Object

Representation ID: 4362

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to Policy DS3 ‘Open Countryside’ on the basis that the proposed employment land strategy is not justified or supported by appropriate evidence.It is considered that there is a significant shortfall of employment land in South Staffordshire of between 76 ha and 257 ha and that further allocations are required. To ensure that South Staffordshire’s future employment needs are met, Policy DS3 should be amended, similar to the approach taken in the North West Leicestershire Local Plan, to provide sufficient flexibility to enable the delivery of additional employment sites in the open countryside (outside of the Green Belt), as and when required to address the identified needs of SSDC and the wider FEMA.

Policy DS3 should be amended with the following added as a penultimate paragraph to the policy:

'Where evidence indicates an immediate need or demand for additional employment land (E(g), B2 and B8) that cannot be met from land allocated in this plan, the Council will consider favourably proposals that meet the identified need in appropriate locations outside of the district’s settlements in the open countryside, subject to proposals:
a. Being accessible or will be made accessible by a choice of means of transport, including sustainable transport modes, as a consequence of planning permission being granted for the development; and
b. Having good access to the strategic highway network (M6 motorway) and an acceptable impact on the capacity of that network, including any junctions; and
c. Not being detrimental to the amenities of any nearby residential properties or the wider environment.'

It is also requested that the third paragraph of Policy DS3 be amended as follows to provide the flexibility needed to address the employment needs of South Staffordshire:

'All types of development in the Open Countryside which are not explicitly supported by Policy DS3 will be considered on a case-by-case basis. Such proposals will only be permitted on best and most versatile agricultural land where the benefits of the scheme outweigh the economic and other benefits of that agricultural land and are fully consistent with any other relevant policies set out elsewhere in the Local Plan. '