Object

Representation ID: 21320

Received: 11/10/2021

Respondent: J Holt & Sons

Agent: Spawforths

The Plan’s explanatory text recognises that a significant proportion of the identified needs for both housing and employment will need to be met on sites which lie beyond the Black Country Authorities boundaries. It is considered that the Key Diagram should reflect this, and provide a spatial framework for meeting these identified needs within adjacent authorities, recognising those authorities and locations which have a strong functional relationship with the Black Country, and are located along key strategic routes. Of particular interest to J Holt & Sons, we consider that the spatial framework should identify the key importance of the linkage between the Black Country and areas of South Staffordshire located along the A449, and M6 to meet strategic employment needs.

Policy CSP1 should reflect Table 2 and Part 1 and hence should establish the full housing and employment land requirements. The Spatial Strategy contained within Part 2 should establish the strategy for meeting the needs which cannot be met within the Plan area, to provide certainty and ensure that the Plan is effective.

Policy CSP1 should therefore reflect the full employment land requirements, and be clear that based on the authority’s current evidence, at least 210 hectares of need is to be exported outside the Black Country boundaries to other adjacent authorities. This constitutes a substantial proportion of the identified requirement and therefore should be reflected within the strategic policy CSP1, which is intended to establish the Spatial Strategy to meet the objectively assessed needs.

Policy CSP1 Part two should also address the locational requirements of specific sectors including those of the storage and distribution sector, taking account of the specific locational characteristics of this sector.

The 2021 Framework also requires policies to set out a clear economic vision and strategy, and address barriers to investment. It is therefore imperative in order not to constrain the growth of the Black Country and indeed the wider region that the identified needs for both the Black Country and wider region, are met in full.

We do not consider that the scale of need (565 ha) identified within the explanatory text is based on robust and up to date evidence. We consider that as the need is based on past trends then it does not reflect the significant structural changes to the economy and the drivers for growth resultant from the rise in e-commerce and the need to build resilience in the supply chain.