Comment

Representation ID: 22521

Received: 11/10/2021

Respondent: Clowes Developments

Agent: Harris Lamb

Employment Land Issues

The Representor considers that the Black Country economy is an important element of the overall West Midlands’ economy and, as such, needs to be strongly supported in terms of the Plan’s policy objectives and the allocation of land to meet the future economic needs of the Plan. In this context, the Representor strongly supports the desire to allocate further land to meet the Black Country’s needs and provide support for the principle of Policy EMP1. The draft Plan acknowledges that the employment needs of the Black Country are such that not all of this need can be accommodated within the Plan area. Paragraph 7.10 explains that the allocations in the Plan will meet only 63% of forecast needs arising within the Black Country. It is explained in paragraph 7.12 that a further 37% of employment land will, therefore, not be met within the Black Country and that this will need to be accommodated in adjoining authorities which have a strong existing economic relationship with the Black Country.

The Representor welcomes the acknowledgement that not all of the Plan’s needs can be met in the Black Country authorities administrative areas and that land will have to be released elsewhere to meet the overall economic needs of the Plan area. The Representor also welcomes the identification of South Staffordshire as having a strong economic link with the Black Country.

However, the Representor is concerned that the extent of the overspill requirement has been underestimated. Policy EMP1 explains that of the total of 355 hectares of employment land which is to be delivered in the Plan period, some 74 hectares (a minimum figure) will be brought forward on other sites throughout the Black Country, mainly through the redevelopment, intensification and enhancement of existing employment areas and premises. It is clear, therefore, that a significant proportion of the land to be brought forward is in fact redevelopment of the existing stock and does not represent net additions which will meet the increased needs identified for the Plan area. Therefore, the Representor objects to Policy EMP1 and considers that the actual figure identified in sub-para 1 of 355 hectares should be reduced to 281 hectares. This would mean that the extent of the overspill identified at paragraph 2.10 should be increased by 74 hectares to 284 hectares (it is also noted that the figures identified in 7.10 do not appear to tally with those in Policy EMP1, sub-para 1 and this error should be rectified).

The Representor has submitted details of land at Wall Heath, which is well placed to accommodate the overspill needs for employment land for the Black Country.

The Representor is also extremely concerned that the supply figure identified to meet the Black Country’s needs should place no reliance upon the strategic logistic site at Four Ashes. That site serves a regional/national need and is not suitable for many of the businesses seeking premises within the Black Country or on sites immediately adjoining it.