Representations to Submitted Site Allocations Document (SAD) Publication Plan of South Staffordshire Council As Part of Its Local Plan

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

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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

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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.

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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

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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. However, the NPPF policy on Green Belt (paragraph 85) includes a number of parameters for local authorities considering Green Belt boundaries (as the Council is in this SAD). One of these is to:

“Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the Plan period”.

2.7 Given the Core Strategy Policy for Hilton Cross which contemplates modest extension to it, paragraph 85 of the NPPF would logically require the Council in this Plan to identify – either through allocation or safeguarded land – where that extension should be so that the Green Belt is not altered at the end of the Plan period.

2.8 Peveril Securities considers in any event that the interpretation which is being placed on the conclusions of the Employment Land Study by the Council to be overly conservative in relation to the Hilton Cross site. The Study itself under-estimates the need for further quality sites to be brought forward – hence a specific allocation for employment, ie the modest extension to Hilton Cross can be made. More recent information in terms of likely increased population in the area (both the Black Country and Birmingham in particular) and the lack of good quality employment sites to serve medium term populations means that more quality land is needed so an additional specific allocation of an extension to Hilton Cross should take place.

The Employment Land Study

2.9 The Black Country authorities produced the sub-regional high quality Employment Land Study during 2014 and 2015 in order to review and assess its future need for quality employment sites up to 2026. Knight Frank (see attached report) assesses various aspects of the report. The Employment Land Study over-estimates the supply of what are termed ‘high quality’ employment sites. In certain cases the identified quality sites do not in themselves merit the term ‘quality’ for the reasons set out by Knight Frank. Even if one adopted the potential ‘requirement’ for high quality sites set out in the Employment Land Study the actual supply of

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quality sites which are identified seriously under-estimates the supply of true good quality land. The Hilton Cross site is indisputably a high quality site and can provide B1 development close to a motorway junction and close to the conurbation of Wolverhampton. The potential success and delivery of an extension to the Hilton Cross site is likely to mirror the success of the delivery of Peveril’s Wolverhampton Business Park site.

2.10 In this regard the Council’s position in the SAD in relation to Hilton Cross relies on the conclusions made in stages 1 and 2 of the Employment Land Study. The projected under- supply of 147 hectares of quality employment land in stage 1 of the study is a result of a somewhat random choice of likely demand for high quality land to 2026 and does not take account of what the study says in paragraph 6.8 that if greater supplies of high quality land are readily available then developers and the market are more likely to deliver it. Peveril therefore considers the 147 hectare requirement for high quality land to be an under-estimate. Even if the 147 hectare requirement is accepted the reduction of that requirement in section 2 of the stage 2 report is challenged with particular regard to the assumptions (see Knight Frank report) that 20 hectares can be taken off the 147 hectares because of the potential contribution to quality employment land at the former Showcase Cinema and Casino, Bentley Mill Way and the former Willenhall sewage works which for reasons given by Knight Frank will not achieve a high quality employment development.

2.11 The analysis set out in sections 3 and 4 of the stage 2 report therefore do not take account of a need to provide at least 101 hectares of quality employment land rather than the 81 identified in paragraph 4.4 of the conclusions. On that basis the conclusions that prioritisation should not be given to Hilton Cross are ill-advised and should be reconsidered. The bringing forward of a modest extension to Hilton Cross is required either to fill the gap that the Bentley Mill Way and Willenhall sites will not fill or in any event provide for more quality employment land than the Employment Land Study under-estimates.

2.12 The combination of the over-estimation of supply of high quality sites (with specific sites identified as being of high quality not approaching the appropriate definition) and an under- estimation of employment land requirements would all suggest that there is a need for additional deliverable high quality employment land to serve the Black Country in South Staffordshire. This also takes into account that the Employment Land Study end date is 2026 rather than the SAD end date which is later at 2028. Whilst a large element of need for quality land emanates from Sandwell, there is insufficient quality land in that area to meet need. A key factor is what constitutes a quality employment site in its location. The M54 corridor is identified as a priority regeneration zone in the Black Country Core Strategy so is an appropriate location for quality employment land.

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2.13 The four free standing sites allocated in the Core Strategy have been identified for that purpose, ie to provide good quality sites to support the Black Country growth. Due to the under-estimation of the supply of quality sites and under-estimation of potential requirement it can be concluded that a good case exists to make additional allocations of high quality employment land.

2.14 The Council in allocating the four strategic sites took what in Peveril’s view was the correct decision to confirm a policy basis for the future extension of these sites. The Council is also taking the correct decision, in Peveril’s view, to allocate an extension to the ROF site. The Council should though extend this principle to providing an extension to Hilton Cross as it provides for mainly different needs than ROF as a stand-alone quality B1 site.

2.15 Whilst Peveril considers there to be a strong case in relation to the statistical calculations that the Council is using to justify further release of employment land (or lack of them in certain cases), even if the Council does not accept Peveril’s view that an allocation should be made in the current SAD at Hilton Cross then there should at least be the designation of safeguard land from the Green Belt to allow for a longer term allocation of employment land at Hilton Cross to be made. The Council has accepted that principle in relation to housing land. Given the changing landscape in terms of statistics (principally housing but clearly having a knock- on effect on employment land) the allocation of safeguarded land would be a sensible policy response. It is Peveril’s view that the approach of identifying safeguarded land that should be adopted by the Council in its Plan would comply with paragraph 85 of the NPPF. The Plan is unsound in its current form without this approach to safeguarded land being carried through to employment land as well as housing.

The Potential Allocation and Modest Extension to Hilton Cross

2.16 The current allocated area of Hilton Cross based on the existing consent for B1, B2 and B8 in the area is some 18 hectares. A landscaping scheme was required by the Council as part of the development of Hilton Cross which extends to 3.5 hectares. Thus adopting the same approach as the Council has carried out at ROF, the total area of Hilton Cross for the purposes of calculating a ‘modest extension’ is 21.5 hectares. Thus a 50% extension to the site could be up to 10.75 hectares or 9 hectares if the Council sets aside the landscaping scheme.

2.17 Peveril is supportive of the principle of a link road in connection with the development of the ROF site. If option 9 is designated as the appropriate route to serve ROF, the building of the road will also mean that the potential qualities of Hilton Cross as an employment site will be increased. Its proximity to the motorway will clearly remain but there will be more industrial traffic passing Hilton Cross that could regard the site as being, in B1 terms, a convenient

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location to complement the B2, B8 uses on ROF. Thus a potential area for the modest extension to Hilton Cross would lie to the south of the link road in the area shown on the plan in Appendix 2. An alternative extension could take in land immediately to the west of Hilton Cross. This would require a relocation of the existing strategic landscape strip and to replace it on a new outer western edge of the site. Regard would need to be paid to the setting of the listed building to the west of Hilton Cross.

2.18 The provision of additional land in the form proposed would allow continuation of the success of Hilton Cross and deliver over the period up to 2028 and beyond quality employment development. The allocation of a specific land extension would provide more of an attraction to the market interested in B1 uses in this area than the current Core Strategy which accepts the principle of further development but is not committed to a specific site.

2.19 In the case of both options identified for the extension of Hilton Cross, a defensible long term boundary to the Green Belt can be established although it is accepted that the option extending Hilton Cross to the south rather than to the east would be better in Green Belt terms. It would be possible to establish a strategic landscaping belt on the southern side of the proposed extension to Hilton Cross that would be reflective of the strategic landscaping boundary already established (with planning permission) that currently defines the western boundary of Hilton Cross and the boundary with the Green Belt. In this regard the advice on redefining Green Belt boundaries in paragraph 85 of the NPPF would be accorded within that a boundary that would use either physical features that are readily recognisable and likely to be permanent – in this case a strategic landscaping belt would result.

2.20 The extension of Hilton Cross would also complement the proposals for the extension of ROF and in association with the road provide a significant new employment hub close to the M54 junction. That will continue to be regarded as a destination for high quality employment land. Either extension could take place even if the road along the option 9 route does not proceed. The site would be accessed from the Cannock Road and existing roundabout.

2.21 In this regard there is clear merit in providing safeguarded land in addition to what may be allocated as a modest extension to Hilton Cross. In these circumstances if the Council does accept the need to allocate a modest extension to Hilton Cross on site A to the south of the existing development, then there is the potential to ‘safeguard’ site B and/or land further to the south of site A. This is shown on the plan attached as Appendix 2.

2.22 Peveril agrees with the Council’s assessment that the Four Ashes site should probably be seen as distinct from Hilton Cross and ROF and that the motorway junction and presence of the

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M54 should be seen as the key factor in releasing further land for high quality employment sites.

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3.0 Conclusions

3.1 Peveril Securities supports the objectives of South Staffordshire District Council to ensure that appropriate supplies of high quality employment land are allocated through the SAD process in accordance with the Core Strategy. Whilst Peveril recognises and supports the extension of the ROF site that will achieve these objectives, it considers that South Staffordshire Borough Council has not gone far enough in its SAD to ensure a range of high quality employment sites allowing B1, B2 and B8 uses to come forward in the Plan period without the need for significant review of either employment land allocations or more relevantly the Green Belt at the end of the somewhat short Plan period. Therefore Peveril considers the Local Plan has failed the test of soundness with particular regard to it being positively prepared over its entire period; justified in relation to not providing a continuing of quality (particularly B1) employment land nor applied the principle of safeguarded land to the Green Belt with particular regard to the policy context of the Hilton Cross strategic employment site.

3.2 For the reasons set out in these representations, however, it is considered that insufficient provision is made for quality employment land to be delivered at Core Strategy approved location within South Staffordshire at Hilton Cross.

3.3 Although in other representations Peveril has supported the ‘modest extension’ to one identified strategic employment sites, the Council should specifically allocate further land as a modest extension to the Hilton Cross site in accordance with the plan attached. This could be either option (preference being for the southern area A) as shown on the plan in Appendix 2. This is to ensure a continuity of supply of quality employment land, particularly for B1 purposes that will make up for the under-estimates arising from the stages 1 and 2 Employment Land Study (see Knight Frank representations).

3.4 Junction 1 of the M54 has the potential to act as a significant employment hub given the likely development and expansion of the ROF site whether or not a new link road between that site and the motorway passing adjacent to Hilton Cross. To ignore the opportunity that the expansion of Hilton Cross would create would be contrary to the objectives for economic growth arising in the Black Country. The assessment made about lack of priority to be given to Hilton Cross in the part 2 Employment Land Study which forms the basis for the Council’s approach in the SAD is ill-considered and should be set aside.

3.5 Notwithstanding Peveril’s view that there should be a specific allocation for an extension to the Hilton Cross site within the SAD, there should in any event (assuming no allocation is made) be land designated as ‘safeguarded land’ from the Green Belt for future long term

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growth for employment purposes. The safeguarded land could include site B if not allocated as a modest extension to Hilton Cross and land to the south of site A on the plan in Appendix 2.

3.6 This would be in accordance with the Core Strategy Policy GB2; reflect the fact the end date of the SAD is 2028 compared to the Employment Land Study end date of 2026 and be a logical extension of the current Core Strategy policy which contemplates extensions being made. It would also accord with NPPF policy in paragraph 85. The SAD should identify where those potential modest extensions should be given the Plan’s short duration and the need to avoid reviewing Green Belt boundaries at the end of the Plan period.

3.7 To enable the Plan to reflect these representations, an amendment should be made to draft Policy SAD6 (the table) to include an extension of up to 50% of the Hilton Cross site for B1, B2/B8 uses (with a consequent change to the Proposals Map). If that is not supported then an amendment should be made to Green Belt policy identifying land to the south of Hilton Cross as ‘safeguarded’ for policy purposes again indicated on the Proposals Map.

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Appendix 1

Knight Frank report

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RESPONSE TO EMPLOYMENT LAND STUDY HILTON CROSS, WOLVERHAMPTON

FEBRUARY 2016 HILTON CROSS, WOLVERHAMPTON

PURPOSE

REPORT

This report is produced to support the representations made by Peveril Securities to ensure the allocation of additional high quality employment land as an extension to the Hilton Cross site at Junction 1 of the M54.

The purpose is to comment on the Black Country and South Staffordshire Sub Regional High Quality Employment Land Study Stages 1 and 2 reports and to conclude that the reports overestimate the supply of Potential High Quality (PHQ) land available which an extension to the Hilton Cross site would help alleviate.

The report also examines the particular characteristics of the four identified strategic employment sites in the emerging Local Plan and concludes that whilst the sites at Four Ashes, i54 and ROF Featherstone each have specific merits as high quality employment sites, the Hilton Cross site is the best of the four sites for a quality B1 development adjacent to a motorway junction. It can therefore be differentiated from the other three identified strategic sites.

The report comments on the background to Hilton Cross and gives examples of other key development sites in the region as well as commenting on the pattern of demand and supply of quality employment land in the Midlands with reference to previous take-up rates. It gives information on the size of existing requirements for quality land in the West Midlands and the Black Country.

It is considered that a strong case exists in relation to the employment land background in South Staffordshire to support the allocation of an extension to the Hilton Cross site.

In this context the report explores the following areas:

 Definition of High Quality (HQ) Employment Land  Classifications of HQ land  Demand and Supply  Use Classes  Land Area Estimates  Identified Potential High Quality (PHQ) Employment Land

HILTON CROSS, WOLVERHAMPTON

BACKGROUND

DESCRIPTION  Hilton Cross Business Park is situated next to J1 of the M54 close to M6 interchange  The site is located within Wolverhampton to the north of Black Country close to the border of South Staffordshire  The park comprises a mixture of B1 (a) offices (known as Element Court) and B2 industrial occupiers (known Mercury)  Existing occupiers include Mann + Hummel, BMI and Squire  Undeveloped plots total c. 4.84 hectares in two parts of the site  Potential for expansion of Hilton Cross through land immediately to the south and possibly the west of the business park bounded by Moseley Road to south

SITUATION  The Black Country and South Staffordshire Sub Regional High Quality Employment Land Study 2014 Stage 1 Report and 2014/15 Stage 2 Report identifies Hilton Cross as potential for ‘modest’ expansion along with i54 and ROF Featherstone  Potential range of ‘modest’ extension at Hilton Cross is indicated between 3.6 and 10 hectares.

HILTON CROSS, WOLVERHAMPTON

LOCATION OVERVIEW

HILTON CROSS SITE LOCAL OCCUPIERS

1 Mann + Hummel 1 2 Element Court (Offices)

3 BMI

4 Squire

5 Arthur Hough & Sons

6 J Banks

7 Joseph Joseph

8 Mann + Hummel

10 9 Tarmac

10 Hilton Main

DEVELOPMENT LAND

1 Hilton Cross – 4.84 hectares

Vernon Park – 2.79 hectares Hilton cross, WOLVERHAMPTON

KEY DEVELOPMENT SITES

Hilton Cross, Wolverhampton 1 • Size –12 hectares • Status – Green Belt land. Proposed expansion of existing business park.

2 Vernon Park, Wolverhampton (Available Now) • Size – 2.79 hectares / up to 120,000 sq ft • Planning – Detailed consent for B2 / B8 4

3 ROF, Featherstone • Size – 14 hectares / up to 500,000 sq ft 3 • Planning – Existing B2 factory. Proposed expansion in Green Belt land as HQ employment site 5 7 1 2 4 Bericote, Four Ashes (Available Now) 6 • Size – 21 hectares / up to 900,000 sq ft • Planning – Outline consent for B1 (c), B2 and B8

5 i54, Wolverhampton (Available Now) • Size – 4.61 hectares remaining / up to 160,000 sq ft • Planning – Outline consent for B1 / B2 uses only (No B8). Enterprise Zone.

6 Lupus Park, Wolverhampton (Available Now) • Size – 4.25 hectares / up to 200,000 sq ft • Planning – Outline consent for B1 (c) / B2 / B8 uses. Enterprise Zone.

7 Wolverhampton Business Park (Available Now) • Size – 3.06 hectares / up to 150,000 sq ft • Planning – Outline consent for B1 (a)

8 Phoenix 10, Darlaston • Size – 16.16 hectares / up to 600,000 sq ft • Planning – Allocated employment site. Enterprise Zone. 10 9 Popes Lane, Oldbury (Available Now) • Size – 4.85 hectares / up to 250,000 sq ft 9 • Planning – Outline consent for B1 (c) / B2 / B8

10 Kelvin Way, West Bromwich (Available Now) • Size – 4.45 hectares / up to 160,000 sq ft • Planning – Earmarked for employment HILTON CROSS, WOLVERHAMPTON

SITE PHOTOS

Hilton Cross land bounded by Moseley Road to South Hilton Cross land bounded by Moseley Road to South

Industrial Units at Mercury, Hilton Business Park Offices at Element Court, Hilton Business Park

HILTON CROSS, WOLVERHAMPTON

High quality employment land

DEFINITION KEY CONSIDERATIONS FOR OCCUPIERS & INVESTORS  The key characteristics that define “Strategic High Quality Employment Land” referred in paragraph  Availability of labour supply / cost 1.4 of the Black Country and South Staffordshire Employment Land Study (Stage 1 report) and set out in EMP2 of the Black Country Core Strategy (BCCS), are as follows:  Access – within a maximum of 1-2 miles from a motorway  Strong public transport links for employees – within 1 mile of a train / bus route, with regular services around shift patterns STRATEGIC HIGH QUALITY EMPLOYMENT LAND (HQ)  Amenities – nearby shops / restaurants / gyms / hotels within – within 1 mile  Well-located to a large skilled workforce  Modern business park environment with open areas / footpaths / cycle paths  Well-located to the motorway network to provide good accessibility to international, national and  Infrastructure – availability for all main utilities, particularly power supply and broadband regional markets and supply chains  High quality estate infrastructure – estate roads / drainage / street lighting / signage  With a good public transport accessibility  Free from constraints – hours of use restrictions (24/7 required), environmental contamination, ground  With a critical mass of active industrial and logistics land and premises that are well suited to the conditions, flood risk zones and ecology needs of modern industry  Planning Use Flexibility – National and international investors will require exit strategy on funding  Good proximity to an existing or proposed knowledge cluster opportunities and therefore look for as wide use as possible. B1 / B2 / B8 would ensure maximum  High existing or potential environmental quality including high quality green space, good quality appeal. Equally occupiers would also have preference for unrestricted use to future proof their own exit built environment and linkages to walking and cycling routes strategy or change in business needs.  Attractive or potentially attractive to national or international investment  B1 offices and B1 (c) high office content industrial users will generally have similar requirements for build densities and site requirements. These will often differ to B2 and B8 users where more HGV movements NOTE – The BCCS study emphasises that it is not always necessary for a site to have all these are required. characteristics to be High Quality  Car Parking – B1 users typically require 1:200/400 sq ft and B2 / B8 users 1:500/1,000 sq ft ratios.

LOCAL QUALITY EMPLOYMENT AREAS (LQ) ESTIMATIONS ON LAND

Represent employment land that is occupied and will continue to serve local markets, but not The estimates for land show that of the 311 hectares of HQ land, only 40 hectares is made from existing considered likely to be attractive to higher value industrial businesses and inward investors seeking undeveloped land. The remaining land is on Potentially High Quality Land (PHQ) potentially available up to premises. These are less accessible or buildings of lesser quality than on HQ sites and characterised 2026. by: Of the 40 hectares, these include 19.2 hectares at i54 Plot A-B. This land is owned by Jaguar Land Rover  A critical mass of active industrial and service uses and premises that are fit for purpose who have now committed to developing out 915,000 sq ft expansion of their engine plant, therefore can no  Good access to local markets, suppliers and employees longer be counted in the calculations.  The existing or potential use and/or traffic generated by the use does not have an unacceptable impact on the amenity of surrounding land uses or on the highway network Furthermore, a sale of i54 Plot G has now been agreed to ERA who will be developing out 135,000 sq ft for  Good public transport accessibility their own occupation. This takes a further 3.11 hectares out of these calculations. The net position of land after deductions equates to 17.69 hectares.

HILTON CROSS, WOLVERHAMPTON

Classification of HQ LAND

In respect of a HQ employment land within the immediate vicinity, we have considered and appraised the sites below against their HQ classification as follows:

FOUR ASHES If we consider Four Ashes in the context of HQ Employment Land, we have to explore the key considerations for occupiers and investors.  Location – Four Ashes is approximately 3.5 miles from J2 of M54 and 2.3 from J12 of M6, therefore outside the 1-2 miles indicated by HQ requirements  Public Transport – No direct public transport to site, again a requirement for HQ site  Critical Mass of Industrial & Logistics Property to meet their needs – At present there are a couple of small buildings on the site, but largely the site is undeveloped. As such, it is too early in the development cycle of the site to have a critical mass.  Potential green initiatives – no linkages to walking or cycle routes and green areas around site.  Amenity – No on site or nearby shops / restaurants / hotels, as indicated by HQ requirements.  Infrastructure – limited to site at present, with access via concrete road a bridge

In consideration of the above, it could be argued that the Four Ashes site does not meet the strict criteria of a HQ Employment site. Therefore, the 20 hectares indicated could deducted from the existing calculations.

Aerial picture of Four Ashes development site

ROF FEATHERSTONE i54 Whereas this site does have strategic benefits from being promoted as an employment site, there are The i54 has been successful scheme attracting major occupiers to the region. The remaining land is currently issues due to the existing access that may put off any potential occupiers / investors. We being promoted and is a HQ site for B2 uses. understand a link road is being promoted in order to improve access into this site and will create a HQ site. HILTON CROSS ROF Featherstone can be regarded as a HQ site for B2 / B8 occupiers, if the link road is approved. Of all the above sites, Hilton Cross, is considered the best for access to the motorway network and which has been evidenced by successful schemes in close proximity. Out of the above Hilton Cross is the only site that can be considered HQ for predominantly B1 users. HILTON CROSS, WOLVERHAMPTON

DEMAND & SUPPLY MIDLANDS INDUSTRIAL & LOGISTICS MARKET DEMAND Knight Frank research (LOGIC) has shown that the take up in the Midlands Industrial and Logistics market The report highlighted there was demand for 458 hectares of land up to 2026. has been robust following the downturn.  Knight Frank are currently tracking in excess of 4 million sq ft of requirements equating to Take up figures for the past 5 years are as follows: 81 hectares of land in the West Midlands that could be accommodated within the Black Country  2015 – 12.027 million sq ft  Of the current supply, over 3.2 million sq ft is currently under offer.  2014 – 18.08 million sq ft  2013 – 9.75 million sq ft SUPPLY  2012 – 9.5 million sq ft There are currently no modern warehouse buildings in the Black Country in excess of 100,000  2011 – 8.61 million sq ft sq ft. Any major occupier with a sizeable requirement in the area would therefore need to consider new build sites to satisfy their requirement in the region. Knight Frank research (LOGIC) also shows that:  5 year long term average – 11.59 million sq ft per annum

 Existing industrial space above 50,000 sq ft across the Midlands stood at 7.65 million sq ft  The key sector driving take up is retail which accounted for over a third of all take up in 2015. at H2 2015.  New build space accounted for approximately 6.54 million sq ft (54%) of take up in 2015.  The total new build industrial space under construction for units in excess of 50,000 sq ft accounts for 3.76 million sq ft across 24 building for delivery in 2016/17. KEY TRANSACTIONS  The total supply, is equivalent to approximately 12 months take up Within the West Midlands, there has been significant activity over the past couple of years which has resulted in a shortage of land across the region. Key Black Country deals include: COMMENTS

 The Black Country is well situated to capitalise on demand from the industrial and logistics  Plots A-B, i54, J2 M54, Wolverhampton – 19.2 hectares 915,000 sq ft (Jaguar Land Rover, Engine markets both in the manufacturing sector and the retail / logistics sectors. Plant Extension)  Occupiers from manufacturing and retail have a common need to be situated in close  Plot G, i54, J2 M54, Wolverhampton – 3.11 hectares / 135,000 sq ft (ERA Home Security) proximity to their supply chain. This will involve parcel carriers and pallet companies who  Opus Blueprint, J9 M6, Wednesbury – 8.9 hectares / 425,000 sq ft (Lidl Regional Distribution Centre) are able to undertake over night and same day deliveries.  Target Point, Bull Lane, Wednesbury – 3.72 hectares / 184,000 sq ft (Toolbank)  Citadel, Bilston, Wolverhampton – 322,000 sq ft (Wiggle National Distribution Centre) CONCLUSION  Citygate Park, Wolverhampton – 233,000 sq ft (TASK Consumer Products)  From the key transactions and Knight Frank expert knowledge of current occupier

requirements in the region ,we conclude that the report has underestimated the amount of HQ land required to accommodate future growth.

HILTON CROSS, WOLVERHAMPTON

USE CLASSES

SITES It is noted from the report that the following sites are aimed at specific planning use classes

 i54, Wolverhampton – Predominantly a large floor plate B2 use  ROF Featherstone – B2 / B8 uses

The layout of the above sites will differ vastly from B1 (a) offices or B1 (c) lighting industrial use with high office content. These will typically reply on:

 Higher level of car parking ratio (typically 1: 200-400 sq ft ratio for B1, against 1:500-1,000 per sq ft for B2/B8)  Amenity (retail, gyms, nursery, pubs, etc.)  Support services (high quality broadband, etc.)  Environmental quality (landscaping, security, building environment)  Strong public transport links (within 1 mile of main road / public transport)

This can be noted at Wolverhampton Business Park which has amenity by way of a pub / restaurant, gym and hotel . The offices can former smaller footprint, higher building density environment with typically 1 per 400 sq ft parking ratios. The park has proved successful since its conception and is now reaching maturity with the likelihood the remaining plots will be filled within the next few years.

It can be noted from the report that there is very limited HQ B1 land coming forward to replace this with occupiers now having to look further afield to M42 Corridor or towns such as Cannock to satisfy requirements. Offices at Wolverhampton Business Park, Stafford Road, Wolverhampton

Small infill plots are available such as Castlegate at Dudley and Tempus 10 at Walsall, but this is generally very limited in supply and below 0.8 hectares.

It is vital to retain land capable of delivering B1 users into the area to meet the HQ criteria.

HILTON CROSS, WOLVERHAMPTON

LAND AREA ESTIMATES

GROSS AND NET AREAS In arriving at the land area estimates, it is with questioning the basis these areas are calculated.

Areas can often be misinterpreted for development land as the gross and net areas will vary greatly as a result of the significant infrastructure needed by way of estate roads, drainage attenuation and services into a site.

In addition to the site infrastructure, individual plot build densities are generally lower for B2 / B8 planning uses against B1 planning uses, where offices can be over multiple floors.

Institutional standard for modern industrial warehouse are as follows:

• 40-45% site cover (20,000 sq ft per 0.4 hectares) • 50m deep service yard • 1 loading door per 10,000 sq ft • Separate car park with 1:500/1,000 sq ft car parking ratio • 5-10% office content

In respect of a larger development when master planning an estate the loss of development land to common areas and landscaping can be as much as 25% of the site, although typically would expect 10-15%.

NET DEDUCTIONS Indicative warehousing scheme at Rugby Gateway showing estate common areas (green), estate From the 40 hectares of HQ employment land identified in the report, it is possible that this could be roads and attenuation basins (blue). Typical individual plots (grey) providing c. 45% site coverage. reduced down to a net area of c. 36 hectares, when considering infrastructure within an estate. Furthermore, additional consideration could be taken in account of the build densities of approximately 45% building footprint, which could further reduce this gross land area to 16.2 CONCLUSION hectares of useable space. • The report has not taken into account the gross to net development deductions necessary to create a marketable scheme, and question whether assumed floor area which would be created has taken into This is without taking into account the loss of land at i54 (22.31 hectares) following the 2 account institutional requirements for B2 / B8 warehousing schemes. transactions mentioned earlier in this report. • Knight Frank s research demonstrates that more HQ land needs to be allocated in order to account for the loss of floor area as a result of designing suitable schemes on the land already classed as HQ.

HILTON CROSS, WOLVERHAMPTON

IDENTIFIED PHQ EMPLOYMENT LAND

FORMER CINEMA AND CASINO, BENTLEY MILL LANE, DARLASTON FORMER WILLENHALL SEWAGE WORKS, WILLENHALL 4.56 hectares (gross) / 4.104 hectares (net) / 1.846 hectares (site cover) 9.7 hectares (gross) / 8.73 hectares (net) / 3.928 hectares (site cover)

The site comprises of a former Showcase Cinema, close to J10 of M6. The site has the potential to This PHQ site is owned by Severn Trent and as a former operational site expect this will be subject to accommodate either a single industrial occupier or a smaller unit industrial scheme. However, the site OFWAT approval prior to any disposal of the site. There are two major constraints to this site namely would involve demolition of existing buildings and there are unknown environmental constraints, Access for HGVs / cars and environmental remediation. which as an individual plot of 4.56 hectares may prove challenging for the viability of industrial uses. The main access into the site is presently via Anson Road through a built up residential area and not The property is situated in a historic mining area, which is in close proximity to the ‘Phoenix 10’ and considered suitable for commercial vehicles. The potential access that could bring the site forward ‘Parallel 9-10’ sites which are understood to have previously mined areas. would involve a major infrastructure project, as there is no current access from the Marshland Way / Black Country Route (A454) roundabout into the site and a significant change in levels. Further investigation would be required to satisfy whether a suitable development platform could be created. The site totals 9.7 hectares gross and expect there to be some loss of development land as a result of any landscaping required adjacent the residential and through loss of site with a new access. Given the likely expenditure for access and environmental remediation against predicted future values for The site is also remote from existing business park space and could be argued that it is not a HQ site industrial it is likely this project would have viability challenges for the proposed uses. It could have on this basis. more potential however through residential redevelopment, which generally will drive a higher value.

Whilst the site is reasonably close to the Axcess 10 Business Park, it would be a remote standalone site from existing business park space and could be argued that it is not representative of a HQ site.

HILTON CROSS, WOLVERHAMPTON

Potential AREAS USING NET AREAS

HQ SUPPLY AND DEMAND IN THE BLACK COUNTRY TO 2026 (HECTARES) – NET AREAS

Proposed Sites Supply Supply Most Likely Difference Supply Most Likely Difference Hectares Hectares Scenario Hectares Scenario (Gross) (Net of 10% Demand (Net of 45% Demand infrastructure) Requirements site cover plus Requirements infrastructure) HQ 40 36 296 -260 16.2 296 -279.8

PHQ 271 243.9 162 +81.9 109.755 162 -52.23

Total 311 279.9 458 -178.1 125.955 458 -332.045

HQ SUPPLY AND DEMAND IN THE BLACK COUNTRY TO 2026 (HECTARES) – NET AREAS WITH DEDUCTIONS

PHQ 271 243.9 162 +81.9 109.755 162 -52.23

Total 288.69 259.821 458 -198.179 116.919 458 -341.081

* Less 22.31 hectares following transactions at i54 Plots A-B (JLR) and i54 Plot G (ERA) HILTON CROSS, WOLVERHAMPTON

SUMMARY

 Hilton Cross is capable of meeting demand for the shortfall in HQ Employment Land to suit B1 planning uses

 Hilton Cross can be distinguished from the other three strategic employment sites in South Staffordshire as is well placed for offering B1 uses.

 The location of the site is very strong within 1 mile from the M54 at J1 providing direct links to the interchange with the M6 at J10a

 There are a cluster of existing occupiers on the original phase of Hilton Cross Business, who have already started to expand in the same location (J Banks and Mann + Hummel have taken space at Vernon Park)

 The site presents an opportunity for existing occupiers to future proof their business with ready made expansion land

 Query as to whether some HQ sites and PHQ sites should be reclassified or even considered as deliverable at all.

 Query as to whether gross development areas or net developable areas have been adopted in calculating the HQ Supply and Demand assessments

 Knight Frank research suggests that the report underestimates the demand for HQ sites, and overestimates the total floor area to be delivered as a result of the development deductions necessary to create a marketable scheme (gross to net infrastructure / landscaping, and to meet institutional requirements).

• In conclusion Knight Frank are confident that Hilton Cross is suitable of being extended in order to be able to provide a continuous supply of HQ land for B1 uses.

HILTON CROSS, WOLVERHAMPTON

GENERAL INFORMATION & EXTENT OF REPORT

Extent This report is for the use to whom it is addressed, and no responsibility is accepted to any third party for the whole or any part of its contents. Neither the whole nor any part of this report nor any reference thereto may be included in the published document, circular or statement, nor published in any way without approval of the form and context in which it may appear.

Any indication of value provided regarding indicative rents or achievable prices is provided for discussion purposes only. It is not, and is not intended to be, a valuation. We would be pleased to undertake the additional necessary research and provide a formal valuation if required, on the basis of a separate instruction.

Representations

Appendix 2

Plan showing proposed modest extension(s) to Hilton Cross and safeguarded land

Report date: February 2017 Reference: HG2716 www.wyg.com 13 creative minds safe hands

KEY EMPLOYMENT EXTENSION EXISTING SITE (18ha) OPTIONS PLAN A: EXTENSION OPTION SCALE: 1:10,000@A1 EXTENSION OPTIONS (circa 10ha each) DATE: 11/02/16 DWG NO: HG2716-EOP B: EXTENSION OPTION LANDSCAPE STRIP (3.5ha)

RELOCATED LANDSCAPE STRIP SAFEGUARDED LAND