Object

Representation ID: 14200

Received: 14/12/2020

Respondent: IM Properties - Employment Land

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The employment land supply set out in Policy P3 is inadequate to meet the longer term needs of the borough for industrial and warehousing land. This is based on two premises:
(a) The HEDNA underestimates local industrial and warehousing need by some margin
(b) The plan does not address the acknowledged need for strategic employment sites based on the 2015 study

Policy P3 should plan for a higher amount of industrial floorspace (between 22.1 and 60.7ha ) than what was concluded in the HEDNA.

The approach of the HEDNA is justified however there are a number of shortcomings to the specific method used by the HEDNA:

• Tables 101 and 102 appear to contain errors, incorrectly transposing the VOA data cited at Table 100;
• The decision to use only a two year margin is insufficiently justified where it is commonplace to apply a more generous five year margin, to ensure sufficient flexibility in the supply calculated as being needed; and
• There is insufficient justification for the dismissal of recent evidence of much stronger growth in the industrial stock, when focusing on the period back to 2011 rather than the longer-term period back to 2001.

Recent employment changes have been the result of structural changes in the distribution and retail / e-commerce markets which are acknowledged within the HEDNA. The UK has emerged as the third largest online shopping market in the world and the largest in Europe.

The demand for logistics space is directly related to changes in the size of the population. The HEDNA confirms, with reference to various scenarios, including one incorporating the UKC Hub, that the population of Solihull is projected to increase significantly. It has been evidenced that as the population grows, there is likely to be a corresponding increase in consumer demand and the need for warehouse space. The HEDNA confirms that the population of Solihull has grown at a greater rate over more recent years, with Figure 9 suggesting that the rate of growth will increase to an even greater extent when meeting even the minimum need for housing implied by the standard method.

Using VOA data and incorporating data from March 2020 the annual net change in industrial/warehouse floorspace shows a rising trend in the past decade. Last year’s data (2019/20) shows a new record level of growth, a continuation of the short-term trend would see more pronounced growth than the longer-term trend.
Accounting for last years growth would identify a greater need than the 16ha concluded in the HEDNA. Even if the short-term trend was not sustained it would be reasonable to conclude that a more representative position would fall somewhere within this range of between 19 and 52 ha. In the context of the evidence relating to sustained growth of e-commerce and a projected strong local growth in population that the upper end is more likely to represent a reasonable level of need to be planned for, to ensure the plan’s resilience.
Even the lower end of this need aligns with the Labour Demand Growth Scenario identifying a need for 19.1 ha, this should be the absolute minimum to be planned for. If flexibility of 5 years take up was included it would be sensible to plan for between 22.1 and 60.7ha.
This strongly indicates that the shortfall in industrial land to which the Plan should respond, in quantitative terms alone, is much higher than concluded in the HEDNA.