Object

Representation ID: 4485

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to Policy EC4 ‘Rural Economy’ on the basis that the proposed employment land strategy is not justified or supported by appropriate evidence, or positively prepared. The plan does not identify sufficient employment land to address the needs of South Staffordshire during the plan period and as such flexibility is required in Policy EC4 to enable additional sites to come forward to address the identified need.

Provisions in EC4 Part 2 for rural employment proposals require developments to be ‘small in scale’ and comprising the ‘conversion and reuse of rural buildings’. This is extremely restrictive and greatly limits development in rural areas.

Policy EC4 fails to take account of the importance of motorway junction locations to the delivery of industrial and logistics development.The policy also fails to recognise that many medium and large employment sites within rural areas are capable of delivering sustainable economic growth. Such sites may benefit from
access to public transport and active travel routes.

it is considered that there is a significant shortfall of employment land in South Staffordshire of between 76 ha and 257ha. Policy EC4 should be amended to enable the delivery of additional employment sites in rural areas, as and when required to address the identified needs of SSDC and the wider FEMA.

It is requested that the following additional text be included at the end of Section 2 of Policy
EC4:

'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.'