7 The Black Country Economy

Comment

Representation ID: 11521

Received: 03/10/2021

Respondent: Richard Power

Pouk Hill public open space, Bentley Lane, Reedswood, Walsall.

• The Pouk Hill green space area should not be promoted for new housing or new employment land development within the emerging BCP (Review).



Public open space located North of Churchill Road and the Jane Lane School, Reedswood, Walsall.

• Given its natural green space sensitivity, critical public open space importance for local residents, and urban green lung sensitivity helping to significantly reduce harmful levels of air pollution from the M6 motorway network, this green space site should be removed from the employment land allocation as shown on page 499 (within Figure 19: Walsall Spatial Strategy Plan) of the emerging BCP (Review) (2021).


Reedswood Town Park public open space

• Reedswood Town Park public open space should not be promoted as a potential new housing or new employment land development site within the emerging BCP (Review). Walsall Council should be aware that Town Parks are not appropriate locations for these types of uses given their high level of green space planning policy sensitivity.

Comment

Representation ID: 11762

Received: 08/10/2021

Respondent: Mr John Hemming

The map below is very poor , giving little idea of where employment sites are planned

Comment

Representation ID: 12332

Received: 01/10/2021

Respondent: Mr & Mrs Barry and Joan Richards

Number of people: 2

Brownhills is surrounded by land unsuitable for farming whereas the land targeted is good arable farm farmland producing cereal crops in its entirety year on year. It is also rich in minerals which when exhausted can be turned back to farmland. Leaving the EU has left us at their mercy and buying food from them in the future is going to be expensive.
There are much better opportunities all round and certainly Brownhills which would benefit from the regeneration possibilities increased population would bring.

Comment

Representation ID: 13234

Received: 08/10/2021

Respondent: Mrs Angela Wadeley

Concerning business and industry needs, we are supposed to be encouraging low carbon, light, hi-tech, high wage industries with a smaller footprint to that of the old heavy industry on which the Black Country area was built. Building on undeveloped land is obviously cheaper and easier but surely with foresight and ambition we could build on former and underused existing business sites. Remediation is a valuable, usually sustainable income stream with many positives to bring back land into use. Businesses are already showing that recycling can be profitable as well as reducing Greenhouse gas emissions. Where is our innovation?

Comment

Representation ID: 14691

Received: 11/10/2021

Respondent: Irene Wilkinson

We need to encourage new green industries to our area to bring employment and sustainable development. We have plenty of empty commercial spaces that can be repurposed.

We need to lobby the government to allow refurbished building projects to be VAT exempt in the way new builds are currently to make reusing existing buildings more attractive.

We MUST NOT build on green belt land. It should be preserved for future generations. Please note the lyrics of Big Yellow Taxi by Counting Crows and Vannesa Carlton.

Comment

Representation ID: 19394

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 7.1 - Supports the balanced approach to delivering employment land, but with the following caveat "the plan should recognise the changing nature of much employment, including following the Covid-19 pandemic which has seen a shift towards home working, alongside the Government’s ambition to allow for more flexible working patterns and potentially consider the inclusion of local employment 'hubs' which would allow for working in close proximity to residents' homes whilst allowing for the more social aspects of office working."

Object

Representation ID: 20990

Received: 10/01/2022

Respondent: Miss Joanne Bevan

This cannot be done by taking high proportions of Green Belt Land away.
• Noted also in the plan:
"a) Industry and warehousing (E(g)(ii), E(g)(iii)), 82 and 88 use)
b) Motor trade activities, including car showrooms and vehicle repair
c) Haulage and transfer depots
d) Trade, wholesale retailing and builders' merchants
e) Scrap metal, timber and construction premises and yards
f) Waste collection, transfer and recycling uses as set out in Policy W3."

There is a national shortage of HGV drivers, large haulage companies have not encourage newly qualified drivers while they have been able to get cheaper labour from abroad, this shortage has been happening for decades, not only since Brexit. The above types of industry highlighted in the plan are all very dependent on HGV and not a broad enough spectrum to get working families into Walsall.
• Already only two-thirds of working-age residents in Walsall are in employment, and for those in work, earnings are below the national average while testing economic conditions prevail. None of this information is a picture of a flourishing economy with in Walsall.
• Walsall is already struggling, it is crime ridden, with closed shops, with a poorly manned police force and unpunished crimes. The only reason I am still a resident of Hawthorn Road is because of the surrounding Green Belt Land. If the intention is to remove this then Walsall will have one less resident. Walsall Council needs to come up with a strategy to improve all services
for the existing population and get that right.

Support

Representation ID: 21245

Received: 11/10/2021

Respondent: Newlands Developments

The Black Country Economy (Section 7)
Part (a) of NPPF Paragraph 82 makes reference to local authorities having regard to Local Industrial Strategies when setting out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth. The West Midlands Local Industrial Strategy (May 2019) recognises the significant shortfall in employment land across its geography (Page 63) and makes a commitment to implementing a strategic programme of employment land development based on up-to-date, locally-led evidence (Page 65). This supports the allocation of the Site in this sustainable location.

Part (b) of Paragraph 82 requires strategic policy-making authorities to set criteria, or identify strategic sites, for local and inward investment to match the strategy and to meet anticipated needs over the Plan period. In addition, NPPF Paragraph 83 states that planning policies should recognise and address the specific locational requirements of different sectors. This includes making provision for clusters or networks of knowledge and data-driven, creative or high technology industries, and for storage and distribution operations at a variety of scales and in suitably accessible locations. The Site reflects the locational requirements of logistics that are described in the Planning Practice Guidance (PPG) (031 Reference ID: 2a-031-20190722) and, in particular, it would be attractive to last mile operators given its excellent access to the wider conurbation. Both the PPG and National Infrastructure Commission’s (NIC’s) ‘Better Delivery: The Challenge for Freight’ Report (April 2019) (see Recommendation 4) make specific reference to the provision of sites for last mile logistics in recognition of the changing nature of the market and boom in ecommerce. This supports the case for designating the Site for employment uses and initial interest has already been received from a number of occupiers looking to invest at this location.

Draft Policy EMP1 (Providing for Economic Growth and Jobs) seeks to ensure a sufficient quantum of development opportunities are provided to meet the demand for economic growth and support the diversification of the Black Country economy. The Black Country Authorities will seek the delivery of at least 355 hectares of employment land within the Black Country, in Use Classes E(g)(ii), E(g)(iii), B2, and B8 between 2020 and 2039: mostly through sites allocated for development in the Plan. This includes 164 hectares in Walsall. The Site is identified on the Employment Key Diagram as an Employment Development Site and will thus be safeguarded for employment uses within Use Classes E(g)(ii), E(g)(iii), B2, and B8, as noted within Part 4 of Draft Policy EMP1. We are supportive of this draft policy which aligns with the aims of NPPF Paragraph 82.

Improving Access to the Labour Market

Draft Policy EMP5 (Improving Access to the Labour Market) requires planning applications for new major job-creating development to demonstrate how job opportunities arising from the proposed development will be made available to the residents of the Black Country, particularly those in the most deprived areas of the sub-region and priority groups. Furthermore, Part 2 of Draft Policy EMP5 goes on to state that planning conditions or obligations will be negotiated with applicants and applied as appropriate to secure initiatives and/or contributions to a range of measures to benefit the local community, including the potential for working with local colleges and universities, to ensure:-

a) The provision of training opportunities to assist residents in accessing employment opportunities;
b) The provision of support to residents in applying for jobs arising from the development;
c) Enhancement of the accessibility of the development to residents by a choice means of transport;
d) Child-care provision which enables residents to access employment opportunities;
e) Measures to assist those with physical or mental health disabilities to access employment opportunities.

We are generally supportive of this approach as it looks to ensure that development proposals for employment generating uses meet the needs of local residents. However, it is noted that there is no information available as to the level of financial contributions which will be sought as part of development proposals. We would therefore be grateful if the Council could provide further details of the contributions which will be sought as part of any future consultation. Whilst it is important to ensure that development proposals meet the needs of local residents, this cannot result in schemes becoming unviable.

Comment

Representation ID: 22049

Received: 11/10/2021

Respondent: Ms Jan Norton

It seems there has been little or no consultation focus on land earmarked for the development of employment opportunities or to meet industrial needs. This is a significant flaw in the consultation and it will be interesting to see the extent to which responses make reference to this.

I have not had time to consider this in detail, neither have I heard feedback from others about this.

Comment

Representation ID: 22075

Received: 11/10/2021

Respondent: Kinver Parish Council

Strategic Employment Areas:

• The evidence base has been revised from 2017 in 2021 to reflect post Covid-19 changes. The Employment Land Supply Technical Paper identifies a shortfall of land availability and a reliance on neighbouring areas to meet the need in full. How is this being addressed with South Staffs and what are the implications for the neighbouring authorities?

Comment

Representation ID: 23252

Received: 11/10/2021

Respondent: Historic England

Section 7 This section sets out a hierarchy of employment centres and the need to safeguard employment areas for future development.
It remains unclear as to what the implications may be for the historic environment and what assessment has been undertaken at this stage. We require further detail in order to make an assessment.

Comment

Representation ID: 44784

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

3. Consequences of failing to meet need

Planning to reduce the recent rate of housing delivery

3.1 The Draft BCP acknowledges a need for 76,076 homes, equivalent to 4,004 dwellings per annum throughout the plan period, but only identifies sufficient land to provide 47,837 homes or 2,518 dwellings per annum17. It openly admits that this would meet less than two thirds (63%) of the reported housing need, with a presumption – but no guarantee – that neighbouring authorities will accommodate the shortfall18.

3.2 Such an approach, whilst evidently threatening to leave a substantial amount of need unmet, would reverse the progress that has recently been made in boosting housing delivery in the Black Country. Figure 3.1 shows that the proposed requirement for 2,518 dwellings per annum is less than what has been delivered in each of the last six years, the average rate of provision in this period having been boosted by around one third (34%) compared to the six years prior but now apparently at risk of falling by some 12% under the approach proposed by the Draft BCP. This would represent a missed opportunity, as positively planning for a further boosting – of the scale achieved recently (+34%) – would very nearly meet the minimum need suggested by the standard method19.

See attachments for Figure 3.1:Proposed housing requirement relative to recent delivery
Risking the benefits associated with recently increased provision

3.3 The recent boosting of housing supply has brought demonstrable benefits to the Black Country which will be put at risk if delivery is allowed to fall.

3.4 One such benefit relates to the attraction and retention of people within the Black Country. This area has historically tended to lose residents to other parts of the UK without attracting the same number from elsewhere, but Figure 3.2 shows that the average size of this net annual outflow over the past six years (2014-20) has been less than half that recorded previously, over the years for which consistent data is available20 (2001-14).

See attachment for Figure 3.2: Recent change in the average net outflow from the Black Country

3.5 This smaller net outflow of people has helped to restore a trend of growth amongst the working age population (16-64) which had been faltering in the years before21. Having declined throughout the 1990s, this cohort grew in size for ten straight years to 2011 before effectively remaining static for three years, with average annual growth of close to zero (0.04%). The boosting of supply from 2014 onwards, however, has helped to once again grow this key cohort of the population as shown at Figure 3.3 overleaf.
See attachment for Figure 3.3:Annual change in the working age population of the Black Country

3.6 The positive trends outlined above appear extremely unlikely to continue if the rate of housing delivery slows to the rate proposed by the Draft BCP, according to demographic modelling by Edge Analytics which has been commissioned to inform this report. This is intended to illustrate how the provision of 2,518 dwellings per annum from 2020 onwards could, in combination with other demographic factors, affect the size and profile of the Black Country population. Further detail on the methodology is provided at Appendix 1.

3.7 The model suggests that the proposed level of housing provision would be unable to accommodate a net inflow of people from outside of the Black Country, effectively forcing circa 5,525 residents every year to move to other parts of the UK. This is more than three times greater than the net outflow of recent years, shown at the earlier Figure 3.2, and indeed is without recent precedent where it is larger than recorded in any year since at least 2001. This does technically allow for a net inflow of international migrants, albeit one that is smaller than recorded in recent years, but even if this does not materialise and their homes accommodate those otherwise assumed within the model to move elsewhere, the overall net outflow – shown as a dotted grey line at Figure 3.4 below – would remain larger than seen historically.
See attachment for Figure 3.4: Modelled impact of reduced housing provision on net migration

3.8 Population growth would be expected to dramatically slow in this scenario, falling to only 0.1% per annum over the 19-year plan period compared to 0.6% per annum over the equally long historic period (2001-20).

See attachment for Figure 3.5: Modelled impact of reduced housing provision on total population

3.9 The working age population would also be expected to shrink by circa 2% in total – as shown at Figure 3.6 overleaf – while the elderly population, aged 65 and over, could grow by as much as a quarter. This would increasingly and markedly shift the demographic profile of the Black Country towards older age groups.

See attachment for Figure 3.6: Modelled impact of reduced housing provision on selected age groups

Implications for the Black Country economy

3.10 Such limited population growth, combined with a changing age profile, would in turn affect the size of the resident labour force, and its ability to support the creation of new jobs in the Black Country. Edge Analytics’ modelling suggests, based on the assumptions detailed at Appendix 1, that the labour force could support the creation of only 615 jobs per annum over the plan period if housing delivery aligns with the proposed requirement.

3.11 At least one economic forecast, produced by Experian, suggests that the Black Country has the potential to create over three times as many jobs over the same period (2,116pa). The Local Enterprise Partnership (LEP), meanwhile, has previously expressed a target that – although not officially annualised – appears to equate to more than 6,000 jobs per annum if reasonably assumed to cover a period of twenty years22. This is over ten times more jobs than could be supported by the Draft BCP, as shown by Figure
3.7 overleaf.

See attachment for Figure 3.7: Benchmarking job growth annually supported through the proposed approach


3.12 The proposed housing requirement will therefore hamper, rather than support, the recovery and growth of the Black Country economy. This is contrary to one of the overarching aims of the Draft BCP, which explicitly seeks to ‘attract new businesses and jobs’ to the area and:

“…increase employment opportunities to support the delivery of the Black Country and West Midlands Combined Authority Strategic Economic Plans (SEP), the Local Industrial Strategy and Covid-19 recovery plans”23

3.13 It later describes the LEP’s ‘overall aim of transforming the sub-regional economy by creating the conditions for enterprise to flourish, resulting in greater economic prosperity across the Black Country’24. It states that its own ‘challenge’ is to maintain the ‘momentum’ that has recently led to economic growth, particularly in light of the pandemic, suggesting that ‘the Black Country Plan is part of that process’25 in terms of providing employment sites without acknowledging the parallel importance of attracting and retaining labour through making sufficient provision for housing.

3.14 The proposed approach to housing supply does not rise to this ‘challenge’, threatening instead to stall any ‘momentum’ that has developed in recent years. It must therefore be reconsidered, with the aim of further boosting housing supply and retaining the benefits that have recently been generated through increased delivery.

Object

Representation ID: 44792

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

The relationship with the need for employment land and reliance on the SHLAA

4.16 The BCP evidence base26 concludes there is a gap (shortfall) of 140.3 ha against the demand requirement for employment sites in the Black Country area. The Councils state this will need to be addressed through ongoing Duty to Co-operate engagement with neighbouring local authorities.

4.17 There are a number of sources of the Councils’ housing land supply which are proposed on existing vacant or occupied employment land. The NPPF states that a sufficient supply of employment sites should be provided as well as housing. The NPPF is also clear at paragraph 81 that planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. It states that significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for
development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future.

4.18 In this way, the reliance on occupied employment sites to deliver housing instead directly contradicts the intention of national policy to support economic growth and productivity.

4.19 The NPPF requires there to be a realistic prospect that a site will be available and could be viably developed at the point envisaged. The fact that many sites in the Councils’ trajectory are likely to be in demand for employment land, given the shortfall of 140.3ha identified, increases doubt that they will be developed for housing at the point envisaged.

4.20 The NPPF also states at paragraph 68 that strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability.

4.21 Having reviewed the four SHLAAs, which are a key source in determination of the urban capacity in the Black Country, we have concerns with the approach taken, and any plan making decisions based upon them. The SHLAAs state that:

“Only where a site has a realistically implementable permission for an alternative, non- housing use will it be removed from the list of SHLAA sites”

4.22 This does not account for the likely high number of sites which may have potential for alternative, non-housing uses, but that simply do not benefit from an implementable permission. It could be argued that based on the SHLAA conclusions, these sites are as much possible employment sites as they are housing sites.

4.23 If this is the approach taken to understanding the stock of available housing sites, it is vital that reasonable and realistic planning judgement is then applied when relying on their delivery to meet requirements in the plan period.

Object

Representation ID: 44812

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Proposed allocations on occupied employment land – discounted by 15%

5.45 The Councils rely on 3,091 homes in the plan period from this source. When considered against the NPPF tests, which emphasises ‘availability’ as a key tenet of being both developable and deliverable, these sites are unavailable as they are presently occupied by existing uses. There are particular risks with bringing forward occupied employment sites, in that they:
• have existing commercial value

• require business relocation

• are often in multiple ownerships without any form of collaboration agreement or equalisation

• have other commercial considerations (such as lease status)

• require land assembly

• will most likely require complex phases of remediation and new infrastructure

5.46 Whilst the Councils do highlight that investment may be forthcoming to assist land assembly and viability, specific evidence should be submitted for what sites this may affect. The allocation of occupied employment land for housing, in the context of the Councils’ own evidence base concluding that there is a gap (shortfall) of 140.3 ha against the demand requirement for employment sites in the Black Country area, casts doubt over whether there is a reasonable prospect that any of this source of supply is developable at all.

5.47 The Councils report, in the Urban Capacity Review, the following historic rates on occupied employment sites.

See attachment for Table 5.6: Homes Allocated and Delivered on Occupied Employment Land

5.48 The above demonstrates that of the occupied employment land allocated in the previous round of development plan documents associated to the BCCS, just 4.2% of the homes have been delivered.

5.49 It is acknowledged that there are additional permissions which have been granted (193 homes on 4.5ha of land in Dudley, and 510 homes on 23ha of land in Sandwell) but these do not substantially change the conclusion, and these sites remain undelivered.

5.50 The NPPF states that Local Plans must be aspirational but deliverable. We suggest that a precautionary approach to occupied employment sites as a source of supply must apply given the local track record of delivery, and due to the known constraints to delivery of these sites.
5.51 The precautionary principle should apply even more so, given the findings of the Councils’ evidence base and conclusions on employment land over the Draft BCP plan period.

5.52 The Councils apply a 15% discount rate to account for non-implementation, but it is considered that this does not go nearly far enough. The Councils state that the 15% non-implementation rate is supported by the GL Hearn Greater Birmingham HMA Strategic Growth Study (2018) which endorsed application of a 15% discount in the Black Country to:

“…take account of the significant proportion of the land supply which comprises employment sites where there are challenges associated with delivery related to assembling land, relocating existing occupiers, and development viability.”

5.53 Paragraph 4.123 of that report acknowledges that the discount is:

“…judgement-based and applied for the purposes of this report only and should not be considered to prejudge what allowance should be made for non-implementation in individual local plans or authorities’ land supply assessments, which can take account of locally-specific circumstances and evidence.”

5.54 It is clear then that the 15% discount was not intended to be relied on in Local Plan preparation, and does not assist in endorsing the Black Country authorities’ approach on this matter. It is still necessary for the Councils to prepare their own, authority specific, evidence to support their approach.

5.55 Dudley have undertaken a landowner engagement exercise in relation to assessing the availability of existing employment sites. The Dudley Employment Landowner Engagement Technical Report (August 2021) Appendix B sets out the responses to a direct land owner approach survey. There appears to be only two sites out of circa 45 sites documented where the owners have confirmed availability for the proposed use and the site has also been submitted into the SHLAA for housing availability.

5.56 For the significant majority of sites proposed in the Landowner Engagement Exercise Technical Report his document to be re-allocated for housing, the evidence suggests that no response was received from the landowner.

5.57 Evidence from only one of the four authorities covered by the BCP is insufficient to justify an approach with such strategic implications.

5.58 Given the Councils’ track record of delivery and the findings of their evidence base, the BCP should only include sites on occupied employment land that is known to be available, suitable and where some evidence is available of likely economic viability.

5.59 In reality this involves removal of all sites where there is any ambiguity around leases/current employment occupation etc.

5.60 This results in a reduction of the full 3,091 homes relied on from this source in the plan period, based on the Councils’ current limited and insufficient evidence base. However, it is suggested that some of this number could be offset through appropriate re-allocation, or identification as specific developable existing allocations where up to date evidence provided to confirm there is a reasonable prospect that they will be available and could be viably developed at the point envisaged.

Comment

Representation ID: 45420

Received: 11/10/2021

Respondent: Lichfield District Council

To whom it may concern,
LDC Representations to Draft Black Country Plan Review

Thank you for consulting Lichfield District Council on the Draft Black Country Plan 2018-2039 (BCP) Regulation 18 consultation. Lichfield District Council welcomes the opportunity to provide comments on the BCP at this emerging stage. Lichfield District Council welcomes the continuing, positive dialogue with the Black County Authorities through the Duty to Co-operate process as
the Black Country Plan progresses.

Housing requirement and delivery:
Lichfield District Council notes that the proposed housing requirement figure for the plan period (2020- 2039) for the Black Country area is 76,076 homes or a need for 4,004 new homes each year as detailed within Table 2 of the BCP. This is based on the standard method used to calculate Local Housing Need (LHN) for the four Black Country authorities which includes the
35% uplift to the Wolverhampton housing need figure as a result of the changes to the standard method in regard to the country’s largest cities and urban centres that were made in December 2020.

The May 2021 Wolverhampton SHLAA outlines that 19,646 net homes would be required to meet the LHN for the current Black Country Plan review period (2020-39). It is acknowledged that the BCP aims to deliver 12,100 homes in Wolverhampton with 11,083 of these homes within the urban area of Wolverhampton and included within this is a target for 4,838 homes to be delivered within the city centre itself.

This leaves a shortfall of 7,546 homes that cannot be delivered within Wolverhampton’s own area and will need to be exported via the Duty to Co-operate. However, 5,092 homes (268 per annum) of this figure is the urban uplift for Wolverhampton. The Planning Practice Guidance sets out where the cities and urban centres uplift should be met (Paragraph: 035 Reference ID: 2a-035-20201216). This states that “This increase in the number of homes to be delivered in urban areas is expected to be met by the cities and urban centres themselves, rather than the surrounding areas, unless it would conflict with national policy and legal obligations. In considering how need is met in the first instance, brownfield and other under-utilised urban sites should be prioritised and, on these sites density should be optimised to promote the most efficient use of land. This is to ensure that homes are built in the right places, to make the most of existing infrastructure, and to allow people to live nearby the service they rely on, making
travel patterns more sustainable”. This makes clear that a proportion of the unmet need relating to this uplift should therefore not be included within the shortfall numbers to be exported to other authorities.

It is noted that the BCP, through policy HOU1 – Delivery Sustainable Housing Growth, will provide sufficient land for at least 47,837 net new homes over the plan period within the area. It is noted that this creates a housing shortfall of 28,239 that is to be exported through the Duty to Co-operate of which 5,092 homes come from the uplift applied to Wolverhampton’s LHN. This housing shortfall represents 37% of the housing need for the Black Country area. This is a significant figure given neighbouring authorities need to meet their own LHN and demonstrate their Local plans are realistic in terms of delivery. There is therefore concern as to whether this
level of export of growth to neighbouring authorities is realistic in respect of delivery or that such an approach meets the need where it is most needed.
It is nevertheless acknowledged by Lichfield District, along with other authorities within the HMA that they should seek to provide a proportionate and meaningful contribution toward the unmet need arising from the Black Country HMA. Lichfield District Council has progressed in the review of its Local Plan. The Local Plan 2040 was subject to consultation in July and August 2021 and is scheduled for submission before the end of the year. The draft Local Plan 2040 proposes a
contribution of 2,665 homes between 2018 – 2040 towards the Greater Birmingham and Black Country Housing Market Area shortfall, of which 2,000 homes are to assist with the unmet need arising from the Black Country and will be delivered from 2027/28. Lichfield District Council considers this to be a significant and proportionate contribution to unmet needs, equating to an
additional 37.7% on the District’s LHN. Accordingly the District Council would like to stress the importance of the Black Country Authorities proactively seeking the absolute maximum within their own borders and to identify any further potential sites from Urban Capacity work and from robust consideration of additional Green Belt release where these are evidenced and appropriate.

The District Council notes the Green Belt Review and acknowledges the methodology used. The District Council concurs with the BCP that exceptional circumstances exist to merit the release of Green Belt within the area noting the level of growth required for the Black Country Authorities over the plan period. The District Council would like to reiterate that sites that serve a lower significance to Green Belt purpose need to be robustly and purposefully assessed considering
the unmet need. Such consideration could identify further allocations within the BCP area to meet the housing and/or employment requirements of the plan.

The District Council notes the Urban Capacity work and acknowledges the loss of surplus occupied employment land that had previously been allocated as housing land and the impact this has had on supply. It may be that further demonstration of evidence is required at Publication stage of the BCP as to the justification of this loss given the plan period runs until 2039. It is not unreasonable to consider that some of these surplus employment sites may reach the end of their commercial life within this plan period and assist with meeting development needs towards the medium to end of the Black Country Plan period.

Housing Allocations
The District Council notes the allocation of Sites WAH235, WAH 237 and WAH 253 in the West Midlands Green Belt in Walsall to the east of Brownhills and Leighswood and sites WAH230, 246
and 254 north of Hardwick.

We would like to make the Black Country Authorities aware of the Air Quality Management Area (AQMA) at the A5/A461 Muckley Corner junction in Lichfield District. Further to this, Chasewater and Southern Staffordshire Coalfields Site of Special Scientific Interest (SSSI) is also located in relatively close proximity. Proposals within 15 Km of the Cannock Chase Special Area of
Conservation (SAC) will also need to be informed by the partnership work being undertaken and the evidence base work being prepared.

Such considerations along with any detailed transport assessments should be taken into account when assessing the suitability of these allocations alongside their potential suitability in Green Belt methodology terms.

Employment
The District Council notes that the BCP, through Policy EMP1 – Providing for Economic Growth and Jobs, will seek the delivery of at least 355 hectares of employment land within the Black Country through allocated sites and redevelopment, intensification and enhancement of existing employment areas and premises. It is noted at paragraph 7.12 of the BCP that there is an employment land shortfall of 210 hectares that is to be exported to authorities through the ongoing Duty to Co-operate process and secured through Statements of Common Ground.

This employment land shortfall represents 37% of the overall employment land need. The 2021 Urban Capacity Review Update paper at paragraphs 2.2.4 and 2.2.5 make reference to; a ‘desired economic situation’ and to the ‘economic growth aspirations of the Black Country… past trends plus some growth scenario’. The District Council would question whether this aspirational level of economic growth and increased provision of employment land is realistic given the need to export 210 hectares of employment land to neighbouring authorities through the Duty to Co-operate. Again, LDC would suggest further consideration is given as to whether this aspirational level of growth is an appropriate growth option for the Black Country
Authorities having regard to deliverability, meeting need where it is most needed and the high level of dependency of exportation of the growth.

Lichfield District is unable to assist in meeting any unmet employment need. The emerging Local Plan seeks to meet the Districts own employment needs. The emerging Lichfield District Local Plan 2040 makes clear that evidence demonstrates that there is only sufficient employment land within the District to meet our own requirements with limited potential further options beyond
those allocated. Therefore, the District Council will be unable to assist in meeting unmet need for employment land arising from the Black Country.

Minerals
Lichfield District also notes the identification to the north east of Walsall of a Sand & Gravel Mineral Safeguarded area and a preferred area for sand and gravel extraction and would like to emphasise the importance of the thorough assessment of the environmental and traffic
implications of any future proposals and the appropriate site restoration where any mineral operations take place.
Lichfield District Council welcomes continuing a positive dialogue with the Black County Authorities through the Duty to Co-operate process as the Black Country Plan progresses.

Yours faithfully
S W Stray
Stephen Stray
Spatial Policy and Delivery Manager

Comment

Representation ID: 45891

Received: 11/10/2021

Respondent: Transport for West Midlands

This chapter provides very limited narrative on the importance of good transport accessibility to employment opportunities. Therefore, there is room to strengthen this chapter.