Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14263

Received: 14/12/2020

Respondent: St Mowden Developments Ltd

Agent: JLL

Legally compliant? No

Sound? No

Duty to co-operate? No

JLL considers the approach of the Submission Draft to the provision of industrial and warehouse floor space to be deeply flawed on a number of grounds. These are summarised below.
The principal evidence base to the submission draft, G L Hearn’s HEDNA, has under-estimated substantially the local need for development land for industry and warehousing. GL Hearn has mishandled primary recent evidence on increases in industrial floor space and ignored clear market signals which show a significant imbalance between demand and supply.
The supply of sites to meet local need is wholly insufficient, both quantitatively and qualitatively. It provides a very restricted offer to companies looking to expand or invest in Solihull.
The approach to identifying and delivering employment land to meet local needs for industry and warehousing does not accord with the guidance set out in PPG on Economic need. In addition, it is not justified by its principal evidence base. As such, Policy P3 is unsound in terms of meeting local need for industry and warehousing.
The Submission Draft makes no allowance for large scale logistics. Indeed, the Submission Draft and G L Hearn’s HEDNA make no reference to this sector. This is a significant failing given the circumstances: -
■ Paragraph 82 of the NPPF requires planning authorities to make pro-vision for logistics operators of a variety of scales and in suitably ac-cessible locations.
■ The clear guidance in PPG for strategic authorities to identify the scale of the need for logistics and consider the most appropriate lo-cations to meet those needs.
■ The signposting by the 2015 West Midlands Strategic Employment Sites Study of a “severe shortage” in supply, relative to demand, of development land to accommodate this sector.
■ Similar conclusions by the successor study to the West Midlands Strategic Employment Sites Study, currently in draft form but with its conclusions well known to the strategic authorities (as part of the commissioning group), which refers to an “urgent need” for addi-tional sites to be brought forward.
■ The recognised strength of the logistics market and the growing gap between demand and supply in this location.
The West Midlands Strategic Employment Sites Study 2015 identified Solihull as forming part of the M42 corridor (Area A) and considered this to be an area of high demand for big box logistics, with supply “severely short”. It recommended that local studies should be commissioned to identify specific opportunities and assess policy implications. Unfortunately, no such study has been carried out for Area A. Solihull, as the authority with the greatest access to this stretch of the M42, should have taken a leading role, but has not done so.
Solihull, North Warwickshire, Birmingham and Tamworth – the principal local planning authorities in this area – have simply failed to engage on this issue. This has resulted in very little new land being identified in Local Plans to meet future demand. This is a chronic failure of the Duty to Co-operate.
Similarly, there seems to be a lack of engagement between Birmingham and Solihull – which form part of the same LEP – about how Solihull could take a role in accommodating the significant identified overspill of employment land need for Birmingham.
These omissions are fundamental. They result in the Submission Draft not delivering the scale and quality of employment land required in order for the Borough to meet its economic needs and optimise its assets. This is an abject failing given the uncertain economic and political times ahead.