Solihull Local Plan (Draft Submission) 2020

Removal of potential proposal for the Household waste and recycling plant to be relocated within the allocation.

Flexibility within the policy to accommodate the new dual carriageway proposal to improve accessibility and congestion at junction 6 and future plans to join to the allocation. Allow flexibility for future rail freight capability.

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.

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.