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Support

Draft Local Plan

SO11

Representation ID: 13204

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

Support is offered for including a strategic objective (SO11) which protects and nurtures existing leisure facilities and recreational assets to promote and enhance social inclusion and health and well-being as this recognises the role that sport, recreation and leisure facilities play in meeting this objective.

Full text:

Support is offered for including a strategic objective (SO11) which protects and nurtures existing leisure facilities and recreational assets to promote and enhance social inclusion and health and well-being as this recognises the role that sport, recreation and leisure facilities play in meeting this objective.

Support is also offered for the strategic objective (SO13) relating to delivering essential infrastructure including community facilities in order to support new development growth as this recognises the importance of sport and recreation facilities (which would form part of community facilities) in creating sustainable communities in new developments.

Comment

Draft Local Plan

Policy 6.3: General Development Criteria

Representation ID: 13205

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

Criterion (i) which requires new development to mitigate its impact on local services and community infrastructure is welcomed and considered justified. However, it would be helpful if the supporting text in paragraph 6.19 explains what is included within the term community facilities and services so that there is clarity when implementing the policy about what this covers e.g. are sport, leisure and recreation facilities included?

Full text:

Criterion (i) which requires new development to mitigate its impact on local services and community infrastructure is welcomed and considered justified. However, it would be helpful if the supporting text in paragraph 6.19 explains what is included within the term community facilities and services so that there is clarity when implementing the policy about what this covers e.g. are sport, leisure and recreation facilities included?

Comment

Draft Local Plan

Policy 6.4: Effective Site Planning

Representation ID: 13206

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

In view of the importance attached to promoting and enhancing health and well-being in the plan's strategic objectives (SO11), the policy should be amended to include an additional criterion along the lines that the planning and design of buildings and spaces should promote active lifestyles (through encouraging physical activity). This would thereby contribute to delivering the wider health and well-being objective.

Full text:

In view of the importance attached to promoting and enhancing health and well-being in the plan's strategic objectives (SO11), the policy should be amended to include an additional criterion along the lines that the planning and design of buildings and spaces should promote active lifestyles (through encouraging physical activity). This would thereby contribute to delivering the wider health and well-being objective. The supporting text to the policy (or policy 10.6) should refer to Sport England's and Public Health England's Active Design guidance
http://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/active-design/ which provides Government endorsed guidance (that has recently been refreshed) on how the design and layout of new developments can be planned to make communities more active and healthier.

Object

Draft Local Plan

Policy 7.1: Dunton Hills Garden Village

Representation ID: 13207

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

As set out in detail in Sport England's representations made on the 2015 consultation on this proposal, consideration will need to be given to issues relating to the potential loss of the Dunton Hills Golf Centre, the scale and nature of sports facilities required to meet the needs generated by the development and promoting active lifestyles through the masterplanning of the development. These should be considered in the supporting text to the policy to provide a framework for the masterplan.

Full text:

As set out in detail in Sport England's representations made on the 2015 consultation on this proposal, consideration will need to be given to the following matters when developing the masterplan for this proposal:

* The Dunton Hills Golf Centre will need to be retained or relocated unless it can be demonstrated that it is surplus to requirements through a needs assessment;
* The Council's emerging evidence base for sport (Sport and Leisure Study being prepared by PLC) should be used (together with Basildon BC's evidence base) to inform the scale and nature of community sports facility provision that will need to be provided on-site or off-site to meet the additional needs generated by a development of this scale
* Sport England & Public Health England's Active Design guidance should be used for guiding the masterplanning of the development in order to promote sport and physical activity in the new development and thereby help meet the local plan's wider strategic objective relating to promoting and enhancing health and well-being (SO11)

While the proposed masterplan would be expected to consider these matters, it is advocated that these issues are highlighted in the supporting text to policy 7.1 in order to provide a framework for the masterplan.

Object

Draft Local Plan

044 & 178 Land at Priests Lane, Brentwood

Representation ID: 13208

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

Objection is made to the proposed allocation of site 044/178 - Priests Lane, Brentwood as it would involve the permanent loss of land last used as playing fields which may offer potential to meet community playing pitch needs. Unless the Council's emerging evidence base demonstrates that there is a clear surplus of provision or replacement provision is made, the loss of this site would be contrary to Sport England's playing fields policy and Government planning policy on playing fields set out in paragraph 74 of the NPPF.

Full text:

Objection is made to the proposed allocation of site 044/178 - Priests Lane, Brentwood as it would involve the permanent loss of land last used as playing fields which may offer potential to meet community playing pitch needs. This site may offer potential for meeting community playing field needs if the Council's emerging playing pitch strategy (part of the Sport and Leisure Study) identifies playing pitch deficiencies in this area. Unless the study demonstrates that there is a clear surplus of provision or replacement provision is made, the loss of this site would be contrary to Sport England's playing fields policy and Government planning policy on playing fields set out in paragraph 74 of the NPPF. Consequently, at this stage, Sport England would object to the potential allocation of this sites for residential unless (in accordance with Government policy and Sport England playing fields policy) off-site replacement playing field provision was made to mitigate the impact. While acknowledging reference is made in the allocation to providing sports facilities and open space for public use as part of the development, until clarity is provided about the scale and nature of such provision this cannot be given much weight as it may not accord with the above policies. It should be noted that Government policy in the NPPF and Sport England's playing fields policy applies to both playing fields in use and those last in use as a playing field and applies to all types of playing field regardless of ownership.

The allocation should be reviewed unless the emerging evidence base demonstrates that there is a clear surplus of provision or acceptable replacement provision is made on-site or off-site. In this regard, weight should be given to concerns raised by Sport England and the sports governing bodies on the draft playing pitch strategy because if these are not satisfactorily resolved the strategy will not be considered to be sufficiently robust to satisfactorily demonstrate that there is a clear surplus of provision.
The Council will be aware of Sport England's role as a statutory consultee on planning applications affecting playing fields. To avoid potential objections and delays at a later date if this site ise allocated for development, it is advised that discussions take place with Sport England before this site allocation is confirmed in the pre-submission version of the local plan. Further advice can be provided on how our concerns could be potentially addressed as well as advice on how to avoid some of the problems experienced by other local authorities who have allocated playing fields for development in their local plans.

Object

Draft Local Plan

034, 087 & 235 Officer's Meadow, Shenfield

Representation ID: 13209

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

Objection is made to the proposed allocation of site 087 - Officer's Meadow, Shenfield as it would involve the permanent loss of the playing fields which meet (or offer potential to meet) community or school playing pitch needs. Unless the Council's emerging playing pitch strategy demonstrates that there is a clear surplus of provision, the loss of this site would be contrary to Sport England's playing fields policy and Government planning policy. Consequently, at this stage, Sport England would object to the potential allocation of this site for residential unless off-site replacement playing field provision was made.
[No objection is made to the allocation of site references 034 and 235 which comprise other parts of this site allocation.]

Full text:

Objection is made to the proposed allocation of site 087 - Officer's Meadow, Shenfield as it would involve the permanent loss of the playing fields adjoining Shenfield High School which meet (or offer potential to meet) community or school playing pitch needs. Unless the Council's emerging playing pitch strategy (part of the Sport and Leisure Study) demonstrates that there is a clear surplus of provision, the loss of this site would be contrary to Sport England's playing fields policy and Government planning policy on playing fields set out in paragraph 74 of the NPPF. Consequently, at this stage, Sport England would object to the potential allocation of this sites for residential unless (in accordance with Government policy and Sport England playing fields policy) off-site replacement playing field provision was made to mitigate the impact. While acknowledging reference is made in the allocation to potential for sport/open space uses as part of the development, until clarity is provided about the scale and nature of such provision this cannot be given much weight as it may not accord with the above policies. It should be noted that Government policy in the NPPF and Sport England's playing fields policy applies to both playing fields in use and those last in use as a playing field and applies to all types of playing field regardless of ownership.
The allocation should be reviewed unless the emerging evidence base demonstrates that there is a clear surplus of provision or acceptable replacement provision is made on-site or off-site. In this regard, weight should be given to concerns raised by Sport England and the sports governing bodies on the draft playing pitch strategy because if these are not satisfactorily resolved the strategy will not be considered to be sufficiently robust to satisfactorily demonstrate that there is a clear surplus of provision.
The Council will be aware of Sport England's role as a statutory consultee on planning applications affecting playing fields. To avoid potential objections and delays at a later date if this site is allocated for development, it is advised that discussions take place with Sport England before this site allocation is confirmed in the pre-submission version of the local plan. Further advice can be provided on how our concerns could be potentially addressed as well as advice on how to avoid some of the problems experienced by other local authorities who have allocated playing fields for development in their local plans.
No objection is made to the allocation of site references 034 and 235 which comprise other parts of this site allocation.

Object

Draft Local Plan

Policy 9.9: New Development, Extension and Replacement of Buildings in Green Belt

Representation ID: 13210

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

Objection is made to the wording of the second paragraph of the policy as it implies that the principle of small scale facilities required for outdoor/sport recreation needs to be justified because such proposals are considered inappropriate development in the Green Belt. However, as set out in paragraph 89 of the NPPF, appropriate facilities for outdoor sport should be regarded as an exception to the general approach to the construction of new buildings in the Green Belt and are therefore not inappropriate development. Consequently, justification for the principle of such uses should not be required.

Full text:

Objection is made to the wording of the second paragraph of the policy "Proposals for small scale buildings and facilities required for outdoor sport and recreation will need to demonstrate a justifiable need for such buildings and facilities". This wording implies that the principle of small scale facilities required for outdoor/sport recreation needs to be justified because such proposals are considered inappropriate development in the Green Belt. However, as set out in paragraph 89 of the NPPF, appropriate facilities for outdoor sport should be regarded as an exception to the general approach to the construction of new buildings in the Green Belt and are therefore not inappropriate development. Consequently, justification for the principle of such uses should not be required. As an assessment needs to be made by the Council of whether such facilities are 'appropriate' it would be acceptable for a policy to require such proposals to demonstrate a need for the scale of the proposed building but not the principle as implied by the policy wording. It is therefore requested that this part of the policy be deleted or amended to refer to a "justifiable need for the scale for such buildings and facilities"

Object

Draft Local Plan

Policy 10.6: High Quality Design Principles

Representation ID: 13211

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

In view of the importance attached to promoting and enhancing health and well-being in the plan's strategic objectives (SO11), an additional criterion should be added to the policy which expects new developments to promote active lifestyles (through being designed to encourage physical activity and sport) and thereby contribute to the wider health and well-being objective.

Full text:

In view of the importance attached to promoting and enhancing health and well-being in the plan's strategic objectives (SO11), an additional criterion should be added to the policy which expects new developments to promote active lifestyles (through being designed to encourage physical activity and sport) and thereby contribute to the wider health and well-being objective. The supporting text to the policy should refer to Sport England's and Public Health England's Active Design guidance
http://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/active-design/ which provides Government endorsed guidance (that has recently been refreshed) on how the design and layout of new developments can be planned to make communities more active and healthier.

Comment

Draft Local Plan

Policy 10.7: Infrastructure and Community Facilities

Representation ID: 13214

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

Concerns are raised however about how the proposed policy will make provision for community sports facility infrastructure to be provided by new development in practice. This is pertinent because for the majority of developments proposed in the plan, it will only be practical and appropriate to make provision for indoor or outdoor sport through developer contributions being secured towards off-site projects rather than direct on-site provision being made. There are concerns because at present no specific priority sports facility projects have been identified and the conventional standards based approach for outdoor sport is no longer considered robust.

Full text:

The intention to use policy 10.7 to require new developments to meet on and off site infrastructure requirements which would include sports facilities as set out in paragraph 10.40 is welcomed. While no objection is made to the wording of policy 10.7, concerns are raised however about how the proposed policy will make provision for community sports facility infrastructure to be provided by new development in practice. This is pertinent because for the majority of developments proposed in the plan, it will only be practical and appropriate to make provision for indoor or outdoor sport through developer contributions being secured towards off-site projects rather than direct on-site provision being made. In particular, there are the following concerns
* While it is expected that this will be addressed through the Council's emerging evidence base for sport (the Sport and Leisure Study), at present there are no specific sports facility projects identified in the local plan or any published IDP for meeting current or future needs. Unless priority community sports facility infrastructure projects (justified by a robust evidence base) are included in an IDP with appropriate feasibility work undertaken to assess costs and deliverability, it is considered that the scope for using CIL receipts or developer contributions secured through planning obligations towards sports infrastructure will be limited;
* The local plan's current approach (as set out in policy 10.8) to providing for outdoor sports facility needs is focused around meeting conventional quantity standards derived from the current evidence base and it has not been confirmed in the plan how indoor sports facility needs generated by new development will be addressed. In particular, there are no specific priority facility projects identified for meeting current or future needs e.g. new/enhanced leisure centre projects, new playing field/outdoor sports projects etc. This approach would not be consistent with Sport England's current guidance on assessing needs and strategy preparation which is focused around identifying sport specific needs and developing specific proposals to respond to such needs. Our current guidance does not endorse a standards led approach to provision and the NPPF (unlike PPG17 which it replaced) does not specifically advocate the use of standards for providing sports facilities. There are also concerns about the compatibility of the standards approach with the CIL Regulations due to a more forensic approach being taken in practice to the interpretation of Regulation 122 in relation to the tests of the use of planning obligations to secure sports facilities and the pooling limits that are now in place for developer contributions towards sport where planning obligations are still used. Whether sport is secured through CIL (through sports facility projects being identified on the Regulation 123 list) or through developer contributions secured by planning obligations, an up-to-date evidence base with a strategy that includes specific projects is now considered necessary for ensuring that new developments meet the additional needs that they generate for sport. Authorities that continue to rely on standards and securing developer contributions towards generic infrastructure types (such as outdoor sport, indoor sport etc) are now struggling to secure provision in practice due to the constraints imposed by the CIL regulations.

To address the above concerns and to ensure that the approach set out in the policy can deliver with respect to community sports infrastructure, it is requested that the emerging evidence base for sport is used to identify strategic priority projects (in the strategy and action plan documents that evolve from the evidence base) which should then be used for informing what projects will be included in an IDP. Following feasibility work, priority projects included in the IDP should be assessed to determine which will be funded by a future CIL (through inclusion on a CIL Regulation 123 list) and which will be funded by planning obligations (through an approach set out in a complementary Planning Obligations Strategy that is consistent with the CIL regulations and which accounts for the constraints imposed by the pooling restrictions on developer contributions). It should be noted that the inclusion of generic infrastructure types (e.g. sport, leisure, outdoor sport) in CIL Regulation 123 lists or planning obligations strategies is not favoured as this is more likely to preclude developer contributions being secured through planning obligations which is important in the context of the likelihood that CIL will only have a limited ability to fund community sports projects in view of competing infrastructure demands. In practice, it would be preferable for CIL to only include a very small number of identified strategic projects (e.g. one or two new/improved leisure centres) and for planning obligations to be used for securing funding for other identified sports facility projects to maximise the potential for the implementation strategy to provide adequately for sport.

While no changes are sought to the policy itself it is requested that the above advice is considered and followed to ensure that the policy can deliver in practice in relation to community sports infrastructure.

Object

Draft Local Plan

Policy 10.8: Open Space in New Development

Representation ID: 13217

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

While the policy is welcomed in principle but concern is raised about the restrictive approach proposed for the use of commuted sums if applied to outdoor sport and in relation to the use of quantity standards for securing all forms of open space provision including outdoor sport. Suggestions for addressing these concerns are set out in full text.

Full text:

The policy is supported in principle as it is proposed that new development will make open space (including outdoor sports) provision on-site or through developer contributions to meet the additional needs generated. However, I have the following concerns:

* A restrictive approach is taken to the use of commuted sums in broad terms. While this may be appropriate for other open space types, in relation to outdoor sport, with the exception of the proposed Dunton Garden Village proposal, it is considered that it will be unlikely to be practical or appropriate for any of the other housing allocations in the plan to make on-site provision for outdoor sport in view of the large land take required to make playing fields and other outdoor sports facilities fir for purpose and sustainable and the need for supporting ancillary infrastructure. A less restrictive approach towards the use of commuted sums for outdoor sports open space is therefore required.
* Where open space provision in the form of outdoor sports is considered necessary, it would appear that developments will be expected to meet conventional quantity standards derived from the current evidence base. While this may be helpful for the limited occasions where on-site provision is made, this is not appropriate for securing developer contributions. In particular, there are no current specific priority facility projects identified for meeting current or future needs e.g. new/enhanced leisure centre projects, new playing field/outdoor sports projects etc. This approach would not be consistent with Sport England's current guidance on assessing needs and strategy preparation which is focused around identifying sport specific needs and developing specific proposals to respond to such needs. Our current guidance does not endorse a standards led approach to provision and the NPPF (unlike PPG17 which it replaced) does not specifically advocate the use of standards for providing sports facilities. There are also concerns about the compatibility of the standards approach with the CIL Regulations due to a more forensic approach being taken in practice to the interpretation of Regulation 122 in relation to the tests of the use of planning obligations to secure sports facilities and the pooling limits that are now in place for developer contributions towards sport where planning obligations are still used. Whether sport is secured through CIL (through sports facility projects being identified on the Regulation 123 list) or through developer contributions secured by planning obligations, an up-to-date evidence base with a strategy that includes specific projects is now considered necessary for ensuring that new developments meet the additional needs that they generate for sport. Authorities that continue to rely on standards and securing developer contributions towards generic infrastructure types (such as outdoor sport) are now struggling to secure provision in practice due to the constraints imposed by the CIL regulations.
To address these concerns it is first requested that the policy confirms that commuted sums will be acceptable for securing developer contributions towards outdoor sports facilities.
Second, to address the above concerns about the use of standards, it is requested that the emerging evidence base for sport is used to identify strategic priority projects (in the strategy and action plan documents that evolve from the Sport and leisure Study) which should then be used for informing what projects will be included in an IDP. Following feasibility work, priority projects included in the IDP should be assessed to determine which will be funded by a future CIL (through inclusion on a CIL Regulation 123 list) and which will be funded by planning obligations (through an approach set out in a complementary Planning Obligations Strategy that is consistent with the CIL regulations and which accounts for the constraints imposed by the pooling restrictions on developer contributions). It should be noted that the inclusion of generic infrastructure types (e.g. outdoor sport) in CIL Regulation 123 lists or planning obligations strategies is not favoured as this is more likely to preclude developer contributions being secured through planning obligations which is important in the context of the likelihood that CIL will only have a limited ability to fund community sports projects in view of competing infrastructure demands. In practice, it would be preferable for CIL to only include a very small number of identified strategic projects and for planning obligations to be used for securing funding for other identified sports facility projects to maximise the potential for the policy to provide adequately for outdoor sport. The policy and supporting text should provide guidance on how provision for outdoor sport will be secured in practice in the context of this advice and the use of standards should be qualified accordingly.

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