Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14372
Received: 14/12/2020
Respondent: Prologis UK Ltd
Agent: Delta Planning
Legally compliant? Yes
Sound? Yes
Duty to co-operate? Yes
Supports the inclusion of this site within the table of employment site allocations under Policy P3.
The area quoted within the table should however be clarified. Although the gross area is c94 ha, that area includes substantial areas of land that are already committed/built out as well as substantial areas that will form part of the blue/green infrastructure. The actual net available area remaining is approximately 39 ha.
This also applies to Site UK1, the available employment land within that allocation is, according to the Arden Cross Masterplan, only approximately 30ha.
Based on the conclusions of the HEDNA paragraph 142 concludes that there is a shortfall of around 5.2 - 6.6 ha of employment land that the plan should provide for. The employment land need is far more extensive than the identified shortfall derived from the GL Labour Demand and past trends Modelling. There is no allowance for the past trends of JLR expansion itself (including the major LOC facility within Site UK2) or to meet the very strong regional demand for employment space, in particular for logistics warehousing, as referenced at paragraphs 12.57-12.58 of the HEDNA. That wider need is evidenced through the West Midlands Strategic Employment Sites Study (WMSESS), part 2 of which is due to be published shortly.
Part 1 of that study however has already made clear that the M42 corridor is one of three areas within the West Midlands where there is an acute shortage of land supply set against the highest volume of demand, and that the case for allocating strategic employment sites is strong. On the back of this evidence, both Birmingham and North Warwickshire have released some Green Belt for strategic employment uses. It is evident from interim information arising from the Part 2 study that although this additional supply has come forward in recent years, the overall shortage of land remains and this situation further supports the allocation of Site UK2. We would suggest therefore that Paragraph 142 be expanded to provide a fuller picture of employment needs more clearly.
In line with these comments reference to ‘local employment’ within paragraph 145 should also be removed and just the term ‘employment’ should be used. This paragraph should also cross reference to Policy UK2. We also see no reason for reference being required to a plan-monitor-manage approach in this case or repeated Green Belt justification which is provided for elsewhere in the plan under Policy P1.
Policy P3 Employment Allocations Table should be amended for Sites UK1 and UK2 to reflect the net available areas - Land at HS2 Interchange (UK1) C140 (gross) c30(net available) Land at Damson Parkway (UK2) c94 (gross) c39(net available).
Additional sentences should be added to paragraph 142:
“The HEDNA 2020 also notes that market intelligence shows a very strong demand for warehousing and industrial units across the spectrum which is concentrated along the M42 corridor and forecasts point to a clear need for additional warehousing. This is likely to be reinforced by the West Midlands Strategic Employment Sites Study Part 2. Previous Regional Studies which have consistently shown a shortage of land for strategic employment sites across the West Midlands, with the M42 corridor in particular being an area that has historically had a high volume of demand but a constrained supply. The inclusion of site UK2 can therefore also help towards meeting this wider regional strategic land requirement.”
Paragraph 145 should be amended as follows:
“The above table also includes two allocations (Sites UK1 & UK2) which will necessitate land to be removed from the Green Belt. The justification for Policy P1 provides the exceptional circumstances for this approach. Whilst Site UK2 is partly intended to provide for JLR needs, much of this has already been committed in the form of the despatch area and logistics operations centre, approved under very special circumstances. The concept masterplan shows the development areas that are already committed and constructed and a number of phases remaining for development, which can meet wider general local employment needs together with that required to meet any additional needs of JLR and JLR related activities and ancillary development to Birmingham Airport as set out in Policy UK2. The site can also accommodate a potential replacement Household Waste and Recycling Centre and Depot subject to ongoing options assessment by the Council as set out in Policy P12., Evidence indicates that Site UK1 is likely to have a role to play in meeting local employment needs, especially later in the Plan period.”
See attachments