Publication Plan April 2024

Object

Representation ID: 6152

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Consider that Sandwell MBC is included when assessing the needs of the FEMA due to location on the M6M5 corridor. We recommend that the priority is to seek an agreement to the SoCG by all of the relevant local planning authorities, to provide certainty in relation to both employment and housing requirements for the plan period. Suggest SoCG is updated to reflect outcome of the 2024 WMSESS once published.

Object

Representation ID: 6153

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Still consider that the employment need identified in the Publicatiton Plan is an underestimation as evidenced by the Savills Industrial and Logistics (I&L) Needs Assessment – Addendum Note (May 2024) (Appendix 2) and the Savills Industrial and Logistics Needs Assessment (February 2024) (Appendix 1) accompanying these representations.

SSDC Updated EDNA has limited regard to current day market drivers which we consider has led to an underestimation of ‘true’ market demand for I&L uses in South Staffordshire and has limited regard to market signals. EDNA update also does not take account of demand lost due to supply constraints.

Object

Representation ID: 6154

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

A windfall employment policy should be added to the Plan, to allow other employment sites to come forward if the market supports them. This should be in the form of a separate policy or additional wording to an existing policy. Please refer to our responses to Policy DS3 and EC3.

Support

Representation ID: 6155

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Strategic Objective 6 is supported. The additional allocation at Junction 13, M6 will assist in meeting this objective and is strongly supported.

Object

Representation ID: 6156

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Consider Policy DS3 should be amended to enable the delivery of additional large-scale employment sites in appropriate open locations, as and when required to address the needs of SSDC and the wider FEMA.

It is requested that the following additional text be included in Policy DS3 as a penultimate paragraph in the policy:

"Where evidence indicates an immediate need or demand for additional employment land (Class E(g)ii, E(g)iii, B2 and B8 or sui generis employment generating uses) that cannot be met from land allocated in this plan, the Council will favourably consider proposals that meet the identified need in appropriate locations outside of the district’s settlements in the open countryside. Such development should be delivered in accordance with the requirements of other policies within the local plan."

It is also requested that the fourth paragraph of Policy DS3 be amended as follows to provide the flexibility needed to address the employment needs of South Staffordshire:

"All types of development in the Open Countryside which are not explicitly supported by Policy DS3 will be considered on a case-by-case basis. Such proposals will only be permitted on best and most versatile agricultural land where the benefits of the scheme outweigh the economic and other benefits of that agricultural land and are fully consistent with any other relevant policies set out elsewhere in the Local Plan. These include, but are not limited to, policies which relate to the district’s:..."

Object

Representation ID: 6157

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We do not agree with the wording of paragraph 5.54, which suggests that M6 Junction 13, Dunston (E30) is only required to address the unmet needs in the Black Country FEMA and not South Staffordshire’s own need. The site is capable of meeting the demand arising in South Staffordshire as well as the FEMA, and should not be categorised into meeting unmet needs of neighbouring authorities only. Indeed, the Savills Addendum Note concludes that, regardless of what demand scenario you consider, the Site is needed to accommodate South Staffordshire’s demand.

It recommended that paragraph 5.54 is amended as follows:

"It concluded that in terms of strategic employment land, 27.6ha of surplus land (excluding WMI) could reasonably be attributed to cross boundary unmet needs in the Black Country FEMA. The allocation of land at M6 Junction 13, Dunston (17.6ha) is required to boost the supply pipeline to ensure plan flexibility and that the pipeline of sites more closely reflect recent take up."

Object

Representation ID: 6158

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We consider that the 2024 EDNA underestimates the employment need, with our analysis indicating a shortfall in supply in South Staffordshire alone of between 15ha and 63ha. We therefore object to part b) of policy DS4, which sets out the employment needs for SSDC.

The employment land needs for South Staffordshire should be uplifted to address methodological weaknesses within the EDNA, to reflect significant demand arising within the wider FEMA and to embed flexibility in the delivery of employment land.

Object

Representation ID: 6159

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

In order to be effective and justified, we consider the further flexibility within the Plan is required to ensure that it is capable of adapting to increased demand for employment land within the District and the FEMA.

It is requested that the following additional text be included in Policy DS5, following the section relating to ‘free standing strategic employment sites’:

"Other Employment Locations
Where evidence indicates an immediate need or demand for additional employment land (B1, 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 and freestanding strategic employment sites. Such development should be delivered in accordance with the requirements of other policies within the local plan."

Object

Representation ID: 6160

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We do not consider that the identified objectively assessed need for employment land for South Staffordshire is sufficient ‘to meet South Staffordshire’s needs as well as provide surplus available to contribute towards cross boundary unmet needs’

The objectively assessed need for employment land for South Staffordshire over the period 2023-2041 should be reviewed and uplifted, taking into considerations the analysis contained within the Savills Industrial and Logistics (I&L) Needs Assessment – Addendum Note (May 2024) (Appendix 2) and the Savills Industrial and Logistics Needs Assessment (February 2024) (Appendix 1).

Object

Representation ID: 6161

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We do not agree with Table 9 as currently written in the Plan. We also consider that the site at i54, Wobaston Road (2.4 hectares) (E24) is overestimated in terms of the land that it can deliver for employment. It is also noted that I54 western extension (north) (E44) is ‘restricted to E(g)/B2 use which means it can only respond to a limited component of market demand.