Policy KN1 - Hampton Road, Knowle

To build low density housing next to the current dwellings already in situ and to provide a full plan of the type of housing to be built to enable a proper appraisal of the plan by local residents.

I live on Alveston Grove which backs onto the proposed development, KN1 Purnells Brook to Hampton Road. The immediate plan to build 'medium density housing' closest to the current development does not appear at first glance to be 'in-keeping' with the current housing already in situ. I have no objection per-se to the housing development however, I believe that the current proposal is not in sufficient detail as to the type and format of the housing proposed to allow for full appraisal of the plan. Low density housing needs to be next to the current housing.

I believe that Knowle currently has around 4,000 homes. The current proposals would see this increased by at least a further 1,000 homes. This is an increase of in excess of 25% and considerably more than that anticipated elsewhere in Solihull. It also needs to be considered against the growth in population which the area has seen in the recent past. The local infrastructure is unable to cope with the current volume of use at peak times with the current population. There are a number of road bottlenecks particularly the High Street and Station Road causing considerable traffic congestion. The shopping facilities and related parking provision within Knowle are again sufficient for the current population level but would require considerable enhancement to cope with such an increase in usage. It is difficult to see how this could be accommodated within the current footprint.
There is not a significant pool of employment opportunities within Knowle and most of the residents travel elsewhere for work thus leading to the peak time issues with regard to road congestion. Additionally the capacity at the local railway stations is limited with all available car parking largely full by 8am.
The green belt which surrounds Knowle is a significant local amenity which is used and enjoyed by many residents for activities such as exercise and dog walking. I think many local residents have grown to appreciate these areas during 2020 and they should be safeguarded rather than destroyed. The green belt also serves as a key separation of development and any loss should not be taken lightly. Any reduction in the green belt would be a great loss both to the rural feel of Knowle and to the quality of life of future residents.
We are all encouraged to cut down on consumption of fossil fuels and environmental emissions. It is likely that significant further development of Knowle and surrounding villages will serve to increase such impacts as there would be additional journeys to employment bases. The development of further housing accommodation should be better coordinated with the expected commercial development within the Solihull area.
In conclusion I believe that the green belt and open spaces should be protected in order to prevent urban spread and provide open space for recreational use. Through 2020 such areas have been increasingly used and appreciated by local communities and should be safeguarded for future generations rather than built on. Accordingly I believe that the proposed developments in the Arden Triangle and along Hampton Road are inappropriate and should not be adopted within the final version of the development plan.

Inappropriate development of the local area.

Dear Sirs
Solihull Local Plan- Draft Submission Plan
Proposed Allocation Site: KN1 Hampton Lane Knowle
Further to your letter of 30 October 2020 sent to me as I am adjacent to the above proposed allocation, I wish to question the viability of including this greenbelt site in the Solihull Local Plan.
It is not possible to establish the true ownership of the various parts of the site KN1, but it is likely that it is in at least 4 different ownerships:
1. Knowle Football Club, I believe this is owned by Knowle Cricket Club and subject to restrictive covenants.
2. The former Thacker’s Nursery I believe is owned by Umberslade Investments.
3. The fields in front of Thacker’s Nursery fronting onto Hampton Road used to be owned by the Southall family formerly of Grimshaw Hall, current ownership unknown.
4. The fields beyond Thacker’s Nursery running up to the canal and also fronting onto Hampton Road, current ownership unknown.
In your proposals you have treated them as a single entity, we believe that the site cannot be delivered in this way for the following reasons:
The Football Club is unlikely to have the funds to purchase and satisfactorily develop the steeply sloping site by the canal into workable level playing pitches ahead of the sale of their existing pitch. This is assuming that the Cricket Club will part with the proceeds of sale and also pay the Community Infrastructure Levy. In the past we believe the Football Club have struggled to maintain their present clubhouse, will they have the necessary funds to build and maintain a larger complex with the necessary parking etc? Do the restrictive covenants prevent the existing football pitch being developed? The removal of any covenants could necessitate legal action, if so who pays for this?
The agricultural fields in front of Grimshaw hall fronting Hampton Road, currently being Greenbelt have a limited value. Will the owner of these fields be prepared for this land to become Public Open Space thus not benefitting from the enhanced value enjoyed by the owner’s of Thacker’s Nursery, even though the residential development is supposedly dependent on this open space.
The owners of the fields that are proposed to form the new sports complex again will not have the advantage of the hugely inflated land values enjoyed by Thacker’s Nursery. One must question whether this land will be available as sports pitches at an affordable price.
It would appear that the whole of KN1 has been submitted as a possible site on a number of assumptions that may not be deliverable. If the site is taken out of the Greenbelt it is possible that the developers will seek permission to develop Thacker’s Nursery on its own, which should be resisted as it forms part of “The Meriden Gap”, and in the most part forms an extension of the urbanisation, rather than a “Rounding Off”.
Before finally submitting our views on your portal we would be obliged if you explain to us how the KN1 scheme can be delivered as an entity, taking into account all of the various ownerships. We can only imagine the future disagreements over land values and who pays for what between the owners.
Yours faithfully

There is no justification to move the football club. It should be developed where it is.

The proposal to move the football club to the edge of the built-up area would be reasonable ONLY if floodlighting were to be permanently banned, otherwise it would have a severe impact on the surrounding countryside, espevially as it is on a high part of the site.

I would like to see the loss of this area compensated locally with much more ambitious habitat creation. The plan shows no additional provision for wildlife which could surely be created by the succession of current arable land to habitat creation. The arable land that is currently between the development and the Hall could be simply allowed to develop into scrub and woodland providing a valuable wildlife corridor for species with a light touch management regime or grazing to retain open features. In addition I would love to see some of the current intensive arable land elsewhere in the area allowed to develop into rough grassland succeeding into scrub and woodland. This would help compensate nature for the loss to these developments.

The plan currently consumes quite a large area of formally agricultural (nursery) land which until this year was developing into a mosaic of scrub and rough grassland. In this state it was occupied by a wide variety of wildlife including invertebrates, mammals and birds. The loss of this area to clearance and subsequent development should not be understated. While I understand the need for development and this site has many logistical values for this plan I do not see on the plan any compensation or mitigation for the loss of a valuable wildlife habitat adjacent to the brook and woodland.

Good idea but needs , housing to dense

There should be a clear statement of the number of units that could be provided in order to include them in the overall figures for Knowle and the Borough. This would enable to TRUE impact to be assessed.

The site currently occupied by Knowle Football club is listed as ' identified as a potential site for the development of a care village or retirement complex' in the Plan. However there is no further information on the size or type of accommodation that could be provide, or justification for such a development.
Also, there should be at least some indication of number of additional 'households' that this could/would provide. As a result the impact on Knowle, which would be additional to the other sites, is unknown.

No provision for the impact on the residents of Chantry Heath Crescent i.e planting trees or a green buffer. Grimshaw Hall is barely visible from Hampton Road yet it is afforded a huge buffer from the development.Unfair.
Low density housing should be built behind Chantry Heath Crescent to mirror the existing housing and not adjacent to a football complex.
Will the football complex be for public use and who will maintain it ?.

This site was rejected in the 2013 master plan as being unsuitable because of the topography of the land. Nothing has changed make it suitable now.

I dispute the assertion that building on this land would "round off" the settlement in a logical manner , Wychwood Avenue is very separate because of the Nature reserve and stream, and Hampton Road houses finish opposite Grimshaw Hall which already forms a logical border to the village.

There is nothing logical about taking green belt to move a football club far from the centre of the village, next to the tranquil canal.

Family homes, green space, sports facilities all central.
Traffic survey and measures
No retirement village
Significantly reduced density to minimise risk of infections spreading

The plan does not consider the impact on the traffic congestion that would be caused entering Knowle.
The number of houses and the density is significantly higher.
Another retirement village is a terrible idea. These properties are springing up all over Solihull, very high density, they are difficult to sell on and I don’t think these are a good option many elderly people.
I don’t think this plan benefits the current residents of Knowle.
The football club should be saved as it is of huge benefit to the local children. It is central to the village people can walk there.

No development on Green Belt land

The nature and density of the KN! development is out of character for Knowle - it is not clear how viable the site is for the development outlined. I don't believe that the council is doing enough to promote active travel and give priority to non motor vehicle road users (although the LCWIP is a good start). I have seen very little justification for building on Green Belt land

Both sites are within a stones throw from one of the most important local historical Grade 1 Listed buildings in the borough, more importantly the historic village of Knowle.

Grimshaw hall and its grounds have been made a conservation area by SMBC, as such the greenbelt areas directly connected to them need to be protected to ensure a sustainable habitat for its richly diverse nature such as:

Buzzards
Owls
Swifts
Kingfishers
Other Migratory birds
Bats
Adders and grass snakes

The Greenbelt areas directly bordering the Hall should be preserved as greenbelt. KN1 negatively impacts the views and Historic rural element to residents of the village.

The KN1 development is mostly greenbelt and due to its connection to the hall and connected conservation areas should the KN1 proposal should be scrapped, and alternative site found.

It is my belief that the councils decision is being driven by the landowner looking to create a windfall profit from what is agricultural land.

I do not accept SMBC's justification to develop it, I do not believe the council has exhausted its search for alternative sites.

Alternative areas should be found, such as areas adjacent to Browns Lane in Bentley Heath, this area is more suitable due to it not being in the direct vicinity of Historical gardens and buildings. It is also nearer to the M42 corridor. If this is not suitable, the council should continue its search rather than develop in sensitive green belt next Historic buildings where, Any development can never be reversed.

I do not accept the councils plan to merely move the development a few meters further back so the housing sits downhill and out of site. This does not address the issue of developing in an Historically and Environmentally sensitive area which dates back to the 15th century. No further amendment to this site is acceptable to the residents of Knowle. The site needs to be scrapped and an alternative site found.

Development of precious Greenbelt
Development too close to designated Conservation area
Development too close to Grade 1 Historical building
Negative impact on local nature and birds

Stop building on greenbelt land - move to brown belt land elsewhere

Use of greenbelt land
Lack of infrastructure improvement - Road, public transport and parking. Increased traffic congestion on Knowle High Street plus excessive strain on
Increased population creating further stretching of already fully booked two local GP surgeries with no provision to support in plan.
Increase in school places required predominately because of excess building in the village over the last ten years, and accepting pupils outside of catchment

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 2018 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, 2018. 'Archaeological Assessment to Inform the Solihull Metropolitan Borough Council Local Plan'. Warwick: WCC Archaeological Information and Advice

1. Delay local Plan submission
2. Removal of site from Plan pending further investigation for alternative brownfield sites .
3. Extension of time for enquiries, investigation and reports.

1. In my opinion I consider the plan to use the green belt to be in breach of the Government National Planning Policy Framework Document Section 13 'Protecting Green Belt Land' in particular Paragraphs have not been met in part or full or taken into consideration and are numbered:
133, 134 c, d, e , 136, 137, 138,139, 140,143, 144, 145.
2. In what I consider further breach of NPPF the Council have not adequately demonstrated, investigated, and exhausted the use of Brownfield sites available in the borough as per their 2019 Register https://www.solihull.gov.uk/blr numbering 209 HA and up to 3524 dwellings the Local plan uses just 7 HA (140 Dwellings) of brownfield land as opposed to 340 HA of Green Belt.
3. I consider the Knowle Transport Study dated October 2020 to be missing vital data and other information that was due to be updated in March 2020 but was cancelled due to COVID and therefore is inadequate and to quote the words of the Mark Andrews Solihull Head of Planning in his email reply to me dated 7th Dec 2020 “I should stress though that for the purpose of the Local Plan we must demonstrate that the proposed development could be developed and any impacts it generates could be mitigated in a reasonable way” I do not believe this test has been met.
4. The minimum 6 week consultation period was too short and given the unprecedented Global Pandemic and 4 weeks of this period was a National Lockdown imposed by the Government due process and the ability to engage in person or public was severely impeded and therefore due process could not possibly be achieved for myself or any residents my wholly reasonable requests for an extension of time were refused.
5. I still await full and adequate responses to my further enquiries and just today 14th Dec 2020 (last day for representations) I received a partial reply from Mark Andrews who was absent due to ill health, was there no one else available in his absence or was the Planning Dept disrupted due to the Global Pandemic, further evidence for the need for an extension of time for everyone including the Planning Dept?

Masterplan to include an adequate buffer to Purnells Brook Woodland LWS. Need to correctly define Purnells Brook Meadow LWS.
Alternative paths to provide alternative routes for visitors could be provided through the public open space and link to Grand Union Canal to divert people away from fragile path within LWS.
Need retention of and improvement to ancient hedgerows to facilitate wildlife corridors. This should be included within the policy KN1 2(iii). All hedgerows should be protected and enhanced.
Weight to be given to masterplans needs to be set out to provide certainty for future planning applications.

In circumstances where the site promoters cannot demonstrate during the examination a co-ordinated approach to delivery of the whole site, and a high degree of confidence that the relocation of the football club is viable, then the site allocation should be considered not sound and removed.
In circumstances where the above can be satisfied and the policy is retained, the wording of Policy KN1 and accompanying text should be amended to ensure the club relocation is delivered. In these circumstances Policy KN1 be amended as follows:
- Paragraph 1 should be amended as follows: “The site is allocated for 180 dwellings together with the re-provision of Knowle Football Club”.
- Paragraph 4(iii) should be amended as follows: “The preferred site for the relocation of the existing football club is between the new development and the canal as shown on the concept masterplan. No housing development on any part of the site shall be allowed to commence until such time as the final football club site has been selected, and a commitment and timescale for re-provision is secured.

See attachments

See Attached Word doc.

Modifications as proposed in the representations for Policy KN1 which include:
- Setting out densities specifically.
- Identifying that the area between Hampton Road and the limits of the development shall be landscaped as amenity areas and that mitigation should significantly reduce harm.
- Retention of on-site trees is required.
- Need reference to the sports pavilion when talking about the relocation of Knowle Football Club.
- Retention of public footpath along its current alignment.
- Minimising harmful visual impacts as a result of the engineering works necessary to create the housing and playing fields.
- Need reference to Neighbourhood Plan community access policies in the Policy.
- Need reference to development contributions to local primary care.
- Need reference to specific highway improvement at junction of Arden Vale Road and Warwick Road.
- There should be no departure from the principles set out in the concept masterplan.
- There shall be no commencement of development until a planning obligation has been executed governing the nature of the development; its timing and phasing; and the funding of all aspects. No more than 20% of the housing shall be occupied before the playing fields and sports pavilion are brought into use.
- Additions to paragraph 713 and 714.
- Deletion of paragraph 715
- Correction in paragraph 716 to say that the former hedge line still exists.
- Additional paragraph after paragraph 716:
"Given the need to respect the setting of Grimshaw Hall, and the density characteristics of the surrounding area, low and medium residential densities (up to 35dph) will be appropriate on the northern part of the site. The southern part of the site is closer to the amenities of Knowle village and to higher density development at Wootton Close. Given also the prospect of a care village or retirement complex on the site of the existing football club, a higher density would be acceptable in this location for such a use."
- Amend accessibility commentary in paragraph 718.
- Say that development is consistent with Option F for the limited expansion of rural villages in paragraph 719.

See attachments.

- The developers proposal should be deleted as it adds to confusion as to the status of the Masterplan.
Various modification to the Masterplan as set out in representations including:
- A statement setting out the fundamental aim of the proposals.
- Revisions to the north easterly extent of development.
- Removal of reference to the road being the new Green Belt boundary.
- Reference to Neighbourhood Planning policies.
- Retention of footpaths along current alignment.
- Define medium density as 30 – 35 dph.

See attachments.

A full assessment of the Site KN1 obligations and requirements should be undertaken and this should allow for sensitivity testing for a potentially lower number of dwellings given the site’s constraints.

Hello,

Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.

Regards,

The Masterplan should include actual proposed densities of each indicated area. It should indicate road layouts together with their width to ensure there is no repetition of the mistakes made with the layout of the Middlefield development in order to achieve the Council’s originally identified number of dwellings which they thought could be achieved. The Neighbourhood Plan makes clear the requirement of satisfactory estate development in Knowle and these requirements should be mandatory as part of this Proposal.

See attached representation.

Reprovision of the sports pitches should be secured prior to allocation

Introduction
Paragraph 18 sets out that the site allocations from the Solihull Local Plan (December 2013) will be brought forward. We consider that the automatic allocation of these sites which have been allocated for a number of years, without any justification as to their deliverability, is an incorrect approach. We address this in more detail under our comments in respect of Policy 4.
Finally, Paragraph 21 refers to neighbourhood plans and the importance SMBC places on these. Paragraph 30 of the National Planning Policy Framework (NPPF) sets the most recently adopted policies will take precedence. SMBC may wish to set this out within this section, to make it clear that the LPR will take precedence upon adoption over any currently adopted Neighbourhood Plans.
Soundness – The Plan is not:
- Justified
Change Sought:
- Existing allocations should be tested for deliverability prior to re-allocation
- The hierarchy of neighbourhood plans should be made clear
Vision
Given that paragraph 59 of the NPPF states that the Government’s objective is to significantly boost the supply of housing, the wording relating to meeting the needs of the housing market area should be more positively worded.
Paragraph 50 sets out that SMBC are seeking to protect the integrity of the Green Belt. Wording should be included setting out that lower performing parcels could be released to protect higher performing parcels while meeting identified and evidenced needs.
Soundness – The Plan is not:
- Positively prepared
Change Sought:
- The vision should be more positively worded in order to significantly boost the supply of housing
- The need to release lower performing green belt to meet identified needs, and preserve higher performing parcels, should be set out
Providing Homes for All
Policy P4C Meeting Housing Needs – Market Housing
We object to the inflexible market housing mix which is prescribed within this policy. The NPPF encourages provision of balanced and mixed communities catering for a wide range of the population.
Individual sites should cater for a wide range of housing types and sizes. Provision of such a significant proportion of only smaller (3 bed or fewer) dwellings on sites will not develop long term sustainable communities. Instead it will result in a transient community where people will not be able to form long term neighbourhoods as they will need to move on as their circumstances change if there are insufficient homes of the right size on a site to accommodate them. We do not consider that this represents good planning and consider that the focus should be on building strong healthy communities which can cater for all, rather than simply planning for short term ownership.
The inclusion of a prescribed housing mix runs counter to the criterion elsewhere within the policy which allow a number of factors to be taken into consideration. This plan has a significant lifespan and to prescribe a housing market mix which is to remain in place for the whole of plan period does not provide sufficient flexibility for adaptation to current housing need and demand. We have seen with the current pandemic the way external factors can influence people’s choice of lifestyle.
Soundness – The Plan is not:
• Justified
• Effective
Change Sought:
• Amendment of policy to allow for housing mix based on up to date market evidence
Policy P4D Meeting Housing Needs – Self and Custom Housebuilding
The latest Annual Monitoring Report (March 2020), covering the period 2018/19, sets out that for the period November 2018 – October 2019 there were 374 entries on the Self-build register.
As such, requiring all sites of over 100 houses to provide 5% of open market dwellings in the form of self-build plots is unreasonable and unjustified. Given provision is being made for 7,605 houses through allocations above 100 houses and the UK Central Hub area, this would equate to the 761 self and custom build plots to be provided from the draft allocations.
The Planning Practice Guidance (PPG) advises that the Council should engage with landowners who own sites that are suitable for housing and ‘encourage’ them to consider self-build and custom housing and who are interested in provision. Imposition of mandatory requirement goes beyond encouragement.
Following the example of Stratford District for example, the Council have specifically identified custom build sites which are discreet standalone small sites.
We also include extracts from the Bedford Local Plan Inspector’s Report (Appendix 4) where the Inspector recommended deletion the policy akin to that being proposed here as the policy was not justified with reference to the self-build register. The same principle applies here in that the amount being sought is over double that on the register.
Soundness – The Plan is not:
• Justified
• Consistent with national policy
Change Sought:
• Deletion of specific policy requirement and replacement with specific allocations or general support for self-build sites
Policy P5 Provision of Land for Housing
Policy P5 sets out the Council will allocate sufficient land for at least 5,270 net additional homes to ensure sufficient housing supply to deliver 15,017 additional homes in the plan period. This would result in an average annual housing land provision target of 938 net additional homes per year. This annualised target is made up of a stepped requirement with 851 homes per year delivered between 2020-2026 and 991 dwellings delivered between 2026-2036.
Demand
A Housing Need Technical Report has been provided (December 2020) (Appendix 5) and should be read in conjunction with our commentary on Policy P5. In summary, this Note makes the following key points:
• Planning Practice Guidance (PPG) states the Standard Method (SM) figure represents the minimum housing need, and there may be circumstances whereby need is higher;
• The Draft Plan identifies the clear economic growth aspirations for the Borough, including the nationally significant growth planned for the UK Central Hub. This is a circumstance where housing need may exceed the minimum need. If it does, housing delivery must be of a quantum to support these aspirations;
• The Council’s 2020 HEDNA confirms that the calculation of housing need is underpinned by the growth at the UK Central Hub. The Hub is projected to generate an additional 13,000 jobs to the baseline Experian job growth forecast (10,000 jobs) included in the HEDNA;
• The HEDNA tests several economic-led housing need scenarios. However, the UK Hub Scenario assumes only 25% of the additional 13,000 jobs created by the Hub are to be taken up by Solihull residents. This results in the housing need (816 dpa) underpinning the Plan;
• However, this ignores the ‘Growth A’ scenario which concludes that 908 dpa would be required based on the ‘Adjusted Local Growth’ scenario. This scenario assumes that strong industries in Solihull will outperform the baseline Experian forecast, resulting in an additional 5,680 jobs to the baseline (10,000 jobs) over the Plan period, with Solihull residents taking up these jobs;
• However, no scenario is presented to show what the housing need would be based on the UK Central Hub scenario being fulfilled in full by Solihull residents. It is important to understand this so that the duty to cooperate discussions referred to in the HEDNA are well informed;
Barton Willmore provide these sensitivity scenarios based on two approaches to commuting, and two approaches to underlying demographic rates (mortality, fertility, and migration);
• The results of our testing are summarised in Table 7.1:
Table 7.1: Solihull Borough – Barton Willmore Demographic Forecasting 2020-2036 Scenario Demographic rates Jobs per annum 2020-2036 Dwellings per annum 2020-2036
Dwelling-constrained:
Standard Method
2016 ONS rates
7721 – 8132
807
2018 ONS rates
1,0141 – 1,0682
Employment-constrained:
UK Central Hub
2016 ONS rates
1,437
1,1991 – 1,2482
2018 ONS rates
1,0361 – 1,0852
Source: Barton Willmore Development Economics
1 Commuting Ratio 0.98
2 Commuting Ratio 0.93
• Growth of between 1,036 and 1,248 dpa would be required to support the UK Central Hub scenario (between 16,576 and 19,968 dwellings in total);
• This represents an increase of between 220 dpa and 432 dpa on the housing need calculated by the HEDNA (816 dpa), or an additional 3,520 to 6,912 dwellings over the Plan period;
• Our analysis of historic levels of job growth in Solihull 1991-2019 shows a range of 1,225 and 1,650 jobs per annum (jpa). This highlights that the UK Central Hub scenario (1,437 jpa) is a realistic assumption;
• The HEDNA identifies an ‘acute’ situation in respect of affordable housing need. Our analysis suggests that the HEDNA’s conclusion on overall need (816 dpa) should be increased to meet as much affordable need as possible.
• Furthermore, our analysis of unmet need in the wider GBBCHMA suggests that the 2020 Position Statement’s conclusions under-estimate the remaining unmet housing need from Birmingham up to 2031, and for Birmingham alone the deficit in unmet need is between 11,294 and 13,101 dwellings up to 2031;
• In addition, there is significant unmet need up to 2031 based on the existing Standard Method coming from Birmingham City and the Black Country. This amounts to unmet need of between 25,543 and 27,350 dwellings up to 2031. If we were to assume the increased capacity for Birmingham City (65,400 dwellings 2011-2031) set out in the 2020 Position Statement the unmet need would still be between 11,243 and 13,050 dwellings up to 2031. This increases significantly based on the uncapped Standard Method figure for Birmingham City which would come into effect once Birmingham’s Local Plan becomes older than 5 years in 14 months’ time;
Adoption of the proposed changes to Standard Method consulted on by Government in summer 2020 would lead to there being unmet need against emerging/existing housing requirements in all but one of the GBBCHMA authorities;
• Furthermore, the unmet need post 2031 should be considered, as referenced to in the 2020 Position Statement. Based on data available at the present time and the most recent Local Plan figures, Barton Willmore calculate this to be a minimum 17,700 dwellings 2031-2040.
• In summary, the analysis in this report results in the following broad conclusions:
1. The SM’s minimum need for Solihull (807 dpa) will need to be increased to account for expected job growth from the UK Central Hub and the ‘acute’ need for affordable housing in the Borough;
2. Barton Willmore’s demographic modelling shows that between 1,036 and 1,248 dpa are required to support the UK Central Hub scenario;
3. Barton Willmore’s calculations suggest that the deficit in unmet housing need from Birmingham City being delivered by HMA Local Plans amounts to a minimum of between 11,294 and 13,101 dwellings up to 2031, a significant increase from the 2,597 dwellings concluded on by the 2020 Position Statement. This increases when the unmet need from the Black Country is considered. Additional unmet need will be created post 2031.
As such, in order to ensure the LPR is positively prepared, SMBC should seek to plan for more housing, and should allocate further sites.
SUPPLY
Further to the above, and as set out above, we also consider that some elements of the supply should be reviewed:
Dealing with the supply side of the equation, we make the following objections to the various components of supply:
‘Sites identified in land availability assessments’
It is unclear what is meant by ‘sites identified in land availability assessments’. Given these are sites which do not benefit from a draft allocation, then they are by definition, windfall sites which means that there is double counting from unknown sources of supply.
Solihull Local Plan sites
We question the automatic inclusion of Solihull Local Plan sites which have yet to be granted planning permission. The current Plan was adopted in 2013 and the Council cannot currently demonstrate a 5-year supply of housing. In this situation, the Council should be encouraging every suitable site to come forward. The fact that these sites have not come forward despite the housing shortfall, suggests that these should not be considered ‘deliverable’ housing sites without significant justification as to why they will now come forward when they have not to date.
Brownfield Land Register (BLR)
We query the separate identification of sites identified in the BLR – this BLR is subject to periodic review and thus will not be fixed as a permanent source of supply. We consider that any sites to be delivered in this way should be considered as windfall developments.
Lapse Rates
Whilst we support the use of a 10% lapse rates, it needs to be applied across the board i.e. it is equally application in relation to what is to come as to what has already gone before. If the Council accept that a 10% lapse rate is application to sites which already benefit from planning permission, then surely it should also accept that it is applicable to future planning consents which have yet to be granted.
Windfall allowance
The windfall allowance is justified by reference to past windfall rates however it fails to recognise that ‘ town centre sites’ (a traditional source of windfall supply) are allocated in the plan through the town centre masterplan and the Council have identified other sources of supply through the brownfield register. In the absence of any assessment / analysis of this component demonstrating the projected level of future windfall provision taking these factors in account, we consider that the level of windfall should be reviewed and adjusted accordingly.
UK Central Hub
We consider that given the scale of the UK Central Hub proposals, the rate of delivery assumed by the Council is overly optimistic. The Council have not provided any trajectory for the Site, and we note that the August 2020 consultation did not contain any firm commitments to delivery timescales or set out any delivery partners.
This assertion is supposed by the findings of the Lichfields’ Report1 that sets out the average time from outline planning application to the first delivery of homes is 8.4 years. The average build out rate is 160dpa.
As such, taking this into account, and based on a LPR adoption date of 20222, we consider the first completions will likely be C.2030. With an average build out rate of 160dpa, this means that approximately 960 dwellings will be delivered during the Plan Period, assuming that the housing is within the first delivery phases (the August 2020 consultation referenced a mix of uses coming forward). While more outlets may increase the speed of delivery, the amount of infrastructure required also needs to be taken into account. The type of supply also needs to be considered, with UK Central Hub likely to be geared towards apartments.
As such, we consider that 1,780 houses should be removed to take into account the likely delivery timescales.
Trajectory
We also note that SMBC are seeking to provide a stepped trajectory as some of the larger sites will not make a significant contribution to completions until the mid-delivery phase. The Inspector assessing the Guildford Local Plan set out:
39. In the submitted plan, the combined effect of the stepped trajectory in Policy S2 together with the “Liverpool” methodology (in which the delivery shortfall accumulated over the first 4 years of the plan (2015/16 to 2018/19) is spread over the whole plan period), would have deferred a significant proportion of the housing requirement to the later years of the plan. Set against the (then higher) housing requirement, this would not have met the Government’s objective to boost the supply of housing in the shorter term. (our emphasis)
We consider that SMBC should take the same approach as Guildford and allocate further sites to meet need early in the Plan Period. The existence of the UK Central Hub is not of a sufficient size to warrant a different approach (i.e. it is not akin to a new settlement).
Further, as with the withdrawn Uttlesford Local Plan, this stepped trajectory may create a fragile 5 year housing land supply position, taking into account the ambitious delivery targets of the UK Central Hub and the delivery concerns relating to the draft allocations set out below. The Inspectors’ letter relating to the withdrawn plan states:
29. This calculation relies on the use of a reduced annual requirement of 568 dpa for most of the years, as it is based on the stepped trajectory set out in Policy SP3. It is also based on what we consider to be unrealistic commencement/housing delivery dates for two of the Garden Communities (North Uttlesford and Easton Park, as set out above). So, whilst the Council can, in theory, demonstrate a 5.65 year HLS, we are concerned that if the housing delivery at North Uttlesford and Easton Park slips by just one year, as seems very likely, this would result in 100 less dwellings in this 5 year period. This would result in a very fragile 5 year HLS position.
There are comparisons that can be drawn here based on the stepped trajectory and the anticipated 5.37 year supply upon adoption.
The Inspectors for the withdrawn Uttlesford Local Plan also referenced the need to meet the full objectively assessed need for market and affordable housing in the housing market area (NPPF Paragraph 47). The HEDNA states there is a ‘clearly acute’ shortage of affordable housing. The proposed stepped trajectory therefore may worsen the affordability problem as it would delay the provision of housing until late years of the plan period.
Taking the above into account, we consider that the SMBC’s supply is actually 11,496 (rounded) before any reduction in windfall or the deletion of draft allocations which are unlikely to be delivered is taken into account.
This is a reduction of 3,521 and, as such, to meet the increased demand set out above, and take into account the concerns relating to a stepped trajectory, a review of the supply is required and additional sites allocated.
The Council should also ensure that a large number of these sites can be delivered early on in the Plan Period in order to take account of the likely later delivery of some other sites.
Soundness – The Plan is not:
• Positively prepared
• Justified
• Effective
• Consistent with national policy
Change Sought:
• Review of demand and amendment to the strategy
• Review of supply and amendment to the strategy
• Allocation of additional sites to ensure housing need is met (including suitable provision for wider HMA needs) and an annualised trajectory is possible
Improving Accessibility and Encouraging Sustainable Travel
Policy P7 Accessibility and Ease of Access
We consider that the requirement for major residential development should be clarified to set out that there may be other ways in which sustainable access options can be implemented. The distance to a bus stop/train station should not be seen as the only measure of sustainable access.
Soundness – The Plan is not:
- Positively prepared
Change Sought:
- Policy should be clarified that there are other ways of ensuring sustainable transport options are available
Policy P8 Managing Travel Demand and Reducing Congestion
Paragraph 109 of the NPPF states that development should only be prevented or refused on highway grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. Within point 2(ii), SMBC are seeking to bring in a further test which would not be in accordance with the NPPF. This should therefore be deleted.
Soundness – The Plan is not:
• Consistent with national policy
Change Sought:
• Point 2(ii) should be deleted
Protecting and Enhancing our Environment
Policy P11 Water and Flood Risk Management
With regards to point 6, the confirmation of discharge into a public sewer falls under Section 106 of the Water Industry Act 1991. As such, it should be made clear that planning permission can be granted prior to this being confirmed, as it falls within a different regulatory regime.
With regards to point 14, it should be clarified that contribution through a Section 106 Agreement is only required where it meets the tests set out in NPPF Paragraph 56.
Soundness – The Plan is not:
• Justified
• Consistent with National Policy
Change Sought:
• Deletion of point relating to confirmation from relevant infrastructure owner
• Clarification as to obligation requirements and the necessary tests
Promoting Quality of Place
Policy P17 Countryside and Green Belt
Within Point 1 of the policy, SMBC is seeking to safeguard best and most versatile agricultural land (BMVAL) unless there is an overriding need for development that outweighs the loss. BMVAL is referenced within the NPPF at Paragraph 170 which states that planning policies should contribute to and enhance the natural and local environment by taking into account a number of criteria. One of these is:
b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland.
Firstly, we consider that including reference to BMVAL within a policy relating to Green Belt seeks to conflate two separate issues. Further, as can be seen above, the test set out by the NPPF does not require the safeguarding of BMVAL. Planning policies are required to contribute to and enhance natural and local environment by recognising economic and other benefits from BMVAL. As such, we consider this point should be deleted.
SMBC have set out, within Point 4, a number of different factors that may be taken into account when considering very special circumstances.
Further to this, point 5 sets out that development that is ‘conspicuous’ from the Green Belt must not harm the visual amenity of the Green Belt by reason of siting, materials or design. Given Green Belt is a spatial designation, designed to prevent sprawl, we consider that this requirement goes beyond the scope of the Green Belt, as set out in the NPPF. The LPR contains policies relating to protecting landscape, where necessary, and as such, this point should be deleted.
Soundness – The Plan is not:
• Positively prepared
• Consistent with National Policy
Change Sought:
• Deletion of point 1
• Inclusion of further factors which may create very special circumstances
• Deletion of point 5
Policy P17A Green Belt Compensation
Paragraph 138 of the NPPF sets out that ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt Land.
Policy P17 is seeking to require this by requiring development on sites removed from the Green Belt to provide appropriate compensatory improvements to environmental quality and accessibility of remaining Green Belt in the form of a Section 106 Agreement utilising the below hierarchy:
1. Compensatory requirements as set out as part of the Local Plan masterplans
2. Where no compensation has been set out within the Local Plan masterplan, improvements are provided as:
i. Improvements within the Green Belt adjacent to, or in close proximity to, the development site;
ii. Improvements within the Green Belt adjacent to, or in close proximity to, the settlement or area accommodating the development;
iii. Improvements within the Green Belt in an area identified for environmental improvements as part of the Council’s Green Infrastructure Opportunity Mapping.
3. In the event it is robustly demonstrated that none of the above options can be satisfied then the Council will accept a commuted sum.
Given none of the emerging masterplans show any compensatory improvements within the Green Belt, it would appear that the Policy is relying on there being additional land being available within the control of applicants (which may not be the case), or the payment of contributions.
SMBC’s viability evidence does not take this requirement into account, and no detail is provided as to how these contributions will be spent or what level of contribution is required. This therefore brings uncertainty, and the Policy should be reconsidered to ensure what is required is clear, and that it will not impact upon the viability of schemes.
Soundness – The Plan is not:
• Consistent with National Policy
Change Sought:
• Reconsideration of the policy to ensure that it is evidenced based, does not impact upon viability of schemes, and is in accordance with national policy
Delivery and Monitoring
Policy P21 Developer Contributions and Infrastructure Provision
Policy P21 expected major development to provide or contribute towards the provision of measures to directly mitigate its impact and physical, social, green and digital infrastructure.
SMBC’s viability testing does not take into account digital infrastructure within the testing and, as such, it should be evidenced that this will not render development unviable.
Soundness – The Plan is not:
• Justified
• Consistent with National Policy
Change Sought:
• Confirmation that digital infrastructure provision allows for viable development
Settlement Chapters
Policy BC1 Barratt’s Farm, Balsall Common
We note that 1,756 new homes are proposed for Balsall Common across the plan period with the sole justification seemingly being that it contains both a primary and secondary school and has a full range of retail and associated facilities. However, it is still described as a rural settlement with no significant areas of employment and the distribution strategy remains one of “proportional distribution”. 1,756 dwellings to a single rural village would be completely disproportionate. There is discussion in the document regarding delivery of a by-pass; provision a station car park; improved public transport and a new primary school. However, there is no discussion as to how these are to be funded / delivered relative to the level of growth identified. In addition, there is discussion regarding the scope to enhance the existing local centre and the provision of a village centre masterplan. However, this land is in multiple ownerships and there are no proposals for what these enhancements could entail or how they could function – particularly with a by-pass in place which could actually draw trade away from the existing centre.
There is no assessment of the ability of Balsall Common to deliver this level of growth in such a small area. Whilst clearly some sites (i.e. Barratts Farm) will be able to have multiple outlets, the ability of the market to absorb and deliver multiple sites at any one time in a rural location should be reviewed; particular when Balsall Common will be acutely affected by HS2 – both in terms of the physical construction of the line and the disruption and uncertainty that this will bring; but also in terms of market desirability until such time as the line is constructed.
We also note that Barratts Farm is in multiple ownerships and these are described as “complex” in paragraph 541. This is the single largest site and the one which is proposed to deliver the by-pass. Within the previous draft of the Plan, it was stated that this site would only be taken forward if the landowners / promoters could demonstrate they are working on a collaborate and comprehensive basis. Reading paragraph 541, this collaborate working has clearly not been secured in the way it was envisaged and nothing additional is suggested to demonstrate that joint / collaborative working is possible.
The relief road is identified as being necessary for Barratts Farm in particular with the policy advising that is required early in the plan period. The road is provisionally to be funded via CIL payments; and grant funding which “may” be possible through the WMCA. Firstly, CIL payments can only be secured through those sites which will come forward in the future however these sites are Green Belt sites and cannot therefore be delivered until the Local Plan Review is completed and the subsequent CIL schedule is adopted. Secondly, there is no grant funding proposal in place to fund the road. As it currently stands this road is not deliverable. The road is required to be delivered early in the plan period i.e. before there are significant CIL funds in place and, potentially, at a point where, in order to receive grant funding, applications should be being made now / near future.
There has to be serious doubt over the ability of Barratts Farm to be delivered within the anticipated timeframes and therefore places serous doubt over the plan as a whole given the scale of this allocation.
The Sustainability Appraisal notes that there are limited employment opportunities within Balsall Common and that people travel outside of the settlement to work. As such, it is noted that the expansion of this settlement would fly in the face of sustainability objectives of reducing the need to travel to areas of employment. Whilst such a case could be made for the majority of the rural areas of the Borough, it is heightened especially here when such a large proportion of future growth is identified for one rural settlement.
At this stage, the level of growth attributed to Balsall Common is disproportionate and that inadequate research has been undertaken into the deliverability of this level of growth and the associated aspirations; and the ability of the market to deliver this level of growth in a rural area is considered to be unrealistic.
On the basis that we do not consider the sites identified to be deliverable and the significant shortfall in supply identified by the more realistic timescales we have identified for UK Central, we propose an alternative site – Land at Hawkshurst (Site 544) as an alternative to meeting part of this need. To date this site has been inappropriately assessment by the Council and a more appropriate evaluation of the site is given in the section below.
Policy BL1 – West of Dickens Heath
The policy requires that the proposal for BL1 secures the relocation of the existing sports provision to a suitable site in the local vicinity. Until such time as these facilities are relocated or a plan is in place to secure timely relocation (which should include the grant of planning permission in our view, given that any site will be in the Green Belt), then the site cannot come forward for development. Our key concern here relates to Site 4 (West of Dickens Heath). It is noted that the identification of a Local Wildlife Site within the site hampers re-provision within the site itself and therefore alternative options will need to be pursued outside of the site. We consider that these alternatives should be considered now as clearly, as it currently stands, the pitches will be lost with no alternative in place (and therefore no guarantee of any re-provision). This is all the more important given that the land in the area is all located within the Green Belt and therefore any proposals which may, for example, include floodlighting, will have to be carefully considered against the Green Belt ‘tests’. We understand that the loss of these facilities is causing significant local concern particularly with no proposals for replacement.
The Council have had ample time to identify and secure alternative provision and therefore the fact that this is not identified within the plan, suggests that there are currently no alternative sites. This calls into question the delivery of this site and with no evidence and no proposals in place, we consider that proposal BL1 should be deleted from the plan.
Soundness – The Plan is not:
• Justified
• Effective
• Consistent with National Policy
Change Sought:
• Reprovision of the sports pitches should be secured prior to allocation
Policy KN1 Hampton Road, Knowle
As with the Site West of Dickens Heath, this draft allocation requires the reprovision of sports pitches. In this instance, the re-provided pitches are currently shown within the Green Belt to the north of the allocation.
The Council, within Paragraphs 713-715 state that it’s likely that very special circumstances will exist to support development in this location and, as such, the reprovision will likely be acceptable. However, this pre-judges any application, for which the detail is not known, and as such cannot be relied upon. Therefore the housing that would be provided on the sports pitches should not be included until the reprovision of the sports pitches is secured.
Soundness – The Plan is not:
• Justified
• Effective
• Consistent with National Policy
Change Sought:
• Reprovision of the sports pitches should be secured prior to allocation
Site Assessment Criteria
We consider that a more dispersed growth option should be considered and, as set out previously, consider that the land at Broad Lane, Hawkshurst (Site 544) is ideally suited to make an important contribution to the Council’s housing need. Following the Council’s own site selection criteria, we set out why this site is a suitable and deliverable alternative site which can be delivered utilising existing infrastructure:
We object strongly to the manner in which Site 544 has been assessed in the site selection process for the reasons which are set out below – and on that basis, object to the inconsistent application of the methodology.
Firstly, in assessing Site 544, the Council deemed that the site did not pass ‘Step 1’ – which is the initial, high-level sieving process. Sites which are not taken forward at this stage are then not subject to the more refined ‘Step 2’ analysis. We consider the manner in which the process was applied is fundamentally flawed and have carried out our own assessment (using the Council’s own analysis) to demonstrate that the site should not have been discounted at Step 1 and should have been included in Step 2.
STEP 1
The first stage in the sieving process is a high-level look at the following:
(i) Brownfield vs greenfield
(ii) Urban areas vs Green Belt
(iii) Accessibility
Sites can be rated from Priority 1 (brownfield in urban area or settlement) to Priority 10 (greenfield in isolated highly performing Green Belt location). A traffic light rating is then applied – sites which falls within Priority 1 to Priority 4 are green sites; Priority 5 sites are yellow; Priority 6, 6b and 7 sites are blue; and Priority 8, 9 and 10 sites are red. Red sites fail Step 1 and are not taken forward to Step 2 for assessment. Site 544 was incorrectly identified as a Priority 9 red site and was not therefore taken forward to Step 2.
In summary, Site 544 is a greenfield and Green Belt site. However, it is accessible (being on the edge of the Coventry urban area) and also within an area with a low GB score of 5. Therefore, it should be allocated a Priority score of no higher than 5 (yellow). We review below the manner in which this initial sieving assessment was flawed - taking Site 544 step by step through the same assessment process as the Council.
Green Belt
In the Green Belt Assessment 2016, Site 544 is identified as part of Refined Parcel RP83:5 which has a combined score of 5, within a range from the highest performing Green Belt sites (12) to the lowest performing sites, scoring as low as 0. With a score of 5, site 544 is clearly a lower performing site. The starting point for consideration as a Priority 5 site is a score of 5 or lower in the Green Belt––Site 544 falls into that category. The results of this assessment are backed up by our own Green Belt assessment which is included with this submission.
Accessibility
The second part of the criteria relates to accessibility and to achieve a Priority 5 ranking, the site is required to be in an accessible location. This is defined as:
(a) On the edge of the urban area or
(b) On the edge of a settlement which has a wide range of services and facilities including a primary school and a range of retail facilities.
Site 544 adjoins the urban edge of Coventry – indeed in the Council’s Site Assessment, the site is identified as possibly being an extension to Coventry.
It should be noted that in relation to the Publication Draft Plan, the Council have updated the Accessibility Study to take account of retail / surgery provision in adjoining LPA areas, however they have then not used this information to re-visit first principles and determine whether sites have been appropriately assessed from the start. Therefore, whilst this site now scores more positively, its ‘priority 9’ status has not been re-evaluated despite an Addendum to the Site Assessments being produced and the Accessibility Study being revisited. It appears that despite the site being on the urban edge of Coventry this has been discounted due to the sites geographical relationship with Coventry as opposed to Solihull. However, accessibility should be based upon spatial location rather than boundaries. The fact that the retail offer is in Coventry will not prevent residents of Hawkshurst using it.
For the absolute avoidance of doubt therefore, we enclose our own submission produced by Phil Jones Associates which demonstrates that the site is in a suitable and sustainable location.
It is fundamentally incorrect for Site 544 to have been ‘sieved out’ at Step 1. The site should have been correctly assessed as a Priority 5 yellow site as it meets the two necessary criteria. The site, therefore, should have been taken forward for a more detailed analysis in Step 2.
On the basis that the site does pass Step 1 – we have carried out the Step 2 assessment using the same table and criteria as the Council. There are no scorings or weightings attributed to the Step 2 analysis – it assessed on a qualitative basis.
STEP 2 – REFINEMENT CRITERIA
FACTORS IN FAVOUR
In accordance with the spatial strategy
(including only proportional additions to lower order settlements (i.e. those without a secondary school or not located close to the urban edge).
The preferred spatial strategy would be to locate development needs close to where they arise. However the Plan identifies that there is limited land available to achieve this and therefore the Council has had to look at alternative options, which includes land released from the Green Belt in the form of urban extensions and also followed a more dispersed strategy for development. They have sought to focus development in locations that are, or can be made, accessible and sustainable. Such locations are identified as typically being on the edge of urban areas (or within ruralsettlements) that have a greater range of services. Potential locations for development include adjoining the urban edge or a highly accessible settlement. This will have the benefit of focusing on urban areas and sustainable urban extensions to provide the best opportunity for achieving accessibility and delivering public transport improvements.
It is abundantly clear that geographically Site 544 adjoins the urban edge of Coventry – Coventry is the second largest City in the West Midlands, after Birmingham. Site 544, as confirmed in the SHELAA assessment, would be viewed as an urban extension to Coventry and there is, therefore, no doubt that Site 544 is in accordance with the Spatial Strategy, which seeks to locate development in the most accessible locations. Coventry is clearly such a location and there is nothing within the Spatial Strategy which would rule against this.
Therefore, it can only be concluded that the development of Site 544 would be in accordance with the Spatial Strategy.
Any hard constraints only affect a small proportion of the site and/or can be mitigated.
The SHELAA does not identify any hard constraints – we concur with this assessment.
The site would not breach a strong defensible boundary to the Green Belt.
There are no strong existing defensible Green Belt boundaries that would be breached. The existing boundaries to Bannerbrook Park comprise simply hedgerows, some of which were planted in conjunction with the existing development. The same form of boundary treatment can therefore be replicated on this site and indeed is proposed within the masterplan included with this submission.
Any identified wider planning gain over and above that which would normally be expected.
Following discussions with local undertakers regarding the lack of burial space available within the Borough, the landowners are willing to offer land for a multi faith burial space which will provide a much needed facility for the Borough and also secure the long term permanence of the Green Belt boundary in this location.
Sites that would use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt.
See above.
If finer grain accessibility analysis (including output from the Accessibility Study) shows the site (or the part to be included) is accessible.
The Accessibility Study is flawed when it comes to assessment of sites on the Solihull / Coventry boundary. The Study provides a scoring for accessibility for facilities within 1,200m of a site, however when assessing facilities beyond the administrative area of Solihull only facilities within 800m of the boundary are assessed, this is despite an updated assessment being provided in 2020 which proposed to apply some adjustment of standards and yet makes no sensible adjustment to standards for cross boundary provision. Sites in such locations are not therefore being assessed on a comparable basis. Furthermore, the assessment is only being undertaken of walking distances and makes no allowance for accessing facilities by bike. The document references ‘shared cycle’ routes but then makes no consideration of people actually using them for cycling. Clearly were cycling to be factored in, especially for those sites, which adjoin major settlements and therefore have access to a good cycleway network (such as Site 544) then their accessibility criteria would be much improved.
Whilst it is noted that some provision is now taken off cross boundary retail provision and public transport which has moved Site 544 to a higher scoring position; it is still not being assessed on a comparable basis.
There is a shared footway/cycleway through the Bannerbrook Park development which can be extended into Site 544. Furthermore, opportunities will be considered to accommodate a bus route through Site 544 and on through Bannerbrook Park.
It is therefore clear that the proposal can only be defined as being in an ‘accessible location’.
FACTORS AGAINST
Not in accordance with the Spatial Strategy
As set out above, the development of this site is in accordance with the Spatial Strategy
Overriding hard constraints that cannot be mitigated.
There are no hard constraints identified.
SHELAA Category 3 sites unless demonstrated that concerns can be overcome.
The site is not identified as a Category 3 site in the SHELAA. We make comments below in respect of the flaws of SHELAA assessment and carry out our own assessment.
Sites that would not use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt.
As already confirmed, the site uses existing defensible boundaries and proposes to strengthen the defensible boundary and strengthen existing hedgerow planting.
If finer grain analysis shows the site (or the part to be included) is not accessible.
As previously confirmed, the Council have failed to consider the proximity of services in Coventry on a fair basis and because of this, it is not possible to determine how detailed the assessment has been. However, given that the site adjoins a major urban area is it simply not feasible to draw a conclusion that the site is inaccessible.
If the site is in a landscape character area that has a very low landscape capacity rating.
It is wholly unreasonable if the Council have used this criterion to discount this site. According to the Council’s Landscape Character Study (December 2016) this site falls within Landscape Character Area (LCA) 26 – which covers the eastern fringe of the Borough – yet significant Green Belt release is proposed in other areas of the Borough which are in an identical LCA. With one blanket ‘very low’ landscape capacity conclusion for such wide areas it cannot be used to discount some sites and not others – there must be parity in assessment. Furthermore, the study itself (page 49 – text adjoining Table 24) confirmed that it is not possible to establish a baseline sensitivity to change without having details of a given development proposal and therefore the conclusions should be taken as a guide only. On this basis, we do not consider it appropriate to use this criterion as a basis to discount sites given sites with the same assessment have been given a ‘green’ score’.
We enclose with this submission our own detailed, site specific, landscape and visual appraisal which confirms that the site has the ability to accommodate development of scale which is comparable to the surrounding area without compromising the function of the surrounding Green Belt.
If the SA appraisal identifies significant harmful impacts.
The SA identified 2 harmful impacts:
(i) The site contains over 20ha of Grade 1 – 3 agricultural land.
The site is wholly Grade 3 agricultural land – clearly within Grade 3, the site could in fact be Grade 3b land which would mean it is not BMVL. Furthermore, the Regional ALC mapping, which was last updated in November 2018, shows this to be the prevailing land type across the Borough which is not unsurprising. As a result, a number of proposed allocated sites have the same classification. It is not therefore appropriate to identify this as a harmful impact when a consistent approach has not been applied across the board.
(ii) The distance to jobs is identified as 8km within the SA
This is clearly incorrect as the SA treats the administrative boundary between Coventry and Solihull as a line which people will not cross. This is clearly incorrect. As already stated, there is for example a good bus connection to Warwick University which is a key local employer as well as Coventry city centre which offers multiple employment opportunities. The SA has applied the same approach to all services and facilities – relating its conclusions only to Solihull Borough and thus the distances to shops / schooling / healthcare are distorted. In addition, we highlight that this is a specific issue related to Balsall Common also (which is also further away from Coventry) and yet the Council has seen fit to allocate in excess of 1,700 dwellings in Balsall Common.
In summary:
• The site has medium / high accessibility – at the same level as the other ‘green sites’ identified in the Draft Plan.
• The site is in lower performing Green Belt than other ‘green sites’ in the plan.
• The site has existing defensible Green Belt boundaries which can be strengthened.
• The site has no constraints within the development area which cannot be mitigated in the normal way.
• The site has the same landscape character as other ‘green sites’.
• It is not, therefore, credible for Site 544 to be categorised as a ‘red’ site.
• For this reason, we consider the score for Site 544 should be corrected and the Council should re-visit their assessments from first principles.
As is evidenced from the corrected SHELAA commentary the site is rated as a Category 1 – Deliverable Site. Such sites are deemed to be available now, offer a suitable location for housing now and there is a reasonable prospect that housing will be delivered on site within 5 years from the date of adoption of the plan.

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

See attachments. LAND AT JACOBEAN LANE, KNOWLE

a) To ensure replacement provision is equivalent in terms of quantity and quality 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 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.

Modification – Plan should reference Knowle Transport Study, and make concept masterplans compatible with evidence.

See Attached Letter

No Credible evidence to show deliverability of this allocation.

Please find attached my responses to the Local Plan consultation. All three documents address the issue of the soundness of the Plan.

Solihull Local Plan- Draft Submission Plan
Proposed Allocation Site: KN1 Hampton Lane Knowle
Further to your letter of 30 October 2020 sent to me as I am adjacent to the above proposed allocation, I wish to question the viability of including this greenbelt site in the Solihull Local Plan.
It is not possible to establish the true ownership of the various parts of the site KN1, but it is likely that it is in at least 4 different ownerships:
1. Knowle Football Club, I believe this is owned by Knowle Cricket Club and subject to restrictive covenants.
2. The former Thacker’s Nursery I believe is owned by Umberslade Investments.
3. The fields in front of Thacker’s Nursery fronting onto Hampton Road used to be owned by the Southall family formerly of Grimshaw Hall, current ownership unknown.
4. The fields beyond Thacker’s Nursery running up to the canal and also fronting onto Hampton Road, current ownership unknown.
In your proposals you have treated them as a single entity, we believe that the site cannot be delivered in this way for the following reasons:
The Football Club is unlikely to have the funds to purchase and satisfactorily develop the steeply sloping site by the canal into workable level playing pitches ahead of the sale of their existing pitch. This is assuming that the Cricket Club will part with the proceeds of sale and also pay the Community Infrastructure Levy. In the past we believe the Football Club have struggled to maintain their present clubhouse, will they have the necessary funds to build and maintain a larger complex with the necessary parking etc? Do the restrictive covenants prevent the existing football pitch being developed? The removal of any covenants could necessitate legal action, if so who pays for this?
The agricultural fields in front of Grimshaw hall fronting Hampton Road, currently being Greenbelt have a limited value. Will the owner of these fields be prepared for this land to become Public Open Space thus not benefitting from the enhanced value enjoyed by the owner’s of Thacker’s Nursery, even though the residential development is supposedly dependent on this open space.
The owners of the fields that are proposed to form the new sports complex again will not have the advantage of the hugely inflated land values enjoyed by Thacker’s Nursery. One must question whether this land will be available as sports pitches at an affordable price.
It would appear that the whole of KN1 has been submitted as a possible site on a number of assumptions that may not be deliverable. If the site is taken out of the Greenbelt it is possible that the developers will seek permission to develop Thacker’s Nursery on its own, which should be resisted as it forms part of “The Meriden Gap”, and in the most part forms an extension of the urbanisation, rather than a “Rounding Off”.
Before finally submitting our views on your portal we would be obliged if you explain to us how the KN1 scheme can be delivered as an entity, taking into account all of the various ownerships. We can only imagine the future disagreements over land values and who pays for what between the owners.

The wording in item 6 should remove the word “should” and replace with “could”.
The conclusions drawn by the technical work should be taken into account in the formation of a revised concept plan, as submitted with these representations. It is this concept Plan that we consider the Council should take forward to guide development of the site going forward.
Whilst we support the draft allocation of 180 dwellings, we consider that if the Green Belt boundaries were amended to more permanent features then the allocation would be more effective and deliver a further 70 – 95 dwellings.
The policy should be amended taking on board the findings of this technical work, which demonstrates in a concept plan the potential to deliver A range of 250 – 275 dwellings.

See attached documents.

2019 Heritage Impact Assessment & Concept Masterplan - further discussions required before EIP to establish whether the concept plan and Policy KN1 could be tightened up further in respect of impact on the setting of the GI Grimshaw Hall.

Wording in Policy BC3 requires alteration as suggested below.

In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting since the wording does not tie up with the 2019 Heritage Impact Assessment analysis;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘2*’ etc and should be altered to the Roman numerals used in the listing process i.e. 2* would read II* etc.


With regard to the 2019 Heritage Impact Assessment for this site the analysis refers to ‘significant’ harm – it is not clear whether this means substantial harm or not. We note that the area to the south has not been taken forward.
2 i - Protection Conservation or enhancement of heritage assets and their setting;the setting of heritage assets adjacent the site;

2 ii - Provision of low density housing, and where relevant single storey housing to protect the setting and functionality of GII* Berkswell Windmill.

With regard to the 2019 HIA work and the Concept Masterplans information, we would welcome opportunity to discuss this site with you ahead of the EIP to establish whether the concept plan and Policy BC3 could be tightened up further in respect of impact on the GII* Berkswell Windmill and its setting. The LPA will need to be satisfied that the functionality of this heritage asset would not be affected through the proposed development.

Wording in Policy KN1 requires alteration in line with NPPF requirements for harm (this may be duplication however if text for Policy P16 is revised) and as suggested below.

In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting since the wording does not tie up with the 2019 Heritage Impact Assessment analysis;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘1’ etc and should be altered to the Roman numerals used in the listing process i.e. 1 would read I etc.
With regard to the 2019 HIA work and the Concept Masterplans information, we would welcome opportunity to discuss this site with you ahead of the EIP to establish whether the concept plan and Policy KN1 criteria could be tightened up further in respect of impact on the setting of GI Grimshaw Hall.

Policy P5: Provision of Land for Housing.

Section 1 - The Policy refers to a table setting out allocations which is one table of a number of unnumbered tables which follows the policy.

Section 6 - The setting of heritage assets is not referred to within the policy at present.
Section 1 – It is recommended the tables be provided with Figure numbers so that the allocation table can be linked with Policy P5 for the avoidance of doubt.

Section 6 - In line with NPPF requirements it is recommended that Section 6: Density criteria (iii) be revised to read ‘…and, heritage assets and their setting’.

Historic England would refer you to comments made at an earlier consultation stage where we encouraged SBC to take the opportunity to refine the early post NPPF heritage policy in the extant Plan.

Whilst our earlier comments are predominantly recommendations, the proposed policy wording does not differentiate between harm and substantial harm as set out in the NPPF and we are of the view that this should be addressed within the policy.
The policy should include the following text, or a similar alternative:

Great weight will be given to the conservation of all designated assets and their settings (and non-designated heritage assets of archaeological interest that are demonstrably of equivalent significance to scheduled monuments). Such assets should be conserved in a manner appropriate to their significance, irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance. Development which leads to less than substantial harm to a designated heritage asset will be weighed against the public benefits of the proposal.

Development which leads to substantial harm to, or total loss of, the significance of a designated heritage asset will only be acceptable where it can be demonstrated that it is necessary to achieve substantial public benefits that outweigh that harm or loss, or where all of the following apply:

the nature of the heritage asset prevents all reasonable uses of the site;

no viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its conservation;

conservation by grant-funding or some form of not for profit, charitable or public ownership is demonstrably not possible;

and the harm or loss is outweighed by the benefit of bringing the site back into use.

In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘2’ etc and should be altered to the Roman numerals used in the listing process i.e. 2would read II etc.
In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘2’ etc and should be altered to the Roman numerals used in the listing process i.e. 2would read II etc.
In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘2’ etc and should be altered to the Roman numerals used in the listing process i.e. 2would read II etc.

Policy KN1, Hampton Road, Knowle should be deleted.

See attachments.

Land at four ashes road dorridge