Support is offered for including a strategic objective (SO18) 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 (SO19) relating to delivering essential infrastructure including recreation and 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.

Sport England objects to the potential allocation of Land at Priests Lane, Shenfield (site 044/178) for residential development in the local plan as currently proposed.

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 site allocation opportunities and constraints do not make any reference to a 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. 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 may 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 policy requirements set out in the allocation, it has to be 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 fields 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. It is noted that the 2016 local plan consultation made reference to the allocation including provision of open space and/or sport facilities for public use. The omission of such a reference in the current consultation is of concern in the context of the need to protect or replace the playing fields.

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 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 '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 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 paragraph 74 of 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.

While Sport England's focus is on protecting playing fields for meeting community needs, it should also be demonstrated that the playing fields are no longer required for meeting the current or future needs of the Brentwood Ursuline School that last used it.
While the protection of site and the removal of the proposed allocation 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. It would be inappropriate at this stage to be prescriptive on the nature of replacement provision as the Council's new Playing Pitch Strategy is currently being prepared which will be assessing current and future playing pitch needs in the area. Until this is completed, it will not be clear whether it would be suitable to protect the site and seek to reinstate it to community use, replace it with a new playing field on another site or seek financial contributions in lieu of replacement provision towards priority projects that will address community needs.

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 informed by the Council's Playing Pitch Strategy.

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.

Sport England made detailed representations in the 2015 consultation on this proposal. In summary, the allocation policy for the site will need to address the following matters:

* Provision will need to be made for retaining or replacing the Dunton Hills Golf Centre unless it can be satisfactorily demonstrated that it is surplus to requirements through a golf course needs assessment. Without this, any site allocation would be contrary to current Government policy in paragraph 74 of the NPPF. Due to the size of the golf centre and the potential impact that its retention/replacement would have on the delivery of the development it is advocated that a needs assessment is undertaken as part of the masterplanning stage;
* The Council's emerging evidence base for sport (Playing Pitch Strategy and Built Facilities Strategy) should be used (together with the Basildon Borough Council's emerging 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. The site allocation policy should require the development to make provision for community sports facilities in accordance with local plan policies and the evidence base.
* Sport England & Public Health England's Active Design guidance should be used for guiding the masterplanning of the development in order to create environments which promote active lifestyles 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 allocation policy in order to provide a framework for the subsequent masterplan.