Comment

Draft Black Country Plan

Representation ID: 22278

Received: 21/01/2022

Respondent: Miss Jodi Stokes

Representation Summary:

7.0 THE BLACK COUNTRY ECONOMY

7.1 Draft Policy EMP1 (Providing for Economic Growth and Jobs) sets out that the Black Country Authorities “will seek the delivery of at least 355ha of employment land within the Black Country, in Use Classes E(g)(ii), E(g)(iii), B2, and B8 between 2020 and 2039, to support the growth of the sub-regional economy and increase productivity”. They recognise that most, but not all, of this requirement will be met through sites allocated in the Black Country Plan, with some provision expected to be through the redevelopment, intensification and enhancement of existing employment areas and premises.

7.2 To support the ongoing growth of the distribution sector and a strong resurgence in manufacturing, the Economic Development Needs Assessment (’EDNA’) recommends that this Plan should provide for a minimum of 565 hectares of land for employment development for the period up to 2039. The Black Country Authorities set out that 210 hectares or 37% of employment land need arising in the Black Country cannot be met solely within the Black Country. The Authorities consider that this unmet need should be exported, as far as possible, to authorities that have a strong existing or potential functional economic relationship with the Black Country, for example in terms of migration patterns, commuting links and / or connectivity through physical infrastructure such as rail and motorway. This work is ongoing and will be secured through the Duty to Cooperate and evidenced through Statements of Common Ground. It is also important to consider how this shortfall will affect the local market demand and the Authorities should ensure that a shortfall in employment land does not detract future occupiers or cause existing occupiers to move elsewhere.

7.3 Where existing allocations for employment uses are relied upon within the Black Country Plan, the Authorities and WMCA should work together with developers to ensure the delivery of these Sites to ensure that all proposed delivery can be realised and as many jobs and opportunities can be brought to the Black Country as possible.