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GL Hearn Letter Our ref: 27.02.17 J035136 Your ref: Mr Grant Mitchell Planning and Strategic Services South Staffordshire Council Council Offices Wolverhampton 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. X:\Bristol Planning\Job Files - Live\J035136 - Severn Trent Appraisals\Representations\i54\Publication_SAD_STW_Reps_270217_Final.docx Page 1 of 9 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, X:\Bristol Planning\Job Files - Live\J035136 - Severn Trent Appraisals\Representations\i54\Publication_SAD_STW_Reps_270217_Final.docx Page 2 of 9 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 Land Rover. 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 Black Country 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 Darlaston 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 West Midlands 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 Jaguar Land Rover (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
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