Object
Publication Plan November 2022
Representation ID: 4344
Received: 22/12/2022
Respondent: St Modwen
Agent: Savills
Legally compliant? No
Sound? No
Duty to co-operate? No
The employment land needs for South Staffordshire and the wider FEMA authorities are queried, due to the inconsistencies between the methodologies used for individual EDNAs. Additionally, it is considered that all of the FEMA EDNAs under-forecast employment requirements. The methodology used should be reviewed, as per Savills recommendations in its Industrial and Logistics Need Assessment. This variance in approach mainly stems from the EDNAs being statistical constructs that do not consider market conditions which influence demand. Suppression demand is not dealt with other than apply arbitrary flexibility margins. The Savills Industrial and Logistics Need Assessment identifies a shortfall within South Staffordshire specifically, to be of 76ha - 257 ha.
It is essential that the employment evidence base provides a true representation of the future requirements of the area. As such an updated EDNA should be produced which addresses the methodology points raised.
The landscape sensitivity of the land now being promoted (17.6ha) is less than the wider site .