Object

Representation ID: 21433

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

The economic context of the BCP is stated to include the Black Country Local Enterprise Partnership (BCLEP) and West Midlands Combined Authority (WMCA) Strategic Economic Plans (SEPs) (1.11 & 1.12). The targets of those SEPs are however not fully embodied within the economic development targets of the BCP.
This means the BCP is seeking to accommodate substantially less economic growth than it should be. The Black Country has skills and productivity levels substantially below the regional and national averages. As identified by the SEPs, there is a need to address the widening gap between the Black Country and the rest of England. Planning for low aspiration will prevent the Black Country having the conditions to achieve a step change in its economy and will result in the productivity and skills gap continuing to widen.
There is also need for land to provide opportunities for enhanced education, skills and training to be provided alongside industry. The University of Wolverhampton is interested in opportunities to co-locate a new sector focused educational centre of excellence alongside high value manufacturing which will directly contribute to upskilling the workforce, narrowing the productivity gap and attracting internationally competitive industry. That requires a high quality, accessible site with appropriate sustainability credentials of sufficient size for industry and training to collocate
The conclusions of EDNA2 are significantly influenced by the assessment of future employment growth by sector as illustrated in Fig 2.4. Basing the assessment of need for the manufacturing sector on the GVA projection appears to be a sound basis. This identifies a need for a significant amount of land for new manufacturing development. EDNA2 bases the forecast requirement for logistics floorspace and land upon the employment projection. The report provides no explanation or justification for those employment projections which are fundamental to future floorspace and therefore land requirements. As explained below, our assessment is that this significantly underestimates the amount of floorspace and land that will be required for logistics use over the plan period.
Table 3 within the Land Supply section below shows that there is only one allocated site in the size range above 11.6ha, and that appears to not be available. 77ha of allocated sites are too small to accommodate a building of 100,000sqft. There is therefore a significant deficiency in high quality sites and sites which are able to accommodate larger buildings.
In conclusion on employment land need, the EDNA does not provide sufficient explanation of the assumptions and calculations used to derive the floorspace and land requirements. It appears that there is a very substantial under-estimate of the level of logistics floorspace that will be required over the period to 2039. There is no explanation for why the middle estimate is deemed the most appropriate basis. There is no justification for the assumed increased efficiency in manufacturing use of floorspace. There is no explanation of how the economically determined estimate at 2.8 is adjusted downwards to derive the figures in Fig2.10 and Fig4.1. It appears that the identified need should account for two additional years. As a result of these matters we consider that the employment floorspace and employment land requirement is considerably greater than is currently being planned for.
The findings of the WMSESS are relevant to the BCP and should be taken into account in its preparation. Although there may not be land within the BCP area which can accommodate strategic sites in accordance with the need identified in the WMSESS, the need identified relates to supporting the economy of the BCP area. The preparation of the BCP should therefore take account of the need to ensure that adequate strategic sites are being brought forward in suitable locations as identified by the WMSESS. In this context the definition of ‘strategic’ in the WMSESS is different to that employed in the assessment of existing employment land in the BEAR.
The Strategic Priorities as set out at BCP Table 1 should state clearly that the priority is to identify and allocate sufficient land to meet objectively assessed needs for employment. The objective of enabling a strong and inclusive economy and strategic priority 7 should be clarified accordingly. The current lack of specific target in the strategic priority feeds through into the lack of appropriate target in the policies intended to deliver the strategic economic priorities.
Policy CSP1 states that the BCP will deliver 355ha of employment land which will meet strategic planning targets based upon the needs of local communities and business. It is our assessment that this targets will not adequately meet strategic planning targets, and the BCP does not currently deliver the land to achieve either the correct or the stated targets.
Table 2 identifies the BCP strategy is to deliver 565ha of employment land. As set out above we consider the evidence promoted by BCA supports a higher need of 585ha. The additional 20ha needs to be identified and allocated. If it cannot be accommodated within the BCP area it will increase the amount of employment land required from cross boundary provision.
We have identified a number of factors which indicate that need is likely to be substantially greater than 585ha for local needs for manufacturing and logistics uses. By the same measure as above, that would further increase the needs for cross boundary provision.
Additionally, the BCP does not currently acknowledge the need to plan for strategic sites as identified by the WMSESS. Whilst there may not be opportunity to allocate new strategic sites (as defined by the WMSESS) within the BCP area, it is a component of need which forms part of the objectively assessed need which the NPPF requires the BCP to provide for. If needs for strategic sites cannot be met within the plan area they should be identified and allocated across boundary through the duty to cooperate. Strategic site provision should therefore from part of the need for which there is an obligation upon the BCA to pursue through the duty to cooperate.
BCP Table 2 shows that the BCP plans to identify 355ha of employment land, with the remaining 210ha to be identified and allocated through the duty to co-operate. Taking account of the BCA evidenced need being 20ha greater than included, and no provision yet being made for strategic sites, the starting requirement from cross boundary provision should be 255ha. Any additional local need as discussed above would be a direct addition to that cross boundary requirement.
The 74ha of windfall is expected to come from existing employment land and so is not net additional land to meet the assessed need. The 74ha cannot be double counted. EMP1 and Table 2 is an over statement of employment land supply. Unless additional provision is made from green belt within the BCP area, the requirement from cross boundary provision must increase by 74ha.
Of sites larger than 2.3ha, (total of 204ha allocated) our review suggests that approximately 53ha is already in employment use. This includes sites that appear to have been recently developed, and other sites which appear to be in an existing employment use. The single allocated site which is larger than 11.6ha (WAE412 Sandown Quarry 20.85ha) is currently an operational quarry and associated production works. There is reason to question whether a quarter of all the land allocated above 2.3ha is able to contribute towards land supply. This suggest that there may be need to identify an additional 53ha of land to replace allocations which are not net additional employment land.
Additionally there is a need for the BCA to work with neighbouring authorities within the West Midlands to identify land for Strategic Sites as assessed by the WMSESS. That requires high quality sites of 25ha+ which can attract nationally and internationally mobile business, and/or sites aligned to a specific economic priority growth sector.
Area 4 of the preferred locations for meeting the need is most closely aligned with the BCP area. The WMSESS states that the M54 corridor is likely to have a role in meeting demand for Strategic Sites, and specifically identifies that land at M54 J3 which is on the edge of the study area (and Area 4) could meet needs for Strategic Sites arising from within the study area.