Publication Plan November 2022

Object

Representation ID: 4997

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Lichfields

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Richborough considers that the Council’s proposed employment policy approach, set out in draft Policy DS4 (Development Needs) of the PP, is not underpinned by robust evidence. The employment need set out in the Council’s 2022 EDNA is inadequate to address the pent-up demand and risks suppressing the District’s economy for years to come. A more realistic assessment of the District’s indigenous objectively assessed employment land needs for the plan period 2020-2040 equates to c.115 ha (i.e. the Growth Scenario), or 160 ha if a higher margin of choice is factored in to reflect strategic site delivery. As such, when set against the Council’s purported forward supply of 99 ha, it is clear that the Council’s current approach would be insufficient to address the needs of the District, let alone make a meaningful contribution towards addressing the unmet needs of the FEMA or wider West Midlands Region.

Furthermore, the strategic evidence that is available suggests that the scale of unmet needs that South Staffordshire should be contributing towards is very substantial indeed; comprising potentially 98 ha to meet Birmingham’s unmet needs and between 145 ha and 165 ha of the BCA’s needs even if the 67 ha contribution from the WMI is deducted. It is therefore clear that the District has a critical role to play in delivering strategic logistics/manufacturing floorspace to address very significant levels of unmet need across Birmingham City, the Black Country and the West Midlands as a whole. As such, Richborough considers that it is premature to argue that a modest provision of 36.6 ha and the WMI represents a ‘proportionate’ contribution to meeting wider unmet needs.

In this context, Richborough is concerned that Policy DS4 (Development Needs) as it is drafted is unsound. As it is drafted, Policy DS4 (Development Needs) Richborough does not consider that the Council’s current approach to addressing its own needs, or the unmet needs of the FEMA and wider area is appropriate or justified by robust evidence, and as a result, 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 and beyond. It is therefore critical that a FEMA-wide approach to ensuring additional, well-located sites, which are capable of accommodating larger units, are brought forward through the Council’s Local Plan Review to help meet demand and deliver high-quality floor space within the FEMA. This is critical in order for the Local Plan Review to accord with paragraphs 11b, 24, 35c, 81, 82 and 83 of the NPPF and the guidance within the PPG.

Object

Representation ID: 4998

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Lichfields

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The reasons the Council has not allocated the Site are set out in the Council’s ESES Topic Paper. Fundamentally, the Council considers that these relate to the lack of ‘need’ for additional employment land within the District to meet its needs or the unmet needs of the FEMA and that the Site performs ‘strongly’ against the five Green Belt purposes.

However, Richborough strongly contends that there is a clear and cogent need for additional employment land within the District to meet not just only the District’s own employment needs, but to assist in addressing the acute shortfall arising from the BCAs. Moreover, Richborough considers that it is entirely reasonable, and appropriate, for land which fulfils strong Green Belt purposes to be released where exceptional circumstances are evidenced (i.e., a locational requirement for the logistics sector). The supporting ELNA has clearly shown that there are no other ‘sequentially preferable’ strategic employment opportunities. As such, it is entirely reasonable to release ‘high’ performing Green Belt land at Gailey Lea to address the unmet employment needs of the FEMA.
In addition, the Council’s other reasons for discounting the Site appear to be poorly evidenced, overly critical or could easily be mitigated – as demonstrated in Richborough’s Vision Document for the Site. Indeed, this is clearly shown in the Council’s Reg 19 SA’s testing of Reasonable Alternatives, which shows that, despite the overly critical scoring in the ESES Topic Paper, the Site scores the same as other sites that the Council has elected to allocate in the PP in SA terms.
Therefore, at present, the Council runs the risk of potentially falling into a position where either the evaluation of reasonable alternatives in the SA and Site Selection Process could be interpreted to either have not been undertaken properly or to have been ‘improperly restricted’, in the context of the iterative process necessary for progressing a plan.
To this end, it is clear that through a future Local Plan Review the Council will need to release further employment land, either to address wider FEMA needs or the District’s. As shown in the ELNS Alternative Site Assessment, there are limited options for meeting these long-term needs outside of the Green Belt, by virtue of a majority of the sites that are adjacent to the SRN being within the Green Belt. As such, the permanence of the Council’s currently proposed Green Belt boundaries is in doubt, as it is very likely that the Council will again need to revisit releasing Green Belt land in due course. In this regard, the identification of additional safeguarded land will ensure that Green Belt boundaries will not need to be altered at the end of the plan period. Indeed, this is an approach that the Council has previously adopted in the current Core Strategy (2012) (i.e. Policy GB2: Land Safeguarded for Longer Term Needs). Therefore, at the very least, Richborough considers that a reasonable alternative to allocating the Site in the current Local Plan Review would be to safeguard the land for future development. This approach would be entirely in accordance with the NPPF and will ensure that the Green Belt boundaries will not need to be reviewed again until the end of the next plan period (Para 143c, NPPF).

Comment

Representation ID: 4999

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Lichfields

Omission employment site: Land at Gailey Lea Farm (Site Ref: E58a and E58b).

The site is ideally located in an area that will appeal to regional and national companies looking to capitalise on the opportunity and connections presented by the recently approved WMI, whether that be manufacturers, or rail-linked storage and warehousing. As such, Richborough’s ‘Vision’ for the Site comprises a high-quality, sustainable, attractive and accessible development, complementing the existing WMI in the area. In this context, Richborough has prepared a Vision Document which was submitted in April 2022 in support of Richborough’s earlier Call for Sites submission in December 2021 – a copy of this Vision Document is appended to the representations accordingly (Appendix 3).

The site will deliver a number of economic, social and environmental benefits.

Object

Representation ID: 5161

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Amend objectives to reflect the need to meet both present and future housing requirements including pressures arising within the GBBCHMA.

Object

Representation ID: 5162

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Strategic Objective 1 should provide clarity that meeting present and future growth requirements will necessitate Green Belt land releases.
Strategic Objective 2 could be strengthened to refer to meeting the needs of both existing and new residents.

Support

Representation ID: 5163

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Support overarching thrust that new housing should be focussed on sustainable location in the District.

Support

Representation ID: 5164

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Recognition that exceptional circumstances exist for Green Belt release and support the release of land from Green Belt for development.

Object

Representation ID: 5165

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Object to comment that the Green Belt ‘contributes towards rural character’. Green Belt is a development restraint policy and is not a landscape or character policy. Council should amend Policy DS1 and supporting text to represent national policy.

Object

Representation ID: 5166

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Introduce a safeguarded land policy. Plan should identify safeguarded land to ensure that Green Belt boundaries which will endure beyond the plan period and to maximise the District’s capability to assist the GBBCHMA unmet housing need.

Object

Representation ID: 5167

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Object to hierarchical approach in relation to Green Belt compensation. No reference to such an approach in NPPF/PPG. Whilst GB compensation in close proximity to allocation site could be advantageous it is the overall value of GB improvement which is of greater significance. Site owner may not own land in vicinity of allocated site which could lead to ransom scenarios. Elements lower in the hierarchy could deliver similar or greater benefits. Other benefits may be more significant than just the proximity to the proposed development. Benefits could include improvements to GI, woodland planting, improved active travel routes, improved recreation provision. Suggest amend policy to remove reference to hierarchy and to state that improvements could be delivered through direct improvements or via s106 contributions and that the council will seek the optimum benefits in proportion to the scale of the site being removed from the Green Belt.