Object

Representation ID: 21362

Received: 11/10/2021

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

4. Policy EMPl - Providing for Economic Growth and Jobs


Employment land requirement

4.1 The BCP's approach to employment land, in terms of not meeting the identified needs is through relying upon neighbouring authorities to meet the shortfall, which amounts to 210 hectares of employment land.

4.2 Furthermore, a significant proportion of the identified housing supply comprises existing employments sites. Aside from the identified strategic and local employment areas (Policies EMP2 & EMP3), the plan provides no protection to existing employment sites. In fact, Policy EMP4 is permissive of such sites being developed for housing, without any test as to whether there is a continued need for the site to remain in employment use. This will only exasperate issues of employment land supply in the Black Country.

4.3 Failing to meet the identified need for employment land will cause significant harm to the local economy. Businesses will not be able to invest and grow in the Black Country, and jobs growth will be curtailed to the detriment of residents. This is precisely the situation our client is facing with the uncertainty surrounding the current temporary use and it is frustrating the growth and development of a successful and highly valued local business. There may also be an impact on commuting pattens.

4.4 The Council's reasons for failing to meet the identified need for employment need are similar to its reasons for failing to meet local housing need. The approach is flawed because:

• The SA is based upon flawed assumptions.

• The BCA reliance upon the SA to justify the proposed growth option is misplaced.

• The alleged impacts on landscape and natural resources (including Green Belt) are overstated.

• There is an absence of firm agreement with neighbouring authorities to meet the needs.

4.5 The BCP should therefore not be allocating sustainable employment sites, which are operational, for housing needs whilst there is a clear need for employment land within The Black Country.

4.6 Overall, the proposed approach is not justified, effective or positively prepared. The BCP should seek to meet employment needs in full within the Black Country.