Publication Plan April 2024

Object

Representation ID: 6162

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

For Junction 13, M6, it should be recognised that the site is strategically located on the M6 corridor, and is capable of delivering both mid and big box units. Whilst we agree that the Junction 13 site allocation is necessary and is capable of contributing towards the wider needs of the FEMA, we do not agree that it only required to meet unmet needs.

Wording should be amended as follows:

"‘The plan also allocates an additional strategic employment site at M6 Junction 13, Dunston. This site has the advantage of being non-Green Belt land and is strategically well located adjacent the motorway junction. pipeline of sites in the district. Furthermore, the site’s location aligns with a potential broad location for strategic employment land in the West Midlands Strategic Employment Sites Study (2021). It is of a scale capable of delivering strategic scale employment units, and given its location, is deemed suitable for allocation, and will be subject to further detailed scrutiny through the Development Management process."

Support

Representation ID: 6163

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

We strongly support M6 Junction 13, Dunston (E30) being included as a draft employment allocation in the Publication Plan. The Site is a non-Green Belt strategic employment opportunity located on Junction 13 of the M6. A Planning Application for Outline Planning Permission was submitted to SSDC in December 2023 (reference 23/01080/OUTMEI) which demonstrates the site’s deliverability. Subject to approval of the outline planning permission and subsequent reserved matters, the site is capable to delivering employment floorspace in the short term. The proposal will provide a significnant number of key benefits for the local community and wider district

Object

Representation ID: 6164

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We object to Policy EC1 ‘Sustainable Economic Growth’ as currently written, on the basis that the proposed employment land strategy is not currently justified or supported by appropriate fully tested evidence (NPPF paragraph 35).

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.

An additional policy or policy wording (added to Policy DS3 or EC4) should be included that supports windfall employment coming forward.

Support

Representation ID: 6165

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

We support Policy EC3 as written. As part of the outline planning application for the M6 Junction 13, Stafford (E30) Site, St. Modwen Logistics is in the process of preparing an employment and skills plan in accordance with the policy.

Object

Representation ID: 6166

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We object to the policy NB4, because it is not in accordance with national policy, justified or effective. This policy proposes to strengthen the protection of trees and hedgerows. The NPPF protects ancient woodland and ancient and veteran trees (paragraph 186c), there is no national requirement to protect all trees.

In order for Policy NB4 to be consistent with national policy (paragraph 35d), it should be amended to remove protection of trees which are not defined as ‘irreplaceable habitats’ (NPPF Annex 2).

Object

Representation ID: 6167

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

It is suggested that Policy EC4 is amended to recognise of the importance of motorway junction locations to the delivery of industrial and logistics development.

It is requested that the following additional text be included at the end of Section 2 of Policy EC4:

"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 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: 6168

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Any specific requirements which go beyond the current Local Plan and national guidance need to be supported by an appropriate evidence base, including a viability assessment. In this context we have a number of concerns with regards to a number of requirements set out in the Council’s sustainability and net zero policies.

We object to section ‘B1. BREEAM’ of the policy as written which states that ‘BREEAM outstanding should be targeted and the proposal will be afforded weight in favour where this is achieved.’ It is considered that the target should be ‘excellent’ rather than ‘outstanding’.There can, however, be specific circumstances where achieving Excellent or higher can be challenging due to specific site constraints. We would therefore recommend that the policy is updated to provide flexibility and an option for justifying why this might not be achievable. If the target is retained it should reference BREEAM version 6.

We object to the wording in section B2. Energy Efficiency which states: ‘new non-residential development proposals are expected to achieve a 15% improvement in Part L…’
In light of the 13th December WMS this should be deleted or reworded to ‘encourage’ rather than ‘expect’ improvements against Part L.

We object to the wording used in Policy B3.On-Site renewable energy. The policy as written states: ‘non-residential development must demonstrate the fullest feasible and viable use of on-site renewable energy generation and/or connection…’. We consider that ‘must’ should be amended to ‘where possible should…’.

We object to the wording used in B5. Smart Energy Systems and consider it should allow for more flexibility. The use of the word ‘should’ should be swapped to ‘where possible’.

Object

Representation ID: 6170

Received: 31/05/2024

Respondent: St Modwen

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We object to the policy as written. It is not considered common practice to undertake a whole life carbon assessment.If a “limit” is introduced, further flexibility is required to account for abnormal/unavoidable site-specific drivers of carbon which will influence the ability to limit embodied carbon. National embodied carbon targets may supersede local requirements and a caveat to the policy should be introduced to reflect this.