Policy EMP1 – Providing for Economic Growth and Jobs

Object

Representation ID: 10577

Received: 18/08/2021

Respondent: Mr Stephen James Pratt

Policy EMP1 makes provision for 355ha of employment land to meet an identified need of 565ha, leaving a shortfall of 210ha to be exported to neighbouring authorities through the Duty to Cooperate. However, there is no indication of how this shortfall will be met, either by Statement(s of Common Ground/Memoranda of Understanding with the relevant neighbouring authorities. As such, the policy is unsound and not legally compliant with the Duty to Cooperate.

Comment

Representation ID: 11156

Received: 24/09/2021

Respondent: Mr Richard Carter

Something that is worth saying at this point is that there is a place for Artificial Intelligence (AI) and digital technology in our society. However, while investigating possible uses of such technology, there is an underlying requirement to consider the ramifications of any
implementation on society, i.e. the benefits of implementing technology need to be balanced against potential negative human impact.
If we consider the desire within businesses, and some echelons of society, to increase the use of
driverless vehicles and supermarkets without staffed checkouts, for example, although such
moves should help businesses to become more profitable, they will also dramatically increase
unemployment levels, the strain on society and, in all probability, poverty. In a society where finding meaningful employment is already an uphill struggle, where will the people displaced by these trends work? Where will they obtain the finances to allow them to purchase goods or services from the very businesses that no longer feel there is a need to employ them?

Comment

Representation ID: 11166

Received: 24/09/2021

Respondent: Mr Richard Carter

One factor that is apparently overlooked when multiple strategies for improvement are put in place is the direct correlation that exists between them. For example, if the main headings of this document are examined, i.e. poverty, being green and transport, the following can be identified:
An available, efficient, easy to use and cost effective transport network is required to support employment, our industry, our economy and our society.
Ongoing green development of our transport network will require industry to provide innovative solutions which will support employment the economy.
Transport development and innovation hubs will create employment opportunities which will help to reduce levels of poverty.

Comment

Representation ID: 11171

Received: 24/09/2021

Respondent: Mr Richard Carter

Passing legislation that requires summer tyres to be replaced with all season/all year or stud-less winter tyres during the winter months would:
Improve road safety, reduce the number of accidents and save lives;
Lower insurance premiums;
Reduce the burden on the police, fire and ambulance / healthcare services and motoring organisations;
Dramatically decrease the amount of gritting required, its urgency and gritting related local authority costs,
Increase seasonal employment (more tyre fitters will be required);
Improve tyre industry, wholesaler and retailer productivity and turnover with a possible resultant increase in employment;
Allow more tyre retailers to introduce “Tyre Hotel & Swap” services;
Prevent the road infrastructure from closing down;
Allow life to continue as normal.

Comment

Representation ID: 11174

Received: 24/09/2021

Respondent: Mr Richard Carter

When poverty in the UK is researched, what are considered to be the leading causes of poverty are easy to identify. They include (source: https://cpag.org.uk/ accessed 16/01/2021):
Low paid, insecure jobs.
Unemployment and constantly having to cycle between periods of work and unemployment.
High costs and inadequate benefits.
However, what is often missed (and these factors help to feed the issues identified above) are the underlying social, cultural and environmental factors that generate the negativity, dissatisfaction, disillusionment and despondency which contributes to society’s “why should I bother” attitude and which, subsequently, can also lead to self-imposed poverty, i.e. people get trapped in a rut of accepting “second best” and substandard conditions.
On the surface, many British people appear to be content with their lives, they are supportive of charities and they are willing to help when asked. Yet, beneath the surface they are constantly paddling against a tide of anger and frustration; an anger that quickly surfaces, swells and overruns a person when they are brought to task for parking right on the very corner of a busy road
junction, with the rear of their van partially blocking the main road and blocking the views of other road users. Does that person apologise for not following the Highway Code? No! Their reaction is to chase after the person who “insulted” them, endanger other road users by swerving round pulling in front of the “culprit”, suddenly stopping dead, getting out of their vehicle and threatening physical violence.
In 2020, the United Nation’s “World Happiness Report” 2020 ranked the UK at number 13 out of 156 countries surveyed (Finland was ranked number 1) and ranked London at 36 with Helsinki taking the number 1 slot. This report analyses the results of the Gallop World Poll; which gathers feedback about a country’s Business & Economics, Citizen Engagement, Education & Families, Environment & Energy etc performance, and links this information with six other factors: levels of GDP, life expectancy, generosity, social support, freedom and corruption income.
Although the report provides an indicator of the level of happiness in the UK (the Gallop World Poll surveys approximately 12,900 people or approximately 0.02 of the current population), it may not be truly indicative of the population’s feelings as a whole; particularly if those people are totally unaware of alternative ways of life.
So what could improve the UK’s ranking in the report and peoples’ attitudes?
The primary answer to that question is to implement sustainable changes and systems that will have a positive effect on everyone’s daily life and attitude, and that will result in greater efficiencies and substantial cost savings at national and local government level. I short, implement changes that will make everyone’s life easier.

Comment

Representation ID: 11319

Received: 29/09/2021

Respondent: Councillor Ray Burston

Have the population projections been adjusted to account for lower inward migration based on Britain's departure from the European Union and the drive to fill more job vacancies from within the indigenous workforce? This will impact on projected demand for housing.

Object

Representation ID: 11394

Received: 01/10/2021

Respondent: Mr David Shaw

The policy needs to state that a major pre-requisite to its success is the provision of the underlying infrastructure, especially transport, housing, and their pre-requisites. Without the improvements in the underlying infrastructure this policy will not work.

Object

Representation ID: 12821

Received: 10/10/2021

Respondent: Birchills Agenda 21 Group

Agent: Goldfinch Town Planning Services (West Midlands)

We have concerns in relation to the inclusion of the following public open space sites within the proposed Core Regeneration Area designation
Public open space located North of Churchill Road and the Jane Lane School, Reedswood, Walsall. Closely bordering Junction 10 of the M6 motorway.

The Churchill Road urban green space area is critically important for the following reasons:
• • It provides an essential partly wooded urban green lung helping to significantly reduce harmful levels of air pollution: It forms an absolutely critical urban green lung alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6. As an urban green space ‘green lung’ containing pockets of mature and semi-mature broadleaved woodland it therefore helps to mitigate the effects of harmful air pollution from the M6 motorway network. It therefore helps to play a critical role in helping to protect the health of thousands of local residents living nearby. See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • These critically important urban green space buffers (urban green lungs) located on both sides of the M6 motorway network are critically important to the long-term health and well-being of thousands of local residents. These urban green space lungs are some of the most critically important urban green space lungs within the whole of the West Midlands Region (and potentially of UK wide importance), given the fact that they are located immediately alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6 (Walsall).
• • Given the above issues, it forms a critically important urban green space area that helps to prevent a future Public Health Emergency, by helping to prevent exposure to polluted air from the M6 motorway. This is considered important in order to help reduce cases of lung disease within nearby heavily populated residential areas by reducing their exposure to high levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the M6.
• • Noise reduction from the M6 motorway: It forms a natural green space partly wooded buffer which helps to protect nearby residential communities, by reducing the levels of constant traffic noise from the M6 motorway network.
• • Public open space (POS): It provides an important public open space (POS) area for thousands of local residents, conveniently located on the doorstep of large residential communities. These Local Green Space (LGS) areas are important for the local communities health and well-being.
• • Natural green space area: It provides a local natural green space area which helps local residents re-connect with the natural environment close-to-home and help escape the stresses of urban life. These natural green space areas located on the doorstep of existing residential communities have become of critical importance during the pro-longed 16 months of lock-down restrictions during the years 2020 and 2021 coronavirus pandemic (Covid-19). See further
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 29


• above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Outdoor recreation benefits: It provides an outdoor informal recreational resource (e.g. for walking, place to exercise pet dogs close to home, place to relax within a natural green space environment). It therefore helps support more physically active healthy lifestyles, important for both physical and mental health well-being.
• • Improving the local communities resilience to current and future global health pandemics: See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Natural green space shortage locally: There is an increasing shortage of these types (local natural green space areas) of publicly accessible natural green space sites within the wider Reedswood area due to built development encroachment pressures affecting other green space areas. This is starting to create an increasing shortage of these types of local natural green space sites.

• • Helping support populations of protected wildlife species by providing an important wildlife habitat: This natural green space site provides an important wildlife habitat for a number of protected wildlife species as identified in the Birmingham and Black Country Biodiversity Action Plan (BAP). Most notably, the green space site provides an important foraging habitat for different bat species.
• • Important wildlife corridor: This natural green space site forms an integral part of the important 'landscape-scale' green infrastructure connecting network within the wider surrounding heavily urbanised Reedswood area. Providing a critically important natural urban green space stepping-stone site (forming part of a critical wildlife corridor) connecting to the Pouk Hill natural green space area (located on the opposite side of the M6) and to the Reedswood Town Park natural green space area. The importance of protecting such areas is reinforced in paragraph 179 of the Revised National Planning Policy Framework (NPPF) (July 2021).
• • Climate change mitigation role: It helps to minimise the ‘Urban Heat Island Effect’ by helping reduce local air temperatures. See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Landscape enhancement: It enhances the local landscape quality, setting, character and local distinctiveness of nearby residential areas by providing a large natural green space area with areas of mature broadleaved woodland.

Within the emerging Black Country Plan (BCP) (Review) (Autumn 2021) consultation document, Walsall Council are proposing to allocate part of this sensitive urban green space site (bordering Churchill Road) as an area for new-build industrial uses (new employment land). See the blue shading area on page 499 (Figure 19 - Walsall Spatial Strategy Plan) of the BCP (Review) (2021). We specifically object to this employment land allocation as, in our view it will substantially erode this areas urban green lung benefits, reducing its ability to mitigate harmful levels of air pollution Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 30

from the adjacent M6 motorway network. Re-developing this sensitive urban green space lung for either new employment land or new housing will minimise the extent of a key urban green space lung alongside the M6, potentially placing large communities at increased risk from air pollution. Rather than promoting this site as a potential development area, Walsall Council should be promoting large-scale tree planting across this area of urban green space to help maximise and improve its effectiveness at mitigating air pollution from the M6 and to help strengthen its wildlife corridor function.
The local residents living nearby, have a clear, justified, and fundamental Legal right to ‘be able to breathe Clean Air’. This fundamental Legal Right is supported within the European Convention on Human Rights (The Human Rights Act Legislation) and should therefore be identified (through a designated green lung buffer on the BCP (Review) main Policies Map) and fully respected within the emerging Black Country Plan (Review). Additional tree planting measures are required within this urban green space area for reasons explained below.
Public open space located North of Churchill Road and the Jane Lane School: Summary of measures required to overcome our objections:
The following measures are required in order for the Birchills Agenda 21 Group to withdraw their objection:
• • Given this areas very sensitive urban green lung role, critical for helping to prevent a future Public Health Emergency due to its critical role in helping to reduce exposure to harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) highly toxic air pollution from the heavily congested M6 motorway network, the 'Core Regeneration Area' designation (as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document, within the ‘Figure 19: Walsall Spatial Strategy Plan’) should be fully removed from all parts of the Churchill Road public open space area, including its pockets of natural green space woodlands
• • All references to this highly sensitive urban green space area as falling within a proposed ‘Core Regeneration Area’ should be fully deleted from all parts of the emerging Black Country Plan (2021) (Review) (Regulation 18) public consultation document.
• • Given its green space and air pollution mitigation urban green lung benefits, this sensitive urban green lung (critical for helping to prevent a future Public Health Emergency) natural green space area should be removed from the employment land allocation within the emerging BCP (Review) (2021).
• • On the main Policies Map of the emerging Black Country Plan (BCP) (Review), the entire Churchill Road public open space area should be identified and specifically designated as a critically important ‘Air Quality Enhancement Urban Green Lung Area’ bordering the M6 motorway network. This special ‘green lung air quality enhancement designation’ should be clearly shown on the main Polices Map of the emerging Black Country Plan (BCP) (Review) to
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 31


• help ensure that its critical role in helping to reduce harmful levels of air pollution from the adjacent M6 motorway network continues to remain protected long into the future. This sensitive urban green space area has substantial Public Health benefits.
• • In order to help promote more sustainable patterns of development by conserving critically important areas of urban green space which have a key air pollution reduction role, these important urban green space buffers (urban green lungs helping to mitigate levels of harmful air pollution) on both sides of the M6 motorway should be given special recognition and planning policy protection on the main Policies Map within the emerging BCP (Review).
• • New tree planting should be actively encouraged across this wider urban green space site which is currently dominated by areas of open fields. Additional tree planting (using native tree species to help support biodiversity and therefore deliver net gains for biodiversity) is considered necessary to help strengthen this area’s performance and role as an essential urban green lung to help mitigate the effects of high levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the M6. Expanding tree cover across this largely open urban green space area will help to support the health of nearby residential communities and reduce traffic noise from the M6.
• • On the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area should be specifically designated as a ‘Protected Public Open Space’ area.
• • On the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area (including its natural green space woodlands) should be specifically designated as a ‘Local Green Space’ (LGS) area in accordance with guidance in paragraph 102 of the Revised NPPF) (July 2021).
• • On the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be specifically designated as a ‘Site of Local Importance for Nature Conservation (SLINC)’. This is considered necessary as the whole green space site warrants SLINC designation status given its ecological sensitivity.
• • The entire Churchill Road public open space area should be covered and protected by a ‘blanket Tree Preservation Order (TPO)’ (a blanket TPO) designation within the emerging Black Country Plan (BCP) (Review) (2021). This protection is necessary to help protect this areas continued urban woodland green lung function.
• • In accordance with guidance in paragraph 179 of the Revised NPPF (July 2021), on the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area should be specifically identified as a key wildlife corridor helping to form part of a wider key stepping-stone natural green space area, linking to Pouk Hill natural green space on the opposite side of the M6 motorway network and Reedswood Town Park natural green space area. The Churchill Road natural green space area forms part of the ‘stepping-stone’ natural green space network. This ecological network function needs to
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 32


• be recognised on the main Policies Map of the emerging Black Country Plan (BCP) Review.

Both Goldfinch Town Planning Services (West Midlands) and our client maintain their view that the above measures will help the Black Country Councill’s to deliver a ‘More Effective, Positively Prepared and Justified Plan, consistent with national policy’, in accordance with Local Plan ‘tests of soundness’ as reinforced in paragraph 35 of the Revised National Planning Policy Framework (NPPF) (July 2021).
The above measures will also help the Black Country Plan (BCP) (Review) (2021) to promote a more environmentally sustainable pattern of development, consistent with the expected planning policy approach set out in paragraph 11 of the Revised NPPF (July 2021) which reinforces the importance of promoting sustainable development. It will also help to ensure that an important area of urban green space is protected for the benefit of thousands of local residents to enjoy for outdoor recreation purposes, consistent with guidance in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021).
Finally, above measures will also help the Black Country Plan (BCP) (Review) (2021) to respond more effectively to guidance in paragraph 179 of the Revised NPPF (July 2021) which expects Local Planning Authorities to identify, conserve and protect ‘landscape-scale’ green infrastructure networks within heavily urbanised areas for the health and well-being benefits of local communities, and to ensure that their function and habitat quality as key wildlife corridors is sufficiently protected, to help support biodiversity.

Object

Representation ID: 12965

Received: 10/10/2021

Respondent: Akhlaq Hussain

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). This site should also not be promoted for new housing development within the emerging BCP (Review).

Comment

Representation ID: 16285

Received: 06/10/2021

Respondent: Mr Douglas Winterborn

I am also seeing residential premises used for business/commercial purposes is this legal? I think not,
are commercial rates due in theses cases? These places generally have a great deal of refuse around
encouraging vermin.

Comment

Representation ID: 16553

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

Economy: (BC Plan pg. 120-139)
We would like to see the following Green Jobs targets included in Dudley’s
economic development plans:
• 1770 green apprenticeships could be created in Dudley by 2023 so young
people can get the skills to work in the green economy.
• 2599 green jobs could be created in Dudley by 2030, according to the Local
Government Association.
• Potential jobs by industry: 127 in low-carbon services. 902 in low-carbon
heating. 826 in energy efficiency. 169 in alternative fuels. 393 in lowemissions vehicles. 182 in low-carbon electricity.

Comment

Representation ID: 17432

Received: 11/10/2021

Respondent: Black Country Local Enterprise Partnership (LEP)

In respect of the employment land approach, we welcome: -
1. The 100 plus sites covering 280ha specifically allocated for new industrial and logistics activities across the BC to meet a variety of needs.
2. The EZ projects around M54, Darlaston and Brierley Hill being promoted and would encourage the plan to include other sites for future development, i.e., Sandwell borough.
3 Welcome that the Plan protects the vast majority of our 3,000ha of existing employment areas from redevelopment to provide certainty for businesses.

We would like to see a reference to sustainable development of industrial and the mention of the Repowering the Black Country project, which is one of 7 areas selected across the Country for decarbonisation. In respect of the Black Country 10 sites have currently been identified in the Black Country, at least one in each borough. for zero carbon hub status, whereby complimentary businesses relocate and can share their energy needs. It would be good to include this initiative in the Plan, so that after the initial funding ceases the ambition is hard wired into the region for future commercial developments and repurposing existing developments.

Comment

Representation ID: 21215

Received: 11/10/2021

Respondent: Quadrant Estates

Agent: Quadrant Estates

We are instructed by our client, Walsall Bescot RP Limited (c/o Quadrant Estates), to submit representations to the Draft Black Country Plan 2039 (Regulation 18) Consultation which is being jointly prepared by the four Black Country Authorities (Dudley, Sandwell, Walsall and Wolverhampton). Our client has a site which lies in the jurisdiction of Walsall Council at Bescot Retail Park, Walsall, WS1 4SB (‘the Site’) of which they own the freehold.

We set out below the background behind our clients’ interest in the emerging planning policy within the Draft Black Country Plan 2039 (‘the Plan’) before addressing the relevant employment policies and outlining how the Site should be included going forward.

The consultation expires on 11th October 2021 and we therefore trust these representations will be taken into account.

1 Background
Walsall Bescot RP Limited own Bescot Retail Park which is managed by Quadrant Estates (‘Quadrant’). In view of the changing nature of the retail sector, Quadrant is exploring potential redevelopment opportunities to repurpose existing asset for alternative uses. Indeed, Quadrant have recently undertaken a pre-application meeting (ENQ/0132) with Walsall Council to discuss the potential of redeveloping the Site for employment uses.

Bescot Retail Park has previously been identified as a suitable site to deliver employment development. The Site benefitted from a draft employment allocation within the Issues and Options Site Allocations Document which underwent consultation in 2013 (site ref. IN309). The Site assessment stated that it was suitable for industrial uses due to it adjoining an existing industrial area (Bescot Crescent); and its proximity to Junction 9 of the M6. Its release for employment uses was dependent on the ceasing of the current retail use. However, at that time the existing retail use was performing well and a number of tenants had several years remaining on their leases. This position is now changing.

The feedback from the pre-application meeting, held on 5th October 2021, was positive and Quadrant were encouraged to submit representations to the Regulation 18 Consultation.

These representations outline the potential for the Site to be allocated within the Plan for employment uses but also state the need for the existing use (retail) to be recognised and respected. Whilst the potential for industrial should be promoted, the existing uses need protecting and therefore this letter requests a flexible approach to the allocation of the Site to be adopted.

2 Employment Policies
The Draft Black Country Plan 2039 (Regulation 18) Consultation will direct where new development will be locate up to 2039. Crucially it will also guide key issues such as employment land, answering key questions such as:
• Where does employment land need protection?; and
• How much new employment land is needed and where should it go?

The Plan includes a number of draft policies as well as a Policies Map and these have been considered against Quadrant’s intentions below.

Policies Map
It is understood that given its previous history, the Site was not included within the Black Country Economic Development Needs Assessment Stage 1 Report (May 2017). This is one of two documents which forms the evidence base for the emerging policy. The Site has therefore not been considered to date and therefore is currently shown as ‘white’ unallocated land on the draft Policies Map.
Quadrant wish for Bescot Retail Park to benefit from an employment allocation and it is proposed that the land is allocated as “Land for Employment” (Policy EMP1) or as a “Local Employment Area” (Policy EMP3). This is a natural extension to neighbouring Strategic Employment Allocation in which the remaining land at Bescot Crescent benefits from. The allocation will differ from the neighbouring allocation but this is necessary to protect the existing use in the short term. The medium to long term future of the Site currently looks to lie in employment uses and therefore this allocation will still assist in this land coming forward for employment uses within the Plan period.

However, it is vital that this future allocation must recognise that it is still an active retail park with tenants and the allocation should reflect this. The employment allocation cannot prejudice the existing use. The NPPF at Paragraph 81 outlines the need for “planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt.” Indeed, this will allow the Site to adapt when the time is right and continue to be occupied, employment generating and an asset to Walsall.

Policy EMP1
This policy, titled ‘Providing for Economic Growth and Jobs’ seeks to ensure there is a sufficient quantum of development opportunities in order to meet the employment needs of the Black Country economy.

The Site can help meet the large 164ha target for Walsall by providing another 5.14ha of employment land. Not only this but the land should be considered high-quality, given the neighbouring uses, existing use and proximity to the M6 as well as the A4148. The allocated employment land for Walsall would therefore increase to 169ha.

Within Policy EMP1 at ‘4’ we suggest the following amends to the policy to ensure that allocated employment sites, such as Bescot Retail Park, have their individual needs acknowledged:
“The key clusters of sites are shown on the Employment Key Diagram and individual sites listed in Chapter 13: Sub-Areas and Site Allocations. These sites will be safeguarded for industrial employment uses within Use Classes E(g)(ii), E(g)(iii), B2, and B8, unless stated otherwise.”

The Site will need to be described fully in Chapter 13 of the Plan, specifically within Table 36 under ‘Further Information’. Here it will need to include that whilst the land is allocated for employment uses it is an existing retail park and due respect and flexibility must be applied to recognise the current use. This will ensure that the existing use is recognised and not prejudiced in the short term.

This approach gains support from the NPPF at Paragraphs 81 and 82. At 82 d it states that planning policies should:
“be flexible enough to accommodate needs not anticipated in the plan… and to enable a rapid response to changes in economic circumstances.”

Policy EMP3
This Policy allocates and describes Local Employment Areas which would be a suitable allocation for the Site in the emerging Plan subject to the suggested changes below. Given the Site is a long standing, well-established commercial and industrial location it would be entirely suited to this allocation as it is characterised by “a critical mass of industrial, warehousing and service activity with good access to local markets and employees” as stated within the draft policy.

However, in order for the policy wording to ensure the short-term protection of the retail use in the short term and to allow suitable flexibility to the SIte, we propose the following amends at ‘2’ and ‘3’:
“These areas will provide for the needs of locally-based investment and will be safeguarded for the following uses;
a) Industry and warehousing (E(g)(ii), E(g)(iii)), B2 and B8 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
g) any existing uses.
3) Not all areas will be suitable for all uses and any existing uses should be taken into consideration.”

The above amended will ensure that the Site’s existing use will be recognised going forward and duly taken into account. Again, this approach gains support through Paragraphs 81 and 82 of the NPPF.

3 Summary
In view of the changing nature of the retail sector, which has seen a notable contraction of large format retailers, Quadrant is exploring potential redevelopment opportunities to repurpose the existing asset for alternative uses. Having gone through a positive pre-application with Walsall Council, it was encouraged that representations were submitted to this Regulation 18 Consultation to express how the Site could be allocated as an employment site.

Quadrant are therefore looking for the Site to be allocated for employment uses. However, key to any future allocation being accepted, any allocation or policy wording relating to the Site will need to recognise the need for the short-term use (retail) to be safeguarded or for due flexibility to be applied.

The retail park remains active and with a number of tenants still trading. Whilst an application for redevelopment for industrial uses is envisaged in the short term, given the existing tenants are still in occupation, redevelopment is more likely to come forward in the medium term. Any future allocation or site-specific policy will need to reflect this and not prejudice the current retail use.

Object

Representation ID: 21321

Received: 11/10/2021

Respondent: J Holt & Sons

Agent: Spawforths

For the purposes of clarity we consider that Policy EMP1 should reflect the total objectively assessed need for employment land; the nature of need especially with regard to storage and distribution requirements; and it should establish the quantum of need that will need be exported outside of the Black Country to adjacent authorities. In order to provide certainty this policy should establish the spatial strategy for meeting that need both within the Black County and beyond its boundaries.

Object

Representation ID: 21330

Received: 08/10/2021

Respondent: Nurton Developments Ltd

Agent: Jones Lang LaSalle

JLL considers the overall approach of the draft Black Country Plan to the economy to be sound. A need for employment land has been derived (a minimum of 565 hectares), a supply has been assessed (355 hectares) and a shortfall has been identified (210 hectares). The shortfall cannot be met within the Black Country and is to be exported, as far as possible, to Local Authorities which have a strong existing or potential functional economic relationship with the Black Country.

However, JLL considers that the figures for employment land need have been under-estimated and the assessment of deliverable supply has been over-estimated. Thus, the shortfall has been under-estimated.

In addition, there is a mismatch between the quality and types of site demanded and those being supplied. This is particularly so with larger or strategic sized sites (i.e. 25 hectares).

This scenario will act to hold back the delivery and pace of release of high quality employment land in the Black Country, and its associated Functional Economic Market Area (FEMA), which includes South Staffordshire and Cannock. This, in turn, will affect detrimentally the capacity of the Black Country to recover strongly from the Covid-19 induced recession and to accelerate the growth of the economy, thereafter, in line with the aspirations and ambitions of the Black Country Strategic Economic Plan (SEP).

Object

Representation ID: 21362

Received: 11/10/2021

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

4. Policy EMPl - Providing for Economic Growth and Jobs


Employment land requirement

4.1 The BCP's approach to employment land, in terms of not meeting the identified needs is through relying upon neighbouring authorities to meet the shortfall, which amounts to 210 hectares of employment land.

4.2 Furthermore, a significant proportion of the identified housing supply comprises existing employments sites. Aside from the identified strategic and local employment areas (Policies EMP2 & EMP3), the plan provides no protection to existing employment sites. In fact, Policy EMP4 is permissive of such sites being developed for housing, without any test as to whether there is a continued need for the site to remain in employment use. This will only exasperate issues of employment land supply in the Black Country.

4.3 Failing to meet the identified need for employment land will cause significant harm to the local economy. Businesses will not be able to invest and grow in the Black Country, and jobs growth will be curtailed to the detriment of residents. This is precisely the situation our client is facing with the uncertainty surrounding the current temporary use and it is frustrating the growth and development of a successful and highly valued local business. There may also be an impact on commuting pattens.

4.4 The Council's reasons for failing to meet the identified need for employment need are similar to its reasons for failing to meet local housing need. The approach is flawed because:

• The SA is based upon flawed assumptions.

• The BCA reliance upon the SA to justify the proposed growth option is misplaced.

• The alleged impacts on landscape and natural resources (including Green Belt) are overstated.

• There is an absence of firm agreement with neighbouring authorities to meet the needs.

4.5 The BCP should therefore not be allocating sustainable employment sites, which are operational, for housing needs whilst there is a clear need for employment land within The Black Country.

4.6 Overall, the proposed approach is not justified, effective or positively prepared. The BCP should seek to meet employment needs in full within the Black Country.

Object

Representation ID: 21433

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

The economic context of the BCP is stated to include the Black Country Local Enterprise Partnership (BCLEP) and West Midlands Combined Authority (WMCA) Strategic Economic Plans (SEPs) (1.11 & 1.12). The targets of those SEPs are however not fully embodied within the economic development targets of the BCP.
This means the BCP is seeking to accommodate substantially less economic growth than it should be. The Black Country has skills and productivity levels substantially below the regional and national averages. As identified by the SEPs, there is a need to address the widening gap between the Black Country and the rest of England. Planning for low aspiration will prevent the Black Country having the conditions to achieve a step change in its economy and will result in the productivity and skills gap continuing to widen.
There is also need for land to provide opportunities for enhanced education, skills and training to be provided alongside industry. The University of Wolverhampton is interested in opportunities to co-locate a new sector focused educational centre of excellence alongside high value manufacturing which will directly contribute to upskilling the workforce, narrowing the productivity gap and attracting internationally competitive industry. That requires a high quality, accessible site with appropriate sustainability credentials of sufficient size for industry and training to collocate
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.
Table 3 within the Land Supply section below shows that there is only one allocated site in the size range above 11.6ha, and that appears to not be available. 77ha of allocated sites are too small to accommodate a building of 100,000sqft. There is therefore a significant deficiency in high quality sites and sites which are able to accommodate larger buildings.
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.
The findings of the WMSESS are relevant to the BCP and should be taken into account in its preparation. Although there may not be land within the BCP area which can accommodate strategic sites in accordance with the need identified in the WMSESS, the need identified relates to supporting the economy of the BCP area. The preparation of the BCP should therefore take account of the need to ensure that adequate strategic sites are being brought forward in suitable locations as identified by the WMSESS. In this context the definition of ‘strategic’ in the WMSESS is different to that employed in the assessment of existing employment land in the BEAR.
The Strategic Priorities as set out at BCP Table 1 should state clearly that the priority is to identify and allocate sufficient land to meet objectively assessed needs for employment. The objective of enabling a strong and inclusive economy and strategic priority 7 should be clarified accordingly. The current lack of specific target in the strategic priority feeds through into the lack of appropriate target in the policies intended to deliver the strategic economic priorities.
Policy CSP1 states that the BCP will deliver 355ha of employment land which will meet strategic planning targets based upon the needs of local communities and business. It is our assessment that this targets will not adequately meet strategic planning targets, and the BCP does not currently deliver the land to achieve either the correct or the stated targets.
Table 2 identifies the BCP strategy is to deliver 565ha of employment land. As set out above we consider the evidence promoted by BCA supports a higher need of 585ha. The additional 20ha needs to be identified and allocated. If it cannot be accommodated within the BCP area it will increase the amount of employment land required from cross boundary provision.
We have identified a number of factors which indicate that need is likely to be substantially greater than 585ha for local needs for manufacturing and logistics uses. By the same measure as above, that would further increase the needs for cross boundary provision.
Additionally, the BCP does not currently acknowledge the need to plan for strategic sites as identified by the WMSESS. Whilst there may not be opportunity to allocate new strategic sites (as defined by the WMSESS) within the BCP area, it is a component of need which forms part of the objectively assessed need which the NPPF requires the BCP to provide for. If needs for strategic sites cannot be met within the plan area they should be identified and allocated across boundary through the duty to cooperate. Strategic site provision should therefore from part of the need for which there is an obligation upon the BCA to pursue through the duty to cooperate.
BCP Table 2 shows that the BCP plans to identify 355ha of employment land, with the remaining 210ha to be identified and allocated through the duty to co-operate. Taking account of the BCA evidenced need being 20ha greater than included, and no provision yet being made for strategic sites, the starting requirement from cross boundary provision should be 255ha. Any additional local need as discussed above would be a direct addition to that cross boundary requirement.
The 74ha of windfall is expected to come from existing employment land and so is not net additional land to meet the assessed need. The 74ha cannot be double counted. EMP1 and Table 2 is an over statement of employment land supply. Unless additional provision is made from green belt within the BCP area, the requirement from cross boundary provision must increase by 74ha.
Of sites larger than 2.3ha, (total of 204ha allocated) our review suggests that approximately 53ha is already in employment use. This includes sites that appear to have been recently developed, and other sites which appear to be in an existing employment use. The single allocated site which is larger than 11.6ha (WAE412 Sandown Quarry 20.85ha) is currently an operational quarry and associated production works. There is reason to question whether a quarter of all the land allocated above 2.3ha is able to contribute towards land supply. This suggest that there may be need to identify an additional 53ha of land to replace allocations which are not net additional employment land.
Additionally there is a need for the BCA to work with neighbouring authorities within the West Midlands to identify land for Strategic Sites as assessed by the WMSESS. That requires high quality sites of 25ha+ which can attract nationally and internationally mobile business, and/or sites aligned to a specific economic priority growth sector.
Area 4 of the preferred locations for meeting the need is most closely aligned with the BCP area. The WMSESS states that the M54 corridor is likely to have a role in meeting demand for Strategic Sites, and specifically identifies that land at M54 J3 which is on the edge of the study area (and Area 4) could meet needs for Strategic Sites arising from within the study area.

Comment

Representation ID: 22278

Received: 21/01/2022

Respondent: Miss Jodi Stokes

7.0 THE BLACK COUNTRY ECONOMY

7.1 Draft Policy EMP1 (Providing for Economic Growth and Jobs) sets out that the Black Country Authorities “will seek the delivery of at least 355ha of employment land within the Black Country, in Use Classes E(g)(ii), E(g)(iii), B2, and B8 between 2020 and 2039, to support the growth of the sub-regional economy and increase productivity”. They recognise that most, but not all, of this requirement will be met through sites allocated in the Black Country Plan, with some provision expected to be through the redevelopment, intensification and enhancement of existing employment areas and premises.

7.2 To support the ongoing growth of the distribution sector and a strong resurgence in manufacturing, the Economic Development Needs Assessment (’EDNA’) recommends that this Plan should provide for a minimum of 565 hectares of land for employment development for the period up to 2039. The Black Country Authorities set out that 210 hectares or 37% of employment land need arising in the Black Country cannot be met solely within the Black Country. The Authorities consider that this unmet need should be exported, as far as possible, to authorities that have a strong existing or potential functional economic relationship with the Black Country, for example in terms of migration patterns, commuting links and / or connectivity through physical infrastructure such as rail and motorway. This work is ongoing and will be secured through the Duty to Cooperate and evidenced through Statements of Common Ground. It is also important to consider how this shortfall will affect the local market demand and the Authorities should ensure that a shortfall in employment land does not detract future occupiers or cause existing occupiers to move elsewhere.

7.3 Where existing allocations for employment uses are relied upon within the Black Country Plan, the Authorities and WMCA should work together with developers to ensure the delivery of these Sites to ensure that all proposed delivery can be realised and as many jobs and opportunities can be brought to the Black Country as possible.

Object

Representation ID: 22386

Received: 08/10/2021

Respondent: Inland Waterways Association Lichfield

Policy EMP1 - Site WAE410 - Johnsons Farm and Meadow Farm, Watling Street, Brownhills

This site is an important area of countryside alongside the Anglesey Branch of the Wyrley & Essington Canal. It is part of the West Midlands Green Belt which serves to check the sprawl of built-up areas, to encourage the regeneration of urban land, and to safeguard the countryside. Its proposed removal from the Green Belt would undermine those purposes and damage the setting and economy of the canal. Therefore, IWA objects in principle to its allocation for development. However, if exceptional circumstances can be proven then it is important that the adverse impact of development on the canal is limited and mitigated by sensitive layout, design and landscaping.
The Anglesey Branch is a historic waterway and a valuable amenity and recreational corridor, providing leisure boating, walking, angling, cycling and nature conservation benefits to the area. It is part of the national waterway system which attracts millions of visits each year from local people and holidaymakers from home and abroad, and is a major component of the nation’s tourism industry.
The rural environment of the canals plays a vital role in attracting and sustaining the recreation and tourism use of the whole canal system, which contributes to the visitor economy and helps support local businesses. The income from boating activities provides a major part of the funding necessary for the Canal & River Trust to maintain the canals for public use and enjoyment.
Although much of the canal network in the Black Country is urban or suburban in character, the northern parts of the system in Walsall in particular include several attractive countryside sections. Because of their limited extent, these are of particular value to sustaining tourism as well as an important amenity for nearby residents.
However, major built developments in the countryside adjacent to the canal system destroy the rural setting that contributes to their heritage interest, wildlife, amenity value and recreational use. Visually intrusive built development alongside the canals damages their tourism potential and economic benefits.
The Anglesey Branch currently enjoys a pleasant open rural outlook across this site that enhances its attractiveness for recreational use. The canal towpath is open to the public and provides an accessible footpath. However, the attractive countryside setting of this section of the canal will be largely lost by this proposed allocation and its overall value to the local community and the visitor economy would be diminished if the development is visually intrusive. Industrial units are often large featureless sheds that are inherently more intrusive than housing developments.
It is therefore important that the visual impact of the development on the canal is limited by sensitive design, layout and landscaping of the site. This should provide a broad buffer zone alongside the canal with only limited built development forming a landscaped corridor to help preserve and enhance the canal environment.
This will be in line with the aspirations of Policy ENV7 – Canals, that development affecting the canal network should (1) “deliver a high quality environment”, (2e) “protect and enhance its visual amenity, key views and settings”, and (3d) “positively relate to the waterway by promoting high quality design, including providing active frontages onto the canal and by improving the public realm”.

Comment

Representation ID: 22402

Received: 11/10/2021

Respondent: RCA Regeneration Ltd

EMP1 and WAE333 – Employment Allocation
2.23. Walsall Borough has a significantly higher employment land allocation than the other BC
authorities, but it is not clear why this should be the case: [Policy pictured from BCP document]
2.24. We consider that there remains greater scope for Walsall Borough to lose some ‘old’ or
longstanding employment allocations which have not yet come forward in favour of more
housing – because the pressure on neighbouring the neighbouring Staffordshire authorities
should not just translate into them blindly accommodating unmet need from the BC if there are
sites which still have not been delivered for employment uses.

Support

Representation ID: 22484

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Employment needs and functional geography
The clarity that the Draft Plan provides in relation to Black County’s employment land requirement
is welcomed, with it noted that that the plan will seek to provide for a minimum of 565ha up to
2039 with this figure based upon the findings of the Black Country EDNA update (August 2021).
The Draft Plan confirms that following site assessment, the plan has been able to provide for 365ha
of this within the administrative boundaries of the Black Country. It is understood that this supply
is made up of allocations within the urban area, redevelopment of existing employment premises,
other site that have planning permission for employment developments and 48ha of employment
allocations within Walsall’s Green Belt.

It is recognised that this results in a shortfall of employment land, with paragraph 7.12 of the Draft
Plan confirming:
“210ha or 37% of employment land need arising in the Black Country cannot be met solely within
the Black Country. This unmet need should be exported, as far as possible, to authorities that have
a strong existing or potential functional economic relationship with the Black Country, for example
in terms of migration patterns, commuting links and / or connectivity through physical
infrastructure such as rail and motorway. This work is ongoing and will be secured through the Duty
to Co-operate and evidenced through Statements of Common Ground.”

Whilst we recognise that cooperation on unmet employment needs is ongoing, the above
statement is somewhat ambiguous as to what the Black Country authorities consider to be the
most appropriate functional geography for addressing unmet employment needs. The PPG
confirms that when addressing strategic matters under the Duty to Cooperate and confirming
these through Statements of Common Ground, the geographical area for doing this will depend on
the strategic matter being planned for and ‘the most appropriate functional geographical area to
gather evidence and develop policies to address these matters, based on demonstrable cross-
boundary relationships’. It is therefore critical that clarity is provided on what you consider the
functional geography for addressing your unmet employment needs is, in order to enable swift
progress with Statements of Common Ground following our respective Regulation 18
consultations.

We recognise that South Staffordshire has a strong functional economic relationship with part of
the Black Country, specifically Dudley, Walsall and Wolverhampton, but it is unclear from the
statement above what other authorities the Black Country consider fall within the functional
geography. The Black Country EDNA (2017) recognises South Staffordshire and Birmingham as
areas ‘areas of strong economic transactions with the Black Country’ and Cannock Chase, Lichfield,
Tamworth, Wyre Forrest, Bromsgrove and Solihull as ‘areas of moderate economic transactions
with the Black Country’ so it seems appropriate given the scale of the shortfall that solutions are
sought across the wider geography. It is also noted that Shropshire are proposing a contribution of
30ha of employment land towards Black Country employment needs and their evidence relating to
the M54 growth corridor does appear to imply there are functional links between the Black
Country and parts of east Shropshire, so including Shropshire within the functional geography is
also considered appropriate.

It is also noted that the Black Country EDNA update (August 2021) concludes that the plan should
seek to provide for around 30% B8 activity and 70% E(g)(ii)/(iii)/B2. It is unclear from the Draft Plan
if the proposed employment allocations are along these lines and therefore whether the plan is
seeking to deliver new employment along this split. Subject to a review of the South Staffordshire
EDNA, it is expected that we will have a significant oversupply of B8 land (as a result of the WMI
consent) and therefore your policy intentions for this issue may affect the contribution we can
make towards your unmet employment needs. Confirmation of this is sought, and if the aim is to
achieve this split, then details of the shortfall for B8 and E(g)(ii)/(iii)/B2 should be separately


provided to inform Duty to Cooperate discussions, as well as confirmation of whether the most
appropriate functional geographies differ between B8 and E(g)(ii)/(iii)/B2 needs.
In summary, we seek confirmation on the following:

1. Which authorities does the Black Country consider fall within the most appropriate
functional geography for addressing your unmet employment needs?
2. Is it the Black Country’s intention that the plan seeks to provide for 30% logistics (B8) needs
and 70% commercial (E(g)(ii)/(iii)/B2)? If yes, then please could you provide a breakdown of
what your shortfall is by use class.
3. If the Black Country are looking to provide for a split between B8 and (E(g)(ii)/(iii)/B2) uses,
can it confirm what the functional geography is for each use (if different).

Comment

Representation ID: 22521

Received: 11/10/2021

Respondent: Clowes Developments

Agent: Harris Lamb

Employment Land Issues

The Representor considers that the Black Country economy is an important element of the overall West Midlands’ economy and, as such, needs to be strongly supported in terms of the Plan’s policy objectives and the allocation of land to meet the future economic needs of the Plan. In this context, the Representor strongly supports the desire to allocate further land to meet the Black Country’s needs and provide support for the principle of Policy EMP1. The draft Plan acknowledges that the employment needs of the Black Country are such that not all of this need can be accommodated within the Plan area. Paragraph 7.10 explains that the allocations in the Plan will meet only 63% of forecast needs arising within the Black Country. It is explained in paragraph 7.12 that a further 37% of employment land will, therefore, not be met within the Black Country and that this will need to be accommodated in adjoining authorities which have a strong existing economic relationship with the Black Country.

The Representor welcomes the acknowledgement that not all of the Plan’s needs can be met in the Black Country authorities administrative areas and that land will have to be released elsewhere to meet the overall economic needs of the Plan area. The Representor also welcomes the identification of South Staffordshire as having a strong economic link with the Black Country.

However, the Representor is concerned that the extent of the overspill requirement has been underestimated. Policy EMP1 explains that of the total of 355 hectares of employment land which is to be delivered in the Plan period, some 74 hectares (a minimum figure) will be brought forward on other sites throughout the Black Country, mainly through the redevelopment, intensification and enhancement of existing employment areas and premises. It is clear, therefore, that a significant proportion of the land to be brought forward is in fact redevelopment of the existing stock and does not represent net additions which will meet the increased needs identified for the Plan area. Therefore, the Representor objects to Policy EMP1 and considers that the actual figure identified in sub-para 1 of 355 hectares should be reduced to 281 hectares. This would mean that the extent of the overspill identified at paragraph 2.10 should be increased by 74 hectares to 284 hectares (it is also noted that the figures identified in 7.10 do not appear to tally with those in Policy EMP1, sub-para 1 and this error should be rectified).

The Representor has submitted details of land at Wall Heath, which is well placed to accommodate the overspill needs for employment land for the Black Country.

The Representor is also extremely concerned that the supply figure identified to meet the Black Country’s needs should place no reliance upon the strategic logistic site at Four Ashes. That site serves a regional/national need and is not suitable for many of the businesses seeking premises within the Black Country or on sites immediately adjoining it.

Comment

Representation ID: 22630

Received: 11/10/2021

Respondent: National Highways

Meeting the Employment Need
The plan brings forward 281ha of employment site development at a number of locations
where their impacts upon the SRN are in proximity to junctions and corridors which are
currently at or exceeding capacity.
An additional aspiration of 71ha of employment land is committed to within the BLP, which
will be brought forward on other sites throughout the Black Country, mainly through the
redevelopment, intensification and enhancement of existing employment areas and
premises. Furthermore, a further 210ha of employment land is to be delivered by
neighbouring authorities. Similar to the shortfall in housing provision, the reallocation or
intensification of employment land and its distribution around the west midlands will be
crucial in the forecasting and assessment of transport impacts on the SRN.
However, based on our review National Highways are unable to conclude if this quantum
of employment land is acceptable. We therefore request the provision of the transport
evidence base, strategic transport assessment and any supporting modelling to be
provided. This will enable us to undertake a full and robust assessment of the proposals
and understand the impact on the safe and efficient operation of the SRN.

Comment

Representation ID: 23149

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

A glaring omission to our mind in this section of the plan is the lack of recognition of the visitor economy and the accomodation and hospitality sectors – which are strongly associated with heritage clusters and strategic centres. We feel that these important and growing areas of the economy should at least be cross referenced to the policies in other sections which indicate the strategic importance of these sectors of the economy and their strategic sites and centres. It would be preferable though to explicitly cite these within the EMP3 bullet points for local employment areas.

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.

Object

Representation ID: 23571

Received: 11/10/2021

Respondent: Save the Seven Cornfields Campaign Group

Agent: Save the Seven Cornfields Campaign Group

It is quite strange that the Black Country Local Plan has not given proper Spatial Land Use Planning Consideration for Employment or Economic Development. It is unfortunate and untimely that the Black Country Employment Area Review Or BEAR will not be available until August.

It has premised growth through Housing but not materially considered alternative perspectives.

For instance, it would not be out of the question to adopt a thriving no growth strategy which is about making Black Country capable of standing alone in a sustainable local economic development model. Such a strategy being more akin to current vectors of change and not positioned on continuous sustained consumption.

It might also have been a strategic decision to promote micro-enterprises and venture capital investment which fostered business that were not dependent on travel to and from the major business hubs. After all the networked world has demonstrated the potential for different kinds of business and, during Covid shut down, the attractiveness of working from home.

This refreshed option builds upon the strength of adding a more current and real employment perspective which seeks to broaden the economic base. This needs to be interdependent, agile, far-sighted, current and inclusive rather than orthodox, rigid, myopic and exclusive.

The fallacy of linear projection of employment applies in the current Local Plan and its preparation, this is where agencies such as the Council act as institutions of continuity as they show themselves loathe to innovate, preferring incremental change of a known order rather than violent transformations in line with emerging trends.

The Black Country plan demonstrates the popularity and longevity of the dominant paradigm regarding unchecked growth which may not prove sustainable.

Local Planning was meant to take on sociological, technological and economical change

The whole point of a Local Plan for the Black Country is to provide an integrated and comprehensive series of policies which draws together the inter-related aspects of a complex world. For instance, to consider Homelessness (which is not given proper consideration) is to treat a problem of inequality which is multifaceted and not just a matter of buildings and availability. Local Plans are meant to go beyond simple Land Use Planning considerations.

Likewise, providing the right dwellings at the right time is not about providing, for instance, building 4 bedroom luxury homes at points unconnected to future growth points, technological assets and demands created by changing sociological characteristics.

Much of the Black Country Local Plan appears a ‘gold rush’ to release the national treasure of the Green Belt and important greenfield sites without a comprehensive consideration of inter-related aspects that determine quality of life, real life chances and opportunities for all.

Planning, simply is about making decisions and taking actions, now or in the very near future, to make sure total future benefits are maximised and / or the overall direct and indirect costs are reduced.

When applied to Land Use, it seeks to consider the allocation, benefits and costs of Town Planning Classes of Use to meet interdependent activities required by individuals, groups, communities and populations within a Local Authority Area or, as in this case, four Local Authorities.

Many of options and considerations within the Black Country Local Plan do not attempt to draw together the interconnected aspects of service provision with the broadest possible set of features arising from the 4 Council’s corporate organisational policies. To do this would be to ensure the best of all futures and quality of life for its stakeholders.

The Plan simply considers Land for Housing but does not consider how to ensure its service or those of the sub-region and neighbouring areas can be better focused with Land Use Planning to enrich the area. For example, Widening Participation and Life Long Learning can be perspectives that bring education, training and learning relationships with economic development and local planning for the benefit of an area.

Local Planning should extend corporate planning, amenities and wrap round services around major new residential build. Briefly, but relevant here is an understanding of Local Plans which depends to some extent on its genesis. It arose out of the knowledge that Land Use Planning was linked to sociological, economic and technological change. There was a clear link between Economic Development and Planning. These grew out of a disaffected population pressure to ensure that the public ought to participate in the process - as there was disenchantment with planning generally. Development control had been a success when it avoided development in the wrong places and when better results were achieved than would otherwise be the case. There was in many cases a lack of correspondence between the Development Control and Development Planning.

Object

Representation ID: 44777

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Housing supply and shortfall

6. The Draft BCP intends to make provision for only 47,837 homes over the plan period, equivalent to 2,517 dwellings per annum, leaving a shortfall of circa 28,239 homes to 2039 with an assumption – but no guarantee – that this will be met in neighbouring areas. The proposed level of annual provision has been exceeded in each of the last six years, when roughly a third more homes have been delivered. The Black Country has seen tangible benefits as a result, more effectively attracting and retaining people than has been the case historically and once again growing its working age population.

7. Rather than planning positively for a similar “boosting” that would very nearly meet the minimum need for housing suggested by the standard method, the Draft BCP instead threatens to reduce the recent rate of delivery by 12%. Demographic modelling suggests that this would dramatically slow the recent rate of population growth and effectively force around 5,500 residents to move elsewhere every year, over three times more than in recent years.

8. The associated reduction in the size of the working age population, combined with potential behavioural changes, would be expected to leave a labour force capable of supporting only 615 new jobs every year, whereas at least one economic forecast suggests that the Black Country has the potential to create over three times as many jobs (c.2,100 per annum) and indeed the LEP has previously expressed a target that appears to be over ten times greater, at in excess of 6,000 jobs per annum.

9. This demographic modelling could even be reasonably described as optimistic as it assumes that the proposed requirement can be met through the supply identified in the Draft BCP, which may not be the case based on the analysis in this report. The National Planning Policy Framework (NPPF) requires Local Plans to be aspirational but deliverable, identifying a sufficient supply of sites taking into account their availability, suitability and likely economic viability. Those sites should meet the tests of deliverable and developable contained in the NPPF glossary. This report assesses the Councils’ claimed supply against the NPPF guidance and concludes that 9,571 homes are unlikely to be deliverable/developable during the plan period. This has a significant impact because it would result in the shortfall increasing to 37,810 homes, circa 50% of the minimum need for housing.

10. Given the large gap between supply and need, compounded by previously over optimistic assumptions on what can be delivered, the Councils’ sources must be scrutinised further as the BCP advances, and the implications of the possible additional housing supply shortfalls considered closely.

11. This report follows on from Turley’s ‘Falling Short – Taking stock of unmet needs across the Greater Birmingham and Black Country Housing Market Area’ published in August 2021. That report identifies a housing shortfall across the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) of between circa 18,700 and 42,000 dwellings up to 2031, and between 68,700 and 78,000 homes up to 2040. This includes the Black Country shortfall as currently reported in the Draft BCP. Any reduction to the Councils’ proposed supply would only exacerbate and worsen the wider GBBCHMA shortfall up to 2031 and 2040.

Comment

Representation ID: 44906

Received: 10/10/2021

Respondent: Cannock Chase Council

Paragraph 7.12 It is noted that the document states that unmet need should be
exported. Cannock Chase Council do not have sufficient land to meet their own
needs without removing land from the Green Belt. We welcome discussions
regarding this.

Comment

Representation ID: 46186

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

EMP1 should acknowledge that the housing policies of the Black Country Plan include existing/former employment sites/areas that are allocated for and transitioning to residential use. Some of these existing/former employment sites/areas being brought forward for housing will be alongside other employment areas being retained in employment use. EMP1 should set out that any proposals for the regeneration or renewal of existing employment areas will be considered in context of the potential impact on neighbouring land uses, both existing and proposed.