brentwood.gov.uk

Sport England objects to part of the potential allocation of Land at Officer's Meadow, Shenfield (site 087) for residential development in the local plan as currently proposed.

The site is known as Alexander Park and is a small public playing field containing two mini soccer pitches adjoining Shenfield High School's playing fields. The site is in active use and is currently used by Hutton FC's (one of the largest community football clubs in the Brentwood area with 60 teams) mini football teams.

While acknowledging reference is made in the site allocation to indicative uses including playing pitches, until there is some certainty in the policy about the nature of such provision this cannot be given much weight. The site allocation opportunities and constraints do not make any reference to a specific 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. This site was assessed as part of the study and identified that the mini soccer pitches were being overplayed (i.e. level of use was exceeding their carrying capacity). 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 is expected to 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 specific policy requirements set out in the allocation relating to the Alexander Park playing fields, it has been 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 pitches 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.

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 specifically proposed as part of the site allocation;
* The allocation is principally 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 protection of site and the removal of the proposed allocation (site 087) 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. To address this, the site allocation policy would need to set out that any development of the site (site 087) would not be acceptable unless replacement playing field provision was made as part of the wider site allocation which was equivalent or better provision in terms of quantity and quality on the wider Officers Meadow site allocation (incorporating sites 034, 087, 235 and 276) prior to any development commencing. Alternatively, a replacement playing field (outside of the Officers Meadow site allocation) would need to be identified and allocated through the local with the same provisions in terms of the replacement being equivalent or better in terms of quantity and quality and being implemented prior to any development commencing. This may be preferential to like for like provision being made in the site allocation due to the limited size of the site e.g. a contribution to a more strategic project identified in the emerging playing pitch strategy may be more appropriate. Regard should also be had to the Council's new Playing Pitch Strategy when determining to most appropriate form of mitigation.

The authority will be aware that Sport England would be a statutory consultee on any future planning application for development on this site. As the principle of development on this site will be considered through the local plan rather than a planning application, it will be important that the Council engages Sport England with a view to reaching a mutually agreeable solution through the local plan process. We would wish to avoid a potential scenario where we would have no option but to object to a future planning application due to the matters set out above not being satisfactorily addressed through the local plan. This scenario may also result in uncertainties and delays with respect to the delivery of development on the site.

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.