Object

Representation ID: 4134

Received: 19/12/2022

Respondent: Nurton Developments Ltd

Agent: JLL

Legally compliant? No

Sound? No

Duty to co-operate? No

The employment need figure in Policy DS4 is not reliable and will result in a significant reduction the recent pace of development for industrial and warehouse premises in the District. On a past completions trend method large completions at i54 and Four Ashes have been considered atypcial and excluded from the analysis which has a large effect on past completion rates. Including Four Ashes in a past completions analysis would result in an increased employment land requirement of 127ha. The past trends analysis in undermines the use of the labour demand basis of assessment and should have led to the conclusion that reliance on a projection based on labour demand is unjustified. JLL considers that the local need for employment land for South Staffordshire must be totally reassessed.

The supply of employment land is an overestimation including relying on land at i54 western extension, ROF Featherstone and land at Hobnock Road. i54 and ROF were allocated through the 2018 SAD on the basis on meeting unmet Black Country needs.This reduces the supply to 17.8ha, Overall there is a qualitative shortfall of over 90ha. This shortfall is substantial, quantitatively, and requires the immediate identification of new sites to ensure that the employment land needs of the district are met

The plan also disregards the findings of the West Midland Strategic Employment Sites Study and the qualitative need from this study should be reflected in Policy DS4. This reference should also highlight the opportunities offered by the M54/M6 link road, for unlocking development potential for strategic employments sites.