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While the protection of the site and the removal of the proposed allocation from the local plan would be an acceptable solution, as an alternative, potential would exist for this objection to be addressed in accordance with paragraph 97 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. As the Council's playing pitch strategy has recently considered the matter and specifically recommended that the loss of the playing fields be mitigated through replacement playing field provision, a solution that would be acceptable would be for an appropriate financial contribution to be secured towards the delivery of replacement playing field provision either on new playing field sites or in enhancing existing playing fields nearby. This could be addressed through modifying the policy's development principles to make provision for replacement playing field provision to be a pre-requisite of the development.

To take this matter forward with a view to reaching a mutually agreeable solution in advance of the matter being considered at the local plan examination, the Council are urged to engage with Sport England to explore a potential solution.

Sport England objects to the allocation of Land at Priests Lane, Shenfield for residential development in the local plan.

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 Council's new Playing Pitch Strategy (November 2018), 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 pitch provision especially for youth and mini football pitches and 3G artificial grass pitches. In response to the deficiencies identified in the strategy, the action plan in the document has specifically confirmed that the loss of this site should be mitigated by investment in replacement facilities elsewhere in the Borough. Furthermore, recommendation 5 of the strategy specifically refers to protecting the current level of football provision including sites that have been used for football in the past. The study has not identified that this playing field could be disposed of without mitigation because it is surplus to requirements.

The site allocation policy does not make reference to the playing fields and there are no development requirements for retaining or replacing the playing fields in accordance with Government policy or the Council's evidence base. As there is no supporting information to explain the Council's position on this matter or any specific policy requirements set out in the allocation, it has been interpreted that it is proposed that the site will be allocated for development without any provision being made to retain or replace the playing fields. This would not be justified by the Council's evidence base on playing pitch provision or by policy BE23 of the local plan which contains a presumption against development which would result in the loss of open space or sports facilities unless it can be demonstrated that alternative facilities will be provided. While reference is made to the provision of public open space being a development principle, it has been interpreted that this relates to public open space to support the residential development rather than provision to mitigate the loss of the playing fields.

The allocation would not accord with Government policy in the NPPF, especially paragraph 97, 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 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 97 of the NPPF and is given weight in the development management process due to Sport England's statutory consultee role. The proposal in its current form would not therefore be considered to meet the 'justified' or 'consistent with national policy' tests of soundness.

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 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. This is recognised in the Council's playing pitch strategy and explains why the strategy's action plan seeks mitigation in the form of investment on other playing field sites.