Policy BL1 - West of Dickens Heath

Reprovision of the sports pitches should be secured prior to allocation.

See attachments. LAND AT JACOBEAN LANE, KNOWLE

For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

To ensure the sporting needs from the development are met in line with Playing Pitch Strategy the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

If issues of soundness cannot be overcome- paragraphs 225 and 226 should be amended to remove BL1 from Delivery Phases I and II.

Policy BL1 should be amended in light of the findings of additional evidence gathering, negotiations with landowners, playing field search and masterplan work.

Dear Sir/Madam,

Please find attached representations submitted on behalf of our Clients Messrs Benton & Neary to the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Site Policy BL1 - West of Dickens Heath should be removed as an allocation in the Draft Local Plan.

See attached representation form

I would like to object in the strongest way possible to plans Solihull council have to build houses on football pitches on tythe barn lane. I’m the manager of an under 8’s team at wychall wanderers and building on the pitches will ruin a lot of young peoples lives. Kids don’t have many places nice to go and play football. Both wychall and Highgate next door are valuable areas well worth keeping to help young children play the game they love. Please reconsider these plans and think of the harm you will do to young lives in the local area!!!!!!

I strongly object to any plans to build on the recreational grounds on which many children have played, enjoyed, developed and excelled on. The memories for families have been enjoyed for many years.

The destruction of such a Solihull legacy would be tragic and simply unjust.

I don’t believe I need to say more on the matter.

Dear Sir / Madam,

I am writing to object to the Proposed Site 4 in Dickens Heath. The plans inadequately address even the existing infrastructure problems and go no way to making the site viable for the burden of several hundred new homes on the overstretched local roads, parking and public transport services. The impact of blurring the boundaries of the village will damage its character, road safety and physical environment irreparably and the perceived ‘benefits’ are far outweighed by the costs.

At a time when we are all more reliant on safe outdoor spaces this proposal affects many of our local sports fields and will detrimentally affect both adults and children in the local area. The impact on both adjoining ancient woodland and the local wildlife sites is also unjustified.

It is highly irresponsible to continue to approve development in a flood zone, especially given the spectacular (and repeated) failure of your previous flood mitigation schemes in and around Dickens Heath which have not only flooded homes in the new developments but also caused flooding in areas never previously flooded. A simple visual inspection clearly demonstrates the area is prone to flooding and the clay soil restricts drainage.

The proposed mitigations across the piece, are, in many cases, unachievable which makes the plan far less sustainable than the alternatives which do not have any of the problems outlined here.

Finally, given the manifold problems with Site Four identified above the case for destroying high quality green belt in an area with creaking infrastructure above developing brownfield sites which are the government’s priority has manifestly not been made.

The proposed mitigations across the piece, are, in many cases, unachievable which makes the plan far less sustainable than the alternatives which do not have any of the problems outlined here.


Regards,

Helen Shute
5 Boundary Lane
Dickens Heath
Solihull
B90 1TX

Good morning,


Having only recently moved to the area I was concerned to see the plans for the proposed Site 4 for Dickens Heath.
I would like to add my objection to this plan and to confirm that I agree with the details included in the email below which outlines those concerns.


Regards,


David Shute
5 Boundary Lane,
Dickens Heath,
B90 1TX



Dear Sir / Madam,

I am writing to object to the Proposed Site 4 in Dickens Heath. The plans inadequately address even the existing infrastructure problems and go no way to making the site viable for the burden of several hundred new homes on the overstretched local roads, parking and public transport services. The impact of blurring the boundaries of the village will damage its character, road safety and physical environment irreparably and the perceived ‘benefits’ are far outweighed by the costs.

At a time when we are all more reliant on safe outdoor spaces this proposal affects many of our local sports fields and will detrimentally affect both adults and children in the local area. The impact on both adjoining ancient woodland and the local wildlife sites is also unjustified.

It is highly irresponsible to continue to approve development in a flood zone, especially given the spectacular (and repeated) failure of your previous flood mitigation schemes in and around Dickens Heath which have not only flooded homes in the new developments but also caused flooding in areas never previously flooded. A simple visual inspection clearly demonstrates the area is prone to flooding and the clay soil restricts drainage.

The proposed mitigations across the piece, are, in many cases, unachievable which makes the plan far less sustainable than the alternatives which do not have any of the problems outlined here.

Finally, given the manifold problems with Site Four identified above the case for destroying high quality green belt in an area with creaking infrastructure above developing brownfield sites which are the government’s priority has manifestly not been made.

The proposed mitigations across the piece, are, in many cases, unachievable which makes the plan far less sustainable than the alternatives which do not have any of the problems outlined here.


Regards,

Helen Shute
5 Boundary Lane
Dickens Heath
Solihull
B90 1TX

Below are the reasons I object to planning 350 more houses on site BL1:

• Flooding - the site is flood zone 1, the area floods every single year and the drains in the area cannot cope. Every time there is heavy rainfall on Tilehouse Lane and Tythe Barn Lane the drains are overflowing with water into the roads. The last time flooding warnings were ignored, the plot on Dickens Heath road (0.25 miles away) ended up flooding the newly built houses and families had to vacate from their homes within the first year of living there. The area cannot facilitate houses and by building more you put the houses in the surrounding area at risk of flooding also.

• Green Belt - the land is high protected green belt land. The area is a habitat for natural wildlife. I have seen foxes, deer and bats on numerous occasions on my walks on Tythe Barn lane and building on these plots will disturb wildlife and take away their homes. These objections were ignored by the council when the new plot on dickens heath road was proposed however it did seriously disturb and confuse the wildlife in the area. Two times bats flew into my aunty’s home on dickens heath road when the building works began, which proves the bats were disturbed and couldn’t find their roots. The area on Tythe Barn Lane is high grade green belt for a reason, it is there to protect natural wildlife. The barn on Tythe Barn Lane has never been able to be redeveloped due to it becoming a habitat for the bats. We should not be allowed to build 350 houses only a few yards from where these protected animals live. It will lead to more street lights and lighting from houses which will effect their feeding and foraging and will lead to the needless deaths of a species that has a already declining population.

• Facilities - Whitlocks End car park was only extended a few years ago and it already can not facilitate the growing population in the local area. There are new housing plots on Tilehouse lane and Low brook lane which are less than a mile from the proposed plot. Locals in the area should not suffer from being unable to use facilities due to the council accepting ill thought out plots.

• Traffic - every morning Dickens’s heath road is overflowing with traffic during rush hour. This traffic flows up Tythe Barn Lane. The roads and village were never built for level of traffic it currently has and there are no plans to facilitate the growing population in the area. Adding another 350 houses when there are unfinished new build plots less than a mile away will make the area an incredibly inconvenient place to live.

• Sports - there are two football clubs, a rugby club and a fitbox club on the area proposed to build these new houses. Local sport, leisure and physical activity can help people to live longer, healthier lives. This makes them fundamental to achieving councils’ aspirations for their communities. In the current economic climate and in the face of national challenges such as obesity and mental health, it is vital for these sports clubs to stay in the local area.

With regard to the Draft submission plan above my wife and I wish to register our grave concerns regarding to proposed areas BL1 west of Dickens Heath and BL3 Whitlock's End Farm. Both of these proposals will generate much more traffic and with the already severe traffic issues on mainly rural routes in this area will make the situation intolerable for every ones health, safety and wellbeing. In particular Haslucks Green Road has seen a substantial increase in traffic since the development of Dickens Health and Whitlock's End railway Station. The road is very narrow with severe and dangerous bends between Bills Lane and Tilehouse Lane/ Peterbrook Road this already being a high accident area, more traffic generated from these proposed developments will only exacerbate the problem. Dickens Heath although an award winning site has extensive parking problems with the village gridlocked at peak times, more vehicles from these additional properties would add to the problem.

In addition the loss of the sports facilities in Tythe Barn Lane is not necessary and would be a great loss to the community. We realise that the proposal states that these facilities will be replaced but nothing written as to when and where.

The proposal to run a bus route down Birchy Leasowes Lane is not feasible as the junction with Dickens Heath road has ancient woodland on either side which would prevent the junction being altered to accommodate buses turning safely.

We also have concerns with regard to flooding for example, Tythe Barn Lane was impassable on a number of occasions only this year after not significantly heavy rain, we feel this will only worsen with the onset of climate change. The football grounds at present flood and act as a natural soak away for excess rainwater, building on this land would prevent that happening.

Being conservationists we are also concerned if these proposals are adopted a number of local wildlife and ancient woodland sites would be lost forever also adding to climate change.

To summarise this area has seen extensive development over the last few years with Dickens Heath now much larger than the original plans and the further developments at Tilehouse Lane/ Norton Lane, High Street Solihull Lodge and Lowbrook Lane. We feel only so much development in a relatively small area is sustainable and we urge you to reconsider these proposals utilising brown field sites as opposed to the loss of our endangered and much needed green belt land.

I wish you to register this email as my submission and objection to the proposals in the Solihull Local Plan dated October 2020. In particular I am writing to object to the proposals under Blythe BL1. My objections are as follows:

1.I jointly purchased the above address on 31st January of this year and in that short time I have encountered numerous incidents of flooding in my road and the surrounding area. The water table is high, my garden is already sodden from the rain this week and the culvert on my boundary appears as a river, despite the beginning of the culvert only being some 10 years beyond my property. Traffic already suffers from being diverted when the road floods and alternate routes need to be taken. I am aware that this year, since I’ve moved here, Haslucks Green Road, Birchy Leasowes Lane, Houndsfield Road, Norton Lane / Rumbush Lane junction and Dickens Heath village itself have all had diversions because of flooding in the roads.

2.My property overlooks the fields in question, which are immediately adjacent. There is an enormous amount of wildlife in these fields. There are daily sightings of deer and foxes. We have owls, bats, woodpeckers and any amount of beautiful birds who will lose their extensive rich habitat if the proposed development takes place.

3.The village of Dickens Heath is within my walking distance but it is already at capacity. Parking is frequently an issue, even with the slowdown of lockdown and tier 3 it is impossible to pop into the village to collect a takeaway or do some essential shopping at the one shop (Tesco) without being prepared to wait for a parking space. The character of the village will be detrimentally changed with a large development on this site as it appears that the proposals would increase the capacity of dwellings by some 20%. There is only one doctors surgery AND NO POST OFFICE in Dickens Heath. Despite the proposals for a walkway or a cycle path, this would not sufficiently service the additional population with their daily needs and the roads, which are already busy and overloaded, would not be able to cope.

4.Birchy Leasowes Lane is narrow. Traffic already has to slow down to pass oncoming traffic. The road cannot be widened as it has drainage ditches both sides. The end of Birchy Leasowes Lane at the junction with Tilehouse Lane is a traffic blackspot as faster moving traffic in the latter road speeds around the bend at the point of the junction and there is no proper visibility.

5.The site itself is prime greenbelt land. It is the government’s policy to use available brownfields sites in priority. The site is not suitable for development. It is prone to flooding within its boundaries.

6.The Solihull Local Plan (paragraph 65) discusses spatial strategy. I suggest that the land in question is not highly accessible. It is bounded by two lanes and a B road which is already at capacity. One of the lanes is so narrow that it has traffic calming bollards only allowing one vehicle through at once. There is a suggestion that the proposed settlement will be able to take advantage of the existing facilities in the village. The village cannot cope with such expansion. It was not designed for such an expansion and the village is already larger than originally planned for. The nearest primary school is at capacity and has no chance of expansion. The second nearest primary school would be a drive away (not a walk) for most of the new development.

7.There is a suggestion that some of the proposed new housing would be for those wishing to downsize or for those needing care. Nearby Shirley Town, along the busy A34, has several new developments catering for this need and far outnumbers other types of housing.

8.There are bus stops around the village. The service is poor, buses are rare. Prior to the pandemic the car park at Whitlocks End station was at capacity, in fact there is no space to be had in the car park after 7.30am. so public transport will need to be enhanced.

9. There is a suggestion that the existing sports facilities, football clubs etc will be rehoused. They are perfect where they are. Moving them may not be adequate and would inevitably mean more cars on the roads as the existing ones are accessed from the urban edge of Birmingham, and not through the countryside.

There has been no contextual thought in the process of proposing site BL1 as an allocation. The site cannot be considered available, achievable and deliverable and should be deleted from the Plan.

See attached form and written representations

Draft Solihull Local Plan Consultation Response – Objections and points to be considered.
From Paula Pountney -
44 Langcomb Road,
Shirley,
Solihull,
West Midlands, B90 2PR 10.12.2020

With reference to the above, I understand that one of the main objectives and directives of the plan is to distribute development throughout the borough which is clearly not the case in this plan, as 39% is disproportionately designated to Shirley, with at least 5% being on the green belt.
• There has been a huge amount of development in the Blythe area already in the last 5 – 8 years and a significant amount more than elsewhere, is being planned additionally and this fact seems to have been disregarded.
• Site BL3 is designated as highest value green belt so why build there, when there are clear alternative options?
• Site BL1 is not sustainable, with the only advantage being it is near to Whitlocks End Railway Station. It is wholly inappropriate because it is very high grade green belt land around Dickens Heath rated 7 and 8 status and should have been a red site on the very first round of sustainability appraisals. I understand that The Campaign for the Protection of Rural England has stated that in paragraph 11B of the National Policy Framework because the site has very high areas of ecological value, including at least 4 nature reserves very nearby and a high flood risk, the constraints are proven to be so bad, it’s justified that this land should not be included for development.
• National government guidelines state that Natural Wildlife sites should have interconnecting routes, so why is site BL3 and BL2 included in the plan?
• Why have only such a small number of dwellings - in the region of 3000, been designated for the HS2 site, when it could easily accommodate three times that number? It would be a much superior option with great transport links, job opportunities and much less environmental damage.
• Regeneration in Chelmsley Wood - which appears to have little housing allowance being considered for the town, which is classed as an urban renewal area. This would be a much more appropriate area for extra development environmentally and for future sustainability.
• As previously recorded at the Council, the Solihull Town Centre Masterplan should be brought forward including many suggestions made several years ago. Following the very sad demise of Shops such as those in the Arcadia Group and also soon to be closed - House of Fraser, much of the redundant shop and office space could be re-developed for housing accommodation. It’s a stark fact that since the pandemic, many more people work from home and much of the structure of people’s lives have completely changed and this alone should be a critical reason for the overhaul of the whole plan.
• Alternative locations – such as the Tidbury Green Golf Course Site should be strongly considered as it’s nearer the Railway Station, and would allow preservation of the gaps between Shirley, Dickens Heath and Cheswick Green, preventing coalescence of areas.
• Why have the Council not agreed to these suggestions, in order to protect the majority of the sites on the greenbelt? More importantly, the kind of homes that are most needed, in locations that promote sustainable travel.
• Loss of vast amounts of sports grounds/playing fields with no mention of where all this valuable resource could be re-located? This would result in a loss of health and well-being to the community, which would be a total disgrace!
• The pandemic has had a drastic effect on Doctors Services already completely stretched and failing to keep pace with current demand. This is due partly to the existing retirement and extra care facilities, with more to follow. We know that there is an ageing population and the demographic is 30% higher in this area than the national average. This presents a massive challenge to existing services and should be acknowledged and mitigated by the plan. This has not been addressed, as far as I understand.
• I believe that there has been no extra provision for Hospitals, Dentists and other services featured in the plan. Infrastructure investment has not been clarified and the mechanisms designed to ensure Developers pay fair costs have not been outlined. The consequences of this could be disastrous, as future health and wellbeing have not been addressed. It should be mandatory, in my opinion that Developers are held to scrutiny regarding the protection and enhancement of high quality health and social care Services.
• Roads will be totally gridlocked in Shirley. The traffic is already to utmost capacity, resulting in even more air pollution and noise. This will really exacerbate problems to access the M42. It is also a really terrible idea for additional traffic to be fed through Bills Lane and Haslucks Green Road, which is already highly congested at peak times.
• The Blythe Valley is a well-known flood plain on mainly clay soil, while little or no recognition of this is mentioned in the plan. We are worried about the risk of flooding at the bottom of Bills Lane and Haslucks Green Road, as it is already prone to flood round this area. Will the Council and Developers compensate for any future damage done, as it’s a big risk?
• Solihull should not have to take an extra 2000 houses from the Greater Birmingham area. Andy Street has overseen a lot of development in the centre of Birmingham on derelict and brown field sites and they have brought in an extra £434million to clean up these sites for homes and businesses, easing pressure on Green Belt sites.
• I have been directly advised by Andy Street’s office that Solihull Council are working hard to get a Local Plan in place to provide a safeguard to communities across the borough against a barrage of speculative and unwelcome planning applications. The email stated that the Council have been determined to maximise the use of sites like UK Central and Solihull Town Centre to ease the pressure on the Green Belt Sites. The email states that there is a genuine and serious attempt to meet the challenge and he will continue to work with the Council to do whatever he can to help them in their ambition to defend the Green Belt.
• Is this truthfully the case? As I mentioned earlier in the point about building more development in Solihull town centre, Chelmsley Wood and UK central, why can this not be undertaken before the undesirable outcome of building on the precious Green Belt?
• This plan should be considered unsound as due diligence does not appear to have been carried out on analysing sustainability of the individual sites.
• I do not consider 6 weeks consultation to have been enough time for the public to have had time to adequately study the plan and it has very unfairly been pushed through under the cover of the pandemic. It’s almost like a smokescreen and other Councils have given people much longer to state their opinions and this can only be detrimental to Shirley!
• It’s really difficult to comprehend why the Developers have so much power over Councils to force development on the Green Belt? Shirley has 3 Green Party Councillors acting on our behalf that are opposed to so much development, particularly on the Green Belt in Shirley. Surely, in a democracy they should have a great deal of influence, after being voted for by the people of Shirley? How can Solihull Council impose this plan and believe it is fair and equitable to the already wonderful town of Shirley?
• Finally, please re-consider this contentious, unfair, unfinished plan adversely affecting Shirley. If continued, it will be a drastic legacy for the Council which will ruin the character and identity of Shirley.
Thank you
Regards

Paula Pountney

I was to make a formal objection to the extension of the dickens heath site on behalf of my household:

My reasons for objection are:

The loss of key habitats and ancient woodlands which are vital towards the biodiversity.

The loss of significant greenbelt land, hedgerows and key habitats which fall under the wildlife and countryside act 1981. Brown belt Should be first used and greenbelt at the last resort.

The lack of infrastructure, schools and increase in traffic around the area.

Increase in air pollution, flooding, car dependencies, loss of natural beauty which will impact of human physical and mental health.

This is a pure greed development and not required.

My personal recommendation after consultation with the CPRE is that you would consider to halve the proposed housing numbers for both sites BL1 site 4 and site BL2 site 12. which would preserve some much needed space and green belt. and the excess housing numbers should be re considered for the area east of the borough near the HS2 interchange which would benefit from cutting excessive commuting across the borough and pollution.

Regarding the housing proposals and numbers for the South Shirley Area. While i am pleased to see site 11(668) is in progress and is suitable for the location i still have grave concerns over the size of area and excessive loss of greenbelt regarding site 12((BL2) and site 4 (BL1) which are clearly not Brownfield sites as promised by Council MPs and also mentioned in the NPPF which is too great for space regarding coalition of areas south Shirley Dickins Heath and Cheswick Green. In its current Draft proposal i will object to because of the excessive housing numbers for sites 12 BL2 and sites 4 BL1 which if go ahead will cause serious over crowding and local infrastructure problems for the south shirley area and will increase pollution and a great loss of environmental wildlife. Added to this we are too close to the border draft plans of Bromsgrove and Worcester who are also planning large scale allocations near the area proposed.

My personal recommendation after consultation with the CPRE is that you would consider to halve the proposed housing numbers for both sites BL1 site 4 and site BL2 site 12. which would preserve some much needed space and green belt. and the excess housing numbers should be re considered for the area east of the borough near the HS2 interchange which would benefit from cutting excessive commuting across the borough and pollution.

Following a discussion with the CPRE and NPPF I would ask you to re consider.

I object to the latest developments for the following reasons:

- There are numerous sports fields included so this will affect our children (and adults) who play rugby and football on these fields, including Old Yardleians Rugby Club, Highgate Football Club and Wychall Wanderers Football Club, as well as Fitbox boot camp on the rugby field.

- The land is high grade GREEN BELT – Government policy is to protect Green Belt and develop Brownfield land first.

- Site 4 is surrounded by Local Wildlife Sites and Ancient Woodland – this will be so detrimental to the deer, badgers, bats and other wildlife that roam in these fields and adjoining woodland.

- The narrow rural road network cannot take further development and is already overloaded.

- Site 4 is mostly in flood Zone 1, these fields flood every winter and whenever there is a particularly heavy rainfall as the area is of bolder clay that restricts permeability.

- Sustainability – Some of the mitigation measures included in the Plan are not achievable, therefore it isn’t sustainable. Other sites are more sustainable.

- The character and setting of the Village will be adversely affected and sense of community and identity compromised. There are strong, definable boundaries to the existing Village being the canal and the woodlands and ancient hedgerows.

With regard to the planning permission for Site 4/BL1.


I would formally like to make an objection to this being passed. I have lived in Dickens Heath since 1997 and am appalled that it is proposed for more housing to be built around here. Initially the plans were for 850 houses!! The character of our village has already changed from a rural idyll to just another suburb.


1. How will the existing village deal with the amount of traffic being forced through? Tythe Barn Lane is already jammed with traffic from people leaving the village towards Dickens Heath road and Miller and Carter. I have witnessed traffic at a standstill for 20 minutes or more. Tythe Barn Lane is not suitable for the increase in traffic. The road is too narrow for more traffic. Irritated drivers already sit outside my house sounding their horns because their passage is impeded. This is not an "A" road it's a road that was built to discourage traffic and traffic calming measures are in place - the main one being the width.


2. The traffic at school times is already dangerous. I have witnessed bad parking and worse still bad driving when drivers mount the pavement during peak times. This will only get worse if there are more houses built. More houses = more cars = more children = accidents.


3. The rural roads in this area cannot take increased traffic. The roads are too narrow.



4. I thought the proposed area was greenbelt. At a time when everyone is looking to be eco and environmentally friendly this can only be detrimental to our wildlife and the wellbeing of people who use this area.


5. Surely there are brownfield sites, especially in this changing environment where businesses are vacating because of the economy which can have a change of use to housing. Commercial sites could be converted.


6. There are a number of sports fields that are going to be lost and they form an integral part of our village for children and adults alike. Exercise is so important and even more so in the present climate. We should not be losing the facilities we have.


I sincerely hope that more consideration is going to be given to this application. The people who live in Dickens Heath and surrounding areas are going to be adversely affected by this development.

Solihull Council’s Local Plan Review is now inviting comments about "Site 4"– which means proposals to build 350 homes in Dickens Heath.

Below in details I explain why I'm against your proposals:


- There are numerous sports fields - The land is high grade GREEN BELT – Government policy is to protect Green Belt and develop Brownfield land first.
- Site 4 is surrounded by Local Wildlife Sites and Ancient Woodland – we should work how to protect it and not how to make easy to destroy it. Deers, badgers, bats and other wildlife are still there.
- Road network in area is already overloaded.
- Site 4 = flood Zone 1 and that can only make a trouble in future.
- The character of the Village will be adversely affected
- Sense of community and identity compromised.

I wish to object to the proposed development at site BL1 for the following reasons.
1. There has already been excessive development in the area with Dickens Heath more than doubling in size; Tidbury Heights on Fulford Heath Road and Regency Fields.
2. We were told that the area would Green Belt after the building of Tidbury Heights and Regency Fields.
3. Traffic levels have significantly increased with the resulting congestion.
4. There are other sites in Solihull Borough that are more sustainable and with better facilities that seem to have been ‘overlooked’ eg Dorridge, Knowle, Hampton in Arden and others.
5. The building of the site will cause coalescence between Tidbury Green, Majors Green, Dickens Heath and Shirley with the resulting loss of identity.
6. Access to Dickens Heath Village Centre can only be achieved by car.
7. Vehicles and any bus will use Birchy Leasowes Lane which is narrow with dangerous junctions at either end. Many local people will not use this road because of the danger.
8. There will be the inevitable loss of wildlife and damage to the environment.

I want to object to the council proposed plans to build yet more housing in the Dickens Heath area for the following reasons.
There are numerous sports fields included so this will affect our children (and adults) who play rugby and football on these fields, including Old Yardleians Rugby Club, Highgate Football Club and Wychall Wanderers Football Club, as well as Fitbox boot camp on the rugby field.
- The land is high grade GREEN BELT – Government policy is to protect Green Belt and develop Brownfield land first.
- Site 4 is surrounded by Local Wildlife Sites and Ancient Woodland – this will be so detrimental to the deer, badgers, bats and other wildlife that roam in these fields and adjoining woodland.
- The narrow rural road network cannot take further development and is already overloaded.
- Site 4 is mostly in flood Zone 1, these fields flood every winter and whenever there is a particularly heavy rainfall as the area is of bolder clay that restricts permeability.
- Sustainability – Some of the mitigation measures included in the Plan are not achievable, therefore it isn’t sustainable. Other sites are more sustainable.
- The character and setting of the Village will be adversely affected and sense of community and identity compromised. There are strong, definable boundaries to the existing Village being the canal and the woodlands and ancient hedgerows.
In addition to this the local infrastructure cannot cope with the existing housing and population. To add to this will severely worsen the situation.
There are plenty of brownfield site in the Solihull MBC area that could be built on rather than further r eroding the green belt.

I wish to add my opposition to the above development.
Having lived in the area for over 40years I have seen the results of the building of more and more homes on this green belt.
The country lanes are filled with more traffic, much of which is oblivious to walkers, cyclists and horse riders.
Dickens Heath itself is totally spoilt by the number of cars on its narrow roads.
New developments in Tidbury Green are adding to the strain on local amenities, in particular G.P centres.
Surely there must be more environmentally suitable areas to build new homes.

I have lived in Dickens Heath for 20 years. I have seen the amount of houses go up after being told no more would - the amount of issues that have risen from all these houses with no sufficient drainage so the roads and gardens flood (the fields that are left can't hold the water so how are more houses going to help?)
I have a horse near the village and since the new developments have been built, countless times now have we been vandalised e.g. broken into, things chucked in the field, people trying to get in the field with our horses (mostly kids because i assume they have nothing better to do), and now EVEN MORE housing is going up.. how is it going to help anything other than the fact a building company gets a big wad of cash. No concern to those who have been here from the start of Dickens Heath, no concern to those who have seen what it used to be like - a rural village surrounded by fields, farmers, livestock etc. But now roads are being ruined and nothing is done, crime rates are going up and nothing is done... see a correlation?
I'm sure if you even read this email you will probably think i'm talking nonsense. It used to be lovely and quiet and what is it now? You get yobs walking around doing drug deals outside your house, you get people going the wrong way around the roundabouts, people speeding down country lanes when there are working farms moving cattle, constant complaints about the state of the roads and about the flooding... but you don't choose to address the problems of those who have lived here from the start, you choose to listen to those who could move here and give you money.

I am writing this email to request you think twice about your decisions especially at the time of covid-19 when we are getting told if you are over weight you are more likely to die yet you are choosing to take away our sport clubs this dose not only infected our health but the community will not be the same think about when you were a child if someone took your friends away the place you feel safe your passion you would feel terrible it would effect your life think about what you are doing to our children

I wish you to register this email as my submission and objection to the proposals in the Solihull Local Plan dated October 2020. In particular I am writing to object to the proposals under Blythe BL1. My objections are as follows:

1. I moved to the above address in the spring of this year and in that short time I have encountered numerous incidents of flooding in my road and the surrounding area. The water table is high, my garden is already sodden from the rain this week and the culvert on my boundary appears as a river, despite the beginning of the culvert only being some 10 years beyond my property. Traffic already suffers from being diverted when the road floods and alternate routes need to be taken. I am aware that this year, since I’ve moved here, Haslucks Green Road, Birchy Leasowes Lane, Houndsfield Road, Norton Lane / Rumbush Lane junction and Dickens Heath village itself have all had diversions because of flooding in the roads.
2. My property overlooks the fields in question, which are immediately adjacent. There is an enormous amount of wildlife in these fields. There are daily sightings of deer and foxes. We have owls, bats, woodpeckers and any amount of beautiful birds who will lose their extensive rich habitat if the proposed development takes place.
3. The village of Dickens Heath is within my walking distance but it is already at capacity. Parking is frequently an issue, even with the slowdown of lockdown and tier 3 it is impossible to pop into the village to collect a takeaway or do some essential shopping at the one shop (Tesco) without being prepared to wait for a parking space. The character of the village will be detrimentally changed with a large development on this site as it appears that the proposals would increase the capacity of dwellings by some 20%. There is only one doctors surgery AND NO POST OFFICE in Dickens Heath. Despite the proposals for a walkway or a cycle path, this would not sufficiently service the additional population with their daily needs and the roads, which are already busy and overloaded, would not be able to cope.
4. Birchy Leasowes Lane is narrow. Traffic already has to slow down to pass oncoming traffic. The road cannot be widened as it has drainage ditches both sides. The end of Birchy Leasowes Lane at the junction with Tilehouse Lane is a traffic blackspot as faster moving traffic in the latter road speeds around the bend at the point of the junction and there is no proper visibility.
5. The site itself is prime greenbelt land. It is the government’s policy to use available brownfields sites in priority. The site is not suitable for development. It is prone to flooding within its boundaries.
6. The Solihull Local Plan (paragraph 65) discusses spatial strategy. I suggest that the land in question is not highly accessible. It is bounded by two lanes and a B road which is already at capacity. One of the lanes is so narrow that it has traffic calming bollards only allowing one vehicle through at once. There is a suggestion that the proposed settlement will be able to take advantage of the existing facilities in the village. The village cannot cope with such expansion. It was not designed for such an expansion and the village is already larger than originally planned for. The nearest primary school is at capacity and has no chance of expansion. The second nearest primary school would be a drive away (not a walk) for most of the new development.
7. There is a suggestion that some of the proposed new housing would be for those wishing to downsize or for those needing care. Nearby Shirley Town, along the busy A34, has several new developments catering for this need and far outnumbers other types of housing.
8. There are bus stops around the village. The service is poor, buses are rare. Prior to the pandemic the car park at Whitlocks End station was at capacity, in fact there is no space to be had in the car park after 7.30am. so public transport will need to be enhanced.
9. There is a suggestion that the existing sports facilities, football clubs etc will be rehoused. They are perfect where they are. Moving them may not be adequate and would inevitably mean more cars on the roads as the existing ones are accessed from the urban edge of Birmingham, and not through the countryside.

The reason for objections are as follows:

Your possible comments might be around:

- There are numerous sports fields included so this will affect our children (and adults) who play rugby and football on these fields, including Old Yardleians Rugby Club, Highgate Football Club and Wychall Wanderers Football Club, as well as Fitbox boot camp on the rugby field.

- The land is high grade GREEN BELT – Government policy is to protect Green Belt and develop Brownfield land first.

- Site 4 is surrounded by Local Wildlife Sites and Ancient Woodland – this will be so detrimental to the deer, badgers, bats and other wildlife that roam in these fields and adjoining woodland.

- The narrow rural road network cannot take further development and is already overloaded. The congestion within Dickens Heath at peak times is not sustainable.

- Site 4 is mostly in flood Zone 1, these fields flood every winter and whenever there is a particularly heavy rainfall as the area is of bolder clay that restricts permeability.

- Sustainability – Some of the mitigation measures included in the Plan are not achievable, therefore it isn’t sustainable. Other sites are more sustainable.

- The character and setting of the Village will be adversely affected and sense of community and identity compromised. There are strong, definable boundaries to the existing Village being the canal and the woodlands and ancient hedgerows.

1. The Plan is un-sound as an accurate, up-to-date analysis of the capacity of the Solihull Town Centre to accommodate additional housing has not been undertaken, particularly in view of Covid and the inevitable closure of many town centre shops and offices. Only then can the number of houses needed to be built in the Green Belt be calculated.
2. Site BL1, west of Dickens Heath (also referenced as Site 4) is in a high performing Green Belt area, which has not been taken into consideration in the Sustainability Appraisal. Central Government Policy is to protect the Green Belt and develop on Brownfield land first.
3. The Sustainability Appraisal tries to prove that this Site is sustainable when it clearly is not, owing to the numerous mitigation measures proposed to try and make it sustainable, some of which are unachievable.
4. The sports fields can be re-located but at some upheaval to the clubs and members, but why move them in the first place?
5. The Council have not undergone a proper scrutiny of all other more sustainable sites in a sequential test that would have fewer constraints if the Sustainability Appraisal had been carried out correctly in the first place, before the site allocation, rather than trying to make the pre-selected site allocations fit the Plan.
6. This proposed development will be un-associated, both visually and physically, with the award-winning Village of Dickens Heath. The character and setting of the Village will be adversely affected and sense of community and identity compromised. There are strong, definable boundaries to the existing Village being the canal and the woodlands and ancient hedgerows. The proposal falls outside the Village’s built-up boundary.
7. Site BL1 is surrounded by Local Wildlife Sites and Ancient Woodland. Although the Council state that to mitigate for the proposed development the area can be enhanced, they have not considered the very important connectivity of these important ecological sites. Indeed, Natural England have stated that “Ensure current ecological networks are not compromised, and future improvements in habitat connectivity are not prejudiced.”
8. Traffic & Village centre parking. The Traffic Study does propose some works to improve the congestion in peak hours but the situation will be further exacerbated by the huge number of new homes proposed in the Blythe area and South Shirley. The Council only propose to solve the Village Centre parking problem by controlling some on-street parking which will not solve the existing problem and will only be made worse with more development. The narrow, rural road network cannot take further development and is already overloaded.
9. The proposed development is not within a recognised walking distance from the Village Centre facilities, so further adds to the un-sustainability of the development. The Council state that a new footpath will be needed to the private road of Birchy Close to reduce the walking distance but this is legally unachievable. They suggest that a new bus route down Birchy Leasowes Lane could be provided but how will a bus exit the junction with Dickens Heath Road safely? At this junction the ancient woodland either side of this junction would inhibit any road improvement which has not been recommended. All the proposed footpaths are welcomed and should have been put in place many years ago to facilitate the extensions of the existing Village. The Village already acts as a commuter settlement with higher than average car ownership. Additional housing will only exacerbate the use of the car contributing to global warming.
10. Although the flooding report states that Site BL1 is mostly in flood Zone 1, local residents have evidence that the sports fields flood nearly every year because of the increased rainfall due to climate change and the fact that this area is of bolder clay that restricts permeability. Even given the fact that a sustainable urban drainage (SUD) system is proposed, this all adds to the unsustainability of this site when other “Amber” sites have far less constraints.

1) I am concerned that there are no proposals for the relocation of the sports fields that are being removed. These must be located within this area to allow the present users easy access.

2) Traffic is a major concern the roads around this area are already very busy for most of the day. Tythe Barn Lane is already very congested in the peak times and when schools start or finish. To have another large number of houses each with possibly two cars will make the situation here chaotic to say the least. And what of the lack of parking provision on the main Dickens Heath site? People will use cars to go to the village center where parking is already in high demand. The council has already made on street parking around Dickens Heath difficult by yellow lines in many areas where parking could safely take place!

3) Another concern is flooding again in the area along Tythe Barn Lane where the road itself is often like a river during periods of heavy rainfall.
The playing fields along with the road suffer the same fate and become like marshland when deluges occur and this is where you plan to build houses. I thought housing could not be placed in areas at risk from flooding