Draft Black Country Plan

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.

Object

Representation ID: 21434

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

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

Representation ID: 21435

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

Policy CSP1 (Development Strategy) states that the BCP will seek to deliver at least 47,837 dwellings between 2020 – 2039. However, paragraph 3.21 of the BCP states that there is actually an overall need for 76,076 homes over that period. This will leave a shortfall of circa 28,239 homes that will need to be accommodated by the Housing Market Area (‘HMA’) under the Duty to Cooperate (DtC). We understand that although some HMA authorities have suggested various contributions to meet this need, these contributions are still not enough to meet the identified shortfall therefore additional land will be required to meet housing and employment needs within the Black Country.
We therefore object to draft Policy CSP1 and the evidence base on which it relies upon.

Object

Representation ID: 21436

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

Draft Policy HOU1 (Delivering Sustainable Housing Growth) states that sufficient land will be provided to deliver at least 47,837 dwellings (2020-2039) with the majority of the requirement to be met through sites with existing planning permission and sites allocated for housing. Below we set out our concerns regarding sites identified in the UCS which not only brings into question the reliance that should be placed on the UCS and proposed housing sites identified, but also the identified shortfall of circa 28,239 homes which we consider to be even greater.
We therefore object to draft policy HOU1 and the evidence base used to support it.

Based on the information we have gathered, a list of sites which are deemed to be undeliverable within the plan period has been compiled. Along with Savills Development colleagues (who are active in the Black Country residential land market), we have extended our review of the sites proposed in the UCR to include a view on potential development and viability issues.
From our review of the sites set out in the UCR it is estimated that around 5,000 dwellings are likely to be undeliverable for a variety of planning and deliverability. This figure could be higher should any of the existing employment sites identified for housing not come forward.
We consider that not all sites included within the draft Black Country Plan are deliverable and this juxtaposed with the housing shortfall in the Black Country clearly means that additional sites will be required to meet the Black Country’s housing need. In that regard, we consider that the housing “offers” currently proposed fall significantly short of what is needed to deliver an effective and sound strategy for meeting the Black County (and wider HMA) housing shortfall which is clearly evidenced and significantly worse than is being presented.

Object

Representation ID: 21438

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

At present the BCP provides no certainty of how the full extent of the 210ha of unmet employment land need will be provided for. As set out above that requirement for cross boundary provision is more accurately 339ha+. The NPPF and PPG requires the plan to identify and allocate the land to meet all of the objectively assessed need, and where that cannot be achieved within the plan area the duty to co-operate requires the balance of that need to be identified and allocated in the development plans of other LPA.
The BCP currently fails in these respects. It is not sufficient to state as 3.24 does, that the Statement of Consultation sets out the current position which will be elaborated on at the submission stage. That approach does not meet the requirements of the duty to cooperate, which are to produce a single statement of common ground together with all those LPA which will contribute to satisfying the unmet need. That statement of common ground should set out the governance and process for agreeing the distribution of satisfying the unmet need amongst those authorities. It should also identify the capacity of the areas of the LPAs party to the statement of common ground, and the details of agreement and disagreement about how the unmet needs can be met across the combined area. At present there is no statement of common ground within the evidence base.
A substantial amount of land remains to be identified to meet identified needs in order for the duty to cooperate to be satisfied. It is imperative that BCA secures sufficient land through cross boundary provision, to meet the unmet needs in both quantitative and qualitative terms. That needs to be achieved without reliance upon reviews of other local plans.
The published evidence of duty to co-operate correspondence with other LPA indicates that the strongest potential source in quantitative and qualitative terms that meets the employment land needs of the BCP is Shropshire. The evidence of the last meeting / dialogue with Shropshire being in April 2020, and with outstanding objections from ABCA, Walsall and Dudley in early 2021 stating that the Submission Shropshire Plan is not sound, indicates that the engagement between BCA and Shropshire is not as constructive, active and ongoing as it is required to be. Notwithstanding the submission of the Shropshire Plan, we urge BCA to actively engage with Shropshire in the interests of securing appropriate land quantitatively and qualitatively to enable the BCP to be found sound.

Object

Representation ID: 21439

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

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.