Preferred Options November 2021

Object

Representation ID: 1309

Received: 13/12/2021

Respondent: J Holt & Sons

Agent: Spawforths

EDNA
Concerned that the EDNA Stage 1, does not reflect the full potential for the growth in demand for industrial and logistics land, the scenarios for Employment Growth appear to be unduly pessimistic. Sets out drivers for increased market demand. A higher margin than that currently proposed by the EDNA should be used.

In regards to the EDNA 2 - Site E30, land at Junction 13 of the M6 Motorway should be scored 'best' rather than 'good'. Land at Junction 13 of the M6 should be identified to meet the emerging needs.
It is not reasonable to include that Site E33 (interchange) can contribute 297 hectares to the supply of employment land. This is not consistent with the DCO, it is not
consistent with the proposals to remove 232 hectares from the Green Belt.

Duty to Cooperate/ Sustainability Appraisal
The Duty To Cooperate Topic Paper should also highlight the need to engage with the Greater Birmingham Authorities, to fully consider the ability of South Staffordshire to meet some of the unmet needs for employment land arising from these authorities. It is not clear from the Sustainability Appraisal of the
Preferred Options Plan, what reasonable alternatives to the quantum of employment land have been assessed. Issue taken with the Sustainability Appraisal’s assessment of the Site E30.

Object

Representation ID: 1310

Received: 13/12/2021

Respondent: J Holt & Sons

Agent: Spawforths

There is a need to update the Vision and Objectives
to provide a longer term vision (up to 30 years) for the South Staffordshire area, having regard to the provisions of Policy DS4.

Object

Representation ID: 1311

Received: 13/12/2021

Respondent: J Holt & Sons

Agent: Spawforths

Policy DS2 - Open Countryside is unduly restrictive and is not consistent with the 2021 Framework.

Support

Representation ID: 1312

Received: 13/12/2021

Respondent: J Holt & Sons

Agent: Spawforths

Concerned that Policy DS3 does not seek to establish a total requirement for employment land or establish an appropriate framework for the whole Plan period to support
the delivery of objectively assessed employment land requirements and any unmet need arising from outside South Staffordshire.

Object

Representation ID: 1313

Received: 13/12/2021

Respondent: J Holt & Sons

Agent: Spawforths

Concerned that the current approach does not provide a flexible framework for securing the provision of employment land, and to ensure sufficient choice of sites. Concerns with regards to the evidence base that underpins the identification of employment sites in Table 9.

Land at Junction 13 of the M6 Motorway should be allocated for Employment Use.