Policy SA7 - Employment Allocations

Comment

Representation ID: 4093

Received: 13/12/2022

Respondent: Staffordshire Police

The Council should continue to consult Staffordshire Police regarding potential employment sites, for both the buildings themselves and car parks.

Object

Representation ID: 4132

Received: 19/12/2022

Respondent: Peveril Securities ltd.

Agent: S Drury

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In order to recognise the benefits that the Hilton Cross site has to complement WMI, the Hilton Cross allocation should be extended to provide more land for well-located small scale employment opportunities close to the M54. The proposed extension to Hilton Cross would be served by a new access from the A460 and its release would result in defensible boundaries to the Green Belt being established in the form of existing roads/tracks and tree belts. This allocation should be for Class E(i), (ii) and (iii).

Object

Representation ID: 4133

Received: 19/12/2022

Respondent: Bericote Properties Limited

Agent: Sheppard Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The current green belt boundary at site E51a and E51b is illogical and the site does not meet any of the 5 purposes of the Green Belt - the land will be surrounded by development at WMI

The allocation would help address an undersupply of employment land towards local needs of 9ha. There is a lack of choice and flexibility in the employment land supply with a lack of small-medium logistics units. Units only likely to be delivered on ROF Featherstone, Hilton Cross and Vernon Park over the plan period and there are deliverability concerns with ROF. Bericote’s site at Gravelly Way should be allocated to provide more choice, in a location close to West Midlands Interchange where there will be increased demand for supply chain service.

Not allocating E51a/b is not supported by the evidence (EDNA) with some poorer performing sites being allocated. The development could also create in the region of 325 jobs on site and produce GVA of up to £23.8m per annum when operational. The development therefore offers considerable economic benefits.

Retaining Bericote’s sites as Green Belt is not an appropriate strategy and therefore not justified. The retention of these sites as Green Belt does not meet current national policy in relation to the necessary openness and permanence of Green Belt boundaries or the need for Green Belt to meet the Five Purposes to some degree. taking into account it’s evidence base. It is not Positively Prepared as it does not provide, as a minimum, to meet the area’s objectively assessed needs for local employment sites.

Object

Representation ID: 4156

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

See objections to policies DS4 & DS5

Object

Representation ID: 4158

Received: 19/12/2022

Respondent: Nurton Developments Ltd

Agent: JLL

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy SA7 needs to identify new sites which will fill the gap across the FEMA, both quantitatively and qualitatively. The potential strategic employment site at Hilton Park at Junction 11, M6, is best placed to help fill this gap.

The assessment of the site at Hilton Park (Site ref E43) is flawed as the site includes many significant advantages. These include proximity to M6 J11, A460 and M54/M6 link road, access to workforce, and being a regular shaped site large enough to accommodate a critical mass of buildings of varying sizes for B1, B2, B8 employment. The M54/M6 link road will significantly increase capacity along the A460. The site is also free of major constraints.

The assessments had not taken into account technical information supplied by JLL about the site’s capacity for development. The Council's assessment paper for the site includes an incorrectly drawn boundary for the site and the Green Belt Assessment 2019 has not been updated to take account of the M54/M6 link road and its impact on the Green Belt harm rating for the parcel of land.

The plan needs to identify and allocate new sites to meet the shortfall of available development land to meet local needs. This shortfall has been identified by JLL to be at least 90 hectares. Hilton Park is an obvious candidate for a new freestanding strategic employment site. This development opportunity should be reassessed by the Council in light of the technical information provided and its assessment in the West Midlands Strategic Employment Sites Study 2021, prior to allocating additional sites through Policy SA7, to meet fully the needs for new employment development land for the district

Support

Representation ID: 4308

Received: 22/12/2022

Respondent: Cllr Robert Cope

I support the economic development needs assessment [EDNA 2022] and its evidence based local needs. In regards to the unmet need of the Black Country I support the employment land contribution being made to the Black Country by South Staffs Council, however any further shortfall should be made up by other authorities with economic employment connections to the Black Country, regarding the proposal for employment land at Hilton Park Junction 11 the release of this green belt site is inappropriate in this plan period as there is adequate land available at WMI.

I therefore wish to present my views on the above and participate at the relevant hearing sessions to the appointed inspector.

Support

Representation ID: 4317

Received: 20/12/2022

Respondent: Cannock Chase Council

The proposed employment sites and the proposed employment allocations of the West Midlands Interchange as an employment allocation for a Strategic Rail Freight Interchange in accordance with the existing Development Consent Order is supported and we acknowledge its removal from the Green Belt. We recognise the impact the site will make to the employment land requirement within Cannock Chase District as evidenced in the West Midlands Strategic Rail Freight Interchange: Employment Issues Response Paper - Whose need will the SRFI serve? (Stantec Feb 2021).

Comment

Representation ID: 4333

Received: 22/12/2022

Respondent: National Grid C/O Avison Young

Following a review of the above Development Plan Document, we have identified that one or more proposed development sites are crossed or in close proximity to National Grid assets. This includes ROF Featherstone.

Object

Representation ID: 4373

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to Policy SA7 ‘Employment Allocations’ on the basis that it is not justified or supported by appropriate evidence. The policy does not provide sufficient employment land to address the needs of South Staffordshire during the Local Plan period. WMI although allocated will only contribute 18.8ha to South Staffordshire.

it is considered that there is a significant shortfall of employment land in South Staffordshire of between 76 ha and 257 ha, based on the scenarios considered. As such further employment sites need to be allocated to meet the needs of the district and wider FEMA in the
plan period.

As the only remaining non-Green Belt site located on a motorway junction in South Staffordshire, which is not constrained by other factors such as flood risk, the Junction 13 site at Dunston is a logical location for employment development. Furthermore the site is the only remaining site recommended in the EDNA Part 2 as being suitable for allocation.Land at Dunston is ideally located to cater for the significant demand for Industrial and Logistics premises. The vision documents demonstrate the sites deliverability directly adjacent to a junction of an important motorway.

Request that the site (17.61ha) is added as an allocated site in Policy SA7 along with the following wording:

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.

Comment

Representation ID: 4467

Received: 22/12/2022

Respondent: Historic England

Site E33 has a Development Consent Order and that various heritage assessments and mitigation measure were part of this approach. As such we have no additional comments to raise at this time.
Site E44 i54 a mitigation measure should be included which incorporates appropriate archaeological investigation and mitigation to support planning applications pre-determination.

Comment

Representation ID: 4694

Received: 23/12/2022

Respondent: National Highways

The West Midlands Interchange site has now been formally allocated but benefits from consent through the Development Consent Order process, including requisite mitigation measures pertaining to the SRN. Similarly the ROF Feahterstone site is also consented and mitigation pertaining to the A449 agreed. As no additional employment sites above the existing supply have been identified since the Preferred Options consultation we have no further comments to provide.

Support

Representation ID: 4868

Received: 15/12/2022

Respondent: ST FRANCIS GROUP

Agent: Carneysweeney

Supportive of the approach to employment strategy, and support for the former ROF site (site E18) as an employment allocation.

Comment

Representation ID: 4869

Received: 15/12/2022

Respondent: ST FRANCIS GROUP

Agent: Carneysweeney

There is a discrepancy regarding the extent of the 'Green Infrastructure' boundary (purple line) in relation to Inset Plan 53, ROF Featherstone. The extent of the employment allocation appears to be based on what would be the area of built form under the approved outline planning permission. However the purple 'Green Infrastructure' line extends beyond the approval and also includes land which is shown on the approved Illustrative Masterplan to include 'built development'.

The draft Policies Map should be amended so that the boundary of the employment allocation and any 'Green Infrastructure' reflects the extent of the outline planning approval (20/01131/OUT).

Object

Representation ID: 4905

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Land to the north of Wall Heath should be allocated under SA7 and Table 9 for 80ha of mixed employment in view of the need to allocate 183.6ha in the District overall, in recognition that the Regulation 19 Plan fails to make proper provision for employment land needs, in part due to an over reliance on WMI for meeting local needs.

The site is also well defined by existing, physical boundaries meaning that, in Green Belt terms, its release from the Green Belt can be done so with identifiable boundaries containing the site. In landscape terms the site is very well contained within its own boundaries and is not expected to make any material impact on the wider
landscape. in transport terms it is not expected that the site will require anything other than localised alterations to junctions to accommodate the scale of development proposed

There is a clear need to allocate further land for employment purposes to meet both the needs of South Staffordshire and the Black Country. Such an
allocation should take place as close as possible to the Black Country boundary in order to help support expansion of existing businesses in that area. The failure of the Council to identify appropriate levels of land to meet the Black Country overspill means that it cannot be said to address the Duty to Cooperate in a meaningful way

Comment

Representation ID: 4999

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Lichfields

Omission employment site: Land at Gailey Lea Farm (Site Ref: E58a and E58b).

The site is ideally located in an area that will appeal to regional and national companies looking to capitalise on the opportunity and connections presented by the recently approved WMI, whether that be manufacturers, or rail-linked storage and warehousing. As such, Richborough’s ‘Vision’ for the Site comprises a high-quality, sustainable, attractive and accessible development, complementing the existing WMI in the area. In this context, Richborough has prepared a Vision Document which was submitted in April 2022 in support of Richborough’s earlier Call for Sites submission in December 2021 – a copy of this Vision Document is appended to the representations accordingly (Appendix 3).

The site will deliver a number of economic, social and environmental benefits.