Policy ENV8 – Open Space, Sport and Recreation

Comment

Representation ID: 10592

Received: 19/08/2021

Respondent: Mr Ian Satterthwaite

There has been a loss of facilities and provision of poorer replacement or refurbishment over the tenure of the metropolitan councils that took over in 1974, viz the closure of Brierley Hill swimming baths, the Replacement of the Stourbridge baths, and lowering of the quality of Halesowen pool facilities that were the best in North Worcestershire

Comment

Representation ID: 11247

Received: 15/09/2021

Respondent: Mr Neil Saunders

I wish to comment on Section ENV 8 re the provision of new favcillities.
I strongly feel that provision should be made within the Plan for the construction of a new sports facility in the area which could house local sports teams, in particularly the much missed Cradley Heathens speedway team. The Heathens were undoubtedly the biggest sports team in the Borough and the campaigns to return the Heathens to the area, which are still ongoing, appear to have been largely ignored by successive Councils.
It seems incredible that a town the size of Dudley, for example, now has no major sports facility. With the increase in population proposed under the Plan, more facilities of this type would surely be required, to encourage both support and participation and to promote the night time economy.
Whilst writing, I also strongly oppose the contruction of housing on green belt land whilst there are many sites within the area where houses could be constructed-for example, i am personally aware of a number of sites which were formerly public houses which have been derelict for a number of years.

Comment

Representation ID: 11301

Received: 29/09/2021

Respondent: Mrs Usha Kumari-Burns

Wildlife suffers, well being suffers when there are no open spaces.

Comment

Representation ID: 11309

Received: 29/09/2021

Respondent: Mrs Emily Fitz-Harris

We need to provide green spaces within reach of housing for mental and physical wellbeing and cause as little negative impact on the environment as possible.

Comment

Representation ID: 11354

Received: 30/09/2021

Respondent: Ms Julia Hawes

Our priority should be protecting the green belt and enhancing it, not destroying it. The loss of green belt in Pelsall/Shelfield - Coronation Street will affect the local residents by depriving them of access to green spaces, as well as removing vital habitats for wildlife, including a variety of birds, deer and small mammals.

Support

Representation ID: 11543

Received: 05/10/2021

Respondent: Hawbush Community Gardens

Happy to see the emphasis given to the retention of open, green spaces - I'm including in this the great parks and recreation facilities across Dudley Borough and facilities like our own Hawbush Community Gardens (Bull Street, DY5 3NQ) - their importance has been underlined by the pandemic. Not only important for health and wellbeing, but for the environmental benefits of valuable habitats for reduction of urban flooding risk, air quality and for pollinating insects and all sorts of wildlife. Also urban food production will be increasingly important in the future, to build resilience into UK food supplies.

Comment

Representation ID: 11746

Received: 08/10/2021

Respondent: Walsall MBC

Good point about making sure new sport and recreation space can be adequately funded

Support

Representation ID: 11885

Received: 10/10/2021

Respondent: Mr. Dennis R Whittaker

This is all about quality of life and well-being. The Policy says it all. We do not want to live in a soul-destroying "concrete jungle".

Support

Representation ID: 12039

Received: 10/10/2021

Respondent: Miss Emma Thompson

as per Wildlife Trust's response

Comment

Representation ID: 12689

Received: 05/10/2021

Respondent: Ms Pamela Wakelin

why can’t things be left I walk in this park every day

Object

Representation ID: 12731

Received: 06/10/2021

Respondent: Dr Gill Pearce

Objection to anymore football pitches in area where we live in kings hill fields. There are 3 already in the park plus others nearby within 5 mins walk. We don’t have a running track and need one.
Spend money on fee lessons at swimming baths tour whole families to encourage healthier population.
Spend money on free access to gyms.
Ban electronic motorised scooters in parks and quad bikes and motorbikes.
Ban electronic scooters and other motorised vehicles on footpaths and enforce this

Support

Representation ID: 15442

Received: 11/10/2021

Respondent: Natural England

We welcome this policy. We would advise linking the Plan’s ambitions for green space with other initiative like Natural England’s Midlands Heathland Heartland partnership the Purple Horizons Nature Recovery Project. See Annex 1 for further information on the project.

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.

Comment

Representation ID: 21271

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy ENV8 – Open Space, Sport and Recreation
Point 2 of this policy states that development that would increase the overall value of open space will be supported particularly in areas of proven deficiency. NPPF Paragraph 31 states that plans need to be supported by up to date evidence. The BCA need to undertake updated open space assessments to identify potential deficits and confirm the likely public open space requirements which may be required on strategic sites.

Comment

Representation ID: 21353

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY ENV8 – OPEN SPACE, SPORTS AND RECREATION
WDH recognises the importance of developments providing or contributing towards public open space, sports and recreation facilities to support the needs of future residents. In that regard, WDH welcomes the reference within Policy ENV8 that open space requirements will be informed by “up-to-date local open space, sport and recreation standards for each local authority, in terms of quantity, quality and access.”

WDH would, however, welcome additional flexibility within the policy to allow open space provision to respond to existing provision (including oversupply and shortfall) in the immediate locality, to ensure that the quantum and type of open space provision meets the evidenced need.

Object

Representation ID: 21485

Received: 11/10/2021

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

Policy ENV8 – Open Space

6.9. As currently drafted, it is considered that this policy is not sound and is not consistent with national policy. This is specifically in regard to the potential for development to be built on existing open space, the potential for which does not appear to be recognised in the emerging policy or supporting text. This is despite the inclusion of specific provisions in Chapter 8 of the National Planning Policy Framework which identifies circumstances where the loss of open space may be acceptable. This should be reflected in the emerging Plan, in order to ensure that it is consistent with national policy.

Object

Representation ID: 21496

Received: 11/10/2021

Respondent: Dudley Group NHS Foundation Trust

Agent: Claremont Planning Consultancy

Policy ENV8 – Open Space

6.9. As currently drafted, it is considered that this policy is not sound and is not consistent with national policy. This is specifically in regard to the potential for development to be built on existing open space, the potential for which does not appear to be recognised in the emerging policy or supporting text. This is despite the inclusion of specific provisions in Chapter 8 of the National Planning Policy Framework which identifies circumstances where the loss of open space may be acceptable. This should be reflected in the emerging Plan, in order to ensure that it is consistent with national policy.

Comment

Representation ID: 22195

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

In principle we support the requirement to make provision for open space and recreation land within new housing developments. The policy advises that open space standards will be set in Part 2 Local Plan produced by each LPA. We therefore cannot comment on this matter any further at this time.

Support

Representation ID: 22225

Received: 11/10/2021

Respondent: Steve Crutchley

Policy ENV8 – Open Space, Sport and Recreation

In principle we support the requirement to make provision for open space and recreation land within new housing developments. The policy advises that open space standards will be set in Part 2 Local Plan produced by each LPA. We therefore cannot comment on this matter any further at this time.

Support

Representation ID: 22244

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Support: WTBBC support the inclusion of Policy ENV8 and, whilst supporting all the Policy points, have suggested changes and additions to a number of these. Explicit support is given to those which WTBBC consider to be of particular significance in the context of the protection and enhancement of the natural environment.
10.107
Support: WTBBC support the recognition that all development proposals should recognise the values and functions of open space as set out in Government policy and guidance, and also address as appropriate various functions of open space that are of particular importance in the Black Country.
3b
Support: WTBBC support that each local authority will set out proposals for specific open spaces that address the priorities set out in the Draft Black Country Local Nature Recovery Strategy.
3cii
Support: WTBBC support protecting the existing greenway network for recreation and biodiversity and taking opportunities to strengthen and expand the network. WTBBC are of the view that to fully realise many of the BCP’s aspirations that mapping of the existing multifunctional green space and greenway network should be undertaken in parallel with the Local Nature Recovery Strategy. This will enable targeted investment in the network which maximises biodiversity, social and a range of other ecosystem services benefits.

Comment

Representation ID: 22245

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1g
Comment: WTBBC welcome the BCP’s recognition of the role of open space in preserving and enhancing diversity in the natural and built environment and preventing the fragmentation of habitat networks. WTBBC are of the view, however, that the policy would be stronger if the built and natural environment are included as separate points.
1h
Comment: WTBBC support strengthening (through extension, increased access and enhanced value) and providing components of a high quality, multifunctional green space and greenway network. This point links with Policy CSP4 point 6: the pursuance of an integrated and well-connected multifunctional open space network. WTBBC are of the view that to fully realise many of the BCP’s aspirations that mapping of the existing multifunctional green space and greenway network should be undertaken in parallel with the Local Nature Recovery Strategy. This will enable targeted investment in the network which maximises biodiversity, social and a range of other ecosystem services benefits.

Comment

Representation ID: 22286

Received: 21/01/2022

Respondent: Miss Jodi Stokes

Open Space, Sport and Recreation

9.5 Draft Policy ENV8 (Open Space, Sport and Recreation) sets out that all development proposals should recognise the values and functions of open space as set out in Government policy and guidance and also address as appropriate the functions of open space that are of particular importance in the Black Country. Part 3 of draft Policy ENV8 confirms that each local authority will set out, in their Local Plans and on Policies Maps, proposals for specific open space, sport and recreation facilities and planning requirements for open space, sport and recreation

Comment

Representation ID: 22364

Received: 11/10/2021

Respondent: Canal & River Trust

The Trust welcomes the proposal to 'move towards the most up-to-date local open space, sport and focuses on quality, quantity and access.

Comment

Representation ID: 23070

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy ENV8 – Open Space, Sport and Recreation

Point 2 of this policy states that development that would increase the overall value of open space will be supported particularly in areas of proven deficiency. NPPF Paragraph 31 states that plans need to be supported by up to date evidence. The BCA need to undertake updated open space assessments to identify potential deficits and confirm the likely public open space requirements which may be required on strategic sites.

Comment

Representation ID: 23162

Received: 11/10/2021

Respondent: Environment Agency

Policy ENV8 – Open Space, Sport and Recreation
Point 1F) of the policy should be expanded as follows to include reference to climate change impacts on flood risk:

‘mitigating the effects of climate change, through reducing potential urban heat island effects and providing opportunities for additional landscaping and tree planting in addition to the ability of open space to be used to provide flood risk betterment in accordance with policy CC5’

Comment

Representation ID: 23270

Received: 11/10/2021

Respondent: Historic England

Clause 1 we are not clear on what assets this policy is aiming to protect. Where heritage is relevant, we recommend that the policy protects the significance of the heritage assets including their setting. How will this clause be considered through the development management process?

Support

Representation ID: 23315

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

In principle we support the requirement to make provision for open space and recreation land within new housing developments. The policy advises that open space standards will be set in Part 2 Local Plan produced by each LPA. We therefore cannot comment on this matter any further at this time.

Support

Representation ID: 23431

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

9.17 Draft Policy ENV8 (Open Space, Sport and Recreation) advises that each local authority will set out, in their Local Plans and on Policies Maps, proposals for specific open space, sport and recreation facilities and planning requirements for open space, sport and recreation. We support this policy

Object

Representation ID: 43880

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

11.17 Policy ENV8 considers open space, sport and recreation, and identifies that open space quantity standards to be provided through new development will be set out within local plans produced by each of the Black Country authorities. This is not supported as it does not provide any certainty or confirmation of viability to those allocations contained within the Plan. Whilst the provision of separate standards for each of the authority areas is supported, it is not understood why these open space standards could not be forthcoming through this Plan.

Support

Representation ID: 43923

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.64 As expressed throughout these representations, there is a need for policy
requirements to be fully evidence and justified. Barratt therefore support using the most up to date local open space, sport and recreation standards and these should be evidenced accordingly by each local authority and inform further development of the plan.
3.65 Barratt support draft policy ENV8 which sets out the aim for expanding community use of open space, sport and play, and moving towards most ‘up to date’ local open space, sport and recreation standards. Open space evidence identifies deficit around land at Pennwood. As such, the masterplan comprises a large amount of open space including a new woodland park and play facilities.
3.66 Wolverhampton’s most up to date evidence is the Open Space Strategy and Action Plan (2018). This report finds that:
· There is a decrease in the quantity standards of open space provided in Wolverhampton from 4.43ha per 1,000 population in 2012 to 4.38ha per 1,000 population. This is due to the reduction in the total amount of open space and increase in population.
· The ‘Central and South’ area (which land at Pennwood is located within) represents the second most significant decrease in open space – 0.76ha per 1,000 population. This includes a 0.18ha per 1,000 population loss of parks. The

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loss has seen the need for children and young person’s provision not being met in the area.
· In terms of accessibility to district parks, a large proportion of Sedgley to the north of land at Pennwood is not within a 20 minute walk of a district park.
· The overall summary for the ‘Central and South’ area is that “there are low levels of open space provision” (page 25) and that “there is little potential to create new open space through development”.
3.67 Land at Pennwood’s significant benefit of public open space representing more than 50% of the proposals, including a woodland park and play areas will make a substantial contribution to the deficits identified in Wolverhampton’s most up to date open space, sport and recreation evidence.