Policy EC1: Sustainable Economic Growth

Comment

Representation ID: 4217

Received: 22/12/2022

Respondent: Connectivity and Sustainability, Staffordshire County Council

HGV parking has been referenced in the policy in relation to future parking. However, this does not address the current situation. SCC’s ‘Freight Strategy for the County of Staffordshire 2019’ discusses issues with a lack of HGV parking and SCC’s previous consultation response highlighted this. However, the Local Plan has not allocated any sites for HGV parking. The Freight Strategy highlights the need for new/extended facilities in the M6 – A449 and A5 – M6 Toll corridors which are both within South Staffordshire district. SCC consider that SSC should make provision within their Local Plan and look to allocate sites.

Object

Representation ID: 4360

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The West Midlands Interchange was identified and given a Development Consent Order on the basis of the road/rail link. If removed from the Green Belt there is a distinct possibility that the road-rail interchange would not be built but the development would proceed anyway. As the consent is already in place there is no good reason to allocate the site - this could be considered again in local plan reviews once the site is constructed.

Object

Representation ID: 4415

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to Policy EC1 ‘Sustainable Economic Growth’ on the basis that the proposed employment land strategy is not justified or supported by appropriate evidence.
Policy EC1 states that the existing supply of available employment land and allocations in the plan is enough to ensure there is a sufficient supply of employment land. However, in light of the conclusions of the Savills Industrial and Logistics Needs Assessment (attached as Appendix A), it is considered that there is a significant shortfall of employment land in South Staffordshire of between 76ha and 257ha, based on the scenarios considered. As such it is maintained that
insufficient employment sites are allocated within the Local Plan. To ensure that South Staffordshire’s future employment needs are met, Policy EC1 should be amended to allocate additional employment sites, whilst also providing sufficient flexibility to enable the delivery of additional employment sites, 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 in Policy EC1:
'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 favorably 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.'

Object

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.

Object

Representation ID: 5060

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

A rigidly fixed template for the future spatial distribution of new housing and new and existing employment land development across the district has already been decided by the LPA and is being forced-through and used as the place shaping agenda going forward, from the now heavily out-of-date existing adopted Core Strategy (adopted 2012). The adopted Core Strategy (2012) (which is now 10 years old since it was originally adopted) now forms a heavily and long out-of-date Plan, based on a huge mountain of insufficiently robust, highly questionable pre-COVID-19 economic data, long out-of-date, unsound background supporting technical evidence base, and unsound spatial planning policy modelling assumptions for the future spatial distribution across the district of new employment land.
This is not a sound and robust way to undertake a Local Plan Review and does not conform with the planning policy approach expected by paragraph 31 of the Revised NPPF (2021).
contend that the Employment land policy approach being taken forward within both the Publication Stage Report (November 2022) and the accompanying not fit-for-purpose Sustainability Appraisal (SA) background evidence supporting Local Plan preparation, are clearly both unsound and are not legally compliant.
both the Publication Stage Report and accompanying SA are both failing to shape into their Plan-preparation approach the huge and unprecedented rapid shift in adverse economic circumstances now affecting the South Staffordshire District) of the Revised NPPF (2021). We have concerns about the “incapable” management and leadership approach being taken towards Local Plan preparation by the Council.

Object

Representation ID: 5401

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Amend wording to recognise that close proximity to national road network is a critical requirement for B8 use development.