Publication Plan November 2022

Object

Representation ID: 4134

Received: 19/12/2022

Respondent: Nurton Developments Ltd

Agent: Nurton Developments Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

The employment need figure in Policy DS4 is not reliable and will result in a significant reduction the recent pace of development for industrial and warehouse premises in the District. On a past completions trend method large completions at i54 and Four Ashes have been considered atypcial and excluded from the analysis which has a large effect on past completion rates. Including Four Ashes in a past completions analysis would result in an increased employment land requirement of 127ha. The past trends analysis in undermines the use of the labour demand basis of assessment and should have led to the conclusion that reliance on a projection based on labour demand is unjustified. JLL considers that the local need for employment land for South Staffordshire must be totally reassessed.

The supply of employment land is an overestimation including relying on land at i54 western extension, ROF Featherstone and land at Hobnock Road. i54 and ROF were allocated through the 2018 SAD on the basis on meeting unmet Black Country needs.This reduces the supply to 17.8ha, Overall there is a qualitative shortfall of over 90ha. This shortfall is substantial, quantitatively, and requires the immediate identification of new sites to ensure that the employment land needs of the district are met

The plan also disregards the findings of the West Midland Strategic Employment Sites Study and the qualitative need from this study should be reflected in Policy DS4. This reference should also highlight the opportunities offered by the M54/M6 link road, for unlocking development potential for strategic employments sites.

Object

Representation ID: 4158

Received: 19/12/2022

Respondent: Nurton Developments Ltd

Agent: Nurton Developments Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy SA7 needs to identify new sites which will fill the gap across the FEMA, both quantitatively and qualitatively. The potential strategic employment site at Hilton Park at Junction 11, M6, is best placed to help fill this gap.

The assessment of the site at Hilton Park (Site ref E43) is flawed as the site includes many significant advantages. These include proximity to M6 J11, A460 and M54/M6 link road, access to workforce, and being a regular shaped site large enough to accommodate a critical mass of buildings of varying sizes for B1, B2, B8 employment. The M54/M6 link road will significantly increase capacity along the A460. The site is also free of major constraints.

The assessments had not taken into account technical information supplied by JLL about the site’s capacity for development. The Council's assessment paper for the site includes an incorrectly drawn boundary for the site and the Green Belt Assessment 2019 has not been updated to take account of the M54/M6 link road and its impact on the Green Belt harm rating for the parcel of land.

The plan needs to identify and allocate new sites to meet the shortfall of available development land to meet local needs. This shortfall has been identified by JLL to be at least 90 hectares. Hilton Park is an obvious candidate for a new freestanding strategic employment site. This development opportunity should be reassessed by the Council in light of the technical information provided and its assessment in the West Midlands Strategic Employment Sites Study 2021, prior to allocating additional sites through Policy SA7, to meet fully the needs for new employment development land for the district