No

ID sylw: 107374

Derbyniwyd: 07/03/2025

Ymatebydd: Sport England

Sport England notes the inclusion of sports venues within the policy and consider that this should instead be covered within the remit of a revised Policy 44 Outdoor Sports and Leisure.
This is on the basis of Policy 44 replicating in part NPPF paragraph 104 with national policy referring to sports and recreational buildings, which covers sports venues. An example of this is Coventry Stadium Appeal Ref: APP/E3715/W/23/3322013 with the Inspector assessing the proposed loss of the site for residential development and sports provision against NPPF paragraph 103 (now 104). At the appeal it was agreed that viability did not form part of any consideration as to whether the proposal would meet NPPF paragraph 103.

No

ID sylw: 107375

Derbyniwyd: 07/03/2025

Ymatebydd: Sport England

Sport England notes that the infrastructure delivery plan (IDP) will be updated as new evidence base documents are completed such as the Playing Pitch and Outdoor Strategy (PPOSS), which is welcomed. The infrastructure plan though should have a site-specific focus particularly if any new settlements are proposed or large scale developments to ensure that sports provision is accessible to the local community by active travel links.
It is noted IDP refers to the six acre standards for playing pitch provision, Sport England considers that a standards approach does not take account of existing provision and the way sports is played within an area. Instead Sport England would advocate the use of Sport England’s Playing Pitch Calculator tool which is already utilised by Warwick District Council. The tool takes account of the population profile of the development and propensity of different age groups to participate in sport based on existing activity. An up to date PPOSS is required to use the tool and the findings of the document will help to inform if new on site provision would be required or enhancements to existing sites. Sport England are happy to discuss the use of the tool and how it can be utilised to inform site allocations and the IDP.

Sport England notes that there is no reference to indoor sports provision within the IDP. As previously commented a Buit Facilities Strategy (Indoor Sports Strategy) should be undertaken for the Plan in line with NPPF paragraph 103 and the finding of the document should be incorporated within the IDP. Again, Sport England’s Sports Facility Calculator, which has been utilised by both Council’s, should be utilised to inform the requirements for specific site allocations and the IDP.

No

ID sylw: 107376

Derbyniwyd: 07/03/2025

Ymatebydd: Sport England

Sport England supports the principal of Policy 44 though consider the wording of the policy should be more aligned to National Planning Policy Framework paragraph 104.
For example, the first exception for when a site can be developed is that there is no need or demand for the existing community, sport and leisure uses and land formerly used as such and adequate alternative provision is available to meet the needs of the area.
Sport England consider that the policy/the policy justification should state that to demonstrate compliance with this exception, an assessment should be undertaken which clearly shows the open space, buildings or land to be surplus to requirements. As part of this consideration should be given to current and future demand for the sports provision and the capacity of existing alternative provision to meet demand in the area. Consideration of the need of the site should also not be focused on the existing or previous pitch sport use, with the assessment covering all potential sports and leisure usage of the site. Sport England also consider that the word community should be removed from the policy as there are a number of planning appeals which state NPPF paragraph 104 applies to both community accessible and private sites (even when they are not accessible to the community). Sport England can provide the relevant appeals to the Council should this be of assistance.



In relation to the second exception of equivalent or better replacement facilities are secured on or off site that are equally accessible to the community. The wording of this policy appears to facilitate enabling development i.e. development of part of a playing field site and improvement to the remaining site which is not supported by Sport England. The reasoning for this is that it would not have been demonstrated that the playing field land proposed to be lost is surplus to requirement (to meet current and future demand). Sport England consider that policy wording should be altered to state the provision to be lost would be replaced by equivalent or better provision in terms of quantity and quality that is equally accessible to the community.

Sport England also consider the scope of the policy should extend to built sport facilities and venues, in line with NPPF paragraph 104.

Other

ID sylw: 107378

Derbyniwyd: 07/03/2025

Ymatebydd: Sport England

Sport England note the identification of strategic growth location/proposed new settlements. Some of these sites include sports provisions (indoor and outdoor) which should be protected and enhanced/where possible extended to help meet the sporting demand generated from the new development. Should sites proposed to be lost then replacement provision should be secured and made available for use prior to the loss, this should be a key requirement within any site allocation policies.

Sport England also consider that as site allocations are firmed up that consideration should be had to the allocation of sites for sport. This would help set out a strategic identification of how the needs of community will be met and not defer matters to the planning application stage. This would be aligned with NPPF paragraph 102.