Comment

Representation ID: 43932

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

Policy DEL2 (balanced between employment land and housing)
3.28 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.
3.29 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




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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).
3.30 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).
3.31 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.
3.32 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. Indeed this is an approach taken by a
number of authorities, including neighbours such as Lichfield District.
3.33 Rather than compromising its employment land supply further, the plan should be
seeking to maximise locations for development outside of the urban area, and if
anything, increasing the number of homes allocated on sites currently in the Green
Belt. This only emphasises how important IM Land’s site at Queslett Road, Walsall is to
ensuring the plan delivers on its objectives and meets it housing and employment
needs.