Support

Representation ID: 22484

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Employment needs and functional geography
The clarity that the Draft Plan provides in relation to Black County’s employment land requirement
is welcomed, with it noted that that the plan will seek to provide for a minimum of 565ha up to
2039 with this figure based upon the findings of the Black Country EDNA update (August 2021).
The Draft Plan confirms that following site assessment, the plan has been able to provide for 365ha
of this within the administrative boundaries of the Black Country. It is understood that this supply
is made up of allocations within the urban area, redevelopment of existing employment premises,
other site that have planning permission for employment developments and 48ha of employment
allocations within Walsall’s Green Belt.

It is recognised that this results in a shortfall of employment land, with paragraph 7.12 of the Draft
Plan confirming:
“210ha or 37% of employment land need arising in the Black Country cannot be met solely within
the Black Country. 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 Co-operate and evidenced through Statements of Common Ground.”

Whilst we recognise that cooperation on unmet employment needs is ongoing, the above
statement is somewhat ambiguous as to what the Black Country authorities consider to be the
most appropriate functional geography for addressing unmet employment needs. The PPG
confirms that when addressing strategic matters under the Duty to Cooperate and confirming
these through Statements of Common Ground, the geographical area for doing this will depend on
the strategic matter being planned for and ‘the most appropriate functional geographical area to
gather evidence and develop policies to address these matters, based on demonstrable cross-
boundary relationships’. It is therefore critical that clarity is provided on what you consider the
functional geography for addressing your unmet employment needs is, in order to enable swift
progress with Statements of Common Ground following our respective Regulation 18
consultations.

We recognise that South Staffordshire has a strong functional economic relationship with part of
the Black Country, specifically Dudley, Walsall and Wolverhampton, but it is unclear from the
statement above what other authorities the Black Country consider fall within the functional
geography. The Black Country EDNA (2017) recognises South Staffordshire and Birmingham as
areas ‘areas of strong economic transactions with the Black Country’ and Cannock Chase, Lichfield,
Tamworth, Wyre Forrest, Bromsgrove and Solihull as ‘areas of moderate economic transactions
with the Black Country’ so it seems appropriate given the scale of the shortfall that solutions are
sought across the wider geography. It is also noted that Shropshire are proposing a contribution of
30ha of employment land towards Black Country employment needs and their evidence relating to
the M54 growth corridor does appear to imply there are functional links between the Black
Country and parts of east Shropshire, so including Shropshire within the functional geography is
also considered appropriate.

It is also noted that the Black Country EDNA update (August 2021) concludes that the plan should
seek to provide for around 30% B8 activity and 70% E(g)(ii)/(iii)/B2. It is unclear from the Draft Plan
if the proposed employment allocations are along these lines and therefore whether the plan is
seeking to deliver new employment along this split. Subject to a review of the South Staffordshire
EDNA, it is expected that we will have a significant oversupply of B8 land (as a result of the WMI
consent) and therefore your policy intentions for this issue may affect the contribution we can
make towards your unmet employment needs. Confirmation of this is sought, and if the aim is to
achieve this split, then details of the shortfall for B8 and E(g)(ii)/(iii)/B2 should be separately


provided to inform Duty to Cooperate discussions, as well as confirmation of whether the most
appropriate functional geographies differ between B8 and E(g)(ii)/(iii)/B2 needs.
In summary, we seek confirmation on the following:

1. Which authorities does the Black Country consider fall within the most appropriate
functional geography for addressing your unmet employment needs?
2. Is it the Black Country’s intention that the plan seeks to provide for 30% logistics (B8) needs
and 70% commercial (E(g)(ii)/(iii)/B2)? If yes, then please could you provide a breakdown of
what your shortfall is by use class.
3. If the Black Country are looking to provide for a split between B8 and (E(g)(ii)/(iii)/B2) uses,
can it confirm what the functional geography is for each use (if different).