Object

Representation ID: 21323

Received: 11/10/2021

Respondent: J Holt & Sons

Agent: Spawforths

J Holt & Sons are concerned that the EDNA 2 (2021), does not reflect the full potential for the growth in demand for industrial and logistics land.

In summary, we consider that the overall requirements for employment land are an underestimate of both the quantitative and qualitative requirements and do not reflect the drivers of current and future demand. Furthermore, there is a need for an appropriate margin for choice and flexibility, in addition to factoring losses. As a result the amount of land required is under-estimated and hence so too is the amount of land that needs to be exported to appropriate authorities. This amount of land is likely to be higher than that shown in the draft Plan and EDNA, given the lack of strategic sites within the Black Country.

J Holt & Sons consider that any employment need that is to be exported should be focused in locations which have a strong functional relationship with the Black Country. The EDNA notes that Birmingham and South Staffordshire have strong economic interactions with the Black Country.