Representations to Submitted Site Allocations Document (SAD) Publication Plan of South Staffordshire Council As Part of Its Local Plan
Total Page:16
File Type:pdf, Size:1020Kb
Representations to submitted Site Allocations Document (SAD) Publication Plan of South Staffordshire Council as part of its Local Plan Client: Peveril Securities Site: Land at Hilton Cross, Strategic Employment Site Date: February 2017 Ref: HG2716 Rowe House, 10 East Parade, Harrogate HG1 5LT Tel: +44 (0)1423 857 510 Email: [email protected] Website: www.wyg.com WYG Planning Limited. Registered in England & Wales Number: 5241035 Registered Office: Arndale Court, Otley Road, Headingley, Leeds, LS6 2UJ Representations Contents 1.0 Introduction ......................................................................................................................... 2 2.0 Background to employment land issues in South Staffordshire ................................................. 4 3.0 Conclusions ........................................................................................................................ 10 Appendices Appendix 1: Knight Frank report Appendix 2: Plan showing proposed modest extension(s) to Hilton Cross and safeguarded land Report date: February 2017 Reference: HG2716 www.wyg.com 1 creative minds safe hands Representations 1.0 Introduction 1.1 Peveril Securities is pleased to note the progress that South Staffordshire Council is making with its Local Plan process and welcome the opportunity to comment on particularly the employment land proposals within the Publication Site Allocations Draft Document (SAD). 1.2 As the Council is aware, Peveril Securities is an experienced developer of employment land and has delivered a successful development at Wolverhampton Business Park on the northern side of Wolverhampton and on the boundary of South Staffordshire. Peveril has also in conjunction with St Francis Group submitted a supporting representation to the Council in relation to the proposed allocation of an enlarged employment development at the Royal Ordnance Factory site (ROF) although has concerns to ensure the SAD proactively deals with the need for a new link road. 1.3 Whilst Peveril considers that the proposals for an extension to the ROF site are to be welcomed, it is concerned that the Council is not encouraging a similar extension to one of the other four strategic employment sites identified in the Core Strategy – land at Hilton Cross. 1.4 The purpose of these representations is to suggest to the Council that it would be in accordance with the Core Strategy and – when a reasonable view is taken of future employment land requirements (not necessarily those given in the Employment Land Study in the evidence base for the Plan) – that an extension to Hilton Cross for development within the Plan period would be in accordance with intentions for provision of quality employment land in the area. As for the potential size and location of the extension it is considered that the principles which the Council has applied to ROF where a modest extension has been regarded as up to 50% of the identified ROF site (including land permitted as landscaping as part of the employment scheme) could come forward. In the case of ROF this area is 24 hectares (including landscaping) so an additional 12 hectares is put forward with a further allowance on top of that for strategic landscaping. 1.5 In the case of Hilton Cross the area granted planning permission for employment and landscaping in association with the scheme (granted separately) is 21.5 hectares. Therefore Peveril is suggesting that the Hilton Cross extension should be in the same ‘modest’ terms as the ROF up to 10.75 hectares with additional landscaping – as a consequence of this allocation a redefinition is required of the Green Belt boundary. 1.6 Without prejudice to 1.5 above, Peveril also considers that the Council should, as a matter of principle, identify safeguarded land for employment purposes, ie land currently in the Green Belt that should be capable of being removed from it should the Council not accept the need Report date: February 2017 Reference: HG2716 www.wyg.com 2 creative minds safe hands Representations for immediate release of additional employment land adjacent to the four strategic sites in the current Plan period. The Council is applying the principle of safeguarded land in its policies related to housing and there is no reason not to extend that principle to employment land (in accordance with Core Strategy Policy GB2). This is in accordance with the NPPF. 1.7 These representations set out: The background to the employment land calculations. The merits of extending the Hilton Cross existing site as part of the SAD and redefinition of the Green Belt boundary. If that is not accepted, the need to have a policy that identifies safeguarded land that could ultimately result in an extension to Hilton Cross, assuming a ‘robust case’ can be made for a further release of safeguarded land for development. 1.8 These representations should be read alongside a report on the current quality of employment land in South Staffordshire and in relation to the Black Country prepared by Knight Frank (Appendix 1). Knight Frank’s conclusions are a key part of the reasons why Peveril considers that the Hilton Cross site should be extended now in the context of the SAD. There is a lack of high quality sites to serve future employment needs and the location of Hilton Cross and its ability to provide mainly B1 uses. The site is close to a motorway junction and can provide a stand-alone development that would respond to needs arising in the Black Country. This can be distinguished from the ROF site which is more of a B2/B8 site albeit with an element of potential B1. 1.9 Therefore, the changes to the SAD which are requested by Peveril in connection with the Hilton Cross site are: 1. Specific identification of land that could provide a ‘modest’ extension to the Hilton Cross site within the Plan period – two potential options are identified. 2. The identification of ‘safeguarded land’ that could be released from the Green Belt should needs arise. 3. If no specific allocation is made in 1. above then a larger area of safeguarded land allocated. 1.10 In essence Peveril considers that a robust case already exists for the release of land at Hilton Cross in accordance with the Core Strategy and the Council should therefore allocate an extension to the Hilton Cross site. Report date: February 2017 Reference: HG2716 www.wyg.com 3 creative minds safe hands Representations 2.0 Background to employment land issues in South Staffordshire 2.1 Peveril does not intend in these representations to re-visit an analysis of employment land provision and the history of the relevant policy in South Staffordshire as these will be known to officers. The views set out relate to the four tests for soundness of the SAD in paragraph 182 of the NPPF, ie that the Plan should be positively prepared, justified, effective and consistent with national policy. However, the key elements are as follows. The Core Strategy 2.2 The approved Core Strategy identifies the Hilton Cross site as one of the four strategic sites that are considered to be important in providing for employment needs for quality land in the Core Strategy Plan period. The Core Strategy was adopted in December 2012 and covers the period up to 2028. It was recognised that due to the location and importance of the four free-standing strategic sites, that the possibility existed that they could be extended in area. Core Strategy Policy 7 states that: “Proposals for modest extensions to the four free-standing strategic employment sites in South Staffordshire to accommodate justified development needs will be supported where robust evidence and a reasoned justification is provided to support their expansion”. 2.3 The term ‘modest extension’ has been interpreted by the Council in the context of the proposed extension of the ROF site to constitute up to 50% of the existing allocated area including its associated landscaping – which in the case of ROF means a further allocation of 12 hectares over and above the 24 hectare site. In addition further landscaping is proposed. 2.4 The ‘robust case’ which the Core Strategy policy requires has, it would appear in the case of ROF, comprised firstly the findings of the Employment Land Study (see below); Part I of which was received by the Council in February 2013 and Part 2 in April 2015 – this however assessed employment needs up to 2026 rather than 2028. Secondly it includes viability considerations and the need for a new access road. 2.5 The fact that the Council is relying on the Employment Land Study that has an end date of 2026 is a cause of concern that the Local Plan is not based on sound evidence relating particularly to the latter part of the Plan period. In this regard the Council has not positively prepared the Plan in this respect nor had it justified why additional allocations for quality employment land are not required to cover the last two years of the Plan period. The Report date: February 2017 Reference: HG2716 www.wyg.com 4 creative minds safe hands Representations combination of these concerns suggests there is an overall under-provision of quality employment land (particularly for B1 purposes). Peveril agrees the Council is making the right decision to extend the ROF site but this will cover mainly B2 and B8 needs. 2.6 The Council may say in the context of the Core Strategy that it remains possible up to 2028 for an application to be made on the Hilton Cross site for a ‘modest extension’, where a robust case is put together. However, that approach in Peveril’s view does not amount to this Plan being positively prepared and justified in accordance with paragraph 182 of the NPPF. Given the Plan extends to 2028 it will need to be reviewed quite quickly (say in four or five years time) after its adoption.