Publication Plan November 2022

Object

Representation ID: 4343

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

Cooperation between the local authorities which form the South Staffordshire Functional Economic Market Area (FEMA) is essential to ensuring an appropriate supply of land to address future needs. An agreed Duty to Cooperate Statement of Common Ground is required for the South Staffordshire FEMA. This should confirm the requirements of the FEMA local authorities and Sandwell, following the termination of the joint Black Country Plan preparation. Without a full understanding of the implications of this on the requirements of the FEMA authorities and wider West Midlands, the employment land requirements for SSDC cannot be confirmed.

Object

Representation ID: 4344

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

The employment land needs for South Staffordshire and the wider FEMA authorities are queried, due to the inconsistencies between the methodologies used for individual EDNAs. Additionally, it is considered that all of the FEMA EDNAs under-forecast employment requirements. The methodology used should be reviewed, as per Savills recommendations in its Industrial and Logistics Need Assessment. This variance in approach mainly stems from the EDNAs being statistical constructs that do not consider market conditions which influence demand. Suppression demand is not dealt with other than apply arbitrary flexibility margins. The Savills Industrial and Logistics Need Assessment identifies a shortfall within South Staffordshire specifically, to be of 76ha - 257 ha.

It is essential that the employment evidence base provides a true representation of the future requirements of the area. As such an updated EDNA should be produced which addresses the methodology points raised.

The landscape sensitivity of the land now being promoted (17.6ha) is less than the wider site .

Object

Representation ID: 4345

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

SA is based on a significant underestimation of employment need in South Staffordshire and the wider FEMA. SA does not reach conclusion on whether employment Option A-C are the best way forward. It is considered that Employment Growth Option C is the appropriate way forward. It is noted that all options have a neutral score (SA Vol 2 Table 5.6) in relation to ‘Transport and Accessibility’. The assessment does not take into account the potential for locating freestanding
employment sites where they would have direct access to the strategic highway network. Furthermore, it is unclear why only option B received negative scores in terms of biodiversity and landscape

Additional allocations will be required to address both the FEMA’s employment needs and also SSDC’s needs. The SA should be revised to address the findings of an updated EDNA. The SA assessment carried out for E30 ‘Land south of Junction 13 (M6)’ should be re- assessed in light of the reduced site area which is now being promoted (17.6ha).

Object

Representation ID: 4346

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

The development of an industrial and logistics site at junction 13 would make a significant contribution to providing a wide range of jobs, requiring a breath of skills and experience, within South Staffordshire which would be available to existing and future residents of the district. Opportunity for employment site at Junction 13 to serve new residents at Penkridge development. Junction 13 is the only remaining none Green Belt employment site options along the motorway network.

Object

Representation ID: 4348

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

A industrial and logistics site at junction 13,would make a significant contribution to providing a wide range of jobs within South Staffordshire which would be available to existing and future residents of the district.

In both South Staffordshire and the FEMA there has been an under supply of employment land and premises. That constraint has suppressed demand as not all occupiers have been able find space to meet their needs. As a result businesses have had to look outside of the area to find suitable premises, taking the jobs and investment they generate with them.As such, the EDNA should be reconsidered to ensure sufficient employment land is made available.

Object

Representation ID: 4349

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

Table 5 states that ‘when planning to meet housing needs, authorities should direct development away from Green Belt where possible’. This section should reference both housing and employment needs.The site at Junction 13 is not in the Green Belt so would achieve the objective of protecting the Green Belt

Object

Representation ID: 4361

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 2 is supported however all the FEMAs EDNAs have underestimated employment requirements. The methodology used should be reviewed, as per Savills recommendations in its Industrial and Logistics Need Assessment. Object to the evidence base supporting Strategic Objective 2.

Strategic Objective 6 is supported however suppressed demand as a result of under forecasting will mean that the Local Plan does not fulfill the requirements of Strategic Objective 6. Industrial and logistics development have a critical infrastructure role. Sites located directly adjacent to major motorway junctions such as Land at Dunston are critical to facilitating this growth in accordance with the requirements of Paragraph 83 of the NPPF. However, as matters stand, the Plan significantly underestimates the true extent of demand in the sector, and fails to deliver sufficient allocations to achieve Objective 6.

Object

Representation ID: 4362

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to Policy DS3 ‘Open Countryside’ on the basis that the proposed employment land strategy is not justified or supported by appropriate evidence.It is considered that there is a significant shortfall of employment land in South Staffordshire of between 76 ha and 257 ha and that further allocations are required. To ensure that South Staffordshire’s future employment needs are met, Policy DS3 should be amended, similar to the approach taken in the North West Leicestershire Local Plan, to provide sufficient flexibility to enable the delivery of additional employment sites in the open countryside (outside of the Green Belt), as and when required to address the identified needs of SSDC and the wider FEMA.

Policy DS3 should be amended with the following added as a penultimate paragraph to the policy:

'Where evidence indicates an immediate need or demand for additional employment land (E(g), 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.'

It is also requested that the third 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. '

Object

Representation ID: 4363

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to Policy DS4 ‘Development Needs’ as written as it is not considered positively prepared or justified. The methodology and findings of the EDNA, that Policy DS4 are based on, are challenged. Junction 13 site benefits from a number of strategic advantages which make it ideal for industrial and logistics development.

it is considered that all of the FEMA EDNAs significantly under-forecast employment requirements. The methodology used should be reviewed, as per Savills
recommendations in its Industrial and Logistics Need Assessment, which is PPG compliant and represents industry best practice. The requirements in Policy DS4 ‘Development Needs’ needs to be revised to take into account updated employment needs figures for SSDC and the wider FEMA.

Object

Representation ID: 4368

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to Policy DS5 ‘The Spatial Strategy to 2039’ as written as it is not considered justified. In light of the conclusions of the Savills Industrial and Logistics Needs
Assessment (attached as Appendix A), it is considered that there is a significant shortfall of employment of land in South Staffordshire of between 76 ha and 257ha, based in the scenarios considered in the assessment. As such further employment sites must be allocated to meet the needs of the district in the plan period.

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 (E(g), 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.