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Sandwell Local Plan - Reg 19 Publication

Ended on the 11 November 2024
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(3) 8. Sandwell's Economy

Introduction

8.1 The policies in this chapter are concerned with promoting and supporting employment in manufacturing, research and development (Use Class E(g)(ii), E(g)(iii) and B2), warehousing (Use Class B8) and other uses that are appropriately located in industrial employment areas.

8.2 Offices (Use Class E(g)(i)) are not classed as an employment use for the purposes of these policies; they are covered by Policies SCE1 - SCE7, which relate to uses that are more appropriately located in town centres.

8.3 The evidence base for the employment land policies primarily consists of a two-stage Economic Development Needs Assessment (EDNA)[178], and the Sandwell Employment Area Review (SEAR) formerly the Black Country Employment Area Review (BEAR)[179]. The EDNA provides an objective assessment of the employment land requirement for Sandwell to 2041, based upon an independent assessment of the area's economic development needs.

8.4 In terms of Sandwell's specific employment land needs, the evidence contained within the latest Black Country Economic Development Needs Assessment (EDNA) 2023 provides an overall target figure for the Black Country area of 494 hectares (23.52 hectares per annum) from 2020 to 2041 with the target figure for Sandwell being 185 hectares or 8.81 hectares per annum, based on past completions data, between 2020 - 2041. This target figure has been evidenced through past employment land completions between 2001-2020 and is based upon the high rate of past completions scenario.

8.5 The target figure for Sandwell was based on forecasts. As such, an indicative split between different uses (manufacturing uses, logistics / storage and distribution) was not given in the EDNA. It is estimated that 60 hectares is required for manufacturing uses and 126 hectares is required for storage and distribution uses (based on 32% manufacturing and 68% distribution and logistics).

8.6 Within the EDNA, the overall employment land need figure for the Black Country is stated to increase from 470 hectares to 494 hectares, to include the employment land lost because of planned redevelopment to alternative uses. In Sandwell, that total target figure of 186 hectares is increased to 211 hectares through the addition of 26 hectares associated with those sites comprising existing operational employment land that are allocated for housing and other land uses. The need for the replacement of losses will be monitored as the Plan is implemented.

8.7 The key conclusions of the EDNA studies were:

  1. Sandwell forms part of the Black Country Functional Economic Area (FEMA) and is a clearly defined geographical unit. It has strong employment and labour market links to a hinterland that includes southern Staffordshire, north Worcestershire, Birmingham, and Solihull;
  2. Sandwell has an employment land shortfall, which will be met through the Black Country FEMA[180] and the Duty to Co-operate with those neighbouring Local Authority Areas identified as having a strong or moderate relationship with the Black Country FEMA and other areas with an evidenced functional relationship.
  3. Sandwell has been hit hard by the COVID19 recession but is expected to recover strongly and has the capacity to deliver significant growth, given the diversity, resilience and concentration of key national sectors located in the area;
  4. even pre-COVID19, recent growth was achieved against a backdrop of a weak local skills base, low business start-up rates and low GVA per head in comparison with the West Midlands and UK averages;
  5. economic development strategies including the Strategic Economic Plan (SEP) and Local Industrial Strategy seek to address these challenges to accelerate the growth of the local economy;
  6. Sandwell's employment land supply in 2020 was largely that inherited from the Black Country Core Strategy and the suite of Tier 2 Plans that supported it. This land supply is dominated by small sites in the urban area. The plan will allocate 1,193 ha of occupied employment land for strategic, local or other employment provision;
  7. going forward, attracting high-growth knowledge-based industries in line with SEP ambitions will require the provision of more prestigious sites, high-quality space with easy access to key transport hubs and good connectivity;
  8. the Plan also needs to ensure Sandwell can accommodate a variety of business needs, including start-ups and smaller businesses. This means that a mixed portfolio of sites will need to be made available, including larger and smaller sites and spaces, and areas of both higher and lower quality;
  9. it is imperative to protect the existing supply of land to meet future needs that will arise from a high growth-driven economy;
  10. there is a significant gap between the employment land supply, inherited from the Core Strategy and subsequent Tier 2 Plans, and forecast future needs.

8.8 To address these issues, the strategy that underpins the SLP policies contains the following objectives:

  1. to facilitate the growth and diversification of the economy, the Plan allocates land for new development within Sandwell to accommodate jobs and output growth (Policy SDS1);
  2. to accommodate a variety of business needs including high technology manufacturing and logistics sectors, the Plan provides for a balanced portfolio of sites (Policy SEC1);
  3. to protect and enhance land and premises within existing employment areas where this provides for the needs of jobs and businesses (Policies SEC2, SEC3 and SEC4);
  4. to recognise that some sites will become unsuitable for continued employment uses and to facilitate their redevelopment to alternative uses including housing (Policy SEC4). However, the number of such sites is expected to be considerably less than was envisaged by the Black Country Core Strategy adopted in 2011;
  5. to enable local communities to share the benefits of economic growth (Policy SEC5).
  6. In relation to employment land, the Spatial Strategy's intention is to focus new development on sites within the Regeneration Areas, as set out in Policy SDS3. This will be achieved through the development of currently vacant sites allocated for development in the Plan, and the redevelopment and 'intensification' of existing premises. The great majority of existing employment areas which accommodate most of the Sandwell's existing manufacturing and logistics jobs and businesses are also located within the Regeneration Area.

Providing for Economic Growth and Jobs

8.10 Policy SEC1 seeks to ensure a sufficient quantum of development opportunities are provided to meet the demand for economic growth and support the diversification of Sandwell's economy. This policy supports Strategic Objectives 2, 8 and 9.

(5) Whitehall Road, Tipton (1) Lion Farm, Oldbury (2) Policy SEC1 – Providing for Economic Growth and Jobs

  1. The Sandwell Local Plan will seek to maintain the existing provision of around 1,221 hectares of employment land[181] across the borough.
  2. The borough is subject to a demand for 211 hectares of new employment land (based on the past trends forecast of 185 hectares and accounting for the loss of employment land of 26 hectares to non-employment uses), between 2020 and 2041. This will be delivered through:
    1. The development of employment development sites allocated in the Plan, equal to 42 hectares (this figure includes past completions since 2020).
    2. Additional land will be brought forward through the redevelopment, intensification, conversion and enhancement of existing employment sites allocated under Policies SEC2, SEC3 and SEC4.
    3. Through the Duty to Co-operate process: the development of employment sites outside the borough (Black Country FEMA and those local authorities with an evidenced functional economic link to Sandwell).
  3. The Plan will deliver a portfolio of sites of various sizes and quality to meet a range of business needs. This land is in addition to those sites currently occupied for employment purposes. These sites will be safeguarded for industrial employment uses[182].
  4. Within the existing employment areas subject to Policies SEC2, SEC3 and SEC4, the Council will support, with public intervention as necessary, the regeneration and renewal of such areas, including their environmental enhancement and incorporation of sustainable measures to mitigate climate change impacts. Industrial developments will need to demonstrate how they have been designed to maximise resistance and resilience to climate change, as set out in Policy SDS2.
  5. To enable Sandwell's employment areas to remain competitive and fit-for-purpose in the long term, and to aid in the economic recovery and rejuvenation of the borough's industrial economy, new and resident companies should be encouraged to adopt a circular economy approach and related infrastructure[183].

Justification

8.11 Building a strong, responsive, and competitive economy is one of the three overarching objectives of the NPPF. This should be achieved by ensuring that sufficient land of the right type is available in the right place and at the right time to support growth, innovation and improved productivity, and by identifying and co-ordinating the provision of infrastructure.

8.12 To support the ongoing growth of the distribution sector and a strong resurgence in manufacturing, the EDNA recommends that the SLP should provide for a minimum of 211 ha of land (this includes 26 ha of employment land lost to other uses) for employment development, for the period up to 2041. This is based on an average provision of 9.07 ha per annum and allows for the replacement of some poorer quality employment land and premises redeveloped for non-industrial uses. The employment land supply baseline figures also include completions between 2020 and 2022.

8.13 The SLP allocates 28 ha of vacant employment land for development for the period between 2020 – 2041; further employment development will come forward through the redevelopment of existing employment land and premises. Further land is provided on other sites that have planning permission for employment development.

8.14 170 ha of the employment land need arising in Sandwell cannot be met solely within the Borough. Land to address this unmet need will be sought in the first instance across the Black Country Functional Economic Market Area (FEMA). It will also be exported, as far as possible, to authorities that have a strong existing or potential functional economic relationship with Sandwell; for example, in terms of migration patterns, commuting links and / or connectivity through physical infrastructure such as rail and motorway.

8.15 The work to export unmet need is ongoing, through the Duty to Cooperate process, and evidenced through relevant Statements of Common Ground. However, given that South Staffordshire District is an area of strong economic transaction with the Black Country, and that authority has been generally able to demonstrate a surplus of employment land to meet its needs, the siting of the West Midlands (Strategic Rail Freight) Interchange (WMSRFI) near J12 of the M6 and within that district, has been the subject of an assessment by (consultants) Stantec (2021 report). This work was undertaken to determine how much demand for employment land could be exported to those neighbouring authorities with strong functional economic ties to South Staffordshire.

8.16 The Stantec Report stated that 67 hectares could be apportioned to the Black Country; out of this total, 18 ha can be directly apportioned to Sandwell to help meet its needs. Given the robustness of this evidence, the figure of 18 ha can be considered as a commitment towards contributing to Sandwell's employment land supply. Given the offer of WMSFRI as Europe's largest new logistics development site, this can be directly attributed towards Sandwell's logistics need total.

Strategic Employment Areas

8.17 Policy SEC2 provides for a sufficient stock of strategic employment land suitable for a growing and diversified economy. This policy supports Strategic Objectives 2 and 8.

(1) Policy SEC2 – Strategic Employment Areas

  1. The Strategic Employment Areas are shown on the Policies Map. They are characterised by excellent accessibility, high-quality environments and clusters of high technology growth sector businesses. These areas will be safeguarded for manufacturing and logistics uses within Use Classes E(g)(ii), E(g)(iii), B2 and B8.
  2. Within Strategic Employment Areas, high-quality development or redevelopment of sites and premises will be required, and planning applications that prejudice or dilute the delivery of appropriate employment activity, or deter investment in such uses, will be refused.
  3. Strategic Employment Areas will be safeguarded from redevelopment for other non-manufacturing / logistics uses.
  4. Some ancillary employment-generating non-Class E(g)(ii), E(g)(iii), and Class-B2 and B8 uses, such as childcare facilities and small-scale food and drink outlets, may also be permitted in Strategic Employment Areas, where they can be shown to strongly support, maintain or enhance the business and employment function and attractiveness of the area, and meet sequential and other national or local policy tests relating to appropriate uses as necessary.

Justification

8.18 Strategic Employment Areas (SEAs) are high-quality employment areas that are considered essential to the long-term success of Sandwell's economy. They correspond to areas of the strongest occupier and market demand and are of high environmental quality, with excellent links to the Strategic Highway Network. They should be protected from non-employment uses that could impact upon their viability as employment locations. These areas contain, or have the potential to attract, those knowledge-based growth sector businesses whose success will be critical to the delivery of Sandwell's economic ambitions.

8.19 Policy SEC2 is based on the approach set out in the 2011 Core Strategy, which distinguished between Strategic High-Quality Employment Areas and Local Employment Areas. The EDNA recommended that the approach set out in the Black Country Core Strategy has served the Black Country well. Subject to some refinement, this approach has been carried forward into the SLP. Consequently, the Strategic Employment Areas identified in the SLP are the equivalent of the Strategic High-Quality Employment Areas in the former Core Strategy.

8.20 The characteristics and extent of the Strategic Employment Areas reflect the findings of the Sandwell Employment Area Review (SEAR). The SEAR re-examined the totality of Sandwell's employment areas against a set of criteria based on those set out in the Core Strategy and the recommendations of the EDNA.

8.21 The key characteristics of Strategic Employment Areas are as follows:

  1. to be highly accessible to the Strategic Highway Network, preferably well- located in relation to the motorway network, to provide good accessibility to international, national, and regional markets and supply chains;
  2. to have good public transport accessibility;
  3. to maintain a critical mass of active industrial and logistics sites and premises that are well suited to the needs of modern industry;
  4. to maintain an existing (or develop a potential) high-quality environment, including suitable landscaping and greenspace and an attractive and functional built environment;
  5. to be attractive to national and / or international investment.

8.22 The majority of the defined strategic employment areas satisfy all these characteristics or are considered capable of acquiring them. The SEAR has found that it is not always necessary for an area to display all these characteristics to attract high-quality development.

8.23 The broad extent of the strategic employment areas is shown on the Policies Map.

8.24 The Plan seeks to safeguard land and premises within strategic employment areas for industrial and logistics activity and supports proposals that involve the improvement and renewal of land and premises within them. This process of redevelopment, intensification and enhancement of existing Local Employment Areas will provide a significant source of land to meet future growth needs.

8.25 Some small-scale ancillary uses will be supported in strategic employment areas where this meets the day-to-day needs of employees of businesses within the SEA. Such uses include food and drink or childcare facilities. They should be of a scale, nature, and location to serve the needs of the employment area, where existing facilities are inadequate and where such needs cannot be met in adjacent town centres. While Policy SEC2 considers development for uses that are not within an industrial employment use class, these will only be supported in exceptional circumstances as it is the intention to safeguard strategic employment areas from non-manufacturing / logistics uses (B Use Classes).

Local Employment Areas

8.26 To achieve the appropriate balance of employment uses and successfully underpin the local economy, it is essential to make provision for those types of industrial, logistics and commercial activities that do not need to be situated in strategic employment areas and are not appropriate for town centres or residential locations. This Policy supports Strategic Objectives 2 and 8.

(5) Policy SEC3 – Local Employment Areas

  1. Local Employment Areas are shown on the Policies Map. They are characterised by a critical mass of industrial, warehousing and service activity with good access to local markets and employees.
  2. These areas will provide for the needs of locally based investment and will be safeguarded for the following uses;
    1. industry and warehousing[184];
    2. motor trade activities, including car showrooms and vehicle repair;
    3. haulage and transfer depots;
    4. trade, wholesale retailing and builders' merchants;
    5. scrap metal, timber and construction premises and yards;
    6. waste collection, transfer and recycling uses.
  3. Some ancillary employment-generating non-Class E(g)(ii), E(g)(iii)) and B uses such as childcare facilities and food and drink outlets may also be permitted in Local Employment Areas where they can:
    1. be shown to strongly support, maintain or enhance the business and employment function of the area; and
    2. meet sequential and other national or local policy tests (particularly Policies SCE5 and SCE6) relating to appropriate uses, as necessary.

Justification

8.27 Local Employment Areas (LEAs) are particularly prevalent in Sandwell and play an important role in the local economy. They offer a valuable source of mainly low-cost industrial units that are vital in providing local jobs and a balanced portfolio of sites of different sizes and quality, including for small or new businesses that do not require higher-quality or large-scale premises and land.

8.28 Policy SEC3 is based on the approach set out in the 2011 Black Country Core Strategy, which distinguished between Strategic High-Quality Employment Areas and Local Quality Employment Areas. The EDNA recommended that the approach set out in the Core Strategy has served the Sandwell well and, subject to some refinement, should be continued. The Local Employment Areas in the Sandwell Local Plan are the equivalent of the Local Quality Employment Areas in the Core Strategy.

8.29 The characteristics and extent of the Local Employment Areas reflects the findings of the SEAR. The SEAR re-examined all of Sandwell's employment areas against a set of criteria based on those in the Core Strategy and having regard to the recommendations of the EDNA.

8.30 The key characteristics of Local Employment Areas are as follows;

  • a critical mass of active industrial and service uses and premises that are fit for purpose;
  • good access to local markets, suppliers, and employees;
  • the existing or potential use and / or the traffic generated by the use does not have an unacceptable impact on the amenity of surrounding land uses or on the highway network;
  • good public transport accessibility.

8.31 The broad extent of the Local Employment Areas is shown on the Employment Land Key diagram and the detailed boundaries are on the Sandwell Local Plan Policies Map.

8.32 The SLP seeks to safeguard Local Employment Areas as locations for industrial and logistics activity and uses that share the characteristics of Classes E(g)(ii), E(g)(iii)) and B2 and B8 uses, which are typically located within industrial areas.

8.33 The Plan also supports proposals that involve the improvement and renewal of land and premises within them, particularly where this involves older or outdated industrial premises that are no longer fit for purpose. This process of redevelopment, intensification and enhancement of existing Local Employment Areas will help deliver a significant source of land to meet future growth needs.

8.34 Local Employment Areas are often vulnerable to pressure for redevelopment to other uses such as housing. However, the loss of local employment land will compromise the successful delivery of Sandwell's employment strategy. It would inhibit economic development, endanger the viability of businesses and affect the balance of jobs and workers. People working for companies in Local Employment Areas that are displaced by new forms of development would have to travel increased distances to work and the viability and sustainability of those firms would be put at risk. These areas will therefore be primarily safeguarded from non-employment uses.

8.35 Sites within Local Employment Areas may also be appropriate for uses that serve the needs of businesses and employees working in the area. Such uses may include small-scale food and drink provision or childcare facilities. They should be of a scale, nature, and location to serve the needs of an employment area where existing facilities are inadequate or where such needs cannot be met in adjacent centres.

Other Employment Sites

8.36 The Council recognises that there are several older employment areas across Sandwell that are not of the quality of Strategic or Local Employment Areas. Sites and premises within these areas may be suitable for redevelopment for continued employment use, or for alternative uses such as housing. Policy SEC4 provides a flexible policy framework to guide development proposals in these areas. This policy supports Strategic Objectives 2 and 8.

(2) Policy SEC4 – Other Employment Sites

  1. In employment areas that are not designated as either Strategic Employment Areas or Local Employment Areas on the Policies Map, but which comprise land / sites that are currently in use (or if currently vacant, were last used) for employment purposes, development will be supported for:
    1. new industrial employment uses or extensions to existing industrial employment uses, or
    2. housing or other non-ancillary, non-industrial employment uses.
  2. Development or uses under part 1(b) will only be supported where there is robust evidence that:
    1. if the site is vacant, that it has been marketed for employment use for a period of at least 12 months, including by site notice and through the internet or as may be agreed by the local planning authority;
    2. if the site is occupied or part-occupied, that successful engagement has been undertaken with the occupiers to secure their relocation;
    3. if the site forms part of a larger area occupied or last occupied for employment, that residential or any other use will not be adversely affected by the continuing operation of employment uses in the remainder of the area;
    4. the site could be brought forward for housing in a comprehensive manner and would not lead to piecemeal development;
    5. residential development would not adversely affect the ongoing operation of existing or proposed employment uses on the site or nearby; and
    6. the site is suitable for housing or other non-ancillary non-employment uses in accordance with local or national policies relating to these uses.

Justification

8.37 There are various existing employment locations in Sandwell that are not currently designated as either Strategic or Local Employment Areas. They tend to be older, less marketable employment sites close to or within residential areas, which may be in poor physical condition. They are however important to the employment land supply in Sandwell, as they provide smaller-scale and inexpensive sites and premises, suitable for use by companies who do not need, or cannot afford, larger and more modern premises.

8.38 Proposals for redevelopment to other uses could give rise to significant regeneration benefits in some cases on those sites that, when assessed, do not meet the thresholds for being allocated as local employment areas. Larger sites (over 0.4ha) subject to this policy are shown on the Policies Map; smaller sites and areas are not included on it.

8.39 Whilst Sandwell will continue to support these existing businesses, it is also necessary for the SLP to allow flexibility for them to be considered for alternative forms of appropriate development.

8.40 The circumstances where such redevelopment will be permitted are set out in sections 2a – f of the policy. In addressing criteria a and b, applicants will be required to submit an Economic and Market appraisal that demonstrates that the site is unsuitable for continued employment use. The sustainability of the location (including its accessibility by a choice of modes of transport) will be a matter that should be considered in this context.

8.41 In assessing the potential of attracting continued employment use, the Economic and Market Assessment must consider whether the costs of the necessary remediation works would make the reuse or redevelopment for employment uses unviable. The Economic and Market Assessment should also include evidence that the site is vacant (unless it can be demonstrated that occupiers are to be relocated) and has been marketed over a reasonable period and at realistic rental and capital values.

Improving Access to the Labour Market

8.42 Restructuring Sandwell's economy is one of the key principles of the Plan's Vision, but the provision of land and premises alone will not deliver the necessary economic transformation without new skills and training in the workforce to help it meet the challenges of changing work requirements and patterns. This policy supports Strategic Objectives 8 and 9.

Policy SEC5 – Improving Access to the Labour Market

  1. Planning applications for new major (over 1000m2) job-creating development will be required to demonstrate how job opportunities arising from the proposed development will be made available to the residents of Sandwell, particularly those in the most deprived areas of the borough and other priority groups.
  2. Planning conditions or obligations will be negotiated with applicants and applied as appropriate to secure initiatives and /or contributions to a range of measures to benefit the local community, including the potential for working with local colleges and universities, with focuses specifically on training and recruitment with all new developments where possible, to ensure:
    1. the provision of training opportunities to assist residents in accessing employment opportunities;
    2. the provision of support to residents in applying for jobs arising from the development;
    3. enhancement of the accessibility of the development to residents by a choice of means of transport, including walking, cycling and public transport (see Policy STR1);
    4. child-care provision which enables residents to access employment opportunities;
    5. measures to assist those who are disadvantaged and vulnerable, with physical and / or mental health disabilities, to access employment opportunities.
  3. In respect of planning applications for new employment-generating development Sandwell will negotiate with applicants on financial or other contributions, to be secured through planning obligations or the CIL Charging Schedule.

Justification

8.43 The Plan plays a key role in ensuring that people who suffer from social exclusion and disadvantage can contribute fully to the regeneration of Sandwell. It is therefore important that jobs created through new developments across the borough are accessible to as many of Sandwell's residents as possible, especially those in the most deprived areas or who belong to priority groups. In its role as Corporate Parent, the Council is also keen to make sure that care leavers continue to be supported to access suitable training and job opportunities and will respond positively where opportunities become available to ensure this.

8.44 There are several aspects to increasing the accessibility of job opportunities to residents. Firstly, it may be necessary for improvements to public transport infrastructure and services to be funded, and better facilities for pedestrians and cyclists to be provided, to ensure that residents are able to travel to and from their places of employment within reasonable timescales.

8.45 Support may also need to be provided to assist residents, particularly those from disadvantaged groups or areas, in applying for new jobs and to receive training that will assist them in accessing employment opportunities. Childcare provision may also help in enhancing access to employment and individuals with mental or physical health difficulties may also require additional support to enable them to access jobs.

8.46 There are existing support structures and facilities in place across the sub-region to help ensure that local people can access and receive appropriate training to develop the necessary skills to compete successfully for jobs.

8.47 To assist with this, where major new employment-creating development is proposed, the Council's Social Value Team will implement a social value delivery plan and negotiate with companies to devise suitable bespoke training and recruitment programmes that can benefit local people, educational and community organisations[185].

8.48 Attracting graduates to, and retaining them within, Sandwell will also be key to securing the growth of a knowledge-based economy. The higher and further education sector is a major driver of economic, social and cultural regeneration and ongoing investment in this sector is supported. The Council will also support initiatives that strengthen linkages between the education sector and the wider economy.

Relationship between Industry and Sensitive Uses

8.49 As Sandwell is a predominantly urban area, there are parts of the Borough where industrial sites and premises are situated adjacent to sensitive uses such as residential, which can lead to adverse effects on neighbouring uses.

Policy SEC6 – Relationship between Industry and Sensitive Uses

  1. Proposals for new industrial development that is likely to have an adverse effect[186] on neighbouring uses will not be permitted, unless the adverse effects can be reduced to an acceptable level, by means of a buffer[187] or other robust mitigation measures.
  2. Equally, new proposals that may adversely affect, or be adversely affected by, existing industry operating in appropriate locations will not be permitted unless the adverse effects can be reduced to an acceptable level. Where this is to be achieved by means of a buffer, the new development will be required to provide and maintain the buffer.
  3. Where existing industry operates within residential areas the Council will seek to ensure that any harmful effects are mitigated. If necessary, the Council will consider the enforcement of appropriate regulations or other means to reduce the problem.

Justification

8.50 As Sandwell is an urban borough with a thriving industrial and manufacturing based economy, there are areas within it where employment land is situated adjacent to sensitive uses. There is the potential for housing to be adversely affected by the businesses operating in these areas.

8.51 Equally, given pressure on older and underused industrial areas to be redeveloped for housing, the existing businesses operating in these areas should not have unreasonable restrictions placed on them because of development permitted after they were established. Where the operation of an existing business could have an adverse effect on new development (including change of use) in its vicinity, the applicant for the incoming development will be required to provide suitable mitigation measures before the development is completed.

8.52 This is dealt with in the NPPF[188] as the "agents of change" principle. This places the responsibility for mitigating impacts from existing noise-generating activities or uses on the proposed new noise-sensitive development; effectively, the person or business responsible for creating the conditions causing the change must also be responsible for managing the impact of it on the new / potential occupants.

[178] Prepared by Warwick Economics & Development Limited (WECD)

[179] Led by the Black Country Local Planning Authorities

[180] National Planning Practice Guidance states that economic needs should be assessed in relation to relevant Functional Economic Market Areas (FEMAs), that is, the spatial level at which local economies and markets actually operate.

[181] Of which 28ha is currently vacant, while 1,193ha is existing occupied employment land (2023)

[182] In Use Classes E(g)(ii), E(g)(iii), B2, and B8

[183] The circular economy is a model of production and consumption, which involves sharing, leasing, reusing, repairing, refurbishing and recycling existing materials and products as long as possible (https://www.europarl.europa.eu/news/en/headlines/economy/20151201STO05603/circular-economy-definition-importance-and-benefits#:~:text=The%20circular%20economy%20is%20a,products%20as%20long%20as%20possible).

[184] Classes E(g)(ii), E(g)(iii), B2 and B8 uses.

[185] https://sandwellbusinessgrowth.com/run-your-business/responsible-business/csr-and-social-value/

[186] E.g., excessive traffic, pollution (air, noise, fumes, water, soil), disturbance, visual amenity etc.

[187] An appropriate buffer may take a variety of forms such as open space, a landscaped area, a wall or other physical barrier.

[188] Paragraph 193 (NPPF, December 2023)

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