The key deficiencies can be summarised as follows:
1. The Solihull Retail, Leisure and Office Study 2009 (refreshed 2011) is out of date. This was recognised by the Council at page 115 of the November 2015
consultation but no work has been undertaken to bring the Study up to date, which is necessary owing to the significant structural changes planned within the Borough. This includes accommodating a proportion of the Birmingham overspill housing numbers and the iunclusion of Arden Cross.
Expenditure data and retail need will now be fundamentally different to that previously identified.
2. Without an up to date retail and leisure evidence base, the full quantitative and qualitative needs for the Borough are unknown. It is therefore not possible for the Plan to identify how and when these needs will be met in full and whether these will be delivered sustainably. This is a clear requirement of the NPPF.
3. The emerging Plan does not deal with the requirements of the NPPF to clearly define on a plan(s) the primary shopping areas for defined centres.
This is required to inform the application of the sequential and impact tests.
4. The Council has not assessed whether a locally set threshold for impact assessment is required. At present the Local Plan defers to the National Planning Policy Framework (NPPF) which sets a substantial threshold of 2,500 sqm over which an impact assessment should be undertaken. This is sufficient floorspace to accommodate a full range foodstore or an entire neighbourhood centre. Such a quantum of floorspace is of concern as retail schemes of this size would impact significantly on more vulnerable centres such as
Chelmsley Wood. A lower threshold should be explored and incorporated into the Local Plan – this threshold should have regard to the economic disparities in the Borough and as such could be set at different levels to
reflect local markets.
5. The emerging policies covering Blythe Valley Business Park and HS2 Interchange require far more clarity on the scale and type of retail that will be
permissible. Uncertainty as to the scale of retail floorspace to be delivered in these locations will put investment in established town centres and regeneration
areas at risk. Any allocations for retail in these locations should be guided by updated retail evidence that also factors in timescales for delivery of anticipated growth.
6. The term ‘commercial development’ and ‘employment uses’ is used throughout the emerging Local Plan and seems to be used interchangeably to describe a number of different uses. The Local Plan should be clear what
is meant by commercial development in the context of the Local Plan to avoid confusion and potential unintended consequences.
In summary, the focus of the spatial strategy is very much on the objectively assessed need for housing and major economic (Use Classes E(B)/(G), B2 and B8)
development schemes with less regard for the integral spatial planning requirements for retail and leisure uses. The evidence underpinning the retail and leisure
requirements of the Plan are out of date and need to be updated and incorporated within the body of the Plan to inform site allocations.