Policy P12 Resource Management

Should include policies on biogenic waste, use of anaerobic digestion and new sources of energy generation.

See Attached letter.

POLICY P12 – REPLACEMENT TEXT
Insert between 2 and 3:
Provision to Meet Solihull’s Needs
Local Authority Collected Waste; Commercial and Industrial Waste; and Construction, Demolition and Excavation Waste

Sustainable provision of waste management facilities will be made to meet the requirements identified in the Waste Needs Assessment for Solihull at the dates identified in the Assessment.

Other types of waste

On suitable sites, support in principle is given to the provision of:

• facilities for the management of secondary and recycled materials and minerals waste; and

• hazardous waste management facilities.

Replace 3 to 6 with:
Suitable Sites and Areas

Locations that are in principle acceptable for waste management include the strategic waste management sites identified on the Policies Map where consolidation or expansion may be appropriate; suitable industrial areas or sites allocated for industrial or employment purposes; and, for the co-location of complementary waste management operations, the Berkswell and Meriden quarries. The re-use of previously-developed land, sites identified for employment uses, and redundant agricultural and forestry buildings and their curtilages will have priority.

Where it is not possible or appropriate for new operations to be developed in these locations, developers shall consider the potential of sites within the Area of Search for waste management facilities as identified on the Policies Map.

Many of the strategic waste management sites, and the Area of Search, are within the Green Belt. As such, development would not normally be permitted other that in very special circumstances. These are likely to include the particular locational needs of some types of waste management facilities and the absence of suitable sites elsewhere. Very special circumstances will need to be demonstrate in applications.

Replace 7 with:
Household Waste Recycling Site

Land is identified for a relocated Household Waste and Recycling Centre within UK2 Land at Damson Parkway which is allocated for employment purposes in Policy P1 and Policy UK2.

Split 9 into 2 sections:
Safeguarding Waste Management Facilities

In considering non-waste management development proposals, the Council will take into account any adverse impact on the strategically important waste management sites and the potential of the Area of Search for waste management facilities identified in this plan.

Provision of Waste Facilities in Non-Waste Development

Non-waste development will be required to accommodate facilities for the storage, sorting and presentation of waste arising from the development, and developers will be expected to demonstrate satisfactory provision for waste management.

See attached

Good evening

Please see attached letter from Meriden Parish Council in response to Solihull’s Draft Local Plan consultation.

Site at former Arden Brickworks should be allocated as a potential Eco-Park for waste management, energy and employment related development in order to provide flexibility in the plan for the delivery of the Council's vision and objectives to provide adequate waste management provision to meet the waste management needs arising in the plan period within the Borough.
The Plan should acknowledge in any potential allocation at the former Arden Brickworks site as shown in red on the accompanying site layout plan that these proposals would assist the Borough in moving towards net zero carbon emissions with the Eco-Park attracting inward investment into the Borough for co-locating waste management and energy generation facilities.
The Local Geological Site designation should be removed from the emerging policies map.

Pegasus Group are instructed to make representations to the Solihull Regulation 19 Local Plan (October 2020) (SLP) on behalf of our clients Kilbride Resources Ltd with regard to emerging draft Policy P12 and land at the former Arden Brickworks site situated to the south of the A45 as shown on the red line plan attached at Appendix 1. Our clients have an interest in the site as the landowner's preferred development partner.
Paragraph 38 of the SLP recognises at bullet point I that providing sufficient waste management facilities is one of challenges the Borough faces during the proposed plan period. This point is expanded on at p.19. which states that objectives of the SLP with regard to waste are;
• To promote the management of waste arising in the Borough further up the waste hierarchy and its treatment as a resource to be used wherever possible.
• To address the identified needs for waste management in the Borough.
Paragraph 53 states that the vision for the Borough with regard to waste is that;
" Solihull will have reduced the amount of waste produced in the Borough through increased recycling and re-use, eliminated the gap between the amount of waste arising and the capacity of its facilities.."
In order to address this matter the SLP identifies at Policy P12 the removal of land from the Green Belt to the south east of Damson Parkway/Old Damson Lane with an option for a relocated Household Waste Recycling Centre and Council Depot as an option on part of this land.
Draft Policy P12 – 'Resource Management' refreshes the existing Policy P12 in the adopted Solihull Local Plan (Dec 2013) and points to the need for focus on moving towards a net zero carbon economy with regard to the transportation of waste from source to processing facility with an associated sequential approach to the identification of the appropriate location for new waste management facilities.
The Cushman Wakefield 'Assessment of land for potential re-location of a Household Waste Recycling Centre and Depot' (June 2019) provides a significant part of the evidence base for the consideration of such facilities in the Borough with the northern and southern parcels of the former Arden Brickworks site being identified sequentially as the first and third most appropriate sites respectively within the Borough, whilst the allocated Damson Parkway site as the fourth most sequentially preferable site.
The Arden Brickworks site is identified on the existing adopted Policies Map and the emerging Policies Map as a Strategic Waste Management Facility, therefore the consolidation and expansion of waste management activities at the site would be held to be appropriate under emerging Policy SP12 criteria 3.ii.
Moreover, draft policy SP 12 criteria 5 states;
"Strategically important waste management sites within the Borough, where waste management activities will be supported in principle, are identified on the Policies Map. These sites include the site of the former Arden Brickworks in Bickenhill, which contains the household waste recycling centre, and a range of other waste management operations…" (emphasis added)
Draft Policy SP12 criteria 6 states;
"When investigating the suitability of sites for waste management operations in the Borough, the potential for consolidating or expanding waste management facilities at the former Arden Brickworks site …. shall be considered."
Draft Policy SP12 criteria 8 provides a list of 15 sub-criteria to be used in the consideration of waste management criteria proposals and include at criteria vi. and vii.
"vi. The potential for the co-location of complementary activities where there are no adverse cumulative impacts
vii. The contribution towards the restoration of former mineral workings in the Borough."
Our client's site is situated within the Green Belt. However, the southern part of the site includes a former quarry area, and given its identification in the emerging SLP as an existing Strategic Waste Management Facility, the location of the site with regard to the strategic highway network, its location in very close proximity to the NEC, Birmingham Airport and the strategic Arden Cross site, the potential for the co-location of waste recycling and energy generation facilities in an eco-park campus style development merits further consideration for inclusion as part of an allocation in the emerging SLP.
Our client's site would comply with criteria already contained within emerging Policy SP12 and has been identified in the Council's own evidence base as comprising the first and third most sequentially preferable sites for the relocation of a household waste management facility within the Borough.
The plan attached at Appendix 1 comprises only the brownfield and mineral extraction areas of the southern parcel of Arden Brickworks considered in the Cushman Wakefield report (and omits the area of green field agricultural land to the east of this area which is included in the parcel in the evidence base and contributes towards its lower scoring).
Attention is also drawn to the identification by the authority of a 'Local Geological Site' (LGS) designation at the Arden brickworks site. The site is not identified as a Local Geological Site on the adopted Solihull Local Plan Proposals Map nor it is it listed as a Regional Important Geological Site (RIG) or Local Geological Site in the adopted Solihull Local Plan. As an emerging LGS, the site would be subject to criteria 5 and 18 of Policy P10 of the emerging Local Plan.
Research into this matter has elucidated that the main geological value of the site is for educational purposes post GCSE, owing to the visible exposure of strata from the Triassic, Mercia Mudstone Group; "The strata consists of irregularly bedded red clay and mudstone, interbedded with green mudstone and green sandstone skerry horizons".
While visits to the site can be arranged for educational purposes, it should be noted that the site is privately owned and not publicly accessible.
It is also noted; as referred to in Chapter 10 of the Environmental Statement presented to the Development Consent Order Inquiry into the widening of Junction 6 of the M42, (prepared by Highways England and dated January 2019); that the mineral extraction permission at the site requires the restoration of the site once extraction is complete, at which point the currently exposed strata would be lost.
Whilst it is appreciated that restoration at the site might occur after the end of the emerging SLP plan period, it is requested that consideration be given to the removal of the LGS designation from the site and the emerging policies map and instead further consideration be given to the allocation of the site as an Eco Park for waste recycling and energy generation purposes. This may of itself present opportunities for the retention of the geological features of interest for educational purposes however this would need to be the subject of detailed further investigations.
Our client's site is suitable, available and deliverable and therefore offers a sequentially preferable potential alternative location to the Damson Parkway site for a new Household Waste Recycling Facility in the Borough, and an opportunity for such a Materials Recycling Facility to be combined with complementary energy storage and generation as part of a comprehensive approach to deliver a Waste and Energy Eco-Park development.
This comprehensive form of allocation would assist the Borough in moving towards net zero carbon emissions, with the Eco-Park attracting inward investment into the Borough comprising of waste management coupled with energy generation technologies to the benefit of the local economy and environment.

It is requested that the emerging SLP allocate our client's site at former Arden Brickworks as a potential Eco-Park for waste management, energy and employment related development in order to provide flexibility in the plan for the delivery of the Council's vision and objectives to provide adequate waste management provision to meet the waste management needs arising in the plan period within the Borough.
It is also requested that the SLP acknowledge in any potential allocation at the former Arden Brickworks site as shown in red on the accompanying site layout plan that these proposals would assist the Borough in moving towards net zero carbon emissions with the Eco-Park attracting inward investment into the Borough for co-locating waste management and energy generation facilities.
It is also requested that the Local Geological Site designation be removed from the emerging policies map.

SOLIHULL LOCAL PLAN OBJECTION

Dear sir/madam, as a local resident I wish to lodge an objection over the proposal to move the Bickenhill Household Waste Recycling Centre to Damson Parkway as outlined in paragraphs 105 and 831 of the Solihull Local Plan (site map reference UK2).

For over three decades, the green belt land in what used to be an attractive and leafy approach to Solihull town centre has been steadily eroded as the adjacent Jaguar Land Rover factory has expanded to more than double its original size.

The current ongoing addition - a huge logistics centre right alongside the proposed tip - is built on a large tract of green belt land that was waved through by Solihull Council as it was deemed exceptional circumstances. There are no exceptional circumstances about this latest project, which explains why the Council has kept it under wraps until the 11th hour while Local Plan developments in other wards have been in the public domain for four years resulting in consultations, amendments and even cancellations.

In making this proposal, the Council has ignored the traffic problems that already exist along Damson Parkway - and this is before the logistics centre comes into operation early next year. The addition of long queues of cars and vans trying to access the proposed refuse tip - not to mention the lorries required to service the site - will lead to more traffic chaos, especially when the various shifts change over at JLR.

Down the years, the residents of Elmdon have protested in vain about a couple of JLR expansion plans that have blighted the area but most accept the company is a huge asset to the region and employs around 9,000 workers at the site. However, Solihull Council should be fully aware of the traffic congestion, inconvenience and increased pollution that this has created along Damson Parkway - a main thoroughfare to the A45 - yet has shown total disregard for local residents by trying to sneak this recycling centre through under the radar.

Back in 2016, when HS2 decreed the tip had to be moved to make way for their expansive Birmingham Interchange plans, among the first sites earmarked was in nearby Meridan. However, Meridan Parish Council minutes for October that year record that the ward's Conservative councillors made representation to the local Conservative MP and consequently Conservative-led Solihull Council decided to look elsewhere. Elmdon residents have not been afforded a similar courtesy of advanced warning as the ward has no Conservative councillors. This petty politicking should not impact on such important long-term decisions.

The JLR factory will expand even further over the coming years and the company has already announced plans to close the adjacent sports field and social club and convert it into a giant car park - which is exactly what Damson Parkway is destined to be if this recycling centre is added to the industrial behemoth the area has become.

Consideration should be given within Policy P12 to the need and support for the permanent retention of mineral infrastructure to meet anticipated demand as well as maintaining existing supply.

Introduction and Background
Representations to the above consultation are made on behalf of our clients Tarmac Trading Limited and Tarmac Building Products Limited (Tarmac). Tarmac operate two Readymix (RMX) Plants and a Dry Silo Mortar (DSM) Plant situated off Cornets End Lane, Meriden. All Tarmac plants are strategically important for the supply of mineral product to serve local, regional and national construction needs.
Both RMX plants have permanent planning consent for their continued operation. Planning permission has recently been granted to replace one of the RMX plants to supply HS2. On completion of that contract, the RMX site will revert to serving local construction markets.
Dry silo mortar is a specialised construction material comprised of kiln dried materials and is supplied direct to market in sealed silos, which are typically transported by road. The materials (sand, cement, pigment and additives) at the plant are blended in accordance with each customer’s bespoke requirements. The DSM plant is of national strategic importance. The operation of the DSM plant is time limited to working of the adjacent Meriden Quarry site.
DSM is ideal for housing and commercial developments alike, particularly at larger sites which require larger mortar volumes produced under rigorous factory-controlled conditions. There is no need for onsite mixing given the requisite materials are already contained within a sealed silo
and the required volumes can be produced as and when necessary. This ensures consistency of
mortar colour for the whole construction project and helps to minimise waste caused by adverse
weather conditions when compared with other mortar products (it is mixed as and when
required as opposed to deliveries of wet mix to sites). Such is the specialist nature of the product
that there are understood to be only twenty DSM plants located within the entirety of the United
Kingdom. Tarmac operate five of these plants in the following locations:
• Colchester, Essex;
• Meriden, Solihull;
• Glasgow, Scotland;
• Leeds, West Yorkshire; and
• Croxden, Staffordshire.
In the last five years, sales of DSM have doubled whilst the number of sites has not increased
proportionately. Although aggregate workings generally have a defined market area, DSM plants
do not, owing to the specialist nature of the product and limited locations across the United
Kingdom. The result of this is that one site may supply a number of areas across different
administrative boundaries. For example, Tarmac’s Meriden site is of national importance forming
a key part of the DSM network, supplying customer needs in location as far as Kent, East Sussex,
West Sussex, Hampshire, Dorset, Devon, Cornwall, North and South Wales and East Anglia.
Tarmac supplies two of the top three UK housing developers, a key strategy is to maintain
continuity of supply to sustain and meet future demands for a growing national housing market.
Both the RMX and DSM plants are supplied by sand from the nearby Meriden Quarry and
Berkswell Quarry sites. In addition, sand is imported from Shireoak Quarry (Walsall) for blending
with sand from Meriden Quarry to make it suitable for the DSM process. Whilst fine sand is an
important mineral resource it is not suitable for use as an aggregate required for production of
ready mixed concrete. These quarries are used as they are a local resource, and they produce a
distinctive and popular colour to the mortar.

The Local Plan Consultation
All Tarmac plant sites situated at Cornets End Lane are within land designated on the emerging
Plan Policy map as ‘Mineral Safeguarding Areas’ and ‘Areas of Search for Waste Management
Facilities’. They are in proximity to land designated as ‘Preferred Areas for Minerals
Development’. This whole area is designated Green Belt.
Emerging Policy P17 (Countryside and Green Belt) seeks to retain land permanently open unless
very special circumstances have been demonstrated in accordance with the NPPF. Part 4 of the
policy identifies very special circumstances which may be considered when assessing proposals
for ‘inappropriate’ development. One of those very special circumstances for development is the
provision of waste management operations, providing that the development accords with the
waste management policy of the plan. Waste Management development is to be determined in
accordance with the requirements of Policy P12 (Resource Management).
Part 3 of Policy P12 identifies the strategy for waste provision and the sites preferred for waste
management and uses. The policy seeks to ensure that an equivalent tonnage is provided for
within waste management facilities to that arising within the Borough. To achieve this, a
sequential approach is proposed to determine the appropriate location for new waste
management facilities as follows:
i. On-site management
ii. Consolidation or expansion at strategic waste management sites
iii. Suitable industrial areas or sites allocated for industrial or employment uses
iv. Co-location of complementary waste management operations at Berkswell and
Meriden quarries
v. Area of Search for waste management facilities.
Part 5 to Policy P12 identifies strategically important waste management sites within the
Borough, where waste management activities will be supported in principle. These sites include
the site of the former Arden Brickworks in Bickenhill, which contains the household waste
recycling centre, and a range of other waste management operations, the materials recovery
facilities at Berkswell and Meriden Quarries, the composting facilities in Berkswell, and the Moat
Lane and Chapelhouse Depot waste transfer stations in the Mature Suburbs and North Solihull.
As identified above, these preferred areas for new waste management facilities are collocated
with mineral development at Berkswell and Meriden Quarries. Some of which have permanent
consent. The justification for allowing permanent forms of waste development that would go
against the principles of maintaining openness in the Green Belt is objectively assessed need for
waste capacity and the difficulty in finding suitable locations for such uses on land not designated
as Green Belt. In addition to proximity to demand/need, the highway network and the ability of
these areas to accommodate the traffic generated.
With consideration of potential/future waste facilities, the emphasis is on managing indigenous
requirements (equivalent tonnage within waste management facilities to that arising). It is
Tarmac’s view that objectively assessed need for mineral development and associated
infrastructure needs have been overlooked. The existing facilities contribute significantly to local,
regional and national need. This goes far beyond only the local requirements within the Borough
that are the necessary exception tests for new waste development. As a result the support and
retention of minerals associated development should hold equal weight if not greater weight
within these areas. The LAA (2015) identifies, ‘the main issue for local plans is to ensure that the
role of the existing network of manufacturing plants is recognised’ (paragraph 3.5.5 Heatons
emphasis). Although these facilities are safeguarded under minerals policy, their importance and
role should be given elevated status and recognition within the Plan.
Very special circumstances precedent has already been accepted/demonstrated in the case of
permanent waste management operations permitted adjacent to the Tarmac’s existing
operations. The early review of the Plan has been triggered by the need for Solihull to find land
to meet its own housing needs, as well as helping to address the housing shortfall occurring in
the wider Housing Market Area. The growth/development plans in Solihull and the West
Midlands create such a substantial long-term need for aggregate and aggregate related products
- that will, by virtue of the location of the Meriden sand and gravel Area of Search, involve mineral
extraction and associated infrastructure in the Green Belt for the duration of the plan period –
such that these considerations substantially outweigh the level of potential harm to the Green
Belt. Particularly as these are facilities already in situ and have been for a number of years. They
are not new development further encroaching on the Green Belt.
In view of the above comments, it is considered that the policy relating to Resource Management
(P12) and exceptions within the Green Belt (P17) is not an effective or positively prepared
strategy for managing mineral product supply over the Plan period. The policy should also give
due consideration to the need and support for the permanent retention of mineral infrastructure
to meet anticipated demand as well as maintaining existing supply. It is questioned whether this
area being retained as Green Belt is appropriate given the proximity to land being released to
accommodate large scale development, historic industrial activity as well as the long term
strategy for waste management/industrial uses being accepted in this area.
Policy P13 identifies, ‘Mineral Safeguarding Areas (MSAs) for sand and gravel aggregate
resources between Berkswell, Hampton and Meriden and east of the NEC and M42, including
sites for important associated infrastructure and to meet potential needs are defined on the
Policies Map’. As drafted Policy P13 is not in accordance with the NPPF. The NPPF paragraph
204c states that planning policies should safeguard mineral resources. The policy reads as though
safeguarding of mineral resource is only applicable to the above identified areas and shown
designated on the policies map. The approach to resource safeguarding should cover the whole
Plan area and the policy wording and associated mapping should not exclusively identify
resource in only one specific area.
Part 9 of Policy P13 states that, proposals for ancillary uses will be permitted where they are
located within the extraction site, are limited to the life of the permitted reserves and minimise
the impacts on environmental assets, transport infrastructure and surrounding occupiers and
uses. The Council will support proposals for complementary recycling facilities, which should be
as close as possible to the point of extraction or disposal’. The above comments have clearly
demonstrated that the minerals infrastructure already in place (some of which have permanent
consent) are essential to meeting the objectively assessed need for mineral products over the
Plan period. Policy P13 should remove reference to limiting the life of ancillary activities to the
life of reserves in order to be positively prepared to manage forecasted demand for mineral
product. If there are clear exceptional circumstances, including objectively assessed need for
mineral development and mineral related product, these should not be life limited.

Consideration should be given within Policy P12 to the need and support for the permanent retention of mineral infrastructure to meet anticipated demand as well as maintaining existing supply.

Introduction and Background
Representations to the above consultation are made on behalf of our clients Tarmac Trading Limited and Tarmac Building Products Limited (Tarmac). Tarmac operate two Readymix (RMX) Plants and a Dry Silo Mortar (DSM) Plant situated off Cornets End Lane, Meriden. All Tarmac plants are strategically important for the supply of mineral product to serve local, regional and national construction needs.
Both RMX plants have permanent planning consent for their continued operation. Planning permission has recently been granted to replace one of the RMX plants to supply HS2. On completion of that contract, the RMX site will revert to serving local construction markets.
Dry silo mortar is a specialised construction material comprised of kiln dried materials and is supplied direct to market in sealed silos, which are typically transported by road. The materials (sand, cement, pigment and additives) at the plant are blended in accordance with each customer’s bespoke requirements. The DSM plant is of national strategic importance. The operation of the DSM plant is time limited to working of the adjacent Meriden Quarry site.
DSM is ideal for housing and commercial developments alike, particularly at larger sites which require larger mortar volumes produced under rigorous factory-controlled conditions. There is no need for onsite mixing given the requisite materials are already contained within a sealed silo
and the required volumes can be produced as and when necessary. This ensures consistency of
mortar colour for the whole construction project and helps to minimise waste caused by adverse
weather conditions when compared with other mortar products (it is mixed as and when
required as opposed to deliveries of wet mix to sites). Such is the specialist nature of the product
that there are understood to be only twenty DSM plants located within the entirety of the United
Kingdom. Tarmac operate five of these plants in the following locations:
• Colchester, Essex;
• Meriden, Solihull;
• Glasgow, Scotland;
• Leeds, West Yorkshire; and
• Croxden, Staffordshire.
In the last five years, sales of DSM have doubled whilst the number of sites has not increased
proportionately. Although aggregate workings generally have a defined market area, DSM plants
do not, owing to the specialist nature of the product and limited locations across the United
Kingdom. The result of this is that one site may supply a number of areas across different
administrative boundaries. For example, Tarmac’s Meriden site is of national importance forming
a key part of the DSM network, supplying customer needs in location as far as Kent, East Sussex,
West Sussex, Hampshire, Dorset, Devon, Cornwall, North and South Wales and East Anglia.
Tarmac supplies two of the top three UK housing developers, a key strategy is to maintain
continuity of supply to sustain and meet future demands for a growing national housing market.
Both the RMX and DSM plants are supplied by sand from the nearby Meriden Quarry and
Berkswell Quarry sites. In addition, sand is imported from Shireoak Quarry (Walsall) for blending
with sand from Meriden Quarry to make it suitable for the DSM process. Whilst fine sand is an
important mineral resource it is not suitable for use as an aggregate required for production of
ready mixed concrete. These quarries are used as they are a local resource, and they produce a
distinctive and popular colour to the mortar.
The Local Plan Consultation
All Tarmac plant sites situated at Cornets End Lane are within land designated on the emerging
Plan Policy map as ‘Mineral Safeguarding Areas’ and ‘Areas of Search for Waste Management
Facilities’. They are in proximity to land designated as ‘Preferred Areas for Minerals
Development’. This whole area is designated Green Belt.
Emerging Policy P17 (Countryside and Green Belt) seeks to retain land permanently open unless
very special circumstances have been demonstrated in accordance with the NPPF. Part 4 of the
policy identifies very special circumstances which may be considered when assessing proposals
for ‘inappropriate’ development. One of those very special circumstances for development is the
provision of waste management operations, providing that the development accords with the
waste management policy of the plan. Waste Management development is to be determined in
accordance with the requirements of Policy P12 (Resource Management).
Part 3 of Policy P12 identifies the strategy for waste provision and the sites preferred for waste
management and uses. The policy seeks to ensure that an equivalent tonnage is provided for
within waste management facilities to that arising within the Borough. To achieve this, a
sequential approach is proposed to determine the appropriate location for new waste
management facilities as follows:
i. On-site management
ii. Consolidation or expansion at strategic waste management sites
iii. Suitable industrial areas or sites allocated for industrial or employment uses
iv. Co-location of complementary waste management operations at Berkswell and
Meriden quarries
v. Area of Search for waste management facilities.
Part 5 to Policy P12 identifies strategically important waste management sites within the
Borough, where waste management activities will be supported in principle. These sites include
the site of the former Arden Brickworks in Bickenhill, which contains the household waste
recycling centre, and a range of other waste management operations, the materials recovery
facilities at Berkswell and Meriden Quarries, the composting facilities in Berkswell, and the Moat
Lane and Chapelhouse Depot waste transfer stations in the Mature Suburbs and North Solihull.
As identified above, these preferred areas for new waste management facilities are collocated
with mineral development at Berkswell and Meriden Quarries. Some of which have permanent
consent. The justification for allowing permanent forms of waste development that would go
against the principles of maintaining openness in the Green Belt is objectively assessed need for
waste capacity and the difficulty in finding suitable locations for such uses on land not designated
as Green Belt. In addition to proximity to demand/need, the highway network and the ability of
these areas to accommodate the traffic generated.
With consideration of potential/future waste facilities, the emphasis is on managing indigenous
requirements (equivalent tonnage within waste management facilities to that arising). It is
Tarmac’s view that objectively assessed need for mineral development and associated
infrastructure needs have been overlooked. The existing facilities contribute significantly to local,
regional and national need. This goes far beyond only the local requirements within the Borough
that are the necessary exception tests for new waste development. As a result the support and
retention of minerals associated development should hold equal weight if not greater weight
within these areas. The LAA (2015) identifies, ‘the main issue for local plans is to ensure that the
role of the existing network of manufacturing plants is recognised’ (paragraph 3.5.5 Heatons
emphasis). Although these facilities are safeguarded under minerals policy, their importance and
role should be given elevated status and recognition within the Plan.
Very special circumstances precedent has already been accepted/demonstrated in the case of
permanent waste management operations permitted adjacent to the Tarmac’s existing
operations. The early review of the Plan has been triggered by the need for Solihull to find land
to meet its own housing needs, as well as helping to address the housing shortfall occurring in
the wider Housing Market Area. The growth/development plans in Solihull and the West
Midlands create such a substantial long-term need for aggregate and aggregate related products
- that will, by virtue of the location of the Meriden sand and gravel Area of Search, involve mineral
extraction and associated infrastructure in the Green Belt for the duration of the plan period –
such that these considerations substantially outweigh the level of potential harm to the Green
Belt. Particularly as these are facilities already in situ and have been for a number of years. They
are not new development further encroaching on the Green Belt.
In view of the above comments, it is considered that the policy relating to Resource Management
(P12) and exceptions within the Green Belt (P17) is not an effective or positively prepared
strategy for managing mineral product supply over the Plan period. The policy should also give
due consideration to the need and support for the permanent retention of mineral infrastructure
to meet anticipated demand as well as maintaining existing supply. It is questioned whether this
area being retained as Green Belt is appropriate given the proximity to land being released to
accommodate large scale development, historic industrial activity as well as the long term
strategy for waste management/industrial uses being accepted in this area.
Policy P13 identifies, ‘Mineral Safeguarding Areas (MSAs) for sand and gravel aggregate
resources between Berkswell, Hampton and Meriden and east of the NEC and M42, including
sites for important associated infrastructure and to meet potential needs are defined on the
Policies Map’. As drafted Policy P13 is not in accordance with the NPPF. The NPPF paragraph
204c states that planning policies should safeguard mineral resources. The policy reads as though
safeguarding of mineral resource is only applicable to the above identified areas and shown
designated on the policies map. The approach to resource safeguarding should cover the whole
Plan area and the policy wording and associated mapping should not exclusively identify
resource in only one specific area.
Part 9 of Policy P13 states that, proposals for ancillary uses will be permitted where they are
located within the extraction site, are limited to the life of the permitted reserves and minimise
the impacts on environmental assets, transport infrastructure and surrounding occupiers and
uses. The Council will support proposals for complementary recycling facilities, which should be
as close as possible to the point of extraction or disposal’. The above comments have clearly
demonstrated that the minerals infrastructure already in place (some of which have permanent
consent) are essential to meeting the objectively assessed need for mineral products over the
Plan period. Policy P13 should remove reference to limiting the life of ancillary activities to the
life of reserves in order to be positively prepared to manage forecasted demand for mineral
product. If there are clear exceptional circumstances, including objectively assessed need for
mineral development and mineral related product, these should not be life limited.

See Attached document

See Attached Document

See Attached Document

Hello SMBC. It is rare for me to complain about future plans from SMBC. However I feel so strongly about the whole idea of moving the new council dump/recycling centre to Damson Parkway. I have lived in *** for nearly 18 years and in that time the airport has been expanded which I was completely in favour for. Then the "travellers" permanent site. Then the JLR expansion into a green field site across from the football ground. Currently the area is in chaos because of the new logistics centre again for JLR, and whatever future problems and polutates that will bring. Solihull Moors are expanding and only becoming a bigger club, which again is great news for them. Elmdon Park is a beautiful natural haven for wildlife and a fabulous asset for Solihull. However this proposal for a new DUMP in a green field site to be so close to a residential area that has endured so much in the last decade is beyond belief. Surely you can see this from the residents side. Traffic around this area is unbearable at certain times and becomes grid locked frequently. With the proposal of a new public access DUMP will only add to the misery the local residents. Also noise and light pollution will be a problem, let alone a real threat to local wildlife. Just 7 years ago Solihull was voted best place in the UK to live, I was proud of that but now, I feel persecuted for choosing to live here. A very disgruntled rate payer.

Due to the inadequate information provided and the failure to consult on this proposal then the Plan should be confined to stating /justifying the need for improved waste/recycling facilities and then state what the identified options are, i.e. 1) alter existing site, 2) relocate to Damson Parkway (and identify exactly where) and 3) relocate to the other site the Council have referred to (the not preferred option) and identify where that site is. The plan should state what consultation will be undertaken in order to inform a decision as well as state what evidence base will be published prior to such consultation. No preference as to the solution should be expressed in the plan.

The proposed relocation of the Bickenhill tip is not legally compliant because this has not been consulted upon, this is the first time this proposal has been put into the public domain, so it does not comply with the statement of community involvement. No information about the alternative (but not preferred) site that it turns out has been considered and rejected have been provided, no details about the possibility of expansion of the current site have been provided. It is stated that there is sufficient space for queuing vehicles, but no evidence has been provided. Relocation of the site to land adjacent to Damson Parkway would significantly increase traffic/congestion on Damson Parkway, Damson Lane and Rowood Drive and at shift change times at JLR plus traffic from the new logistics facility would likely result in traffic gridlock. No traffic assessment/sustainability assessment appears to have been undertaken. Thus there is inadequate information provided/available to support the "exceptional circumstances to justify the the potential use of the site" as referred to in para 354.
Other options to co-operate with other local authorities, in particular Birmingham Council, have not been explored thus the duty to co-operate has not been met.

The plan should remove any reference to the Household Waste and Recycling Centre and Depot being moved from its present Bickenhill Site to Damson Parkway, and instead the plan should concentrate on how the Bickenhill site could be improved (better parking, access booking systems etc.).

Paragraph 831 - Reference to moving the Household Waste and Recycling Centre and Depot from its present Bickenhill site to Damson Parkway is not legally compliant, or sound. A move is not justified on environmental grounds, and does not properly take account of the negative climate change / environmental impacts of an unnecessary move (Planning and Compulsory Purchase Act 2004, s. 19 (1A), nor the requirement for community involvement given the strong objections from the residents nearest to the proposed Damson Parkway site (s. 19 (3)). No evidence of co-operation with other agencies regarding this site move is provided.