Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14358

Received: 14/12/2020

Respondent: Prologis UK Ltd

Agent: Delta Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Supports UK Central concept as offering the greatest potential for economic growth in the Borough. The key objectives for development proposals set out in the policy fully align with our own proposals for Site UK2.

With specific regard to JLR and Site UK2, support the release of this land from the Green Belt to accommodate employment development and generally agree with the exceptional circumstances case set out.
The Concept Masterplan referenced at paragraph 107 is not included in the Draft Submission Plan. As site promoters we have included with these representations a Site Supporting Statement which sets out our vision for the site and contained within this is our Concept Masterplan which we put forward for consideration with the aim of having this agreed with Solihull MBC and included within the final plan.

The following text should be amended to make the policy clearer and support the soundness of the Local Plan.

• The heading ‘Jaguar Land Rover’ above paragraphs xii-xv of Policy P1, as well as the heading which precedes paragraph 104 in the supporting text to Policy P1, should be amended to make it clearer that this policy and text covers both JLR and Site UK2, given that these sites are distinctly different areas on the Proposals Map and that different policies apply to the two areas. This will help with clarification in reading the plan.
• Paragraphs xii-xv of Policy P1 which provides the details of Site UK2 should be amended to better align with Policy UK2. It would be clearer if there was a clear cross reference to Policy UK2 after the words ‘employment development’ on line 2, as this would help to define the proposals and by ensuring that it is Policy UK2 that ultimately sets out the site specific policy for Site UK2. It is important also to make clear that uses with links to JLR are not the only employment uses permitted on the site.
• Within paragraph 104 of the supporting text to Policy P1 reference to ‘local’ should be removed in relation to employment uses. There is no definition of what ’local’ means within the plan with reference to economic development and the term has no meaning, purpose or enforceability in employment land delivery terms, especially in a location like this which will clearly be a highly attractive location for both businesses relocating from within the District but also new inward investment and businesses relocating from within the wider region. The subsequent text should also be amended to cross reference to Policy UK2 as the principal policy for Site UK2.
• We see no need for the first two sentences of Paragraph 105 to make more specific separate reference to land on the south eastern side of Damson Parkway being attractive to the automotive and motorsport industries. There is no reason why this area is any different from the rest of the allocation area. These two sentences should be deleted.
• In the third sentence of Paragraph 105 reference is made to part of the site also being identified for a relocated Household Waste and Recycling Centre (HWRC) and Council Depot. We would suggest that this reference be clarified to reflect the Council’s stated position on this matter in Paragraph 353 of the Draft Plan which is that the site has been identified as one ‘option’ for the HWRC relocation and that no final decision has yet been taken on this proposal. Indeed, it is apparent from the Council’s 2019 evidence base assessment report that there are other sites also in contention for this use which have a higher suitability scoring.
• In the fifth bullet point of Paragraph 106 reference to the primary highway infrastructure should also be included in the list of already committed development, together with that fact that this and the other committed development within Site UK2 have now been constructed not just permitted.
• Given there are other possible sites for the Council’s HWRC we do not consider that the 8th bullet point of Paragraph 106 adds anything to the special circumstances case for UK2. The case for Green Belt release is compelling without this.

Object

Representation ID: 14372

Received: 14/12/2020

Respondent: Prologis UK Ltd

Agent: Delta Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Supports the inclusion of this site within the table of employment site allocations under Policy P3.
The area quoted within the table should however be clarified. Although the gross area is c94 ha, that area includes substantial areas of land that are already committed/built out as well as substantial areas that will form part of the blue/green infrastructure. The actual net available area remaining is approximately 39 ha.
This also applies to Site UK1, the available employment land within that allocation is, according to the Arden Cross Masterplan, only approximately 30ha.

Based on the conclusions of the HEDNA paragraph 142 concludes that there is a shortfall of around 5.2 - 6.6 ha of employment land that the plan should provide for. The employment land need is far more extensive than the identified shortfall derived from the GL Labour Demand and past trends Modelling. There is no allowance for the past trends of JLR expansion itself (including the major LOC facility within Site UK2) or to meet the very strong regional demand for employment space, in particular for logistics warehousing, as referenced at paragraphs 12.57-12.58 of the HEDNA. That wider need is evidenced through the West Midlands Strategic Employment Sites Study (WMSESS), part 2 of which is due to be published shortly.
Part 1 of that study however has already made clear that the M42 corridor is one of three areas within the West Midlands where there is an acute shortage of land supply set against the highest volume of demand, and that the case for allocating strategic employment sites is strong. On the back of this evidence, both Birmingham and North Warwickshire have released some Green Belt for strategic employment uses. It is evident from interim information arising from the Part 2 study that although this additional supply has come forward in recent years, the overall shortage of land remains and this situation further supports the allocation of Site UK2. We would suggest therefore that Paragraph 142 be expanded to provide a fuller picture of employment needs more clearly.

In line with these comments reference to ‘local employment’ within paragraph 145 should also be removed and just the term ‘employment’ should be used. This paragraph should also cross reference to Policy UK2. We also see no reason for reference being required to a plan-monitor-manage approach in this case or repeated Green Belt justification which is provided for elsewhere in the plan under Policy P1.

Object

Representation ID: 14383

Received: 14/12/2020

Respondent: Prologis UK Ltd

Agent: Delta Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Acknowledges the plan has a crucial role to play in securing mitigation against and adapting to climate change. Fully in support of the aims and objectives of Policy P9 and the general requirement that proposals for major development be accompanied by a Climate Change Assessment as set out under Paragraph 7 of the Policy.
However, some of the site level requirements within paragraph 3 should be less specific to ensure a holistic approach to sustainable design is taken. In particular concerned by mandatory BREEAM Excellent accreditation and a 15% renewable/low carbon energy source requirement as may not present best sustainability outcomes. Also securing BREEAM Excellent on green field sites can be extremely difficult under the new 2018 BREEAM standards. Other approaches can be just as effective in reducing carbon emissions, and could be set out in the Climate Change Assessment already contained in the policy.
As site promoters of UK2 for example we would approach building design to minimise operational carbon emissions based on a three-step approach of • Step 1 - Passive Design Measures, including
i. high levels of air-tightness and insulation to reduce potential heat loss.
ii. rooflights to cover 15% of the warehouse roof area in order to maximise the use of daylight, while optimal orientation takes into account the path of the sun and the prevailing winds.
iii. Where possible offices are designed on a narrow floorplate with dual aspect glazing to take advantage of natural daylight and allow for effective passive ventilation.
iv. Provision of solar shading to ensure thermal comfort and avoid solar gain.
• Step 2 – Efficient Systems. Where energy use is required this can be specified and installed using the most energy efficient plant systems available. This can include intelligent lighting with low-energy LED fittings, daylight linking and presence-detecting controls. High-efficiency, low-NOX boilers with thermostatically controlled radiators to provide heating to offices, and the sub-metering of buildings to help users track and manage their energy consumption.
• Step 3 – Low or Zero Carbon Technologies. Once the operational energy use in the building has been minimised we then design and install low-or zero-carbon technologies to meet customer’s specific operational needs and, as a result, further reduce operational carbon emissions.

In addition to the above, we can undertake ‘cradle to rave’ Carbon Life Cycle Assessments based on the requirements of BS EN 15978 which show the significance of the embodied carbon emissions associated with the construction process which typically accounts for as much as 70% of lifetime carbon emissions of a warehouse, based on a 30-year assessment period. In this way we can therefore reduce embodied emissions through efficient design, the use of low carbon materials and the focused reduction of construction waste including diverting waste from landfill.

Therefore suggest that a more bespoke approach is taken to consider each site on its merits through the requirement to provide a bespoke Climate Change Assessment.
The policy should be clear as regard to which BREEAM standard it relates to (i.e. BREEAM new Construction 2018’ standard) and that these should be referenced as targets given there is no way to guarantee the outcome of an assessment
It is not realistic to expect minor development to undertake BREEAM Assessments

Object

Representation ID: 14402

Received: 14/12/2020

Respondent: Prologis UK Ltd

Agent: Delta Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Support this policy and the accompanying text at Paragraph 857-86. As landowners and developers of the site we have set out our Concept Masterplan which we put forward for consideration with the aim of having this agreed with Solihull MBC and included within the final plan. This Plan fully aligns with the development principles listed in the policy and the infrastructure requirements listed, and also includes a phasing strategy.

There are some aspects of the detailed text we consider should be amended in order to make the policy clearer and which would further support the soundness of this aspect of the Local Plan.
These are as follows:
• The text within the Policy and at paragraph 859 should remove references to ‘local’ employment needs. As stated elsewhere in our submissions to the Plan, there is no definition of what ’local’ means within the plan with reference to economic development and the term has no meaning, purpose or enforceability in employment land delivery terms, especially in a location like this which will clearly be a highly attractive location for business relocating from within the District but also from new inward investment and businesses relocating from within the wider region.
• The list of acceptable development in the allocation area should generally be set out more clearly.
• References in the Policy and paragraph 859 to the inclusion of a Household Waste and Recycling Centre and Council Depot should be amended to make clear that the Council has not yet made a decision on this issue and other sites are still in consideration as set out in Paragraph 353 of the Submission Draft Plan.
• The opportunity should be taken in the supporting text to clarify the scale of the available allocated land.
• The special circumstances case for Green Belt release are contained in the explanatory text to Policy P1 and cross referenced at Paragraph 863. There is no need for Paragraph 859 to try and summarise this again.