Evidence

Showing comments and forms 1 to 4 of 4

Object

Draft Black Country Plan

Representation ID: 21323

Received: 11/10/2021

Respondent: J Holt & Sons

Agent: Spawforths

Representation Summary:

J Holt & Sons are concerned that the EDNA 2 (2021), does not reflect the full potential for the growth in demand for industrial and logistics land.

In summary, we consider that the overall requirements for employment land are an underestimate of both the quantitative and qualitative requirements and do not reflect the drivers of current and future demand. Furthermore, there is a need for an appropriate margin for choice and flexibility, in addition to factoring losses. As a result the amount of land required is under-estimated and hence so too is the amount of land that needs to be exported to appropriate authorities. This amount of land is likely to be higher than that shown in the draft Plan and EDNA, given the lack of strategic sites within the Black Country.

J Holt & Sons consider that any employment need that is to be exported should be focused in locations which have a strong functional relationship with the Black Country. The EDNA notes that Birmingham and South Staffordshire have strong economic interactions with the Black Country.

Object

Draft Black Country Plan

Representation ID: 21434

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

Representation Summary:

The conclusions of EDNA2 are significantly influenced by the assessment of future employment growth by sector as illustrated in Fig 2.4. Basing the assessment of need for the manufacturing sector on the GVA projection appears to be a sound basis. This identifies a need for a significant amount of land for new manufacturing development. EDNA2 bases the forecast requirement for logistics floorspace and land upon the employment projection. The report provides no explanation or justification for those employment projections which are fundamental to future floorspace and therefore land requirements. As explained below, our assessment is that this significantly underestimates the amount of floorspace and land that will be required for logistics use over the plan period.
The calculation of the figures in Fig2.5 is unclear, as the projections for each sector are not applied equally to those sectors across each of the four Black Country Authorities (BCAs). Over the period 2020 – 2039 Dudley is stated to expect falling employment in both manufacturing and logistics, Sandwell and Walsall have falling employment in the manufacturing sector only, and Wolverhampton has growth in all sectors. It is not clear how Fig2.5 flows from Fig 2.4 as stated at 2.10. For the Black Country as a whole, Fig 2.5 projects growth in office employment, lower amounts of growth in logistics employment and a significant decline in manufacturing employment.
Those projections must be questioned based upon the evidence of activity in the occupier and development land markets both in the long term, and in the period since the onset of the pandemic in March 2020. Both manufacturing and logistics sectors are experiencing record breaking levels of demand for floorspace in midsize to large buildings.
EDNA2 2.11 states that past trends show a greater correlation between GVA in the manufacturing sector than employment forecasts. The swing in need depending upon the factor used as the measure is highly significant. On the employment measure Fig2.5 projects a requirement for manufacturing land of - 23.44ha (negative). On the GVA measure 2.11 states the requirement for manufacturing alone would be 866ha. A swing of 890ha. In order to reduce that requirement of 866ha EDNA2 assumes efficiency gains for manufacturing in the use of its floorspace from 1,544sqm per £1million of GVA to a range between 1,000qsm and 800 sqm of floorspace per £1million GVA. A 35% to 48% increase in efficiency across the manufacturing sector. Whilst some increased efficiency may be a reasonable expectation, there is no explanation or justification provided for such a bold assumption as to efficiency gains in the use of floorspace. The application of those efficiency gains reduces the manufacturing land requirement from 866ha to between 448 – 560ha over the period 2020- 2039. EDNA2 does not state where the change in GVA is sourced or what it reflects. It is not possible therefore to assess the degree of ambition upon which the floorspace and land requirement is based, or the likelihood of achieving the efficiency gains which are assumed. Given the SEP focus upon high value manufacturing, and technology based industry as 4 of the 5 transformational sectors of the Black Country economy, it is vital that opportunity for these sectors is adequately provided for and not artificially constrained at the land allocation stage.
EDNA2 favours the GVA based method (with assumed floorspace efficiency) for the manufacturing sector, but utilises the employment projection based floorspace requirement as the basis for land required for the logistics sector. EDNA2 forecasts a requirement of just 31ha for the 19 year period (see Fig 2.8). EDNA2 2.19 states that 94% of future land requirements will be for classes E (g)(ii)(iii) and B2, with only 6% being for B8 use. 2.17 states that evidence since 2016 indicates 13ha per annum has been taken up by manufacturing uses, with 5.6ha per annum by logistics. As a result 2.19 projects 30% of future demand for B8 and 70% for manufacturing.
Savills research shows that for buildings above 100,000sqft, the split between manufacturing and logistics take-up is the reverse of what the EDNA states. Savills evidence shows that nationally 85% of take-up is for logistics and 15% for manufacturing. For the West Midlands, the proportion of manufacturing use is higher at 23%, but 77% of take-up is accounted for by third party logistics operators and the retail industry.
We do not take issue with a GVA based approach being the appropriate basis for assessing future business floorspace and hence land requirements. As such the proportional split of demand in the market does not directly affect the assessment of manufacturing floorspace need. What it does highlight, is the under estimate of logistics floorspace that is required at a wider market level to support that manufacturing output. The relatively low levels of take-up for logistics which EDNA2 reports is likely to be a function of the lack of large and well connected sites within the Black Country, limiting the potential for logistics operations. The assessment of past levels of take-up and applying that to the future scenario, simply exacerbates the problem of constrained land supply of the appropriate quality, size and location. That should be of concern, as logistics is vital to efficient manufacturing. The gains in manufacturing floorspace utilisation efficiency which EDNA2 factors in, are likely to require increased levels of just in time delivery of materials and components, and reduced levels of on-site storage of materials and finished products. That will require increased amounts of floorspace for logistics in the right locations to serve those manufacturing business. The principle of the GVA based assessment for manufacturing is not affected by this, but the amount of floorspace for the logistics sector would be very substantially greater than has been allowed for in the EDNA conclusions on need at 2.21.
In conclusion on employment land need, the EDNA does not provide sufficient explanation of the assumptions and calculations used to derive the floorspace and land requirements. It appears that there is a very substantial under-estimate of the level of logistics floorspace that will be required over the period to 2039. There is no explanation for why the middle estimate is deemed the most appropriate basis. There is no justification for the assumed increased efficiency in manufacturing use of floorspace. There is no explanation of how the economically determined estimate at 2.8 is adjusted downwards to derive the figures in Fig2.10 and Fig4.1. It appears that the identified need should account for two additional years. As a result of these matters we consider that the employment floorspace and employment land requirement is considerably greater than is currently being planned for.

Object

Draft Black Country Plan

Representation ID: 21439

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

Representation Summary:

Spatial development Option J which has been selected as the preferred basis for the BCP is reliant upon cross boundary provision being made. The sustainability appraisal of option J is not complete without understanding the sustainability and environmental implications of that cross boundary provision, which could be negative or positive.
The BCP reliance upon cross boundary provision for employment land to meet assessed needs is not currently assessed in the Sustainability Appraisal and Strategic Environmental Assessment (SASEA). The SASEA states at 1.4.4 that sites proposed through cross boundary provision will be subject to sustainability appraisal and strategic environmental assessment by those LPA that are making that provision.
We do not disagree that the LPA proposing to allocate land for the BCP needs should make such assessment. However, in the absence of certainty about where and even if such cross boundary provision will be made, it is necessary for the BCP SASEA to consider the options for meeting the needs. If the alternative to provision across boundary is additional release of land from Black Country green belt, then that option should be assessed. The various options that are being considered for cross boundary provision should also be assessed in the SASEA, to help inform which of those options is / are best suited to meeting the identified needs.
The completion of the SASEA will therefore require understanding of the options for delivering cross boundary provision to meet all of the identified need, and certainty that such provision will be made to deliver that land within the BCP period.

Comment

Draft Black Country Plan

Representation ID: 22487

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Representation Summary:

Urban Capacity Review Update May 2021

The published Black Country Urban Capacity Review Update May 2021 provides evidence of the
extent of the housing shortfall arising from the Black Country’s urban area, informing the housing
requirement set out in Policy HOU1 of the consultation document. We note and welcome the
attempts to maximise urban supply set out in this document and agree with the conclusion that
there will be a substantial shortfall arising from the Black Country urban area up to 2039. This is
consistent with the GBHMA-wide picture given in the GBHMA Strategic Growth Study 2018, which
indicated a significant shortfall would remain at a GBHMA-scale up to 2036 even if significant
density increases were realised in land supply across the GBHMA.

South Staffordshire therefore considers that the Black Country Urban Capacity Review Update May
2021 offers a reasonable basis on which to progress Duty to Co-operate discussions regarding the
Black Country’s urban housing shortfall within the GBHMA. However, before the extent of the
Black Country’s urban capacity is finalised through the submitted Black Country Plan, there are matters that we believe could be more fully addressed within the document, that may then help to
inform ongoing Duty to Co-operate discussions regarding the exact extent of the shortfall and the
scale of contributions required to address it.



Firstly, we note that the urban capacity review has sought to identify urban land opportunities
from annual updates of individual local authority SHLAAs, informed by regular call for sites
exercises. We acknowledge that this approach largely conforms to the historic approach set out in
Planning Practice Guidance for establishing housing land availability within an area. However, there
is a need for greater consistency on how urban supply is assessed across the conurbation, given
the Duty to Co-operate implications of shortfalls arising from this area. Specifically, Birmingham
City Council have recently commissioned assistance from the PropTech sector to find innovative
ways to survey its urban land supply, allowing it to identify and survey a far larger number of infill
site opportunities than would otherwise be possible through a traditional SHLAA exercise. This is
despite previous SHLAAs being found to be consistent with guidance at the time through the
Birmingham Development Plan examination. This work does not appear to be limited to increasing
densities in established urban centres and appears more reflective of the approach advocated by
the more recently published National Model Design Code, which encourages “[c]oding for the
intensification of lower density areas that use land inefficiently”1 when planning for an efficient use
of urban land. For consistency in approach across the housing market area to addressing the 35%
urban uplift in housing needs, we consider that the Black Country should work with the West
Midlands Combined Authority to explore similar approaches to identify further urban supply to
meet its needs.

We would also welcome a re-examination of the approach to windfall allowances within the urban
capacity review, which paragraph 2.1.11 confirms have been based upon past land supply trends
on small sites (i.e. sites of 9 homes or less). This suggests that future trends will not have an impact
upon windfall development realised within the Black Country and that there is no realistic scope
for windfall development on sites or 10 or more homes. Whilst we understand the desire to pursue
a conservative approach to such matters, we do not consider it fully reflects the opportunities for
windfalls identified in paragraph 71 of the NPPF, which also requires expected future trends to be
considered in establishing any realistic windfall allowance. We would support a slightly more
ambitious windfall allowance that had regard to recent and upcoming permitted development
changes (e.g. Class E to residential) that may not be fully reflected in current past trends, or the
potential for landowner intentions to change during the plan period on non-residential uses.
Given the significant scale of the Black Country’s housing shortfalls, we do not anticipate that
exploring the approaches set out above would alter the need for Duty to Co-operate discussions to
address housing shortfalls. However, they would offer greater comfort to surrounding authorities
within the GBHMA that the Black Country is truly maximising all available housing land within its
urban area and help to reinforce the necessity of housing contributions from other areas of the
GBHMA.

1 National Model Design Code – Part 2 Guidance Notes, Section U.1.i ‘Efficient Use of Land’