Support

Representation ID: 21245

Received: 11/10/2021

Respondent: Newlands Developments

The Black Country Economy (Section 7)
Part (a) of NPPF Paragraph 82 makes reference to local authorities having regard to Local Industrial Strategies when setting out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth. The West Midlands Local Industrial Strategy (May 2019) recognises the significant shortfall in employment land across its geography (Page 63) and makes a commitment to implementing a strategic programme of employment land development based on up-to-date, locally-led evidence (Page 65). This supports the allocation of the Site in this sustainable location.

Part (b) of Paragraph 82 requires strategic policy-making authorities to set criteria, or identify strategic sites, for local and inward investment to match the strategy and to meet anticipated needs over the Plan period. In addition, NPPF Paragraph 83 states that planning policies should recognise and address the specific locational requirements of different sectors. This includes making provision for clusters or networks of knowledge and data-driven, creative or high technology industries, and for storage and distribution operations at a variety of scales and in suitably accessible locations. The Site reflects the locational requirements of logistics that are described in the Planning Practice Guidance (PPG) (031 Reference ID: 2a-031-20190722) and, in particular, it would be attractive to last mile operators given its excellent access to the wider conurbation. Both the PPG and National Infrastructure Commission’s (NIC’s) ‘Better Delivery: The Challenge for Freight’ Report (April 2019) (see Recommendation 4) make specific reference to the provision of sites for last mile logistics in recognition of the changing nature of the market and boom in ecommerce. This supports the case for designating the Site for employment uses and initial interest has already been received from a number of occupiers looking to invest at this location.

Draft Policy EMP1 (Providing for Economic Growth and Jobs) 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. The Black Country Authorities will seek the delivery of at least 355 hectares of employment land within the Black Country, in Use Classes E(g)(ii), E(g)(iii), B2, and B8 between 2020 and 2039: mostly through sites allocated for development in the Plan. This includes 164 hectares in Walsall. The Site is identified on the Employment Key Diagram as an Employment Development Site and will thus be safeguarded for employment uses within Use Classes E(g)(ii), E(g)(iii), B2, and B8, as noted within Part 4 of Draft Policy EMP1. We are supportive of this draft policy which aligns with the aims of NPPF Paragraph 82.

Improving Access to the Labour Market

Draft Policy EMP5 (Improving Access to the Labour Market) requires planning applications for new major job-creating development to demonstrate how job opportunities arising from the proposed development will be made available to the residents of the Black Country, particularly those in the most deprived areas of the sub-region and priority groups. Furthermore, Part 2 of Draft Policy EMP5 goes on to state that planning conditions or obligations will be negotiated with applicants and applied as appropriate to secure initiatives and/or contributions to a range of measures to benefit the local community, including the potential for working with local colleges and universities, to ensure:-

a) The provision of training opportunities to assist residents in accessing employment opportunities;
b) The provision of support to residents in applying for jobs arising from the development;
c) Enhancement of the accessibility of the development to residents by a choice means of transport;
d) Child-care provision which enables residents to access employment opportunities;
e) Measures to assist those with physical or mental health disabilities to access employment opportunities.

We are generally supportive of this approach as it looks to ensure that development proposals for employment generating uses meet the needs of local residents. However, it is noted that there is no information available as to the level of financial contributions which will be sought as part of development proposals. We would therefore be grateful if the Council could provide further details of the contributions which will be sought as part of any future consultation. Whilst it is important to ensure that development proposals meet the needs of local residents, this cannot result in schemes becoming unviable.