Black Country Core Strategy Issue and Option Report

RTAB welcomes the preparation of an updated Waste Study, and would be pleased to contribute to its preparation and comment on its findings.The Waste Study should provide an updated assessment of additional infrastructure required to 2036, taking into account the ambitions to achieve zero waste and support the concept of the circular economy; the revised housing and economic forecasts; and assumptions/ targets to move waste up the waste hierarchy. Whilst embracing the concept of equivalent self-sufficiency as a minimum, the Study should also identify any additional provision required to provide flexibility and support the growth and development of the waste sector of the economy. It should update information on existing capacity and identify gaps in provision and any requirements which need to be met within adjacent areas.

In the context of the area's growing economy and the continuing significance of manufacturing, RTAB would urge the explicit recognition of and support for the concept of the circular economy and the associated improvements in resource efficiency, productivity and competitiveness that this could bring to the Black Country. Progress towards the circular economy will require support for more sustainable and innovative waste management provision, embracing new technologies and adapting to changes in waste recycling and energy recovery trends.

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.

The EDNA has assessed the need for land for employment purposes. It is noted that the waste sector is identified as one that has experienced significant employment growth, but it is not clear what specific allowance has been made for waste management related uses in the assessment of need. RTAB would expect that the proposed Waste Study should identify the broad requirement for land for waste management uses, including any additional provision required to provide flexibility and support the growth and development of the waste sector of the economy.

Yes, but:

The Core Strategy includes policies to safeguard existing strategic waste management capacity and enable existing waste management infrastructure to expand or relocate where appropriate. RTAB fully supports the ambitions of these policies. It would be instructive to know whether they have been invoked - whether existing sites have been successfully defended against proposals for, or lost to, other uses. Similarly, it would be helpful to be informed whether proposals for expansion, redevelopment or relocation have been supported under the terms of these policies.

RTAB has some concerns about the potential implications of the continued release of surplus employment land for housing. These concerns stem from situations where land use conflicts have occurred because 'sensitive' land uses have been allowed on land adjacent or close to established waste management operations or proposed waste development sites. This can adversely affect the waste management activity and constrain its expansion or improvement.

This situation would not appear to be addressed explicitly in the existing policy base. Current policy DEL2 addresses the way in which the balance between employment land and housing land is to be managed. Policy WM2 includes a criterion against which proposals for expansion etc of waste infrastructure uses are to be considered; this addresses the issue of 'existing land use conflicts'. Now that the Environment Agency is no longer a statutory consultee on planning applications within 250m of waste sites, RTAB would like to see a strengthened policy included in the revised Core Strategy to safeguard established waste operations and development sites from incompatible development on adjacent or nearby land.

Progress towards the circular economy will require support for more sustainable and innovative waste management provision, embracing new technologies and adapting to changes in waste recycling and energy recovery trends. In this respect, a level of waste management provision to meet the 'equivalent self-sufficiency' approach might be regarded as a minimum, and the Black Country authorities might consider building in additional provision over and above this minimum to provide for flexibility and to maximise the economic and employment potential of effective and sustainable waste management.