Policy P2 provides no clarity over the strategy for Chelmsley Wood Town Centre and is poorly written. It needs amending to ensure retail and leisure uses within
the core of the centre remain protected and are not diluted by additional edge of centre development which the current wording appears to support.

The policy needs to be redrafted to provide clarity to its purpose. It should include reference to a primary shopping area which is then annotated on the
Proposals Map.
It should also have clear reference to the Chelmsley Wood Masterplan and provide guidance on the extent and acceptable locations for additional uses.

Ellandi object to the current wording of Policy P2. As set out in our representations of 22 January 2016 and 9 February 2017, the new Local Plan is not based on up to
date evidence of retail and leisure need. The evidence that is currently relied upon is significantly out of date and does not reflect the scale of development now
proposed for the Borough and the timing of that development.
The anticipated timing of the substantial growth in the Borough will influence the phasing for when and where the Local Plan seeks to deliver plan led retail and
leisure need and the preferred strategy for doing this. These considerations will in turn influence how the sequential and impact tests within the NPPF are interpreted and drafted within the new Local Plan. At present it simply defers to the NPPF which is a missed opportunity to provide a robust and locally focused strategy that fosters investor confidence. The NPPF requires plan led need to be met in full and therefore
the Local Plan must grapple with how to do this in the most sustainable manner that supports the overall vision for Solihull.
In addition, SMBC should undertake an assessment of thresholds to identify a locally set threshold or thresholds over which impact assessment will be required for retail
uses. The NPPF threshold of 2,500 sqm is too high, particularly in areas where town centres are vulnerable and even a small out of centre scheme could have a
disproportionate effect on the vitality and viability of the centre. Our experience of the NPPF threshold is that developers of out of centre proposals deliberately size a
scheme just under the NPPF threshold on the basis of there not being a unit available within a town centre location that meets all of the operational requirements of
an occupier. This then allows the applicant to circumvent the requirement to assess the proposals against the impact test - the NPPF is clear that this is only required over the nationally set threshold or where a locally set threshold, based on robust evidence, is set. We would therefore raise again that research led by SMBC should
be undertaken to assess where the current balance of unit sizes lies in each of the
Borough’s town, district and local centres. A suitable threshold or thresholds can then be set which supports the spatial strategy for the Plan.
In addition, thresholds for impact assessment in relation to town centre uses at Arden Cross, Birmingham Business Park and Blythe Valley Business Park should be set.
Otherwise there is no mechanism by which to assess whether the scale of development is commensurate with serving those developments only; which is the intention
of the policies as drafted.
One further point is in relation to objective 15 of Policy P2. This policy is not effective or consistent with national policy. It seeks to encourage new development on the
edge of the town centre for a diverse range of uses. This has the potential to undermine the strength of Chelmsley Wood Shopping Centre if this is effectively giving support to competing retail and leisure town centre uses in an edge of centre location. The policy needs to be redrafted to give clarity to its purpose.