Policy P3 Provision of Land for General Business and Premises

In Balsall Common allocate sites for employment purposes on one or more af the following sites
• Lavender Hall Farm site BC6
• Call for Sites site 1 – Springhill, 443 Station Road, Balsall Common
• Call for Sites site 43 – Land adjacent to Old Lodge Farm, Kenilworth Road

In Knowle an area within the Arden Triangle a suitable site should be allocated for employment uses.

While it is clearly important in the Local Plan to address the issue of providing sufficient land for housing over the plan period, it is apparent that less serious attention has been given to the provision of new land for employment purposes.
The allocation of Site UK2 on land at Damson Parkway in the Policies Map, is to be released from the Green Belt to accommodate employment development, including that required for JLR operational needs or to enable JLR component suppliers, needed to directly support JLR operational needs, to be located close to the plant. That land has also been earmarked for the relocation of the existing public Civic Amenity Recycling site presently sited at Arden Eco Park
Arden Cross is being promoted as providing for housing as well as other uses including such as research and development and advanced manufacturing as part of an innovation district for employment and higher education.
The Council has readily diluted the original business allocation of Blythe Valley Park and other business parks with significant residential development.
While much of that is to be welcomed in the two main areas of residential growth – Knowle and Balsall Common – no provision has been made of land for employment purposes to help to create a balanced community rather than commuter villages where the population has to travel usually by car to employment opportunities elsewhere. In both those communities’ provision should be made in the Local Plan for a modest amount of employment land.
In Balsall Common sites such as
• Lavender Hall Farm site BC6
• Call for Sites site 1 – Springhill, 443 Station Road, Balsall Common
• Call for Sites site 43 – Land adjacent to Old Lodge Farm, Kenilworth Road

In Knowle an area within the Arden Triangle a suitable site should be allocated for employment uses.

Arden Eco Park should be allocated as a site for a Power from Waste site to service Arden Cross.

The wider former Arden Brickworks site, now called Arden Eco Park, covers a total area of around 38.6 hectares (95.4 acres). The Eco Park site is accessed from the A45 via a one-way service road running on the south side of and parallel to the A45 between Stonebridge Island to the east, at the junction of the A45/A452, and M42/J6 to the west.

The Arden Eco Park lies within the M42 Solihull Economic Gateway with additional expansion proposed to this gateway. It is located in the West Midlands Green Belt in the Meriden Gap which separates Birmingham from Coventry and is largely surrounded by agricultural land apart from a large Kennel complex – Top Hat Kennels - on the frontage which is likely to be directly affected by HS2, and Pasture Farm to the east. The HS2 line is due to pass just to the east of Arden Eco Park leading into the new Interchange Station north of the A45.

Birmingham International Airport, the National Exhibition Centre and Birmingham International Station are located around 2 miles to the north west accessed off the A45 to the west of the M42.

Future development of the site

As such Arden Eco Park is a major previously developed site in a strategic position and already operates a Materials Recovery Facility (MRF) at the rear of the site alongside the remaining areas of clay extraction. The Local Plan recognises the clay extraction operation as well as the MRF as established facilities.

The major frontage part site comprises a Civic Amenity Facility which has operated for many decades to service the wider Solihull community but is proposed to be relocated to a site near Damson Parkway which for many is likely to be less accessible that the present facility at Bickenhill. HS2 will run directly adjacent to the eastern boundary and Adren Cross is directly on the north side of the A45.

Behind the Civic Amenity site lie a large number of business units used by utility and civil engineering companies for offices and ancillary facilitate as well as open storage (B8) with ancillary facilities mainly covered by a Certificate of Lawful use granted by the LPA in 2007 (ref 2007/ 1171). The site comprises a large area of hardstanding a range of buildings in brick or profiled steel buildings which have largely replaced the former brickwork buildings.

The owners of the land have ambitions to establish a major Power from Waste facility on this site which would make a major contribution to the energy needs of the area around including the Arden Cross development area around the HS2 Interchange with over 5000 new houses as well as business development.

The Arden Eco Park site has been submitted under the Council’s Call for Sites in relation to the Local Plan as land for business and employment uses given into extensive past history. The Local Plan has not recognised that submission and no provision is being made in the plan for the site to contribute positively to needs of the Solihull Economic Gateway which it is well placed to do.

No provision is made in the Plan for dealing with major brownfield sites in the Solihull Local Plan which are included within many other local plans. Leaving it to the development management process is not sufficient to give a proper and appropriate policy framework for considering proposals. In the future.

The Arden Eco Park site should be allocated as a site for energy from waste and other related development.

Allocate land for employment uses on Balsall Common and Knowle

While it is clearly important in the Local Plan to address the issue of providing sufficient land for housing over the plan period, it is apparent that less serious attention has been given to the provision of new land for employment purposes.
The allocation of Site UK2 on land at Damson Parkway in the Policies Map, is to be released from the Green Belt to accommodate employment development, including that required for JLR operational needs or to enable JLR component suppliers, needed to directly support JLR operational needs, to be located close to the plant. That land has also been earmarked for the relocation of the existing public Civic Amenity Recycling site presently sited at Arden Eco Park
Arden Cross is being promoted as providing for housing as well as other uses including such as research and development and advanced manufacturing as part of an innovation district for employment and higher education.
The Council has readily diluted the original business allocation of Blythe Valley Park and other business parks with significant residential development.
While much of that is to be welcomed in the two main areas of residential growth – Knowle and Balsall Common – no provision has been made of land for employment purposes to help to create a balanced community rather than commuter villages where the population has to travel usually by car to employment opportunities elsewhere. In both those communities’ provision should be made in the Local Plan for a modest amount of employment land.
In Balsall Common sites such as
• Lavender Hall Farm site BC6
• Call for Sites site 1 – Springhill, 443 Station Road, Balsall Common
• Call for Sites site 43 – Land adjacent to Old Lodge Farm, Kenilworth Road

In Knowle an area within the Arden Triangle a suitable site should be allocated for employment uses.

See Attached Word doc.

The employment requirement should be set out within a strategic policy within the Plan.

The employment requirement should be increased to reflect past performance, the market evidence of supply and demand, the Local Industrial Strategy for the West Midlands Combined Authority and the unmet needs of the Black Country Authorities.

Evidence should be provided as to the availability and deliverability of the proposed allocations and the trajectory for their delivery.

Additional employment sites should be allocated to address the additional employment land requirement to ensure a continuous supply. Site 62 (Land west of Stratford Road) should be allocated as a mixed use allocation comprising residential and employment.

Dear Sir or Madam,

Please see attached multiple representations on behalf of IM Properties in respect of land west of Stratford Road (Site 62).

Kind Regards,

Objects to the addition of the proposal for the waste and recycling centre and Council depot to be relocated within the UK2 allocation through policy UK2.

We write on behalf of our client, Jaguar Land Rover, to submit a response to the publication of the
Solihull Local Plan (Draft Submission) 2020 (Reg 19) consultation (the ‘Draft Submission Plan’).
Jaguar Land Rover’s Lode Lane manufacturing site (the ‘site’) employs approximately 7,000
people, operating 24 hours a day to meet the global demand for Range Rovers and the Jaguar FPACE.
It forms one of the largest employment sites in the West Midlands and is Jaguar Land
Rover’s largest manufacturing facility in the UK.
This site bounds the draft employment land allocation UK2 at Damson Parkway, Solihull (formerly
known as Proposed Employment Site 20 in earlier versions of the draft Plan), with specific
reference made to the site providing expansion opportunities for Jaguar Land Rover.
Jaguar Land Rover support the principle of allocating employment land at draft allocation UK2.
Jaguar Land Rover does however have serious and grave concerns with some of the detail of draft
allocation UK2 as submitted for Regulation 19 consultation, and requests Solihull MBC takes into
account the detail of this letter and makes the requested changes to this policy.
Concerns with draft Policy UK2
The recently published Draft Submission Plan October 2020 (Reg 19) amends the previous
wording of draft Policies UK2 – Land at Damson Parkway and P12 – Resource Management to
include an option for the provision of a relocated Household Waste and Recycling Centre and
Council Depot within the land allocation. Jaguar Land Rover has serious and grave concerns
regarding this addition within the allocation and does not support this amendment, due to following
potential implications:
▪ The potential impact on the future site expansion of Jaguar Land Rover’s Solihull
manufacturing facility;
▪ The potential impact on the future aspirations of creating direct access to the new M42
Junction 6 road link; and
▪ The non-compliance with adopted Policy P3 Provision of Land for General Business
and Premises.
Page 2
Future expansion
The continued expansion and growth of the largest of Jaguar Land Rover’s UK manufacturing sites
and one of the West Midlands’ largest employers, is largely constrained on the north, south and
west by the neighbouring urban form and protected Elmdon Park. Land to the east of the facility is
the only area that could accommodate growth. It is therefore essential that this land is protected for
the future expansion needs of Jaguar Land Rover.
As a recognised Key Economic Asset contributing to Solihull and creating a substantial number of
local skilled employment opportunities, the Solihull Local Plan Review reinforces the Council’s
objective to support Jaguar Land Rover’s continued economic success, understanding their need
to stay competitive and the requirement for growth through the proposed allocation of employment
land site Ref: UK2 (adopted and draft Policy P1). Site UK2 identifies the only area available for the
Lode Lane facility’s expansion, to the north/east of the existing site.
The land to the immediate north of the existing facility, to the west of Damson Parkway, was
granted consent for development in conjunction with the continued operation of Jaguar Land
Rover. The location of this development infills the remaining available land to the west of Damson
Parkway and south of the A45.
The proposed amendment to the justification text of Policy UK2 notes that part of the draft
allocation, to the south east of Damson Parkway, has been identified as an option for the relocation
of the Household Waste and Recycling Centre and Council depot. This area of land bounds Jaguar
Land Rover’s existing dispatch lot to the east.
The development of a Household Waste and Recycling Centre and Council depot in this location
would result in the total enclosure of Jaguar Land Rover’s Lode Lane facility, developing the last
area of land available as a natural extension to the existing facility’s footprint.
Further details would also be needed to understand the security provisions of any facility which
bounds our site. There is a potential to weaken defensible boundaries and pose additional security
risks.
Prior to the recent amendments to the wording of Policy UK2, the proposed allocation supported
Paragraphs 80 and 82 of the NPPF, seeking to create an identified area of employment land for
the continued growth and expansion of Jaguar Land Rover and/or for the addition of alternative,
complementary automotive use, creating a cluster of industry.
The proposed provision of a waste treatment facility and depot would result in the inability for the
continued growth of the existing large-scale local employer, one of the largest in the West
Midlands, contrary to their adopted and draft Local Plan and the National Planning Policy
Framework (2019) (‘NPPF’).
As such, Jaguar Land Rover request that the Household Waste and Recycling Centre and Council
depot are not located within draft allocation UK2.
Future connectivity to the highway network
Highways England has recently obtained consent for a series of works between Junction 5 and
Junction 6 of the M42, resulting in the creation of a 2.4km dual carriageway link road aligned to the
A45 and access via Junction 5A. This area of the M42 currently supports road access to
Birmingham Airport and significant business locations, such as the UK Central Solihull Hub Area.
Page 3
The justification for these works is supported by the current, significant congestion issues that form
a constraint to any future investment and economic growth in this area. The benefits of the scheme
once complete will be an increase in capacity at Junction 6, reduced congestion, improved access
to key business areas in the region, and improved local cycle and pedestrian routes.
There is a future aspiration to connect Damson Parkway directly with this new dual carriageway.
Such a link road would create a more direct route between the UK2 allocation and the M42,
directing traffic away from the existing routes and improving capacity on the local and strategic
road network. This could also allow for further economic development opportunities in the local
area in the future.
The route for such a link road is not yet known, nor has a case been made for it. As such, Jaguar
Land Rover is not asking Solihull MBC to protect the potential route but merely ensure the Local
Plan and allocation UK2 is sufficiently flexible to incorporate this road should it be needed during
the plan period between (2020-2036).
There is an aspiration to have rail freight connectivity serving the allocation to ensure future logistic
capability for all parties. Any plan policy should protect this aspiration.
Policy P3 assessment
Adopted Policy P3 protects allocated employment land for their allocated purposes and
employment uses defined as offices, industrial and warehousing, and where appropriate, waste
management. The amendment to the wording of Policy UK2 seeks to include waste management
as an appropriate land use at Damson Parkway.
Considering site UK2, it is located on both sides of Damson Parkway. The surrounding land
comprises the Jaguar Land Rover Lode Lane facility and its phased extension to the south of the
A45, whilst within the wider site there are several residential dwellings, a gypsy traveller site and
other small, home-based businesses.
Policy UK2 states that the waste treatment centre and depot would be located within the allocation,
understood to comprise the two land parcels to the east and north of Jaguar Land Rover’s dispatch
lot.
Based on the existing site uses and in the interest of enabling the continued growth of Jaguar Land
Rover, a waste management facility is not deemed appropriate in this location.
Policy P3a sets out five criteria for the assessment of alternative uses:
▪ Site is relatively isolated from other business premises or neighbouring uses;
▪ Demonstrated that there is no longer a need to retain the site for their intended
business class purpose; or
▪ There is no reasonable prospect of attracting business development in market terms;
▪ The alternative use will support sustainable development principles and directly deliver
employment locally; and
▪ There is no conflict with policies of the Local Plan or National Planning Policy.
Against the aforementioned criteria, a waste management site and Council depot in this location
would not be deemed appropriate. The proposed location is in proximity to a 24-hour operating
business, which is continuing to expand into the wider area. Furthermore, its neighbours include
Page 4
residential dwellings to the north and south, which are not directly compatible with a waste
treatment facility.
The site in its current form does not lack prospects for its future development, nor does it require
extensive marketing to identify potential interest, as this exists in the form of Jaguar Land Rover,
as identified in Policies P1, P3, UK2 and the Council’s objectives to support its continued growth.
The continued growth of one of the West Midland’s largest employers, in proximity to the existing
facility ensuring a concentrated operation, provides a clear rationale for supporting sustainable
development and the delivery of local employment. A concentrated approach reduces the travel
and movement of goods and people across Solihull, supporting the best use of space with their
dense development footprint maximising employment opportunities for skilled workers within the
local community.
Finally, the provision of a waste management facility that would severely constrain the continued
growth of an existing, prosperous and beneficial employer does not constitute the best use of land,
contrary to the NPPF. Jaguar Land Rover currently employ approximately 7,000 people at the
Solihull facility, with any expansion allowing for increasing figures and generating employment
rates in keeping with business use class densities. A waste management facility and depot,
however, would not provide employment densities of the same level based on the site’s function
and use of space, nor does it support the continued large-scale growth of an existing large
employer.
CONCLUSION
Jaguar Land Rover support the principle of employment land at draft allocation UK2 within the
Draft Submission Plan, supporting the continued growth and operation of employment uses within
the area.
Notwithstanding, the amended wording of draft policy UK2 identifies the allocation as a potential,
appropriate option for the relocation of a Household Waste and Recycling Centre and Council
Depot. Jaguar Land Rover do not consider the provision of this option within site UK2 is an
appropriate location for this operation, based on its existing local context. Such a facility, located in
the south east of the allocation, would prejudice the future expansion and continued growth of
Jaguar Land Rover’s Solihull facility. It would potentially prejudice future connectivity with
Highways England’s M42 Junction 6 relief road and does not constitute an appropriate location as
per the adopted Policy P3a assessment.

see attached document

See attached - employment Land Reps

See attached - employment Land Reps

See attached - employment Land Reps

Good evening

Please see attached letter from Meriden Parish Council in response to Solihull’s Draft Local Plan consultation.

To rectify matters, the Submission Draft should increase its requirement to meet local need for industry and warehousing to 44 hectares (developable, rather than gross).
In addition, the Submission Draft should make an express allowance for the large scale logistics sector. This allowance should be over and above local need and provide a minimum of a further 35 hectares.
In combination, the Submission Draft should provide and plan for at least 80 hec-tares of employment land for industry and warehousing to provide for both local need and the need for large scale logistics (i.e. big box). Without the allocation of this land, the demand for industrial and warehouse units for Solihull will be further suppressed and opportunities for economic growth, whether organic or inward in-vestment, will be missed.
This will require the release of Green Belt land and the allocation of additional new sites. We consider that the scale of need for new employment land, the reasons for its need, the emphasis placed on meeting this need in the NPPF and PPG, the increasing importance of employment in an uncertain economic outlook and the absence of other alternatives, amount to the exceptional circumstances required by the NPPF to release Green Belt land through the development plan-making process. Releases in similar circumstances have already been previously made within Solihull – Blythe Valley Business Park and Birmingham Business Park – and the wider region – i54, Peddimore and Coventry Gateway.
If it is recognised that more land is required and needs to be identified, then there should be a further consultation and/or Call for Sites. Our client, St Modwen Developments Ltd, would be pleased to provide details of a large site that is well related to a motorway junction of the M42, that is capable of meeting some of the additional need referred to above.

Please see attached document

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

See Attached Document

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