Publication Plan November 2022

Object

Representation ID: 4369

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

To the north of Penkridge the A449 corridor is not located within the Green Belt and provides an opportunity for delving a new settlement. As set out in Policy DS6, a new settlement will need to be supported by a range of local employment types and premises. The delivery of further employment sites in the non-Green Belt section of the A449 corridor, north of Penkridge, would support any future new settlement in that area.

Object

Representation ID: 4373

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to Policy SA7 ‘Employment Allocations’ on the basis that it is not justified or supported by appropriate evidence. The policy does not provide sufficient employment land to address the needs of South Staffordshire during the Local Plan period. WMI although allocated will only contribute 18.8ha to South Staffordshire.

it is considered that there is a significant shortfall of employment land in South Staffordshire of between 76 ha and 257 ha, based on the scenarios considered. As such further employment sites need to be allocated to meet the needs of the district and wider FEMA in the
plan period.

As the only remaining non-Green Belt site located on a motorway junction in South Staffordshire, which is not constrained by other factors such as flood risk, the Junction 13 site at Dunston is a logical location for employment development. Furthermore the site is the only remaining site recommended in the EDNA Part 2 as being suitable for allocation.Land at Dunston is ideally located to cater for the significant demand for Industrial and Logistics premises. The vision documents demonstrate the sites deliverability directly adjacent to a junction of an important motorway.

Request that the site (17.61ha) is added as an allocated site in Policy SA7 along with the following wording:

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.

Object

Representation ID: 4415

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to Policy EC1 ‘Sustainable Economic Growth’ on the basis that the proposed employment land strategy is not justified or supported by appropriate evidence.
Policy EC1 states that the existing supply of available employment land and allocations in the plan is enough to ensure there is a sufficient supply of employment land. However, 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 land in South Staffordshire of between 76ha and 257ha, based on the scenarios considered. As such it is maintained that
insufficient employment sites are allocated within the Local Plan. To ensure that South Staffordshire’s future employment needs are met, Policy EC1 should be amended to allocate additional employment sites, whilst also providing sufficient flexibility to enable the delivery of additional employment sites, as and when required to address the identified needs of SSDC and the wider FEMA.

It is requested that the following additional text be included in Policy EC1:
'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 favorably 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: 4416

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

The acknowledgement of the important of creating more skilled jobs and increasing the retention of young, educated residents is supported. The industrial and logistics sector provides a diverse range of jobs. St Modwen actively support initiatives to improve skills, training and employment opportunities. Indeed, St. Modwen Logistics is the latest partner to join the NSCG-led consortium of education providers and employers from across the Midlands to form the Stoke-on-Trent and Staffordshire Institute of Technology (IoT) development.

By allocating additional employment land the Council would support sustainable economic growth, facilitate access to training and employment opportunities, and deliver significant socio-economic benefits. This would in turn respond positively to the opportunities provided
within the district, notably the accessibility of the Strategic Road Network, which is extremely beneficial for Industrial and Logistics occupiers and logistics companies in particular.

Object

Representation ID: 4485

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to Policy EC4 ‘Rural Economy’ on the basis that the proposed employment land strategy is not justified or supported by appropriate evidence, or positively prepared. The plan does not identify sufficient employment land to address the needs of South Staffordshire during the plan period and as such flexibility is required in Policy EC4 to enable additional sites to come forward to address the identified need.

Provisions in EC4 Part 2 for rural employment proposals require developments to be ‘small in scale’ and comprising the ‘conversion and reuse of rural buildings’. This is extremely restrictive and greatly limits development in rural areas.

Policy EC4 fails to take account of the importance of motorway junction locations to the delivery of industrial and logistics development.The policy also fails to recognise that many medium and large employment sites within rural areas are capable of delivering sustainable economic growth. Such sites may benefit from
access to public transport and active travel routes.

it is considered that there is a significant shortfall of employment land in South Staffordshire of between 76 ha and 257ha. Policy EC4 should be amended to enable the delivery of additional employment sites in rural areas, as and when required to address the identified needs of SSDC and the wider FEMA.

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(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.'

Object

Representation ID: 4486

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

Object to Policy NB2 ‘Biodiversity’ on the basis that the proposed wording is not effectively or positively prepared.

NB2 identifies a clear preference for on-site delivery of biodiversity net gain (BNG), as opposed to the provision of BNG off-site. In relation to this point, it is highlighted that on-site BNG is not always the best option in relation to strengthening the district’s nature network. On-site provision can lead to small, isolated areas of BNG land, designed primarily to fitted within a development layout. However, an off-site scheme in a strategically valuable area has the potential to make a more substantive contribution to the wider nature network.

Park C of the policy seeks to secure habitat management in perpetuity unless it can be demonstrated this is not possible. It is noted that this requirements goes beyond the 30 year requirement set out in the Environment Act 2021. As such it is considered onerous and a requirement that will be unimplementable in many cases. The policy wording should be in accordance with the Environment Act.

It is requested that parts A and C of Policy NB2 be amended as follows:

'a. Delivery of the biodiversity net-gain on-site wherever possible, unless evidence identifies an ecologically preferable off-site solution which would deliver improved biodiversity net gains, ideally within a strategically or functionally favourable location. Delivery of biodiversity net gains should be in a manner consistent with national requirements, ensuring that existing habitats on site are maintained and enhanced as a priority. Where it is demonstrated that this cannot be achieved on site, the required level of off-site biodiversity net-gain must be provided. As a last resort, statutory biodiversity credits may be acceptable.

c. Securing of the habitat for at least 30 years. This will typically be achieved via a S106 agreement, planning conditions or a conservation covenant.'