Draft Black Country Plan

Object

Representation ID: 17575

Received: 11/10/2021

Respondent: Sport England

DUH049 - Former Mons Hill Campus (Dudley College), Wrens Hill Road, Dudley.

Sport England understands that the proposed allocation (being carried over from the adopted Dudley Borough Development Strategy) relates solely to the former college buildings and does not include the associated former playing fields to the south? The wording of the proposed allocation should ensure that the future use of the playing fields is not adversely affected by retaining access to the playing fields.

Object

Representation ID: 17577

Received: 11/10/2021

Respondent: Sport England

DUH204 - Wellington Road and Dock Lane, Dudley (Dudley Leisure Centre site).

The wording of the allocation should set out that before the site comes forward for development the replacement leisure centre in Dudley should be implemented and available for use to ensure the allocation accords with para 99 of the NPPF.

Object

Representation ID: 17578

Received: 11/10/2021

Respondent: Sport England

DUH216 - Bryce Road, Pensnett.

This site includes playing fields, the loss of which needs to be addressed in line with para 99 of the NPPF and Sport England's Playing Fields Policy. In the absence of evidence that the playing field is surplus, mitigation provision that is equitable in quantity and quality in a suitable location will be required. This should be set out in the wording of the allocation, otherwise Sport England will be likely to maintain an objection to the proposed allocation. The Football Foundation advise that the site has been used in the past for Stourbridge and Dudley Youth Football League for girls league matches, and so the site could make an important contribution to meeting local needs.

Object

Representation ID: 17579

Received: 11/10/2021

Respondent: Sport England

DUH002 - Land at Wharf Road, Stourbridge.

Sport England understands that the proposed allocation is to be carried over from the adopted Dudley Borough Development Strategy. Notwithstanding this, the allocation of the whole of the site for development for housing and associated open space represents a missed opportunity to address known issues of lack of capacity for football and cricket at the adjoining sports ground; home of Stourbridge FC and Stourbridge CC. Both clubs would benefit from the provision of an additional pitch to reduce the pressures of ground sharing and to facilitate expansion of the clubs. Both clubs have growing numbers of teams and a lack of pitch capacity which will be considered in detail in the forthcoming Playing Pitch and Outdoor Sports Strategy (PPOSS). The PPOSS is likely to recommend a need for access to additional pitches to meet their respective needs. Sport England would wish to see the allocation be amended to require the provision of a new playing pitch and associated ancillary facilities within part of the site to address this issue?

Object

Representation ID: 17653

Received: 11/10/2021

Respondent: Sport England

The occupiers of new development, especially residential, will generate demand for sporting provision. The existing provision within an area may not be able to accommodate this increased demand without exacerbating existing and/or predicted future deficiencies. Therefore, Sport England considers that new developments should contribute towards meeting the demand that they generate through the provision of on-site facilities and/or providing additional capacity off-site. The level and nature of any provision should be informed by a robust evidence base such as an up to date Sports Facilities Strategy, Playing Pitch Strategy or other relevant needs assessment. The Council are currently preparing a new Playing Pitch and Outdoor Sports Facilities Strategy (PPOSS) to consider how to meet existing and future needs for playing pitches and other outdoor sports facilities. The PPOSS will scenario test the proposed major housing growth sites within the proposed plan and make recommendations for how best to meet the future needs generated by this population growth. These needs might be best met by either on-site provision of new pitches and ancillary facilities, off-site contributions to improve existing provision of pitches/ancillary facilities in the local area or a combination of both. Sport England are aware that there are several existing sports facilities locally that would potentially benefit from developer contributions in order to improve the existing provision to cater for the additional demand generated by these proposed developments. Sport England considers that the following proposed allocations are of sufficient size to justify suitable developer contributions towards sport to meet the needs of the respective developments. At Reg 19 stage, following the completion of the PPOSS, Sport England will make more detailed comments with reference to Sport England's Playing Pitch Calculator. The following proposed policy allocations should make specific reference to securing suitable developer contributions towards the provision of facilities for sport in line with the findings and recommendations of the PPOSS:
DUH208 (DSA 1) - Land south of Holbeache Lane/Wolverhampton Road, Kingswinford - 330 dwellings

Object

Representation ID: 17654

Received: 11/10/2021

Respondent: Sport England

The occupiers of new development, especially residential, will generate demand for sporting provision. The existing provision within an area may not be able to accommodate this increased demand without exacerbating existing and/or predicted future deficiencies. Therefore, Sport England considers that new developments should contribute towards meeting the demand that they generate through the provision of on-site facilities and/or providing additional capacity off-site. The level and nature of any provision should be informed by a robust evidence base such as an up to date Sports Facilities Strategy, Playing Pitch Strategy or other relevant needs assessment. The Council are currently preparing a new Playing Pitch and Outdoor Sports Facilities Strategy (PPOSS) to consider how to meet existing and future needs for playing pitches and other outdoor sports facilities. The PPOSS will scenario test the proposed major housing growth sites within the proposed plan and make recommendations for how best to meet the future needs generated by this population growth. These needs might be best met by either on-site provision of new pitches and ancillary facilities, off-site contributions to improve existing provision of pitches/ancillary facilities in the local area or a combination of both. Sport England are aware that there are several existing sports facilities locally that would potentially benefit from developer contributions in order to improve the existing provision to cater for the additional demand generated by these proposed developments. Sport England considers that the following proposed allocations are of sufficient size to justify suitable developer contributions towards sport to meet the needs of the respective developments. At Reg 19 stage, following the completion of the PPOSS, Sport England will make more detailed comments with reference to Sport England's Playing Pitch Calculator. The following proposed policy allocations should make specific reference to securing suitable developer contributions towards the provision of facilities for sport in line with the findings and recommendations of the PPOSS: DUH211 (DSA 2) - Land at Swindon Road, Wall Heath, Kingswinford (The Triangle site) - 533 dwellings

Object

Representation ID: 17655

Received: 11/10/2021

Respondent: Sport England

The occupiers of new development, especially residential, will generate demand for sporting provision. The existing provision within an area may not be able to accommodate this increased demand without exacerbating existing and/or predicted future deficiencies. Therefore, Sport England considers that new developments should contribute towards meeting the demand that they generate through the provision of on-site facilities and/or providing additional capacity off-site. The level and nature of any provision should be informed by a robust evidence base such as an up to date Sports Facilities Strategy, Playing Pitch Strategy or other relevant needs assessment. The Council are currently preparing a new Playing Pitch and Outdoor Sports Facilities Strategy (PPOSS) to consider how to meet existing and future needs for playing pitches and other outdoor sports facilities. The PPOSS will scenario test the proposed major housing growth sites within the proposed plan and make recommendations for how best to meet the future needs generated by this population growth. These needs might be best met by either on-site provision of new pitches and ancillary facilities, off-site contributions to improve existing provision of pitches/ancillary facilities in the local area or a combination of both. Sport England are aware that there are several existing sports facilities locally that would potentially benefit from developer contributions in order to improve the existing provision to cater for the additional demand generated by these proposed developments. Sport England considers that the following proposed allocations are of sufficient size to justify suitable developer contributions towards sport to meet the needs of the respective developments. At Reg 19 stage, following the completion of the PPOSS, Sport England will make more detailed comments with reference to Sport England's Playing Pitch Calculator. The following proposed policy allocations should make specific reference to securing suitable developer contributions towards the provision of facilities for sport in line with the findings and recommendations of the PPOSS:

For the reasons explained above, Sport England does not agree with the contents of para A92 which states that it is considered that the local area will have good access to...sports facilities that have capacity to meet the varied needs of new residents. In advance of the completion of the PPOSS this cannot be agreed. The PPOSS may in fact demonstrate a shortfall of capacity for some sports? DUH203 (DSA 3) - Ketley Quarry/Ketley Farm, Dudley Road, Kingswinford - 612 dwellings

Object

Representation ID: 17657

Received: 11/10/2021

Respondent: Sport England

SAH091 - Land at Friar Park Road, Wednesbury - 750 dwellings.

The site includes playing fields, the loss of which needs to be addressed in line with para 99 of the NPPF and Sport England's Playing Fields Policy. Sport England notes that the table states the playing pitches on the site will need to be retained or replaced. The wording of the policy should be refined to ensure that in the absence of the playing field being demonstrated to be surplus, mitigation provision that is equitable in quantity and quality in a suitable location will be required. This is necessary to ensure the policy accords with para 99 of the NPPF and Sport England's Playing Fields Policy.

Object

Representation ID: 17658

Received: 11/10/2021

Respondent: Sport England

SAH228 - Brandhall Golf Course - 560 dwellings.

The site allocation involves the loss of an existing sports facility. The Council have undertaken a Golf Needs Assessment to make the case that the golf course is surplus. Whilst Sport England do not wish to object to the loss of the golf course, as its accepted that there are other courses in the local area with capacity for new members and for pay and play use, there is a strong case for securing mitigation from the loss of this course to invest in improvements to existing golf facilities. England Golf advise that Warley Woods is a prime candidate for investment and could definitely offer a more rounded facility to cater for more golfers if money were to be spent here. They advise that the golf club members have been asking for a while for improvements to the building they use as a clubhouse and have faced numerous challenges. Sport England would therefore be likely to object to the allocation at Reg 19 stage unless the policy allocation expressly includes a requirement to secure a suitable developer contribution towards mitigation for the loss of the golf course. Whilst Sport England understand that the development of the site will also involve the development of a new park with opportunities for informal recreation, this cannot be agreed as mitigation for the loss of the golf course as this does not benefit golf.

Object

Representation ID: 17659

Received: 11/10/2021

Respondent: Sport England

SAH103 - Former Phoenix Collegiate School, Friar Park Road, Wednesbury - 84 dwellings.

The site includes playing fields, the loss of which needs to be addressed in line with para 99 of the NPPF and Sport England's Playing Fields Policy. The wording of the policy should be revised to ensure that in the absence of the playing field being demonstrated to be surplus, mitigation provision that is equitable in quantity and quality in a suitable location will be required. This is necessary to ensure the policy accords with para 99 of the NPPF and Sport England's Playing Fields Policy. The table refers to a planning application having been submitted. Sport England have objected to the planning application as a package of mitigation has not yet been agreed.