Sandwell Local Plan - Reg 19 Publication

Duty to Cooperate

WMRTAB is pleased to confirm that Sandwell Metropolitan Borough Council is an active member of WMRTAB and an officer from the Council regularly attends the group’s meeting and contributes to its work. WMRTAB has therefore facilitated discussion between Sandwell Metropolitan Borough Council and other neighbouring waste planning authorities to assist with meeting its Duty to Cooperate (DtC) on matters pertaining to the planning for waste management. Furthermore Sandwell Council is a signatory to the WMRTAB Statement of Common Ground.

Planning for Waste Management

WMRTAB is pleased to see that the important matter of waste management has been planned for in the Local Plan and considers that the Vision and Objectives broadly address issues associated with waste management which will arise during the SLP period. WMRTAB also supports the inclusion of a chapter dedicated to waste (and minerals) (Chapter 13). WMRTAB welcomes the fact the SLP addresses the management of all forms of waste (paragraph 13.6).

WMRTAB notes and broadly welcomes policy which:
• Encourages development to utilise heat and energy generated from energy from waste facilities (Policy SCC2);
• encourages reduction of waste from construction (Policy SCC3 and Policy SWA1);
• encourages design of buildings to ensure ease of end of life disassembly and material reuse (policy SCC4);
• requires all new development to consider in detail how waste will be minimised, managed and utilised in construction e.g. recycled materials
(Policy SWA5);
• requires Local Employment Areas to be safeguarded for various uses which includes waste collection, transfer and recycling uses (Policy SEC3);
• sets out the overall strategy for waste management and identifies how much new waste management capacity is likely to be needed (Policy SWA1);
• expects waste to be managed in accordance with the waste hierarchy and the proximity principle (Policy SWA1);
• allows for capacity to be developed which will ensure waste can be managed in accordance with the waste hierarchy and will reduce reliance on other authority areas (Policy SWA1);
• encourages collaborative working with neighbouring authorities ‘who import waste into, or export waste out of, Sandwell, to ensure a cooperative cross boundary approach to waste management is maintained’ (Policy SWA1);
• gives priority to the safeguarding of existing and allocated sites for their continued use and the retention of the local employment areas in which they occur (Policy SEC3 and Policy SWA2);
• protects existing sites from encroachment by other forms of development and requires a ‘Waste Site Impact Assessment’ for development proposals which might impact on the effective operation of existing waste sites (Policy SWA2). WMRTAB notes that the addition of a reference to the ‘agent of change’ principle, mentioned in the NPPF, in paragraph 13.41, might provide further clarification/support for this approach. WMRTAB considers that to ensure the effectiveness of this policy, this requirement should be extended to development proposed proximate to preferred locations allocated for waste management use in the Local Plan.

WMRTAB makes the following further comments which are intended to help ensure the effectiveness of the Plan:
• The term ‘Major’ should be defined in clause 1. c. of Policy SHW1 It is recommended that such a definition considers site area and waste
throughput;
• to avoid ambiguity and ensure the objectives of the Plan are met, WMRTAB suggests that the term ‘maximum’ replaces ‘existing’ in clause 1 of Policy SWA2 to read:
‘Sandwell will safeguard all existing strategic and other waste management facilities from inappropriate development, to maintain existing maximum
levels of waste management capacity and meet Strategic Objective 17, unless it can be demonstrated that:…..’
It is considered that this change will improve the effectiveness of the policy by clarifying that the maximum throughput of a facility should be safeguarded;
• WMRTAB notes that paragraph 3.53 of the Plan suggests that ‘negative environmental impacts’ ‘generally accompany’ waste management
operations. WMRTAB does not agree with this statement as, while waste management operations are generally industrial in their appearance, modern waste management facilities do not ‘generally’ result in ‘negative environmental impacts’. WMRTAB request that this statement be modified
as, without modification, this may make it unduly challenging for proposals for waste management facilities to be granted planning permission in
accordance with the policies of the SLP.

WMRTAB has the following additional comments:
• WMRTAB notes and broadly supports the manner in which waste management capacity gaps have been identified. This includes the fact that
waste management capacity requirements have been assessed with the objective of achieving net self-sufficiency;
• WMRTAB notes and supports:
o the separate consideration of waste imports and exports at paragraphs 13.25 to 13.28;
o clarification of the contents of, a Waste Site Impact Assessments in paragraph 13.42.

Duty to Cooperate

WMRTAB is pleased to confirm that Sandwell Metropolitan Borough Council is an active member of WMRTAB and an officer from the Council regularly attends the group’s meeting and contributes to its work. WMRTAB has therefore facilitated discussion between Sandwell Metropolitan Borough Council and other neighbouring waste planning authorities to assist with meeting its Duty to Cooperate (DtC) on matters pertaining to the planning for waste management. Furthermore Sandwell Council is a signatory to the WMRTAB Statement of Common Ground.

Planning for Waste Management

WMRTAB is pleased to see that the important matter of waste management has been planned for in the Local Plan and considers that the Vision and Objectives broadly address issues associated with waste management which will arise during the SLP period. WMRTAB also supports the inclusion of a chapter dedicated to waste (and minerals) (Chapter 13). WMRTAB welcomes the fact the SLP addresses the management of all forms of waste (paragraph 13.6).

WMRTAB notes and broadly welcomes policy which:
• Encourages development to utilise heat and energy generated from energy from waste facilities (Policy SCC2);
• encourages reduction of waste from construction (Policy SCC3 and Policy SWA1);
• encourages design of buildings to ensure ease of end of life disassembly and material reuse (policy SCC4);
• requires all new development to consider in detail how waste will be minimised, managed and utilised in construction e.g. recycled materials
(Policy SWA5);
• requires Local Employment Areas to be safeguarded for various uses which includes waste collection, transfer and recycling uses (Policy SEC3);
• sets out the overall strategy for waste management and identifies how much new waste management capacity is likely to be needed (Policy SWA1);
• expects waste to be managed in accordance with the waste hierarchy and the proximity principle (Policy SWA1);
• allows for capacity to be developed which will ensure waste can be managed in accordance with the waste hierarchy and will reduce reliance on other authority areas (Policy SWA1);
• encourages collaborative working with neighbouring authorities ‘who import waste into, or export waste out of, Sandwell, to ensure a cooperative cross boundary approach to waste management is maintained’ (Policy SWA1);
• gives priority to the safeguarding of existing and allocated sites for their continued use and the retention of the local employment areas in which they occur (Policy SEC3 and Policy SWA2);
• protects existing sites from encroachment by other forms of development and requires a ‘Waste Site Impact Assessment’ for development proposals which might impact on the effective operation of existing waste sites (Policy SWA2). WMRTAB notes that the addition of a reference to the ‘agent of change’ principle, mentioned in the NPPF, in paragraph 13.41, might provide further clarification/support for this approach. WMRTAB considers that to ensure the effectiveness of this policy, this requirement should be extended to development proposed proximate to preferred locations allocated for waste management use in the Local Plan.

WMRTAB makes the following further comments which are intended to help ensure the effectiveness of the Plan:
• The term ‘Major’ should be defined in clause 1. c. of Policy SHW1 It is recommended that such a definition considers site area and waste
throughput;
• to avoid ambiguity and ensure the objectives of the Plan are met, WMRTAB suggests that the term ‘maximum’ replaces ‘existing’ in clause 1 of Policy SWA2 to read:
‘Sandwell will safeguard all existing strategic and other waste management facilities from inappropriate development, to maintain existing maximum
levels of waste management capacity and meet Strategic Objective 17, unless it can be demonstrated that:…..’
It is considered that this change will improve the effectiveness of the policy by clarifying that the maximum throughput of a facility should be safeguarded;
• WMRTAB notes that paragraph 3.53 of the Plan suggests that ‘negative environmental impacts’ ‘generally accompany’ waste management
operations. WMRTAB does not agree with this statement as, while waste management operations are generally industrial in their appearance, modern waste management facilities do not ‘generally’ result in ‘negative environmental impacts’. WMRTAB request that this statement be modified
as, without modification, this may make it unduly challenging for proposals for waste management facilities to be granted planning permission in
accordance with the policies of the SLP.

WMRTAB has the following additional comments:
• WMRTAB notes and broadly supports the manner in which waste management capacity gaps have been identified. This includes the fact that
waste management capacity requirements have been assessed with the objective of achieving net self-sufficiency;
• WMRTAB notes and supports:
o the separate consideration of waste imports and exports at paragraphs 13.25 to 13.28;
o clarification of the contents of, a Waste Site Impact Assessments in paragraph 13.42.

Duty to Cooperate

WMRTAB is pleased to confirm that Sandwell Metropolitan Borough Council is an active member of WMRTAB and an officer from the Council regularly attends the group’s meeting and contributes to its work. WMRTAB has therefore facilitated discussion between Sandwell Metropolitan Borough Council and other neighbouring waste planning authorities to assist with meeting its Duty to Cooperate (DtC) on matters pertaining to the planning for waste management. Furthermore Sandwell Council is a signatory to the WMRTAB Statement of Common Ground.

Planning for Waste Management

WMRTAB is pleased to see that the important matter of waste management has been planned for in the Local Plan and considers that the Vision and Objectives broadly address issues associated with waste management which will arise during the SLP period. WMRTAB also supports the inclusion of a chapter dedicated to waste (and minerals) (Chapter 13). WMRTAB welcomes the fact the SLP addresses the management of all forms of waste (paragraph 13.6).

WMRTAB notes and broadly welcomes policy which:
• Encourages development to utilise heat and energy generated from energy from waste facilities (Policy SCC2);
• encourages reduction of waste from construction (Policy SCC3 and Policy SWA1);
• encourages design of buildings to ensure ease of end of life disassembly and material reuse (policy SCC4);
• requires all new development to consider in detail how waste will be minimised, managed and utilised in construction e.g. recycled materials
(Policy SWA5);
• requires Local Employment Areas to be safeguarded for various uses which includes waste collection, transfer and recycling uses (Policy SEC3);
• sets out the overall strategy for waste management and identifies how much new waste management capacity is likely to be needed (Policy SWA1);
• expects waste to be managed in accordance with the waste hierarchy and the proximity principle (Policy SWA1);
• allows for capacity to be developed which will ensure waste can be managed in accordance with the waste hierarchy and will reduce reliance on other authority areas (Policy SWA1);
• encourages collaborative working with neighbouring authorities ‘who import waste into, or export waste out of, Sandwell, to ensure a cooperative cross boundary approach to waste management is maintained’ (Policy SWA1);
• gives priority to the safeguarding of existing and allocated sites for their continued use and the retention of the local employment areas in which they occur (Policy SEC3 and Policy SWA2);
• protects existing sites from encroachment by other forms of development and requires a ‘Waste Site Impact Assessment’ for development proposals which might impact on the effective operation of existing waste sites (Policy SWA2). WMRTAB notes that the addition of a reference to the ‘agent of change’ principle, mentioned in the NPPF, in paragraph 13.41, might provide further clarification/support for this approach. WMRTAB considers that to ensure the effectiveness of this policy, this requirement should be extended to development proposed proximate to preferred locations allocated for waste management use in the Local Plan.

WMRTAB makes the following further comments which are intended to help ensure the effectiveness of the Plan:
• The term ‘Major’ should be defined in clause 1. c. of Policy SHW1 It is recommended that such a definition considers site area and waste
throughput;
• to avoid ambiguity and ensure the objectives of the Plan are met, WMRTAB suggests that the term ‘maximum’ replaces ‘existing’ in clause 1 of Policy SWA2 to read:
‘Sandwell will safeguard all existing strategic and other waste management facilities from inappropriate development, to maintain existing maximum
levels of waste management capacity and meet Strategic Objective 17, unless it can be demonstrated that:…..’
It is considered that this change will improve the effectiveness of the policy by clarifying that the maximum throughput of a facility should be safeguarded;
• WMRTAB notes that paragraph 3.53 of the Plan suggests that ‘negative environmental impacts’ ‘generally accompany’ waste management
operations. WMRTAB does not agree with this statement as, while waste management operations are generally industrial in their appearance, modern waste management facilities do not ‘generally’ result in ‘negative environmental impacts’. WMRTAB request that this statement be modified
as, without modification, this may make it unduly challenging for proposals for waste management facilities to be granted planning permission in
accordance with the policies of the SLP.

WMRTAB has the following additional comments:
• WMRTAB notes and broadly supports the manner in which waste management capacity gaps have been identified. This includes the fact that
waste management capacity requirements have been assessed with the objective of achieving net self-sufficiency;
• WMRTAB notes and supports:
o the separate consideration of waste imports and exports at paragraphs 13.25 to 13.28;
o clarification of the contents of, a Waste Site Impact Assessments in paragraph 13.42.

Duty to Cooperate

WMRTAB is pleased to confirm that Sandwell Metropolitan Borough Council is an active member of WMRTAB and an officer from the Council regularly attends the group’s meeting and contributes to its work. WMRTAB has therefore facilitated discussion between Sandwell Metropolitan Borough Council and other neighbouring waste planning authorities to assist with meeting its Duty to Cooperate (DtC) on matters pertaining to the planning for waste management. Furthermore Sandwell Council is a signatory to the WMRTAB Statement of Common Ground.

Planning for Waste Management

WMRTAB is pleased to see that the important matter of waste management has been planned for in the Local Plan and considers that the Vision and Objectives broadly address issues associated with waste management which will arise during the SLP period. WMRTAB also supports the inclusion of a chapter dedicated to waste (and minerals) (Chapter 13). WMRTAB welcomes the fact the SLP addresses the management of all forms of waste (paragraph 13.6).

WMRTAB notes and broadly welcomes policy which:
• Encourages development to utilise heat and energy generated from energy from waste facilities (Policy SCC2);
• encourages reduction of waste from construction (Policy SCC3 and Policy SWA1);
• encourages design of buildings to ensure ease of end of life disassembly and material reuse (policy SCC4);
• requires all new development to consider in detail how waste will be minimised, managed and utilised in construction e.g. recycled materials
(Policy SWA5);
• requires Local Employment Areas to be safeguarded for various uses which includes waste collection, transfer and recycling uses (Policy SEC3);
• sets out the overall strategy for waste management and identifies how much new waste management capacity is likely to be needed (Policy SWA1);
• expects waste to be managed in accordance with the waste hierarchy and the proximity principle (Policy SWA1);
• allows for capacity to be developed which will ensure waste can be managed in accordance with the waste hierarchy and will reduce reliance on other authority areas (Policy SWA1);
• encourages collaborative working with neighbouring authorities ‘who import waste into, or export waste out of, Sandwell, to ensure a cooperative cross boundary approach to waste management is maintained’ (Policy SWA1);
• gives priority to the safeguarding of existing and allocated sites for their continued use and the retention of the local employment areas in which they occur (Policy SEC3 and Policy SWA2);
• protects existing sites from encroachment by other forms of development and requires a ‘Waste Site Impact Assessment’ for development proposals which might impact on the effective operation of existing waste sites (Policy SWA2). WMRTAB notes that the addition of a reference to the ‘agent of change’ principle, mentioned in the NPPF, in paragraph 13.41, might provide further clarification/support for this approach. WMRTAB considers that to ensure the effectiveness of this policy, this requirement should be extended to development proposed proximate to preferred locations allocated for waste management use in the Local Plan.

WMRTAB makes the following further comments which are intended to help ensure the effectiveness of the Plan:
• The term ‘Major’ should be defined in clause 1. c. of Policy SHW1 It is recommended that such a definition considers site area and waste
throughput;
• to avoid ambiguity and ensure the objectives of the Plan are met, WMRTAB suggests that the term ‘maximum’ replaces ‘existing’ in clause 1 of Policy SWA2 to read:
‘Sandwell will safeguard all existing strategic and other waste management facilities from inappropriate development, to maintain existing maximum
levels of waste management capacity and meet Strategic Objective 17, unless it can be demonstrated that:…..’
It is considered that this change will improve the effectiveness of the policy by clarifying that the maximum throughput of a facility should be safeguarded;
• WMRTAB notes that paragraph 3.53 of the Plan suggests that ‘negative environmental impacts’ ‘generally accompany’ waste management
operations. WMRTAB does not agree with this statement as, while waste management operations are generally industrial in their appearance, modern waste management facilities do not ‘generally’ result in ‘negative environmental impacts’. WMRTAB request that this statement be modified
as, without modification, this may make it unduly challenging for proposals for waste management facilities to be granted planning permission in
accordance with the policies of the SLP.

WMRTAB has the following additional comments:
• WMRTAB notes and broadly supports the manner in which waste management capacity gaps have been identified. This includes the fact that
waste management capacity requirements have been assessed with the objective of achieving net self-sufficiency;
• WMRTAB notes and supports:
o the separate consideration of waste imports and exports at paragraphs 13.25 to 13.28;
o clarification of the contents of, a Waste Site Impact Assessments in paragraph 13.42.

Duty to Cooperate

WMRTAB is pleased to confirm that Sandwell Metropolitan Borough Council is an active member of WMRTAB and an officer from the Council regularly attends the group’s meeting and contributes to its work. WMRTAB has therefore facilitated discussion between Sandwell Metropolitan Borough Council and other neighbouring waste planning authorities to assist with meeting its Duty to Cooperate (DtC) on matters pertaining to the planning for waste management. Furthermore Sandwell Council is a signatory to the WMRTAB Statement of Common Ground.

Planning for Waste Management

WMRTAB is pleased to see that the important matter of waste management has been planned for in the Local Plan and considers that the Vision and Objectives broadly address issues associated with waste management which will arise during the SLP period. WMRTAB also supports the inclusion of a chapter dedicated to waste (and minerals) (Chapter 13). WMRTAB welcomes the fact the SLP addresses the management of all forms of waste (paragraph 13.6).

WMRTAB notes and broadly welcomes policy which:
• Encourages development to utilise heat and energy generated from energy from waste facilities (Policy SCC2);
• encourages reduction of waste from construction (Policy SCC3 and Policy SWA1);
• encourages design of buildings to ensure ease of end of life disassembly and material reuse (policy SCC4);
• requires all new development to consider in detail how waste will be minimised, managed and utilised in construction e.g. recycled materials
(Policy SWA5);
• requires Local Employment Areas to be safeguarded for various uses which includes waste collection, transfer and recycling uses (Policy SEC3);
• sets out the overall strategy for waste management and identifies how much new waste management capacity is likely to be needed (Policy SWA1);
• expects waste to be managed in accordance with the waste hierarchy and the proximity principle (Policy SWA1);
• allows for capacity to be developed which will ensure waste can be managed in accordance with the waste hierarchy and will reduce reliance on other authority areas (Policy SWA1);
• encourages collaborative working with neighbouring authorities ‘who import waste into, or export waste out of, Sandwell, to ensure a cooperative cross boundary approach to waste management is maintained’ (Policy SWA1);
• gives priority to the safeguarding of existing and allocated sites for their continued use and the retention of the local employment areas in which they occur (Policy SEC3 and Policy SWA2);
• protects existing sites from encroachment by other forms of development and requires a ‘Waste Site Impact Assessment’ for development proposals which might impact on the effective operation of existing waste sites (Policy SWA2). WMRTAB notes that the addition of a reference to the ‘agent of change’ principle, mentioned in the NPPF, in paragraph 13.41, might provide further clarification/support for this approach. WMRTAB considers that to ensure the effectiveness of this policy, this requirement should be extended to development proposed proximate to preferred locations allocated for waste management use in the Local Plan.

WMRTAB makes the following further comments which are intended to help ensure the effectiveness of the Plan:
• The term ‘Major’ should be defined in clause 1. c. of Policy SHW1 It is recommended that such a definition considers site area and waste
throughput;
• to avoid ambiguity and ensure the objectives of the Plan are met, WMRTAB suggests that the term ‘maximum’ replaces ‘existing’ in clause 1 of Policy SWA2 to read:
‘Sandwell will safeguard all existing strategic and other waste management facilities from inappropriate development, to maintain existing maximum
levels of waste management capacity and meet Strategic Objective 17, unless it can be demonstrated that:…..’
It is considered that this change will improve the effectiveness of the policy by clarifying that the maximum throughput of a facility should be safeguarded;
• WMRTAB notes that paragraph 3.53 of the Plan suggests that ‘negative environmental impacts’ ‘generally accompany’ waste management
operations. WMRTAB does not agree with this statement as, while waste management operations are generally industrial in their appearance, modern waste management facilities do not ‘generally’ result in ‘negative environmental impacts’. WMRTAB request that this statement be modified
as, without modification, this may make it unduly challenging for proposals for waste management facilities to be granted planning permission in
accordance with the policies of the SLP.

WMRTAB has the following additional comments:
• WMRTAB notes and broadly supports the manner in which waste management capacity gaps have been identified. This includes the fact that
waste management capacity requirements have been assessed with the objective of achieving net self-sufficiency;
• WMRTAB notes and supports:
o the separate consideration of waste imports and exports at paragraphs 13.25 to 13.28;
o clarification of the contents of, a Waste Site Impact Assessments in paragraph 13.42.

Duty to Cooperate

WMRTAB is pleased to confirm that Sandwell Metropolitan Borough Council is an active member of WMRTAB and an officer from the Council regularly attends the group’s meeting and contributes to its work. WMRTAB has therefore facilitated discussion between Sandwell Metropolitan Borough Council and other neighbouring waste planning authorities to assist with meeting its Duty to Cooperate (DtC) on matters pertaining to the planning for waste management. Furthermore Sandwell Council is a signatory to the WMRTAB Statement of Common Ground.

Planning for Waste Management

WMRTAB is pleased to see that the important matter of waste management has been planned for in the Local Plan and considers that the Vision and Objectives broadly address issues associated with waste management which will arise during the SLP period. WMRTAB also supports the inclusion of a chapter dedicated to waste (and minerals) (Chapter 13). WMRTAB welcomes the fact the SLP addresses the management of all forms of waste (paragraph 13.6).

WMRTAB notes and broadly welcomes policy which:
• Encourages development to utilise heat and energy generated from energy from waste facilities (Policy SCC2);
• encourages reduction of waste from construction (Policy SCC3 and Policy SWA1);
• encourages design of buildings to ensure ease of end of life disassembly and material reuse (policy SCC4);
• requires all new development to consider in detail how waste will be minimised, managed and utilised in construction e.g. recycled materials
(Policy SWA5);
• requires Local Employment Areas to be safeguarded for various uses which includes waste collection, transfer and recycling uses (Policy SEC3);
• sets out the overall strategy for waste management and identifies how much new waste management capacity is likely to be needed (Policy SWA1);
• expects waste to be managed in accordance with the waste hierarchy and the proximity principle (Policy SWA1);
• allows for capacity to be developed which will ensure waste can be managed in accordance with the waste hierarchy and will reduce reliance on other authority areas (Policy SWA1);
• encourages collaborative working with neighbouring authorities ‘who import waste into, or export waste out of, Sandwell, to ensure a cooperative cross boundary approach to waste management is maintained’ (Policy SWA1);
• gives priority to the safeguarding of existing and allocated sites for their continued use and the retention of the local employment areas in which they occur (Policy SEC3 and Policy SWA2);
• protects existing sites from encroachment by other forms of development and requires a ‘Waste Site Impact Assessment’ for development proposals which might impact on the effective operation of existing waste sites (Policy SWA2). WMRTAB notes that the addition of a reference to the ‘agent of change’ principle, mentioned in the NPPF, in paragraph 13.41, might provide further clarification/support for this approach. WMRTAB considers that to ensure the effectiveness of this policy, this requirement should be extended to development proposed proximate to preferred locations allocated for waste management use in the Local Plan.

WMRTAB makes the following further comments which are intended to help ensure the effectiveness of the Plan:
• The term ‘Major’ should be defined in clause 1. c. of Policy SHW1 It is recommended that such a definition considers site area and waste
throughput;
• to avoid ambiguity and ensure the objectives of the Plan are met, WMRTAB suggests that the term ‘maximum’ replaces ‘existing’ in clause 1 of Policy SWA2 to read:
‘Sandwell will safeguard all existing strategic and other waste management facilities from inappropriate development, to maintain existing maximum
levels of waste management capacity and meet Strategic Objective 17, unless it can be demonstrated that:…..’
It is considered that this change will improve the effectiveness of the policy by clarifying that the maximum throughput of a facility should be safeguarded;
• WMRTAB notes that paragraph 3.53 of the Plan suggests that ‘negative environmental impacts’ ‘generally accompany’ waste management
operations. WMRTAB does not agree with this statement as, while waste management operations are generally industrial in their appearance, modern waste management facilities do not ‘generally’ result in ‘negative environmental impacts’. WMRTAB request that this statement be modified
as, without modification, this may make it unduly challenging for proposals for waste management facilities to be granted planning permission in
accordance with the policies of the SLP.

WMRTAB has the following additional comments:
• WMRTAB notes and broadly supports the manner in which waste management capacity gaps have been identified. This includes the fact that
waste management capacity requirements have been assessed with the objective of achieving net self-sufficiency;
• WMRTAB notes and supports:
o the separate consideration of waste imports and exports at paragraphs 13.25 to 13.28;
o clarification of the contents of, a Waste Site Impact Assessments in paragraph 13.42.

Duty to Cooperate

WMRTAB is pleased to confirm that Sandwell Metropolitan Borough Council is an active member of WMRTAB and an officer from the Council regularly attends the group’s meeting and contributes to its work. WMRTAB has therefore facilitated discussion between Sandwell Metropolitan Borough Council and other neighbouring waste planning authorities to assist with meeting its Duty to Cooperate (DtC) on matters pertaining to the planning for waste management. Furthermore Sandwell Council is a signatory to the WMRTAB Statement of Common Ground.

Planning for Waste Management

WMRTAB is pleased to see that the important matter of waste management has been planned for in the Local Plan and considers that the Vision and Objectives broadly address issues associated with waste management which will arise during the SLP period. WMRTAB also supports the inclusion of a chapter dedicated to waste (and minerals) (Chapter 13). WMRTAB welcomes the fact the SLP addresses the management of all forms of waste (paragraph 13.6).

WMRTAB notes and broadly welcomes policy which:
• Encourages development to utilise heat and energy generated from energy from waste facilities (Policy SCC2);
• encourages reduction of waste from construction (Policy SCC3 and Policy SWA1);
• encourages design of buildings to ensure ease of end of life disassembly and material reuse (policy SCC4);
• requires all new development to consider in detail how waste will be minimised, managed and utilised in construction e.g. recycled materials
(Policy SWA5);
• requires Local Employment Areas to be safeguarded for various uses which includes waste collection, transfer and recycling uses (Policy SEC3);
• sets out the overall strategy for waste management and identifies how much new waste management capacity is likely to be needed (Policy SWA1);
• expects waste to be managed in accordance with the waste hierarchy and the proximity principle (Policy SWA1);
• allows for capacity to be developed which will ensure waste can be managed in accordance with the waste hierarchy and will reduce reliance on other authority areas (Policy SWA1);
• encourages collaborative working with neighbouring authorities ‘who import waste into, or export waste out of, Sandwell, to ensure a cooperative cross boundary approach to waste management is maintained’ (Policy SWA1);
• gives priority to the safeguarding of existing and allocated sites for their continued use and the retention of the local employment areas in which they occur (Policy SEC3 and Policy SWA2);
• protects existing sites from encroachment by other forms of development and requires a ‘Waste Site Impact Assessment’ for development proposals which might impact on the effective operation of existing waste sites (Policy SWA2). WMRTAB notes that the addition of a reference to the ‘agent of change’ principle, mentioned in the NPPF, in paragraph 13.41, might provide further clarification/support for this approach. WMRTAB considers that to ensure the effectiveness of this policy, this requirement should be extended to development proposed proximate to preferred locations allocated for waste management use in the Local Plan.

WMRTAB makes the following further comments which are intended to help ensure the effectiveness of the Plan:
• The term ‘Major’ should be defined in clause 1. c. of Policy SHW1 It is recommended that such a definition considers site area and waste
throughput;
• to avoid ambiguity and ensure the objectives of the Plan are met, WMRTAB suggests that the term ‘maximum’ replaces ‘existing’ in clause 1 of Policy SWA2 to read:
‘Sandwell will safeguard all existing strategic and other waste management facilities from inappropriate development, to maintain existing maximum
levels of waste management capacity and meet Strategic Objective 17, unless it can be demonstrated that:…..’
It is considered that this change will improve the effectiveness of the policy by clarifying that the maximum throughput of a facility should be safeguarded;
• WMRTAB notes that paragraph 3.53 of the Plan suggests that ‘negative environmental impacts’ ‘generally accompany’ waste management
operations. WMRTAB does not agree with this statement as, while waste management operations are generally industrial in their appearance, modern waste management facilities do not ‘generally’ result in ‘negative environmental impacts’. WMRTAB request that this statement be modified
as, without modification, this may make it unduly challenging for proposals for waste management facilities to be granted planning permission in
accordance with the policies of the SLP.

WMRTAB has the following additional comments:
• WMRTAB notes and broadly supports the manner in which waste management capacity gaps have been identified. This includes the fact that
waste management capacity requirements have been assessed with the objective of achieving net self-sufficiency;
• WMRTAB notes and supports:
o the separate consideration of waste imports and exports at paragraphs 13.25 to 13.28;
o clarification of the contents of, a Waste Site Impact Assessments in paragraph 13.42.

Duty to Cooperate

WMRTAB is pleased to confirm that Sandwell Metropolitan Borough Council is an active member of WMRTAB and an officer from the Council regularly attends the group’s meeting and contributes to its work. WMRTAB has therefore facilitated discussion between Sandwell Metropolitan Borough Council and other neighbouring waste planning authorities to assist with meeting its Duty to Cooperate (DtC) on matters pertaining to the planning for waste management. Furthermore Sandwell Council is a signatory to the WMRTAB Statement of Common Ground.

Planning for Waste Management

WMRTAB is pleased to see that the important matter of waste management has been planned for in the Local Plan and considers that the Vision and Objectives broadly address issues associated with waste management which will arise during the SLP period. WMRTAB also supports the inclusion of a chapter dedicated to waste (and minerals) (Chapter 13). WMRTAB welcomes the fact the SLP addresses the management of all forms of waste (paragraph 13.6).

WMRTAB notes and broadly welcomes policy which:
• Encourages development to utilise heat and energy generated from energy from waste facilities (Policy SCC2);
• encourages reduction of waste from construction (Policy SCC3 and Policy SWA1);
• encourages design of buildings to ensure ease of end of life disassembly and material reuse (policy SCC4);
• requires all new development to consider in detail how waste will be minimised, managed and utilised in construction e.g. recycled materials
(Policy SWA5);
• requires Local Employment Areas to be safeguarded for various uses which includes waste collection, transfer and recycling uses (Policy SEC3);
• sets out the overall strategy for waste management and identifies how much new waste management capacity is likely to be needed (Policy SWA1);
• expects waste to be managed in accordance with the waste hierarchy and the proximity principle (Policy SWA1);
• allows for capacity to be developed which will ensure waste can be managed in accordance with the waste hierarchy and will reduce reliance on other authority areas (Policy SWA1);
• encourages collaborative working with neighbouring authorities ‘who import waste into, or export waste out of, Sandwell, to ensure a cooperative cross boundary approach to waste management is maintained’ (Policy SWA1);
• gives priority to the safeguarding of existing and allocated sites for their continued use and the retention of the local employment areas in which they occur (Policy SEC3 and Policy SWA2);
• protects existing sites from encroachment by other forms of development and requires a ‘Waste Site Impact Assessment’ for development proposals which might impact on the effective operation of existing waste sites (Policy SWA2). WMRTAB notes that the addition of a reference to the ‘agent of change’ principle, mentioned in the NPPF, in paragraph 13.41, might provide further clarification/support for this approach. WMRTAB considers that to ensure the effectiveness of this policy, this requirement should be extended to development proposed proximate to preferred locations allocated for waste management use in the Local Plan.

WMRTAB makes the following further comments which are intended to help ensure the effectiveness of the Plan:
• The term ‘Major’ should be defined in clause 1. c. of Policy SHW1 It is recommended that such a definition considers site area and waste
throughput;
• to avoid ambiguity and ensure the objectives of the Plan are met, WMRTAB suggests that the term ‘maximum’ replaces ‘existing’ in clause 1 of Policy SWA2 to read:
‘Sandwell will safeguard all existing strategic and other waste management facilities from inappropriate development, to maintain existing maximum
levels of waste management capacity and meet Strategic Objective 17, unless it can be demonstrated that:…..’
It is considered that this change will improve the effectiveness of the policy by clarifying that the maximum throughput of a facility should be safeguarded;
• WMRTAB notes that paragraph 3.53 of the Plan suggests that ‘negative environmental impacts’ ‘generally accompany’ waste management
operations. WMRTAB does not agree with this statement as, while waste management operations are generally industrial in their appearance, modern waste management facilities do not ‘generally’ result in ‘negative environmental impacts’. WMRTAB request that this statement be modified
as, without modification, this may make it unduly challenging for proposals for waste management facilities to be granted planning permission in
accordance with the policies of the SLP.

WMRTAB has the following additional comments:
• WMRTAB notes and broadly supports the manner in which waste management capacity gaps have been identified. This includes the fact that
waste management capacity requirements have been assessed with the objective of achieving net self-sufficiency;
• WMRTAB notes and supports:
o the separate consideration of waste imports and exports at paragraphs 13.25 to 13.28;
o clarification of the contents of, a Waste Site Impact Assessments in paragraph 13.42.

Duty to Cooperate

WMRTAB is pleased to confirm that Sandwell Metropolitan Borough Council is an active member of WMRTAB and an officer from the Council regularly attends the group’s meeting and contributes to its work. WMRTAB has therefore facilitated discussion between Sandwell Metropolitan Borough Council and other neighbouring waste planning authorities to assist with meeting its Duty to Cooperate (DtC) on matters pertaining to the planning for waste management. Furthermore Sandwell Council is a signatory to the WMRTAB Statement of Common Ground.

Planning for Waste Management

WMRTAB is pleased to see that the important matter of waste management has been planned for in the Local Plan and considers that the Vision and Objectives broadly address issues associated with waste management which will arise during the SLP period. WMRTAB also supports the inclusion of a chapter dedicated to waste (and minerals) (Chapter 13). WMRTAB welcomes the fact the SLP addresses the management of all forms of waste (paragraph 13.6).

WMRTAB notes and broadly welcomes policy which:
• Encourages development to utilise heat and energy generated from energy from waste facilities (Policy SCC2);
• encourages reduction of waste from construction (Policy SCC3 and Policy SWA1);
• encourages design of buildings to ensure ease of end of life disassembly and material reuse (policy SCC4);
• requires all new development to consider in detail how waste will be minimised, managed and utilised in construction e.g. recycled materials
(Policy SWA5);
• requires Local Employment Areas to be safeguarded for various uses which includes waste collection, transfer and recycling uses (Policy SEC3);
• sets out the overall strategy for waste management and identifies how much new waste management capacity is likely to be needed (Policy SWA1);
• expects waste to be managed in accordance with the waste hierarchy and the proximity principle (Policy SWA1);
• allows for capacity to be developed which will ensure waste can be managed in accordance with the waste hierarchy and will reduce reliance on other authority areas (Policy SWA1);
• encourages collaborative working with neighbouring authorities ‘who import waste into, or export waste out of, Sandwell, to ensure a cooperative cross boundary approach to waste management is maintained’ (Policy SWA1);
• gives priority to the safeguarding of existing and allocated sites for their continued use and the retention of the local employment areas in which they occur (Policy SEC3 and Policy SWA2);
• protects existing sites from encroachment by other forms of development and requires a ‘Waste Site Impact Assessment’ for development proposals which might impact on the effective operation of existing waste sites (Policy SWA2). WMRTAB notes that the addition of a reference to the ‘agent of change’ principle, mentioned in the NPPF, in paragraph 13.41, might provide further clarification/support for this approach. WMRTAB considers that to ensure the effectiveness of this policy, this requirement should be extended to development proposed proximate to preferred locations allocated for waste management use in the Local Plan.

WMRTAB makes the following further comments which are intended to help ensure the effectiveness of the Plan:
• The term ‘Major’ should be defined in clause 1. c. of Policy SHW1 It is recommended that such a definition considers site area and waste
throughput;
• to avoid ambiguity and ensure the objectives of the Plan are met, WMRTAB suggests that the term ‘maximum’ replaces ‘existing’ in clause 1 of Policy SWA2 to read:
‘Sandwell will safeguard all existing strategic and other waste management facilities from inappropriate development, to maintain existing maximum
levels of waste management capacity and meet Strategic Objective 17, unless it can be demonstrated that:…..’
It is considered that this change will improve the effectiveness of the policy by clarifying that the maximum throughput of a facility should be safeguarded;
• WMRTAB notes that paragraph 3.53 of the Plan suggests that ‘negative environmental impacts’ ‘generally accompany’ waste management
operations. WMRTAB does not agree with this statement as, while waste management operations are generally industrial in their appearance, modern waste management facilities do not ‘generally’ result in ‘negative environmental impacts’. WMRTAB request that this statement be modified
as, without modification, this may make it unduly challenging for proposals for waste management facilities to be granted planning permission in
accordance with the policies of the SLP.

WMRTAB has the following additional comments:
• WMRTAB notes and broadly supports the manner in which waste management capacity gaps have been identified. This includes the fact that
waste management capacity requirements have been assessed with the objective of achieving net self-sufficiency;
• WMRTAB notes and supports:
o the separate consideration of waste imports and exports at paragraphs 13.25 to 13.28;
o clarification of the contents of, a Waste Site Impact Assessments in paragraph 13.42.

Duty to Cooperate

WMRTAB is pleased to confirm that Sandwell Metropolitan Borough Council is an active member of WMRTAB and an officer from the Council regularly attends the group’s meeting and contributes to its work. WMRTAB has therefore facilitated discussion between Sandwell Metropolitan Borough Council and other neighbouring waste planning authorities to assist with meeting its Duty to Cooperate (DtC) on matters pertaining to the planning for waste management. Furthermore Sandwell Council is a signatory to the WMRTAB Statement of Common Ground.

Planning for Waste Management

WMRTAB is pleased to see that the important matter of waste management has been planned for in the Local Plan and considers that the Vision and Objectives broadly address issues associated with waste management which will arise during the SLP period. WMRTAB also supports the inclusion of a chapter dedicated to waste (and minerals) (Chapter 13). WMRTAB welcomes the fact the SLP addresses the management of all forms of waste (paragraph 13.6).

WMRTAB notes and broadly welcomes policy which:
• Encourages development to utilise heat and energy generated from energy from waste facilities (Policy SCC2);
• encourages reduction of waste from construction (Policy SCC3 and Policy SWA1);
• encourages design of buildings to ensure ease of end of life disassembly and material reuse (policy SCC4);
• requires all new development to consider in detail how waste will be minimised, managed and utilised in construction e.g. recycled materials
(Policy SWA5);
• requires Local Employment Areas to be safeguarded for various uses which includes waste collection, transfer and recycling uses (Policy SEC3);
• sets out the overall strategy for waste management and identifies how much new waste management capacity is likely to be needed (Policy SWA1);
• expects waste to be managed in accordance with the waste hierarchy and the proximity principle (Policy SWA1);
• allows for capacity to be developed which will ensure waste can be managed in accordance with the waste hierarchy and will reduce reliance on other authority areas (Policy SWA1);
• encourages collaborative working with neighbouring authorities ‘who import waste into, or export waste out of, Sandwell, to ensure a cooperative cross boundary approach to waste management is maintained’ (Policy SWA1);
• gives priority to the safeguarding of existing and allocated sites for their continued use and the retention of the local employment areas in which they occur (Policy SEC3 and Policy SWA2);
• protects existing sites from encroachment by other forms of development and requires a ‘Waste Site Impact Assessment’ for development proposals which might impact on the effective operation of existing waste sites (Policy SWA2). WMRTAB notes that the addition of a reference to the ‘agent of change’ principle, mentioned in the NPPF, in paragraph 13.41, might provide further clarification/support for this approach. WMRTAB considers that to ensure the effectiveness of this policy, this requirement should be extended to development proposed proximate to preferred locations allocated for waste management use in the Local Plan.

WMRTAB makes the following further comments which are intended to help ensure the effectiveness of the Plan:
• The term ‘Major’ should be defined in clause 1. c. of Policy SHW1 It is recommended that such a definition considers site area and waste
throughput;
• to avoid ambiguity and ensure the objectives of the Plan are met, WMRTAB suggests that the term ‘maximum’ replaces ‘existing’ in clause 1 of Policy SWA2 to read:
‘Sandwell will safeguard all existing strategic and other waste management facilities from inappropriate development, to maintain existing maximum
levels of waste management capacity and meet Strategic Objective 17, unless it can be demonstrated that:…..’
It is considered that this change will improve the effectiveness of the policy by clarifying that the maximum throughput of a facility should be safeguarded;
• WMRTAB notes that paragraph 3.53 of the Plan suggests that ‘negative environmental impacts’ ‘generally accompany’ waste management
operations. WMRTAB does not agree with this statement as, while waste management operations are generally industrial in their appearance, modern waste management facilities do not ‘generally’ result in ‘negative environmental impacts’. WMRTAB request that this statement be modified
as, without modification, this may make it unduly challenging for proposals for waste management facilities to be granted planning permission in
accordance with the policies of the SLP.

WMRTAB has the following additional comments:
• WMRTAB notes and broadly supports the manner in which waste management capacity gaps have been identified. This includes the fact that
waste management capacity requirements have been assessed with the objective of achieving net self-sufficiency;
• WMRTAB notes and supports:
o the separate consideration of waste imports and exports at paragraphs 13.25 to 13.28;
o clarification of the contents of, a Waste Site Impact Assessments in paragraph 13.42.