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Staffordshire Place C/O Wedgwood Building Tipping Street Stafford ST16 2DH Telephone: (01785) 276643 Email: James.Chadwick@Staff Staffordshire Place c/o Wedgwood Building Tipping Street Stafford ST16 2DH Telephone: (01785) 276643 Email: [email protected] Please ask for: James Chadwick 29 August 2017 Dear Sir/Madam WEST MIDLANDS INTERCHANGE – STAGE 2 CONSULTATION Thank you for consulting Staffordshire County Council on your Stage 2 public consultation for the proposed Strategic Rail Freight Interchange (SRFI) at Four Ashes. In July 2016 we responded to your Stage 1 consultation and set out the broad parameters and issues we felt would need to be considered as the proposal evolved. Whilst we have been in discussions with you in certain specific technical areas some of the information and documents we are seeing for the first time, indeed this is the first time we have seen the full application detail packaged together. It is acknowledged that the documents provided at this stage are working drafts and our comments below are provided on that basis. Before moving into detailed comments on the technical documentation we note that the newsletter accompanying the consultation makes reference to a Community Fund. However, this then does not feature in the technical documents or the draft Order. We acknowledge that the provision of a community fund is a voluntary offer and that such funds have no weight in the planning balance. As such the decision maker in this respect will have no regard to the provision of a community fund in determining the application. However, this point is not made clear in the consultation documents nor is it evident what mechanism by which the fund will be secured. It could therefore be the case that the public may have misinterpreted the offer of the fund and responded negatively. Alternative Site Assessment The draft Alternative Site Assessment (ASA) sets out to identify potential alternative sites that could provide a SRFI. It is noted that there is no specific guidance on the production of an ASA. The approach taken here to review and take direction from previous assessments that have been through the planning process therefore seems an appropriate starting point. The structure of the report follows a logical progression in setting out the search criteria and then applying those to narrow the search area. At the point where actual sites are defined from the narrowed search area, with the exception of the documented sites, it is unclear how alternative sites have been determined. Whilst the ASA sets out the process there is no means of verifying the outcome in the report. It is also noted that in terms of evidence available no apparent regard has been had to any SHLAA in the search area, which could have assisted in defining ownerships and potential availability. Furthermore, for the three undocumented sites that have been identified it is unclear how the boundaries of these sites have been determined. Economy With regard to the suggested, “benefits arising from the WMI project,” we acknowledge that the proposed scheme would create a significant number of jobs through the construction phase and once the scheme is complete and fully operational, whilst logistics operations do indeed provide a vital function in support of the other industries, particularly manufacturers, which are prevalent within the area. However, we do have a number of concerns as to the work that has been done so far, particularly in considering the potential labour force for the site. Firstly the Draft Planning Statement states that:- “The jobs available will provide a range of skill and salary levels; part time and full time; shift and non-shift. These would be high quality jobs with opportunities for career development and training – and salaries well above the regional average for skilled and experienced roles. It is estimated that 20% of jobs would have salaries above the median for the area.” Whilst we agree that there will undoubtedly be a range of jobs available, the definition of, “high quality,” is debatable as is the suggestion that salaries will be, “well above the regional average.” There seems little evidence to support this statement, whilst it is also questionable as to whether all of the jobs are high quality when it is estimated that 80% of the jobs will have below average salaries. This is important as it will affect the travel to work area (TTWA) for the site. This is not to say that the jobs that will be created are not suitable for the residents within the locality and we agree that the development would have benefits in providing jobs for people who are unemployed. However, the statement that, “ Workers will be drawn from a travel to work area (‘TTWA’) that includes neighbourhoods in Wolverhampton, Stoke and Stafford,” is far too simplistic. Whilst there are likely to be workers at the site from all parts of the TTWA and beyond, the nature of the labour force required at the site and where these workers will come from is far more nuanced than the analysis that has been completed so far suggests. It has already been acknowledged that the vast majority of jobs at the site will have below average salaries, and it is known that people with lower-skilled, lower-wage jobs are far less likely to commute relatively longer distances. The number of people that the site will be able to draw from Stoke-on-Trent, for example, is therefore likely to be relatively small, despite the fact that the large unemployed cohort of Stoke-on-Trent residents are currently being considered as potential workers at the site. Given this issue it also seems to be an omission that no consideration has been given to the official TTWAs produced by ONS. The WMI site straddles two TTWAs (75% self- containment), covering a far smaller area than what is currently being used by the site promoters. Given the nature of the jobs at the site, it may actually be that the expected TTWA for the site may be even smaller than this as suggested by the ‘alternative travel to work area’ for people with low levels of qualifications, produced by ONS. 1 Intuitively this is what we would expect and is supported by evaluations we have previously completed for Staffordshire County Council employment sites, including those that have primarily been occupied by logistics companies. 2011 Travel to Work Areas Source: ONS, Produced by Staffordshire County Council Contains OS data © Crown Copyright and database right 2017 © Crown copyright and database rights 2017. Ordnance Survey 100019422. Of course the travel to work areas provide an indication of commuting patterns at a point in time and this will change, not least as a result of housing and employment developments. However, it does have to be questioned as to whether there is currently a credible plan in place as to how the labour force for the site will be met. There is commitment within the Planning Statement for an employment and skills plan to be produced for the site prior to commencement, but given the importance of this issue we believe that further work is needed not prior to commencement but prior to submission of the DCO. Whilst there is a relatively large unemployed cohort within the Black Country, the level of unemployment in Staffordshire is at its lowest ever point and 1 Alternative Travel to Work Areas, 2011 Census, ONS, http://ons.maps.arcgis.com/apps/MapSeries/index.html?appid=397ccae5d5c7472e87cf0ca766386cc2 ultimately we have concerns that full labour force for the site cannot currently be met, which may have further implications locally that have not been identified and consequently not been assessed in the work to date. We believe that there needs to be further assessment undertaken and, if necessary, strategies devised as to how this issue would be addressed throughout the development of the site. The Planning Statement also implies that all of the business rates expected to be generated by the site will be retained by South Staffordshire Council and Staffordshire County Council. Whilst it is expected that a proportion of the business rates will be retained locally, the move to 100% business rates retention is not currently being progressed as the Local Government Finance Bill is no longer before Parliament. Regardless of this however, the exact design of the 100% business rates retention scheme was not known and it therefore could not be said with any confidence as to whether the full amount of business rates generated by WMI would indeed be retained locally. The Planning Statement gives the impression that the business rates generated by WMI would directly be supporting local council services, and whilst this may be true to a small extent it certainly does not provide a true picture and needs to be clarified. We also question the work that has been done to assess the issue of job displacement. The Planning Statement makes a very general statement that job displacement would be expected to be minimal, but there again seems to be little evidence to support this. Given that the logistics industry has grown substantially in the area in recent years, and the wider area is now home to a great deal of large logistics operations and big-sheds, the rail connectivity provided by WMI would surely provide an added benefit which could lead to displacement, particularly given that a key argument frequently used by the site promoters in favour of the development is that it will bring both time and cost benefits for freight movement. This issue therefore requires greater consideration than it has been afforded so far, and particularly how displacement can be minimised and mitigated against. Transport It is noted that regular meetings have been held with the highway authorities and South Staffordshire District Council as the highways work progressed.
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