Policy HH1 - Land South of School Road, Hockley Heath

Priority must be given to redeveloping brownfield sites in the Borough over breaches of the Green Belt. Solihull Council should be seeking the plans of Warwickshire to ensure a holistic approach to the area.

A 12% increase in homes in a small village is excessive especially as it breaches the Green Belt. I note plans to address traffic along School Road and regular flooding but given past inaction on these issues, why should these be trusted now? There is no reference to any plans by Warwickshire Council - new houses have recently been built along Aylesbury Road and those residents undoubtedly use Hockley Heath facilities. There are persistent rumours locally of further developments off that Road.

As the current owners of the site have proposed the north east end of the site up to Saddlers Wells lane is to be allocated as a nature reserve. Why is this being removed from green belt status. Retaining the nature area as green belt, as indicated in current plans, will prevent any future builder from changing plans and developing on it.

The policy must not change the Green Belt zone. It should be pushing for developments such as SO2 and NS1. The planning model is outdated, paying no attention to sustainability. Covid has proved not just locals (656) but people from the wider West Midlands have valued and used the country byways for their health and wellbeing. Eroding the Green Belt meadowland and wooded copses for housing will exacerbate the feeble road structure with its 200 extra vehicles, (672), circulating at the congested T-junctions either end of School Road. Neither are 90+ houses in keeping with the current ribbon development.

The plan for 90-100 houses is unsound and unsustainable on a field/meadow for 6-9 horses and countless species of wildlife. The environmental damage will be immense, not just destroying natural habitats including the canal banks but putting extra stress on already stretched electricity and water supplies. Water pressure is so low I have had to install a water pump to shower in the morning. Electricity cuts happen frequently and the increased traffic will cause more air pollution. The cycle lanes should be planned into the road system and the nature-rich canal banks should not be dismantled to provide more access.

Before demonstrating that exceptional circumstances exist to remove land from the greenbelt, SMBC needs to exhaust all Brownfield land use. Within Solihull, there remains a small number of brownfield sites that have not been taken forward for development due to isolation and infrastructure, but solutions need to be identified to overcome these and include them in the Plan before releasing undeveloped greenbelt.

Attention should also be given in the Plan to the exact location of medical services for residents in the proposed developments. Hockley Heath is located the furthest distance from any GP medical facilities than other rural areas in the Plan identified for expansion, all other proposed areas for development are within easy reach of Dr surgeries.

The Plan should also clearly state in detail the infrastructure available within the area. Hockley Heath does not have a bus service to Birmingham Monday - Saturday. The local bus service from Hockley Heath to neighbouring areas with a larger range of services is hourly. Development should take place in areas with a wider range of services and improved/frequent public transport links as opposed to more rural settlements with limited facilities/transport.

The Plan should detail the impact of the motorway network upon areas proposed for development. Hockley Heath is surrounded by both the M42 and the M40 and the village becomes heavily congested when issues on the motorway network arise. The village is also a designated diversion route for the motorway.

The Plan should provide details of improvements required along the canal network where developments are proposed adjacent to canals. Site HH1 would place additional pressure on the canal bridges, one of which needs repairing and would be likely to see an increase in vehicle traffic. Towpath improvements should also be detailed in the plan for developments that are likely to see an increase in towpath use due to their proximity to canals.

Due to a lack of services and infrastructure in Hockley Heath, and the flooding issues experienced in the village, site HH1 should not feature in the Plan.

Limited infrastructure in Hockley Heath, The Parish Council raises the following:
Bus service to Birmingham is on Sunday/bank holidays only.
Nearest train service, Doctor's surgery and pharmacy is 2.5 miles away, via an hourly bus service.
No Post Office.
Primary school concerns regarding over subscription.
Catchment secondary school located 5 miles away.
Large volumes and speed of traffic on School Road and A3400 - SMBC not undertaken a localised traffic impact assessment.
Site HH1 suffers from flooding.
Other rural areas identified for limited expansion have more facilities (i.e. Doctor's).
Pressure on Hockley Heath from Warwick and Stratford upon Avon developments.

Remove from the list of allocated sites and add land at rear of 114 - 118 Widney Manor Road in part compensation to the loss of this site.

The site intrudes into the openness of the Green Belt and is remote from employment opportunities.

1. The site allocation is to be read with the Concept Masterplan. Both have different house numbers in, which is the definitive document. Other planned developments are to be considered outside of the scope of this policy - why? I refer to Site 328 and 49.

2. i. - does this mean conserve it as it is, or enhance it to something different? Does it mean improve the towpath surface. Does it imply that the hedgerow os retained - it is not clear, where it is clear in part ii.

2. ii .- How much hedgerow and tree must be retained, would a token number constitute compliance with the policy?.

2. iv. - How far along either School Road or the Canal does this refer? Or is it limited just to the new development - it is not clear

3. i. - What Financial Contribution, made by who for what. I assume there is a contribution for each child currently, if the school is full there is little more support required, so what does this imply and how is it measured in a transparent way.
3. ii. - Highway improvements in the policy are determined as Speed Reduction and Access Improvements. These are not referred to in any other documents, however other documents do make note that the developer should provide a mitigation for congestion around the school (672) why is this not part of the policy?

3. iii. - "Developer Contributions to primary care health services in the vicinity" - What are these, to who and to provide what? There is no Doctors Practice in the village, so does this mean the developer has to contribute towards one, or is this just to support other locations (Dorridge, Cheswick Green or Shirley) How would anyone know it has happened? Again, why would this policy not apply to any other planned development site (328 & 49?) and "appropriate UHB secondary care". Again how would anyone prove this has been delivered. This type of support is ongoing, so I assume is not aimed at the developer - so what does it mean? - just woolly words!
I have had two recent situations where urgent NHS support was required in the locality of Hockley Heath. One where it was thought that my Mother In Law was having a stroke, while out at a Resturaunt. The Ambulance service suggested the wait would be a hour (4 miles from Solihull Hospital). Upon us taking her ourselves to Solihull Hospital, she waited over 4 hours to be seen by a Doctor.
On Friday afternoon (11/12), I was witness to a car accident involving a Cyclist along the route from School Road to Shirley. This time the Ambulance service would not provide a timescale, and it was in excess of 45 minutes before one turned up.
Both of these lead me to believe the services cannot cope with the current volumes today, adding more people to the extremity of the borough, just leaves these new houses, and those existing in Hockley Heath with an inferior service to those living closer to the built up areas, near the Doctors/Hospitals.
3. iv. - What are appropriate measures in this context? There is little point if the village people can get to the limited range of shops by walking or cycling, if there is no wider access to any real retail stores, any formal entertainment venues or any employment opportunities. What are the wider transport connections planned to join to the other locations being promoted by this Local plan, or just to London or Birmingham? Is it therefore accepted that the motor vehicle is to be used for all other journeys, and therefore where is the traffic studies, and where is the commitment to Electric Charging Points, either at the new properties or locally?
3. v. - Pedestrian crossing - there is no mention of this in any other part of the document. Is this to be near the School, and the access road into the development, or at the Saddlerswell Lane end of the development where the pedestrian footpath is shown on the master concept plan? or both? Is this to be provided by the developer? How is this built into the traffic mitigation plans and School congestion plans?

4. i. - How much access is to be provided is not clear, but how does this comply with 2.i. conserving and enhancing of the towpath. The wildlife needs careful consideration here, to ensure that the existing habitat and corridors are not lost - who is providing the control on this balance?

4. ii. - What does this mean? This development will destroy an area of Green Belt, what more is planned? The Greenbelt should be protected, and maintained as it is, It is not just to show unbuilt areas on a map, it is to provide a living for those working the land, and a home for those living on it. (wildlife) It does not need more people traversing it, whether walking, cycling or any other sort of non motorised activity.

5. Who is the custodian of the policy?, who will be able to defend and police the expectations it places on the allocation? Also when the other allocations 328 and 49 become reality, will the same policies be applied, and how will the people of Hockley Heath see transparent delivery of the Policy principles. If this was an Industrial Company defining its policies, then they would regularly publish, even just to the internal stakeholders, how they are progressing in aligning to the policies.

The terms within the Policy document are too weak, either the policy is the policy and must be followed, or it is not and therefore has little value. There is little to give the reader any confidence that the document has to be followed or how one might determine if the actions expected in the policy have been delivered.
The Policy needs to provide more clarity and responsibility to make it deliverable and the performance measurable.

Develop elsewhere

We need the green belt protected around the village

No developments at all in this location it is simply not a suitable place

Previous objections have raised the issues that surround a development such as that which is planned. The field highlighted for development should remain green belt being home to many animals. It is not right that land that is also constantly flooded and so close to a school can be considered. There are major issues with parking today and it is has been mentioned numerous times that adding more houses and cars into this area very close to a school will result in more dangerous situations than is happening today. There is no duty of care being shown to this issue in increasing the likelihood of a tragedy happening with school kids and parents crossing that road.

School Road is not suitable.

School Rd is not capable of taking any more traffic. It already has a problem with speeding traffic. In places it is almost a single track road. The conjustion and potential for accidents is unacceptable.

The policy should reference the significant archaeological potential of this area and highlight that, prior to the submission of any planning application, a detailed archaeological assessment, including evaluative fieldwork, should be undertaken. It should further advise that results of the assessment should inform the development of a strategy, if appropriate, to mitigate the potential archaeological impact of the proposed development and that this strategy may include designing the development to avoid impacting any archaeological features present which are worthy of conservation.

This will help to ensure that any planning application is submitted with sufficient archaeological information to enable a reasoned and informed planning decision to be made.

As highlighted in the 2020 Archaeological Assessment undertaken by the Warwickshire County Council Archaeological Information and Advice team on behalf of SMBC*, this site has significant archaeological potential. This potential, and the need for further archaeological assessment in advance of the submission of any planning application is not referenced in this policy. As the results of the assessment may influence the final form of the development across this area, it should be.

* WCC Archaeological Information and Advice, 2020. 'Archaeological Assessment to Inform the Solihull Metropolitan Borough Council Local Plan. Additional Sites, 2020'. Warwick: WCC Archaeological Information and Advice

The plan does not take account the nature of small villages. Their unique community is destroyed by mass development.

The village cannot sustain a development of this size. We have a small.school, just lost our post office and no doctors. School Road already suffers from traffic congestion and this would make it worse. This is green belt land which is greatly used by residents and a much needed amenity. We cannot justify lifting it to make a developer rich. There are manybrownfield sites in the region which can be used.

See attachment

The plan should not include the land in Hockley Heath at this time where other more established areas/ sites have been identified within the plan for the reasons outlined above "Hockley will required protection" and the reasons clearly highlighted within section 662-667. The plan clearly identifies the need for the village to be protected from excessive development and whilst the proposal of 90 dwellings in isolation appears proportionate in order to maintain the character and so forth, the items identified in order to provide the necessary infrastructure needed viable are not proportionate and do not consider the natural environment; the traffic adjustments as a key example. The plan should remove Hockley Heath from its proposals.

The plan has focussed on the basic principles of housing development such as schooling, traffic flow and provision of a doctors surgery. However, it has omitted to make reference to 1) the abundance of wildlife within the land earmarked. This is evidenced by the regular sightings of the many families of Muntjac deer, wild birds, otters and Hedgehogs and secondly , the 2) flooding of this land and road ( something highlighted from local searches when we had a property survey completed).The housing requirement doesn't have any robust evidence into terms of how it has been calculated? For example; Is it based on the requirement of positive need, ie, a need for social or affordable housing, a need for sheltered housing, and whether the new houses will be provided by the council or housing associations or if it is developer led where housing is based on the profits method.

Any development will change the historic landscape character of this area from its present state which consists of paddocks and closes with good survival of field boundaries since the 1st Edition Ordnance Survey map.
Planning Recommendations for the PSS:
A programme of archaeological assessment should be undertaken, the first phases of which should comprise detailed desk-based (including a walkover survey) and geophysical survey. This should include an assessment of the impacts of the proposed development upon any historic buildings which survive across and in the vicinity of the application site. This should be followed by a programme of evaluative fieldwork, including fieldwalking and trial trenching, the scope of which should be informed by the results of the earlier surveys. This fieldwork should be undertaken prior to the determination of any planning application in order to provide sufficient information to enable a reasoned and informed planning decision to be made. The archaeological evaluation will inform the development of a strategy, if appropriate, to mitigate the potential archaeological impact of the proposed development; this strategy may include designing the development to avoid impacting archaeological deposits of national significance which are worthy of conservation.
The Historic Landscape Character of this area should be taken into account when considering any planning application for this site.
The plan also omits reference to the following; air quality, pollution etc, more cars on road. What will be done to provide the additional school places /bus services to senior schools given there is no secondary school in the village
. The development will require the implementation of a full functional doctors practice/dentist and and capacity to cope with more residents. There have been several recent developments in School Road and nearby Aylesbury Road. There is also a recent social housing development opposite the Hockley Heath memorial hall. There is also a risk of buy to let expansion so what arrangements are going to be imposed to prevent speculative buy to let investors buying up new properties and renting out at full market rents?
Further more, what control over design and appearance of new homes? Can there be house build, design and materials used like Poundbury in Dorset to make use of local materials and resources and to provide character to enhance the area rather than more bland infill development.
And also what measures will be applied to prevent ribbon development?

No modifications are required.

We write on behalf of Mr Robert Muntz and his family, who own part of the land
proposed for allocation under Policy HH1.
Our clients support the proposed release of this land from the Green Belt and
allocation for residential development. It is considered that the Plan’s intentions
for the site are sound, for the following key reasons:
• The site has strong defensible boundaries, in the form of the Stratford upon
Avon Canal and of a number of roads. These are clear, physical and
permanent boundaries in place which would enable the site to be released
from the Green Belt and would define the limit of development on the site.
• The site lies in a sustainable location, with excellent accessibility to local
services in Hockley Heath, including the primary school and a range of shops
and services. The pedestrian access between the site and the village would be
improved as part of the development.
• Community engagement about potential development on the site has taken
place during the preparation of the Plan. The feedback from this engagement
has informed the criteria within Policy HH1, to ensure that the policy provides
X
for the retention of trees and hedgerows, the management of flood risk and the provision of enhancements to pedestrian safety in the vicinity of the site.
• Our client confirms the deliverability of the site. The site offers a suitable location for development now, it is achievable and housing could be delivered on the site within two years of the adoption of the Local Plan.

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 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.

That HH1 is not removed from the Green Belt and is not allocated for around 90 dwellings owing to the failure to comply with national and local policies, and the failure to correctly assess HH1 as a site of considerable value and importance which precludes development.

see attached representation form

That HH1 is not removed from the Green Belt and is not allocated for around 90 dwellings owing to the failure to comply with national and local policies, and the failure to correctly assess HH1 as a site of considerable value and importance which precludes development.

see attached representation form

No modifications are required.

See attached representation forms

Dear Gary

In response to the letter dated 30 October 2020 Re. Solihull Local Plan - Draft Submission Plan HH1 - Land South of School Road, Hockey Heath we would like to share our views.

We strongly oppose these plans based on the following:
• Unjustified use of green belt land before non-green belt land in the district have been utilised
• Environmental damages to green belt land (nature and wildlife) and removal of the rural feel of the local area
• Increased risk of traffic and foot congestion and accidents on school road, an already very narrow lane, particularly where the new junction will be located. This is of significant concern at school drop off/collection times as we witness already how busy this time is and in relation to lack of safe roadside parking available
• Risk to the limited amenities in Hockey Heath by increasing the site by 12% e.g. school places, medical facilities, local amenities stores and parking
• Lack of specificity of the size of the proposed new properties e.g. how many will be 2 or 3 story (?). Significant concern about further light/sound pollution in the local community.
• Unfair timing of this consultation, taking place during COVID19 when the district is in Tier 3 local down, resulting in issues attending meetings to discuss such matters

Regards
Kimberley Orme,
Resident: 8 Blackberry Avenue, B94 6QE

See attachment

- An additional sub-paragraph to be included under Paragraph “Development of this site should be consistent with the principles of the Concept Masterplan for this site, which includes the following”:
‘Create a place which is safe with a strong sense of identity, incorporating high quality design which meets ‘Secured by Design’ standards to reduce crime and the fear of crime and to this end applicants are encouraged to engage with the West Midlands Crime Prevention Advisor at the earliest opportunity.’

- An additional sub-paragraph to be included Paragraph “Likely infrastructure requirements will include”:
Developer contributions to Police infrastructure to ensure an appropriate level of service can be maintained so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion.

See attached representations forms

The policy should reference the significant archaeological potential of this area and highlight that, prior to the submission of any planning application, a detailed archaeological assessment, including evaluative fieldwork, should be undertaken. It should further advise that results of the assessment should inform the development of a strategy, if appropriate, to mitigate the potential archaeological impact of the proposed development and that this strategy may include designing the development to avoid impacting any archaeological features present which are worthy of conservation.

This will help to ensure that any application is submitted with sufficient archaeological information to enable a reasoned and informed planning decision to be made.

As highlighted on pg. 19 of the 2020 Archaeological Assessment undertaken by the Warwickshire County Council Archaeological Information and Advice team on behalf of SMBC*, this site has significant archaeological potential. This potential, and the need for further archaeological assessment in advance of the submission of any planning application is not referenced in this policy. As the results of the assessment may influence the final form of the development across this area, it should be.

*Warwickshire County Council, 2020. 'Archaeological Assessment to Inform the Solihull Metropolitan Borough Council Local Plan. Additional Sites, 2020'. Warwick: Archaeological Information and Advice