Policy KN2 : South of Knowle (Arden Triangle)

This site is not appropriate for development. Sites around Dorridge would have provided better opportunities for smaller scale development providing greater sustainability being closer to the station.

This is unnecessary development which will result in the loss of valuable greenbelt. It is misleading to say that Arden Academy needs a new site. Many of the buildings are modern and the older elements can be rebuilt over time. Valuable Greenbelt will be lost, which is home to a significant amount of wildlife and the area along Warwick Road provides significant visual amenity as you approach Knowle from the South. The scale of development is significantly out of proportion with the size of Knowle and will create significant issues with traffic and safety, which already struggles at the moment.

It should be made perfectly clear that to comply with the concept master plan that item 2.i sould be worded as

2. Development of the site should be consistent with the principles as shown in the concept masterplan, which include:
i. Retention of important landscape features and the setting of heritage assets (to include the existing green corridor created by the old line of Knowle bypass);

I would like the council when considering the Solihull Local Plan, to take into account and retain the greenway corridor created by the Knowle bypass over the last 60 years. This is essential for wildlife and in line with the councils own stated position.

Reference Page 101 of the Draft Infrastructure Delivery Plan 5.1 Natural & Semi-Natural Green Spaces which deals with these issues specifically: Enhance existing green corridors and Encourage the incorporation of green infrastructure in new developments.

We support the site as we are realistic about the need for more housing, which is better delivered in a coordinated means with infrastructure to support the provision of the needs of the community in the climate emergency. The number of houses seems excessive however, given the need to retain green space and protect existing trees and biodiversity. Please ensure that the utmost care is taken in the building of the new area with sustainable ideologies (referring to advice from experts such as the Royal Horticultural Society) as well as safe, protected cycle routes to encourage cycling for all ages.

Masterplan must be re-drawn and Policy KN2 re-drafted. There are two reasonable alternatives which must be considered.
The first is to leave the extent of any built development to the South to extend no further than the existing public footpath linking Warwick Road with Grove Road. The area to the south of the footpath should remain Green Belt and enhanced for open space, ecology, heritage and to provide compensation for loss of Green Belt in relation to other parts of the allocation.
The second reasonable alternative is to utilise the line of the Cuttle Brook which is intended to be de-culverted and integrated into the drainage and environmental strategy for the site. This will be a strong physical feature, which will clearly demarcate the sensitive southern part of the site.
Without due consideration of reasonable alternatives and subsequent amendments, the allocation of site KN2 is considered to be unsound.
Vehicular accesses should be avoided from roads to the East which includes Station Road, Grove Road and Knowle Wood Road. These roads should be used to provide traffic free pedestrian and cycle routes.
Policy KN2 and supporting Concept Plan should be amended to retain the southern section of the site within the Green Belt. This area of the site can then be used for Green Belt compensation measures.

See attachments.

In circumstances where the Council and site promoters cannot demonstrate during the examination a comprehensive and co-ordinated approach to delivery of the whole site can be achieved and that it is viable in line with paragraph 709 of the Plan, then the site allocation should be considered not sound and removed.
In circumstances where the comprehensive treatment and viability of the site can be satisfied and the policy is retained, the wording of Policy KN2 and accompanying text should be amended to ensure the critical education infrastructure is delivered. In these circumstances the policy should be amended as follows:
- Policy KN2 Paragraph 3(i) should be replaced with the following: “Re-provision of the existing Arden Academy and provision of new primary school as an ‘all through school. The preferred site for the school is on land immediately south of the existing school 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 site has been selected, and a commitment and timescale for the school development is secured, in addition to the necessary financial contributions”.

See attachments

See Attached Word doc.

Reliance upon Concept Masterplan KN2 should be removed or the masterplan amended to ensure constraints can be appropriately assessed and impacts quantified, within adequate mitigation and infrastructure provision allowed for.
The Allocation proposals for the Arden Triangle site should provide for the retention of Stripe Hill House and existing trees that are of significance and should be retained. The related Masterplan for the allocation should be suitably amended to respond to these considerations so that the educational development is relocated elsewhere within the allocation. Such a relocation will enable the delivery of the education facilities within the required timetable and to the standard required; without the ensured delivery of these educational facilities the strategic allocation of this site and the infrastructure it is intended to deliver is undermined. Similarly, the reasoning for the site’s Green Belt release is also detrimentally affected.
It is recommended that further consideration of alternatives is undertaken, particularly with respect to the delivery of a new Arden Academy within the School’s existing landholdings. Until the Council has agreement of the allocation masterplan, the policy should not rely upon the accompanying masterplan document to secure the various components of the allocation.
Specific deletion of paragraph 724 is also recommended.
An alternative Masterplan is provided for consideration.

See attached documents

Allocation Policy KN2 and paragraphs 720 -729 require modification. The accompanying Concept Masterplan KN2 also requires redrafting to be relatable to the documented evidence base and to demonstrate the allocation is deliverable.
The Concept Masterplan for Allocation KN2 should be amended or removed to ensure constraints can be appropriately assessed and impacts quantified, with adequate mitigation and infrastructure provision allowed for. Failure to provide sufficient flexibility at this early stage could jeopardise the proposed allocations through a risk of challenge to the development extents and impacts arising.
The educational development should either kept on its existing site or relocated on the Council’s own site within the allocation. This will enable the delivery of the education facilities within the required timetable and to the standard required; without the ensured delivery of these educational facilities the strategic allocation of this site and the infrastructure it is intended to deliver is undermined. Similarly, the reasoning for the site’s Green Belt release is also detrimentally affected.
It is recommended that further consideration of alternatives is undertaken, particularly with respect to the delivery of a new Arden Academy within the School’s existing landholdings. Until the Council has agreement of the allocation masterplan, the policy should not rely upon the accompanying masterplan document to secure the various components of the allocation.
Specific alteration to paragraph 724 is also recommended (see para 5.1.5 of Representations document for exact wording).
An alternative masterplan is proposed.

See attachments

Revised Masterplan for KN2

See attachments

Modifications as proposed in the representations for Policy KN2 which include:
- Setting out densities specifically.
- Referencing Neighbourhood Plan policies relating to community access to school.
- No vehicular access to the schools off Station Road.
- Important landscape features specifically mentioned.
- Need for a landscaping strategy to include screen planting along Warwick Road
- Developer contributions will be required for related improvements to the local primary health care system;
- Provision shall be made for access to enhanced bus services;
- Retention of exiting rights of way along current alignment
- No departure from the principles and other requirements applying to Site KN2
- 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.
- Additional para after Para 720 as follows:
"That part of the site adjacent to Station Road is closer to bus routes and to the amenities of Knowle and Dorridge. Higher densities would be appropriate. Elsewhere, the landscape setting and proximity to the listed Rotten Row Farm dictate a lower density of housing, reducing in a southerly and easterly direction reflecting the transition to countryside."
- Additional para after Para 724 as follows:
"Policy KN2 requires access to enhanced bus services. As a minimum, applicants will be expected to negotiate with providers to achieve a meaningful diversion of existing services into the site. Increased frequency and the provision of new services shall also be considered and addressed where feasible."
- Valued landscape features should be named.

See attachments.

Various modification to the Masterplan as set out in representations including:
- Developer masterplan to be deleted.
- Include the objective for including the site i.e. to build a new through school funded by housing. available for use by the public.
- A planning obligation (or similar binding legal agreement) will be necessary to secure the objectives of the site.
- Inclusion of likely required household types and reference to Neighbourhood Plan policies.
- Include a maximum density of 40dph.
- Clarify the position regarding access onto Grove Road (one access point or two) and required junction works.

See attachments.

A full assessment of the KN2 availability, obligations and requirements should be undertaken, particularly around the deliverability of the new all through school.

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,

New development must ensure landscape features are retained as far as possible noting veteran – non-protected trees should also be retained to contribute to natural flood mitigation on site.
Reduce densities on site and ensure Neighbourhood Plan policies are reflected.
Masterplan needs specific reference to upgraded footpath link to Middlefield and Dorridge to reduce walking along Station Road.
Plan should recognise that improvements to Grove Road / Warwick Road / Norton Green Lane junction are likely to be required.

See attached representation.

Clarification that the masterplan is for indicative purposes with a final masterplan formulated as part of the development management process.
The provision of open space and how and where this could be located for example in relation to the Local Wildlife Site is to be explored further.
Infrastructure requirements should refer to the provision of 40% affordable housing in accordance with Policy P4A.
The extent of Green Belt enhancements will need to be considered once further work is concluded in relation to the Concept Master Plan and the position is settled upon in terms of on-site mitigatory measures.
Clarification regarding the reprovision of Arden Academy including evidence to supporting the relocation and whether this is a necessary infrastructure requirement arising from the draft allocation.

See attached documents

We are satisfied that Policy KN2 has been sufficiently well developed in collaboration with all parts of the community and represents a Place Based approach that we can fully support without further modification.

See attached document.

Paragraphs 225 and 226 should be amended to remove the estimated contribution of KN2 from Delivery Phases I and II.

Policy KN2 should be amended in light of the findings of additional evidence gathering, negotiations with landowners and masterplan work.

Dear Sir/Madam,

I submitted these representations yesterday and have just notice that my email gave the wrong client name and so to clarify this particular set of representations are submitted on behalf of our Client Mrs M Joyce (our Ref 10444) in respect of the Draft Submission Solihull Local Plan currently out to consultation.

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

We look forward to hearing from you.

Kind regards,
Glenda

Robust evidence is required to demonstrate Arden Academy proposals are the most appropriate strategy having regard to reasonable alternatives.

Dear Sir/Madam,

I submitted these representations yesterday and have just notice that my email gave the wrong client name and so to clarify this particular set of representations are submitted on behalf of our Client Mrs M Joyce (our Ref 10444) in respect of the Draft Submission Solihull Local Plan currently out to consultation.

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

We look forward to hearing from you.

Kind regards,
Glenda

The following modifications are proposed to policy KN2:
(a) New 2x 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) 3v Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

See attachments. Site KN2

See attached.

I support Policy KN2 – South of Knowle (Arden Triangle); it takes a Placed Based approach and will bring benefits to the local community over the long term.

I support these proposals because the existing Arden Academy is ageing, energy inefficient and lacks community facilities. The new schools will meet the educational needs of our children for decades to come. It will move school traffic off Station Road, reducing congestion at peak times and improving the environment for local householders as well as those driving to Knowle. It will provide new homes for younger and older people.

Paragraphs 225 and 226 should be amended to remove the estimated contribution of KN2 from Delivery Phases I and II.

Policy KN2 should be amended in light of the findings of additional evidence gathering, negotiations with landowners and masterplan work

Dear Sir/Madam,

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

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

We look forward to hearing from you.

Robust evidence is required to demonstrate Arden Academy proposals are the most appropriate strategy having regard to reasonable alternatives.

Dear Sir/Madam,

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

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

We look forward to hearing from you.

I am satisfied that Policy KN2 has been sufficiently well developed in
collaboration with all parts of the community and represents a Place Based
approach that I can fully support without further modification.

Providing the very best possible effective education in 21st Century buildings on a magnificent site fit for purpose without having to battle
conditions in ageing premises. Modern facilities designed around the
needs of young people. The plan prevents having to spend huge sums
on catch up on old school buildings and facilitates buildings and
facilities where young peoples all important education will create the
best possible surroundings within which learning and teaching can
blossom;
 Provide opportunities for all children to develop to their full potential and
are prepared for the challenges of school and beyond meeting the
educational needs of both primary and secondary pupils in the
settlement in a single location, utilising shared and modern facilities in a
safe and pleasant learning environment. Three purposes – empowering
young people to succeed in the economy, participate in culture, and
leave school prepared for adult life – have consistently guided the
government’s programme for reform which this new provision
champions;
 Presents a higher quality educational design without compromises in
final design as opposed to upgrading one school. Higher energy

efficiency and lower maintenance costs purpose built educational
setting to replace the out-dated, ageing fabric of the existing Arden
Academy, much of which is increasingly expensive to maintain and
service, energy inefficient, has poor infrastructure and a lack of
community facilities hampering involvement of the wider community;
 Present improved and modern infrastructure that will support education
and increase opportunities for pupils at all stages of their learning, as
well as providing better sport, leisure and learning facilities that can be
used and enjoyed by the wider community;
 An extended pool of staff expertise is of a huge value and will offer a
teaching environment where there are more styles, approaches and
levels of experience. The finest staff will be attracted to apply for
positions and there will be a very wide range of opportunities for staff to
develop their careers on site having increased access to promotion
therefore learning will be enriched. Access to state of the art facilities
will help in increasing the reputation of provision and attract staff,
potential pupils and their families;
 Be located away from Station Road with the main vehicular access
taken from Warwick Road. This will displace school traffic away from
Station Road, improving highway safety, reducing traffic congestion and
alleviating parking problems;
 Provide a safer environment when travelling to and from school, with
good pedestrian and cycling connectivity from both within and through
the site to the schools;
 Allow the release of the existing Arden school site to provide for new
residential development on the most accessible and sustainable parts
of the Arden Triangle site, near to village centres and public transport
links. The proposals will provide a mix of market and affordable homes,
including smaller homes for young people and specialist housing to
meet the needs of older people. This will also help regenerate Knowle
and our wider local community by supporting local businesses seeking
increased footfall along the high street to maintain economic strength
and viability.
I confirm that I fully support Policy KN2 – South of Knowle (Arden Triangle)
and believe it meets the Tests of Soundness and is compliant with relevant
legislation. I have arrived at these conclusions as follows:
Soundness and Legal Compliance:
The Policy KN2 Concept Masterplan follows a Placed Based approach and I
believe will benefit all parts of the local community over the term of the Local
Plan and beyond. The proposed Concept Masterplan is the outcome of a
lengthy collaborative approach involving landowners, Arden Academy,
parents, students, and many members of the local community who, alongside
the Council, have sought to establish a Place-Based concept masterplan that
all parties can support in principle, as an effective solution to meeting the
needs of the whole community. In my view, this open and collaborative
approach to the production of the Policy KN2 Concept Masterplan meets the
required tests of soundness and legal compliance.

I am satisfied that Policy KN2 has been sufficiently well developed in collaboration with all parts of the community and represents a Place Based approach that I can fully support, without further modification.

I fully support Policy KN2 – South of Knowle (Arden Triangle) and believe it meets the Tests of Soundness and is compliant with relevant legislation. This is because the Policy KN2 Concept Masterplan follows a Placed Based approach and will benefit all parts of the local community over the term of the Local Plan and beyond.

Most of our buildings still running old cables which tend to degrade over time which are hard to reach and replacement will cost a lot. A careful new school design layout would consider that making the whole system future proof including new improved computer server rooms, communication channels/cabinets/rooms etc which will make the whole system scalable and thus reduce long term costs significantly.

Also a greener new school would decrease the total CO2 emission significantly.

No doubt, Arden offers excellent teaching and learning environment to the students, staff members and local community but unfortunately the school buildings and infrastructures are now failing due to age, capacity and spiralling regular maintenances costs. A new school with newer and much better ICT system, Library, PE, Hall, classrooms will not improve the services but will also increase the school capacity to admit more students and add various services which would be available to the local community.

None

As a former resident of Knowle, the Redevelopment Plans seem to have been on the table for discussion for a long time and it is now a suitable moment to action them. The existing school is tired and many renovations are required to bring it up to scratch. The local community should look to the future and hopefully accept that there are many more pros than cons in the Arden Local Plan. I remember clearly that when I bought my first home in Knowle in the early 1980’s, all the talk then was of a Knowle by-pass to reduce the traffic on the Warwick Road. Well that never happened and look at the weekday congestion during busy peak periods in recent years, especially when large lorries use the road because of holdups on the M42/M6 to gain access to the M40 at Warwick.

I would like to see however, from an IT perspective, dedicated server room, which will help IT Teams to greatly reduce downtimes and avoid affecting the classrooms and students work.
Implement fibre optics to and around the building, which will greatly improve the school network.
Current copper wires are degrading, with little room for improvement. Fibre optics will help future proof the network for expansion, functionality, supporting huge number of devices simultaneously.

There is no doubt in my mind, that Arden provides excellent teacher abilities to all students.
The staff are doing their part, going above and beyond, for the excellence that is Arden Academy.

That is why in my opinion; they deserve a building facility to match their incredible dedication, to help serve them as well in teachings.

N/A

Both a new building for Arden School and an additional primary school are
urgently needed. Arden pupils walking along the Station Road pavement which is
very narrow in places is an accident waiting to happen

None

Arden Academy is desperately in need of modernisation which would be extremely costly and difficult to achieve while keeping the school operating. The development of a new school on a new site is the only practical way forward to have a school site and buildings commensurate with the aspirations of the school community.

The proposal makes economic sense to deliver the new school facilities and also to breathe economic life into the village of Knowle; it’s business and amenities