Response from Ms Fiona Pudge, Sport England
1. Ms Fiona Pudge, Sport England : 5 Jan 2016 13:02:00
Please make your comments below on the Policy Area / Topic you have selected. Where appropriate, make reference to the Option you prefer and the question number referred to in the Discussion Paper.
Green Infrastructure and Open Space
Qu 51: Which option do you think is appropriate?
Paragraphs 73 and 74 of NPPF place a slightly different requirement on Council’s than the previous PPG17 guidance on which the saved policies are based. For this reason Option 2 is the most appropriate.
Qu 52: If a new policy is needed should it be informed by a new Open Space and Recreation Study?
Yes – the Council do not have an up to date and robust Needs Assessment as required by paragraph 73 of the NPPF. As the Needs Assessment is required to help inform the preparation of policy the Needs Assessment should be undertaken at this stage. However, a combined Open Spaces, Sports and Recreation Study is not appropriate for playing pitches. The assessment of playing pitches requires a completely different methodology to that used by other open space typologies. There is also a separate methodology for non-pitch outdoor sports. Guidance can be found on our website and is referenced in the Planning Practice Guidance:
Playing Pitch Strategy Guidance: http://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/playing-pitch-strategy-guidance/
Non pitch outdoor/indoor sport guidance: http://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/assessing-needs-and-opportunities-guidance/
Qu 53: Whichever option is chosen, should the policy position be supported by a Green Infrastructure Supplementary Planning Document?
Yes – paragraph 74 of NPPF no longer requires local standards to be set because developer contributions must be related to specific sites. In particular the Playing Pitch Strategy and Indoor/Outdoor Sports will result in a site specific action plan that can be used to help develop appropriate developer contributions. The action plans will be updated annually which means any developer contribution formula and process can contained within the SPD can be more easily amended to reflect actual needs than if it was embodied in a Local Plan policy.
The evidence base is likely to take 12 months to complete so any SPD could not be prepared at this stage.
Community Facilities
Qu 56: Which option do you think is appropriate?
Paragraphs 73 and 74 of NPPF include buildings used for sport and recreation purposes fall within the definition of community facilities. NPPF place a slightly different requirement on Council’s than the previous PPG17 guidance on which the saved policies are based. For this reason Option 2 is the most appropriate.
Qu 57: If a new policy is needed should it:
(a) be applied district-wide, certain areas only?
(b) be applied to all community facilities, certain types only?
(c) be applied to proposals for residential use only? or all non-community use development?
(b) apply to all community facilities because many buildings have a multi function which may include sport and recreation – the Council do not have an up to date and robust Needs Assessment as required by paragraph 73 of the NPPF. As the Needs Assessment is required to help inform the preparation of policy the Needs Assessment should be undertaken at this stage.
I hope these comments are helpful but if you have any queries please contact the undersigned.
Fiona Pudge BA (Hons) BTP MRTPI
Planning Manager
