Preferred Options November 2021

Object

Representation ID: 1926

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Lichfields

(b)
Richborough does not consider that the Council’s proposed approach to addressing the District’s
employment needs, and the unmet needs of the wider FEMA, proposed in draft Policy DS3 (The Spatial Strategy to 2038), would adequately deliver Strategic Objectives set out in Table 6 of the PO. In particular, it would not deliver Strategic Objective 6 or the additional Strategic Objective required to address the unmet employment land needs of the FEMA.

Object

Representation ID: 1927

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Lichfields

The PO has only made provision for c.107 ha of
employment land when excluding the WMI (See Table 9) – the supply from the WMI is not necessarily all attributed to the Council as it serves a regional role. Of this, and notwithstanding the WMI, only two strategic sites8 have been identified at ROF Featherstone and i54 (Western
Extension) with a combined capacity of 76 ha.

The Council’s evidence base
At present, there are a number of deficiencies in the Council’s approach which Richborough consider points to potentially a significantly greater level of need for B8
storage and distribution floorspace in the District and across the FEMA than is recommended in the Council’s current evidence base.

Object

Representation ID: 1928

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Lichfields

Projected Job Growth
The EDNA’s forecast job growth scenario are now nearly 4 years out of date.
It is Important to note that the national Experian forecasts of April 2021 show an increase of 1.6% nationally in the logistics sector alone by 2040, when compared to the pre-Covid 19 (March 2020) forecasts, which is largely a result of Covid-19 and Brexit.
The high level of home working as a result of the Covid-19 may also mean that future patterns of working are
changed permanently, which may have a serious knock-on effect on the need for new office space.

Object

Representation ID: 1929

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Lichfields

Past Trends/Completions:
Richborough notes that the underlying data collection and analysis contained in the Stage 1 EDNA was produced prior to the Covid-19 pandemic, with
the logistics requirements derived from net completion rates covering the 2012/13 –2017/18 period. Richborough considers that this five year period is not a reliable basis upon which to forecast a 20-year Local Plan period.

Net to Gross Employment Requirements:
The Stage 1 EDNA estimates the net employment requirements across the District without applying any additional allowances that are typically included within the recommended employment requirements.

Object

Representation ID: 1930

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Lichfields

Addressing the general employment needs of the FEMA
Whilst the Council could make provision for its c.19 ha of oversupply to meet the needs of the BCAs, it is not necessarily within the Council’s gift to apportion the WMI to neighbouring authorities as it sees fit. Even if it were accepted that the Council could distribute some of the employment land arising from the WMI to other authorities, there would still be an acute unmet need for employment land within the BCAs. However, despite this context, there is no coherent strategic approach to addressing these needs.

Object

Representation ID: 1931

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Lichfields

Addressing the demand for logistics across the FEMA
Richborough considers that the West Midlands is well-placed to meet the demand for distribution, particularly given the strong existing manufacturing base across the region.as a result of this demand from the logistics and manufacturing sectors and despite increasing supply through speculative development, the region has seen high levels of take-up, which has resulted in a critical undersupply of floor space. Richborough considers that the Council and other FEMA (or wider) authorities should explore whether the current FEMA aligns with the employment and business needs within different market segments, or whether an alternative market area might be necessary to address logistics needs.

Object

Representation ID: 1932

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Lichfields

Conclusion
Richborough considers that the Council’s proposed employment policy approach, set out in emerging Policy DS3 (The Spatial Strategy to 2038) of the PO, is not underpinned by robust evidence. The employment need set out in the Council’s Stage 1 EDNA is now markedly out-of-date.
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.
Furthermore, Richborough also considers that the need for storage and distribution has been essentially overlooked by the emerging Local Plan Review, contrary to the NPPF’s requirement for planning policies to accommodate the bespoke locational requirements

Support

Representation ID: 1933

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Lichfields

Richborough supports the Council’s proposed allocation in draft Policy SA7. It is entirely logical to rationalise the consented WMI within the emerging Local Plan Review and remove it from the Green Belt. Indeed, the adjoining Four Ashes Industrial Estate is already inset from the Green Belt, and such an approach would align with this.