Object

Representation ID: 21438

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

At present the BCP provides no certainty of how the full extent of the 210ha of unmet employment land need will be provided for. As set out above that requirement for cross boundary provision is more accurately 339ha+. The NPPF and PPG requires the plan to identify and allocate the land to meet all of the objectively assessed need, and where that cannot be achieved within the plan area the duty to co-operate requires the balance of that need to be identified and allocated in the development plans of other LPA.
The BCP currently fails in these respects. It is not sufficient to state as 3.24 does, that the Statement of Consultation sets out the current position which will be elaborated on at the submission stage. That approach does not meet the requirements of the duty to cooperate, which are to produce a single statement of common ground together with all those LPA which will contribute to satisfying the unmet need. That statement of common ground should set out the governance and process for agreeing the distribution of satisfying the unmet need amongst those authorities. It should also identify the capacity of the areas of the LPAs party to the statement of common ground, and the details of agreement and disagreement about how the unmet needs can be met across the combined area. At present there is no statement of common ground within the evidence base.
A substantial amount of land remains to be identified to meet identified needs in order for the duty to cooperate to be satisfied. It is imperative that BCA secures sufficient land through cross boundary provision, to meet the unmet needs in both quantitative and qualitative terms. That needs to be achieved without reliance upon reviews of other local plans.
The published evidence of duty to co-operate correspondence with other LPA indicates that the strongest potential source in quantitative and qualitative terms that meets the employment land needs of the BCP is Shropshire. The evidence of the last meeting / dialogue with Shropshire being in April 2020, and with outstanding objections from ABCA, Walsall and Dudley in early 2021 stating that the Submission Shropshire Plan is not sound, indicates that the engagement between BCA and Shropshire is not as constructive, active and ongoing as it is required to be. Notwithstanding the submission of the Shropshire Plan, we urge BCA to actively engage with Shropshire in the interests of securing appropriate land quantitatively and qualitatively to enable the BCP to be found sound.