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Mr Grant Mitchell Planning and Strategic Services South Staffordshire Council Council Offices Road Codsall South Staffordshire WV8 1PX

27 February 2017

Dear Mr Mitchell,

South Staffordshire Local Plan Site Allocations Document (SAD) ‘Publication Plan’ Consultation January 2017

GL Hearn acts on behalf of Severn Trent Water (STW) in relation to their land interests within South Staffordshire north of and adjacent to the existing i54 South Staffordshire employment site and is instructed to make representations to the current consultation stage of South Staffordshire Local Plan Site Allocations Document (hereafter SAD). STW’s landholding, which is no longer required for operational use, is identified on the attached Location plan and is proposed for future allocation as employment land within the South Staffordshire SAD.

Land west of i54

South Staffordshire Council (SSC) will be aware that STW controls the land to the west of the existing i54 employment site that forms the northern part of the proposed extension to this strategic employment site (ref. ‘Land west of i54’) under emerging policy SAD5 ‘Employment Land Allocation’. STW strongly supports the proposed i54 extension identified within the SAD, which is considered to be a logical extension to the existing i54 site, and can confirm the availability of the land for development. These representations support earlier submissions made on Severn Trent’s behalf, which have consistently expressed support for the proposed allocation. Further to our meeting in May 2016, STW will seek to work collaboratively with SSC and Wolverhampton City Council (WCC) to successfully deliver the proposed extension to i54. There is nothing however that should prevent the allocation coming forward in phases, relative to land ownership.

Land to the north of i54

The land to the north of the i54 site, on the northern side of the M54, would form the next logical extension to the i54 site, being readily accessible and complementing long-term growth ambitions focussing on the motorway junction.

These representations are submitted having regard to objectives set out within:

i) The Strategic Economic Plans of the Local Enterprise Partnerships and their growth ambitions for the region; ii) The National Planning Policy Framework/National Planning Policy Guidance; and iii) The local planning policy context relating to employment land within the District.

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The National Planning Policy Framework - Building a strong, competitive economy

With respect to economic development, the NPPF is unequivocal; planning should proactively drive and support sustainable economic development to deliver the business and industrial units, infrastructure and thriving local places that the country needs (paragraph 17). The NPPF sets out that “significant weight should be placed on the need to support economic growth through the planning system” (paragraph 19) and is clear that LPAs should “should plan proactively to meet the development needs of business and support an economy fit for the 21st century” (paragraph 20).

Paragraph 21 of the NPPF further states that LPAs should:

 set criteria, or identify strategy sites, for local and inward investment to match the strategy and to meet anticipated needs over the plan period;  support existing business sectors, taking account of whether they are expanding or contracting and, where possible, identify and plan for new or emerging sectors likely to locate in their area. Policies should be flexible enough to accommodate needs not anticipated in the plan and to allow a rapid response to changes in economic circumstances;  plan positively for the location, promotion and expansion of clusters or networks of knowledge driven, creative or high technology industries” (paragraph 21).

The NPPF makes clear that Local Plans should allocate sites to promote development and flexible use of land, bringing forward new land which is necessary to deliver against growth ambitions. Paragraph 161 further states that local planning authorities should use their evidence base to assess the needs for land or floorspace for economic development and the existing and future supply of land available for economic development and its sufficiency and suitability to meet the identified needs.

Section 33A of the Planning and Compulsory Purchase Act 2004 sets out obligations placed upon local authorities under the ‘duty to co-operate’, which requires Councils to engage constructively, actively and on an on-going basis with other local authorities in relation to strategic matters when preparing their local plans. This will include considerations relating notably to the supply of employment land and housing in line with meeting joint ambitions relating to economic growth.

The NPPF also provides policy guidance regarding the need to plan strategically across local boundaries (strategic policies include those seeking to deliver the jobs needed in an area). With specific regard to business, the NPPF states:

“Local planning authorities should have a clear understanding of business needs within the economic markets operating in and across their area. To achieve this, they should:

 work together with county and neighbouring authorities and with Local Enterprise Partnerships to prepare and maintain a robust evidence base to understand both existing business needs and likely changes in the market; and  work closely with the business community to understand their changing needs and identify and address barriers to investment, including a lack of housing, infrastructure or viability” (paragraph 160).

There is a clear, proactive message running through national policy and guidance, which seeks to ensure that economic development needs are actively planned for and met through Local Plans.

The Midlands Engine for Growth

An ambitious masterplan for the Midlands region is contained within the 'The Midlands Engine for Growth' prospectus (December 2015). The 11 local enterprise partnerships (LEPs) covering the region, including the Stoke-on-Trent and Staffordshire Local Enterprise Partnership were instrumental in devising the strategy,

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which makes clear the central objective of developing and driving a strong manufacturing base across the region, emphasising the importance of globally significant companies such as Jaguar . The Midlands Engine for Growth Group aims to develop a pitch book of investible sites across the Midlands Region working with the UK Trade and Investment Regeneration Investment Organisation.

The Stoke-on-Trent and Staffordshire Enterprise Partnership’s Strategic Economic Plan (SEP) (which includes the i54 site) and the LEP’s Strategic Economic Plan (SEP) (which includes the Black Country Enterprise Zone, of which i54 also forms part) reflect this strategy and set out ambitious plans for economic growth.

The Vision underpinning the Black Country SEP states that by 2033 the Black Country will:

 Become globally competitive with a significant number of leading manufacturing companies;  Maximise the benefit of its locations at the centre of the transport network, ensuring modern, convenient and reliable connectivity both within the Black Country and connecting to key areas of economic growth”;  Increase the number of jobs by 113,060;  Deliver an additional 937ha of employment land from a baseline of 634ha; and  Increase the business birth rate by 1,453 from 3,400 new business starts.

To achieve these aims there should be 50% uplift in the supply of employment land and 100% growth in new business start-ups across the area. The SEP identifies the Aerospace industries; automotive industries and Building Technologies sector as key markets to expand.

Specific reference is made to the i54 site:

“The Black Country Enterprise Zone covers 120 hectares of land across two prime locations: i54 Wolverhampton North and in Walsall. Together these sites offer some of the most desirable and competitive locations for business within the Black Country, at the heart of the manufacturing and distribution networks. We have invested approximately £60m in transport schemes at J2 of the M53 and Darlaston to enable and support this growth. The Zone is already acting as a catalyst for growth for the national and local economy. The decision by (JLR) to invest £0.5bn in its new UK engine centre of excellence is a landmark moment and its impact is potentially transformational. Also significant is Moog’s decision to invest £15m in new facilities, creating 400 jobs” (Black Country SEP, page 26).

The Stoke-on-Trent and Staffordshire SEP is equally as ambitious, seeking to become:

“an economic powerhouse driven by the transformation of Stoke-on-Trent into a truly competitive and inspiring Core City …. by accelerated growth in our Country Corridors and urban centres”. The SEP will seek to drive the “development of the peri-urban areas along the County’s key transport corridors that provide a strong, agile and competitive offer locally and nationally”.

The SEP’s stated aim is to grow the economy by 50% and generate 50,000 new jobs in the next 10 years, with the i54 site identified within the SEP as a ‘Priority Strategic Employment Site’. The LEP seeks to focus growth around key opportunities relating to specific advanced manufacturing sectors highlighting the importance of both the aeronautical and automotive industries within the region:

“The Midlands and North West of England are home to large concentrations of transport technology firms. The high concentration of employment within the aeronautical and automotive technology sector in the Midlands is linked to the presence of major manufacturers in the area, particularly Jaguar Land Rover, Toyota and their extensive supply chains.

The development of a number of aerospace companies around the i54 area also presents considerable opportunities for the development of advanced-technology manufacturing industries” (paragraphs 2.10 and 2.11, page 9).

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i54 South Staffordshire

The sub-regional Employment Land Study 2014 concluded that the national significance and market attractiveness of i54 South Staffordshire marked the site out as a priority investment location able to meet a significant proportion of the Black Country shortfall of High Quality Employment land between 2014 and 2026.

“The opportunity and the effect of Jaguar Land Rover’s engine plant i54 cannot be underestimated for the Black Country Region. There is some spin off from this plant with requirements from companies either working directly or indirectly in the supply chain with Jaguar Land Rover and they are looking to secure sites or a new facility in the Black Country which meet their criteria” (page 13, 2014 Employment Land Study).

“Clearly, the furtherance of i54 as a nationally significant employment site is a clear priority for South Staffordshire Council, Staffordshire County Council and Wolverhampton City Council. (GLH emphasis). This is reflected in both the Black Country and South Staffordshire Core Strategies and the Black Country SEP, which identify high value manufacturing as a key sector for growth. Furthermore, the site’s national recognition as a centre for advanced manufacturing dictates that any extension would be very attractive to the market and could make a notable contribution to the Black Country’s HQ employment requirements. Within this context, to the west, for example, i54 would be suitable for HQ B1/B2 use - in keeping with the existing i54 Business Park” (page 15, Employment Land Study 2015).

Within the representations made by Jaguar Land Rover to the South Staffordshire Site Allocations document (JLR 26), it is made clear that to ensure long-term growth and pre-eminence in a highly competitive global marketplace Jaguar Land Rover would benefit significantly from the opportunity to expand and adapt to swiftly changing circumstances without impediment. This necessarily will involve the availability of land in the short, medium and long-term:

“…Whilst the car manufacturing industry is unpredictable, Jaguar Land Rover predict that manufacturing output will expand… As a business Jaguar Land Rover needs to ensure that it can adapt quickly to external forces such as technological advances and changes in customer demand. As a result, Jaguar Land Rover requires certainty in order to have confidence in its ability to invest, expand and broaden operations in the future as part of its long term plans which will be of benefit to the local, sub-regional and national economy, and to minimise planning risk’. Within this context, as the same note states, ‘Jaguar Land Rover welcomes the identification of land for future extension at i54 and considers that both Sites E7 and E8 represent a logical extension to the i54 Business Park. It is critical that i54 can expand in order that it can continue to fulfil its important role as a Strategic Employment site”.

The West Midland Strategic Employment Site Study 2015, commissioned in 2014 by Local Authority Chief Executives across the West Midlands, also supported the i54 South Staffordshire site as a regionally significant and attractive location for national and international economic development. The study highlighted that the area as a whole suffered from constraints in the supply of land, which necessarily will exert a negative influence on economic growth and employment prospects in the West Midlands in the manufacturing and distribution industries. Ensuring long-term sufficiency in the supply of current and future employment land would offer greater certainty to investors and would encourage firms already based in the region to grow, expand and diversify (page 58, Employment Site Study 2015).

The adopted South Staffordshire Core Strategy Development Plan Document (2012), the Site Allocations Document and the Employment Land Evidence Base

The Site Allocations Document (SAD) forms the second part of the South Staffordshire Local Plan. The first part of the Local Plan (the Core Strategy) sets the levels of development to be achieved over the plan period, and identifies broad locations for such development. The SAD draws from the Core Strategy and seeks to provide site specific proposals and policies for the use of land. With particular regard to employment and

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economic development, Core Policy 7 of the adopted Core Strategy states that the Council, working in partnership with businesses and local communities, will support measures to sustain and develop the local economy of South Staffordshire and encourage opportunities for inward investment and further economic development of the District. The policy further supports the development of creative and high tech industries at strategic employment sites in suitable locations within South Staffordshire.

With specific regard to the strategic employment sites within the District, including i54 Wobaston Road, Core Policy 7 expresses support for the delivery of these sites. The policy states:

“Proposals for modest extensions to the four freestanding strategic employment sites in South Staffordshire (i54, Hilton Cross, ROF Featherstone/Brinsford and Four Ashes) to accommodate justified development will be supported where robust evidence and a reasoned justification is provided to support the expansion” (GLH emphasis).

This qualified support for ‘modest extensions’ to the existing employment sites, including i54 South Staffordshire is carried forward into the SAD. As such, a number of employment sites, including 40 hectares to the west of the existing i54 site, are proposed as ‘modest extensions’ to the existing strategic sites as set out in draft Policy SAD6. The allocation of the land to the west of the existing i54 site for employment use is supported. However, the allocation within the SAD is considered too modest having regard to the ‘duty-to- cooperate’ and the wider economic aspirations of the Midlands. The proposed extension to the i54 site allocation considers immediate needs that are likely to be manifest in the short to medium term, but does not maximise to the full the long-term potential of this location, or its strategic potential. Preparation of the SAD offers an opportunity to secure the identification of this area as a long term, strategic inward investment location capable of responding positively to the employment land requirements of the Black Country and the wider Midlands region as a whole, provided that sufficient land is identified to meet long-term development needs.

The Core Strategy was adopted in December 2012. Whilst this post-dates the publication of the NPPF, the hearing sessions pre-dated the NPPF publication, as did, more importantly, the production and publication of the evidence base documents on which the Core Strategy relies. In considering the level of employment land planned for within the Core Strategy over the plan period, the Inspector observed:

“Some have argued for more land to be brought forward in the CS for employment uses. However, the evidence base, and the Employment Land Study 2009 in particular, could not be said to offer unequivocal, robust support for this position… Moreover, in the absence of any compelling evidence to the contrary, it seems to me that adding further land than that proposed to the employment portfolio would run the risk of undermining the rural renaissance of South Staffordshire and the urban renaissance of the Black Country MUA. The Employment Land Study reflects this general point, and indicates that a ‘cautious approach’, which I take to mean one which does not involve adding to the portfolio, would support the wider policy objective of regenerating the Black Country MUA. Overall, on the evidence produced, I am not persuaded that more employment land is needed to result in a sound plan.

Allowing the modest expansion of the existing four strategic sites will provide some flexibility in this regard. This approach, rather than one which identifies wholly new, unrelated land, has the advantage of providing opportunities for existing businesses to expand without relocating or operating from multiple locations. It is clear from Core Policy 7 that any enlargement of these employment sites will only be supported where there is clear justification for it based on robust evidence” (paragraphs 59 and 60 of the IR, October 2012).

The Inspector noted later in the report, however, that the Council had committed to a ‘refresh’ of the Employment Land Study and acknowledged the pledge to carry out a partial review of the Core Strategy if the updated Employment Land Study revealed a need for new employment sites in the District. He noted:

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“In such circumstances, I concur that a partial review should be undertaken. This commitment amounts to an appropriate safeguard in the event that new information unearths shortcomings in the present employment evidence base, adds to the plan’s flexibility and helps to seal the soundness of the CS in this respect” (paragraph 67 of the IR, October 2012).

As noted at paragraph 5.13 of the Publication SAD, a refresh of the South Staffordshire Employment Land Study was published in February 2013. It concludes that there was a slight oversupply of employment land within the District of 12.3ha. However, the 2012 Employment Land Study did conclude that in meeting employment needs, South Staffordshire has strong links with other parts of the sub region, in particular the Black Country. Recommendations in the 2012 Employment Land Study set out that the employment relationship between South Staffordshire and the Black Country should be explored further in the form of a more comprehensive cross-boundary employment study. As part of this, the study should consider whether it would be appropriate for employment need arising from the Black Country to be accommodated in or around any of the four freestanding Strategic Employment Sites in South Staffordshire.

Following this recommendation, the SSC, in partnership with Staffordshire County Council (SCC) and the Black Country authorities, commissioned a wider cross boundary employment study. The suite of Employment Land Studies to date since the adoption of the Core Strategy, including the sub-regional Employment Land Study 2015, have identified that there is a gap of 101ha of High Quality (HQ) employment land between 2014 – 2026. After taking account of potential HQ sites within the Black Country likely to come forward, the gap reduced to circa 81 – 87ha.

The Employment Land Study 2015 notes that some of the future demand for employment land in the Black Country is generated within Sandwell where there is little travel to work connectivity with South Staffordshire. Nonetheless, this amounts to, at most, 32ha of the overall minimum 81 hectare shortfall. The ELS 2015 acknowledges that the functional economic relationship between the Black Country and South Staffordshire is a complex one, but sets out that existing commuting patterns are strongest with Wolverhampton and Walsall (where approximately 46ha of the future identified 101ha demand for HQ employment land is generated).

While the publication SAD proposes 62ha of additional supply of employment land (including 40ha to the west of i54) this is significantly less land than is required to accord with the ‘Vision’ scenario within the Black Country LEP Strategic Economic Plan (SEP). Failure to align positively with growth ambitions set out within the SEP will inevitably frustrate the growth aspirations for the sub-region and does not embrace the NPPF advice to local planning authorities to proactively drive economic growth.

The level of employment land set out within the ELS 2015 should be considered as a minimum; and where feasible, in response to likely future demand, opportunities should be sought to increase the area of employment land available that is able to respond swiftly to growth demands.

As well as taking a relatively conservative approach to future employment land requirements, the Employment Land Study 2015 only addresses demand to 2026. The Core Strategy, and consequently the draft SAD also run only until 2028. Given that the SAD is due to be adopted in early 2018, the policy landscape will extend only for a period of up to 10 years. NPPF (paragraph 157) advises that Local Plans should be drawn up over an appropriate time scale, preferably a 15-year time horizon, to take account of longer term requirements, and should be kept up to date.

Given the following considerations:

i) The plan period for the SAD post adoption; ii) The horizons of the Stoke-on-Trent and Staffordshire SEP and the Black Country SEP, which extend to 2030 and 2033 respectively; and iii) The clear evidence and aspirations within the Employment Needs Assessments and SEPs respectively regarding future economic growth;

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GLH submit that, as a minimum, the SAD should be safeguarding land to accommodate anticipated economic growth over a plan period to 2033. To this end, there is explicit policy provision within Policy GB2 of the Core Strategy Development Plan Document (2012) to facilitate the safeguarding of land within the SAD for longer term needs.

“Additional safeguarded land will be identified in the Site Allocations DPD for housing and employment development for the period 2028 – 2038. This will be at Main and Local Service villages and at the four existing freestanding strategic employment sites at i54, Hilton Cross, ROF Featherstone/Brinsford and Four Ashes”.

Draft policy SAD3 ‘Safeguarding land for longer development needs’ seeks to release 86.8 hectares of Green Belt land and safeguard it beyond 2028. This policy doesn’t currently identify any additional land around i54 which may be required to meet future employment needs at the site.

Reviewing Green Belt boundaries

The land surrounding the i54 South Staffordshire site falls within the open Green Belt. The NPPF is clear that, when defining Green Belt boundaries, local planning authorities should:

 not include land which it is unnecessary to keep permanently open;  where necessary, identify in their plans areas of ‘safeguarded land’ between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period; and  satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period” (paragraph 85, NPPF) (GLH emphasis).

The Employment Sites Study 2015, highlights that to respond positively to market demand employment sites should be in accessible locations, close to cities and transport corridors; in practice this is likely to mean that the most suitable sites will be located within the Green Belt, where such development will be deemed inappropriate; only being acceptable if exceptional benefits can be evidenced.

The study acknowledges that it will be difficult for individual districts to make the case for development in the Green Belt because the benefits of such strategic schemes are often spread across large geographies. The ELS advocates ‘larger-than-local policies’ as a more effective way to bring forward these sites.

Given the established strategic importance of the i54 South Staffordshire site within the sub-region, it is considered that the Green Belt boundary surrounding the site to the north should have been fully reviewed in the Green Belt Review document dated November 2016 in the context of the likely need for expansion in the future to 2038, in accordance with the provisions of Policy GB2 of the adopted Core Strategy.

Furthermore, the wider expansion of this strategic site should be viewed in the context of the current plans to develop ROF Featherstone. We understand that the owners of this site are in detailed discussions with SSC regarding its redevelopment for employment use serviced via a proposed link road improving connectivity between ROF Featherstone and Wolverhampton. This nearby development will only serve to increase the overall viability and attractiveness of the area surrounding Junction 2 of the M54 as a focus for industry and economic growth.

Having regard to the NPPF, the provisions of the adopted Core Strategy and the overall clear indication from the Employment Land Studies, the Strategic Economic Plans and the plans of Jaguar Land Rover itself that the i54 South Staffordshire will continue to expand, it is considered that a timely review of the Green Belt to the north of i54 should be carried out as part of the plan-making process for the SAD. It is contended that the land should as a minimum be removed from the Green Belt and identified as safeguarded land to meet future development requirements beyond the current Plan period. However, given the ready means of direct access to the site, which assessment work indicates has sufficient capacity to accommodate up to 600,000sqft of B2/B8 development, the immediate availability of the land for development, and having regard to the aspirations set out within the relevant SEPs referred to above, the Council could consider positively

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allocating the land for employment development within the current Plan period to support inward investment associated with the i54 cluster.

Severn Trent Water

As noted above, STW controls land to the north of the M54 as identified on the attached Location plan. Part of the site is in operational use as the Coven Heath Sewage Treatment Works. However, the remaining land is available for development and could be accessed via the existing junction serving the i54 South Staffordshire site. As you will be aware, STW is a major landowner within the District, and over recent years, changing processes in respect of both clean water provision and treatment of waste water have led to significant areas of land being no longer required for operational purposes. Severn Trent has sought where possible to release these sites for alternative beneficial uses. Whilst resulting from a recent closure, the development of the i54 Major Employment site has taken place largely on the site of a former sewage treatment works, which is just one of many developments of former Severn Trent sites across their operational area. This process is now in place for the land to the west and north of the i54 South Staffordshire site.

The ELS 2015 sets out that in identifying land for employment use, any sites identified ideally should be in the ownership of public organisations. STW confirm that the former public utility land identified within the attached Location plan is suitable and available for development to complement and expand the existing i54 South Staffordshire site.

Conclusion

STW strongly supports the allocation of the additional land to the west of the existing i54 South Staffordshire site for employment purposes and will work collaboratively and proactively with SSC and WCC to deliver land to the west of i54.

However, mindful of the clear indications that employment and businesses within the i54 South Staffordshire site will likely look to expand significantly over the plan period, it is considered that the currently proposed ‘modest’ extension of the existing i54 South Staffordshire is insufficient to meet the land requirements of the sub-region having regard to the clear strategic economic importance of the site. In light of this STW consider that land to the north of i54 should be allocated for employment use under policies SAD5 and SAD6 or at the very least safeguarded for future expansion requirements beyond 2028 and removed from the Green Belt under policy SAD3. STW confirm the additional land to the north of the M54 identified within the attached Location plan is suitable and available for development to complement and expand the existing i54 South Staffordshire site, a site of regional and national economic importance.

We trust that these representations will be taken into full consideration in the preparation of the next stage of the SAD and would be grateful if you could ensure that we are on the mailing list to receive notifications of future updates and consultations.

Should you have any queries or wish to discuss then please do not hesitate to contact me.

Yours sincerely,

Emma Jones Planning Associate Director [email protected]

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Enc: Location plan

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