Policy P15

The White Paper Fixing our broken housing market is indicating a change to national policy to recognise the value of using a widely-accepted design standard, such as Building for Life 12, and making it clear that this should be reflected in plans and given weight in the planning process. Richborough Estates Limited does not object to this as a matter of principle.

However, the dogmatic application of national standards and the other advice/guidance contained in the documents referred to in Policy P15 should be avoid because, in some circumstances, they can stifle innovation, originality or initiative design of the type referred to in the National Planning Policy Framework. Master plans for developments should fit their context because there is no a one size fits all approach available in national design guidance which can be adopted in all cases.

Policy P17

As sought under Policy P20 and the site-specific representation concerning land West of Dickens Heath (Potential Housing Allocation 4), Richborough Estates advocate the removal from the Green Belt of the land generally contained by Tythe Barn Lane, Tilehouse Lane and the Stratford upon Avon Canal to the north of Dickens Heath as a specific allocation for outdoor sports and recreation, namely a Community Sports Hub.

However, in the alternative, the current drafting of Policy P17 is such that a change of use of land to accommodate outdoor sports and recreation uses requires very special circumstances. Richborough Estates Limited object to this policy because it should be amended to enable such changes of use in Solihull Borough to be regarded as not inappropriate development.

Although the forthcoming amendment to the National Planning Policy Framework cannot be fully known at the current time, one of the potential matters which could be addressed is the re-instatement of the previous policy which allowed for changes of use of land provided such uses do not adversely affect the openness of the Green Belt. The reintroduction of this policy would address the anomaly that buildings associated with sports and recreation uses in the Green Belt may be considered as not inappropriate development. The White Paper Fixing our broken housing market has started to consider this point by suggesting that facilities for cemeteries may be included in the Framework as not inappropriate development in the Green Belt which is a response to Case Law.

Irrespective of any change to the Framework, if the Borough Council wishes to promote a healthy lifestyle for its residents then the opportunity exists for Policy P17 to support outdoor sports and recreations uses within the Green Belt by allowing changes of use of land provided the individual proposals preserve the openness of the Green Belt. The need for very special circumstances can be obviated by a redrafting of Policy P17.

If there are concerns that such an amendment would be drafted too widely a refinement could be that the Proposals Map identifies areas where such changes of use within the Green Belt would be assessed as not being inappropriate development. In this context, Richborough Estates would encourage the Council to identify land generally contained by Tythe Barn Lane, Tilehouse Lane and the Stratford upon Avon Canal to the north of Dickens Heath as a location within the Green Belt for outdoor sports and recreation as part of Policies P17 and P20. The principle of land being identified for such uses and remaining in the Green Belt has been incorporated into the Warwick District Local Plan to the south of Kenilworth. This assumes that the land is not, as advocated by Richborough Estates, taken out of the Green Belt and allocated as a Community Sports Hub.

The provision of a Community Sports Hub can deliver the approach identified in the White Paper of securing compensatory improvements to the environmental quality or accessibility of remaining Green Belt land, particularly for community, sporting and recreation purposes.