brentwood.gov.uk

To address these objections, the following amendments should be made to the policy:

* Criterion (c) of section A is replaced with a criterion along the lines that that playing fields are either retained for community use or replaced in accordance with policy BE23;
* An additional criterion is added to the policy which expects new educational establishments to be planned and designed to allow use by the community when not required for educational use and which encourages developments on existing establishments to facilitate new or increased community access.

Objection is made to criterion (c) of part A of the policy as it would allow in principle the change of use or redevelopment of an educational playing field if it could be demonstrated that the area of the site is in excess of Government guidelines for playing field provision. This approach is contrary to both the Council's evidence base on playing fields and Government policy in paragraph 97 of the NPPF.

As demonstrated by the Council's new Playing Pitch Strategy, the education sector provides the largest proportion of the community's playing fields in Brentwood Borough and the community is dependent on the retention of educational playing fields for meeting needs. As set out in the strategy's action plan, the strategy seeks to protect existing sites and increase/secure community use on educational playing fields. Criterion (c) of the policy would be contrary to the recommendations of the Playing Pitch Strategy as it would potentially allow educational playing fields to be redeveloped for other uses if they were surplus to educational requirements. No account or reference is made to the community use of playing fields in this criterion. The Government guidelines on playing field provision referred to (the DfE's Building Bulletin 103 at present) do not account for community use of school playing fields as they are entirely focused on educational needs and they represent DfE guidance rather than Government planning policy and are not referred to in the NPPF.

Government planning policy in paragraph 97 of the NPPF does not distinguish between public and educational playing fields and does not allow for educational playing fields to be disposed of if they are surplus to educational needs. It should be emphasised that current Government policy on the protection of playing fields has been strengthened since the 1990s in response to school playing fields being disposed of that were surplus to educational requirements but important for meeting community needs. Sport England was also made a statutory consultee by the Government in order to police the Government's planning policy in response to this. The retention of criterion (c) could potentially result in valued dual use playing fields being unintentionally lost if applicants made the case the proposals accord with this policy despite being contrary to the Council's evidence base, policy BE23 on open space and the NPPF.

Objection is also made to the policy as while the reasoned justification in paragraph 7.95 encourages education providers to share their assets with the community, this is not reflected in the policy itself. Given the importance given by the Government in paragraph 92 of the NPPF to planning policies planning for the provision and use of shared spaces and the importance attached to this in the Council's evidence base (e.g. recommendation 3 of the Playing Pitch Strategy) expecting new educational facilities to be planned and designed to facilitate shared use and encouraging greater shared use of existing facilities would be justified.

In its current form Policy PC15 would not be justified by the Council's current evidence base and would not accord with Government policy in the NPPF. The approach would therefore not meet the 'justified' and 'consistent with Government policy' tests of soundness.