Local Development Framework Consultation

Policy DM1: Expand both the policy and reasoned justification to integrate the 10 key principles of 'Active Design' to create opportunities for physical activity to accord with Section 8 (Promoting Healthy Communities) and Section 7 (Requiring Good Design) of NPPF, and to help implement the objectives in Sport England's Strategy 'Towards an Active Nation'. Active Design can be found on Sport England's webiste and was published in partnership with Public Health England.

Policy DM2: comments as for DM1

Policy DM4: This policy relates to Green Infrastructure and open space, of which outdoor sport and playing fields is a specific typology. The policy makes no reference to outdoor sport and playing field provision, neither is there a seperate policy covering this typology. Housing and employment growth generate additional demand for sport and recreation and the impact of that increased demand must be factored in when assessing planning applications for new development. Sport England strongly suggest creating a new policy that covers all aspects of sport, indoor and outdoor. The Core Strategy policy CS8.3b contains quantity standards for playing pitches which are to be used in conjunction with the accessibility standards contained in policy CS8.3a.

However, there are no accessibility standards for playing pitches within that policy so policy CS8.3b cannot be implemented for playing pitches or any other outdoor sport. A separate development management policy to cover outdoor sport will help bridge that gap. It should be noted that accessibility and quantitative standards are not appropriate for outdoor sport because demand is derived from certain sections of the community and not the population as a whole. A Playing Pitch Strategy will provide evidence of what shortfalls/spare capacity exists and where, and which sites require capacity to be increased to accommodate demand from housing growth. A formula can then be devised to obtain contributions to increase capacity at existing sites or create new. It should be noted that Sport England do not support the creation of single pitch sites within housing developments because they do not contribute to the pitch supply. They often become unusable for matchplay and there use is as informal kick about areas and informal greenspace for other community activities. Any new provision must be capable of providing pitches with supporting ancillary facilities to meet an identified demand from specific clubs/teams. Sport England would be happy to provide guidance and be included in the preparation of a Playing Pitch Strategy and wider Sports Facility Strategy to help inform policy and contributions. Any new sport policy will need to reflect locally the requirements of paragraph 73 and 74 of NPPF.

Physical Activity: Sport England would wish to see higher priority given to Sport and Physical Activity. This DPD should reflect how the development management policies can help promote sport and physical activity as a core theme throughout the Plan in accordance with Section 8 (Promoting Healthy Communities). The Government has also changed their thinking around this area published in the DCMS Strategy "Sporting Future: A New Strategy for an Active Nation". In response to this strategy Sport England has published 'Towards an Active Nation' which sets out how Sport England will work in partnership with a range of organisations, including Local Planning Authorities, to implement the Strategy. Both Strategies can be found on Sport England's website. Sport England and Public Health England has prepared guidance called 'Active Design' which helps planners, developers and suchlike to incorporate key principles into new development which creates physical activity opportunities. Sport England would wish to see these principles embodied into all design policies. The guidance can be found on Sport England's website.

Sport and Recreation policy: see comments for Policy DM4. There is a significant policy gap in relation to sport and physical activity within both the adopted Core Strategy policies and the proposed DPD policies. Given South Lakeland is a very popular destination for sporting activities, given it's proximity to the Lake District and Yorkshire Dales, this policy gap is surprising. Sports clubs contribute tot he economy whether they are grassroots or premier/superleague. Research carried out by Sport England 'Economic Value of Sport' (2013) shows that sport contributed £20.3 billion GVA and was 14th in the Industry Sector League Table ahead of telecoms and architectural and engineering services. There is also a clear link to the health agenda with sport representing £11.2 billion towards health. To provide evidence of the value of sport to South Lakeland, Sport England has produced a tool called 'Economic Value of Sport - Local Model (Updated 2015)'. This can be accessed via the Research page of Sport England's website.

Open Space Sport and Recreation evidence base: the study cited in the evidence base refers to the out of date 2008 Open Space Sport and Recreation Study (EvE08 and EvE08a). 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 prior to submission of this DPD. However, it should be noted that a combined Open Space, Sport 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 sport. Guidance can be found on Sport England's website. It should also be noted that Sport England as statutory consulted on all planning applications that affect playing fields use Playing Pitch Strategies to help assess proposals against the requirements of paragraph 74 of NPPF and Sport England's Playing Fields Policy. Sport England's policy and guide to how we assess planning applications can be found on our website. Sport England are likely to object to any proposal that uses an out of date Needs Assessment to justify any loss of playing field or creation of new where there is no evidence of strategic need. In addition the Needs Assessment should be used to provide a clear direction of what mitigation is required and where in those instances where loss occurs and requires replacement. The Needs Assessment should also be used to provide evidence of additional demand for sport generated by housing growth. The Needs Assessment should then be used to help calculate and obtain developer contributions that can be used to either build in additional capacity at existing facilities or create new provision. It shoud be noted that paragraph 73 of NPPF no longer require local standards to be set because demand for individual sports is specific to certain groups of people and not to the population as a whole. Developer contributions must be related to specific sites. In particular the Playing Pitch Strategy and Indoor/Outdoor Sports Startegy will result in a site specifc action plan that can be used to help calculate appropriate developer contributions.