Object

Representation ID: 4997

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Lichfields

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Richborough considers that the Council’s proposed employment policy approach, set out in draft Policy DS4 (Development Needs) of the PP, is not underpinned by robust evidence. The employment need set out in the Council’s 2022 EDNA is inadequate to address the pent-up demand and risks suppressing the District’s economy for years to come. A more realistic assessment of the District’s indigenous objectively assessed employment land needs for the plan period 2020-2040 equates to c.115 ha (i.e. the Growth Scenario), or 160 ha if a higher margin of choice is factored in to reflect strategic site delivery. As such, when set against the Council’s purported forward supply of 99 ha, it is clear that the Council’s current approach would be insufficient to address the needs of the District, let alone make a meaningful contribution towards addressing the unmet needs of the FEMA or wider West Midlands Region.

Furthermore, the strategic evidence that is available suggests that the scale of unmet needs that South Staffordshire should be contributing towards is very substantial indeed; comprising potentially 98 ha to meet Birmingham’s unmet needs and between 145 ha and 165 ha of the BCA’s needs even if the 67 ha contribution from the WMI is deducted. It is therefore clear that the District has a critical role to play in delivering strategic logistics/manufacturing floorspace to address very significant levels of unmet need across Birmingham City, the Black Country and the West Midlands as a whole. As such, Richborough considers that it is premature to argue that a modest provision of 36.6 ha and the WMI represents a ‘proportionate’ contribution to meeting wider unmet needs.

In this context, Richborough is concerned that Policy DS4 (Development Needs) as it is drafted is unsound. As it is drafted, Policy DS4 (Development Needs) Richborough does not consider that the Council’s current approach to addressing its own needs, or the unmet needs of the FEMA and wider area is appropriate or justified by robust evidence, and as a result, Richborough considers that there is a cogent argument for the Council to accommodate further employment growth within the District, as it is unlikely that this could be accommodated elsewhere within the FEMA and beyond. It is therefore critical that a FEMA-wide approach to ensuring additional, well-located sites, which are capable of accommodating larger units, are brought forward through the Council’s Local Plan Review to help meet demand and deliver high-quality floor space within the FEMA. This is critical in order for the Local Plan Review to accord with paragraphs 11b, 24, 35c, 81, 82 and 83 of the NPPF and the guidance within the PPG.