Support

Representation ID: 17540

Received: 11/10/2021

Respondent: Sport England

Sport England is generally supportive of this policy which serves to ensure that required social infrastructure is provided to meet the respective development's needs, noting that sport and recreation facilities are expressly included in para 4.24 which defines the Council's broad list of infrastructure within the scope of this policy. The policy refers in part 1) to ensuring all new developments mitigate its impacts. Part 5) of the policy states that proposals that are unable to comply with BCP policies on viability grounds must be accompanied by a detailed Financial Viability Assessment. When read together, this potentially creates an unintended consequence that mitigation for loss might not be required under the terms of this policy where it is not viable to do so. Sport England would object to the loss any existing sports facilities, including loss of playing field that has not been appropriately mitigated in line with para 99 of the NPPF, Sport England's Planning for Sport Guidance, and Playing Fields Policy and Guidance on grounds that it would be unviable to do so. This would not be consistent with national policy since there is no viability criteria to para 99 of the NPPF. This could be addressed by ensuring that the wording of part 5) of the policy is amended to make clarify that this does not relate to mitigating the impacts of the development, and that viability testing relates solely to required infrastructure to meet the needs of the proposed development. The Council have commissioned a new Black Country-wide Playing Pitch and Outdoor Sports Strategy (PPOSS) which will assess the needs for outdoor sports facilities arising from the planned housing growth in the proposed plan. Sport England considers that the PPOSS should be added to the list of relevant evidence for this policy on page 62, ensuring that the PPOSS is then referred to in respect of infrastructure needs for outdoor sport when applying this policy.