Greater Cambridge Local Plan: Proposed Submission

Recommended Modification to Address Soundness Concern:
For soundness purposes, Sport England recommends the inclusion of a separate criterion to ensure that any playing field lost to residential or other non-sporting development is appropriately replaced, along the following lines:
“Where residential or other non-sporting development would result in the loss of playing field, replacement playing field provision shall be provided which is of equivalent or better quantity and quality, in a suitable location which offers comparable or improved accessibility for the community it serves.”
Other Recommended Modifications Proposed:
Sport England recommends that “playing fields” is expressly included within criterion 3 as follows:
“Any loss of Protected Open Space and playing fields to new sporting provision only will need to be outweighed by the enhancement of open space through the provision of a sports hall, sports pitches and a MUGA.”
Sport England also recommends the inclusion of an additional criterion within Policy S/C/NCA along the following lines:
“Development proposals shall be accompanied by an appropriate phasing plan to ensure, where possible, that replacement playing field and associated sports facilities are available for use before development takes place that would result in existing playing field or sports facilities becoming unavailable for sporting use. Where this is not possible, suitable alternative or transitional provision shall be secured for affected sporting users to maintain continuity of sporting activity until the replacement provision is available for use.”

Policy S/C/NCA: North Cambridge Academy, 108, Arbury Road
Sport England's Representation: Soundness Concerns - Recommend Modification
Sport England welcomes the policy requirements for the expansion of the existing sports hall, provision of a new all-weather pitch, four tennis courts and a Multi-Use Games Area (MUGA), together with a Community Use Agreement to secure public access to the sports facilities outside school hours, subject to the benefits of the proposed alternative sports provision clearly outweighing the loss of any existing playing field or other sporting facility resulting from its provision.
Sport England also welcomes the requirement that any loss of Protected Open Space should be outweighed by enhancements to sports and open space provision. However, Sport England recommends that explicit reference is also made to playing fields and that is it clear this criteria applies to sport provision proposed only, to ensure that the policy appropriately addresses any loss of playing field arising from the the sport provision proposed only, not the housing element.
Additionally, Sport England considers that the policy should explicitly address the potential loss of playing field arising from the residential element of the allocation. Where residential development would result in the loss of playing field, such development would not constitute alternative sports and recreational provision. In the absence of an appropriate requirement for replacement provision, Sport England considers that the policy is not consistent with national policy, giving rise to a soundness concern. The Playing Pitch Strategy also identifies deficits in playing field provision and does not demonstrate a surplus of playing field provision in Cambridge that could justify such a loss without appropriate mitigation.
Sport England therefore considers that, without an explicit requirement for appropriate replacement provision, the policy does not provide sufficient certainty that any loss of playing field arising from residential or other non-sporting development would be appropriately mitigated.
Accordingly, to ensure the policy is sound and consistent with national policy, it should explicitly require that any playing field lost to residential or other non-sporting development is replaced by equivalent or better provision in terms of quantity and quality, in a suitable location which offers comparable or improved accessibility for the community it serves.
Sport England also considers that the policy should address the phasing of development to maintain continuity of sporting use. Where possible, replacement playing field and associated sports facilities should be available for use before development takes place that would make existing provision unavailable. Where this cannot reasonably be achieved, suitable alternative or transitional provision should be identified and made available to affected users.
Sport England considers that all reasonable steps should therefore be taken to secure suitable transitional arrangements, acceptable to the affected sporting users, where construction or development phasing would otherwise disrupt existing sporting activity.
Recommended Modification to Address Soundness Concern:
For soundness purposes, Sport England recommends the inclusion of a separate criterion to ensure that any playing field lost to residential or other non-sporting development is appropriately replaced, along the following lines:
“Where residential or other non-sporting development would result in the loss of playing field, replacement playing field provision shall be provided which is of equivalent or better quantity and quality, in a suitable location which offers comparable or improved accessibility for the community it serves.”
Other Recommended Modifications Proposed:
Sport England recommends that “playing fields” is expressly included within criterion 3 as follows:
“Any loss of Protected Open Space and playing fields as a result of new sporting provision will need to be outweighed by the enhancement of open space through the provision of a sports hall, sports pitches and a MUGA.”
Sport England also recommends the inclusion of an additional criterion within Policy S/C/NCA along the following lines:
“Development proposals shall be accompanied by an appropriate phasing plan to ensure, where possible, that replacement playing field and associated sports facilities are available for use before development takes place that would result in existing playing field or sports facilities becoming unavailable for sporting use. Where this is not possible, suitable alternative or transitional provision shall be secured for affected sporting users to maintain continuity of sporting activity until the replacement provision is available for use.”
Reason
The modifications are necessary to ensure that the policy expressly addresses playing fields and distinguishes between the enhancement of sports provision, appropriate replacement of playing field lost to residential or other non-sporting development, and the continuity of sporting use during redevelopment.
The requirement for replacement provision is necessary for soundness purposes to ensure that any playing field lost to residential or other non-sporting development is appropriately mitigated through replacement provision, rather than being treated as having been addressed solely through qualitative enhancements to other sports facilities.
Appropriate phasing should also ensure, where possible, that replacement provision is available before existing playing fields or sports facilities become unavailable. Where this cannot reasonably be achieved, suitable alternative or transitional arrangements should be secured to minimise disruption to existing sporting users until the replacement provision is available.
These modifications would provide greater certainty that redevelopment of the site would not result in an inadequately mitigated loss of playing field or an unacceptable interruption to sporting activity or displacement of existing users.

Sport England's Representation: Recommend Modification
Sport England notes that the policy requires re-provision of the bowls club; and re-provision of the Multi-Use Games Area.
Recommended Modification
Replace/revise criteria f as follows: "Re-provision on-site or within the immediate local area of the existing bowls club and multi-use games area of an equal or enhanced quality
Reason: The term “quality” provides greater clarity than “standard” and makes explicit that replacement provision must be of an equivalent or better quality than the provision being lost.

Sport England welcomes the supporting text requirement that the design of the proposed football facilities should meet the relevant standards of the Football Foundation and Cambridgeshire Football Association. This will help to ensure that the proposed facilities are appropriately designed and capable of meeting the needs of football.

Sport England recommends that the policy is modified to explicitly acknowledge the loss of playing field and identify how that loss will be appropriately addressed through replacement or other mitigation, informed by the identified needs within the Playing Pitch Strategy.

Sport England is aware that planning permission 22/01623/FUL has been granted and that development is underway. Sport England also notes that the Orchard Park Design Guidance SPD, adopted in March 2011, provided the planning and design framework for the remaining development parcels at Orchard Park and identified the playing field to remain as public open space.

Sport England nevertheless wishes to highlight that, prior to approving the loss of the playing field, the implications of that loss should have been appropriately assessed having regard to national planning policy and the identified needs for playing field provision. Where the playing field was not demonstrated to be surplus to requirements, appropriate replacement provision or other mitigation should have been considered and secured before its loss.

Given that the development is now underway, Sport England recognises that the Local Plan cannot retrospectively alter the planning permission. However, the loss of the playing field should be recognised when considering the current and future supply of playing field provision and the actions necessary to address identified needs through the Playing Pitch Strategy and its Strategy and Action Plan.

Sport England notes that planning permission 23/04687/FUL has been granted for redevelopment of the site. The permission includes replacement sports provision to mitigate the sporting facilities affected by the redevelopment. Reference to the planning permission demonstrates that the loss of the existing sporting provision has been assessed against national policy and that replacement mitigation has been secured.

Recommended Modification

Sport England recommends that criterion 3 is deleted.

Reason

The modification is necessary for soundness purposes to ensure that demonstrable educational need is not established through the Local Plan as a separate exception to the protection afforded to existing open space, playing fields and other sports and recreational provision under national policy.

Sport England considers that proposals for educational development affecting existing open space should instead be considered against the wider requirements of Policy BG/PO and the relevant national policy tests applicable at the time a development proposal is determined.

This is also important for the effectiveness of the Local Plan over its lifetime. While the Local Plan is being progressed under the transitional plan-making arrangements, future planning applications will be determined having regard to the national policy framework applicable at the time of determination. The current NPPF Policy HC7 expressly addresses development affecting existing recreational land and facilities, including development for public service infrastructure.

Subject to the deletion of criterion 3, Sport England supports the overall approach of Policy BG/PO.

Sport England supports the overall approach of Policy BG/PO to the protection of existing open space. In particular, Sport England welcomes the requirement that, where existing open space is to be replaced, replacement provision should be equivalent or better in terms of quality, quantity and accessibility.

Sport England also welcomes the requirement that, where replacement open space is provided in an alternative location, it should be fully available for use before the area of open space to be lost is redeveloped. This provides important certainty regarding continuity of provision.

However, Sport England raises a specific soundness concern regarding criterion 3, which states:

“In the case of school, college and university grounds, development may be permitted on existing open space where it meets a demonstrable educational need and does not adversely affect playing fields or other formal sports provision on the site.”

Sport England welcomes the explicit protection afforded to playing fields and other formal sports provision within criterion 3. However, Sport England is concerned that demonstrable educational need could be interpreted as providing a separate exception for development on existing open space which does not reflect the relevant tests within national policy.

Sport England recognises that educational development may constitute public service infrastructure. It is also relevant that the current NPPF Policy HC7 provides that where development for public service infrastructure results in the loss of existing open space, sports or recreational land or facilities, the resulting loss should be replaced by equivalent or better provision in terms of quantity and/or quality.

Sport England therefore considers that educational need should not, in itself, provide justification for the loss of existing open space without appropriate consideration of the requirements of national policy.

This is particularly important given that the Playing Pitch Strategy identifies deficits in playing field provision and does not demonstrate a surplus of playing field provision that could otherwise justify the loss of such provision.

Recommended Modification

Sport England recommends that criterion 3 is deleted.

Reason

The modification is necessary for soundness purposes to ensure that demonstrable educational need is not established through the Local Plan as a separate exception to the protection afforded to existing open space, playing fields and other sports and recreational provision under national policy.

Sport England considers that proposals for educational development affecting existing open space should instead be considered against the wider requirements of Policy BG/PO and the relevant national policy tests applicable at the time a development proposal is determined.

This is also important for the effectiveness of the Local Plan over its lifetime. While the Local Plan is being progressed under the transitional plan-making arrangements, future planning applications will be determined having regard to the national policy framework applicable at the time of determination. The current NPPF Policy HC7 expressly addresses development affecting existing recreational land and facilities, including development for public service infrastructure.

Subject to the deletion of criterion 3, Sport England supports the overall approach of Policy BG/PO.

Recommended Modification

Sport England recommends that a separate “Playing Fields” heading is incorporated within Policy BG/EO to distinguish the assessment of playing field requirements from the general Accessible Green and Open Space Standards.

Suggested wording:

Playing Fields

Development should address the playing field needs it generates. The scale, type and location of provision required should be informed by the most up-to-date Playing Pitch Strategy and, where appropriate, Sport England's Playing Pitch Calculator and relevant National Governing Body requirements.

Where playing field needs cannot appropriately be met through on-site provision, appropriate off-site provision and/or financial contributions should be secured towards relevant projects identified within the Playing Pitch Strategy and Action Plan, having regard to the sporting needs generated by the development and its location.

Reason

The modification would provide greater clarity as to how playing field requirements generated by new development should be assessed and delivered. It would ensure that playing field requirements are informed by the local sporting evidence base rather than relying solely upon generic open space standards, and that any off-site contributions are appropriately directed towards projects that address identified playing pitch needs.

Sport England supports the overall principle of Policy BG/EO that new development should address the open space needs it generates through an appropriate combination of on-site provision and/or financial contributions towards off-site provision, enhancement and management.

However, Sport England recommends that playing field provision is addressed separately from the general Accessible Green and Open Space Standards within Policy BG/EO.

While playing fields form part of the wider network of open space and green infrastructure, Sport England does not advocate the use of generic open space standards as the principal means of determining the quantity or type of playing pitch provision required to meet the needs generated by new development. Playing fields have specific sporting functions and requirements, and provision should be informed by a robust and up-to-date assessment of local sporting need. This accords with Sport England's planning principles, which advocate undertaking, maintaining and applying robust and up-to-date assessments of need and strategies for sport and physical activity provision.

For playing pitch provision, Sport England considers that the Playing Pitch Strategy (PPS) should provide the principal evidence base for identifying existing and future needs. Sport England's PPS guidance provides a methodology for understanding and assessing playing pitch needs and developing an appropriate strategy for provision.

Where new residential development generates additional playing pitch demand, the PPS should be used alongside Sport England's Playing Pitch Calculator (PPC). The PPC is specifically designed to help estimate the demand for playing pitches generated by an additional population and uses locally derived information from the assessment of playing pitch need. This enables development-generated demand to be considered in the context of local supply and demand rather than relying solely upon a generic hectares-per-population standard.

Additionally, where provision cannot appropriately be made on-site, Sport England considers that off-site financial contributions towards playing field provision should be directed towards appropriate projects identified within the PPS Strategy and Action Plan that are relevant to the sporting needs generated by the development and its location. This would provide a clear relationship between development-generated demand, the local evidence base and delivery of the provision or improvements required to meet that demand.

Recommended Modification

Sport England recommends that a separate “Playing Fields” heading is incorporated within Policy BG/EO to distinguish the assessment of playing field requirements from the general Accessible Green and Open Space Standards.

Suggested wording:

Playing Fields

Development should address the playing field needs it generates. The scale, type and location of provision required should be informed by the most up-to-date Playing Pitch Strategy and, where appropriate, Sport England's Playing Pitch Calculator and relevant National Governing Body requirements.

Where playing field needs cannot appropriately be met through on-site provision, appropriate off-site provision and/or financial contributions should be secured towards relevant projects identified within the Playing Pitch Strategy and Action Plan, having regard to the sporting needs generated by the development and its location.

Reason

The modification would provide greater clarity as to how playing field requirements generated by new development should be assessed and delivered. It would ensure that playing field requirements are informed by the local sporting evidence base rather than relying solely upon generic open space standards, and that any off-site contributions are appropriately directed towards projects that address identified playing pitch needs.

Recommend the following modification

“Residential development must contribute towards both indoor and outdoor sports facilities, including ancillary provision such as changing facilities, appropriate to the scale and location of the development and the needs generated by it, informed by the Indoor Sports Facility Strategy, Playing Pitch Strategy and Outdoor Courts and Rinks Strategy, or successor documents. Where justified, provision can be made off-site through financial contributions towards publicly accessible provision which addresses the identified sporting needs generated by the development.”

Sport England supports criterion 7 and particularly welcomes the requirement for residential development to contribute towards both indoor and outdoor sports facilities, including necessary ancillary facilities, with requirements informed by the Indoor Sports Facility Strategy, Playing Pitch Strategy and Outdoor Courts and Rinks Strategy.

This approach is consistent with Sport England's guidance, which advocates the preparation and use of robust assessments of need to inform planning for indoor and outdoor sports facilities and playing pitches.

Sport England also supports the ability, where justified, for requirements to be met through appropriate off-site financial contributions towards publicly accessible provision. However, it is important that the scale and nature of contributions are directly related to the sporting needs generated by development and informed by the relevant sports evidence base.

For playing pitches, the Playing Pitch Strategy should provide the principal evidence base, supplemented by Sport England's Playing Pitch Calculator where appropriate, rather than applying generic open-space standards.

Recommend the following modification

“Residential development must contribute towards both indoor and outdoor sports facilities, including ancillary provision such as changing facilities, appropriate to the scale and location of the development and the needs generated by it, informed by the Indoor Sports Facility Strategy, Playing Pitch Strategy and Outdoor Courts and Rinks Strategy, or successor documents. Where justified, provision can be made off-site through financial contributions towards publicly accessible provision which addresses the identified sporting needs generated by the development.”

Recommended Modification to Address the Soundness Concern

Sport England recommends that criterion 5(a) is amended to make clear that it does not provide an additional exception for the loss of playing fields or other sports and recreational land.

If the Council does not intend criteria 4 to 6 to establish alternative tests for the loss of playing fields, Sport England recommends that this is made explicit within the policy or supporting text.

Suggested additional wording:

“For the avoidance of doubt, criteria 4 to 6 do not establish alternative tests for the loss of playing fields or other sports and recreational land. Proposals which would result in the loss of such provision will also be required to satisfy the relevant requirements of local and national policy and should be informed by the relevant up-to-date sports evidence base, including the Playing Pitch Strategy where applicable.”

Sport England further recommends clarification that:

“Where a school or educational site includes playing fields, demonstration that the site is no longer required for educational purposes does not, in itself, demonstrate that the playing field, including ancillary sporting provision, is surplus to requirements.”

Reason

The modifications are necessary for soundness purposes to ensure that Policy WS/CF does not establish alternative or broader tests for the loss of playing fields and other sports and recreational provision than those provided for through national policy.

They would also provide certainty that the loss of playing fields is subject to the relevant national policy tests; replacement sports provision is equivalent or better in appropriate terms; any conclusion that sports provision is surplus is supported by robust and up-to-date evidence of sporting need; and playing fields on education sites are not regarded as surplus to sporting requirements solely because they are no longer required for educational purposes.

Subject to satisfactory modification or clarification of these matters, Sport England supports the overall approach of Policy WS/CF.s when considering the loss or replacement of indoor sports facilities.

Sport England supports the overall approach of Policy WS/CF to the protection, enhancement and provision of community, sports and leisure facilities.

Sport England particularly welcomes the requirements for new or enhanced facilities to respond to identified local need, improve the range, quality and accessibility of provision, and facilitate wider community access through measures such as Community Use Agreements.

Sport England also supports the supporting text requiring proposals involving the loss or replacement of indoor sports facilities to have regard to Sport England's strategic planning tools, including the Facilities Planning Model (FPM) and Active Places Power, when assessing the impact of any proposed loss. The FPM is specifically intended to assist in assessing strategic provision and can test the impacts of closing, relocating or providing facilities, while Active Places Power supports evidence-based facility planning and investment decisions.

Sport England also welcomes the requirement for replacement leisure facilities to comply with relevant sports design guidance and avoid any net reduction in leisure facility provision. However, outputs from strategic planning tools should be considered alongside the relevant up-to-date needs assessment and facility strategy and should not be relied upon in isolation. Sport England's guidance specifically advises that FPM outputs should form part of an overall assessment incorporating local context, knowledge and data. Wording to this affect should be included.

Protection of Existing Sports Provision

Notwithstanding this overall support, Sport England raises a soundness concern regarding the application of criteria 4 to 6 to playing fields and other sports and recreational provision, with particular concern regarding criterion 5(a).

Criterion 4 provides that development will be refused where the loss of a facility would cause an “unacceptable reduction in the range, quality and accessibility of facilities or services in the locality”. While this may provide an appropriate test for community and leisure facilities generally, Sport England considers that it should not be interpreted as establishing an alternative test for the loss of playing fields or other sports and recreational land, which are subject to specific national policy requirements.

Sport England's principal concern relates to criterion 5(a), which permits loss where:

“The proposal would deliver community, sports or leisure facilities or services of sufficient benefit to outweigh the loss.”

As drafted, this could be interpreted as permitting the loss of a playing field or other sports and recreational provision where the benefits of a different community, sports or leisure facility are considered sufficient to outweigh that loss.

This is broader than the approach within national policy. National policy provides a specific exception where development is for alternative open space, sports and recreational buildings and land and the benefits clearly outweigh the loss, rather than applying a general balancing test involving any community or leisure use.

Sport England therefore considers that criterion 5(a), if applied to playing fields and other sports and recreational land, could establish a broader local exception than provided for in national policy, giving rise to a soundness concern regarding consistency with national policy.

Sport England is also generally supportive of criterion 5(b), which provides for replacement facilities. However, where the provision affected is a playing field or other sports facility, replacement should be equivalent or better in terms of quantity and quality and in a location offering comparable or improved accessibility for the community it serves, consistent with the national policy approach.

Sport England also supports the principle of criterion 5(c). However, where playing fields or sports facilities are concerned, any conclusion that there is an excess of provision should be supported by a robust and up-to-date assessment of sporting need, including the Playing Pitch Strategy or other relevant sports facility evidence. National policy similarly provides an exception where an assessment has clearly demonstrated that provision is surplus to requirements.

With regard to criterion 6, Sport England considers that the fact that a school site or educational facility is no longer required for educational purposes should not, in itself, demonstrate that any playing field forming part of that site is surplus to sporting requirements. The need for the sports provision should be considered separately against relevant national policy and the up-to-date sports evidence base.

This clarification is particularly important given the broad scope of Policy WS/CF, which applies to community, sports and leisure facilities.

Recommended Modification to Address the Soundness Concern

Sport England recommends that criterion 5(a) is amended to make clear that it does not provide an additional exception for the loss of playing fields or other sports and recreational land.

If the Council does not intend criteria 4 to 6 to establish alternative tests for the loss of playing fields, Sport England recommends that this is made explicit within the policy or supporting text.

Suggested additional wording:

“For the avoidance of doubt, criteria 4 to 6 do not establish alternative tests for the loss of playing fields or other sports and recreational land. Proposals which would result in the loss of such provision will also be required to satisfy the relevant requirements of local and national policy and should be informed by the relevant up-to-date sports evidence base, including the Playing Pitch Strategy where applicable.”

Sport England further recommends clarification that:

“Where a school or educational site includes playing fields, demonstration that the site is no longer required for educational purposes does not, in itself, demonstrate that the playing field, including ancillary sporting provision, is surplus to requirements.”

Reason

The modifications are necessary for soundness purposes to ensure that Policy WS/CF does not establish alternative or broader tests for the loss of playing fields and other sports and recreational provision than those provided for through national policy.

They would also provide certainty that the loss of playing fields is subject to the relevant national policy tests; replacement sports provision is equivalent or better in appropriate terms; any conclusion that sports provision is surplus is supported by robust and up-to-date evidence of sporting need; and playing fields on education sites are not regarded as surplus to sporting requirements solely because they are no longer required for educational purposes.

Subject to satisfactory modification or clarification of these matters, Sport England supports the overall approach of Policy WS/CF.s when considering the loss or replacement of indoor sports facilities.

Sport England objects to the inclusion of, and reliance upon, the PPS in its current form as part of the evidence base supporting the Local Plan.

Sport England is currently unable to sign off the PPS as it does not yet provide a sufficiently robust and deliverable Strategy and Action Plan capable of providing a reliable basis for Local Plan policy, infrastructure planning and development management decisions.

The principal concerns are:

• Unresolved evidence and modelling issues, including inconsistencies in population and dwelling assumptions, headline provision requirements and 3G AGP figures, together with modelling assumptions that have not been sufficiently explained, reconciled or locally validated.
• Insufficient progression from assessment to strategy, with the PPS containing substantial Stage C analysis and scenario testing but lacking a sufficiently clear Stage D strategic framework identifying what provision is required, where it should be located, how it will be delivered and when.
• Reliance on unsecured provision, particularly education, university and college sites. Provision at education, university and college sites should not be relied upon as meeting identified community needs unless the necessary community access is demonstrated to be deliverable and capable of being secured for an appropriate period.
• Failure to adequately address peak-time capacity deficits. The PPS itself identifies that pitch quality improvements may increase overall weekly capacity without creating additional capacity at the times when demand occurs. Such enhancements therefore cannot, on their own, be relied upon to address identified peak-time shortfalls.
• A disconnect between the evidence and proposed interventions, with pitch improvements and securing community use continuing to be promoted as principal responses to demand in circumstances where the PPS's own analysis indicates that these measures would not necessarily provide the additional capacity required.
• Insufficient spatial and delivery detail, including a lack of clear, prioritised and measurable interventions linked to identified deficits, defined delivery responsibilities, timescales, funding and development phasing.
• An inadequate delivery and monitoring framework. The main Strategy does not contain a sufficiently clear summary action plan identifying priority projects, delivery partners, timescales and measurable outcomes, and monitoring arrangements require clearer indicators and review mechanisms.
• Unresolved sport and site-specific matters, including the proposed approach to the loss of cricket provision at Storey's Field, Eddington, which Sport England does not support; the need to protect existing rugby provision where deficits have been identified; and the extent to which future provision associated with strategic growth locations is evidenced and deliverable.
• Insufficient consideration of ancillary provision, including changing and supporting facilities necessary to ensure that pitch provision is genuinely usable and capable of supporting inclusive participation.
• Outstanding National Governing Bodies of Sport sign-off, which Sport England requires before it can provide final sign-off to the Strategy and Action Plan.

Taken collectively, these matters mean that the PPS does not currently provide a sufficiently clear and robust relationship between identified need, spatial provision, mitigation and delivery to support the Local Plan's approach to playing pitch provision. In particular, there is a risk that identified playing pitch deficits could be assumed to have been addressed through qualitative improvements or unsecured community access where these measures do not provide the additional peak time capacity required.

Sport England therefore considers that, until these matters are satisfactorily resolved, the Local Plan has not demonstrated that its approach to meeting playing pitch needs and mitigating the impacts arising from planned growth is justified or effective.

Consequently, Sport England has concerns regarding the robustness of the evidence base underpinning the Local Plan's approach to playing pitch provision and the ability of the Plan to ensure that the sporting needs arising from planned growth will be appropriately addressed over the Plan period.

Sport England recommends that the PPS is revised and completed to address the detailed comments raised by Sport England and the relevant National Governing Bodies of Sport.

In particular, the final PPS should include a robust Strategy and Action Plan that clearly translates the findings of the assessment into identified, prioritised and deliverable actions. This should demonstrate what provision is required, where it is required, how identified deficits will be addressed, and how and when the necessary interventions will be delivered.

Where provision at education, university or college sites is relied upon to meet identified community needs, the PPS should demonstrate that the necessary community access is deliverable and capable of being appropriately secured.

The updated Strategy and Action Plan should be subject to further consultation with Sport England and the relevant National Governing Bodies, with outstanding matters satisfactorily addressed before the PPS is finalised and relied upon as part of the Local Plan evidence base.

Until Sport England's outstanding comments have been satisfactorily addressed, Sport England does not consider that the PPS provides a sufficiently robust basis for identifying and planning for future playing pitch requirements or demonstrating that the impacts of planned growth on playing pitch provision can be appropriately mitigated.
Sport England's objection can therefore be overcome through the satisfactory amendment and completion of the PPS and its Strategy and Action Plan, including resolution of the outstanding matters raised by Sport England and the relevant National Governing Bodies of Sport.