Object

Representation ID: 17564

Received: 11/10/2021

Respondent: Sport England

Policy ENV8 - Open Space, Sport and Recreation Sport England supports the intention of this policy which seeks to provide for the protection of open space (including playing fields), to protect existing built sports facilities, to support the provision of new built sports facilities and to address the approach to developer contributions from housing development to the provision of sports facilities. Some authorities prefer to cover these in separate policies, which is worth considering. However, there are several key issues that warrant our objection as drafted: 1) The approach to protection of open space, sport and recreation network in part 2) of the policy does not currently accord with para 99 of the NPPF and Sport England’s Playing Fields Policy (see attached link), where as drafted the policy refers to "value" as the relevant metric and does not include suitable criteria to align with the above policies. The policy should provide a criteria-based assessment for the loss of sports buildings and land, including playing fields in line with para 99 of the NPPF: ie. either that there is robust up to date evidence to demonstrate a surplus of provision in the relevant catchment area; the sports facility to be lost would be replaced by provision that is equitable in quantity, quality and in a suitable location; or that the proposed development is a development for sport which would be of sufficient benefit to outweigh the loss. Sport England would recommend using the wording of our policy, or alternatively the wording of para 99 which are comparably very similar to our policy. If the Council wishes to re-phrase, that would be acceptable too so long as the meaning isn’t altered. https://www.sportengland.org/how-we-can-help/facilities-and-planning/planning-for-sport#playing_fields_policy 2) Sport England wishes to object to the wording of part 3) of the policy which states in a) that a loss of quantity can be offset by a gain in quality. This is not consistent with para 99 of the NPPF and Exception E4 of SE policy where the test is to secure equitable mitigation for quantity AND quality in a suitable location. Rather than to refer to playing fields standards, which Sport England does not advocate, a more appropriate approach would be to set out that in order to ensure sufficient supply of good quality sports and recreation facilities, the LA’s will prepare Development Plans informed by a needs assessment in accordance with Sport England guidance (ie the Playing Pitch and Outdoor Sports Facilities Strategy - PPOSS). Notwithstanding the above points, Sport England supports part 3ciii) which promotes expanding the use of sports facilities at education sites, part 3civ) which promotes increased access for all including those with disabilities, and part 3cvii) to addressing cross boundary impacts, a key issue being considered in the PPOSS. 3) In regard to Part 4) of the policy that relates to protecting existing built sports facilities, the wording of the policy should be revised be consistent with the criteria tests in para 99 of the NPPF. As drafted, the wording does not do this as the only criteria referred to is where adequate alternative provision is available. Also, the plan does not have a separate policy to protect other community facilities, since this only deals with built sports facilities? Is this an omission that should be re-considered? 4) In regard to part 5) of the policy which relates to the provision of new built sports facilities, the policy wording should require that the provision of new sports facilities should be demonstrated to accord with identified needs to ensure provision of appropriate facilities in a suitable location to meet that need. 5) In regard to part 6) of the policy that relates to meeting the needs of proposed housing development, the wording of the policy only refers to meeting the need for built sports facilities, where Sport England would wish to see reference to natural turf playing pitches as well as built sports facilities (such as AGP's, courts, sports halls etc). Part 6 of the policy does not currently address how such developer contributions are to be derived. eg. to use the findings and recommendations of relevant evidence base assessments. (ie PPOSS) and Sport England's Playing Pitch Calculator and Sports Facilities Calculator tools, or other such alternative means of calculating developer contributions, where necessary to be set out in further detail in a Planning Obligations SPD or similar? Sport England would recommend the Council considers other tier 1 plans such as the London Plan 2021 Policy S5 as an example of how this policy could be worded to accord with relevant guidance in the NPPF and Sport England's Playing Fields Policy. https://www.london.gov.uk/sites/default/files/the_london_plan_2021.pdf

In Para 10.109 of the justification an associated reference to the Sport England Calculator's should be added if these are to be used alongside the evidence of need to secure appropriate developer contributions. In para 10.114 of the justification an associated reference to provision of natural turf playing pitches should be added to the existing reference to built sports facilities. Within the evidence base, Sport England's Active Design policy is referenced which is positive, though the relevance should be explained in the justification.