Draft Black Country Plan

Object

Representation ID: 21319

Received: 11/10/2021

Respondent: J Holt & Sons

Agent: Spawforths

The Vision is written in a positive way however, consistent with the provisions of the 2021 Framework (paragraph 22) we consider there is a need to update the Vision and Objectives to provide a longer term vision (up to 30 years) for the Black Country. This needs to reflect the scale of housing need, economic ambition, infrastructure improvements and investment opportunities. It should provide a longer term framework for meeting the needs of the Black Country, including the strategy for meeting those needs outside the Black Country Authorities boundaries. In this context it needs to fully explore opportunities outside of the Green Belt prior promoting Green Belt release which would fundamentally affect the permanence of Green Belt boundaries in the long term. This approach should be reflected on the Key Diagram.

Object

Representation ID: 21320

Received: 11/10/2021

Respondent: J Holt & Sons

Agent: Spawforths

The Plan’s explanatory text recognises that a significant proportion of the identified needs for both housing and employment will need to be met on sites which lie beyond the Black Country Authorities boundaries. It is considered that the Key Diagram should reflect this, and provide a spatial framework for meeting these identified needs within adjacent authorities, recognising those authorities and locations which have a strong functional relationship with the Black Country, and are located along key strategic routes. Of particular interest to J Holt & Sons, we consider that the spatial framework should identify the key importance of the linkage between the Black Country and areas of South Staffordshire located along the A449, and M6 to meet strategic employment needs.

Policy CSP1 should reflect Table 2 and Part 1 and hence should establish the full housing and employment land requirements. The Spatial Strategy contained within Part 2 should establish the strategy for meeting the needs which cannot be met within the Plan area, to provide certainty and ensure that the Plan is effective.

Policy CSP1 should therefore reflect the full employment land requirements, and be clear that based on the authority’s current evidence, at least 210 hectares of need is to be exported outside the Black Country boundaries to other adjacent authorities. This constitutes a substantial proportion of the identified requirement and therefore should be reflected within the strategic policy CSP1, which is intended to establish the Spatial Strategy to meet the objectively assessed needs.

Policy CSP1 Part two should also address the locational requirements of specific sectors including those of the storage and distribution sector, taking account of the specific locational characteristics of this sector.

The 2021 Framework also requires policies to set out a clear economic vision and strategy, and address barriers to investment. It is therefore imperative in order not to constrain the growth of the Black Country and indeed the wider region that the identified needs for both the Black Country and wider region, are met in full.

We do not consider that the scale of need (565 ha) identified within the explanatory text is based on robust and up to date evidence. We consider that as the need is based on past trends then it does not reflect the significant structural changes to the economy and the drivers for growth resultant from the rise in e-commerce and the need to build resilience in the supply chain.

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: 21323

Received: 11/10/2021

Respondent: J Holt & Sons

Agent: Spawforths

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.