Draft Black Country Plan

(16)7 The Black Country Economy

Employment Land

Introduction

7.1 The policies in this chapter (Policies EMP1- EMP6) are concerned with promoting and supporting employment in manufacturing, research and development (Use Class E(g)(ii), E(g)(iii) and B2), warehousing (Use Class B8) and other uses that are appropriately located in industrial employment areas Offices (Use Class E(g)(i)) are not classed as an employment use for the purposes of these policies; they are covered by policies CEN1 - CEN7, which relate to uses that are more appropriately located in town centres.

7.2 The evidence base for the employment land policies primarily consists of a two stage Economic Development Needs Assessment (EDNA)^[19], and the Black Country Employment Area Review (BEAR)^[20]. The EDNA provides an objective assessment of the industrial land needs for the Black Country to 2039, based upon an independent assessment of the area's economic development needs.

7.3 The key conclusions of the EDNA studies are:

a) the Black Country is a clearly defined geographical unit. It has strong employment and labour market links to a hinterland that includes southern Staffordshire, north Worcestershire, Birmingham, and Solihull. The links with the City of Birmingham and the district of South Staffordshire are particularly significant;
b) the Black Country has been hit hard by the CV-19 recession but is expected to recover strongly and has the capacity to deliver significant growth, given the diversity, resilience and concentration of key national sectors located in the area;
c) even pre-COVID19, recent growth was achieved against a backdrop of a weak local skills base, low business start-up rates and low GVA per head in comparison with the West Midlands and UK averages;
d) economic development strategies including the Strategic Economic Plan (SEP) and Local Industrial Strategy seek to address these challenges to accelerate the growth of the local economy;
e) the Black Country employment land supply in 2020 was largely that inherited from the Core Strategy and the suite of Tier 2 Plans which supported it. This land supply is dominated by small sites in the urban area;
f) going forward, attracting high-growth knowledge-based industries in line with SEP ambitions will require the provision of more prestigious sites, high-quality space with easy access to key transport hubs and good connectivity;
g) the Plan also needs to ensure the Black Country can accommodate a variety of business needs, including start-ups and smaller businesses. This means that a mixed portfolio of sites will need to be made available, including larger and smaller sites and spaces (including areas of both higher and lower specification);
h) it is imperative to protect the existing supply of land to meet future needs that will arise from a high growth-driven economy;
i) there is a significant gap between the employment land supply, inherited from the Core Strategy and subsequent Tier 2 Plans, and forecast future needs.

7.4 To address these issues, the strategy that underpins the Employment Land Policies is made up of the following elements:

a) to facilitate the growth and diversification of the economy, the Plan allocates land for new development within the Black Country, to accommodate jobs and output growth (Policy EMP1);
b) to accommodate a variety of business needs including high technology manufacturing and logistics sectors, the Plan provides for a balanced portfolio of sites (Policy EMP1);
c) to protect and enhance land and premises within existing employment areas where this provides for the needs of jobs and businesses (Policies EMP2, EMP3 and EMP4);
d) to recognise that some sites will become unsuitable for continued employment uses and to facilitate their redevelopment to alternative uses including housing (Policy EMP4). However, the number of such sites is expected to be considerably less than was envisaged by the Black Country Core Strategy adopted in 2011;
e) to enable local communities to share the benefits of economic growth (EMP6).

7.5 The spatial strategy in relation to employment land is to focus new development to sites within the Core Regeneration Areas as set out in Policies CSP1- CSP3. This will be achieved through the development of currently vacant sites allocated for development in the Plan, and the redevelopment and 'intensification' of existing premises. There are also a number of opportunities on sites within the Towns and Neighbourhoods Area within Walsall. The great majority of existing employment areas which accommodate most of the Black Country's existing manufacturing and logistics jobs and businesses are also located within the Core Regeneration Areas.

Figure 6 - Black Country Employment Key Diagram

 

Providing for Economic Growth and Jobs

7.6 Policy EMP1 seeks to ensure a sufficient quantum of development opportunities are provided to meet the demand for economic growth and support the diversification of the Black Country economy. This Policy supports Strategic Priority 7.
 

 

Justification

7.7 Building a strong, responsive, and competitive economy is one of the three overarching objectives of the NPPF. This should be achieved by ensuring that sufficient land of the right type is available in the right place and at the right time to support growth, innovation, and improved productivity; and by identifying and co-ordinating the provision of infrastructure.

7.8 The NPPF specifically advises that for forecasting future trends:

a) Plan makers should consider forecasts of quantitative and qualitative need (i.e. the number of units and floorspace for other uses needed) but also its unique characteristics (e.g. the footprint of economic uses and proximity to infrastructure). The key output is an estimate of the scale of future needs, broken down by economic sectors.
b) Local authorities should develop an idea of future needs based on a range of data that is current and robust. Authorities will need to take account of business cycles and make use of forecasts and surveys to assess employment land requirements.
c) Emerging sectors that are well-suited to the area being covered by the analysis should be encouraged where possible. Market segments should be identified within the employment land under consideration.
d) The available stock of land should be compared with the particular requirements of the area so that gaps in local land provision can be identified.

7.9 To support the ongoing growth of the distribution sector and a strong resurgence in manufacturing, the EDNA recommends that this Plan should provide for a minimum of 565ha of land for employment development for the period up to 2039, based on an average of 26.4ha per annum and allowing for the replacement of some poorer quality employment land and premises redeveloped for non-industrial uses.

7.10 The BCP allocates 280ha of employment land for the period between 2020 - 2039 and provides for a further 69ha of development to come forward through the redevelopment of existing employment land and premises. Further land is provided on other sites that have planning permission for employment development. This will therefore provide for 365ha in total and will accommodate 63% of forecast needs arising within the Black Country.

7.11 The main clusters of sites are shown on the Employment Land Key Diagram to illustrate the distribution across the Black Country. The detail of employment land allocations for each Black Country authority is provided in Chapter 13.

7.12 210ha or 37% of employment land need arising in the Black Country cannot be met solely within the Black Country. This unmet need should be exported, as far as possible, to authorities that have a strong existing or potential functional economic relationship with the Black Country, for example in terms of migration patterns, commuting links and / or connectivity through physical infrastructure such as rail and motorway. This work is ongoing and will be secured through the Duty to Co-operate and evidenced through Statements of Common Ground.
 

(4)Evidence

• Economic Development Needs Assessment Part One (2017) and Part Two (2020).
• Black Country Urban Capacity Review Update (2020)
• Black Country Plan Site Assessment Report (2020)
• Black Country BEAR
• Black Country Strategic Employment Land Reviews
• Statements of Common Ground
   

Delivery

• Through the Development Management process.
• Through partnership with Economic Development Partners in promoting development opportunities and improvement programmes.
   

Issues and Options responses

7.13 A range of comments were made to the Issues and Options consultation. There was general agreement that the Plan should support additional economic growth, but views differed on how much additional land would be needed, given economic uncertainty over such a long period. Brownfield opportunities should be prioritised but there was a general recognition that green belt land will be required to come forward for development.

7.14 There was support for the Plan identifying a portfolio of employment sites to meet a variety of investment needs rather than a broad brush 'reservoir' approach. There was general agreement that there is a lack of strategic sites and the Plan should provide for large, regular, and unconstrained sites with good motorway and highway access. There was also a recognition that some 'export' of growth would be required but some responses suggesting this should be an option of last resort.
 

Strategic Employment Areas

7.15 Policy EMP2 provides for a sufficient stock of Strategic Employment Land suitable for a growing and diversified economy. This Policy supports Strategic Priority 7.
 

 

Justification

7.16 Strategic Employment Areas (SEAs) are high-quality employment areas that are considered essential to the long-term success of the Black Country's economy. They correspond to areas of the strongest occupier and market demand and are of high environmental quality with excellent links to the Strategic Highway Network, and should be protected from non-employment uses that could impact upon their viability as employment locations. These areas contain, or have the potential to attract, those knowledge-based growth sector businesses whose success will be critical to the delivery of the Black Country's economic ambitions.

7.17 Policy EMP2 is based on the approach set out in the 2011 Core Strategy, which distinguished between Strategic High-Quality Employment Areas and Local Employment Areas. The Strategic Employment Areas in the BCP are the equivalent of the [existing and potential] Strategic High-Quality Employment Areas in the Core Strategy. The EDNA recommended that the approach set out in the Core Strategy has served the Black Country well and subject to some refinement, should be carried forward into the BCP.

7.18 The characteristics and extent of the Strategic Employment Areas reflect the findings of the Black Country Employment Area Review (BEAR). The BEAR re-examined the totality of the Black Country's employment areas against a set of criteria based on those set out in the Core Strategy and the recommendations of the EDNA.

7.19 The key characteristics of Strategic Employment Areas are as follows;

a) To be highly accessible to the Strategic Highway Network, preferably well- located in relation to the motorway network, to provide good accessibility to international, national, and regional markets and supply chains.
b) To have good public transport accessibility.
c) To maintain a critical mass of active industrial and logistics sites and premises that are well suited to the needs of modern industry.
d) To maintain an existing (or develop a potential) high-quality environment, including suitable landscaping and greenspace and an attractive and functional built environment.
e) To be attractive to national and / or international investment.

7.20 The majority of the defined Strategic Employment Areas satisfy all these characteristics or are considered capable of acquiring them. The BEAR has found that it is not always necessary for an area to display all these characteristics to attract high-quality development. For example, in the Pensnett area of Dudley and parts of Aldridge in Walsall, the market has delivered high-quality investment, despite the sites being some distance from the motorway network.

7.21 The broad extent of the strategic employment areas is shown on the Employment Land Key diagram and the detailed boundaries on the Black Country Plan Policies Map.

7.22 The Plan seeks to safeguard land and premises within Strategic Employment Areas for industrial and logistics activity and supports proposals that involve the improvement and renewal of land and premises within them. This process of redevelopment, intensification and enhancement of existing Local Employment Areas will provide a significant source of land to meet future growth needs.

7.23 Some small-scale ancillary uses will be supported in Strategic Employment Areas where this meets the day-to-day needs of employees of businesses within the SEA. While Policy EMP2 considers development for uses that are not within an industrial employment use class, these will only be supported in exceptional circumstances as it is the BCA intention to safeguard Strategic Employment Areas from non-manufacturing / logistics uses (B Use Classes).
 

Evidence

• Economic Development Needs Assessment Part One and Part Two
• Black Country Employment Areas Review[BEAR]
• BCLPA Strategic Employment Land Reviews
   

Delivery

• Through the Development Management process.
• Through partnership with Economic Development Partners in promoting development opportunities and improvement programmes.
   

(1)Issues and Options responses

7.24 There was broad support for the Plan to continue to distinguish between Strategic and Local Employment Areas with appropriate uses in each. There was also broad support for the criteria used to define Strategic Employment Areas but including suggestions to amend the accessibility criteria to focus on good access to the strategic road network, rather than just focussing on access to the motorway network. A number of responses suggested that the Plan should contain flexibility to allow for the introduction of non-industrial employment, ancillary uses in employment areas.

7.25 A number of responses suggested that the Plan should be informed by a thorough review of employment land to evaluate the merits of existing employment areas and prevent the long-term protection of sites which may no longer be suited to meet modern requirements.
 

Local Employment Areas

7.26 In order to achieve the appropriate balance and underpin the local economy, it is essential to make provision for those types of industrial, logistics and commercial activities that do not need to be situated in Strategic Employment Areas and are not appropriate for town centres or residential locations. This Policy supports Strategic Priority 7.
 

 

Justification

7.27 Local Employment Areas (LEAs) are particularly prevalent in the Black Country and play an important role in the local economy. They offer a valuable source of mainly low cost industrial units that are vital in providing local jobs and a balanced portfolio of sites of different sizes and quality.

7.28 Policy EMP3 is based on the approach set out in the 2011 Black Country Core Strategy, which distinguished between Strategic High-Quality Employment Areas and Local Quality Employment Areas. The Local Employment Areas in the BCP are the equivalent of the Local Quality Employment Areas in the Core Strategy. The EDNA recommended that the approach set out in the Core Strategy has served the Black Country well and, subject to some refinement, should be continued.

7.29 The characteristics and extent of the Local Employment Areas reflects the findings of the BEAR. The BEAR re-examined all of the Black Country's employment areas against a set of criteria based on those in the Core Strategy and with regard to the recommendations of the EDNA.

7.30 The key characteristics of Local Employment Areas are as follows;

• A critical mass of active industrial and service uses and premises that are fit for purpose.
• good access to local markets, suppliers, and employees.
• The existing or potential use and / or the traffic generated by the use does not have an unacceptable impact on the amenity of surrounding land uses or on the highway network.
• good public transport accessibility.

7.31 The broad extent of the Local Employment Areas is shown on the Employment Land Key diagram and the detailed boundaries on the Black Country Plan Policies Map.

7.32 The Plan seeks to safeguard Local Employment Areas as locations for industrial and logistics activity and uses that share the characteristics of Class E(g)(ii), E(g)(iii)) and B2 and B8 uses, which are typically located within industrial areas.

7.33 The Plan also supports proposals that involve the improvement and renewal of land and premises within them, particularly where this involves older outdated industrial premises that are no longer fit for purpose. This process of redevelopment, intensification and enhancement of existing Local Employment Areas provides a significant source of land to meet future growth needs.

7.34 Local Employment Areas are often vulnerable to pressure for redevelopment to other uses such as housing. However, the loss of too much local employment land will compromise the successful delivery of the BCP's employment strategy. It would inhibit economic development, endanger the viability of businesses, and affect the balance of jobs and workers; workers located at companies in Local Employment Areas who are displaced by new forms of development would have to travel increased distances to work and the viability and sustainability of firms would be put at risk. These areas will therefore be primarily safeguarded from non-employment uses.

7.35 Sites within Local Employment Areas may also be appropriate for uses that serve the needs of businesses and employees working in the area. Such uses include food and drink or childcare facilities. Such uses should be of a scale, nature, and location to serve the needs of the employment area, where existing facilities are inadequate and where such needs cannot be met in adjacent town centres.
 

Evidence

• Economic Development Needs Assessment Part One and Part Two
• Black Country BEAR
• Black Country Strategic Employment Land Reviews
   

Delivery

• Through the Development Management process.
• Through partnership with Economic Development Partners in promoting development opportunities and improvement programmes.
   

Issues and Options responses

7.36 There was broad support for the Plan to continue to distinguish between Strategic High-Quality Employment Areas and Local Employment Areas. Some respondents suggested that there will be potential for the reallocation of some local quality employment land for housing, while protecting the more important and productive sites.
 

Other Employment Sites

7.37 The BCA recognise that there are a number of older employment areas across the Black Country that are not of the quality of Strategic or Local Employment Areas. Sites and premises within these areas may be suitable for redevelopment for a continued employment use, or to alternative uses such as housing. Policy EMP4 provides a flexible policy framework to guide development proposals in these areas. This Policy supports Strategic Priorities 3, 4 and 7.
 

 

Justification

7.38 There are a number of existing employment sites / areas that are not designated as Strategic or Local Employment Areas. These tend to be older, less marketable employment sites close to or within residential areas, where proposals for redevelopment to other uses could give rise to significant regeneration benefits, and that, when assessed through the BEAR, do not meet the thresholds for being allocated as LEA. The larger areas (of over 0.4ha) subject to this Policy are shown on the Policies map.

7.39 Whilst the Black Country Authorities will continue to support these existing businesses, it is also necessary for the BCP to allow flexibility for them to be reused for alternative forms of appropriate development. These sites and areas are not shown on the Policies Map. The circumstances where such redevelopment will be permitted are set out in sections 2ai – div of the Policy. In addressing criteria a and b, applicants will be required to submit an Economic and Market appraisal that demonstrates that the site is unsuitable for continued employment use. The sustainability of the location (including its accessibility by a choice of modes of transport) will be one matter that should be considered in this context. In assessing the potential of attracting continued employment use, the Economic and Market Assessment should consider whether the costs of the necessary remediation works would make the reuse or redevelopment for employment uses unviable. The Economic and Market Assessment should also include evidence that the site is vacant (unless it can be demonstrated that occupiers are to be relocated) and has been marketed over a reasonable period of time and at realistic rental and capital values.
 

Evidence

• Economic Development Needs Assessment Part One and Part Two
• Black Country BEAR
• Black Country UCS
• BCLPA Strategic Employment Land Reviews
   

Delivery

• Through the Development Management process.
• Through partnership with Economic Development Partners in promoting development opportunities and improvement programmes.
   

(1)Issues and Options responses

7.40 This Policy responds to those suggestions that the Plan should continue to allow active employment sites to remain, but poorer quality sites no longer needed for industry could be redeveloped.
 

Improving Access to the Labour Market

7.41 Restructuring the Black Country's economy is one of the key principles of the BCP Vision, but the provision of land and premises alone will not deliver the necessary economic transformation without new skills and training in the workforce to help it meet the challenges of changing work requirements and patterns. This Policy supports Strategic Priority 8.
 

 

Justification

7.42 The Plan plays a key role in ensuring that people who suffer from social exclusion and disadvantage are able to fully contribute to the regeneration of the Black Country. It is therefore important that jobs created through new developments across the Black Country are accessible to as many of the Black Country's residents as possible, especially those in the most deprived areas or priority groups.

7.43 There are several aspects to improving the accessibility of job opportunities to residents. Firstly, it may be necessary for improvements to public transport infrastructure and services to be funded, and better facilities for pedestrians and cyclists to be provided, to ensure that residents are able to travel to and from their places of employment within reasonable timescales.

7.44 Support may also need to be provided to assist residents, particularly those from disadvantaged groups or areas, in applying for new jobs and to receive training that will assist them in accessing employment opportunities. Childcare provision may also help in enhancing access to employment and individuals with mental or physical health difficulties may also require support to enable them to access jobs.

7.45 There are existing support structures and facilities in place across the sub-region to help ensure that local people can access and receive appropriate training to develop the necessary skills to compete successfully for jobs.

7.46 To assist with this, where major new employment-creating development is proposed, the BCA will negotiate with companies to devise suitable bespoke training and recruitment programmes that can benefit local people.

7.47 Attracting graduates to, and retaining them within, the Black Country will also be key to securing a knowledge-based economy. The higher and further education sector is a major driver of economic, social and cultural regeneration and ongoing investment in this sector is supported. The BCA will also support initiatives that strengthen linkages between the education sector and the wider economy.
 

Evidence

• Economic Development Needs Assessment Part One and Part Two
   

Delivery

• Through the Development Management process and the negotiations on planning obligations. Through recruitment programmes and partnerships working between economic and employment organisations.
   

Issues and Options responses

7.48 There were mixed views on whether the Plan should continue to require large scale development to provide local recruitment and training programmes. Those in support of the Policy saw local people as an area's biggest potential and new development can create opportunities for them. Those not supporting the Policy suggested it is too restrictive as it can cause problems for companies who have their own training programmes and many developments create opportunities for local people in any case.
 

Monitoring