Draft Regulation 18 Sandwell Local Plan

5215: LAND AT GRANVILLE WORKS, STATION ROAD, CRADLEY HEATH, WEST
MIDLANDS, B64 6PW.

We are writing to provide you with our comments on the current consultation document on behalf of our client Palmer Timber Limited and the above site in their ownership.

We have reviewed the Draft regulation 18 consultation document and we welcome the opportunity to submit comments to the above consultation.

The above site is located off Station Road, Cradley Heath and is a large employment/ industrial site of approximately 2.96 hectares. The site has been in employment related uses for well over one hundred years, during which time the company has been expanding into the land which was purchased, with a significant amount still available for further development.

In the current adopted Sandwell Site Allocations and Delivery DPD (SAD) the site has a designation as a residential site (H13.7). the land surrounding the site has a designation of a SLINC 92.
[see attachment for extract from SAD - inserted figure]

Residential Siles Sandwe/1 Site Allocations and Delivery DPD (SAD) Policies map

The SAD states,
[see attachment for extract from SAD - Area 13.7 - Haden Hill]

We consider the current designation remains wholly appropriate for the site and the surrounding land.

However, we note in the current consultation document the above site has a proposed designation of Local Employment Area and as a wildlife corridor.

[see attachment for extract from Sandwell Local Plan interactive policies map and Policy SEC3 and Policy SNE1] ]

Policy SEC3 - Local Employment Area

Proposed Local Employment Area designation - Current Housing site allocation

We are disappointed to see the housing designation has been removed from the site as we consider the site has ongoing potential to accommodate residential development. The site is surrounded by existing residential development to the east, west and south and therefore is in a location which is suitable to support additional residential development.

We do not consider there is the requirement for the site to be removed from the Local Plan as having potential to accommodate residential development during the emerging plan period.

The circumstance of the site that warranted its allocation for residential housing in the current adopted plan remain unchanged and therefore the site should retain its designation as a potential residential site.

The site is a brownfield site in a sustainable location which offers excellent potential as a future residential site.

My client, in correspondence with the Council, highlighted that the site is in employment use currently, however, the business is under constant review and the current view on the site may be subject to change over the medium-long term.

This indicated that there could be potential for redevelopment of the site to housing in the medium -long term, during the emerging plan period. Therefore, removing the residential development allocation on the site will hinder the forward planning potential of the site and risk a site become vacant and derelict should employment uses on site no longer be viable.

One of the main objectives of the National Planning Policy Framework (NPPF) is to significantly boost the supply of houses, (paragraph 60, NPPF, 2023), the policy states "it is important that a sufficient amount and variety of land can come forward'.

We therefore consider removing allocated housing sites from the emerging Local Plan is not in accordance with National policy.

This is ever more evident when considered against the housing land supply for Sandwell. The Sandwell Authority Monitoring Report 2021-2022, which is the most up to date report on the Council's website this documents states, "The Local Housing Need figure is calculated within the SHLAA. The annual requirement is 1515 homes per annum which equates to 7,575 units for the 5-year period 2022-2027. Including a 20% buffer, as required by the Housing Delivery Test, the five-year supply of deliverable sites required to meet local housing need would therefore be 9,090 net homes. The SHLAA explains that 2,850 homes (without discounts) are deliverable. This means that Sandwe/1 cannot demonstrate a five-year supply of housing land." (Sandwe/1 Authority Monitoring Report 2021-2022, 5.2 - Housing Land Supply, Five-year supply position at April 2022)

Retaining the site as a residential site allows the Local Plan, and the site itself, flexibility to adapt to changing circumstances (such as economic/ political change), providing the ability to accommodate much needed housing. This would therefore assist with the plan being consider positively prepared, justified, effective and consistent with national policy, thus the plan being found sound.

It is important to note that there remains a housing supply shortfall within the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) as confirm by the Position Statement Addendum, April 2023, therefore the inclusion of the site as an additional housing

site will not also assist with identifying sufficient land to meet the housing requirements for the wider housing market area but also assists with the Council fulfilling their duty to cooperate.

We therefore object to the proposed removal of the housing allocation on the above site, and request for that allocation to be reinstated in the emerging Local Plan.

SNE1 - Nature Conservation Wildlife Corridor/SLINC
In the emerging Local Plan, the site has been given a designation as wildlife corridor. This designation encompasses not only the areas of surrounding trees and shrubbery which forms a boundary to the site, but the employment/ industrial land also.

We object to this proposed policy and consider this designation to be inappropriate and unnecessary.

We also consider the proposed Nature Conservation policy SNE1, conflicts with policy SEC3
- Local Employment Areas. 2qwas

The Palmers Timber Site, Station Road, as previously stated, has been in employment use for a significant period of time and is currently in active use.

We consider the site should retain its current designation as a residential site as discussed above, however, against the proposed policy SEC3, policy SNE1 is overly prescriptive and would hinder employment related development/ redevelopment on the site with the requirements for policy SNE1 4, 5 and 6.

We consider this to be contrary NPPF paragraph 81 which states, "Planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development."

The requirements of policy SNE1 and the impacts they could potentially have on the site could result in negative outcomes to Palmers Timber Limited and their continued future use of the site. Should my clients wish to expand their business and increase development on site, the proposed policy may hinder their ability to further the business, therefore potentially requiring an alternative site being sourced. Thus, resulting in the loss of an important business/ employer in the area and resulting in a vacant site at risk of becoming derelict.

The site is heavily developed with significant areas of concrete/ tarmac which is use as parking areas and storage. There are a number of very large industrial/ employment buildings which are all in active use. There are several large vehicle movements throughout the site regularly.

There is no part of the built development which acts as a wildlife corridor/ SLINC that would require a formal designation over the whole site.

[see attachment for Aerial view of the Palmer Timber site]

The above ariel photography highlights the stark contrast between the surrounding flora and the built development of the site.

We also question and object to the designation of the SLING/wildlife corridor surrounding the developed part of the site, as we do not consider there is significant justification for the land to be designated as a SLING.

We fail to see any justification for the current designation of the land as a Wildlife corridor/ SLING. We understand that the current and proposed designations are carried forward from the Unitary Development Plan (UDP) 2004 and the SAD 2012 and this is the reason for its continued designation, not because the site has any continued local importance for nature conservation.

We do not consider the land warrants the designation of a wildlife corridor/SLING and object to the proposed designation.

We therefore object to this policy and consider the wildlife corridor designation should be removed from the site.

We consider sufficient information has been provided to enable the Council to determine the above request and therefore look forward to receiving your feedback.

In the meantime, we trust the above is clear, however, if anything further is required, please do not hesitate to contact me.

5215: LAND AT GRANVILLE WORKS, STATION ROAD, CRADLEY HEATH, WEST
MIDLANDS, B64 6PW.

We are writing to provide you with our comments on the current consultation document on behalf of our client Palmer Timber Limited and the above site in their ownership.

We have reviewed the Draft regulation 18 consultation document and we welcome the opportunity to submit comments to the above consultation.

The above site is located off Station Road, Cradley Heath and is a large employment/ industrial site of approximately 2.96 hectares. The site has been in employment related uses for well over one hundred years, during which time the company has been expanding into the land which was purchased, with a significant amount still available for further development.

In the current adopted Sandwell Site Allocations and Delivery DPD (SAD) the site has a designation as a residential site (H13.7). the land surrounding the site has a designation of a SLINC 92.
[see attachment for extract from SAD - inserted figure]

Residential Siles Sandwe/1 Site Allocations and Delivery DPD (SAD) Policies map

The SAD states,
[see attachment for extract from SAD - Area 13.7 - Haden Hill]

We consider the current designation remains wholly appropriate for the site and the surrounding land.

However, we note in the current consultation document the above site has a proposed designation of Local Employment Area and as a wildlife corridor.

[see attachment for extract from Sandwell Local Plan interactive policies map and Policy SEC3 and Policy SNE1] ]

Policy SEC3 - Local Employment Area

Proposed Local Employment Area designation - Current Housing site allocation

We are disappointed to see the housing designation has been removed from the site as we consider the site has ongoing potential to accommodate residential development. The site is surrounded by existing residential development to the east, west and south and therefore is in a location which is suitable to support additional residential development.

We do not consider there is the requirement for the site to be removed from the Local Plan as having potential to accommodate residential development during the emerging plan period.

The circumstance of the site that warranted its allocation for residential housing in the current adopted plan remain unchanged and therefore the site should retain its designation as a potential residential site.

The site is a brownfield site in a sustainable location which offers excellent potential as a future residential site.

My client, in correspondence with the Council, highlighted that the site is in employment use currently, however, the business is under constant review and the current view on the site may be subject to change over the medium-long term.

This indicated that there could be potential for redevelopment of the site to housing in the medium -long term, during the emerging plan period. Therefore, removing the residential development allocation on the site will hinder the forward planning potential of the site and risk a site become vacant and derelict should employment uses on site no longer be viable.

One of the main objectives of the National Planning Policy Framework (NPPF) is to significantly boost the supply of houses, (paragraph 60, NPPF, 2023), the policy states "it is important that a sufficient amount and variety of land can come forward'.

We therefore consider removing allocated housing sites from the emerging Local Plan is not in accordance with National policy.

This is ever more evident when considered against the housing land supply for Sandwell. The Sandwell Authority Monitoring Report 2021-2022, which is the most up to date report on the Council's website this documents states, "The Local Housing Need figure is calculated within the SHLAA. The annual requirement is 1515 homes per annum which equates to 7,575 units for the 5-year period 2022-2027. Including a 20% buffer, as required by the Housing Delivery Test, the five-year supply of deliverable sites required to meet local housing need would therefore be 9,090 net homes. The SHLAA explains that 2,850 homes (without discounts) are deliverable. This means that Sandwe/1 cannot demonstrate a five-year supply of housing land." (Sandwe/1 Authority Monitoring Report 2021-2022, 5.2 - Housing Land Supply, Five-year supply position at April 2022)

Retaining the site as a residential site allows the Local Plan, and the site itself, flexibility to adapt to changing circumstances (such as economic/ political change), providing the ability to accommodate much needed housing. This would therefore assist with the plan being consider positively prepared, justified, effective and consistent with national policy, thus the plan being found sound.

It is important to note that there remains a housing supply shortfall within the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) as confirm by the Position Statement Addendum, April 2023, therefore the inclusion of the site as an additional housing

site will not also assist with identifying sufficient land to meet the housing requirements for the wider housing market area but also assists with the Council fulfilling their duty to cooperate.

We therefore object to the proposed removal of the housing allocation on the above site, and request for that allocation to be reinstated in the emerging Local Plan.

SNE1 - Nature Conservation Wildlife Corridor/SLINC
In the emerging Local Plan, the site has been given a designation as wildlife corridor. This designation encompasses not only the areas of surrounding trees and shrubbery which forms a boundary to the site, but the employment/ industrial land also.

We object to this proposed policy and consider this designation to be inappropriate and unnecessary.

We also consider the proposed Nature Conservation policy SNE1, conflicts with policy SEC3
- Local Employment Areas. 2qwas

The Palmers Timber Site, Station Road, as previously stated, has been in employment use for a significant period of time and is currently in active use.

We consider the site should retain its current designation as a residential site as discussed above, however, against the proposed policy SEC3, policy SNE1 is overly prescriptive and would hinder employment related development/ redevelopment on the site with the requirements for policy SNE1 4, 5 and 6.

We consider this to be contrary NPPF paragraph 81 which states, "Planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development."

The requirements of policy SNE1 and the impacts they could potentially have on the site could result in negative outcomes to Palmers Timber Limited and their continued future use of the site. Should my clients wish to expand their business and increase development on site, the proposed policy may hinder their ability to further the business, therefore potentially requiring an alternative site being sourced. Thus, resulting in the loss of an important business/ employer in the area and resulting in a vacant site at risk of becoming derelict.

The site is heavily developed with significant areas of concrete/ tarmac which is use as parking areas and storage. There are a number of very large industrial/ employment buildings which are all in active use. There are several large vehicle movements throughout the site regularly.

There is no part of the built development which acts as a wildlife corridor/ SLINC that would require a formal designation over the whole site.

[see attachment for Aerial view of the Palmer Timber site]

The above ariel photography highlights the stark contrast between the surrounding flora and the built development of the site.

We also question and object to the designation of the SLING/wildlife corridor surrounding the developed part of the site, as we do not consider there is significant justification for the land to be designated as a SLING.

We fail to see any justification for the current designation of the land as a Wildlife corridor/ SLING. We understand that the current and proposed designations are carried forward from the Unitary Development Plan (UDP) 2004 and the SAD 2012 and this is the reason for its continued designation, not because the site has any continued local importance for nature conservation.

We do not consider the land warrants the designation of a wildlife corridor/SLING and object to the proposed designation.

We therefore object to this policy and consider the wildlife corridor designation should be removed from the site.

We consider sufficient information has been provided to enable the Council to determine the above request and therefore look forward to receiving your feedback.

In the meantime, we trust the above is clear, however, if anything further is required, please do not hesitate to contact me.

5215: LAND AT GRANVILLE WORKS, STATION ROAD, CRADLEY HEATH, WEST
MIDLANDS, B64 6PW.

We are writing to provide you with our comments on the current consultation document on behalf of our client Palmer Timber Limited and the above site in their ownership.

We have reviewed the Draft regulation 18 consultation document and we welcome the opportunity to submit comments to the above consultation.

The above site is located off Station Road, Cradley Heath and is a large employment/ industrial site of approximately 2.96 hectares. The site has been in employment related uses for well over one hundred years, during which time the company has been expanding into the land which was purchased, with a significant amount still available for further development.

In the current adopted Sandwell Site Allocations and Delivery DPD (SAD) the site has a designation as a residential site (H13.7). the land surrounding the site has a designation of a SLINC 92.
[see attachment for extract from SAD - inserted figure]

Residential Siles Sandwe/1 Site Allocations and Delivery DPD (SAD) Policies map

The SAD states,
[see attachment for extract from SAD - Area 13.7 - Haden Hill]

We consider the current designation remains wholly appropriate for the site and the surrounding land.

However, we note in the current consultation document the above site has a proposed designation of Local Employment Area and as a wildlife corridor.

[see attachment for extract from Sandwell Local Plan interactive policies map and Policy SEC3 and Policy SNE1] ]

Policy SEC3 - Local Employment Area

Proposed Local Employment Area designation - Current Housing site allocation

We are disappointed to see the housing designation has been removed from the site as we consider the site has ongoing potential to accommodate residential development. The site is surrounded by existing residential development to the east, west and south and therefore is in a location which is suitable to support additional residential development.

We do not consider there is the requirement for the site to be removed from the Local Plan as having potential to accommodate residential development during the emerging plan period.

The circumstance of the site that warranted its allocation for residential housing in the current adopted plan remain unchanged and therefore the site should retain its designation as a potential residential site.

The site is a brownfield site in a sustainable location which offers excellent potential as a future residential site.

My client, in correspondence with the Council, highlighted that the site is in employment use currently, however, the business is under constant review and the current view on the site may be subject to change over the medium-long term.

This indicated that there could be potential for redevelopment of the site to housing in the medium -long term, during the emerging plan period. Therefore, removing the residential development allocation on the site will hinder the forward planning potential of the site and risk a site become vacant and derelict should employment uses on site no longer be viable.

One of the main objectives of the National Planning Policy Framework (NPPF) is to significantly boost the supply of houses, (paragraph 60, NPPF, 2023), the policy states "it is important that a sufficient amount and variety of land can come forward'.

We therefore consider removing allocated housing sites from the emerging Local Plan is not in accordance with National policy.

This is ever more evident when considered against the housing land supply for Sandwell. The Sandwell Authority Monitoring Report 2021-2022, which is the most up to date report on the Council's website this documents states, "The Local Housing Need figure is calculated within the SHLAA. The annual requirement is 1515 homes per annum which equates to 7,575 units for the 5-year period 2022-2027. Including a 20% buffer, as required by the Housing Delivery Test, the five-year supply of deliverable sites required to meet local housing need would therefore be 9,090 net homes. The SHLAA explains that 2,850 homes (without discounts) are deliverable. This means that Sandwe/1 cannot demonstrate a five-year supply of housing land." (Sandwe/1 Authority Monitoring Report 2021-2022, 5.2 - Housing Land Supply, Five-year supply position at April 2022)

Retaining the site as a residential site allows the Local Plan, and the site itself, flexibility to adapt to changing circumstances (such as economic/ political change), providing the ability to accommodate much needed housing. This would therefore assist with the plan being consider positively prepared, justified, effective and consistent with national policy, thus the plan being found sound.

It is important to note that there remains a housing supply shortfall within the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) as confirm by the Position Statement Addendum, April 2023, therefore the inclusion of the site as an additional housing

site will not also assist with identifying sufficient land to meet the housing requirements for the wider housing market area but also assists with the Council fulfilling their duty to cooperate.

We therefore object to the proposed removal of the housing allocation on the above site, and request for that allocation to be reinstated in the emerging Local Plan.

SNE1 - Nature Conservation Wildlife Corridor/SLINC
In the emerging Local Plan, the site has been given a designation as wildlife corridor. This designation encompasses not only the areas of surrounding trees and shrubbery which forms a boundary to the site, but the employment/ industrial land also.

We object to this proposed policy and consider this designation to be inappropriate and unnecessary.

We also consider the proposed Nature Conservation policy SNE1, conflicts with policy SEC3
- Local Employment Areas. 2qwas

The Palmers Timber Site, Station Road, as previously stated, has been in employment use for a significant period of time and is currently in active use.

We consider the site should retain its current designation as a residential site as discussed above, however, against the proposed policy SEC3, policy SNE1 is overly prescriptive and would hinder employment related development/ redevelopment on the site with the requirements for policy SNE1 4, 5 and 6.

We consider this to be contrary NPPF paragraph 81 which states, "Planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development."

The requirements of policy SNE1 and the impacts they could potentially have on the site could result in negative outcomes to Palmers Timber Limited and their continued future use of the site. Should my clients wish to expand their business and increase development on site, the proposed policy may hinder their ability to further the business, therefore potentially requiring an alternative site being sourced. Thus, resulting in the loss of an important business/ employer in the area and resulting in a vacant site at risk of becoming derelict.

The site is heavily developed with significant areas of concrete/ tarmac which is use as parking areas and storage. There are a number of very large industrial/ employment buildings which are all in active use. There are several large vehicle movements throughout the site regularly.

There is no part of the built development which acts as a wildlife corridor/ SLINC that would require a formal designation over the whole site.

[see attachment for Aerial view of the Palmer Timber site]

The above ariel photography highlights the stark contrast between the surrounding flora and the built development of the site.

We also question and object to the designation of the SLING/wildlife corridor surrounding the developed part of the site, as we do not consider there is significant justification for the land to be designated as a SLING.

We fail to see any justification for the current designation of the land as a Wildlife corridor/ SLING. We understand that the current and proposed designations are carried forward from the Unitary Development Plan (UDP) 2004 and the SAD 2012 and this is the reason for its continued designation, not because the site has any continued local importance for nature conservation.

We do not consider the land warrants the designation of a wildlife corridor/SLING and object to the proposed designation.

We therefore object to this policy and consider the wildlife corridor designation should be removed from the site.

We consider sufficient information has been provided to enable the Council to determine the above request and therefore look forward to receiving your feedback.

In the meantime, we trust the above is clear, however, if anything further is required, please do not hesitate to contact me.

5215: LAND AT GRANVILLE WORKS, STATION ROAD, CRADLEY HEATH, WEST
MIDLANDS, B64 6PW.

We are writing to provide you with our comments on the current consultation document on behalf of our client Palmer Timber Limited and the above site in their ownership.

We have reviewed the Draft regulation 18 consultation document and we welcome the opportunity to submit comments to the above consultation.

The above site is located off Station Road, Cradley Heath and is a large employment/ industrial site of approximately 2.96 hectares. The site has been in employment related uses for well over one hundred years, during which time the company has been expanding into the land which was purchased, with a significant amount still available for further development.

In the current adopted Sandwell Site Allocations and Delivery DPD (SAD) the site has a designation as a residential site (H13.7). the land surrounding the site has a designation of a SLINC 92.
[see attachment for extract from SAD - inserted figure]

Residential Siles Sandwe/1 Site Allocations and Delivery DPD (SAD) Policies map

The SAD states,
[see attachment for extract from SAD - Area 13.7 - Haden Hill]

We consider the current designation remains wholly appropriate for the site and the surrounding land.

However, we note in the current consultation document the above site has a proposed designation of Local Employment Area and as a wildlife corridor.

[see attachment for extract from Sandwell Local Plan interactive policies map and Policy SEC3 and Policy SNE1] ]

Policy SEC3 - Local Employment Area

Proposed Local Employment Area designation - Current Housing site allocation

We are disappointed to see the housing designation has been removed from the site as we consider the site has ongoing potential to accommodate residential development. The site is surrounded by existing residential development to the east, west and south and therefore is in a location which is suitable to support additional residential development.

We do not consider there is the requirement for the site to be removed from the Local Plan as having potential to accommodate residential development during the emerging plan period.

The circumstance of the site that warranted its allocation for residential housing in the current adopted plan remain unchanged and therefore the site should retain its designation as a potential residential site.

The site is a brownfield site in a sustainable location which offers excellent potential as a future residential site.

My client, in correspondence with the Council, highlighted that the site is in employment use currently, however, the business is under constant review and the current view on the site may be subject to change over the medium-long term.

This indicated that there could be potential for redevelopment of the site to housing in the medium -long term, during the emerging plan period. Therefore, removing the residential development allocation on the site will hinder the forward planning potential of the site and risk a site become vacant and derelict should employment uses on site no longer be viable.

One of the main objectives of the National Planning Policy Framework (NPPF) is to significantly boost the supply of houses, (paragraph 60, NPPF, 2023), the policy states "it is important that a sufficient amount and variety of land can come forward'.

We therefore consider removing allocated housing sites from the emerging Local Plan is not in accordance with National policy.

This is ever more evident when considered against the housing land supply for Sandwell. The Sandwell Authority Monitoring Report 2021-2022, which is the most up to date report on the Council's website this documents states, "The Local Housing Need figure is calculated within the SHLAA. The annual requirement is 1515 homes per annum which equates to 7,575 units for the 5-year period 2022-2027. Including a 20% buffer, as required by the Housing Delivery Test, the five-year supply of deliverable sites required to meet local housing need would therefore be 9,090 net homes. The SHLAA explains that 2,850 homes (without discounts) are deliverable. This means that Sandwe/1 cannot demonstrate a five-year supply of housing land." (Sandwe/1 Authority Monitoring Report 2021-2022, 5.2 - Housing Land Supply, Five-year supply position at April 2022)

Retaining the site as a residential site allows the Local Plan, and the site itself, flexibility to adapt to changing circumstances (such as economic/ political change), providing the ability to accommodate much needed housing. This would therefore assist with the plan being consider positively prepared, justified, effective and consistent with national policy, thus the plan being found sound.

It is important to note that there remains a housing supply shortfall within the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) as confirm by the Position Statement Addendum, April 2023, therefore the inclusion of the site as an additional housing

site will not also assist with identifying sufficient land to meet the housing requirements for the wider housing market area but also assists with the Council fulfilling their duty to cooperate.

We therefore object to the proposed removal of the housing allocation on the above site, and request for that allocation to be reinstated in the emerging Local Plan.

SNE1 - Nature Conservation Wildlife Corridor/SLINC
In the emerging Local Plan, the site has been given a designation as wildlife corridor. This designation encompasses not only the areas of surrounding trees and shrubbery which forms a boundary to the site, but the employment/ industrial land also.

We object to this proposed policy and consider this designation to be inappropriate and unnecessary.

We also consider the proposed Nature Conservation policy SNE1, conflicts with policy SEC3
- Local Employment Areas. 2qwas

The Palmers Timber Site, Station Road, as previously stated, has been in employment use for a significant period of time and is currently in active use.

We consider the site should retain its current designation as a residential site as discussed above, however, against the proposed policy SEC3, policy SNE1 is overly prescriptive and would hinder employment related development/ redevelopment on the site with the requirements for policy SNE1 4, 5 and 6.

We consider this to be contrary NPPF paragraph 81 which states, "Planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development."

The requirements of policy SNE1 and the impacts they could potentially have on the site could result in negative outcomes to Palmers Timber Limited and their continued future use of the site. Should my clients wish to expand their business and increase development on site, the proposed policy may hinder their ability to further the business, therefore potentially requiring an alternative site being sourced. Thus, resulting in the loss of an important business/ employer in the area and resulting in a vacant site at risk of becoming derelict.

The site is heavily developed with significant areas of concrete/ tarmac which is use as parking areas and storage. There are a number of very large industrial/ employment buildings which are all in active use. There are several large vehicle movements throughout the site regularly.

There is no part of the built development which acts as a wildlife corridor/ SLINC that would require a formal designation over the whole site.

[see attachment for Aerial view of the Palmer Timber site]

The above ariel photography highlights the stark contrast between the surrounding flora and the built development of the site.

We also question and object to the designation of the SLING/wildlife corridor surrounding the developed part of the site, as we do not consider there is significant justification for the land to be designated as a SLING.

We fail to see any justification for the current designation of the land as a Wildlife corridor/ SLING. We understand that the current and proposed designations are carried forward from the Unitary Development Plan (UDP) 2004 and the SAD 2012 and this is the reason for its continued designation, not because the site has any continued local importance for nature conservation.

We do not consider the land warrants the designation of a wildlife corridor/SLING and object to the proposed designation.

We therefore object to this policy and consider the wildlife corridor designation should be removed from the site.

We consider sufficient information has been provided to enable the Council to determine the above request and therefore look forward to receiving your feedback.

In the meantime, we trust the above is clear, however, if anything further is required, please do not hesitate to contact me.