Sport England supports the 'Healthy' development principle as this would be consistent with Government policy in paragraph 91 of the NPPF in relation to planning policies enabling and supporting healthy lifestyles.

To address this objection, the policy should be amended to add an additional policy criterion requiring the loss of Dunton Hills Golf Centre to be addressed through demonstrating that the facility is surplus to requirements or provision being made for its retention or replacement with equivalent/better facilities as part of the development.

Sport England welcomes that the development will be underpinned by Garden Community principles and qualities and is particularly supportive of the proposals in section 4 of the policy relating to community/health infrastructure and green/blue infrastructure.

However, the policy is objected to because it has not addressed the need to either demonstrate that Dunton Hills Golf Centre is surplus to requirements through a golf course needs assessment or make provision for retaining/replacing the golf centre if the needs assessment shows that all or parts of the golf centre should be protected for meeting community golf facility needs.

While the Council has recently produced a draft Golf Course Needs Assessment (October 2018), Sport England's and England Golf's (the governing body) feedback on this assessment has been that the scope of the assessment needs to be widened to cover the full range of golf facilities in the study area (not just 18 hole courses) such as driving ranges, putting areas and par 3 courses. Without this, the assessment would not be comprehensive e.g. there could be a surplus of 18 hole courses in the area but a deficiency of driving ranges. Until an acceptable golf course needs assessment has been completed, Sport England and England Golf are not in a position to provide informed advice on whether the loss of the golf centre within this allocation would accord with Government policy in paragraph 97 of the NPPF or policy BE23(D) of the local plan. Consequently, Sport England would have to object to the policy in its current form as it would not be considered to meet the 'justified' or 'consistent with national policy' tests of soundness.

The approach to the spatial design of the Dunton Hills Garden Village is supported especially in relation to:

* Green Infrastructure - section C
* Sport, Recreational, Leisure and Public Open Space - section C
* Sustainable Travel - section G
* Social Infrastructure - section L

This approach would be considered to accord with Government policy in section 8 of the NPPF in relation to 'promoting healthy and safe communities. The reference in paragraph 9.52 of the reasoned justification to the principles of active design guiding the evolution of the village layout, street hierarchy and connectivity is particularly welcomed.

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.

The removal of the Shenfield High School and Alexander Park playing fields from the R03 from the local plan would be the preferred solution to addressing this objection. However, as an alternative, potential may exist for this objection to be addressed in accordance with paragraph 97 of the NPPF, policy BE23 of the local plan 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 development principles in the site allocation policy would need to set out that the playing fields and supporting facilities at Shenfield High School and Alexander Park would either need to be retained unless replacement playing field provision (including ancillary facilities such as the pavilion and car parking) was made which was equivalent or better provision in terms of quantity and quality on the wider site allocation prior to any development commencing. Any replacement provision would need to avoid prejudicing Shenfield High School or the community from meeting their needs.

The authority will be aware that Sport England would be a statutory consultee on any future planning application for development on this site which affects the playing fields. 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 is likely to result in uncertainties and delays with respect to the delivery of development on this site.

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 part of the allocation of Land North of Shenfield for residential development in the local plan. While acknowledging that only 28.2 of the 58.2 hectare site is proposed for development, a substantial area of the southern part of the allocation includes Shenfield High School's playing fields and the adjoining Alexander Park to the east of the school's playing fields.

Shenfield High School's playing fields, which are located on both sides of Alexander Lane, are a strategically important site for meeting community playing field needs in Brentwood Borough and contains six junior and mini football pitches of different sizes plus a non-turf cricket wicket. The playing fields to the south of Alexander Lane adjoining the school buildings also contain a full size floodlit artificial grass pitch (3G surface) and a pavilion containing six team changing rooms and social facilities. As demonstrated by the Council's recent playing pitch strategy, the playing pitches and supporting pavilion are used extensively by the community as well as the school and demand for the use of the artificial grass pitch exceeds capacity at peak times. The Essex County FA have advised that the artificial grass pitch provides Hutton Football Club (who run around 60 teams) with a training and match play venue and that the school's main and detached playing fields are also used by the club who are one of the Borough's largest community youth football clubs. Alexander Park is a small public playing field containing two mini soccer pitches and is in active community use and is currently used by Hutton FC's mini football teams. The loss of any of these facilities would have a huge impact on community grassroots football in Brentwood Borough and would add extra pressure to an already stretched grass pitch stock.

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 provision especially for youth and mini football pitches and 3G artificial grass pitches. The sites were assessed as part of the strategy and identified that the pitches were being fully used by the community and that some pitches were being overplayed (i.e. level of use was exceeding their carrying capacity). The strategy has confirmed that both the Shenfield High School and Alexander Park sites should be protected through the local plan. The study has not identified that any playing fields be disposed of because they are surplus to requirements.

In addition to meet community needs, the Shenfield High School playing fields are needed for meeting the school's PE and sports needs and the site allocation would potentially prejudice the school from meeting their needs. Even if the playing fields were replaced elsewhere on the R03 allocation site, it is difficult to see how they could be replaced without the playing fields being divorced from the school site and the consequent implication for meeting the school's PE curriculum.

A further constraint that will need to be considered is that the artificial grass pitch and pavilion on the site was substantially funded through a grant (around £500,000) made by the Football Foundation to the school. If the site is to be developed without an acceptable replacement solution, the school would be at risk of Football Foundation seeking reimbursement of the grant awards which may affect deliverability of any development on the site.

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 the allocation of the playing field area of the site or any specific policy requirements set out in the allocation relating to playing field mitigation, 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 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.

The allocation in its current from 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 specifically 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.