Object

Representation ID: 43914

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.30 This policy covers development of housing or employment on previously developed land ‘that is not allocated for this uses’, so would apply for any planning applications for residential development on existing employment sites. Both the housing and employment shortfalls are significant – circa 37% of the total need (notwithstanding that no evidence has been prepared to indicate whether the proposed component of the housing supply on existing employment sites has been factored into the employment land shortfall).
3.31 As set out in the Turley Technical Review of Housing Need and Supply in the Black Country (October 2021) (Appendix 7) there is limited evidence that there is any trend of housing sites coming forward for employment development in the urban area, where as there is evidence that employment sites are sometimes redeveloped for new homes. Examples of this are the Bilston Urban Village site in Wolverhampton and the former Cerro EMS Ltd site on Goscote Lane in Walsall (though we do dispute the scale of the Council’s anticipated supply from this source going forward).
3.32 So it is anticipated this policy would mostly be applied to new housing on employment sites. Any further loss of employment land would only exacerbate the Council’s already significant employment land shortfall of 210ha, at a time when the Black Country’s economy is growing, with the employment rate growing faster than the average in England (3.5% growth compared to an average of 0.9%) (paragraph 1.29 of the draft BCP).
3.33 Indeed, it clearly states at paragraph 1.30 that “the challenge is to keep that momentum”. Policy DEL2 should reflect this growth and ensure the employment land shortfall does not unnecessarily increase, it should therefore be seeking to provide greater protection of existing employment sites (no protections are provided in draft policies HOU1 or EMP1-EMP4). This would also ensure the policy and plan conforms to the NPPF, which requires a sufficient supply of employment sites to be provided.
3.34 This can be done through requiring any application for residential development on an existing employment site to include evidence the site has been marketed for a certain period and that there is no reasonable interest. This is an approach taken by a number of authorities, including neighbours such as Lichfield District.
3.35 Rather than compromising its employment land supply further, the plan should be seeking to maximise locations for development outside of the urban area, and increasing the number of homes allocated on sites currently in the Green Belt. Land at Pennwood can assist in ensuring the Black Country’s housing land supply is robust (we set out the site’s benefits at Section 2 and discuss the Councils’ assessment of the site
further at Section 4) and does not compromise the plan’s ability to meet the area’s employment needs.