Draft Black Country Plan

Support

Representation ID: 17544

Received: 11/10/2021

Respondent: Sport England

Sport England supports the reference in part 1d) of this policy to taking opportunities where they arise to co-locate healthcare facilities with facilities for sport to capture opportunities for social prescribing since this can bring about stronger outcomes for physical and mental well-being in line with the plan's objective. A good example of this is Portway Lifestyle Centre in Sandwell (case study link attached below). https://www.sportengland.org/know-your-audience/case-studies/portway-lifestyle-centre

Support

Representation ID: 17545

Received: 11/10/2021

Respondent: Sport England

Sport England supports the policy to require HIA's for relevant development proposals in part 1) and the requirement to mitigate negative health impacts in part 2). We support the reference in para 5.34 to applying this to relevant infrastructure for physical activity, recreation and active travel, and would encourage the Authorities to develop further guidance to explain how this policy will be applied in practice.

Support

Representation ID: 17546

Received: 11/10/2021

Respondent: Sport England

Policy HOU5 - Education Facilities Sport England supports part 4) of the policy which promotes the shared use of education facilities for wider community use for sport. The evidence in the emerging draft Playing Pitch and Outdoor Sports Strategy (PPOSS) points to the importance of protecting and enhancing accessibility to the existing network of sports facilities at education sites across the Black Country as they contribute to meeting the community needs for outdoor sports facilities including playing pitches and courts for the existing population, and this will continue to be important to contribute to meeting the needs of proposed population growth to 2039. We also know from past work with each of the Local Authorities that access to school sports halls and other indoor sports facilities at education sites are also important to meeting community needs. Sport England would recommend a minor modification to the wording to refer to securing community use of new and redeveloped/extended education facilities in line with evidence of need, and to secure this through a suitably worded community use agreement. Sport England supports the reference in part 5) of the policy to protecting and enhancing the existing network of education facilities for the reasons given above. Under the section on delivery reference should be made to securing community use agreements. Sport England's guidance on Community Use Agreements is provided in the link below: https://www.sportengland.org/how-we-can-help/facilities-and-planning/planning-for-sport/community-use-agreements

Support

Representation ID: 17547

Received: 11/10/2021

Respondent: Sport England

Further to Sport England's comments on policies CSP2 and CSP3, Sport England recommends reference being added to part 1) of the policy to include sport and recreation uses within the list of appropriate uses, since this is consistent with NPPF Glossary definition of Main town centre uses, and links well the the later part of this paragraph which refers to fostering healthy communities and increasing social interaction and cohesion. An associated amendment to para 8.15 of the justification to add in reference to sports uses in part a) would also be recommended.

Support

Representation ID: 17548

Received: 11/10/2021

Respondent: Sport England

As above, reference to sports uses should be added to part 1b) of the policy as these uses are suitable complementary uses consistent with the NPPF definition referred to above.

For reference

Policy CEN1 - The Black Country Centres Further to Sport England's comments on policies CSP2 and CSP3, Sport England recommends reference being added to part 1) of the policy to include sport and recreation uses within the list of appropriate uses, since this is consistent with NPPF Glossary definition of Main town centre uses, and links well the the later part of this paragraph which refers to fostering healthy communities and increasing social interaction and cohesion. An associated amendment to para 8.15 of the justification to add in reference to sports uses in part a) would also be recommended.

Support

Representation ID: 17549

Received: 11/10/2021

Respondent: Sport England

Policy CEN3 - Tier Two Centres As above, reference to sports uses should be added to part 1) of the policy as these uses are suitable complementary uses consistent with the NPPF definition referred to above.

For reference:

Policy CEN1 - The Black Country Centres Further to Sport England's comments on policies CSP2 and CSP3, Sport England recommends reference being added to part 1) of the policy to include sport and recreation uses within the list of appropriate uses, since this is consistent with NPPF Glossary definition of Main town centre uses, and links well the the later part of this paragraph which refers to fostering healthy communities and increasing social interaction and cohesion. An associated amendment to para 8.15 of the justification to add in reference to sports uses in part a) would also be recommended. Policy CEN2 - Tier One : Strategic Centres As above, reference to sports uses should be added to part 1b) of the policy as these uses are suitable complementary uses consistent with the NPPF definition referred to above.

Object

Representation ID: 17555

Received: 11/10/2021

Respondent: Sport England

Policy TRAN1 Priorities for the development of the transport network
Sport England supports part 2) of the policy that refers to all new developments must provide adequate access to all modes of travel including walking and cycling and the need to meet accessibility standards. However the policy stops short of requiring developments to contribute to a modal shift to active travel which seems a missed opportunity, since a strong case can be made for requiring developers to do their part to reduce reliance on private cars. Can the policy be stengthened to address this point? Sport England supports part 3) of the policy that includes reference to prioritising key transport corridors for active travel, though the key transport corridors listed in part 4) of the policy do not specifically include any priorities relating to walking and cycling, referring only to priorities for motorways, rail, rapid transit, key road corridors, and interchanges. The associated justification also doesn't make any reference to active travel priorities. This then suggests that the priorities are not active travel related? Can this be addressed by strengthening the policy to provide reference to key corridors for walking and cycling, potentially linked to the national cycle network, existing infrastructure such as canal towpaths etc?

Support

Representation ID: 17559

Received: 11/10/2021

Respondent: Sport England

Sport England supports the proposed policy wording for cross LA working to ensure a comprehensive network and to common design standards for walking and cycling. We support the emphasis in part 2) of the policy to ensuring new developments link to existing walking and cycling networks, ensuring links are suitably designed to be safe and direct and not impeded. In our experience, developers are often less successful in this area and tend to focus on infrastructure for walking and cycling within their developments. The policy should make it clear how developers will be expected to contribute to improving connecting new development to existing links for walking and cycling : ie. through developer contributions. Consideration should be given to including requirements within the policy for the provision of showers/changing facilities and lockers within major employment/workplace uses to complement the requirement for cycle parking facilities to positively influence a modal shift.

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.

Support

Representation ID: 17568

Received: 11/10/2021

Respondent: Sport England

Policy ENV9 - Design Quality Sport England supports Part 1e) of the policy that makes specific reference to the 'agent of change' principle as set out in the NPPF. The footnote that relates needs to be updated to reflect the para numbering (now para 187) and text within the latest version of the NPPF (2021). The policy is a missed opportunity to reference Active Design and Active Environments Principles which would sit well with the other principles of good design that are referenced in this policy and would then cross relate to the reference in policy ENV8, and to the other parts of the plan that relate to Health and Well-Being. For instance, could the wording of this policy be strengthened to require major developments to demonstrate they have addressed Active Design issues by providing an Active Design Checklist? (see appendix A of the attached guidance) https://www.sportengland.org/how-we-can-help/facilities-and-planning/design-and-cost-guidance/active-design