UK Central Hub

The plan would seem to need to consider how it is treating a residential area as simply a form of conurbation that can be expanded
with this expansion consisting of industry, commerce, and transport in a way that reduces quality of life for residents

The plan while making references to e.g. green belt appears to support the expansion of commercial and industrial land in close proximity to residential areas to encroach into it
This is completely unsympathetic towards a long established residential area and the residents that enjoy and support it

Reference in para 831 to “a relocated Household Waste and Recycling Centre and Depot” must be removed due to this inconsistency with policy and lack of very special circumstances justifying it’s removal from Green Belt for use as a HWRC/depot given the availability of alternative sites. Its inclusion in the Plan appears to seek reallocation without having requisite consultation or detailed analysis of other (more highly commended) sites considered in the Cushman report, but not referred to in the Plan.

para 831 identifies land at Damson Parkway as an option for a relocation of HWRC. Its removal from green belt was sought only due to very special circumstances that exist to facilitate the expansion of JLR. HWRC on this site would be inconsistent with such very special circumstances justifying the release of land from the Green Belt and would undermine the policy objectives for the site. The SMBC commissioned report by Cushmans confirms this and highlights 3 more suitable sites. Moreover there has been no detailed assessments or consultation with Councillors or the public which would justify its specific identification.

Alternative land should be found for the waste and recycling plant, away from this already congested area of Solihull. I can only assume that none of the councillors have to suffer trying to reach the Coventry Road junction when JLR are changing shifts - the route is already at breaking point and we have yet to see the impact of the logistics centre. It's always been a case of 'what JLR want, JLR get' and now we are being asked to suffer even more

The proposal to move the waste and recycling plant will cause massive issues in terms of traffic, particularly following the council's previous decision to all JLR to build a new logistics centre in the same area. the loss to date of out natural landscape is a disgrace and this will bring yet more congestion and added pollution to the area

Allocate the Arden Eco Park site for employment uses and an Energy from Waste site.

The wider former Arden Brickworks site, now called Arden Eco Park, covers a total area of around 38.6 hectares (95.4 acres). The Eco Park site is accessed from the A45 via a one-way service road running on the south side of and parallel to the A45 between Stonebridge Island to the east, at the junction of the A45/A452, and M42/J6 to the west.

The Arden Eco Park lies within the M42 Solihull Economic Gateway with additional expansion proposed to this gateway. It is located in the West Midlands Green Belt in the Meriden Gap which separates Birmingham from Coventry and is largely surrounded by agricultural land apart from a large Kennel complex – Top Hat Kennels - on the frontage which is likely to be directly affected by HS2, and Pasture Farm to the east. The HS2 line is due to pass just to the east of Arden Eco Park leading into the new Interchange Station north of the A45.

Birmingham International Airport, the National Exhibition Centre and Birmingham International Station are located around 2 miles to the north west accessed off the A45 to the west of the M42.

Future development of the site

As such Arden Eco Park is a major previously developed site in a strategic position and already operates a Materials Recovery Facility (MRF) at the rear of the site alongside the remaining areas of clay extraction. The Local Plan recognises the clay extraction operation as well as the MRF as established facilities.

The major frontage part site comprises a Civic Amenity Facility which has operated for many decades to service the wider Solihull community but is proposed to be relocated to a site near Damson Parkway which for many is likely to be less accessible that the present facility at Bickenhill.

Behind the Civic Amenity site lie a large number of business units used by utility and civil engineering companies for offices and ancillary facilitate as well as open storage (B8) with ancillary facilities mainly covered by a Certificate of Lawful use granted by the LPA in 2007 (ref 2007/ 1171). The site comprises a large area of hardstanding a range of buildings in brick or profiled steel buildings which have largely replaced the former brickwork buildings.

The owners of the land have ambitions to establish a major Power from Waste facility on this site which would make a major contribution to the energy needs of the area around including the Arden Cross development area around the HS2 Interchange with over 5000 new houses as well as business development.

The Arden Eco Park site has been submitted under the Council’s Call for Sites in relation to the Local Plan as land for business and employment uses given into extensive past history. The Local Plan has not recognised that submission and no provision is being made in the plan for the site to contribute positively to needs of the Solihull Economic Gateway which it is well placed to do.

No provision is made in the Plan for dealing with major brownfield sites in the Solihull Local Plan which are included within many other local plans. Leaving it to the development management process is not sufficient to give a proper and appropriate policy framework for considering proposals. In the future.

Designated the Arden Eco Park for employment uses and an Energy from Waste Facility.

No provision on made for representations in respect of mineral or recycling sites. The site is most related tp UK Hub Central

The wider former Arden Brickworks site, now called Arden Eco Park, covers a total area of around 38.6 hectares (95.4 acres). The Eco Park site is accessed from the A45 via a one-way service road running on the south side of and parallel to the A45 between Stonebridge Island to the east, at the junction of the A45/A452, and M42/J6 to the west. The site is located in the UK Central;Hub Corridor

The Arden Eco Park lies within the M42 Solihull Economic Gateway with additional expansion proposed to this gateway. It is located in the West Midlands Green Belt in the Meriden Gap which separates Birmingham from Coventry and is largely surrounded by agricultural land apart from a large Kennel complex – Top Hat Kennels - on the frontage which is likely to be directly affected by HS2, and Pasture Farm to the east. The HS2 line is due to pass just to the east of Arden Eco Park leading into the new Interchange Station north of the A45.

Birmingham International Airport, the National Exhibition Centre and Birmingham International Station are located around 2 miles to the north west accessed off the A45 to the west of the M42.

Future development of the site

As such Arden Eco Park is a major previously developed site in a strategic position and already operates a Materials Recovery Facility (MRF) at the rear of the site alongside the remaining areas of clay extraction. The Local Plan recognises the clay extraction operation as well as the MRF as established facilities.

The major frontage part site comprises a Civic Amenity Facility which has operated for many decades to service the wider Solihull community but is proposed to be relocated to a site near Damson Parkway which for many is likely to be less accessible that the present facility at Bickenhill.

Behind the Civic Amenity site lie a large number of business units used by utility and civil engineering companies for offices and ancillary facilitate as well as open storage (B8) with ancillary facilities mainly covered by a Certificate of Lawful use granted by the LPA in 2007 (ref 2007/ 1171). The site comprises a large area of hardstanding a range of buildings in brick or profiled steel buildings which have largely replaced the former brickwork buildings.

The owners of the land have ambitions to establish a major Power from Waste facility on this site which would make a major contribution to the energy needs of the area around including the Arden Cross development area around the HS2 Interchange with over 5000 new houses as well as business development.

The Arden Eco Park site has been submitted under the Council’s Call for Sites in relation to the Local Plan as land for business and employment uses given into extensive past history. The Local Plan has not recognised that submission and no provision is being made in the plan for the site to contribute positively to needs of the Solihull Economic Gateway which it is well placed to do.

No provision is made in the Plan for dealing with major brownfield sites in the Solihull Local Plan which are included within many other local plans. Leaving it to the development management process is not sufficient to give a proper and appropriate policy framework for considering proposals. In the future.

The Arden Eco Park site should be allocated as a site for energy from waste and other related development.

RIGS Designation

The Local Plan refers to a Regionally Important Geological Site within the minerals working area. As we understand it RIGS are now called ‘Local Geological Sites’ and have a similar status to Local Wildlife Sites, i.e. non-statutory but protected through policy in Local Plans and as a material planning consideration in applications.

The designation for the Brickworks site still exists in the Submission version of the Local Plan and we believe that the citation for the former brickworks describes important exposures of the Triassic, Mercia Mudstone Group which are important for educational purposes. 'The strata consists of irregularly bedded red clay and mudstone, interbedded with green mudstone and green sandstone skerry horizons'.

While the quarry owners are prepared for students to observe the exposure subject to proper prior and safe arrangements, that exposure is not static and mineral working and subsequent landfill n that such exposure is continually on the move. While extraction is ongoing then presumably there will new exposures of these strata created periodically but the requirements of the minerals planning permission require the land to be back filled and returned to agriculture. As such that designation on the site should be removed from the Local Plan.

The draft plan should reflect that the Schedule 17 submissions for HS2’s new landmark Interchange station and Automated People Mover were approved by the Council and the surface car parking awaiting reserved matters permission.

Thank you for consulting HS2 Ltd on the Draft Local Plan Submission. I can confirm that HS2 Ltd fully supports the ambitions of the local authority to realise the economic and social benefits of the HS2 railway at the heart of the West Midlands in the context of the new HS2 Interchange station. Through ongoing engagement HS2 Ltd will also support the Council in the objectives of developing the UK Central Hub area with both the Interchange station and wider HS2 Phase One scheme.
Having consulted with colleagues across the organisation, including disciplines such as commercial development, delivery, civil engineering, town planning and urban integration, HS2 Ltd has several specific observations and comments to make on the document subject to consultation. However, the following initial points are provided by way of context.
Firstly, as you are aware the government has announced its intention to construct and operate Phase One of a high-speed railway, known as High Speed Two (HS2), between London and Birmingham; and Phase Two between Birmingham and Manchester and Leeds. On 25 November 2013 the government deposited a hybrid Bill with Parliament titled ‘High Speed Rail (London - West Midlands) Bill’. The Bill grants the powers to construct Phase One of the HS2 network. HS2 Ltd is the non-departmental public body responsible for developing and promoting these proposals and the company works to a Development Agreement made with the Secretary of State for Transport.
On 23 February 2017 Royal Assent was granted for Phase One of HS2 and since then there have been two further significant milestones for the HS2 programme, namely; the Government officially giving HS2 the ‘green signal’ on 11 February 2020 and then on 14 July 2020 the Department for Transport giving HS2 Ltd approval to issue ‘Notice To Proceed’ (NTP) to the four Main Works Civils Contractors (MWCC) to commence full detailed design and construction of Phase One. This represented a major milestone for HS2 amidst the difficult and challenging times facing us all currently and marks the point at which our work transitions from scheme design and preparatory works to more detailed design and construction.
HS2 Ltd welcomes fact that the arrival of HS2 in the borough following Royal Assent and NTP is a key feature in the draft Submission Plan, and the Leadership of the Council rightly recognises how the HS2 project represents a unique opportunity, and as such a proper planning policy framework is in place to maximise the benefits arising from this once in a lifetime opportunity.
HS2 Ltd also acknowledges that to help shape that future policy, the plan identifies various potential challenges and what the objectives should be in addressing them. In submitting this consultation response HS2 Ltd wishes to focus on following specific issues which are of relevance to the HS2 project:
1.‘Increasing accessibility and encouraging sustainable travel’ with objectives including: ‘Ensuring that expected levels of population growth as well as delivery of HS2 and UK Central do not compound existing levels of peak hour congestion on the principal road network.’
2.‘Maximising the economic and social benefits of the High Speed 2 rail link and the UKC Hub Area’.
‘Challenges:
• ‘Securing amendment to the HS2 proposal for a Parkway style interchange station with surface car parking, which could undermine efforts to maximise the economic and social benefits of the rail link.’
Objectives:
• ‘Creating a sense of place and arrival via a well-connected and integrated interchange, public realm and development opportunities that help support the HS2 Growth Strategy aspirations for employment, skills, environment and infrastructure.’
• ‘Ensuring appropriate infrastructure is in place that allows the Interchange to be well connected to the nearby key economic assets, including Birmingham Airport, the NEC, local universities and the wider Hub area so that they (and others) can take advantage of the opportunity provided by HS2.’
• Ensuring that the HS2 Interchange prioritises access by bus, cycle, Metro, SPRINT bus rapid transit network, or the Coventry Ultra-Light Rail system rather than the private car.
• Promote cross-boundary connectivity to HS2 from the wider sub-region and key destinations to maximise opportunities for the Midlands Engine for Growth and reduce the need to travel by car.’
3.‘Mitigating the impacts of High Speed 2 and the growth associated with the UKC Hub area’
‘Challenges:
• Impact of construction works on the HS2 rail link and interchange station on the environment, communities and transport network, and subsequently during the operational phase.
• Significant infrastructure requirements associated with the rail link and interchange.
• Impact of the associated economic and housing growth on the Borough’s transport network, communities, environment and its Green Belt.
Objectives:
• Maximise opportunities of HS2.
• Develop a strategy to mitigate the impacts of increased road traffic to/from Birmingham Interchange including public transport provision, junction schemes and environmental measures required.
• To make efficient use of land at the Interchange site by utilising decked car park options in lieu of extensive surface level parking.’
In response to objectives associated with the above points the draft plan should fully reflect the fact that the Schedule 17 submissions (under the HS2 Act) for HS2’s new landmark Interchange station and Automated People Mover were approved by the Council on 1 September 2020 and 15 October 2020 respectively, with the surface car parking awaiting reserved matters permission subject to the completion of a legal agreement (expected imminently), with the planning officer’s report stating the design creates: “an exciting contextual response to its setting”.
Accordingly, HS2 Ltd considers that the base case Interchange station scheme including surface car parking option is already protected through those detailed approvals obtained following Royal Assent for the HS2 Phase One Act of Parliament and associated planning regime. However, as the Council are aware through recent publicity on both the UGC and Arden Cross Masterplan consultations it is also acknowledged that UGC are progressing the necessary design work and planning process for a Multi Storey Car Park (MSCP) option at the site to HS2 standards and requirements.
In that context the draft plan should be clear on a) the requirement to achieve an implementable planning permission for the MSCP in accordance with stakeholder funding timescales as set out in MSCP Steering Group meetings and; b) that UGC will also be responsible for obtaining the necessary planning and Schedule 17 permissions required for the delivery a MSCP option and associated changes to the Interchange station site (note the MSCP will not be permissible under HS2 Act Powers).
HS2 Ltd wishes to clarify that existing high-level assessments of impacts shown in the Arden Cross Masterplan by our appointed design consultants have excluded any analysis of highways, vehicular capacities, sitewide drainage, inclusivity and pedestrian modelling impacts. Therefore, it should be noted that any rearrangement of proposed HS2 carparking and multi-modal provision will have a significant impact on the operation of the new Interchange station and will need to be assessed in detail as the both the ACL Masterplan matures and Draft Local Plan Review progresses further.
Lastly, HS2 Ltd welcomes the identification of the high-speed railway on the Policies Map so proposed allocated sites for development in the draft plan are visible relative to HS2 interests. This is also in line with paragraph 22 of Safeguarding Directions guidance on Local Plans available here: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/844432/LPA_Ph1.pdf.
Conclusion
HS2 Ltd welcomes the opportunity to engage with the local authority through this process of consultation on the draft Local Plan document and is fully supportive of aims to maximise potential development opportunities that help support the HS2 Growth Strategy aspirations for employment, skills, environment and infrastructure in both Solihull Borough and wider West Midlands region. We also look forward to further engagement with the Council as the plan-making process continues.
However, regarding the established local plan soundness criteria and in order to ensure the plan is legally compliant and sound, the Council is also respectfully reminded to consider these representations prior to the document’s submission for examination by a Planning Inspector.

This representation is made on behalf of The National Exhibition Centre Ltd (“The NEC Group”) in response to the publication of the Regulation 19 version of the Solihull Local Plan (Draft Submission Version) (hereafter referred to as “the Plan”).
The NEC Group welcomes the opportunity to submit a representation on the Draft Submission Version and is pleased that further progress is being made toward the adoption of the Local Plan.
The Plan’s overall focus on supporting the continued and sustainable growth of the Borough and meeting both housing and economic needs is welcomed. By directing growth principally toward the UK Central Solihull Hub Area the Plan is implementing a coherent strategy to support growth in a highly accessible and sustainable location alongside maximising the economic and social benefits that High Speed 2 will bring.
The NEC Group supports the objective for the Hub Area to become globally renowned as the best-connected business, leisure and entertainment destination in Europe and a major driver of the UK economy, along with the creation of a sense of place that draws upon a modern interpretation of ‘garden village’ principles. The focus on supporting the aspirations of the economic assets in the Hub, including significant employment based and housing growth, is essential if the Borough is to meet its overall objectives and targets.

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Policy P1 UK Central Solihull Hub Area is an important policy of the Plan supporting the continued success of the most significant economic assets for the Borough and region.
In the context of these overall objectives, it is imperative that the Plan continues to support future development and investment at the NEC site reflecting its status as one of the leading venues in the UK for major exhibitions, events, entertainment, and leisure. This emphasis on continued investment and development at the NEC site will maintain and enhance its role as a key economic asset for the Borough and region.
The NEC site’s exceptional public transport connectivity, set to be further enhanced by the arrival of High Speed 2, location next to a wide range of existing amenities and facilities, and status as brownfield land, makes it a highly sustainable location for future residential and commercial development.
The scale of this opportunity was originally recognised and demonstrated by the nec.city masterplan, which included at least 2,500 new homes. As a result, the NEC site is one of the single largest housing development sites in the Borough contributing significantly to the housing land supply over the plan period. The Plan’s recognition at both Policy P1 and P5 of the NEC’s role in the housing land supply of the Borough is important and welcomed.
Notwithstanding the overall support for the Plan there are opportunities to further strengthen its content and ensure that the scale of the opportunity at the NEC site is fully realised, including for residential development. It is also essential that the Plan incorporates sufficient flexibility to enable the economic role of the NEC site to evolve in response to changing global and national circumstances.
Acknowledging the scale of the opportunity at the NEC site the NEC Group are undertaking to review the existing masterplan, which will continue to demonstrate the central role that the NEC site can play in delivering new development, including for housing and economic growth.
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The NEC Group would therefore welcome continued dialogue with Solihull MBC on the Local Plan. It is suggested that a Statement of Common Ground is produced to establish the areas of agreement and areas where further changes may be required to ensure that the Local Plan fully supports and enables the development potential of the NEC site to be realised and in turn support the delivery of the overall strategy for the Borough.
The NEC Group, and their appointed representatives, would wish to participate, as required, in the examination hearing session(s) relevant to the UKC Solihull Hub Area and the NEC site, including on housing supply and delivery.

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.

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.

The terms for the ‘UK Central Hub’ should be rationalised, clearly defined and used accordingly.

A clear policy on the UK Central Hub housing contribution - the housing contribution should be clearly identified within the Policies Map and a Concept Masterplan for each site, in the same manner as other allocated sites.

The quantum of dwellings and timeframe for delivery as quoted within the Plan and supporting evidence should be consistent.

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 policy and/ or concept masterplan should identify relevant details of coordination of landowners and implementation of necessary infrastructure, including quantum of development and timetable.

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

That NEC site should be fully assessed for its suitability for development.

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 terms for the ‘UK Central Hub’ should be rationalised, clearly defined and used accordingly.

A clear policy on the UK Central Hub housing contribution - the housing contribution should be clearly identified within the Policies Map and a Concept Masterplan for each site, in the same manner as other allocated sites.

The quantum of dwellings and timeframe for delivery as quoted within the Plan and supporting evidence should be consistent.

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.

The policy and/ or concept masterplan should identify relevant details of coordination of landowners and implementation of necessary infrastructure, including quantum of development and timetable.

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.

The development of Arden Cross requires Green Belt compensation.

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.

The NEC site should be fully assessed for its suitability for development.

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.

The Arden Cross site should be fully assessed for its suitability for development.

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.

Additional land should be allocated to accommodate a further 1,740 dwellings (880 dwellings for flexibility buffer to the requirement and 860 dwellings for the revised housing delivery at NEC). ‘Land off Main Road, Meriden’ should be allocated for housing.

Dear Sir / Madam

Please find attached a copy of representations submitted by RPS on behalf of Redrow Homes to the Solihull Local Plan Draft Submission Plan (Regulation 19) consultation in respect to Land off Main Road, Meriden.

Please can we request a delivery receipt once received, for our records.

Many thanks