Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1464

Received: 21/11/2024

Respondent: Nurton Developments Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

**Summary:**

Policy DLP18 aims to deliver at least 72ha of new employment land over the plan period through three methods: developing employment opportunity sites, utilizing windfall sites, and collaborating with neighbouring authorities to meet unmet needs. While Nurton Developments Ltd (NDL) does not oppose this strategy, it raises concerns about the underestimation of the need for employment land in the Borough and the wider Black Country. NDL argues that the evidence base, particularly the Black Country EDNA 2023, is flawed and the projected need for land is too low.

NDL critiques the methodology of the EDNA 2023, highlighting issues such as inconsistent application, lack of allowance for suppressed demand, and insufficient consideration of flexibility and market churn. They suggest that the true need for employment land in the Black Country should be 672ha, with Dudley’s share increasing to 149ha. This is based on a base need of 142ha and an additional 6.82ha for flexibility.

Additionally, NDL questions the supply projections, particularly regarding windfall sites, and concludes that the actual supply of land is significantly lower than stated. They also note a qualitative shortage of large strategic sites, which the EDNA 2023 fails to address. In light of these issues, NDL calls for an increase in the employment land allocation to at least 149ha for Dudley and urges a more ambitious approach to meet the region's economic goals. They also note that the EDNA is being updated, and the latest revisions should take into account the concerns raised.

Object

Representation ID: 1465

Received: 21/11/2024

Respondent: Nurton Developments Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Here's a summary of the key points from the document "Representations of Nurton Developments re the EDNA":

### Introduction
- **Nurton Developments Ltd (NDL)**: A Birmingham-based developer active in the West Midlands, promoting industrial and warehouse premises.
- **Key Projects**: Branston Locks (mixed-use development) and Hilton Park (strategic employment site).

### Main Concerns
- **Accuracy of Employment Land Needs Assessment (EDNA)**: NDL emphasizes the need for accurate, realistic, and consistent data on employment land needs and supply in the Black Country.

### Critique of EDNA 2022
- **Underestimation of Employment Land Need**: NDL argues that the need for employment land has been significantly underestimated.
- **Overestimation of Deliverable Supply**: The supply of employment land has been overestimated, leading to a larger shortfall than reported.
- **Mismatch in Quality and Type of Sites**: There is a discrepancy between the types of sites needed by developers and those provided.

### EDNA 2023 Overview
- **Comparison with EDNA 2022**: The 2023 update shows similar conclusions but with some methodological changes.
- **Key Figures**:
- Need: 533 hectares
- Supply: 380 hectares
- Shortfall: 153 hectares

### NDL's Concerns with EDNA 2023
- **Methodology**: Inconsistent application of forecasting methods across different authorities.
- **Suppressed Demand**: Past completions do not reflect true demand due to constrained site supply.
- **Replacement of Future Losses**: Underestimation of future losses of employment land.
- **Flexibility and Market Churn**: No allowance for market churn or flexibility in the assessment.
- **Strategic Employment Land**: Lack of reference to the need for large strategic sites.

### Recommendations
- **Increased Need**: NDL suggests a minimum need of 672 hectares, including a margin for flexibility.
- **Realistic Supply Assessment**: The maximum realistic supply is estimated at 302 hectares.
- **Shortfall**: A minimum shortfall of 370 hectares, with potential contributions from neighboring areas still leaving a significant gap.

### Conclusion
- **Call for a Bolder Approach**: NDL advocates for a more ambitious release of employment land to support economic growth and attract investment.