Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14200

Received: 14/12/2020

Respondent: IM Properties - Employment Land

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The employment land supply set out in Policy P3 is inadequate to meet the longer term needs of the borough for industrial and warehousing land. This is based on two premises:
(a) The HEDNA underestimates local industrial and warehousing need by some margin
(b) The plan does not address the acknowledged need for strategic employment sites based on the 2015 study

Policy P3 should plan for a higher amount of industrial floorspace (between 22.1 and 60.7ha ) than what was concluded in the HEDNA.

The approach of the HEDNA is justified however there are a number of shortcomings to the specific method used by the HEDNA:

• Tables 101 and 102 appear to contain errors, incorrectly transposing the VOA data cited at Table 100;
• The decision to use only a two year margin is insufficiently justified where it is commonplace to apply a more generous five year margin, to ensure sufficient flexibility in the supply calculated as being needed; and
• There is insufficient justification for the dismissal of recent evidence of much stronger growth in the industrial stock, when focusing on the period back to 2011 rather than the longer-term period back to 2001.

Recent employment changes have been the result of structural changes in the distribution and retail / e-commerce markets which are acknowledged within the HEDNA. The UK has emerged as the third largest online shopping market in the world and the largest in Europe.

The demand for logistics space is directly related to changes in the size of the population. The HEDNA confirms, with reference to various scenarios, including one incorporating the UKC Hub, that the population of Solihull is projected to increase significantly. It has been evidenced that as the population grows, there is likely to be a corresponding increase in consumer demand and the need for warehouse space. The HEDNA confirms that the population of Solihull has grown at a greater rate over more recent years, with Figure 9 suggesting that the rate of growth will increase to an even greater extent when meeting even the minimum need for housing implied by the standard method.

Using VOA data and incorporating data from March 2020 the annual net change in industrial/warehouse floorspace shows a rising trend in the past decade. Last year’s data (2019/20) shows a new record level of growth, a continuation of the short-term trend would see more pronounced growth than the longer-term trend.
Accounting for last years growth would identify a greater need than the 16ha concluded in the HEDNA. Even if the short-term trend was not sustained it would be reasonable to conclude that a more representative position would fall somewhere within this range of between 19 and 52 ha. In the context of the evidence relating to sustained growth of e-commerce and a projected strong local growth in population that the upper end is more likely to represent a reasonable level of need to be planned for, to ensure the plan’s resilience.
Even the lower end of this need aligns with the Labour Demand Growth Scenario identifying a need for 19.1 ha, this should be the absolute minimum to be planned for. If flexibility of 5 years take up was included it would be sensible to plan for between 22.1 and 60.7ha.
This strongly indicates that the shortfall in industrial land to which the Plan should respond, in quantitative terms alone, is much higher than concluded in the HEDNA.

Object

Representation ID: 14201

Received: 14/12/2020

Respondent: IM Properties - Employment Land

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The plan is unclear about the role of the land at Damson Parkway in Policy UK2 which, at one level, is significant in terms of site area when measured against the HEDNA’s assessment of local need, but in policy terms is identified as capable of meeting the specific and unique needs of JLR and/or the airport. What proportion is expected to meet local needs or, whether as part of UKC Hub, it is in effect a strategic site requires clarification.
In either event, market evidence points to a need to identify a more robust supply of industrial and warehouse land as there are very unlikely to be any windfall sites and the only other option would be to consider removal from the Green Belt which should take a plan-led approach.


The HEDNA infers that UKC Hub employment growth scenario and related developments at UK1 and UK2 are intended to accommodate a combination of both local and strategic needs.

The amount of strategic warehousing accounted for as part of UKC is modest and does not take account of the acknowledged sub-regional shortage in the provision of strategic employment sites in this market area.

The 2015 West Midlands Strategic Employment Sites Study13 (WMSESS) highlighted an immediate need for additional sites across the region.
An updated second stage of the WMSESS is awaiting publication and it is anticipated that this will reaffirm the immediate shortage of strategic employment sites, with a specific focus on the M42 corridor including Solihull. The draft Plan does not adequately acknowledge or respond to this need for strategic sites and when the study is published and identifies such a need, it will be necessary for the Plan to engage with the issue positively.

Object

Representation ID: 14202

Received: 14/12/2020

Respondent: IM Properties - Employment Land

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

IM are pleased to see that the Plan continues to provide policy support for the ongoing development of Blythe Valley. In particular, Policy P1A and its supporting text outline what is expected of future development

In relation to the existing BVP site:
• Policy should provide maximum flexibility to reflect market demand. The broad range of the types of uses that could be brought forward in the policy should not seen as an exhaustive list. It should be made clear within the policy wording that a wide range of employment activities will be supported including offices, industrial and warehousing, but also including research and development and other ‘non-traditional’ employment uses.
• The residential part of the site is now subject to reserved matters approvals. It may therefore be appropriate to remove reference to “the residential element of Blythe Valley Park” from this policy
• Reference is made at Paragraph 110 to “an area of land of some 7 ha remaining to be developed”. This figure is incorrect, and should instead read 3 hectares. Amendments should be made to the Plan in this regard to ensure that it is sound, and any references within the Council’s evidence base updated accordingly. IM are already formulating plans to develop out the remaining land at BVP during 2021, at which point there will be no developable employment land along the A34 corridor
• Paragraphs 111 and 112 of the supporting text make reference to various expectations that the Council have of any development at BVP. Given the extent of development that has now been brought forward, we consider that this supporting text should be updated to better reflect the current position with the site

Object

Representation ID: 14203

Received: 14/12/2020

Respondent: IM Properties - Employment Land

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As has been set out in previous representations to the Plan, IM also control an area of land to the east of the M42.
This land is bound by the BVP estate road to the south, the A3400 to the east, and the M42 to the west

Whilst the site lies within the Green Belt, it is considered to be in a suitable location for further employment uses due to proximity to the motorway network and the cluster of high quality employment uses that have developed in this location, based at both BVP and Fore Business Park
Whilst the site was not specifically considered within the PBA Employment Land Review report in 2017, it has many of the same characteristics as the wider BVP site. It therefore has strong potential to form part of the wider BVP scheme.

The 2020 SHELAA assessed the site and confirms that there would be ‘good’ demand attractiveness to occupiers. Analysis of the HEDNA shows there is a greater need for employment sites within the Borough than have currently been identified. It is therefore respectfully requested that further consideration is given to the potential of this site to meet this need.

Object

Representation ID: 14204

Received: 14/12/2020

Respondent: IM Properties - Employment Land

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy P9 ‘Mitigating and Adapting to Climate Change’ sets out an expectation that development within the Town Centre should contribute towards “existing or planned district energy and/ or heat networks”.
Given the pace of change within the sustainable energy sector, IM would suggest that to ensure this policy is future-proofed over the life of the Plan period, text should be added to the end of clause (2iv) that reads “or other suitable sustainable/ low carbon energy solution”. This would support the ambitions of the Government, as set out within the NPPF (paras 149 – 151).

Object

Representation ID: 14206

Received: 14/12/2020

Respondent: IM Properties - Employment Land

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

No specific reference is made to Mell Square within this policy. Clause (7) of Policy P2 states that “A range of opportunity sites will be identified under this policy”. However, it is not clear where these sites will be identified. There seems to be no link made to the emerging Town Centre Masterplan, and it is not clear whether it is intended that the Masterplan will contain relevant information about these ‘opportunity sites’. IM would suggest that clause (7) is clarified, and that reference is made to the Town Centre Masterplan or any other documents as appropriate
The supporting text is inconsistent in how it refers to the ‘Town Centre’. At paragraph 116, bullet four, reference is made to the ‘Heart of Solihull’ area, but it is not clear from the text what area this relates too. Paragraph 116 of the Plan sets out a list of the “primary retail frontages” where retailing activity should remain the main street level use. Specific reference is made within bullet four of point two to ‘Mell Square’.IM are concerned that this approach to protecting retail frontage is too restrictive to allow delivery of the flexibility that is referred to within the main Policy.
It would be more appropriate for this supporting text to refer to ‘active uses’ rather than ‘retail use’. This would allow for alternative uses to be brought forward that would retain street level activity, and contribute to the vibrancy of the centre.

IM welcomes the preparation of the masterplan, and the additional guidance that this gives in terms of more specific proposals and high level design. Would suggest that reference to the Masterplan being “updated by the end of the year” (paragraph 120) are removed. There appear to be inconsistencies between figures quoted within the SLPDS Plan, and the Town Centre Masterplan:

The presence of a comma at the end of paragraph 128 may indicate that it was intended to further clarify the position with further text. IM would welcome further text to avoid any confusion regarding what level of delivery is anticipated during the Plan period. Early feasibility work has indicated that Mell Square could accommodate 400 units.

Paragraph 129 of the supporting text makes reference to an economic appraisal and market analysis undertaken by Amion in 2020. In reviewing this IM consider in the context of current and forecast market conditions the potential for 50,000sqft of office floorspace to be brought forward to be ambitious.

It is therefore important that the Plan and the Town Centre Masterplan contain sufficient flexibility to allow for this to ‘shift’ to other uses if it can be demonstrated that there is a need for them. This is the case in policy P4a and the supporting text to Policy P4c which make specific reference to the fact that town centre residential development may result in a different mix, type or size of housing being provided by new development in these locations.

Support

Representation ID: 14209

Received: 14/12/2020

Respondent: IM Properties - Employment Land

Agent: Turley

Fore Business Park is an existing allocation in the Plan, under Policy P1. IM are very supportive of this allocation, it is relevant to note that given the success of the current park, and that much of the floorspace approved through previous planning permissions has been built out, it is unlikely that any significant further floorspace would be brought forward within this location. This is further reinforced by the presence of Green Belt to the north of the site, preventing any significant future expansion in this direction

Support

Representation ID: 15214

Received: 14/12/2020

Respondent: IM Properties - Employment Land

Agent: Turley

Fore Business Park is an existing allocation in the Plan, under Policy P1. IM are very supportive of this allocation, it is relevant to note that given the success of the current park, and that much of the floorspace approved through previous planning permissions has been built out, it is unlikely that any significant further floorspace would be brought forward within this location. This is further reinforced by the presence of Green Belt to the north of the site, preventing any significant future expansion in this direction