Object

Representation ID: 23376

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy EMP1
We object to this policy. In line with our comments on CSP1 we would reduce the allocations in Walsall by 15 hectares because of the impact of WAE409 and WAE410 on the Green Belt. Otherwise, we generally support the policy although the level of employment land which will be needed and which will come forward on existing sites needs to be reviewed prior to the Submission Draft publication (the Regulation 19 Consultation). That is because of uncertainties created particularly by the COVID Pandemic in relation to employment land, most particularly offices.

We object to Para 7.10. The level of additional land which needs to be found elsewhere may need to be reduced and further work should be done prior to the Regulation 19 Consultation. The work we commissioned at the time of the first Urban Capacity Study (which seems to remain reasonable) with some small changes of figures in the update, raised the issues of double-counting of employment land need, particularly on proposed sites adjacent to the Black Country in South Staffordshire where the sites would be serving the Black Country but are included as meeting need in South Staffordshire.
Moreover, we have significant concerns about the recent Strategic Employment Site Study which was based on pre-pandemic assumptions.
For both these reasons we consider the figure of 210 hectares of overspill employment need to be likely to be exaggerated.