brentwood.gov.uk

Sport England objects to the potential allocation of Land at Priests Lane, Shenfield (site 044/178) for residential development in the local plan as currently proposed.

The majority of the site (around 4 hectares) was used as Brentwood Ursuline School's detached playing fields in the past. When the school discontinued use of the site, the site was used by a local football club. Historic aerial photographs indicate that the site was marked out for a number of sports pitches.

The site allocation opportunities and constraints do not make any reference to a policy requirement to replace the playing fields in accordance with Government policy in paragraph 74 and Sport England's playing fields policy.

The Council's Sport, Leisure and Open Space Assessment (2016) (which forms the local plan's current evidence base for sports facilities), has assessed community playing pitch needs in detail and has identified deficiencies in provision including for football and rugby pitches. The assessment has confirmed that existing playing pitches should be protected and improved unless it can be demonstrated that the land is surplus to requirements. The study has not recommended that any playing fields be disposed of because they are surplus to requirements. The Council is currently preparing a new Playing Pitch Strategy that will supersede the 2016 study which may show greater deficiencies of playing pitch provision than that shown in the current study. The new strategy should be completed by the time the Pre-Submission Local Plan is prepared and therefore should be used for informing the site allocation.

As there is no supporting information to explain the Council's position on the allocation of this site or any policy requirements set out in the allocation, it has to be interpreted that it is proposed that the site will be allocated for development without any replacement playing field provision being made. This would not be justified by the Council's evidence base on playing pitch provision which, as set out above seeks to protect existing playing fields due there being no surplus of provision in Brentwood Borough. In addition, it would not be justified by policy 10.9 of the draft local plan (2016) either which contains a presumption against development which would result in the loss of open space or sports facilities unless it can be demonstrated that the site is surplus to requirements. It is noted that the 2016 local plan consultation made reference to the allocation including provision of open space and/or sport facilities for public use. The omission of such a reference in the current consultation is of concern in the context of the need to protect or replace the playing fields.

The allocation would not accord with Government policy in the NPPF especially paragraph 74 which specifically applies to proposals for developing playing fields. None of the three criteria in the policy would be applicable for the following reasons:

* It has not been demonstrated that the site is surplus to requirements as set out above;
* No replacement playing field provision is currently proposed as part of the site allocation;
* The allocation is for residential development and therefore would not represent alternative sport and recreation provision.

The allocation would also be contrary to Sport England's playing fields policy 'fields 'A Sporting Future for the Playing Fields of England' www.sportengland.org/playingfieldspolicy which is used by Sport England for assessing planning applications affecting playing fields where Sport England is a statutory consultee. This policy mirrors paragraph 74 of the NPPF and is given weight in the development management process due to Sport England's statutory consultee role.

While the site may not be currently in use as a playing field, Sport England considers proposals for the development of such sites in the same way as playing fields that are in active use because development on them would permanently prevent such sites from being brought back into use. Even if the playing fields are no longer needed for use by the current owner (the Ursuline Sisters Brentwood CIO), this does not affect our position. Sport England's playing fields policy and the Government planning policy in paragraph 74 of the NPPF does not distinguish between public and private playing fields and whether playing fields are currently in use or not. It should be emphasised that Sport England's role is to safeguard playing fields for meeting the needs of current and future users. While this playing field may not be in active use at present, it may be required for meeting current or future community playing pitch needs.

While Sport England's focus is on protecting playing fields for meeting community needs, it should also be demonstrated that the playing fields are no longer required for meeting the current or future needs of the Brentwood Ursuline School that last used it.
While the protection of site and the removal of the proposed allocation from the local plan would be an acceptable solution, as an alternative, potential may exist for this objection to be addressed in accordance with paragraph 74 of the NPPF and Sport England's playing fields policy if the playing fields were acceptably replaced as a requirement of the site allocation policy. It would be inappropriate at this stage to be prescriptive on the nature of replacement provision as the Council's new Playing Pitch Strategy is currently being prepared which will be assessing current and future playing pitch needs in the area. Until this is completed, it will not be clear whether it would be suitable to protect the site and seek to reinstate it to community use, replace it with a new playing field on another site or seek financial contributions in lieu of replacement provision towards priority projects that will address community needs.

To take this matter forward with a view to reaching a mutually agreeable solution in advance of the Pre-Submission Local Plan being finalised, the Council are urged to engage with Sport England to explore a potential solution informed by the Council's Playing Pitch Strategy.