Solihull Local Plan (Draft Submission) 2020

The key deficiencies can be summarised as follows:
1. The Solihull Retail, Leisure and Office Study 2009 (refreshed 2011) is out of date. This was recognised by the Council at page 115 of the November 2015
consultation but no work has been undertaken to bring the Study up to date, which is necessary owing to the significant structural changes planned within the Borough. This includes accommodating a proportion of the Birmingham overspill housing numbers and the iunclusion of Arden Cross.
Expenditure data and retail need will now be fundamentally different to that previously identified.
2. Without an up to date retail and leisure evidence base, the full quantitative and qualitative needs for the Borough are unknown. It is therefore not possible for the Plan to identify how and when these needs will be met in full and whether these will be delivered sustainably. This is a clear requirement of the NPPF.
3. The emerging Plan does not deal with the requirements of the NPPF to clearly define on a plan(s) the primary shopping areas for defined centres.
This is required to inform the application of the sequential and impact tests.
4. The Council has not assessed whether a locally set threshold for impact assessment is required. At present the Local Plan defers to the National Planning Policy Framework (NPPF) which sets a substantial threshold of 2,500 sqm over which an impact assessment should be undertaken. This is sufficient floorspace to accommodate a full range foodstore or an entire neighbourhood centre. Such a quantum of floorspace is of concern as retail schemes of this size would impact significantly on more vulnerable centres such as
Chelmsley Wood. A lower threshold should be explored and incorporated into the Local Plan – this threshold should have regard to the economic disparities in the Borough and as such could be set at different levels to
reflect local markets.
5. The emerging policies covering Blythe Valley Business Park and HS2 Interchange require far more clarity on the scale and type of retail that will be
permissible. Uncertainty as to the scale of retail floorspace to be delivered in these locations will put investment in established town centres and regeneration
areas at risk. Any allocations for retail in these locations should be guided by updated retail evidence that also factors in timescales for delivery of anticipated growth.
6. The term ‘commercial development’ and ‘employment uses’ is used throughout the emerging Local Plan and seems to be used interchangeably to describe a number of different uses. The Local Plan should be clear what
is meant by commercial development in the context of the Local Plan to avoid confusion and potential unintended consequences.
In summary, the focus of the spatial strategy is very much on the objectively assessed need for housing and major economic (Use Classes E(B)/(G), B2 and B8)
development schemes with less regard for the integral spatial planning requirements for retail and leisure uses. The evidence underpinning the retail and leisure
requirements of the Plan are out of date and need to be updated and incorporated within the body of the Plan to inform site allocations.

Policy P2 provides no clarity over the strategy for Chelmsley Wood Town Centre and is poorly written. It needs amending to ensure retail and leisure uses within
the core of the centre remain protected and are not diluted by additional edge of centre development which the current wording appears to support.

The policy needs to be redrafted to provide clarity to its purpose. It should include reference to a primary shopping area which is then annotated on the
Proposals Map.
It should also have clear reference to the Chelmsley Wood Masterplan and provide guidance on the extent and acceptable locations for additional uses.

Ellandi object to the current wording of Policy P2. As set out in our representations of 22 January 2016 and 9 February 2017, the new Local Plan is not based on up to
date evidence of retail and leisure need. The evidence that is currently relied upon is significantly out of date and does not reflect the scale of development now
proposed for the Borough and the timing of that development.
The anticipated timing of the substantial growth in the Borough will influence the phasing for when and where the Local Plan seeks to deliver plan led retail and
leisure need and the preferred strategy for doing this. These considerations will in turn influence how the sequential and impact tests within the NPPF are interpreted and drafted within the new Local Plan. At present it simply defers to the NPPF which is a missed opportunity to provide a robust and locally focused strategy that fosters investor confidence. The NPPF requires plan led need to be met in full and therefore
the Local Plan must grapple with how to do this in the most sustainable manner that supports the overall vision for Solihull.
In addition, SMBC should undertake an assessment of thresholds to identify a locally set threshold or thresholds over which impact assessment will be required for retail
uses. The NPPF threshold of 2,500 sqm is too high, particularly in areas where town centres are vulnerable and even a small out of centre scheme could have a
disproportionate effect on the vitality and viability of the centre. Our experience of the NPPF threshold is that developers of out of centre proposals deliberately size a
scheme just under the NPPF threshold on the basis of there not being a unit available within a town centre location that meets all of the operational requirements of
an occupier. This then allows the applicant to circumvent the requirement to assess the proposals against the impact test - the NPPF is clear that this is only required over the nationally set threshold or where a locally set threshold, based on robust evidence, is set. We would therefore raise again that research led by SMBC should
be undertaken to assess where the current balance of unit sizes lies in each of the
Borough’s town, district and local centres. A suitable threshold or thresholds can then be set which supports the spatial strategy for the Plan.
In addition, thresholds for impact assessment in relation to town centre uses at Arden Cross, Birmingham Business Park and Blythe Valley Business Park should be set.
Otherwise there is no mechanism by which to assess whether the scale of development is commensurate with serving those developments only; which is the intention
of the policies as drafted.
One further point is in relation to objective 15 of Policy P2. This policy is not effective or consistent with national policy. It seeks to encourage new development on the
edge of the town centre for a diverse range of uses. This has the potential to undermine the strength of Chelmsley Wood Shopping Centre if this is effectively giving support to competing retail and leisure town centre uses in an edge of centre location. The policy needs to be redrafted to give clarity to its purpose.