Object
Publication Plan November 2022
Representation ID: 4872
Received: 22/12/2022
Respondent: CWC Group - Clowes Developments
Agent: Harris Lamb Property Consultancy
Legally compliant? Yes
Sound? No
Duty to co-operate? No
Policy EC1 identifies 5 strategic employment sites. However of these, Hilton Cross is now largely developed and the West Midlands interchange is designed for regional/national requirements and is unlikely to meet the needs of local businesses. Land at I54 is also largely taken up. In this context further land needs to be developed and the policy should be amended to make it clear that other development opportunities are being brought forward to meet the needs of the Black Country overspill which have not been met.
In this context it is noteworthy that the policy does not make reference to meeting the wider needs of the Black Country. In this context the plan does not meet the Duty to Cooperate by failing to meet the needs of other authorities who have a functional and economic relationship with South Staffordshire. As it stands the strategy for employment land delivery fails the tests of soundness.
A new paragraph should be added to EC1 as follows:
'Further land will need to be released to meet the overspill employment needs of the Black Country and allocations have been made as set out on the proposals map in this regard.'
The strategy will be justified, meeting known requirements and would be preferable to the alternative of not meeting these.
Finally the plan, as modified, would then be in line with national policy regarding economic development and the economic strand of sustainability.