RTAB would like the importance of waste management infrastructure to sustainable economic growth and development of the circular economy, and the need to safeguard key waste management sites, to be explicitly recognised as key issues to be taken into account in the Review. There is an urgent need to ensure that the delivery of growth in the Black Country and the wider West Midlands metropolitan area is not impaired by a failure to appropriately value and safeguard an effective network of sites for the recovery, processing and trans-shipment of material resources. Raw materials and waste management costs already represent a significant burden for many businesses, particularly in manufacturing, and restricted access to alternatives to materials recovery facilities can have a significant impact on commercial viability. The Core Strategy should therefore adopt a policy approach which is capable of recognising inter-relationships at a strategic scale, both within the Black Country and between the Black Country and the wider West Midlands.

The supply chain of materials processing which drives the construction materials supply and resource management sectors transcends administrative boundaries and growth and development proposals in an area such as the Black Country can impact on its effectiveness across a wider area. Under the terms of a Protocol agreed in 2014 and to which the Black Country Boroughs are all signatories, WPAs are invited to bring to RTAB at the appropriate stages in the plan-making process any significant cross-boundary issues. With reference to Key Issue 9, therefore, RTAB would welcome the opportunity to consider the waste policy aspects of the Review as it progresses through the various stages of preparation.