are still potentially
available for a new waste management use should be regarded as Strategic Sites.
7
Based on waste inputs by tonnage into “strategic sites” with Environment Agency waste permits in
2011 (1,040,900 tonnes), as a percentage of waste inputs by tonnage into all sites with Environment
Agency waste permits in 2011 (1,247,500 tonnes). All figures rounded to the nearest 100 tonnes. For
further details see Walsall AMR 2012.
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Map 8.2 – Strategic Waste Sites in Walsall and Potential Waste Site Allocations Identified @ March 2013
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Table 8.5: Existing and Proposed Strategic Waste Sites in Walsall
SAD
Waste
Site Ref
SAD
Choices
Site Ref
BCCS
Ref
Site Name/
Location
WS1
WSWa1
Former Bace
Groundworks,
Coppice Lane,
Aldridge
Inert CD&EW
Recycling Site
Permitted
Closed, no new planning
permissions for change of
use
WS2
WSWa2
Branton Hill Quarry
and Landfill,
Aldridge
Inert Landfill and Inert
CD&EW Recycling
Site
Permitted (Landfill) Lawful
Use (Recycling)
Operational
WS3
WSWa3
Credential
Environmental,
Western Way,
Moxley
Specialist Tyre
Treatment Facility
Permitted Operational
WS4
WSWa4
G & P Batteries,
Crescent Works,
Darlaston
Specialist Battery
Recycling Facility
Permitted Operational
Within Darlaston LDO
2012 area but not within
Subzone A.
WS5
WSWa5
EMR Darlaston,
Bentley Road South
Metal Recycling Site
(MRS) and Specialist
Fridge Recycling
Facility
Permitted Operational
Within Darlaston LDO
2012 area and within
Subzone A.
WS6
WSWa6
Veolia, Empire
Treatment Works,
Aldridge
Hazardous Waste
Treatment and
Transfer Facility
Permitted Operational
WS7
WSWa7
Metal & Waste
Recycling, Bull
Lane, Moxley
General Waste
Transfer Facility with
Treatment
Closed in 2011, new
permission for Class B2/
B8 uses implemented in
2012, site no longer has
lawful waste recycling and
transfer use
WS8
WSWa8
Fryers Road
Transfer Station
and HWRC,
Bloxwich
LACW Waste
Transfer, Sorting and
Bulking Facility and
Civic Amenity Site
Permitted Operational
WS9
WSWa9
Aldridge MRF
(Biffa), Westgate
Material Recycling
Facility (MRF)
Permitted Operational
WS10
WSWa10
Highfields South
Landfill Site, Walsall
Road, Shelfield
Non-Hazardous
Landfill
Permitted Operational
WS11
WSWa11
Veolia Darlaston,
Hollands Industrial
Park
Paper and Card
Recycling Facility and
General Waste
Transfer Facility with
Treatment
Permitted
Paper and Card
Recycling Facility
Operational
Within Darlaston LDO
2012 area but not within
Subzone A.
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Operational Status
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SAD
Waste
Site Ref
BCCS
Ref
Site Name/
Location
Facility Type
Planning/
Operational Status
WS12
WSWa12
Interserve Site
Services, Brickyard
Road, Aldridge
General Waste
Transfer Facility
Permitted
Closed – replaced with
new recycling facility (see
WS20) but no new
planning permissions for
change of use
WS13
WSWa13
Metal & Waste
Recycling, Jute
Works, Pleck
Metal Recycling Site
(MRS)
Operational, planning
status to be confirmed.
WS14
WSWa14
Merchants Way
HWRC and Depot,
Aldridge
Civic Amenity Site
and Storage Depot
Permitted Operational
WS15
WSWa15
Vigo/ Utopia Landfill
Site, Coppice Lane,
Walsall Wood
Non-Hazardous
Landfill, Leachate
Treatment Plant,
Landfill Gas Plant
Permitted
Landfill closed in 2010,
leachate treatment and
landfill gas plants still
operational
WS16
WSWa16
Willenhall Skips,
Sharesacre Street,
Ashmore Lake
General Waste
Transfer Facility
Permitted
Appears to have closed,
no new planning
permissions for change of
use
-
Land at Bescot
Triangle
Inert CD&EW
Recycling Site
Existing Permitted Site
not included in BCCS
Operational
WS18
-
Envirosol, Collier
Close, Coppice
Side Industrial
Estate, Brownhills
Hazardous and NonHazardous Waste
Treatment and
Transfer
New Site – Permitted
Operational
WS19
-
Walsall Council
Environmental
Depot, Pelsall
Road, Brownhills
Storage Depot for
Waste Collection
Vehicles
New Site – Permitted
Operational
WS20
-
Interserve
Recycling Centre,
Brickyard Road,
Aldridge
Material Recycling
Facility (MRF) mainly for CD&EW
New Site - Permitted
Operational
WS17
SAD
Choices
Site Ref
April 2013
Adj. CH10
Source: BCCS Table WM2c, Appendix 6, Walsall Waste Sites Database and waste applications monitoring.
A high proportion of waste management sites in Walsall – whether Strategic Sites or
not - are in areas proposed to be allocated for industry (see Chapter 4: Land for
Industry). This gives them a degree of protection. Table 8.6 below summarises the
number of waste sites on employment land proposed to be retained in the long-term,
by employment land category. If these sites are allocated for employment use in the
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SAD, waste facilities within them are less likely to be affected by changes of use to
housing or other uses that may not be compatible. This will provide greater security
for waste operators and is likely to give them confidence to invest in improvements.
However, it would not be feasible to prevent changes to alternative employment use.
Table 8.6: Waste Management Sites in Walsall by Employment Land Category
Employment Land Categories
Number of Waste Management Sites in Walsall by
Type
Existing and Potential
“Strategic Sites”
Existing and Potential
Waste Sites – Other
Waste Management Sites – All
Total Number of Waste
Management Sites by Type
19
65
Waste Management Sites on Employment Land by ELR Category
Employment Land – All
Categories
16
55
Existing High Quality (EHQ)
0
1
Potential High Quality (PHQ)
5
14
11
29
Existing Local Quality – Consider
for Release (CFR)
0
11
Existing Local Quality - Release
Now
0
0
Employment Land with
Permission for Other Uses
0
0
Existing Local Quality – Retain
(LQ)
Source: Walsall Council Waste Sites Database, Walsall ELR Update (2012).
Waste Questions – Safeguarding Walsall’s Existing Waste Infrastructure:
W:Q6 Do you agree that the SAD should safeguard existing waste
infrastructure in Walsall, including Strategic Sites?
Supplementary Question:
W:Q6A If you do not agree that the SAD should safeguard existing waste
infrastructure, what alternative approach would you suggest? Please provide
evidence in support of your suggestions.
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W:Q7 Do you have any comments on the Existing and Potential Strategic
Sites (WS1 – WS20) and the other waste sites (shown as symbols) on Maps
8.1 and 8.2 and the Ward Maps?
Supplementary Questions:
W:Q7A Do you think any sites should be omitted or added other than those we
have shown on the maps and listed in the Waste Technical Appendix? Please
provide supporting evidence if you think we should add or delete any sites.
W:Q7B Do you have any comments on the boundaries of any of the Strategic
Sites shown on Map 2? If you wish to suggest alternative boundaries for a site,
please provide evidence in support of your proposal.
(c) Delivery of New Waste Infrastructure
BCCS Policy WM3 (Table 17) identifies a number of proposals for the delivery of
new strategic waste management infrastructure which are expected to contribute
towards the overall requirements identified in BCCS Policy WM1 (Table 16) – see
Issue (a) above for further details of the requirements identified.
Table W7 below lists the three specific sites in Walsall identified in the BCCS, and
six others which the Council is considering for possible allocation in the SAD. The
table explains how these sites have been identified. BCCS Table 17 also identifies
two other proposals in Walsall, which were not site-specific:
•
Replacement Council Depot and
•
Additional HWRC in Darlaston/ Willenhall.
The replacement Council depot has now been delivered, and is identified as
Strategic Site WS19 (see Table 8.5 above). However, the additional HWRC has not
been delivered and no sites have so far been identified for this, hence it is not
included in Table 8.7 below. The Council’s Planning Policy Team will continue to
liaise with the Council’s Street Pride Team and if a suitable site is identified it will be
considered alongside the others identified below.
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Table 8.7: Potential Waste Management Site Allocations
SAD
Waste
Site Ref
SAD
Choices
Site Ref
BCCS
Ref
Site Name/
Location
Facility Type
WP1
WP1
Aldridge
Quarry, Birch
Lane, Aldridge
Proposed NonHazardous Landfill
Site
Quarrying ceased in
2008, restoration
programme not
started.
WP2
WP3
Land at Fryers
Road,
Bloxwich
Proposed Resource
Recovery Park to
comprise Material
Recycling Facility
(MRF) and
Combined Heat
and Power (CHP)
Plant using waste
wood as feedstock
Outstanding planning
permissions. EIA
Scoping Opinion for
alternative advanced
thermal treatment
scheme requested
2013.
WP3
WP6
Sandown
Quarry,
Stubbers
Green Road,
Aldridge
Proposed NonHazardous Landfill
Site
Quarry still
operational, not likely
to come forward until
2014/15 at earliest.
WP4
-
Darlaston
Biomass
Proposal,
Junction of
Kendrick Road
and Heath
Road
Proposed timber
resource recovery
centre (wood
biomass plant)
Outstanding planning
permission. Within
Darlaston LDO 2012
area but not within
Subzone A.
WP5
-
North Walsall
Cutting,
Between Mill
Street and
Reedswood
Way
Infilling of Railway
Cutting with Inert
C&D Waste
Outstanding planning
permission.
WP6
-
Branton Hill
CLEUD
Relocation
Site, Branton
Hill Quarry,
Aldridge
Relocation of
existing inert
CD&EW recycling
areas
Planning application
to consolidate and
relocate CD&EW
recycling area within
the quarry.
-
Former Moxley
Tip
Potential site for
inert CD&EW
recycling
Potential site for
relocation of
unauthorised facility.
This is a “Choices
Site” as it has outline
planning permissions
for housing,
employment and
open space uses.
WP7
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CH27
Planning/
Operational Status
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SAD
Waste
Site Ref
SAD
Choices
Site Ref
BCCS
Ref
Site Name/
Location
WP8
CH93
-
Land at Yorks
Bridge
Not specified
-
Atlas Quarry,
Stubbers
Green Road,
Aldridge
Potential nonhazardous landfill
site
WP9
Facility Type
Planning/
Operational Status
Put forward in
response to SAD and
AAP “call for sites.”
This is a “Choices
Site” as the site has
been put forward for
a variety of potential
uses including waste
management.
Quarry still in
operation and has
many years’ life
remaining, therefore
not likely to come
forward for
restoration within the
plan period.
Source: BCCS Policy WM3, Table 17, Walsall Council waste applications monitoring, SAD and AAP
“Call for Sites” (November 2011).
The consultation on the Issues and Options will provide a further opportunity for the
waste industry or other organisations to put forward potential waste management
site allocations for consideration.
As part of the Core Strategy preparation process, the Black Country Authorities
developed an assessment framework based on the locational criteria in BCCS Policy
WM4, which was used to evaluate the strategic infrastructure proposals identified in
Table 17, including Waste Sites WP1 – WP3 in the table below. It is proposed that
the same framework will be used to evaluate new waste management site options in
Walsall for possible inclusion in the SAD or AAP, including Waste Sites WP4 – WP9.
There is a copy of the assessment framework in Appendix 8a. New waste
management options will also be subject to sustainability appraisal.
However, the SAD and AAP can only allocate land for waste management
infrastructure if the proposal is deliverable. No waste management sites were put
forward through the “call for sites” during September – November 2011 except for
the Land at Yorks Bridge (Waste Site). The only other proposals currently identified
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are those in the Core Strategy and others that either have planning permission or
that the Council has identified as having potential. However it is possible that
operators might want to put forward other proposals, or may approach the Council
for advice on identifying a suitable employment site for a new facility.
Waste operators seeking to put forward a site for allocation in the SAD will be
expected to provide enough information to allow the Council to assess it. The
Evidence section below summarises the information we would like them to provide.
While all proposals put forward will be considered, those that do not include enough
information are likely to score poorly in the assessments.
Waste Questions – Delivery of New Waste Infrastructure:
W:Q8 Do you agree that the SAD should allocate sites for new waste
management infrastructure expected to be delivered by 2026, including the
three proposals already identified in the Core Strategy?
Supplementary Questions:
W:Q8A If you do not agree that the SAD should allocate sites for new waste
management infrastructure, what alternative approach would you suggest?
Please provide evidence in support of your suggestions.
W:Q8B Do you agree that sites being considered for allocation in the SAD should
be assessed using the criteria in Core Strategy Policy WM4?
W:Q9 Do you have any comments on the Potential Waste Site Allocations
(WP1 – WP9) identified on Map W2 and the Ward Maps?
Supplementary Questions:
W:Q9A Do you think any sites should be omitted or added other than those we
have shown on the maps and listed in the Waste Technical Appendix? Please
provide supporting evidence if you think we should add or delete any sites.
Please refer to the Evidence Base section below for details of the supporting
information that should be provided with any new sites you wish to put forward.
W:Q9B Do you have any comments on the boundaries of any of the Potential
Waste Site Allocations shown on Map W2 and on the Ward Maps? If you wish to
suggest alternative boundaries for a site, please provide evidence in support of
your proposal.
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W:Q9C Should any of the sites shown on the maps and listed in the Waste
Technical Appendix be allocated for a different type of facility or an alternative
land use? If so, please explain why you think the site should be used for
something different.
W:Q9D Can you think of any barriers that could hinder or prevent the delivery of
any of the proposals shown on the maps and in the Waste Technical Appendix?
Please provide evidence in support of your comments.
W:Q9E Do you agree that all sites being considered for potential waste
management development allocations in the SAD, including those we have
identified, should be assessed using the assessment framework developed for
the Core Strategy, in addition to sustainability appraisal? If you do not agree with
this approach, what alternative evaluation method would you suggest?
(d) Suitable Waste Management Locations in Walsall
BCCS Policy WM4 identifies retained employment areas as locations suitable for the
development of enclosed waste management facilities, and sets out criteria for
assessing the suitability of new proposal. We have noted above (Issue (b) that site
allocations for employment will play an important role in safeguarding existing waste
management infrastructure. Allocating land for long-term retention in employment
use will also ensure that sufficient sites are likely to be available to meet any
remaining requirements over and above any sites we might allocate for waste
management use, and any future requirements we cannot identify at the moment.
The BCCS sets out guidance on the types of facilities likely to be suitable on different
categories of employment land (Policy WM4, also reflected in Policies EMP2 and
EMP3). The SAD could provide more locally-specific guidance for Walsall, reflecting
the Council’s proposed approach towards industrial land supply (see Chapter 5:
Land for Industry). We have identified two alternative options for identifying
Suitable Waste Management Locations in Walsall for future developments –
see Waste Option 3 (3a and W3b) in the Options section below.
The Council has reviewed the guidance in the BCCS Policies EMP2, EMP3 and
WM4, following the Walsall Employment Land Review Update (2012) and the
identification of proposed employment land allocations for the SAD (See Chapter 4:
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Land for Industry). In Table 8.8a below we have identified the types of enclosed
waste management facilities likely to be suitable on each category of employment
land proposed for long-term retention in Walsall. These are facilities that would
normally be enclosed either within a building or fenced enclosure to screen them
from neighbouring uses. This could form the basis of a policy in the SAD.
Table 8.8a: Proposed Employment Land Categories in Walsall - Enclosed
Waste Recycling, Recovery and Treatment Facilities Likely to be Suitable
Existing and Potential High
Quality
Material Recycling Facility (MRF)
In-Vessel Composting (IVC)*
Anaerobic Digestion (AD)
Combined Technologies Mechanical Biological Treatment
(MBT) and Mechanical Heat
Treatment (MHT)
Energy Recovery Facility
Small-Scale Biomass Power Plant
Advanced Thermal Treatment
(pyrolysis and gasification)
Household Waste Recycling Centre
(HWRC)
Ancillary Facilities at Industrial
Sites
Local Quality
Material Recycling Facility (MRF)
In-Vessel Composting (IVC)*
Anaerobic Digestion (AD)
Metal Recycling Site (MRS)
Combined Technologies Mechanical Biological Treatment
(MBT) and Mechanical Heat
Treatment (MHT)
Energy Recovery Facility
Small-Scale Biomass Power Plant
Advanced Thermal Treatment
(pyrolysis and gasification)
Hazardous Waste Treatment
Thermal Treatment (With or
Without Energy Recovery)
Transfer Station/ Skip Hire
CD&EW Recycling
Vehicle Dismantler
End of Life Vehicle (ELV)
Depollution
Scrap Yard
Open Storage
Consider for Release
Transfer Station/ Skip Hire
Vehicle Dismantler
End of Life Vehicle (ELV)
Depollution
Scrap Yard
Open Storage
Temporary Contaminated Soil
Treatment
Source: BCCS Policies EMP2, EMP3 and WM4, Walsall Employment Land Review Update (2012)
*On sites within 250m of “sensitive receptors” (which can include other industrial premises) a risk
assessment must be carried out demonstrating that bio-aerosols can be satisfactorily controlled and
will not present a risk to health or to the environment. The Environment Agency will not grant a permit
for an IVC within 250m of “sensitive receptors” without an assessment.
The SAD could also go further by identifying specific employment areas in Walsall
likely to be suitable for particular types of facilities. An important consideration for
any waste facility is accessibility, so locations with good access to transport
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networks, or with potential to have good access, are likely to be most suitable. For
example, Darlaston, where major transport improvements are planned, has already
been identified as a suitable location for all types of waste management facility (see
Chapter 10: Lad for Transport). Three Strategic Sites at Bentley Road South (EMR
(WS5), Veolia (WS11) and G & P Batteries (WS4)) have already formed a resource
recovery “cluster” in this area. Darlaston was also identified in the as an area with
significant potential for new waste infrastructure, in a study carried out in 2009 on
behalf of the former regional development agency.8
This potential was recognised in the Darlaston Local Development Order (LDO)
2012 which permits sui generis waste management land uses on certain sites
(Subzone A) - see Chapter 4: Land for Industry for details of the extent of the LDO
area and Subzones. As the LDO only has effect until April 2015, we need to consider
whether the SAD should provide guidance on waste management development in
Darlaston beyond that timeframe. Map 8.1 above shows that there are other
employment areas with several waste facilities, such as Aldridge, Ashmore Lake,
Owen Road, Coppice Side and Gatehouse Trading Estate.
BCCS Policy WM4 recognises that there are other waste management facilities that
cannot normally be enclosed within a building and require an open site, possibly in
the Green Belt. Examples of facilities that might require an open site are identified in
the policy. Other facilities that may need to be accommodated on open land in
Walsall could include facilities for agricultural waste management and waste water
treatment. We have reviewed the potential requirements in the light of the emerging
Table W8b below indicates which types of facility might require an open site in
Walsall and what types of site could accommodate them.
The SAD could include guidance on the types of operation suitable on different types
of open land in the borough. However, some of the operations identified in the table
may not be subject to planning control, for example, where they are very small scale
(de minimis) operations ancillary to an existing lawful land use. Many of the
8
The Regional Approach to Landfill Diversion Infrastructure (2009), DTZ and SLR for former
Advantage West Midlands
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operations are also likely to be temporary (e.g. infilling of former mines, quarries and
other voids, use of excavation waste for landscaping).
Table 8.8b: Types of Open Land in Walsall – Open Air Waste Management
Operations Likely to be Suitable
Green Belt
Urban Open Space
Vacant Previously Developed
Land
Use of clean inert waste soils
where required for landscaping,
land remediation and habitat
creation
Use of inert and non-hazardous
wastes to infill voids created by
mining and quarrying
CD&EW recycling at quarries
Commercial open windrow
composting
Small-scale composting associated
with garden centres, nurseries etc.
Small-scale facilities on farms or at
equestrian establishments for
managing agricultural waste
Waste water treatment
Surplus storm and flood water
management (subject to flood risk
assessment)
Use of clean inert waste soils
where required for landscaping,
land remediation and habitat
creation
Small-scale composting associated
with parks, recreation grounds and
allotments
Waste water treatment
Surplus storm and flood water
management (subject to flood risk
assessment)
Use of clean inert waste soils
where required for landscaping,
land remediation and habitat
creation
Use of inert and non-hazardous
wastes to infill and stabilise voids
created by historic mining and
quarrying activities
Use of inert construction and
demolition wastes for infilling of
other voids such as railway cuttings
Use of recycled aggregate for
building and engineering projects
Source: BCCS Policy WM4
All unidentified proposals that come forward as planning applications are assessed
against the criteria in BCCS Policy WM4. We have not identified any need to refine
this guidance to make it more specific to Walsall, as the criteria already allow local
considerations to be taken into account. The Black Country Validation Checklist
provides further guidance to applicants on the information they need to include in a
supporting statement with a planning application to demonstrate compliance with
BCCS Policy WM4 (Item V34 on the Checklist).
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Waste Questions – Suitable Waste Management Locations in Walsall
WQ10 Are there any areas in Walsall that are particularly suitable for new
waste management facilities? If so, which areas are suitable, and what sort
of facilities should be developed there?
Supplementary Questions:
QW10A Does Table 8.8a provide appropriate guidance on the types of indoor
waste management operations that could be accommodated on different
categories of employment land in Walsall? If not, what changes would you
suggest, and why?
QW10B Does Table 8.8b provide appropriate guidance on the types of open air
waste management operations that could take place on different categories of
open land in Walsall? If not, what changes would you suggest, and why?
QW10C Are there any areas in Walsall that are particularly suitable for indoor or
open air waste recycling, recovery and treatment facilities? Please give reasons
for your suggestions.
WQ11 Does waste management have the potential to affect health, the
environment, businesses, the amenity of local communities or other
infrastructure (e.g. the highway network) in Walsall? Please indicate which
operations could have positive and negative effects and provide evidence
in support of your views.
QW11A Do you agree that the criteria in Core Strategy Policy WM4 provide a
sound basis for assessing waste management development proposals, enabling
the Council to identify any potential harmful effects that need to be addressed to
make them acceptable? If not, what alternative approach would you suggest?
8.4
Evidence Base
Future Waste Management Requirements
The main sources of evidence used to identify future waste management
requirements in Walsall are as follows:
•
BCCS Waste Planning Study (2009), Atkins;
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•
April 2013
BCCS Waste Background Paper 2 and Appendices (2010), Black Country
Authorities;
•
Walsall AMR 2012 (2013), Walsall Council;
•
Waste Data Overview (2011), Defra.
These studies have themselves used a wide range of published and unpublished
data, including information derived from the Council’s own monitoring system for
waste development planning applications, the latest Defra statistical releases on
Local Authority Collected Waste (2011/12) and Environment Agency Waste Data
Interrogator and Hazardous Waste Interrogator (2011).
It is anticipated that the responses to the consultation on this paper will be helpful
in identifying other sources of information that could point to unmet needs for
waste infrastructure, which could be addressed in the SAD. As part of the
national waste review, Defra has also recently launched a “call for evidence” on a
Waste Prevention Programme for England (February 2013), which includes
questions aimed at businesses including the construction industry. The
responses to this consultation may also be informative.
Waste Management Infrastructure
The main sources of evidence used to identify existing waste management
infrastructure in Walsall are as follows:
•
West Midlands Waste Capacity Database (2009), former WMRA
•
Environment Agency Waste Data Interrogator 2007 – 2010
•
Walsall Council Waste Application Monitoring Database;
•
Walsall Council planning register;
•
England’s Waste Infrastructure – Report and Data Tables (2010), Defra and
Environment Agency
•
Environment Agency Public Register
•
Walsall Council Pollution Control Public Register
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The Council has developed a database of waste sites which will be further enhanced
during the next stage of the SAD preparation process to provide a more up-to-date
and accurate estimate of Walsall’s waste management capacity, which will reflect the
categorisation of sites recommended in the CLG guidance on the application of the
Waste Framework Directive (2012). This should confirm whether our interim
assumptions about existing capacity are correct, allowing the Council to plan for any
additional requirements identified as a result.
Potential Waste Site Allocations
The main sources of evidence used to identify potential waste site allocations are as
follows:
•
Walsall Council Waste Application Monitoring Database;
•
Walsall Council planning register;
•
Call for Sites Database.
All proposals identified will be assessed using the framework developed for the
BCCS which can be found in the BCCS Waste Background 2, Appendix 6. All
potential site allocation options will also be subjected to sustainability appraisal. The
outcome of these assessments will inform the Council’s decisions over which sites (if
any) should be allocated in the SAD.
To assist with the appraisal process, operators seeking to put forward a new waste
management development proposal for allocation in the SAD will be expected to
provide the information in the box below.
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New Waste Management Development Proposals:
Information Requirements
All proposals put forward for consideration should include the following information:
•
•
•
•
•
•
•
•
•
•
Plan of site with boundary shown;
Types of waste to be managed;
Waste stream/ source of waste to be managed;
Type of facility proposed (recycling, recovery, treatment, disposal);
Estimated annual throughput capacity (tonnes per annum);
For landfill sites, estimated void space (cubic metres) and projected lifespan;
Type of technology proposed if known;
End products from recycling, recovery or treatment and proposed fate;
Reasons for choice of facility/ technology proposed;
Proposed mitigation and enhancement measures where required.
Suitable Waste Management Locations in Walsall
The main sources of evidence used to identify locations likely to be suitable for
different types of waste management facilities are as follows:
•
Planning for Waste Management Facilities (2004), Enviros for ODPM;
•
PPS10 (2011), paragraphs 20 – 21 and Annex E;
•
EfW Development Guidance (2012), WRAP;
•
Energy from Waste – A Guide to the Debate and Updated Municipal Waste
Technology Profiles (2013), Defra;
•
BCCS Waste Planning Study (2009), Atkins;
•
BCCS – guidance in Policies EMP2, EMP3 and WM4;
•
Walsall Employment Land Review Update (2012), Roger Tym & Partners;
•
Walsall Council Open Space Audit Update (2012), Walsall Council.
These documents have helped us to identify the types of area in Walsall likely to be
suitable for and/ or have potential for development of different types of indoor and
open air waste management facilities.
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8.5 Conclusions
Having regard to national and local policy requirements and using the best evidence
available, we are proposing to include the following in the SAD:
•
Waste Management Targets – targets for provision of new waste
management capacity in Walsall, based on the landfill diversion targets in the
BCCS and recycling targets set by the Waste Framework Directive;
•
Waste Sites to be Safeguarded – identification of waste sites in Walsall to
be safeguarded from potential loss or encroachment by other uses, including
Strategic Sites, that because of their scale and function, are important
elements of Walsall’s existing waste management infrastructure;
•
Waste Management Site Allocations – site allocation policies for sites
where new waste management infrastructure will be developed during the
plan period, which will make an important contribution towards meeting local
and national targets for landfill diversion and recycling of waste;
•
Guidance on Suitable Waste Management Locations – locally specific
guidance on where new waste management infrastructure not allocated in the
SAD could be developed in Walsall during the plan period.
Map 8.1 shows the distribution of existing waste sites in the borough and what types
of facilities we have. Map 8.2 shows the location of existing and proposed Strategic
Sites and Potential Waste Management Site Allocations which the Council is
currently considering. Other sites could also come forward for consideration during
the preparation of the SAD. All sites identified will be assessed for suitability and
subjected to sustainability appraisal before the Council decides whether or not they
should be allocated in the SAD.
8.6 Options
We have identified a number of options for delivery of the BCCS waste management
requirements in Walsall, which are summarised in the table below. One of the
options identified (Waste Option 1 (1d only)) is not considered to be a reasonable
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option – see Appendix 12a. This Option is shaded in pale blue in the Options table
below. However, we have identified “reasonable” alternative options for setting local
targets for future waste management requirements, the approach towards
safeguarding Walsall’s waste management infrastructure, and the identification of
suitable locations for new waste infrastructure.
Waste Questions – Options:
W:Q12 Which of the alternative options for Future Waste Management
Requirements, Safeguarding Walsall’s Existing Waste Infrastructure and
Suitable Waste Development Locations in Walsall do you prefer and why?
W:Q13 Are there any other options for waste management development in
Walsall that we have not identified? Please provide details and explain why
you think we should consider these options.
WASTE OPTION 1: FUTURE WASTE MANAGEMENT REQUIREMENTS
Option 1a:
Waste Recovery Targets
The SAD would set general waste
management targets for delivery of
new municipal waste recovery capacity
for paper, card, cans, glass, plastics,
food waste, and/ or green garden
waste, which could met through
delivery of any recycling, composting
or energy recovery facilities.
IMPLICATIONS
This would provide greater flexibility for
the waste industry, and greater likelihood
that the targets would be met, as any type
of municipal waste recovery infrastructure
would be able to contribute. However, it
may not necessarily drive waste further
up the Waste Hierarchy, because the
target could be met entirely through new
energy recovery infrastructure, which is
only just above waste disposal in the
hierarchy. New energy recovery capacity
would also not contribute towards the
Landfill Directive target for municipal
waste re-use and recycling.
Option 1b:
Waste Recycling Targets
The waste management targets in the
SAD would be based on delivery of
new municipal waste recycling and
composting capacity only, for the same
waste types as Option 1a (paper, card,
cans, glass, plastics, food waste, and/
or green garden waste). Such a target
would help Walsall to meet the Waste
Framework Directive for re-use and
IMPLICATIONS
This could help drive waste further up the
Waste Hierarchy, as only recycling and
composting capacity would contribute
towards the target. It would also ensure
that any new capacity delivered would
contribute towards the Landfill Directive
target for municipal waste re-use and
recycling as well as towards the BCCS
target for landfill diversion. However, as
any schemes that come forward must be
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recycling of municipal waste.
market driven rather than being led by the
Council, economic viability is an important
consideration. If it is not economically
viable to develop new recycling and
composting infrastructure in Walsall, it will
not be delivered and the targets will not
be met.
Option 1c:
Additional Target for CD&EW
Recycling
This would be in addition to Option 1a
or 1b. Such a target could be included
if additional CD&EW capacity is
needed to meet the Waste Framework
Directive target for re-use and
recycling of non-hazardous
construction and demolition waste.
IMPLICATIONS
At the moment, Walsall has only limited
capacity for recycling of CD&EW. Due to
the limitations of the data available, it is
uncertain how much waste is likely to
arise from this stream over the plan
period, and therefore, what targets should
be set. However, if we had increased
capacity, it would be more likely that
Walsall would meet the Waste
Framework Directive target for re-use and
recycling of non-hazardous construction
and demolition waste. Having the
capacity to recycle more of the CD&EW
generated by local development projects
would also be more sustainable than
having to transport the material to
recycling sites in other areas. Walsall
could also produce more recycled
aggregate locally, helping to reduce
reliance on other areas for supply of
construction aggregates (see Chapter
10).
Option 1d:
No Waste Management Targets
The SAD would not set any local
targets for waste management in
support of meeting the targets
identified in the BCCS and Waste
Framework Directive.
IMPLICATIONS
This is not regarded as a “reasonable”
option – see Appendix 12a.
WASTE OPTION 2: SAFEGUARDING WALSALL’S EXISTING WASTE
INFRASTRUCTURE
Option 2a:
Prioritise Safeguarding of Existing
Strategic Sites
This would involve showing the
boundaries of Strategic Sites on the
Policies Map for Walsall, but not other
waste sites. There would be a linked
Walsall Council
IMPLICATIONS
This option would give priority to
safeguarding the most important waste
sites in Walsall, whose loss would have
significant effects on the borough’s waste
management capacity. It will be important
to check that we only include Strategic
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site allocation policy in the SAD
explaining how BCCS Policy WM2 will
be applied.
Sites likely to remain in place throughout
the plan period, and not vacant sites that
are unlikely to be re-used or sites
expected to close in the foreseeable
future. The Council is proposing to
undertake further checking of the
planning histories and current operational
status of all of the sites in the Waste
Technical Appendix. However, BCCS
Policy WM2 seeks to safeguard all waste
sites from needless loss, not just
Strategic Sites, although it does not give
any indication of where the non-strategic
waste sites are. BCCS employment land
protection policies (DEL2, EMP2 and
EMP3), would provide a certain amount
of protection for non-strategic waste sites
located within them. Even so, when
planning non-waste developments in or
near to industrial areas, the onus is on
applicants to check whether there are any
waste facilities nearby. Potential issues of
conflict may not become apparent until
after a new scheme has been designed,
and it may be more difficult to “retro-fit”
mitigation measures into it, to safeguard
the waste site and/ or protect the amenity
of the occupiers of the new scheme.
Option 2b:
Safeguard All Existing Waste Sites
As well as Strategic Sites (site
boundaries), the location of nonstrategic sites would be shown on the
Policies Map for Walsall (symbols
only). There would be a linked site
allocation policy in the SAD explaining
how BCCS Policy WM2 will be applied.
IMPLICATIONS
This option would give greater scope to
protect smaller waste management sites
which could be important for managing
waste from local communities and
businesses. Developers seeking to build
other types of development nearby would
be aware of the existence of the site, and
would be able to identify and deal with
potential issues of conflict early on. As
with Option 2a, we should only identify
waste sites likely to remain in place
throughout the plan period on the Policies
Map. Although it would give greater
protection to non-strategic waste sites,
this option would still only provide a
“snapshot” of the situation at the time the
SAD was prepared. It would not be
possible for the Policies Map to reflect
changes that occur after the SAD is
adopted, such as closure of existing sites
Walsall Council
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and development of new site but such
changes could be reported in the AMR.
WASTE OPTION 3: SUITABLE WASTE MANAGEMENT LOCATIONS IN
WALSALL
Option 3a:
Rely on BCCS Policies and SAD
Allocations and Designations
The SAD Policies Map will define the
areas of Existing and Potential High
Quality and Local Quality industrial
land to which BCCS Policies EMP2,
EMP3 and WM4 apply. The Policies
Map will also define “Consider for
Release” industrial sites, areas of
Urban Open Space, and the extent of
the Green Belt. However, there will be
no locally-specific guidance on where
different types of waste facilities could
be located within the borough.
Option 3b: SAD to Provide
Additional Guidance
As well as defining the areas of
Walsall Council
IMPLICATIONS
BCCS Policies EMP2, EMP3 and WM4
already provide guidance on the types of
location that would be appropriate for
different types of waste facility. However,
the BCCS does not identify specific areas
in Walsall, other than the “broad
locations” for Existing and Potential High
Quality and Retained Local Quality
employment land identified on the
Economy and Waste Key Diagrams. As
these are only intended to be indicative
and are not defined in detail, the SAD will
define the extent of these types of
employment areas in Walsall, as well as
other areas where there is more flexibility,
such as the “Consider for Release”
category of sites (see Chapter 5). The
SAD will also show areas that could
accommodate facilities requiring an open
site, such as areas of Urban Open Space
and the Green Belt. However, some
uncertainties would remain, because the
BCCS does not identify any uses suitable
on “Consider for Release” sites, and does
not identify any specific locations in
Walsall that could be suitable for
particular types of facility. Some
proposals might therefore come forward
in less appropriate locations. However, all
applications would still be assessed
against the criteria in BCCS Policy WM4
and would be expected to demonstrate
compliance with local and national
objectives, including the requirement to
apply the Waste Hierarchy and avoid
harm to health and the environment, and
the need to safeguard the amenity of
neighbouring communities.
IMPLICATIONS
This option would provide greater
certainty for the waste industry because it
would give clear indications as to which
types of waste facility would considered
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Existing and Potential High Quality,
Local Quality and “Consider for
Release” industrial sites, areas of
Urban Open Space, and the extent of
the Green Belt on the Policies Map for
Walsall, the SAD will provide guidance
on the types of waste facilities
considered suitable on these types of
site allocations/ designations. The SAD
will also identify specific locations in
Walsall which would be suitable for
particular types of facility.
Walsall Council
April 2013
suitable – in principle - on different types
of land allocated on the Policies Map for
Walsall, including types of land not
specifically identified in the BCCS such
as the “Consider for Release”
employment sites. Identifying specific
locations in the borough as being
particularly suitable for the development
of specified types of facility – in principle would also be of potential assistance to
waste operators seeking to find a suitable
site in the area. All applications would
also be assessed against the criteria in
BCCS Policy WM4, and would be
expected to demonstrate compliance with
local and national objectives, including
the requirement to apply the Waste
Hierarchy, avoid harm to health and the
environment, and safeguard the amenity
of neighbouring communities
199