Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14206
Received: 14/12/2020
Respondent: IM Properties - Employment Land
Agent: Turley
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
No specific reference is made to Mell Square within this policy. Clause (7) of Policy P2 states that “A range of opportunity sites will be identified under this policy”. However, it is not clear where these sites will be identified. There seems to be no link made to the emerging Town Centre Masterplan, and it is not clear whether it is intended that the Masterplan will contain relevant information about these ‘opportunity sites’. IM would suggest that clause (7) is clarified, and that reference is made to the Town Centre Masterplan or any other documents as appropriate
The supporting text is inconsistent in how it refers to the ‘Town Centre’. At paragraph 116, bullet four, reference is made to the ‘Heart of Solihull’ area, but it is not clear from the text what area this relates too. Paragraph 116 of the Plan sets out a list of the “primary retail frontages” where retailing activity should remain the main street level use. Specific reference is made within bullet four of point two to ‘Mell Square’.IM are concerned that this approach to protecting retail frontage is too restrictive to allow delivery of the flexibility that is referred to within the main Policy.
It would be more appropriate for this supporting text to refer to ‘active uses’ rather than ‘retail use’. This would allow for alternative uses to be brought forward that would retain street level activity, and contribute to the vibrancy of the centre.
IM welcomes the preparation of the masterplan, and the additional guidance that this gives in terms of more specific proposals and high level design. Would suggest that reference to the Masterplan being “updated by the end of the year” (paragraph 120) are removed. There appear to be inconsistencies between figures quoted within the SLPDS Plan, and the Town Centre Masterplan:
The presence of a comma at the end of paragraph 128 may indicate that it was intended to further clarify the position with further text. IM would welcome further text to avoid any confusion regarding what level of delivery is anticipated during the Plan period. Early feasibility work has indicated that Mell Square could accommodate 400 units.
Paragraph 129 of the supporting text makes reference to an economic appraisal and market analysis undertaken by Amion in 2020. In reviewing this IM consider in the context of current and forecast market conditions the potential for 50,000sqft of office floorspace to be brought forward to be ambitious.
It is therefore important that the Plan and the Town Centre Masterplan contain sufficient flexibility to allow for this to ‘shift’ to other uses if it can be demonstrated that there is a need for them. This is the case in policy P4a and the supporting text to Policy P4c which make specific reference to the fact that town centre residential development may result in a different mix, type or size of housing being provided by new development in these locations.
No specific reference is made to Mell Square within this policy. Clause (7) of Policy P2 states that “A range of opportunity sites will be identified under this policy”. However, it is not clear where these sites will be identified. There seems to be no link made to the emerging Town Centre Masterplan, and it is not clear whether it is intended that the Masterplan will contain relevant information about these ‘opportunity sites’. IM would suggest that clause (7) is clarified, and that reference is made to the Town Centre Masterplan or any other documents as appropriate
The supporting text is inconsistent in how it refers to the ‘Town Centre’. At paragraph 116, bullet four, reference is made to the ‘Heart of Solihull’ area, but it is not clear from the text what area this relates too. Paragraph 116 of the Plan sets out a list of the “primary retail frontages” where retailing activity should remain the main street level use. Specific reference is made within bullet four of point two to ‘Mell Square’.IM are concerned that this approach to protecting retail frontage is too restrictive to allow delivery of the flexibility that is referred to within the main Policy.
It would be more appropriate for this supporting text to refer to ‘active uses’ rather than ‘retail use’. This would allow for alternative uses to be brought forward that would retain street level activity, and contribute to the vibrancy of the centre.
IM welcomes the preparation of the masterplan, and the additional guidance that this gives in terms of more specific proposals and high level design. Would suggest that reference to the Masterplan being “updated by the end of the year” (paragraph 120) are removed. There appear to be inconsistencies between figures quoted within the SLPDS Plan, and the Town Centre Masterplan:
The presence of a comma at the end of paragraph 128 may indicate that it was intended to further clarify the position with further text. IM would welcome further text to avoid any confusion regarding what level of delivery is anticipated during the Plan period. Early feasibility work has indicated that Mell Square could accommodate 400 units.
Paragraph 129 of the supporting text makes reference to an economic appraisal and market analysis undertaken by Amion in 2020. In reviewing this IM consider in the context of current and forecast market conditions the potential for 50,000sqft of office floorspace to be brought forward to be ambitious.
It is therefore important that the Plan and the Town Centre Masterplan contain sufficient flexibility to allow for this to ‘shift’ to other uses if it can be demonstrated that there is a need for them. This is the case in policy P4a and the supporting text to Policy P4c which make specific reference to the fact that town centre residential development may result in a different mix, type or size of housing being provided by new development in these locations.
See attached - employment Land Reps