Draft Local Plan Review

No

Representation ID: 6486

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Critique of ELR contd:
Agree with using an economic forecasting model to calculate need, further consideration also needs to be given to historic rates of take-up and/or market drivers in validating future need.
ELR concludes there is a 'notional oversupply' of employment land.
Over-stated and not adequately justified.
Concern this conclusion is misleading, fails to fully acknowledge market signals and potential demand generated from major projects both in Solihull and wider region.
Methodology of translating employment forecasts to floorspace and land is not considered to be robust or appropriate.

No

Representation ID: 6489

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Critique of ELR contd:
Evidence fails to adequately reflect the local and sub-regional economic vision and ambition for growth. Need to fully acknowledge Solihull's role within wider functional economic market area and identified plans for investment and job growth. Should consider above baseline growth to accord with PPG, such as strategic aspiration of the GBSLEP and WMCA and needs of different industrial sectors.
Agree that HS2 interchange business land should be treated as separate from local supply; however do not agree that there will be no positive uplift with regards to employment growth and subsequent additional demand for land.

No

Representation ID: 6490

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

HS2 is a once in a generation scale of infrastructure investment; expected to represent a significant 'boost' to commercial market in the HS2 area and beyond.

Preferred baseline scenario is unlikely to take into account the potential growth in online retailing and e-commerce as a driver of logistics demand, nor does it robustly assess the impact of demand from major projects and investments across the wider sub-region. Consider forecasts underestimate actual levels of demand across Solihull over plan period.

No

Representation ID: 6491

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Critique of ELR contd:
Inappropriate to conclude on the market balance for industrial and logistics land until such time that market drivers, the employment yielding potential of major projects, the needs of the supply chain and the wider than local need for sites in Solihull are more accurately addressed in the informing evidence and land requirements calculations being relied upon to draft Policy P3.
Need to update evidence to reflect the above for next version of the Plan.

No

Representation ID: 6492

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Cumulative employment land supply is almost 300ha. However, two thirds of provision is within Sites 19 and 20. Site 19 is identified by a more specific need, and therefore falls outside general land supply.

Next version of Plan needs to present a clearer justification on scale of development planned for, extent to which the identified supply will address needs, plus sufficient flexibility in accordance with NPPF.

Methodology of translating employment forecasts to floorspace and land is not considered to be robust or appropriate. Serves to either suppress or mask the land requirements of some sectors, most notably B8 employment.

No

Representation ID: 6493

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Should be recognition of potential need for additional flexibility in responding to the full need for employment land uses and in particular adequate long-term provision for B8 uses e.g. significant demand for logistics uses in this area.

Should add more flexibility to Policy P3. Should confirm the employment land requirement but should also include flexibility to allow for development to come forward on non-allocated sites where there is a proven need for a specific type of business development to meet a strategic need, e.g. Industrial, inc. logistics.

See Critique of ELR under Q23.

No

Representation ID: 6494

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

WMLC report suggests strategic employment sites (>25ha) is a prerequisite for growth in West Midlands. Two respondents to 'call for evidence' confirmed that lack of such available sites precludes them from operating in the WM.

SMBC should ensure they do not restrict opportunities for this type of investment/development.

WMLC suggest undertaking a strategic Green Belt review of West Midlands. Our view that site allocations should be based on sustainable locations rather than land that contributes the least towards purposes of Green Belt. As BVP and Fore are already allocated site, they are considered sustainable locations, obvious locations for future growth.

No

Representation ID: 6495

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

In principle do not object to separate Policy P1A for BVP, but should not overlook its importance and role in Borough and wider region. Support wording around mixed use community and primary economic asset.
BVP has secured mixed use planning permission.
Note there are inconsistencies between Table at Para. 230 and footnote 34. Should state BVP can accommodate up to 1000 dwellings (assuming Council includes C2 and C3 uses in housing figures).
Request that anomaly between UDP and Solihull Local Plan boundaries for BVP are addressed through DLP.

No

Representation ID: 6496

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Concerned that land holdings at BVP not fully addressed and considered as part of DLP evidence base.

SHLEAA Ref. 146 does not include any additional land submitted by ILM as part of Call for Sites. Land only considered in terms of housing; not housing and employment. Request that full land holdings at BVP are reassessed for these purposes during DLP.

ELR confirms important economic function and attractiveness of M42 corridor for business; Solihull therefore has potential to capture demand far beyond the TTWA geography. ELR conclusion that BVP is 'site for expansion' has not been reflected in DLP.

No

Representation ID: 6497

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

ELR is factually incorrect about Fore; does not capture current extant planning permission on site (PL/2002/02799/RMM). Outline planning permission (PL/1990/00280/OL) has now lapsed, so no further RM applications can be submitted relating to it.
Future development can happen two-fold:
Build out under 2002 application, but buildings are not of suitable design/floorplate for today's market:
Submit a fresh planning application for new employment building. Difficult due to shape and extent of current allocation, and tightly drawn Green Belt boundary.
Request allocation be widened to include additional areas for carparking. Without this, deliverability of a meaningful amount of floorspace will be constrained.