Draft Black Country Plan

Support

Representation ID: 17517

Received: 11/10/2021

Respondent: Sport England

Sport England supports the inclusion of providing infrastructure to support growth (part g) and health and well-being (part h) within the key challenges and issues to be addressed in the proposed plan. These two matters are closely linked together, whereby having the right facilities in the right place to support residents needs for sport and physical activity is proven to contribute to better physical and mental health and well-being.

Support

Representation ID: 17518

Received: 11/10/2021

Respondent: Sport England

The vision as drafted "Creating a prosperous, stronger and sustainable Black Country" is a missed opportunity to make direct reference to creating a healthier and more active Black Country to tie in with the above challenges more directly.

Support

Representation ID: 17519

Received: 11/10/2021

Respondent: Sport England

Sport England supports the inclusion of Strategic Priorities 5 (relating to health and well-being, physical activity, active travel etc), 10 (active travel), and 15 (infrastructure needs), as they relate well to Sport England's new strategy : Uniting the Movement. https://www.sportengland.org/why-were-here/uniting-the-movement

Support

Representation ID: 17522

Received: 11/10/2021

Respondent: Sport England

Sport England supports the reference in part 1c) of this policy to ensuring that sufficient physical, social and environmental infrastructure is delivered to meet identified needs. Sport England are working with the Black Country Authorities on their evidence base for sport, in the form of a new Playing Pitch and Outdoor Sports Strategy (PPOSS). Whilst noting that there is not a specific reference to this evidence on page 32, there is a more generic reference to Strategic Environmental Evidence. If this is considered to encapsulate the PPOSS a separate reference may not be required, however the Council's are invited to consider this point to ensure the PPOSS is appropriately referenced under this policy.

Sport England also supports the reference in 2f) to protecting open spaces, which ties into the protection of playing fields under Policy ENV8.

Support

Representation ID: 17523

Received: 11/10/2021

Respondent: Sport England

Sport England would encourage the Authorities to add a reference to uses for sport and recreation within part 3b) of the policy. Whilst leisure is already included in the policy, this is taken to mean commercial leisure uses rather than sports uses. Sports uses are referenced separately from leisure uses within the NPPF Glossary for the definition of Main town centre uses, and so it would be entirely appropriate to reference sports and recreation uses within this policy.

Support

Representation ID: 17524

Received: 11/10/2021

Respondent: Sport England

As above, Sport England would encourage the Authorities to add a reference to uses for sport and recreation within part 1e) of the policy as this would be consistent with the definition of Main town centre uses within the NPPF. Part 1g) of the policy should add a reference to sport and recreation as the green belt is an important location for sports pitches across the Black Country area.

Support

Representation ID: 17525

Received: 11/10/2021

Respondent: Sport England

Sport England supports the references within this policy to Active Design and Active Environments principles, which we define as creating places and spaces that encourage people to be physically active. In particular, we support: * In part 1) the emphasis on spaces and buildings being influenced by their context to respond positively to identified community needs; * In part 4) to developing a permeable street network that provides active travel choices * In part 5) to ensuring safe and secure environments including safe and accessible pedestrian and cycle infrastructure * In part 6) to ensuring an integrated and well-connected open space network, including through new developments for housing and employment uses, with reference to delivering opportunities for sport and recreation. Since the policy makes specific reference to these Active Design principles, it would be appropriate to reference Sport England's Active Design Guidance in the associated justification and evidence on pages 42-44. A link to Sport England's guidance is provided below: https://www.sportengland.org/how-we-can-help/facilities-and-planning/design-and-cost-guidance/active-design

Object

Representation ID: 17539

Received: 11/10/2021

Respondent: Sport England

Policy GB1 - The Black Country Green Belt The policy wording omits to reference that certain forms of development are not inappropriate development provided they preserve its openness and does not conflict with the purposes of including land within it. The green belt is an important asset for outdoor sport and recreation uses with several playing pitch sites being located within the Black Country Green Belt. Sport England considers that it would be entirely appropriate to expand the wording of the policy to reference such changes of use for outdoor sport and recreation, which would be entirely consistent with the guidance contained in para 150 of the NPPF.

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.

Support

Representation ID: 17543

Received: 11/10/2021

Respondent: Sport England

Policy HW1 - Health and Well-Being As per Sport England's comments on policy CSP4, we welcome the references throughout this policy to encouraging active lifestyles through Active Design and creating Active Environments. In particular we support: * In 1a) the reference to creating inclusive, safe environments that foster a strong sense of place and encourage social interaction for all; * In 1b) the reference to enabling active and healthy lifestyles, through measures to improve active travel opportunities for all; * In 1g) the reference to protecting social infrastructure including sport and recreation. We would recommend a minor modification to the wording to refer to 'protect, enhance and provide' a range of social infrastructure as this would capture a broader range of development opportunities, and also to make an amendment to refer to 'indoor sport and recreation facilities' in part 1g) since outdoor sport and recreation is addressed in part 1h). Part 1g) should cross-refer to the relevant social infrastructure policies including ENV8. * In 1h) the reference to sports facilities should be refined to 'outdoor sports facilities including playing fields' since indoor sports facilities is addressed in 1g). * In 1i) the reference to the importance of allotments and gardens for physical and mental well-being Since the policy makes strong references to Active Design and Active Environments principles it would be entirely appropriate and recommended by Sport England to reference Sport England's Active Design Guidance within the associated justification and evidence. https://www.sportengland.org/how-we-can-help/facilities-and-planning/design-and-cost-guidance/active-design