Publication Plan November 2022

Object

Representation ID: 4872

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policy EC1 identifies 5 strategic employment sites. However of these, Hilton Cross is now largely developed and the West Midlands interchange is designed for regional/national requirements and is unlikely to meet the needs of local businesses. Land at I54 is also largely taken up. In this context further land needs to be developed and the policy should be amended to make it clear that other development opportunities are being brought forward to meet the needs of the Black Country overspill which have not been met.

In this context it is noteworthy that the policy does not make reference to meeting the wider needs of the Black Country. In this context the plan does not meet the Duty to Cooperate by failing to meet the needs of other authorities who have a functional and economic relationship with South Staffordshire. As it stands the strategy for employment land delivery fails the tests of soundness.

A new paragraph should be added to EC1 as follows:

'Further land will need to be released to meet the overspill employment needs of the Black Country and allocations have been made as set out on the proposals map in this regard.'

The strategy will be justified, meeting known requirements and would be preferable to the alternative of not meeting these.

Finally the plan, as modified, would then be in line with national policy regarding economic development and the economic strand of sustainability.

Object

Representation ID: 4873

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Strategic Objective 6 - The strategic objective fails to embrace the need to accommodate the overspill employment requirements from the Black Country, and essentially affects the Duty to Cooperate and is a fundamental element for the test of soundness. The failure to embrace this point means that the plan has not progressed in accordance with the test of soundness and will fail to provide for the overspill needs of the Black Country. As such, the plan fails the tests of soundness.

We suggest that strategic objective 6 is amended by the addition of the following wording:

“Development and economic strategy that seeks to retain existing employment and foster sustainable economic growth including appropriate allocations to accommodate overspill employment land requirements from the Black Country, encouraging inward investment and job creation and key sectors such as advanced manufacturing and providing the skills to enable residents to access these job.”

Object

Representation ID: 4874

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The employment figure set out in Policy DS4 is not sound and the amount of land which needs to be found for development needs to be increased significantly. The policy should be amended by removal of references to contributions from WMI (which would otherwise be regarded as windfalls if they do meet the requirements
for local businesses); this would mean that the amount of land to be developed to meet local needs should be increased by 18.8 hectares, the figure of 1.2 hectares
to be discounted from surplus office floorspace should be removed from the figures and the contribution which will meet the Black Country overspill should be reduced
to 16.6 hectares in terms of the surplus element in the South Staffordshire supply.

Given the strong economic connections between South Staffordshire and the Black Country area, it is submitted that a further 84.6 hectares of land should be allocated in addition to 99 hectares identified in DS4 and with an appropriate amendment made to the proposals map. This gives a total of 183.6 ha to be allocated.

Such an approach would address the Objector’s concerns regarding the Duty to Cooperate and meeting the needs of adjoining authorities and would also ensure compliance with the tests of soundness.

Object

Representation ID: 4893

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

There is no significant impact caused by the release of the land at Wall Heath off the B1476 and A449 for employment in terms of Green Belt objectives and it is clear that Green Belt land has to be released to meet development needs for both South Staffordshire and the Black Country conurbation. Once the site is taken out of the Green Belt, the Green Belt boundaries will not need to be redrawn at the end of the plan period in accordance with NPPF para 143f.

The Green Belt boundary, once redrawn to accommodate the omission site, would help to meet requirements for sustainable development. It provides an opportunity for
close links with the Black Country and the Council’s assessment sheet for the objection site, notes that the site is in a location “in close proximity to Dudley urban
area there is a strong employment population catchment, whilst public transport networks operate around the site”. Clearly the sustainability credentials of the site
have been established by the Council itself; it makes sense to release land which has close links to the conurbation rather than land which is further away and which will increase length of journeys.

The Objector considers that the failure of the Council to allocate the site for employment development is not in accordance with the principles of the Duty to
Cooperate process and also renders the plan unsound.

The proposals map needs to be amended by the removal of the objection site from the Green Belt. Green Belt boundaries will be redrawn to the extent of the site.

Object

Representation ID: 4904

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Should the argument to release the land adjoing Wall Heath south of the B4176 and west of the A449 for employment land then the site should be identified as safeguarded land.

It is clear that South Staffordshire, being on the edge of the Black Country conurbation, will have to accept a significant amount of overspill development, for both housing and employment, both in this plan period and beyond, particularity given lack of PDL land in the District. It is considered that the Council’s failure to identify safeguarded land to meet development needs beyond the plan period is contrary to the clear advice set out in the Framework (Para 140). Therefore, the plan fails the test of soundness set out at paragraph 35. Paragraph 143e also states that local authorities should demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period. Quite clearly the Council is unable to demonstrate this matter.

Object

Representation ID: 4905

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Land to the north of Wall Heath should be allocated under SA7 and Table 9 for 80ha of mixed employment in view of the need to allocate 183.6ha in the District overall, in recognition that the Regulation 19 Plan fails to make proper provision for employment land needs, in part due to an over reliance on WMI for meeting local needs.

The site is also well defined by existing, physical boundaries meaning that, in Green Belt terms, its release from the Green Belt can be done so with identifiable boundaries containing the site. In landscape terms the site is very well contained within its own boundaries and is not expected to make any material impact on the wider
landscape. in transport terms it is not expected that the site will require anything other than localised alterations to junctions to accommodate the scale of development proposed

There is a clear need to allocate further land for employment purposes to meet both the needs of South Staffordshire and the Black Country. Such an
allocation should take place as close as possible to the Black Country boundary in order to help support expansion of existing businesses in that area. The failure of the Council to identify appropriate levels of land to meet the Black Country overspill means that it cannot be said to address the Duty to Cooperate in a meaningful way